IR 05000445/1988010

Insp Repts 50-445/88-10 & 50-446/88-08 on 880203-0301.No Violation or Deviation Noted.Major Areas Inspected:Actions on Previous Insp Findings,Followup on Violations/Deviations, Operations Work Order Process & Records Mgt

ML20148D550
Person / Time
Site:	Comanche Peak
Issue date:	03/18/1988
From:	Hale C, Livermore H NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20148D523	List: IR 05000445/1988010 ML20148D518
References
50-445-88-10, 50-446-88-08, 50-446-88-8, NUDOCS 8803240078
Download: ML20148D550 (21)

Text

_

.. _

. - -,

,

.-

t s

e

,

-

.

'j,,'

>

U.S. NUCLEAR REGULATORY' COMMISSION OFFICE OF SPECIAL PROJECTS-

,

,

NRC : Inspection Report:

50-445/88-10 Permits: CPPR-126 50-446/88-08 CPPR-127 Dockets: 50-445 Categor'1: A2 t

50-446 Construction-Permit Expiration Dates:

Unit 1: August 1, 1988 Unit 2: Extension request submitted.

Applicant:

TU. Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:

Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2 Inspection At:

Comanche Peak Site, Glen Rose, Texas Inspection Conducted:

February 3 through March 1, 1988-Inspecto :

@ ht U 3 -LY-P pq C.

J. Hale, Reactor Inspector Date Consultants:

V. Wenczel, EG&G (paragraph 4.)

J. Birmingham, Parameter (paragraph 3.,

6.,

7.,

and 8.)

Reviewed by:

/A4W/2.V 5//

FI H. H.

Livermore, Lead Senior Inspector Date 8803240078 880318 PDR ADOCK 05000445 O

DCD

O

'

.

.

Inspection Summary:

Inspection Conducted: February 3 through March 1,1988 (Report 50-445/88-10; 50-446/88-08)

Areas Inspected: Unannounced, resident safety inspection of applicant actions on previous inspection findings, follow-up on violations / deviations, operations work order process,. records management, senior review team overview of project corrective

. actions, QC inspector qualification / certification, qualification of engineering personnel, and general plant areas (tours).

~

Results:

Within the areas inspected, no violations, deviations, or unresolved items were identified.

The QC inspector qualification and certification program continues to be effectively implemented.

The records management program (RMP) has been well documented in controlled procedures; however, weaknesses appear to exist in the RMP and will require further NRC inspectio,--

.

..

-

.

.

.

..

.

'

,

,

DETAILS 1.

Persons Contacted M. D. Bever, Supervisor, Internal Audits, TU Electric J. T. Brackney, Project Manager, Records, TU Electric D.

L. Davis, Results Engineering Manager, TU Electric J. W. Donahue, Shift Supervisor Manager, TU Electric C. G.

Garner, Records Management Supervisor, TU Electric T.

L.

Heatherly, Regulatory Compliance Engineer, TU Electric C. W.

Killough, Corrective Action Supervisor, TU Electric D. W.

Leigh, Supervisor, Vendor Compliance, TU Electric B. M.

Palmer, Comanche Peak Review Team (CPRT) Commitment Coordinator, Delian A.

R.

Summers, Supervisor, Operations Records Center, TU Electric W. C. Westhoff, Supervisor, Technical Audits, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.

2.

Applicant Action on Previous Inspection Findings (92701)

a.

(Closed) Unresolved Item (445/8514-U-05; 446/8511-U-05):

TU Electric procedures did not appear to address all elements of ANSI N45.2.9.

(This is the same issue identified as ID Recommendation 25 in Enclosure 1 to Stello's memorandum, "Implementation of Recommendations

of Comanche Peak Report Review Group," April 14, 1987.

Paragraphs 2.b-f, are also related to ID Recommendation 25.)

Prior to 1987, the TU Electric records program had been established to be. responsive to ANSI N45.2.9; however, each site organization developed and implemented procedures based on their scope of work and records commitments.

For example, records of design and

construction activities were controlled by procedures developed to comply with ANSI N45.2.9, Draft 11, while

,

the records from startup and operations activities were developed to comply with ANSI N45.2.9-1974.

In reviewing this unresolved item, the NRC inspector did not attempt to reconstruct conditions as they existed in 1985, rather

.

an inspection of the current program was conducted to j

verify compliance with ANSI N45.2.9.

In early 1987 the Records Management Program (RMP) was established.

The RMP centralized the records management function by the issuance of the RMP procedures manual which applies to all site organizations that are or will be generating records.

