ML20198G214

Expresses Concern Over Lack of Internal civil-structural Design Control Procedures at Gibbs & Hill,Required by 10CFR50,App B.Criteria III Re Design Control & V Re Instructions,Procedures & Drawings Not Implemented

ML20198G214
Person / Time
Site:	Comanche Peak
Issue date:	11/13/1985
From:	Shewmaker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Norkin D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20198G216	List: ML20198G214 ML20210P747 ML20210P797 ML20210P833
References
FOIA-86-38 NUDOCS 8511210020
Download: ML20198G214 (3)

Text

- . _ _ - - _ _ _ _ _ _ _ _ _ _

O

[g acgh, UNITED STATES g a NUCLEAR REGULATORY COMMISSION 3 WASHINGTON, D. C. 20555 s, /

noy , y 3985 '86 AFP 23 A 7 :48 DRR m n MEMORANDUM FOR: Donald Norkin, Team Leader Comanche Peak IDVP Office of Inspection and Enforcement FROM: Robert Shewmaker Civil-Structural Discipline Leader Comanche Peak IDVP Office of Inspection and Enforcement

SUBJECT:

CONCERN OVER LACK OF INTERNAL CIVIL-STRUCTURAL DESIGN CONTROL PROCEDURES AT GIBBS & HILL As a result of our first week of inspection effort at the offices of the IDVP contractor for the licensee at Comanche Peak, it appears that Gibbs and Hill had a major deficiency in the implementation of 10 CFR 50, Appendix B, during the design phase of the plant.

Based on the questioning of TERA, the licensee's IDVP contractor, the civil-structural team ascertained that TERA has been unable to establish that Gibbs and Hill had formal, written procedures, instructions or guidelines which are interpreted to be required under 10 CFR 50, Appendix B. Specifically Criteria III, Design Control and V, Instruction, Procedures and Drawings appear not to have been implemented in the engineering and design offices of Gibbs and Hill. Since the major efforts of design for Comanche Peak were during the years of 1974-1980 I would expect that some system should have existed to control the design process, yet TERA has indicated they have found nothing formal. My previous experience in IDI work has indicated that firms, lik.e Bechtel, Sargent and Lundy and United Engineers had such procedures formalized as part of their design control process for plants designed in the same time period.

This information imediately brings three significant questions to mind which are probably more appropriately addressed within the parent line division of IE to which you belong. I recommend some action be considered to determine why this condition has existed undetected to this point in time.

1. What type of overview, surveillance or control has TUGC0 maintained over Gibbs and Hill? Did TUGC0 review the implementation of 10 CFR 50, Appendix B by Gibbs and Hill?

2. What have the reviews by the Vendor Inspection Branch shown with i respect to the conformance to and implementation of 10 CFR 50,  !

Appendix B at Gibbs and Hill?

u X* Fo/A - 8' '38 4 g(oo

' Bli 1 I

,y

-:t

f -

YDonaldNor' kin j w

3. What commitments exist in the Gibbs and Hill Corporate QA Manual l relative to this issue and what was the NRC's view of the implementation of these commitments?

Whether this problem is limited to the civil-structural area is a question which at this time, I cannot answer, but the scope of the problem should be determined in the future.

If I can be of any assistance in discussing this with your management, please contact me.

obert Shewmaker Civil-Structural Discipline leader Comanche Peak IDVP Office of Inspection and Enforcement i

I

_ _ _ . _