ML20198D231

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Partially Withheld Assessment of Allegation AQ-19 to Category Qa/Qc 2, Document Control Re Use of Control Stamps by QC Dept & Paper Flow Group to Legitimize QC Drawing Packages in Violation of Util Procedures
ML20198D231
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V, Winczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230194
Download: ML20198D231 (4)
v • d • e


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1. Allegation Category: QA/QC 2, Document Control
2. ' Allegation Number: AQ-19

-'3 . Characterization: It is alleged that " control copy" stamps were in use by the. paper flow group (PFG) and quality control (QC) departments for a period of time. It is. alleged that two stamps were issued to;the QC department by document control center (DCC) n.anagement and used-to make QC-drawing packages " legitimate." The use cf these stamps by any organiza-

. tion other- than the DCC/ satellites is in violation of Texas-Utilities Elec-tric Company (TUEC) procedures.

4. Assessment of Safety Significance: The NRC Technical Review Team (TRT)

(1) reviewed TUEC DCC and PFG procedures ar.d documents pertaining to this

. allegation, (2) reviewed a sampling of PFG packages to determine if docu-mentation was current, (3) reviewed DCC/ satellite use of "contrcl~ copy" stamps, and (4) interviewed TUEC representatives and an Authorized Nuclear' Inspector (ANI) relative to the allegation.

The TRT found that DCC management issued only one " control copy" stamp to

. the'QC department as a result o,f the' issuance of a special inspection i services (SIS) report by the ANI of the Hartford Steam Boiler . Inspection and Insurance Company. The SIS report noted that the majority of QC. hanger packages contained drawings which obviously had been reproduced from the original, controlled copies with the control _ number marked over in red.

The ANI believed there would be no-evidence that these drawings were ir fact = controlled if the drawing was not stamped with a red " control copy" 1 stamp. As a result, Brown'& Root (B&R) procedure DCP-3 was revised (Revi-

sion 15) to specifica11y' mandate the use-of red " control copy". stamps for the copies' reproduced. Prior to this time, the color of the control copy 4

stamp was not design ~ated. The stamp used by the QC department was " notched" to distinguish it from those used by the DCC.

.The issuance of the SIS report and the subsequent stamping of hanger draw-ings by B&R' quality engineering occurred because of the manner in which the welding engineering organization had organized hanger packages for

. craft personnel. .The fabricators prepared generic drawings (typicals) that reflected the design of the majority of hangers. Drawing size was

81s x -11 inches. Upon receipt of the red-stamped control copy from DCC,
. welding engineering made copies for affected hanger packages. The control
j. stamp number,'098, was marked in red. Approximately 17,000 hanger packages were. constructed in this manner. In reviewing the hanger packages, the
ANI noted that the hanger drawings were not stamped in:the standard DCC.

method, and therefore issued the SIS. Subsequent to this, as corrective

action, a procedural change to DCP-3 occurred: the B&R welding engineering i organization would no longer make document distribution, and a specifically 1

identifiable stamp was issued to the B&R QC to properly stamp any uncon-

+ trolled hanger drawing within the hanger packages. QC verified the latest revision of any drawing'which did not have a red control number and stamped it with the " notched" control stamp, entering the 098 control number.

, When B&R QC no longer needed the control copy stamp in question, it was

returned to the DCC and defaced so it could not be used again.

t 8605230194 860512

, PDR FOIA 0-89 GARDE 85-09 PDR

l l

The TRT found no evidence in DCC procedures or guidelines, prior to Revi- i sion 15 of DCP-3, which delineated the use of the " control copy" stamps, or stated that the control copy was to be stamped in red. In addition, no evidence was found that written guidelines were issued or that special procedural changes were made to control the use of these stamps by B&R QC.

The TRT considers the lack of guidelines or procedures for QC's use of these control stamps to be a potential violation. The TRT interviewed TUEC and B&R representatives and found no evidence that " control copy" stamps were issued to any other organization.

The IRT noted that if a control stamp came into the possession of an organ-ization outside of DCC, it would not be significant to construction and inspection activities. The document packages used by craft personnel are verified by the DCC satellite for accuracy and completeness, and the documents are updated with current revisions upon the issuance and return of the document packages to the DCC satellite. Since only the DCC has access to non-stamped documents, the possession of a control stamp would serve no purpose in construction and inspection arganizations.

The TRT believes that future, unauthorized use of a control stamp would be difficult and impractical because the control stamps of concern are used only by the DCC satellites, and DCC satellites are the only recipients of non-stamped drawings. In addition, other controlled documents are red-stamped in DCC prior to issuance. Only DCC can make standard size drawings, hnd the personnel in DCC and its satellites are accountable for the docu-ments in their possession.

5. Conclusion and Staff Positions: Based on the above reviews, the TRT fo'und evidence to substantiate the allegation that control stamps had been used by organizations other than DCC; however, since July of 1984, DCC stamps have been adequately controlled. The TRT learned that a " control copy" stamp was issued to the QC department in conformance with the ANI request that documents transmitted to them be " red-stamped." However, methods for the issuance and control of such stamps were not describe,d in TUEC's document control procedures. Issuance of the stamps to QC had no significant safety l implication in the erection, fabrication, or construction of safety-related l

systems, components, and structures, and the TRT found no evidence that there was a loss of hanger drawing control as a result of the QC department's stamping of the hanger drawings of concern.

Although this allegation has generic implications for Unit 2, it is the TRT's position that the multiple levels of checks and verifications asso-ciated with document packages issued to the craf t personnel by the DCC and its satellites would have detected and corrected potential problems.

In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of the allegation and the TRT's conclusion.

There were no major items of disagreement, and no new concerns or allega-tions were identified.

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7.

Attachment:

None.

Reference Documents:

1. Procedure Number DCP-3 "CPSES Document Control Program," all revisions through 18.
2. TUGC0 letter, Director, Division of Licensing, NRC, " Comanche Peak Steam Electric Station Units 1 and 2 Allegations Transmitted by Letter on April 24, 1984," TXX-4180, dated May 25, 1984.
3. Hartford SIS Record #355 " Unsatisfactory Section 7 of Brown & Root QA Manual," dated June 7, 1983.
4. Brown & Root letter SIS #355. dated June 8,1983.
5. Allegation statements: A-1, dated March 2, 1984, page 4.

A-49, dated May 1, 1984, page 4.

6. Alleger's interviews: A-1, dated April 16, 1984, pages 12-24.

A-2, dated April 5, 1984, pages 87,88.

7. A-1, close-out interview, dated December 10, 1984.
8. This statement prepared by: b - d[

V. WenczelY Dat'e Technical Reviewer Reviewed by: rtmaF [o '7- 5 [

H. Livermore, Date Group Leader Approv.ed by:

V. Noonan, Date Project Director l

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