ML20207A670
| ML20207A670 | |
| Person / Time | |
|---|---|
| Issue date: | 01/26/1988 |
| From: | Gillespie F Office of Nuclear Reactor Regulation |
| To: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20206E778 | List:
|
| References | |
| FOIA-88-322 NUDOCS 8801290033 | |
| Download: ML20207A670 (5) | |
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O al0 9q'o UNITED STATES
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!"- n NUCLEAR REGULATORY COMMISSION
{. ,j W ASHING T ON, D. C. 20657
%.,,,,*' JAN 2 61988 ItEl'ORAhDUM F0P.: .irres L. Ili1hoan, Directer Divisien of Reactor Safety Region IV FRCit: Frank P. Gillespie Director Progre.m Manager.ent. Policy Cevelopment and Ar.elysis Staff Office of Nuclear Reactor Regulation
SUBJECT:
DESIGN DOCUMENTS Your memorendum of December 9, 1987, requested assistance in developing guidance relative to the design decurent issue discussed en the enclosure to Robert D. Martin's November 20, 1987 memorandum enclosed to your corresper-dence.
The requested guidance is enclosed. Questions in this regard should be referred to Mark Peranich, FTS 49-28005.
..o UI':p%LL' Frank P. Gillespie. Director Program Management Policy Development and Analysis Staff Office of Nuclear Reactor Regulatien Erclosure:
As Stated cc w/ enclosure:
G. Arlotto L. Shac D. Crutchfield
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FEMORANDUV. FOR: Jancs L. Milhoan, Director Division of Pcactor Safety Region IV FR0ll: Frark F. Gillespic, Directer Program llanecement, Policy Development and Analysir Staff Office of I,'uclear Reacter Regulation SUBeECT: DESIGN C0COMENTS Your recnerandun of Lecember 9. 1987, requested assir.tarce in developing ruidance relative to the tesign decurent issue discussed on the enclosure to ;
Robert D. Martin's licvember 20, IS6/ memorardum enclosed to your correspon-derce.
The requested guidance is enclosed. Questions in this rcrard should be referred to itark Peranich, FTS 49-28085. t Origital signed by Frank P. Gillespie. Director Program Panagement, Policy Develcpment and Analysis Staff Office of Nuclear Pcactor Regulation
Enclosure:
As Stated cc w/enclesure: 1 G. Arlotto L. Shao D. Crutchfield Distribution:
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Enclosure Statt-rent of Issg The CFRRC report neted that the procedure fcr installetien of the reactor vessel, since it recorded irsta11ation dironsions and deviations frem ellched tolerances which recuired evcluation fcr receptability, sheuld have been contre 11tc by the lict.nsee as a Derign Docuaent, khat is not clear from the CPRRG repcrt is whether this conclusion about hcw such records should be hardled differs in any substantive way, in this instance, from the quality contrcis applied to any record which records differenccs ir physicel installatien or systrri performance. Examples nf these records wculo be Nonccnformance Reports and Prreperational Test Procedure results which differ frcr criginal test acceptance criterir.. These kinds of examples are covered by the Quality Assurance Program of a licensee which, in eccordance with Apperdix C to 10 CFR 50, has established controls for resciving such discrepancies. Region IV believes such centrols are appropriete. The CPRRG distirction of handling such records as Design Docurents is not clear.
Guidance
Reference:
The CPRRG Report, NUREG-i257. Appendix A and Appendix B, Sections 3.1 ard 3.2.
Baekcround The CPRRG report noted that the Westinghouse Nuclear Services Division (WNSD) procedure should be controlled as e desior dccument. The procedure called for certain dimensional tolerarces that were to be satisfied during the irstalle-tion of the RPV. The dimensional tolerances were translated irto the contructor's traveler for installation of the RPV along with requirerents for deviations from these tolerances to be recorded on the traveler for review and disposition by the Westinghouse field engineer, which was also recorded on the traveler. However, deviations epproved by the field ergineer did not resPlt ir a revision to the Westinghouse procedure. Therefere, the contnictors traveler was the only quality document utilized to record and disposition deviations from dirensional tolerances called for in the Vestinghouse procedure for the installation of the RPV. The CPRRG report conclusion did not indicate that the traveler should be ccntrolled as a design document.
