ML20198D348

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Partially Withheld Assessment of Allegations AQ-49,AQ-74 & AQ-125 to Allegation Category Qa/Qc 3 Records Re Loss of Permanent Qa/Qc Const,Fabrication,Installation & Insp Records During Various Stages of Completion
ML20198D348
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59 NUDOCS 8605230225
Download: ML20198D348 (6)
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1. Allegation Category: QA/QC 3, Records
2. Allegation Number: AQ-49, AQ-74 and AQ-125
3. Characterization: It is alleged that permanent QA/QC construction, fabri-cation, installation, and inspection records were lost during various stages of record completion.
4. Assessment of Safety Significance: Because these allegations were general in nature, the NRC Technical Review Team (TRT) assessed them for both iso-lated and generic. implications. The alleger's concerns addressed the loss or misplacement of QA/QC records which documented inprocess and completed fabrication and inspection activities performed at Unit 1. These records typtr: ally documented activities for welding, process control, inspection, installation, testing, nonconformance, and corrective action disposition.

Allegations AQ-49 and AQ-74 addressed the loss of individual weld data cards, a: well as the possible loss of hundreds of entire documentation packages for ASME Code hanger. The specific weld data card cited was CC-1-087-004-A33A. Typically, a documentation package contains weld data cards, inprocess and final inspection reports, drawings, vendor documenta-tion, nonconformance reports (NCRs), and ASME Code data reports. In an interview with the TRT, the alleger disclosed that the lost records were apparently found. Notwithstanding the resolt. tion of the alleger's con-

cerns, the TRT assessed the potential loss of QA/QC records for generic implications.

In mid-1983, a joint Texas Utilities Electric Company (TUEC) and Brown &

Root (B&R) task force was organized for the control and management of ASME componentsupports(hangers). The task force mission was to verify that design, fabrication, installation, inspection documentation, and assembly activities were performed adequately and in the correct sequence. Part of the task force responsibilty was to initiate 'and/or track documentation packages. ASME Code,Section III, subsection NA, requires that ASME in-sta11ations and hardware be certified in accordance with Code requirements.

At Comanche Peak Steam Electric Station (CPSES), this effort included assuring that QA/QC records were generated and completed to support con-struction and inspection activities. In addition, the ANI (the Authorized Nuclear Inspector, an independent third party) was required to review, concur, and approve ASME documentation / records requiring certification.

Prior to certification, the records were placed in the construction records vault. To assure adequate control of the records, appropriate processing was established to prevent unauthorized removal from and updating to docu-mentation packages in the vault. If documentation could not be located during record's inspection prior to certification, an NCR was generated and resolved in accordance with approved procedures. The dispositioning of NCRs has resulted in the removal of hangers and piping (or portions thereof) and their replacement.

Of the approximately 17,000 ASME Code pipe supports for Unit 1, 15 have been totally or partially refabricated because of lost records. (The reconstruction of weld data cards is addressed in allegation AQW-67 of Mechanical and Piping Category 25 and allegation AQ-67 of Mechanical and

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860512 4- 0-105 s emose5-e,_.. ran i ,

Piping Category 8 in " Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station" (NUREG-0797, Supp. No. 10). The reconstruction of the lost weld data card (No. CC-1-087-004-A33A) cited in this allegation was reviewed and found acceptable by the TRT. The method used for examining records accountability for support hangers was also used for ASME piping and related hardware.

i. l For non-ASME documentation, a similar verification program was established

, for Unit 1. Non-ASME documentation deficiency resolution was accomplished either by constructing new records from reinspection and supporting docu-

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. mentation or by hardware removal and replacement.

Allegation AQ-125 concerns construction travelers that were possibly lost by the paper flow group (PFG). Construction travelers were issued to the

' craft personnel and controlled by the PFG. Included in the packages were fabrication, inspection, vendor documentation and other supporting docu-i mentation. Excluded were design documents, such as drawings, component modification cards (CMCs), and design change authorizations (DCAs) which p were provided by the document control center or satellite.

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Traveler packages were prepared in accordance with B&R procedure CP-CPM 6.3,

' Revision 10, " Preparation, Approval, and Control of Operational Travelers."

The PFG listed package items in the computer data base as inprocess and completed an inventory card identifying each document in the package. When i

the. package was issued, the inventory card was removed, the name of the person to whom it was issued was entered as the package holder, and the card was filed in the package " outstanding" file to account for the package.

4 The contents of the documentation package were checked against the inventory i

card by PFG personnel prior to issuance and again upon return or completion ,

of work to' assure required documentation was present and correct to the cur-

['

rent revision. Under normal conditions, packages were issued ~at the begin-ning of each work shift and returned at.the close of the shift. Completed

[ packages were forwarded to the QA/QC records review group for final QA/QC review. The data base was then updated'to reflect its completed status.

For documents found missing during the PFG inventory of package contents, an NCR was written to document the discrepancy and to initiate corrective

-action.