These procedures were inspected by the NRC during this report period and found to bc l

-,.

, - _.

_ _ - - _. - _ _ _,

,,

.

-

.

.

_.

_

_

._

_

.

__

_ _

,

'.

'

.

responsive to the requirements of ANSI N45.2.9.

The details of this NRC inspection are found in paragraph 5.

of this report; accordingly, this item is being closed, b.

(Closed) Open Item (445/8514-0-02; 446-8511-0-02):

Two water leaks from the roof have continued to exist in the Interim Record Vault (IRV).

The NRC inspector performed an inspection of the IRV on February 22, 1988.

On February 18, 1988, the site experienced a hard, wind-driven rain.

The NRC inspector interviewed IRV personnel to determine if any roof leaks were observed during the February 18, 1988, rain storm.

The IRV personnel stated that no leaks have occurred since the repair in 1986.

The NRC inspector checked the areas of the previrusly identified leaks.

While the file cabinets, F'

ly under the leak locations showed some evidence c. tust, an inspection of the condition of the records inside these file cabinets did not show any evidence of water entering the cabinets or any detrimental effects on the records contained therein.

Since the water leaks have apparently been corrected and no record damage appears to have occurred, this item is being closed.

Further, current plans are to close the IRV and the' Permanent Plant Records Vault (PPRV) in the near future by transferring all records to a new records facility.

Construction of the new records facility is complete and only its certification as being constructed in compliance with ANSI N45.2.9 requirements remains.

During the 50-445/85-14; 50-446/85-11 inspection, the NRC inspector noted that food and drink were located in the IRV.

These items were removed immediately.

Since that inspection, both the IRV and the PPRV have been modified.

The modification included relocating the vault personnel's desks outside the vault area and all other activities not directly associated with the storage of

records.

These actions were effective in preventing a l

recurrence of the conditions noted by the NRC inspector.

I

c.

(Closed) Unresolved Item (445/8514-U-08; 446/8511-U-08):

(

The absence of an internal fire suppression system for the PPRV appears to deviate from the requirements of ANSI i

i N45.2.9.

I l

The PPRV does not have an internal fire suppression

!

system; however, ANSI N45.2.9 does not clearly require that such a system be internal to the storage facility.

'

Fire protection is provided to the PPRV by several means:

the fire retardant construction of the facility; internal

.

.

-

.

fire detectors and alarms which alert local personnel, as well as, the onsite fire department that is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day; and hand held extinguishers which are available for immediate use by vault personnel.

The PPRV was established in the late 1970s.

At times in the past it was considered as a permanent repository.of plant construction records.

This is no longer the case.

The Project Manager, Records, has placed a request to engineering that the new records facility, mentioned in paragraph 2.b above, be inspected for certification as meeting ANSI N45.2.9.

All the records presently in the PPRV will be transferred to the new facility and the PPRV eliminated.

This transfer will occur after the facility has been certified and the new rolling files have been installed.

No firm date has been established for this transfer, but indications are that it will occur in April 1988.

The certification of the new facility and the transfer of the PPRV records will be monitored by the NRC inspector and tracked as an open item (50-445/8810-0-01; 50-446/8808-0-01).

While the PPRV appears to comply with-commitments and requirements, any continuing areas of concern about the PPRV will be resolved with the abolishment of the PPRV; accordingly, this unresolved item is being closed and the transfer of the PPRV records is being tracked as an open item.

d.

(Closed) Unresolved Item (445/8514-U-10; 446/8511-U-10):

Procurement records were in uncontrolled storage in Warehouse A.

The NRC inspector reviewed the documents remaining in Warehouse A, about 30 to 40 file cabinets.

While access to Warehouse A is controlled, record preservation requirements were lacking.

The NRC inspector did not find any required QA records being stored in Warehouse A.

The procurement records previously found in Warehouse A had been moved to another building.

The NRC inspector reviewed the new location of these procurement records and found that more direct control and preservation

'

measures had been established; however, a review of the documents being retained indicated these documents were carbons or photo copies of the procurement documents.

If only duplicates of procurement records are stored in this new location, the requirements of ANSI N45.2.9 have been satisfied.

The NRC inspector will review this records storage area further to determine if single records are being retained, then if this be the case, verify that

-..

.

-

..

_ - -

.

. _ = -. _ -

-

.

- _ - -.

N

'

'

,

proper storage requirements are being provided

~

(445/8810-0-02; 446/8808-0-02).

