ML20198D576

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Partially Withheld Assessment of Allegations AQ-44 & AQ-128 to Category Qa/Qc 8, As-Built Re Craft Personnel Making Things Fit, Engineers Not Following Design Documents & Nonconformance Repts Voided Improperly
ML20198D576
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Eli M, Livermore H
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59 NUDOCS 8605230328
Download: ML20198D576 (4)
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Text

1. Allegation Category: QA/QC 8, As-Built

2. Allegation Number: AQ-44 and AQ-128
3. Characterization: It is alleged that there were instances when craft personnel would "make things fit" and have an engineer write "as-built" on the document instead of following the appropriate design document. It is also alleged that an as-built verification program was initiated as a result of the above practice (AQ-44). It is further alleged that nonconformance reports (NCRs) were voided (improperly dispositioned) by an engineer writing "as-built" and "use-as-is" on them (AQ-44, AQ-128).
4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) '

evaluated the Texas Utilities Electric Company (TVEC) procedures for implementing 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings"; Criterion X, " Inspection"; and NRC Office of .

Inspection and Enforcement (IE)Bulletin 79-14, " Seismic Analyses for As-Built Safety-Related Piping Systems."

IE Bulletin 79-14 requires a seismic analysis of all sr.fety related systems, as-built verification of safety-related systems, evaluation of nonconformances found during as-built verification or correction of the nonconformance, and revision of documents to reflect as-built conditions in the plant. TUEC's implementing procedures for 10 CFR Part 50, Appendix B and IE Bulletin 79-14 requirements included the following:

Texas Utilities Generating Company (TUGCO) QI-QP-15.2-1, "Startup/

Turnover Record Requirements" Brown & Root (B&R) SFI-1, "Startup/ Turnover Record Requirements" TUGC0 CP-EI-4.5-1, " General Program for As-Built Piping Verification" TUGC0 CP-EP-4.5, " Design Verification" TUGC0 CP-EI-4.5-4, " Technical Service Engineering Instruction for Pipe Hanger Design Review and Verification" TUGC0 CP-QP-16.0, "Nonconformances" TUGC0 CP-QP-11.13, "As-Built Verification" TUGC0 QI-QP-11.13-1, "As-Built Piping Verification Instructions" The TRT verified that these procedures satisfy both 10 CFR Parr. 50, Appendix B (Criteria V and X) and IE Bulletin 79-14. TUGC0 procedure CP-EI-4.5-1 includes verification of piping isomecric drawing dimensions, elevations, valves, angles, sleeves, and interconnecting equipment. This procedure also includes verification of the pipe hanger location, configu-ration, and clearances, and requires analyses of the as-built condition, resolution of unacceptable analysis results, and certification of each analysis (furnished by the responsible analysis organization).

Title 10 CFR Part 50, Appendix B, Criterion III, states that; " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...."

The TRT determined that TUEC prepared engineering procedures (CP-EP-4.6, 7

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" Field Design Change Control," and CP-EP-4.7, " Control of Engineering / Design Review of Field Design Changes") and implemented them to satisfy this require-ment. These procedures required design verification by authorized personnel either prior to or following implementation. Since revision of any design document invalidates its design verification, the organization responsible for the original design must verify these changes. Both principal support vendors (ITT Grinnell and Nuclear Power Service, Inc.) had personnel onsite who verified changes to vendor drawings and recertified these drawings when required.

TUGC0 procedure CP-QP-16.0, Section 3.2.4.1.d states that, "Use-as-is dispositions shall include sufficient engineering technical justification to establish that the nonconforming characteristic will result in no ad-verse conditions and that the affected item will continue to meet all engineering functional requirements, including performance, maintain-ability, fit, and safety." The TRT reviewed 72 nonconformance reports (NCRs) that were dispositioned "use-as-is." In all cases, the technical justification, component modification card, or design change authorization supported the "use-as-is" NCR disposition. In no case did the TRT find an NCR that was improperly dispositioned "as-built" or " accept-as-built."

In addition to the 72 NCRs examined in connection with this allegation, the TRT performed an in-depth evaluation of NCR activity, including voided NCRs. The TRT reviewed 206 NCRs and found none that was voided by an engineer writing " void as-built" on it. (Refer to QA/QC Category 50, alle-gations AQ-31 and AQ-120.)

5. Conclusion and Staff Positions: Based on a review of design, inspection, and as-built procedures, the TRT concludes that supports were changed after the drawings had been vendor-certified, and drawings were revised to reflect the as-built condition. However, these design modifications were recertified by the principal support vendor's onsite staff in accordance with NRC requirements. (For additional information, refer to QA/QC Cate-gory 1, allegations AQ-21 and AQ-22.) The TRT could not substantiate that changes were made to the drawings for the reasons alleged.

Based on interviews with both B&R engineering personnel and TUEC QA person-nel and on a review of inspection and nonconformance procedures and the 72 NCRs dispositioned "use-as-is," the TRT staff concludes that the allegation relating to improper voiding of NCRs cannot be substantiated.

The TRT plans to send a letter to the alleger regarding the TRT's assessment and conclusions. -

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7. Attachments: None.

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l Reference Documents:

1. IE Bulletin 79-14, " Seismic Analysis for As-butit Safety-Related Piping Systems."
2. TUGC0 CP-QP-4.6, " Field Design Change Control."

3dp TUGC0 CP-QP-16.0, "Nonconformance."

4.

gap 2.206 Petition item No. 13, dated March 19,1984(AQ-44).

,. AQ-44 and AQ-128: A-1 Statement dated March 19, 1984, and A-1 Interview pp. 57-63, dated April 6, 1984.

6. A-1 Interview pp. 136-137, dated August 1, 1984.
7. TUEC Letter TXX 4180 dated May 25, 1984.
8. Nonconformance reports as follows:

83-03110 84-00686 84-00607 03114 00398 00609 03093 00469 00596 l 03089 00470 00578 03090 00456 00570 03063 00463 00554 03066 00444 00557 03048 00434 00560 03053 00443 00551 03035 00424 00537 03039 00397 00519 03040 00375 00495 03042 00709 00500 03025 00713 00483 .

'03027 00673 00339 03010 00645 . 00340 03015 00627 00341 02988 00633 00343 02992 00605 00344 ,

02981 00473 00346 03017 00458 00337

! 03004 00459 00361 02475 00608 00371 00579 00485 l

00362

9. Deposition of A-50 (July 13, 1984), Tr. 52,055 Line 21; 52, 079-52,084; 52,182-52,190; Case Exhibit 667, pp. 54-55.
10. Deposition of C. Thomas Brandt, Tr. 45,273-45,276(submittedas profiled written testimony),
11. O! Report 4-84-008, dated July 9, 1984.
12. OI Report, 4-84-006 at 26. March 7, 1984. .
13. Deposition of A-50 (July 13,1984), Tr. 52,085-52,105.
14. Deposition of C. Thomas Brandt, Tr. 45,287 (submitted as profiled l written testimony).

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15. March 19-20, 1984, Hearing Session Transcripts, Tr. 10,383-11,018.

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16. April 24, 1984, Hearing Session Transcripts, Tr. 12,138-12,285.
17. Deposition of A-50 (July 13, 1984), Tr. 52,108-52,111; 52,199-52,202.
18. Deposition of C. Thomas Brandt, Tr. 45,280-45,287 (submitted as prefiled written testimony).
8. This statement prepared by: Nd d b' M. Yli, TRT b/5 [O[

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Technical Reviewer

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. H. Livermore, Date Group Leader V. Noonan, Date Project Director 4

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