The above discussed instructions and practices were apparently adopted and being implemented under the licensee's quality assurance program. In this specific case, the licensee's pregram allowed the use of the Westinghcuse procedure in place of the more normal practice of requiring vendor construction specifications and drawings as the basis for trarslating design criteria in other controlling installatien instructicos such as i traveler. In addition to controlling the design criteria to be followed durirg instellation of the RPV, the traveler was aise used for recording and dispositioning of deviations from the specified dimensional criteria, which is nermally accomplished under a licensee's pregram through the use of ron-confernance reports.
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Discusston it is not readily trrarent from the above f.tatenent of issue whether the referenced ir.r.tructions that should have been centrelled as t, design docunent represer.t the Westinghouse procedure, the censtructr,rs traveler, or both.
However, it is clear that the CPRRG conclusien (Appendix 0, page 49) cnly refers to tbc k'estinghouse procedure as needing te he controlled as design decurentation. An interpretation that the constructors traveler shculd also be
!- centrolled ir that nan,'er would certainly differ substantie11y from how the NRC and irdustry guidanco enderscd by the \RC view how srch instructions /reecrds should t,e handled.
! /lso fron the review of the CPRRG report, it is apparent that the conclusion that the Westinghousc procedure should be controlled as t design docurrnt was reached in absence of all clesired inferration. Hewever, it is viewed as an appropriate conclusien based on decunented evidence or. hard that tbc Westing-heuse procedure was being used as a design docunent. Thus, the CPRRG report conclusion provides an acceptable means to achieve the desired end result.
1 hat is, if the action was taken, it would have required the licensee to
.l clarify the design contrcl ressures utilized by the licensee / vendor to ensure that original design documents are revised, when required, to reflect approved chances to the original design.
However, it is the absence of other inferration, sete which was scucht by the CPRRG, that cer.tribu Ws to makirg this ; + bad of hardling such documents a
- unique case that differs substar.tially frcm in, norn. Exarples of such missing information are
- 1. A clear understanding of Westinghouse cuality assurance program l requirerents relative to dcsigr cutput documents transnitted to
! the licensec for use in the instal 16tien of the vendors major cceponents.
- 2. As noted by the CPRRG report, it was not clear whether the technical inferr.ation (dimensional tolerances and clearances) provided in the Westinghouse generic procedure was ir fact l
design information.
- 3. The quality assurance role of the Westinghouse field engineer relative to design centrol was ret fully investigated ard available for CPRRG review. For exanple, it was not clarified whether the field engineer was authorized to act as an agent of i the home office in reviewing and approving deviations frem i the vendor's original design criteria and what guidance may have been provided to him for this purpose, or otherwise enly l' authorind to approve such deviations subsequent to home effice i review and approval based en design centrol docurentation (e.g.,
l FCR) ferwarded by the field ergineer in accordance with the l venders quality to assurance program. The field engineers role
! was not clear, in particular, since tue CPRRG report (NUREG-1257, page 3-5), indicates it was the licensee that took the action which requested and received approval for a charge in tolerances from the Westinghouse procedure.
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3 Sumary I Due to the circur. stances ditccssed above, the CPRilG report conclusion does differ ir a substantive way fror the norm for licensee herdling of such ;
rccords. If the CPRRG report conclusien is being interpreted te include the ccnstructor's traveler to be contre 11ed as a design doeurert this, in :
particuler, would differ significantly frem hcw such racerds should be handled '
urderethe licensee's QA progrer.
Although unique and perhaps different from the cenclusion that may have bcen i reacned had either the Regicn or the CPPPG had acctss te all the rrrtinent informatien, the CPRRG recomended action for requiring the licensee, rather than the i:RC inspecter, to clarify the adecuacy of such design contrni practices is censidered appropriate cir.ce sufficient objective evidence of such practiec was found to exist.
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