ML20198C859

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Partially Withheld Assessment of Allegations AQ-17,AQ-18, AQ-42,AQ-58,AQ-101,AQ-104,AQ-107 & AQE-9 to Category Qa/Qc 2, Document Control Re Use of Partial Packages During Insp
ML20198C859
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 8605230076
Download: ML20198C859 (6)
v • d • e


Text

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1. Allegation Category: QA/QC 2, Document Control
2. Allegation Number: AQ-17, AQ-18, AQ-42, AQ-58, AQ-101, AQ-104, AQ-107 and.AQE-9
3. Characterization:- It is alleged that there was a lack of control of design document packages (AQ-17, AQ-18, AQ-58); that craftsmen and QC inspectors were provided with obsolete or partial (uncontrolled) design document pack-ages during construction (AQE-9, AQ--42); that individual documents were issued against travelers per telephone request (AQ-107); that a document control center (DCC) supervisor authorized the release of partial document packages to.the field (AQ-104); and that the DCC cathode ray tube (CRT) group was not notified when documents were obtained by the " phone. bank"

.and,the distribution routing contro1~ lists printouts were not updated (AQ-101). .

4. . Assessment of Safety Significance: The issues and. concerns identified by the allegers were for the control of design documents relating to-safety-related hardware constructed and installed at Comanche Peak Steam Electric Station (CPSES). The TRT confined its assessment of these allegations to safety related hardware design docum'nte control for the period from August 1981 through June 1984. (The TRT's assessment of the document control system during July, August, and September 1984, is contained in QA/QC Category-2, allegations AQ-16, 57, 59, 60, and 61.)'

The NRC Technical Review Team (TRT) compared Brown and Root (B&R) procedure DCP-3, Rev. 18, "CPSES Document Control Program," to the requirements of ANSI N-45.2 and found it to be acceptable.

The TRT addressed allegations AQE-9, AQ-17, AQ-18, AQ-42, and AQ-58, by reviewing Texas Utilities Electric Company (TUEC) audit reports, monitoring discrepancy reports (MDRs), and TUEC monitoring team executive summary

-reports. These TUEC reports were issued from' August 1981~through July 1984, and identified the following deficiencies for civil, structural, .s electrical, mechanical, and piping safety-relat.ed systems. ~

a. Drawings in the field were not of the latest revision.
b. Design change authorizations (DCAs) and component modification cards (CMCs) were not of the latest revision.
c. Design documentation was missing.
d. Satellites were not always updated with the latest design document revision.
e. Drawings hanging in an open rack were available to craft and QC personnel with no checkout control.
f. Design change log books were not maintained.
g. Superseded copies and current copies of design documents were filed together.

8605230076 860512 PDR FDIA 0-95 GARDEDS-59 PDRA-

h. Satellite distribution lists were not updated and current.
1. Discrepancies were found between drawings in the satellites and those in the DCC. '

J. . Drawings were missing from the satellite files.

It was determined by the TRT that the above deficiencies were of a recur-ring nature. Therefore, it appears that any corrective actions taken by TUEC based upon these deficiencies were ineffective.

In order to evaluate the consequences of the recurring documentation defi-ciencies, the TRT reviewed a sample.of completed safety-related documenta-tion packages stored in the TUEC permanent plant records vault (PPRV).

Completed records covered the period of December 1977 to June 1984. In-cluded in the packages were documentation for piping, piping supports, assembled and/or installed components, fabrication and inspection / testing

, data including walkdown inspection check *1ists and applicable N-5 data reports. It was noted that checklists, inprocess inspections, final in-spections and acceptances for completed work packages were performed to the latest revision of the design drawings. While reviewing hanger records, the TRT found, in the sample selected, that the design analysis had been performed in accordance with final as-built revisions of the applicable drawings. The TRT did not analyze the adequacy of design. (For details concerning the adequacy of the procedures governing the design processes, see QA/QC Category 1, allegation AQ-90.)

The allegation (AQ-101, AQ-107)_that craft and QC personnel requested individual documents using traveler numbers was assessed by interviewing DCC personnel and reviewing DCP-3 for traveler document requirements. The personnel interviewed referred the TRT to the DCC organization chart which included a " phone bank." The phone bank was established in approximately September 1982, to expedite the issuance of information copy documents.

From a phone request,'DCC would generate a copy of the requested document.

However, the document was not to be issued until DCC received a completed control distribution request form containing'the required approval signa-tures in accordance with DCP-3, Revisions 13 through 18.

The review of DCP-3, Paragraph 3.4, Revision 13, indicated that documents could be released for inclusion into a traveler provided they were iden-tified with the stamp, "The document shall be used only in conjunction with Operation Traveler # .

The organization accountable for controlling the package was responsible for assuring that the current document revision number was referenced in the package.

Further review of the DCP-3, Revisions 13 through 18, revealed that uncon-trolled distribution of design docum,ents was allowed provided they were not used for production activities and were appropriately marked "Informa-tion Only," "For Office and Engineering Use Only," or, when required, "This Document Affected by Design Changes."

