ML20212H398
| ML20212H398 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/17/1986 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20212H304 | List: |
| References | |
| NUDOCS 8701210388 | |
| Download: ML20212H398 (12) | |
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1 COMANCHE PEAK RESPONSE TEAM
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RESULTS REPORT g i
ISAP: VII.a.3 i
Title:
Document Control I i
REVISION 1 i
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Coordinator /
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aw Team' La'ader h'
inb2l'/C Date / '
i V Y.
Joh6/W. Beck, Chairman CPRT-SRT
/Zf/7f6 Date i
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8701210388 870116
, PDR ADOCK 05000445
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Ravision: 1 Pags 1 of 11-RESULTS REPORT O ISAP VII.a.3 1
I Document Control I l
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1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC
- The Comanche Peak SSER 11, Appendix P Section 4.7, pages P-27 and P-28, describes the NRC concerns in the area of document and record control. The concerns pertaining to document control have been extracted and are presented here
, "The TRT assessment of the document control function for the >
period following July 1984 indicates that the preparation, issuance and changes to documents that specify quality requirements or prescribe activities affecting quality are i adequately controlled. Documentation packages reviewed at the point of issue, and in the field where prescribed activities were being performed, were found to be complete and current.
- Further, a sample of safety-related quality records stored in
- the permanent plant records vault (PPRV) was reviewed and found to be acceptable. Included in the documentation l packages were completed records for piping, piping supports (hangers), assembled and/or installed components, fabrication i and inspection / testing data, including walkdown inspection l check lists and the applicable N-5 data reports. In-process and final inspection and acceptances for completed record packages appeared to have been performed to the latest l revision of drawings and specifications.
l Howeve, the history of recurring document control i
deficiencias prior to July 1984 raises concern about certain
! aspects of the quality of construction....In procedural
- control, the TRT sechanical and piping group observed that l uncontrolled and unauthorized procedures were used to perform t cold-springing (realign piping) during its installation.
With respect to drawing control prior to 1984, the TRT found deficiencies that included: distribution of incomplete or j obsolete drawing packages to the craft and QC personnel; i inadequate drawing control; high DCC satellite error rates;
! and procedural non-compliance. The TRT QA/QC Group concludes l that although many of the document control inadequacies have l been corrected, the implications of past inadequacies on construction and inspection have potential generic significance which has not yet been fully analyzed by TUEC." :
f The NRC letter from D. G. Eisenhut to M. D. Spence dated January 8,
! 1985 stated the following:
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R: vision: 1 Pags 2 of 11 RESULTS REPORT V ISAP VII.a.3 (Cont'd)
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (Cont'd)
"The TRT found that the DCC issued a controlled copy stamp to the QC <!ppartment to expedite the flow of hanger packages to the Auct.orized Nuclear Inspector. Methods for this kind of issuance and control of such stamps were not described in TUECs procedures."
2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT."
" Address the root cause of each finding and its generic implications..."
" Address the collective significance of these deficiencies..."
" Propose an action plan...that will ensure that such problems ,
do not occur in the future."
3.0 BACKGROUND
Basic problems in the Document Control Program were identified and documented by TUGCO. As a result, appropriate changes were l introduced into the program, and as indicated in SSER 11, an
! acceptable level of implementation was achieved by July 1984.
l l TUGC0 has, to date, performed activities to ensure that features of the physical plant affected by the CPSES QA/QC program conform to the latest design information. These activities include the following:
Design Change Verification Program - Originated in 1981 to ensure, through document review and/or hardware inspection, ,
that all applicable design changes had been incorporated into '
the plant. The program was implemented in the electrical discipline and was essentially completed in late 1984. A l
current program is being implemented whereby all issued design l changes will be reviewed to ensure that they have been incorporated.
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I R:vicion: 1 l
Pags 3 of 11 i I
i RESULTS REPORT b
i ISAP VII.a.3 l (Cont'd)
3.0 BACKGROUND
(Cont'd)
Preparation of ASME Code Data Sheets (N5) - Performed final verification of acceptable ASME component installation or installation processes for component installation certification. This activity was performed in 1983 and 1984 for Unit i and is presently ongoing for Unit 2.
