ML20198D170
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Allegation Category: QA/QC 2, Document Control 2.
Allegation Number: AQH-1 and AQW-13 3.
Characterization:
It is alleged that construction and inspection records related to some pipe hangers were being separately maintained, resulting in their final QA/QC review being inadequate.
It is also alleged that weld data cards (WDCs) were changed or destroyed.
4.
Assessment of Safety Significance:
Since the alleger provided no specific hanger or package numbers when making this allegation, the NRC Technical Review Team (TRT) used a generic approach to assess this allegation.
The'TRT reviewed the procedures used to fabricate, install, and inspect pipe supports (hangers) and evaluated them for compliance.with require-ments in the ASME Code, 10 CFR Part 50, Appendix B, and ANSI N45.2. The TRT reviewed both the procedures that were in force during the spring of 1980 (the period covered by the allegations) and the current revisions of the procedures and found them to be acceptable (reference 4).
The TRT interviewed the Brown & Root (B&R) and Texas Utilities Electric Company (TVEC) personnel responsible for hanger packages to determine the 4
reason for initiating a change in the method of maintaining documentation for the construction and inspection of hangers in 1980. These interviews 4
disclosed that, prior to April 1980, quality control (QC) was responsible for all inprocess weld inspection activities. B&R deurmined, based on an evaluation of the ASME Code requirements, that craft personnel should perform certain inspection operations for predetermined welds. These operations included visual surveillance checks of cleanliness, preheat temperatures, and the fitup of hangers.
QC personnel were to monitor
-the craft activities to ensure compiiance with procedures and ASME Code requirements.
The TRT learned that motivating factors for this change were financial considerations and the efficient allocation of QC manpower.
Prior to instituting this change in inspection philosophy, B&R contacted the authorized nuclear inspector (ANI) for approval and concurrence. The TRT reviewed the supporting documentation to substantiate this ANI/B&R agreement.
During 1980, the B&R ASME Code manual did not address details on inprocess weld inspections. These instructions were delineated by quality and construction standard practices and by instruction manuals.
. Procedures were revised or developed in order to address craft / quality inspection activities for predetermined welds. The TRT found documentation showing that formal training in inspection procedures was given to TUEC's craft personnel.
In preparation for the 1981 ASME Code resurvey of B&R weld-inspection, previously widespread details were consolidated in the ASME QA manual. The manual was approved by the ASME survey team on January 20, 1982. The implementation of this new procedure could give rise to the impression that construction and inspection records were separately maintained or even destroyed, as described below.
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When craf t personnel began perfornn9 selected inspection operatiuns, a number of inprocess work packages in the field were recalled.
The weld data cards for these work packages were reissued in a new format, which
' ncorporated the craft inspection operations that were to be monitored i
by QC. The old documentation, which contained data on inprocess work completed prior to the recall, was kept by the Welding Engineering Depart-ment as historical backup. When the new inprocess work packages were completed, the documentation packages were sent to the documentation review group where they were reviewed prior to submittal to the Comanche Peak Steam Electric Station (CPSES) vault.
j If the QC record reviewer believed the old records were required to make a final determination of documentation acceptability, the reviewer's supervisor submitted a written request to the weld engineering department.
The stated purpose of the written request was to deter reviewers from asking for information which was not relevant to the acceptability of the hanger package.
During the transition period from the old welding documentation format to the new one, the record reviewers made numerous requests for historical welding records.
Finally, to minimize these requests, welding engineering turned over all historical records to the reviewers.
The TRT found no specific examples of records being purposely or specifically withheld by weld engineering during documentation review.
After the transition period, the hanger packages were developed, processed, and reviewed in accordance with the new documentation format and the corresponding revised procedures.
The TRT also interviewed documentation reviewers and documentation control personnel who performed the final QA/QC review of hanger packages and found that none knew of any weld data cards being destroyed or changed.
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Conclusions and Staff Positions:
Based on its assessment of the separate maintenance of hanger records and changes to weld data cards, the TRT concludes that B&R implemented an adequate method to perform inprocess inspections and to record inspection results.
No evidence of weld data card destruction was found.
In this regard, allegations AQW-13, and AQH-1 were not substantiated and have no generic implications.
The AQH-1 concerns and issues came from a Region IV inspection report.
On October 29, 1984, the TRT was notified that tSe alleger of AQW-13 had declined to have any further contact with the NRC.
Accordingly, no close-out interview was conducted.
s' 7.
Attachments:
None.
Reference Documents:
l 1.
ASME Section III, " Nuclear Power Plant Components."
2.
ANSI N45.2, "QA Program Requirements for Nuclear Facilities."
3.
Brown & Root ASME QA manual - issued September 17, 1981; revised June 11, 1984.
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B&R Procedures:
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l 0-86 i
QI-QAP-11.1-26, " Installation and Inspections of ASME Component a.
i Supports, Class 1, 2 & 3."
b.
QI-QAP-11.1-25, "QA Review of ASME III Documentation."
QI-QAP-11.1-28, Rev. 25, " Fabrication & Inspection of Safety Class c.
Component Supports."
d.
CP-QAP-12.1, Rev. 11. "ASME Section III Installation Verification and N-5 Certification."
5.
Letter to Hartford Steam Boiler's ANI,
Subject:
Weld Inspection Program and Compliance with NA - 4511, dated March 4, 1980.
6.
Hartford Steam Boiler, "Special Inspection Services Records for Monitoring QA/QC Programs Number 308."
7.
AQH-1; RIV IR 81-04, pp. 3 and 7.
8.
AQW-13; OI Report 84-06, dated March 7, 1984; and A-7 Testimony, pp. 33-34.
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(!d 8.
This statement prepared by:
.V. Wenczel, TRT Date Technical Reviewer Reviewed by:
2.4/acy M-7-S'[
H. Livermore, Date Group Leader Approved by:
V. Noonan, Date Project Director i
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