ML20199G442

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Comments on Draft Qa/Qc Ssers Re Category 1 - Design Process.Related Info Encl
ML20199G442
Person / Time
Site: Comanche Peak, 05000000
Issue date: 02/04/1985
From: Tang R
NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To: Livermore H
NRC
Shared Package
ML20197J178 List: ... further results
References
FOIA-85-59 NUDOCS 8606250234
Download: ML20199G442 (9)
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4g UNITED STATES

[ NUCLEAR REGULATORY COMMISSION

7. j WASHINGTON, D. C. 20555

'+,, .....f February 4, 1985 NOTE T0: Herbert Livermore _

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Group Leader, QA/QC m FROM: R. C. Tang g Comanche Peak TRT / <

SUBJECT:

COMMENTS BY TRT CONSULTANT TED WORKINGER ON DRAFT QA/QC SSERS, CATGEGORY 1 - DESIGN PROCESS The following comments are submitted for consideration with respect to preparing the final SSERs for QA/QC. :A ,,cor d/af/mb 5.5c7C A0-15 and 89 (Draft 5 10/9/84)

/ 1. The proposed word changes on page 3 are suggested because, as now stated, it is implied that TRT set out to verify and determine that design verifications were correctly documented. We propose that TRT made a review to determine whether design verifications were correctly documented.

t/ 2. Delete, from the last sentence of the middle paragraph on page 3, the words "no lack of". The sample revealed design verification, rather than no lack of design verification. .  ;

/ 3. The last sentence of Section 5, on page 4, should be deleted. It is an improper conjecture about the alleger's understanding.

AQ-21, A0-22 and A0-119 (Rev. 1 - 10/29/84)

1. The first sentence, of the last paragraph, on the first page raises an issue about why or the basis for selecting only three procedures fer review. Avoid the issue by inserting " relevant" in place of "three of the numerous" before the word procedures.
2. To obtain better sequence or organization, consider moving the last paragraph on page 5 forward to become the second paragraph on page 3.
3. The second paragraph on page 5 states, "As a measure of the effectiveness...TRT selected 11 supports..." and made certain measurements. Either state the conclusion here, or make a specific reference to exactly where the conclusion is stated in QA/QC Category 8; or delete this paragraph.
4. In Section 5, on page 6, for the first , time the issue is raised abcut weld number identifications being deleted. In general, a subject not discussed in the body of the report is not inserted into the summary or conclusions. If this topic has some significant relevance, it should be ,

discussed in Section 4; otherwise, it should be, deleted.

8606250234 860611 9 PDR DE l_

E Herbert Livermore ,

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l. 5. Consider modifying the last sentence of Section 5, on page 6, to state:

However, VCD changes and modifications were acceptable practices, if they were documented and vendor certified, and thus did not violate procedures or requirements.

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QA-90 (Draft 2 10/8/84)

No comments.

The above comments are reflected in the attached marked-up copies of the SSERs.

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~3- fy /0 "b h loca* tion drawings cnd piping isometrics. These isomatrics wera not C&H drawings; therefore, changes to them were net subject to G&H eview.- However DCAs and CMCs written against these piping Carl sometrics -de- af f ect the G&B composites, and changes to them are ubject to G6H design verification. The actual installed e

L onfiguration was documented on "as-btilt drawings, which ve e then sed by C&H for final stress analyses, revieWSk te TRT acrifica implementation of procedures for design verification ny selecting and examining samples of CMCs, DCAs, and drawings to ub b tetermine that- design verifications were correctly documente?. T'te

'RT selected 100 design change documents (CMCs) for review. Of this sample , 17 vere void (not issued), and 49 af fected hanger designs.

the TRT reviewed the recaining 34 CMCs for proper design verificatioqD md fcund that tL m. ycrso. car of Louscr ond voidcd O'C: in the se;. pit acc ::pccacataL A ef the tut-Il pupuiawiua. T TRT selected 42

, D DCAs from those issued and reviewed them for d. ign arification.

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The TRT also reviewed 21 drawings for proper design verification t, sing'~~4, i

the drawing numbers TNE transmitter. to DCC as a key. The sample h revealed me 1;;h of prope: desigr verification. 4 ww Design changes are made during all phases of construction, up to and including operation heee sLanses cust h u .' T-ic d ,- r ad* [he \

<>.,videne<. Mar desiga vecifeie.+s*.n TRT review found no instcnce: in ".ich this was not being accomplished.

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{ 5. Conclusion and Staff Position: Based on our review of applicable procedures and design records, along with intervie'w's with TUEC and ELR S -

personnel, the TRT concludo4 that alterN tiots (changes) to final v

design drawings were supported by adequate technical reviews and design verification in 'accordance with 10 CFR 50, Appendix B, Criterion III " Design Control." The TI.T further concludes that the ,

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allegation concerning design changes ncit being design-verified-wee <

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%.uJ N f, 4he TRT concludes that the __,. _ f cd ,_ i o.1:im u... v .' .hu T .

allegations are without consequence relative to the progra==atic and hyk. . ,,.*Yl'-

, G -u2 a .-n technical i=ple=entation of com=it=ents , d NRC requirements <.g The gg TRT conclusion regarding the as-built condition versus the M/4[ t -

final desi v'erified document. is presented in h QA/QC /' . p/

4w Category 8. f*Y -

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6. Actions Recuired: None.