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Class V Hanger / Support As-Built Program - This activity was performed from 1981 to 1983 in conjunction with the implementation of NRC IE Bulletin 79-14. " Seismic Analysis for As-Built Safety-Related Piping Systems". ,
The CPRT performed the following activities which provided data to verify that the latest design information has been incorporated into the plant features that are of interest:
ISAP III.d, "Preoperational Testing" ISAP VII.c, " Construction Reinspection / Documentation Reviev j Plan" Action Plan VII.a.3 was designed to provide reasonable assurance that past DCC problems have not resulted in adverse hardware conditions in the existing plant. This was evaluated by examining j the results of other ISAPs which address hardware i
configuration / status and test programs results.
TUGC0 has previously responded to the NRC concerning the issue of the " Controlled Copy" stamp to the QC Department. The response and
- subsequent correspondence with the NRC were reviewed to determine the status and possible additional actions.
k 4.0 CPRT ACTION PLAN i
! 4.1 Scope and Methodology j 4.1.1 The objective of this action plan was to provide i confidence that, although problems were identified over a period of time in the implementation of the Document Control prostsa during the construction phase of CPSES,
, the hardware has been installed and tested in j accordance with the current design requirements. In
- addition, the current procedures governing the 4 operation of the Document Control Center were reviewed I
for adequacy of control of drawings and revisions
- thereto.
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i 1 Rsvision: 1 Pag 2 4 of 11 8
, RESULTS REPORT l s
! ISAP VII.a.3 j' (Cont'd) i j 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 The specific methodology is described below.
4.1.2.1 It was determined by the QA/QC Review Team Leader that CPRT Issue Specific Action Plan VII.c, " Construction Reinspection /
f Documentation Review Program", would provide sufficient data to provide confidence that
{i applicable design changes have been j incorporated into the physical plant. This determination was cased on the extensive nature of ISAP VII.c whereby a very large i sample of installed hardware would be compared to the current design information.
It was also determined that ISAP III.d.
"Preoperational Testing", would provide pertinent information concerning the possible
, effect of document control problems on the j , prerequisite and preoperational test programs.
t 4 4.1.2.2 ISAPs VII.c and III.d specified actions to be i
1 performed as follows: '
I t - ISAP VII.c, " Construction
! Reinspection / Documentation Review
] Plan" included a Reinspection /
l Documentation Review of QC-accepted I safety-related construction work i activities performed at CPSES. The
! implementation of this action plan l required that the latest design .
- information be utilised in preparing '
reinspection / documentation review checklists, and that the latest i
applicable design information, I including design change l authorisations (DCA) and component l modification cards (CMC), were included in the reinspection / review package. If equipment differed from
, checklist requirements or if the j associated documentation did not l exist or was improperly completed, a l deviation report was initiated. In j accordance with the requirements of I
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s R;vicien: 1 Page 5 of 11
(} RESULTS REPORT U
ISAP VII.a.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) the ISAP, deviations were evaluated for safety significance, and if required, roor cause, generic implications, and appropriate corrective actions were recommended.
All deviations for each population were also evaluated for adverse trends.
These root cause and generic implication analyses for safety significant deficiencies and adverse trends were reviewed to compile information that might be relatable to document control concerns.
ISAP III.d, "Preoperational Testing" actions included an investigation to
/ determine if the problems associated with document control had an adverse' effect on either prerequisite or preoperational testing.
In accordance with the requirements of the ISAP, identified deficiencies would be evaluated for root cause and generic implications, and appropriate corrective action would be taken. Root cause and generic implication analyses would also be reviewed to compile information that might be relatable to document control problems.
4.1.2.3 Current procedures governing the operation of the Document Control Center were reviewed to verify that adequate controls are provided to ensure that current design drawings and changes thereto are available for construction and inspection activities.
4.1.2.4 The Issue Coordinator compiled.and reviewed the results of ISAPs VII.c and III.d. From this evaluation, and the review of the i
O current program, a determination was made for any corrective actions and/or program changes required for the remaining construction phase of Unit 2 and the operations phase.
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R vision: 1 Pcg2 6 of 11 RESULTS REPORT O ISAP VII.a.3 %
(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
, 4.2 Participants Roles and Responsibilities 4.2.1 TUGC0 4.2.1.1 Scope TUGC0 assisted in identifying and locating applicable information and documentation to support the Review Team activities.
