ML20198D290

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Partially Withheld Assessment of Allegations AQ-75 & AQ-76 to Category Qa/Qc 3, Records, Re 840307 Changes Made to N-5 Program Procedures That Rendered Document Reviewers Unable to Perform Job
ML20198D290
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Watson V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230210
Download: ML20198D290 (4)
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1. A11ecation Category: QA/QC 3, Records
2. Allegation Number: AQ-75 arid AQ-76
3. Characterization: It is alleged that changes made on or about March 7, 1984, in the N-5 program procedures for processing documents into and out of the vault have made it impossible for document reviewers to do their job.
4. Assessment of Safety Significance: Brown & Root (B&R) procedure CP-QAP-18.3, Rev. I states that N-5 program documents shall be complete and certified before being placed in the permanent plant records vault (PPRV). The procedure states that documents can be removed from the vault for specific reasons, such as audit <,, but require authorized approval under those cir-cumstances. TUGC0 procedure CP-QP-18.4, Rev. 2, states that file copies of verification documents shall not leave the records vault for any purpose without the written consent of the site quality assurance manager.

The NRC Technical Review Team (TRT) reviewed B&R procedures CP-QAP-18.2, Rev. 4, CP-QAP-18.3, and instruction transmittals 57 and 58. Although

-the allegation states that the procedure change occurred in early March, transmittal 57 was issued on April 18, 1984. It deleted procedures CP-QAP-18.2 and CP-QAP-18.3 with the anticipation that they would be incorporated into CP-QAP-12.1. B&R determined that CP-QAP-12.1 was not ready for issuance and, therefore, transmittal 58, dated April 23, 1984, was issued reinstating CP-QAP-18.2 and CP-QAP-18.3. The TRT reviewed these N-5 program procedures and found that they adequately met the requirements of the ASME Code,Section III.

The TRT review recognized that the N-5 packages may have been placed in the PPRV when procedures CP-QAP-18.2 and CP-QAP-18.3 were deleted and prior to the time they were reinstated. Accordingly, these packages may not have received adequate review, and therefore may not reflect the as-built

. condition.

The TRT reviewed the PPRV logbook and found no N-5 activity between April 19, 1984 and April 23, 1984. The TRT also reviewed the PPRV log-book for a period of several months and determined that long periods of N-5 inactivity were not uncommon. In addition, the TRT reviewed component cooling water package CC-1-SB-037A which was placed in the vault on April 18, 1984. The package was complete.

5. Conclusion and Staff Positions: The TRT found no evidence to support these allegations. Accordingly, they have no generic implications.

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

A brief discussion ensued. There were no major items of disagreement, and no new concerns or allegations were identified.

IB605230210 860512 l PDR FOIA 0-101

.CARDE85 89_ PDR _ . ,

7. Attachments: None.

Reference Documents:

]; 1. Brown & Root Procedures

-a. CP-QAP-18.2, Rev. 4, "QA Review of ASME III Documentation."

i.

b. CP-QAP-18.3, Rev. 1, "QA ASME III N-5 Certification."
c. CP-QP-18.4, Rev. 2, " Permanent Plant Record Receipt, Control, and Storage."
d. CP-QAP-18.1, Rev. 3, " Processing QA Records."
2. Brown & Root QA Procedure / Instruction Transmittals, Nos. 57 and 58, dated April 18, 1984, April 23, 1984.
3. Permanent Plant Records Vault logbook.
4. N-5 Documentation Package, CC-1-SB-037A, S/N CC-1-410A, " Component Cooling Water."
5. A-1 Statement, dated August 1, 1984, pp. 79-90.
6. A-1 Statement, dated August 11, 1984, pp.99-101.
7. A-1 interview of December 10, 1984, pp. 35-73.
8. This statement prepared by: helm (A), (AJdw 6/6/Pf V. Watson Da'te '

TRT Technical Reviewer Reviewed by:

H. Livermore 24/4e et t [o E i Date Group Leader Approved by:

V. Noonan Date Project Director 0-102

Activity June July Aug. Sept. Oct. Nov. Dec.

A .' Revised Sequences (S L/NRC)

- Review PRA; Revisit "Old" Dominant Sequences Plant Visit Estimate New Frequency Confirm New Frequency B. Containment Event Trees (SNL)

Results Report Peer Review '

Re-evaluation as Necessary C. Source Term Binning (BCL)

Meetings at SNL/BCL Documentation D. Source Term Code Runs (BCL)

Results .

Documentation E. Release Characteristics Binning (BCL/SNL)

Documentation

  • F. Consequence Calculations Results Documentation G. Risk / Risk Reduction Calculations Write-up (SNL)

Draft Report Final Report 1

.~

Activity June July Aug. Sept. Oct. Nov. Dec.

A. Revised Sequences (S L/NRC)

- Review PRA; Revisit "Old" Dominant Sequences Plant Visit Estimate New Frequency Confirm New Frequency "

B. Containment Event Trees (SNL)

Results Report Peer Review Re-evaluation as Necessary C. Source Term Binning (BCL)

- Meetings at SNL/BCL -

Documentation D. Source Term Code Runs (BCL)

Results Documentation E. Release Characteristics Binning (BCL/SNL)

Documentation F. Consequence Calculations Results Documentation G. Risk / Risk Reduction Calculations Write-up (SNL)

Draft Report Final Report

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