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8. Attachnents: None.

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. . .. . : .. . . . Revision 1 10/27/84 e

AQ-21, 22, 119 CP5

.SSER f . ..

l j 1. Allegation Group: QA/QC Category No. 1 i

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2. Allegation Number: AQ-21,.AQ-22, and AQ-119
3. Characterizatior: It is' alleged that vendor-certified drawings (VCDs) for ASME c, ode component supports have numerous dimensional errors when compared to the actual plant installation and that vendor

( certification of drawings has been invalidated by revisions that

! inappropriately reflect the as-built condition of the plant. .

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4. Assessment of Safety Significance: The implied significance of these allegations is that fabrication and installation of safety-related ci:<. . <~ o-- ref e: , u. Med or- c k ^ l' ^ 'a_'

components may have occurred that have not been design certi' icd cr-

-veri #ied, making questionable their ability to perform their intended

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safety function.

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eelevant )h s The NRC Technical Review Team (TRT) reviewed 4hrcc cff;,he "rerote -

t procedures related to the centrol, review, and verification of the fabrication, installation, and inspection of ASME component supports.

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This review and the TRT's subsequent discussions with Brown & Root (B&R) personnel provided an understanding of the vendor document control

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J QA/QC No. 1

. . . . .. . [. . .. . . . .

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During fabrication and installation of supports, however, various l

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conditions may arise that require modification of the original vendor L

drawing. Modifications may result from conditions such as interferences encountered during installations, changes resulting from in-process end final inspection, and engineering design changes directly or indirectly related -to a particular support. Regardless of the reason

,for a change affecting a vendor drawing, its source, or the number of l

times the vendor has previously certified the drawing, both the Final

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Safety Analysis Report (FSAR) commitment and NRC requirements require L

. vendor personnel to recertify their own drawings. M2dition, as-b91t-. l ss .

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! TUEC's vendor document control system is consistent both with their

@ FSAR comitments and applicable NRC requir ments. The TRT verified the implementation of this process by their review of vendor drawings, which included associated change documents, all drawing and change

, revisions, bases for changes and revisions, nonconformance reports (NCRs), and the certification packages for each VCD. The TRT found that VCDs were changed for a number of reasans. The TRT reviewed the t

processing of one drawing which had been identified by the alleger as j being improperly processed. This drawing was processed through vendor

{t drawing control as follows.

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QA/QC No. 1 drawings and install'ed conditions can potentially occur at any time; 6M however, the4 as-built condition must be in conformance with the

_ applicable VCD.

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- As a measure of the effectiveness of the control of VCDs, the TRT h.

selected 11 supports for physical verification against the applicable ,

VCD. Physical measurements made by the TRT included dimensions, weld /

sizes, and location. were wi,thfiiThe i

. Or: mpr;h =S: TRT as-built evaluation g

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is presented in QA/QC Category No. 8. '

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The revision of any design document invalidates the design verification of that document and thus requires verification by. the 4 organization responsible for the original design. (Refer to 10 CFR 50, J.

E s ki A Appendix B, Criterion III). Therefore, onsite changes of essentially .$

j , every vendor support drawing would be in violation of NRC regulations

'[ if B&R personnel ~were perfonning the design verification of the . p g changes instead of the appropriate vendor personnel. However, B&R j personnel were not perfonning these design verifications. The TRT

' determined that both principal support vendors (ITT Grinnell and NPSI) 3 have staffs onsite to conduct design verification of changes to their

. own drawings and to recertify these drawings when required.

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5. Conclusion and Staff Positions: Based on the review described above, the TRT concludes that these allegations are substantiated.

Supports were installed befoie the drawings were vendor certified, .

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VCDs were revised (dimensions, material, orientaticn, etc.) to \'

.f ' i reflect as-built conditions, supports were revised after the. drawings t > -[

were vendor certified, and weld number identifications were deleted 4 ,' A from drawings and weld data cards on nearly all ASP.E Class 2 supports. .y s.

, The TRT also found that vendor drawings were converted to B&R drawings by applying a B&R corporate sticker and, by changing the document numbers to be consistent with the onsite numbering system. However, these practices did not violate procedures or requirementsgd e TRT V

concludes that this allegation has neither safety significance nor \

generic implications. (The'TRT conclusion regarding the as-built condition versus the final design verified documents is presented in g@

q QA/QC Category 8.)

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6. Actions Recuired: None.

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Attachments: None.

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T s_ r Document Hame. -

SSER AQ-91 Requestor's ID: ,

JEAN Author's Name:

Poslusny Document Comments:

1/10/85 REVISIONS - Pleas, return this sheet w/any revisions O

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