4.2.1.2 Personnel Mr. D. Snow TUGCO QC Coordinator 4.2.2 QA/QC Review Team 4.2.2.1 Scope O -
Reviewed ISAPs VII.c and III.d results and compile data related to document control problems.
- Analyse / evaluate data for generic implications Determine corrective actions and recommend program changes 4.2.2.2 Personnel Mr. J. Hansel QA/QC Review Team Leader Mr. J. Gelser Issue Coordinator 4.3 Qualifications of Personnel Participants were qualified to the specific requirements of the CPRT Program Plan.
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, Page 7 of 11 l RESULTS REPORT ISAP VII.a.3 (Cont'd) f 4.0 CPRT ACTION PLAN (Cont'd) >
4.4 Standards / Acceptance Criteria
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Programs and procedures were evaluated for adequacy against applicable portions of the CPSES TSAR and 10CFR50, Appendix B Criterion VI, including the following:
l 4.4.1 That procedures are established to assure that j documents are available at the location where the activity will be performed prior to commencing the
! work.
4.4.2 That procedures are established to assure that obsolete or superseded documents are removed and replaced by applicable revisions in work areas in a timely manner.
4.4.3 A document control system is established to identify the current revision of controlled documents.
f 4.4.4 That the Results Report of Action Plans III.d -
"Preoperational Testing" and VII.c " Construction Reinspection / Documentation Review" provide reasonable I
assurance that items of concerns related to document
- control prior to July 1984 had no adverse impact on either testing conducted or the quality of installed
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l hardware or if, in fact, anomalies are identified, j appropriate corrective measures are indicated in the report.
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5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS i As stated in Section 4.0 of this report, the implementation of this i
ISAP consists of an evaluttion of the results of the implementation
{ of ISAPs III.d and VII.c. specifically the evaluation of the j results of any root cause and generic implications analyses which i
! were performed as a result of identified deficiencies or adverse j trends. The results of this evaluation are discussed below:
3 5.1 ISAP III.d "Preoperational Testina"
{ This ISAP was designed, in part, to determine if past problems with the operation of the DCC had resulted in adverse effects on the prerequisite or preoperational testing program activities.
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R:visient 1 Pcgo 8 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd) 5.0 IMPLFM!NTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
As documented in the CPRT Results Report for ISAP III.d.
Revision 1, there were no deficiencies or adverse trends identified as a result of its implementation. The report also stated the following in Section 5.4.2:
"The CPRT evaluation provided ninety-five percent confidence that at least ninety-five percent of the design changes which could have affected the prerequisite and preoperational testing due to document control center problems did not adversely affect these programs."
In addition, the following is stated in Section 6.0:
"The results of this evaluation' provide reasonable assurance that the document control problems which existed prior to 1984 did not adversely affect the testing program".
5.2 ISAP VII.c " Construction Reinspection / Documentation Review Plan" This ISAF was designed to provide reasonable assurance that the safety-related plant features have been installed and inspected in accordance with current design information.
As described in ISAP VII.c 'the safety-related plant features were divided into thirty-two (32) populations for purposes of investigation and analysis. During its implementation, over 565,000 inspections and document reviews were performed. As a result, approximately 16,000 deviations were identified. From the issues raised by these deviations, Construction
! Deficiencies, adverse trends and unclassified trends have been I
identified that have resulted in approximately forty (40) root cause analyses being performed under ISAF VII.c.
l A review of the results of these root cause analyses l identified no case where a Construction Deficiency, an adverse i trend or an unclassified trend resulted from inadequate
! implementation of the document control program through the DCC.
! Although the reinspection portion of ISAF VII.c is essentially
! complete, the final evaluation of all data is incomplete. As I a result, thsre exists a potential for an adjustment in the total number of Construction Deficiencies and trends, and O therefore the number of root cause analyres required. Initial reviews of the remaining data indicate t ut no new issues
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e R vioicnr 1 Peg 2 9 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) involving the DCC are being raised and therefore any additional root cause analyses would not likely identify inadequacies in the implementation of the document control program through the DCC.
5.3 Review of Current Program Current operation.of the DCC is described in procedure DCP-3, "CPSES Documanc Control Prograa," Revision 19, dated March 31, 1986. Based on the review of this procedure, it is concluded that it provides adequate controls to ensure compliance with the applicable requirements of 10CFR50 Appendix B, Criterion VI and the CPSES FSAR as described in Sections 4.4.1 through 4.4.3 of this report.