Since the QA records in Warehouse A have been moved to a more controlled location and it appears that the new location is a duplicate storage area (to be verified by further NRC inspection), this unresolved item is being closed, e.

-(Closed) Unresolved Item (445/8514-U-ll; 446/8511-U-ll):

There was no evidence that TU Electric had responded to an Ebasco study that identified records management inadequacies.

Since the identification of this unresolved item, the applicant has initiated and completed a comprehensive study of the TU Electric records _ management. This study, performed by Stone and Webster Engineering Corporation (SWEC), was completed in June 1986.

The SWEC study included and went beyond the study performed by Ebasco.

The recommendations coming out of the SWEC study have been or are being implemented by TU Electric, consistent with the current status of project record activities.

A discussior of the SWEC study and an inspection of the current RMP is provided in paragraph 5. of this report.

It is difficult at this time to determine what if any actions were taken by TU Electric based on the June 1981 Ebasco study.

Several changes in the records program have occurred since 1981.

In any case, the SWEC study completed in 1986 and the recommendations, essentially implemented by early 1987, did respond and go beyond the findings of the Ebasco study; accordingly, this item is being closed.

f.

(Closed) Unresolved Item (445/8514-U-12; 446/8511-U-12):

It had been several years since Brown and Root (B&R) had audited the storage of records in the PPRV.

ANSI N45.2.9 requires periodic audits and surveys of the records storage system.

TU Electric performs yearly audits of the PPRV and the Nk0 inspector reviewed the

audit reports of the PPRV for the years 1986 and 1987 (TCP-86-42 and TCP-87-47).

It appears that the annual audits of the PPRV by TU electric satisfies the ANSI N45.2.9 audit requirements.

This is particularly true

,

l since the PPRV has organizationally been under TU Electric from the time it was established.

The PPRV stores Unit 1 ASME and non-ASME records.

The Unit 1 ASME

,

Section III documentation requirements appear to have l

l been satisfied in the 1984 time fram._.

_

.

-

.

_ _ _ -

. - -

-

_=

.

'

.

,

,

While B&R audits of the Unit 1 ASME documentation have not been conducted for several years, it appears the annual audits of the PPRV by the TU Electric audit-organization have satisfied the audit requirements of ANSI N45.2.9; accordingly, this unresolved item is being closed.

g.

(Closed) Unresolved Item (445/8514-U-07; 446/8511-U-07):

Records were being stored in open faced cabinets in the Operations Record Center (ORC).

(This is the same issue identified as ID Recommendation 33 in' Enclosure 1 to Stello's memorandum, "Implementation of Recommendations of Comanche Peak Report Review Group," April 14, 1987.)

The NRC inspector reviewed the records stored in the ORC.

The hard copy records are placed in folders and stored in open faced rolling files.

Section 5.4 of ANSI N45.2.9 (Draft 11) states, in part, "Records shall be firmly attached in binders or placed in folders or envelopes for storage in containers or on shelving."

This section is essentially the same in ANSI N45.2.9-1974.-

The type of storage provided in the ORC does not violate the requirements of this standard.

Further, the current RMP requires the eventual microfilming of all hard copy records with duplicate and remote storage of the microfilm.

Based on the foregoing, this item is being closed, h.

(Closed) Unresolved Item (445/8514-U-09; 446/8511-U-09):

Records withdrawn from the PPRV and placed in the Paper Flow Group (PFG) were not stored in fire rated cabinets.

(This is the same issue identified as ID Recommendation 34 in Enclosure 1 to Stello's memorandum, "Implementation of Recommendations of Comanche Peak Report Review Group,"

April 14, 1987.)

Prior to 1983 as a design or construction activity was completed, the completed documentation package associated with that activity was trans.* erred to the PPRV for retention.

From experience gained during the construction of Unit 1 a different documentation package concept was adopted for the remaining work ou Unit 2 that was based on the component or commodity instead of the activity.

To implement the revised documentation package concept, the PFG was established in 1983.

All Unit 2 and common records in the PPRV were withdrawn and the PFG developed new documentation packages based on component or commodity.

Then as these documentation packages were completed, they were transferred to the IRV.

This process has remained basically unchanged since 1983.

-

-,. - -.- ----

. -.

- -

-...

-. - -. -. -

- - -,

- - - - -

-- -

. --

_

__ _

_ _

_ _ _.. -.

_

_

_ _ - - _.

.

