ML20198D267

Partially Withheld Assessment of Allegations AQ-99 & AQ-136 to Category Qa/Qc 2, Document Control Re Qualification of Authorized Nuclear Inspectors & Acceptance of Documentation Known to Be Flawed & Deficient

ML20198D267
Person / Time
Site:	Comanche Peak
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: IA-85-517, Partially Withheld Assessment of Allegation AQE-41 to Allegation Category Qa/Qc 6, QC Insp Re Worn Gauges Used to Calibr Lighting Restraint Cable Tools Resulting in Incorrect Installation & Issuance of Nonconformance Rept ML20198C594 ML20198C616 ML20198C640 ML20198C704 ML20198C711 ML20198C794 ML20198C831 ML20198C859 ML20198C871 ML20198C883 ML20198C897 ML20198C933 ML20198C974 ML20198D040 ML20198D103 ML20198D141 ML20198D170 ML20198D231 ML20198D267 ML20198D290 ML20198D314 ML20198D348 ML20198D373 ML20198D377 ML20198D391 ML20198D411 ML20198D419 ML20198D424 ML20198D427 ML20198D432 ML20198D437 ML20198D445 ML20198D450 ML20198D460 ML20198D471 ML20198D479 ML20198D487 ML20198D492 ML20198D507 ML20198D510 ML20198D523 ML20198D529 ML20198D534 ML20198D545 ML20198D554 ML20198D559 ML20198D565 ML20198D576 ML20198D585 ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230204
Download: ML20198D267 (2)

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

2. Allegation Number: AQ-99 and AQ-136

3. Characterization: It is alleged that authorized nuclear inspectors (ANIS) accepted documentation which they knew was deficient and contained flaws (AQ-99) and that the ANIS may not be qualified (AQ-136).

4. Assessment of Safety Significance: The Comanche Peak Steam Electric Station (CPSES) Final Safety Analysis Report (FSAR), paragraph 17.1.7, and 10 CFR Part 50, Appendix B, require that sufficient records be maintained to furnish documented evidence of activities affecting quality. The ASME Code, subsection NA 5200, " Duties of Inspectors," paragraph NA 5251 requires that ANIS review the qualification records of the manufacturer or installer. The NRC Technical Review Team (TRT) interviewed ANIS, quality assurance / quality control (QA/QC) managers, and c5cumentation reviewers to determine what types of documentation reviews they performed.

These interviews confirmed that CPSES documents received at least three independent reviews (one by Brown & Root, one from the N-5 group, and one by the ANIS). The applicable procedures provide that deficiencies in the packages were to be identified for correction in accordance with the cer-tification deficiency list from the ANIS to Texas Utilities Electric Company (TUEC). Section 20 of the Brown & Root (B&R) quality assurance manual describes the relationship between the ANIS and Hartford Steam Boiler Inspection & Insurance Company (HSB) at CPSES. The ANIS, who are trained and certified by HSB, use HSB's Form 939, Special Inspection Ser-vices (SIS), to document problems encountered when monitoring the CPSES QA program. The TRT reviewed 12 Form 939s and verified that these monitoring reports were used as a basis for correcting problems in the QA program.

In order to verify the adequacy of the ANI Documentation Review, the TRT reviewed ten record packages for safety-related systems. The TRT identi-fied only one deficiency. The number of the receiving inspection report identified in NCR 14396 was shown as "05825," when it actually was "05835."

During the TRT's review, the NCR was reopened and this clerical error was corrected.

To assess the allegation that ANIS may not be qualified (AQ-136), the TRT determined by reviewing a sample of ANI certifications that the ANIS were tested, qualified, and certified in accordance with ASME Code requirements.

Further, the TRT interviewed QA/QC managers, ANIS, the ANI coordinator, and other personnel associated with documentation reviews and verified that ANIS had passed the tests required by ASME code.

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5. Conclusion and Staff Positions: Based on its review of applicable docu-mentation and on interviews with TUEC personnel, the TRT concludes that the allegation that ANIS accepted flawed packages knowing they contained deficient documentation (AQ-99) cannot be substantiated. Although the TRT did identify a clerical error in one package, adequate documentation was found to verify the actual identity of the material. Based on a review of ANI certifications and interviews with personnel involved, the TRT concludes that ANIS were qualified (AQ-136). Therefore, this allegation could not be substantiated.

4 8605230204 FOIA 860512 0-93 i(PDR 96RDESS-89._. PDR . t

S' The AQ-99 concerns and issues came from an unidentified GAP source.

Accordingly, no closecut interview were conducted. For AQ-136, the TRT attempted to telephone the alleger, whose telephone had been disconnected.

The TRT will mail its findings to the alleger's last known address.

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7. Attachments: None.

Reference Documents:

1. Applicable Documentation - FW-l'RB-04-5, FW1-018-706-C72K, NCR9118SR3, -

SI-2-RB-13-4, CS-1-SB-032, CC-2-SB-042ITT1, BR-1-SB-05 Spool IQ3, BR-1-SB-004 Spool 103, BR-1-SB-006, and MS-1-SB-050, interview 8/23-24/84 NCRs M-2698, M-2701, M-2704, M-2708, M-2713, M-2716, M-2737, M-4974, M-9787, M-9797, M-13450, and M-14396

2. Hartford Steam Boiler, SIS record for monitoring QA/QC programs, No. 317, dated February 6, 1984.

3. A-53 interview of August 24, 1984.

4. GAP, handwritten list, April 1984.

5. Form 939, Hartford Steam Boiler Inspection & Insurance Co., numbered 341, 339A, 334, 332, 319, 313, 304, 380, 377, 371, 368, and 365.

8. This statement prepared by: [ [

V. WenczeFTRT Date Technical Reviewer Reviewed by: trauu b '7- YS' H. Livermore, Date Group Leader Approved by.:

V. Noonan, Date Project Director 0-94

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