In order to obtain a measure of the effectiveness of the current DCC operation, the following information was obtained relative to the operation of the DCC over the past yeart b)
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During the implementation of ISAP VII.c. approximately 23,000 drawings and drawing changes were requested from the DCC and/or satellites. Based on information from the QA/QC Review Team participants, it was determined that the overall error rate of documents received from the DCC was extremely low and did not affect VII.c results.
In an interview with the head of the CPSES Monitors Team, who is responsible for monitoring the performance of the DCC and Satellites, he stated that the incidence of errors in the DCC and Satellites is less than one tenth of one percent (0.1%). A review of the Executive
, Summary Reports of monitoring activities for the past
! year supports this figure.
i i It is therefore concluded that the controls for, and operation
! of, the DCC pertaining to the distribution of drawings and drawing-changes is satisfactory.
1 i 5.4 Closecut of Related External Issues i
l 5.4.1 The issue of the alleged use of uncontrolled and i
unauthorised procedures for cold-springing of piping is i addressed in the Results Report for ISAP V.e. This report concluded, in Section 6.0, that " . . . no such 1 misapplication (of a Bechtel procedure) occurred."
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R:,visien t 1 Pegs 10 of 11 .
l RESULTS REPORT G ISAP VII.a.3 (Cont'd) i i >
l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 1 5.4.2 TUGC0 responded to the issue concerning the " Controlled Copy" stamp in a letter to the NRC (TXX-4180, dated May 3
25, 1984) stating that control stamps were used by Brown & Root ASNE QA personnel for a short period of
, time. The stamps were applied to drawings forwarded to I
the Authorised Nuclear Inspector (ANI) for review.
l These drawings were not used for construction. TUGC0 -
j determined that this activity had no safety significance -
l or generic implications. No subsequent NRC <
l-correspondence (except SSER 11) was noted which applied ,
to this issue. e i i The NRC concluded in SSER 11 that " Issuance of the stamps to QC had no significant safety implication in ;
! the erection, fabrication, or construction of
- safety-related systems, components, and structures, and l the TRT found no evidence that there was a loss of l hanger drawing control as a result of the QC department's stamping of the hanger drawings of concern."
! 5.5 Evaluation of Findings 5.5.1 Because ISAP III.d identified no safety-significant i
deficiencies or adverse trends, no root cause analyses i
- were required. Therefore no further actions are
! required in relation to ISAP III.d results.
i 5.5.2 ISAP VII.c identified safety-significant deficiencies.
l adverse trends and unclassified trends. Over 40 root l cause analyses were performed. Because no root cause i or contributing cause was attributable to document control inadequacies, no further actions are required <
l in relation to ISAP VII.c results.
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! '5.5.3 As a result of the review of the results of ISAPs III.d
{ and VII.c. and the review of the current program, it is i determined that no remedial actions are required.
4 5.5.4 The final evaluation of ISAP VII.c data as well as i ISAPs other than III.d and VII.c may identify ;
i safety-significant deficiencies and/or adverse trends i
! whose root cause is identified as inadequacy in the
! do:usent control program. Should this occur, a j reassessment of the results of this ISAP will be l conducted by the QA/QC Review Team's Collective Evaluation Group after the results of other ISAPs are [
! issued. '
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R:visient 1 Pass 11 of 11 RESULTS REPORT ISAP VII.a.3 (Cont'd)
6.0 CONCLUSION
S The QA/QC Review Team believes that the actions taken through ISAPs l III.d and VII.c respond to the TRT concern contained in SSER-11 i that " . . . implications of past (document control] inadequacies on construction and inspection have potential generic significance j which has not been fully analysed by TUEC."
i It is concluded, based on the findings of ISAPs VII.c and III.d, that there is reasonable assurance that currently there are no i adverse hardware conditions in the plant resulting from past l problems with the operation of the DCC.
However, because of on-going work, modifications, and the several j verification activities that have been performed throughout the plant life, no statement can be made as to whether or not adverse hardware conditions had ever been caused by DCC problems.
] 7.0 ONGOING ACTIVITIES No ongoing activities have resulted from implementation of this Action Plan.
8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE No actions to preclude occurrence in the future are required.
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