0-96

The DCC personnel interviewed confirmed that documents requested by the satellites from the phone bank were not always reported to the DCC CRT group, which was responsible for updating the controlled distribution lists. This resulted in the satellites and/or others not receiving subse-quent revisions of the document. Such actions constitute a procedural violation to DCP-3, 10 CFR Part 50, and ANSI N45.2. Since the types of documents obtained from the phone bank were not used for construction or engineering analysis, the violation was generic, but not safety significant.

However,'the TRT learned that, the DCC supervisor took action in March 1984, to enforce the requirements of DCP-3, upon discovering that the CRT group was not consistently informed when satellites obtained documents from the phone bank. This was accomplished by requiring each requester to deliver a completed " Controlled Distribution Request" to the CRT prior to receiving the requested documents. The action assured that the CRT group was notified when the satellites received a document. The distribution routing control list was then updated accordingly. The TUEC monitoring team executive summary reports confirmed that the corrective action prevented recurrences.

The TRT assessed the allegation (AQ-104) that a DCC supervisor authorized the release of individual documents by interviewing satellite clerks who were onsite at the time this incident supposedly occurred. The B&R satel-lite clerks interviewed stated they had never been instructed by DCC super-vision or management to release partial drawing packages to craft and QC personnel. Rather, they were required to follow procedures prohibiting the issuance of individual design documents.

5. Conclusion and Staff Positions: The review of TUEC audit reports, MDRs, and monitoring team executive reports substantiated the allegations (AQ-17, AQ-18, AQ-'42, AQ-58, AQE-9) to the extent that there were deficiences in the control of design document packages and that obsolete and/or partial documents were available to craft and QC personnel which could have been used in the fabrication, installation, and inspection of safety-related-hardware from August 1981 through June 1984. However, the review of the completed safety-related quality records in the PPRV indicated that draw-ings used for inspection and fabrication were performed to the latest revision.

The interview with DCC personnel substantiated the allegations (AQ-101, AQ-107) that the phone bank released design documents to the satellites without notifying the CRT group to update the distribution list. As a result, some design documents were not updated with the latest document revisions.

The allegation (AQ-104) that a DCC supervisor authorized the release of individual documents could not be substantiated. Satellite clerks inter-viewed stated they had never been instructed by DCC supervision or manage-ment to issue incomplete dre. wing packages.

In a meeting with an alleger on November 27, 1984, the TRT presented the results of the assessment for allegation AQ-17 and the TRT's conclusion.

There were no specific items of disagreement, and no additional concerns 0-97

or allegations were identified. An appointment was made to discuss allega-l tion AQ-18 and a portion of allegation AQ-17 with the cognizant alleger.

However, the alleger did not keep the appointment. Allegations AQ-9, AQ-42, AQ-58, AQ-101, AQ-104, and AQ-107 were issues and concerns not identified by allegers. Therefore, no closecut interviews were conducted for these concerns and issues. _

7. Attachments: None.

Reference Documents: -

1. Work Packages:
a. RC-1-BR-046
b. AF-1-58-007
c. AF-1-58-006
d. AF-1-58-006
e. FST-1-1207-01-A-01
2. TUGC0 Audit Reports:
a. TCP-23
b. TCP-40
c. TCP-68
d. TCP-84
e. TCP-99
3. Surveillance Reports:
a.82-019
b.82-020
c.82-021
d.82-023
e.83-015
f.83-016 l
g.83-017 0-98 l
h.83-018
1.83-020
j.83-027
4. TUEC Monitoring Team Executive Summary Reports 1 through 12.
5. Procedure DCP-3, Revision 0 through 18, "CPSES Document Control Pro-gram," and " Operating Instructions for DCC Satellites," dated October 24, 1983.
6. Hanger Numbers (see QA/QC Category 1, AQ-22).
7. Source Documents:
a. GAP 2.206 Petition, March 19, 1984, Item 8 and A-2 Statement.
b. A-2 letter, item 4, and A-5 letter item 3.
c. Procedure Q4-84-014.

, d. A-15 testimony, page 46.

e. Region IV Report, "New Issues," D. Norman to R. Bangart.
f. TXX-4187.
g. Region IV Inspection Report 50-445/81-04; 50-446/81-04.
8. Internal memo establishing TUEC DCC Monitoring Team reportability to senior management, dated March 30, 1984.
9. A-5 closeout interview, November 27, 1984, pages 105 to 115.
10. ANSI N45.2, "Qualty Assurance Program Requirements for Nuclear Facili ties."
11. TUEC Procedures:
a. CP-QP-19.0, Rev. 2, " Audits."
b. DQI-CS-4.6, Rev. 7, " Conduct of Internal, Prime, and Subcontractor Audits."
c. CP-QP-15.7, Rev. 2, " Tracking of Audit Reports / Corrective Action Reports."
d. CP-QP-1, Rev. I and 2, " Indoctrination Training of TUGC0 QA Personnel."
8. This statement prepared by: #//L M w, [

V. Wenczel,'~TRT d'  % Date Technical Reviewer

' ~

Reviewed by: 148</76 4 b 3 li. Livermore, Date Group Leader Approved by:

V. Noonan, Date Project Director 0-99

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