TU Electric has placed the documents in the PFG in one-hour fire rated cabinets, but consider these as inprocess documents based on their redefinition of what constitutes a completed document package.

The NRC inspector understands the TU Electric position concerning these documents and agrees that based solely on the completed package concept, these packages are inprocess.

Each inprocess package; however, contains documents that have been completed and except for the applicant's completed package concept would require retention consistent with the temporary storage requirements of ANSI N45.2.9.

The NRC inspector has taken the conservative position that the PFG be designated by TU Electric as a temporary storage facility and, as such, compliance with ANSI N45.2.9 be assured.

This position has been expressed to the applicant who is reco sidering their position.

The NRC will track this matter as an open item (445/8810-0-03; 446/8808-0-03).

The NRC inspector reviewed the PFG facility and noted the following features and practices which are consistent with ANSI N45.2.9 requirements:

(1) documents are stored in one-hour fire rated cabinets, (2) access to files is restricted to PFG personnel, (3) a filing system has been established, and (4) document accountability is maintained by package content inventories when the package is checked out and when it is returned.

Based on the fire protection afforded these documents this unresolved item is being closed.

The broader issue of the documents in the PFG being classified as inprocess or completed inprocess documents will be tracked by the NRC as an open item.

3.

Follow-up on Violations / Deviations (92702)

(Closed) Deviation (445/8732-D-02):

During preparation of supplemental verification package I-M-VII.a.9-050-01 eight groove welds and one fillet weld were omitted.

The responsible engineer reviewed the applicable drawings and determined that the welds were improperly omitted from the verification package.

The responsible engineer then issued supplemental verification package I-M-VII.a.9-050-07 to inspect the welds.

The CPRT reviewed all the packages developed by this engineer and determined that the omission was an isolated occurrence.

The NRC inspector reviewed l

supplemental verification package I-M-VII.a.9-050-07 and the

packages developed or worked on by the responsible engineer.

No other omissions were identified.

Based on the review performed by the CPRT and on the NRC inspector's review, this item is closed.

l

l l

- -.., - - - - -. _ -.

--...-n...

-

- - - _ -. -.

-.,_ _

.

,.,.. -. - -

-

- - -. -.-

,

_ _ _.

_

_ _ -.,

__

._

_ _.

.

_.

'.

.

'

.

4.

Review of Operations Work Order Process for Reportability (35061)

The purpose of this inspection was to assure that TU Electric operations Work Orders (WOs), used to correct nonconforming conditions, were subject to review for reportability to the NRC in accordance with requirements and that WOs were trended for initiation of appropriate corrective action.

The following is a : summary of the applicant's WO reportability review and its trend program, the method used by the NRC to inspect these processes, and the inspection results.

The procedure for identifying, processing, and controlling nonconforming conditions is NEO 3.05, "Reporting and Control of Nonconformances."

NEO 3.05 requires that nonconforming conditions, which require engineering review for dispositioning as "repair" or "use-as-is", be documented and processed using a Nonconformance Report (NCR) form.

NCRs are required to be reviewed for reportability and adverse trends.

When nonconforming items can be. reworked, scrapped or replaced, operations may issue a WO to bring the item into conformance, then the issuance of an NCR is not required.

Operations initiates and controls rework, scrap, and replacement activities by implementing procedure STA 606,

"Work Requests and Work Orders."

STA 606 requires that the problem first be identified on a Work Request (WR) form, which is screened for validity.

The valid WRs are used to initiate and develop a WO package.

The WO package provides specific instructions to control and document work activities in correcting the identified problem.

After the WO activities have been completed, the WO package is-reviewed by the operations shift supervisor for reportability to the NRC.

Items identified are documented on a Plant Incident Report (PIR) and forwarded to Results Engineering for processing in accordance with STA-503, "Plant Incident Report."

Results Engineering performs a reportability screening of PIRs, which includes an evaluation to ascertain

,

if a potentially reportable condition exists per the 10 CFR Part 50.55(e) requirements.

PIRs determined to be potentially reportable are forwarded to Comanche Peak Engineering (CPE)

for a second screening and verbal or written notification to the NRC.

With respect to reviewing WOs for adverse trends, STA-606 does not address trending of WOs nor does the FSAR commit to trending of WOs.

To verify that WOs were reviewed for reportability in accordance with STA-606 (Revisions 7 and 8) and STA-503 (Revisions 0 and 1), the NRC inspector reviewed a sample of 14 of 41 closed PIRs.

The time frame covered by the sample was from July 17, 1987, to February 22, 1988.

