ML20198D612
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~ Allegation Category: QA/QC 7, QA Implementation 2.
Allegation Number: AQ'-127 3.
Characterization: It is alleged that site library documents may not be current and the distribution of documents and changes may not always be accomplished.
It is also alleged that design change authorizations (DCAs) may not be available when needed. The alleger stated that valid and current reference documents, including procedures, were not available to the Brown & Root (B&R) quality assurance (QA) personnel who used the B&R site library.
4.
Assessment of Safety Significance: The NRC Technical Review Team (TRT) evaluated the substance of the allegation by:
Reviewing B&R and Texas Utilities Electric Company (TUEC) programs a.
for controlling procedures and reference documents (References 1 through 6).
b.
Interviewing B&R and TUEC QA and document control personnel to deter-mine site practices for the use and control of library reference material and availability of DCAs.
e Auditing a sample of controlled documents within the site library or c.
libraries to determine whether current documents were available.
d.
Evaluating the written program and site practices to determine poten-tial regulatory violations and programmatic weaknesses and to deter-mine the safety significance of the TRT findings.
In a review of TUEC's and B&R's written program, the TRT found that methods for controlling documents existed; however, the TRT found no explicit reference to a " site library," as mentioned in the allegation.
In addi-tion, the TRT found no procedure that described the " site library," its contents or methods for check out, control of material, or for updating or adding material.
The TRT interviewed B&R QA personnel and determined that the term " site library" was used colloquially to describe a collection of five centers of controlled documents and reference materials within the B&R QA building.
The five centers contained different types of materials and were located near the specific QA disciplines needing access to those materials.
The entire " site library" contained the following types of controlled documents:
- Welding engineering specifications and welding procedures
- Material specifications
- Drawings and associated DCAs and component modification cards (CMCs)
In addition, the " site library" contained the following types of uncon-j trolled reference materials:
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' ASME Code, 1974,1980, and 1983 versions with addenda, interpreta-tions, and Code cases
- ASTM standards
- Regulatory Guides and associated ANSI standards j
' College textbooks and professional handbooks By interview, the TRT learned that the function of the " site library" was to serve both the QA and QC activities.
The QC person'nel used the library reference material for interpretation of the inspection results they ob-tained. QA personnel used the library to support their work effort. The library operated on an honor system, using signout cards to identify the name and location of those removing material from each of the five centers.
Drawings and drawing-related material were more stringently controlled and were issued by a clerk.
During periods when B&R QA personnel were assigned to shiftwork, the senior QA engineer on shift provided access to the " site library."
With respect to the allegation that DCAs were not readily available, the ASME mechanical Level III QA engineer agreed that not all DCAs associated with the CPSES project were in the " site library," but that those DCAs associated with his discipline were available.
Furthermore, he stated that he was able to obtain a controlled copy of any other DCA that might be needed by B&R QA personnel by requesting that DCA from the document control center (DCC).
In his experience, the DCC responded to such requests within minutes or hours.
TUEC QA personnel who were contacted and interviewed by the TRT were not I
aware of the use of the term " site library" in the context of a specific location that had reference material for their personnel.
However, in August 1984, B&R established a small reference library containing proce-i dures designated "For Office and Engineering Use Only," under the provi-sions of DCP-3, "CPSES Document Control Program." These procedures were
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for information only copies and were not to be used for fabrication. How-ever, they were updated as revisions occurred to provide the user with current reference material.
This library was located near the TUEC QA offices; therefore, it was readily accessible to TUEC QA personnel.
The TRT audited the controlled set of B&R QA procedures in the site ASME mechanical Level III QA engineer's office. These procedures were contained in three volumes and comprised a portion of the " site library." This set of procedures was the same set that would have been available to the alleger to support the alleger's activities. The TRT compared the con-trolled set of procedures with the procedures listed in the Table of Contents for the source set of B&R QA procedures, and found that in all cases it contained the correct, current revisions and design change notices.
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Conclusion and Staff Positions:
Based on a review of B&R's program for providing reference material to B&R QA personnel and on interviews with site personnel, the TRT concludes that B&R did establish a " site library" to provide ready reference material to their QA personnel. Although the
" site library" consisted of an informal program, the actual practice i
appeared adequate to meet the needs of the B&R QA organization. The TRT found that those documents in the " site library" which were required to 0-250
be controlled by B&R procedure were adequately controlled.
Based upon the results of its evaluation, the TRT concludes that this allegation is not substantiated.
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. A brief discussion ensued.
No new concerns or allegations were identified.
7.
Attachments: None.
Reference Documents:
1.
CPSES FSAR, Section 17.1.6, " Document Control."
2.
Brown and Root CPSES QA Manual, Section 7.0, " Document Control."
3.
Brown and Root QA Procedure CP-QAP-6.1, Revision 6, " Preparation of QA Procedures and Instructions."
4.
CP-QAP-7.1, Revision 6, " Control of QA Procedures and Instructions."
5.
Brown and Root Construction Procedure DCP-3, Revision 18, ACN 1, "CPSES Document Control Program."
6.
CPSES Administrative Procedure, STA-206, Revision 6, " Control of Technical Manuals."
7.
A-1 Interview, August 1, 1984.
8.
A-1, Closecut Interview, December 10, 1984, page 182.
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8.
This statement prepared by-C Haughn
$4te Technicall($,TR Review V
l Reviewed by:
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Date Group Leader Approved byt V. Noonan, Date Project Director 0-251
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