Each new or transfered PFG employee received training that covered job responsibilities, scope of work, specific assignments, and procedures directing work activities. On-the-job training was also given until the

[ employee was adequately trained to function independently of supervision.

, The TRT' reviewed documentation verifying that PFG personnel received this indoctrination and training.

J In assessing AQ-125, the TRT determined that PFG personnel had received adequate classroom and on-the-job training to be competent in performing i their work. Because of the self regulating document accountability system, t

.any loss of records would have been detected by the PFG, as previously

described.

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5. Conclusion and Staff Positions: The TRT evaluated TUEC's and B&R's proce-dures governing permanent QA/QC records, accountability, and preservation and found them to be in compliance with the ASME Code, 10 CFR Part 50, Appendix B, and ANSI N45.2 requirements. Procedure implementation was verified by TRT reviews of documents and records supporting the construc-tion and inspection activities for selected ASME hangers, components, and piping. Document deficiencies relating to the partial ar complete loss of work packages were reported on NCRs for corrective action. In these cases, reconstruction or replacement of lost records was done in accordance with approved procedures. Such documentation was subject to the same review and approval as the original records received. Accordingly, an effective program exists for the accountability of permanent records supporting construction and inspection at CPSES.

The TRT found that the allegations that construction, fabrication, instal-lation, and inspection records were lost has been substantiated. However, the losses were not of the magnitude first alleged, (i.e., " hundreds" of; entire documentation packages), nor were losses attributable to the lack of competence of the PFG. 'Accordingly, these allegations do not have generic implications.

On December 10, 1984, the TRT met with the alleger and presented the AQ-74 findings and conclusions. The alleger presented further examples of lost document packages. These document packages were a part of the review conducted by TRT, as reported above. The alleger associated with AQ-49 declined further contact with TRT, thus no meeting was conducted. The source of AQ-125 was not an alleger.

7. Attachments: None.

Reference Documents:

> 1. ASME Section III, " Nuclear Power Plant Components."

2. ANSI N 45.2, "QA Program Requirements for Nuclear Faci M tics."
3. ANSI N 45.2.9, " Requirements for Collection, Storage,'and Maintenance of QA Records for Nuclear Power Plants."
4. Procedu'res :
a. QI-0AP-11.1-25, Rev. 8, "QA Review of ASME III Documentation."
b. CP-QAP-12.1, Rev. 11, "ASME Section III Installation, Verification, and N-5 Certification."
c. CP-QAP-11.1-28, Rev. 25, " Fabrication and Installation Inspection of Safety Class Components."

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d. CP-QAP-18.2, Rev. 3, " Quality Assurance Review of ASME Documentation."
e. CP-QP-18.2, Rev. 2, " Implementation of the Permanent Plant Records Management System."
f. FP-QP-18.3, Rev. 2, " Permanent Plant Records Systems Organization."
g. CP-QP-18.4, Rev. 2, " Permanent Plant Records Receipt Control and Storage." ,
h. CP-QP-18.5, Rev. 2, " Automatic Records Management System Implementation."
i. CP-QP-18.6, Rev. 2, " Record Turnover to TUGC0 Operations Group."

J. CP-QP-18.7, Rev. 9, "N-5 and N-3 Code Data Reports."

k. CP-QP-18.8, Rev. 1, " Records Verification."
1. CP-QAP-11.1, Rev. 3, " Fabrication and Installation Inspection of Components, Components Supports, and Piping."
m. CP-QAP-16.1, Rev. 20, " Control of Nonconforming Items."
n. CP-QAP-12.1, Rev. 8, " Inspection Criteria and Do.cumentation Requirements Prior to System N-5 Certification."
o. CP-QAP-18.1, Rev. 2, " Processing QA Records."
p. CP-CPM 7.1, Rev. 1, " Package Flow Control," and Appendices 7.1A through 7.11.
q. CP-CPM 6.3, Revision 10, " Preparation, Approval, and Control of Operation Travelers."
5. NCRs M-12988, M-12997, M-12820, M-12807, M-7368, M-6953, M-7370, M-7371, M-10156, M-10403, M-12816, M-10814, M-7369, M-7372, M-10419, M-13319, M-13241, M-13566, M-6440, M-6435, M-9767, M-14560.
6. AQ-49; Interviews with alleger A-13, page 20, and alleger A-1, pages 4 and 9, dated August 1, 1984.
7. AQ-74; A-1 Statement, A-1 Interview pages 24-37, dated April 6, 1984, A-1 Interview pages 4-9 dated August 1, 1964, TUGC0 letter TXX4180 (B. R. Clements to D. G. Eisenhut) dated May 25, 1984.
8. AQ-125; NRC Special Review Team Report, dated July 13, 1984, page 70.

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This statement prepared by:

V. Wenczel,viRT

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Technical: Reviewer Reviewed by: / wat H. Livermore, hDate k [

Group Leader Approved by; V. Noonan, Date Project Director F

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