July 17, 1987, was the beginning of WO review for reportability under STA-606,

-. -

-

-

- --

.-.

- -.

.

..

.

-

.

-

-

. _.

-

- = -

-.

- _. - -

___

.

-

.

-

Revision 7 and STA-503, Revision 0.

In addition, the corrective action supervisor was interviewed to determine if any reviews of conditions corrected by the WO process were being performed to identify adverse trends.

The NRC inspector determined that the 14 PIRs were properly processed and screened in accordance with both STA 606 and STA 503.

of the 14 PIRs, 6 were determined by Results Engineering to be potentially reportable to the NRC and were forwarded to CPE.

Based on CPE's leview, the NRC was notified of the 6 potentially reportable items identified on the PIRs.

The remaining PIRs were found to be not reportable by Results Engineering.

The NRC inspector reviewed the documentation to substantiate the Results Engineering disposition of the PIRs deemed not reportable.

With respect to the review of Wos for potential adverse trends, the corrective actions supervisor stated that Wos were trended, in part.

Those inspection results documented in QC inspection reports from Wos were reviewed for adverse trends; however, the majority of WO activities are documented on other than inspection reports; such as, Wo data sheets.

These documents have not been considered in assessments for potential adverse trends.

Upon realizing this condition existed, the applicant initiated in December 1987 an analysis of the type of trend reviews Wos should receive.

The trend program for W0s is still in the developmental phase; accordingly, the commitment to develop and implement a program to review WOs for potential adverse trends will be inspected further by the NRC (445/8810-0-04; 445/8808-0-04).

In summary, the NRC determined that operations rework, scrap, and repair activities performed to correct identified problems via the WO process were being reviewed for reportability.

The applicant's commitment to develop a program to trend Wo activities will be inspected further.

No violations or deviations were identified.

5.

Records Management I35061)

In June 1986, SWEC performed a detailed records management survey and analysis which resulted in over 50 recommendations proposing revision and enhancement of the TU Electric records system.

By the end of 1987 implementation of these recommendations had either been completed or completion was planned constraent with ongoing record activities.

During this inspect.on, the NRC inspector:

(1)

reviewed the procedural program developed for management of the records system using ANSI N45.2.9 as the basic evaluation criteria; and (2) inspected the implementation of selected elements of the procedural program.

.. _. -. _ -., _ -. -. -,. - _. -.... - _

- -

- -. - - - -.

.-

.-

-

. _

_

.

-

-

_

_

s

'

.

• a.

Procedural Review The development of the procedural program for records began with the issuance of Nuclear Engineering and Operations (NEO) policy statement 38, "Records Management," February 6, 1987.

This policy statement directed the appointment of a Project Manager, Records, and the development and implementation of a corporate records management plan that would integrate and enhance the existing records programs.

As a result of this policy directive, on April 13, 1987, Procedures NEO 2.13,

"Management of Nuclear Power Plant Records," and NEO 2.23, "Turnover of Nuclear Power Plant Records," were issued.

These procedures established the objectives, functions, requirements, processes, and responsibilities for a centralized, integrated records management program.

Based on these upper level documents, the implementing procedures were developed and issued as a controlled document, the RMP Manual.

The RMP Manual contains 28 procedures and guides divided into three sections.

Section 1 of the manual contains procedures which provide specific implementation requirements and responsibilities for all NEO organizations.

Section 2 contains the Records Type List (RTL), the RTL index, and the RTL users guide.

Section 3 contains specific implementation requirements for personnel assigned to the RMP.

All but three of the procedures have been approved and issued for implementation.

All three procedures (two of which are currently in the latter stages of the pre-release review process) relate to activities not presently requiring implementation; e.g.

RMP 3.4,7,

"Archival Film Inspection."

The NRC inspector evaluated each of the above procedures against the requirements of ANSI N45.2.9 No deviations or violations were identified.

Several areas were identified which require further consideration by the applicant and further inspection by the NRC.

A basic purpose of the RMP, as expressed in NEO 2.13, was the centralization of records management activities.

The RMP Manual does provide centralization of records procedures and their control; however, the management of activities associated with records remain somewhat decentralized.

Most noticeable of this lack in centralized management concerns the three record centers being characterized as permanent storage facilities, the ORC, the CPE vault, and the new facility just constructed.

Management of the ORC is from the operations group and engineering manages the CPE vault.

Management of the new facilit; has not been clearly

.

-

-

,

n

.

---

n,-n----.n.

v.

-.nn

-

, - - -, -

..-n,,-----.

.v--..,--

..,v---.

,,--n.-

.--,w.

- -. -

... -. - -,,

-

.

.

.

.

established as yet, but will likely:be under RMP's or construction's control.

Further, Section 5 of ANSI N45.2.9 requires that procedures identify and describe the record storage facilities.

While this information is provided in other procedures, the RMP manual is essentially vcid of this information.

This apparent lack of centralized' management and the identification of the record storage facilities will be inspected further (445/8810-0-05; 446/8808-0-05).

None of the procedures described above provide a process whereby TU Electric verifies all record requirement submittals have been met by vendors, contractors, or onsite record releasing organizations. -The only process identified in other procedures was engineering's verification of records provided on contracts placed directly by TU Electric.

The process by which TU Electric verifies that all required records are being provided will be inspected further (445/8810-0-06; 446/8808-0-06).

Section 17.1.17 of the FSAR provides, among other things, a description of the permanent onsite records storage facility.

This description does not accurately reflect the current facilities.

This observation was discussed with the applicant and will be inspected further when applicant actions are taken (445/8810-0-07; 446/8808-0-07).

In summary, the procedural program developed by TU Electric provides those controls necessary for turnover, processing, storing, and retrieval of QA records.

The procedures were found to be in compliance with commitments.

Several areas were identified that require further NRC inspection and are being tracked as open items.

b.

Implementation Inspection The NRC inspected the implementation of the following RMP manual procedures:

RMP 1.2.1,

"Control of Intermediate Storage Areas,"

.

Revision 2 RMP 1.2.3,

"Control of Permanent Storage

.

Facilities," Revision 1 RMP 3.2.1,

"Operation of the Records Management

.

Temporary Storage Area," Revision 1 RMP 3.4.2,

"Batching and Preparation of Records for

.

Microfilming," Revision 4 During this inspection, the NRC inspected 23 of the 24 P"4 certified intermediate storage areas (ISAs), all

.

,

three facilities indicated as ultimately being permanent storage facilities (PSFs), and the records management temporary storage area (RMTSA).

The RMTSA is used to temporarily store hard copy records that have been turned over to the RMP and are either awaiting filming or film verification.

The RMTSA indexes turned over records, creates a microfilming batch, prepares the records for microfilming, and verifies-the processed microfilm.

When verified, the microfilm becomas the QA record and at present all hard copies are being boxed and stored onsite.

Two silver halide prints of the verified microfilm are made and stored in separate locations.

Currently correspondence and documents are being microfilmed as they are generated.

The onsite microfilming capability is about 5,000 pages per day; therefore, microfilming of older records is being accomplished at a rate dependent on the microfilming workload.

To date, approximately 2.5 million pages have been filmed.

The projected total pages for the complete project is estimated to be 65-100 million pages.

No violations of RMP procedures were identified in this area of the inspection.

The ORC was identified (not in the RMP procedures) as the onsite permanent records storage facility approved for single record storage.

The NRC inspected the ORC and found that the physical appearance and controls met the ANSI N45.2.9 requirements for a single record storage facility.

The ORC vault had two separate sections.

One section was for the storage of hard copy operations and some construction records.

The other section, physically isolated from the first, was for storage of all site film material and was the site single record storage of radiographs.

This section had a controlled environment and the temperature and humidity were continuously recorded.

The NRC inspected the film storage and the temperature and humidity recordings for the past three years.

For one period in 1985 the humidity exceeded recommended limits for more than the seven days permitted.

An engineering evaluation of the condition of the stored film was performed using a film processing consultant.

The stored film was found not to have been affected by the elevated humidity.

The NRC inspector reviewed the files maintained by the ORC supervisor for an engineering evaluation of the design and construction of the ORC.

While a number of engineering studies of the ORC had been performed which resulted in modifications to the facility, no document could be found that clearly stated that the ORC complied with the construction and fire protection requirements of ANSI N45.2.9.

The CPE vault and the new facility were also inspected by the

,

j NRC.

While neither of these facilities is currently l

.

., - -....

-

-

-

. - _

- - -

-. - - - -. - -. - - -. -, -

.

,

'

designated as permanent storage facilities, the Project Manager, Records, indicated that such use was planned.

An engineering evaluation (construction and fire protection compliance) has been requested, but to date has not been performed.

In this area of the inspection no deviations or violations were identified; however, the engineering review and certification of the design and construction of these three facilities will be inspected when they become available (445/8810-0-08; 446/8808-0-08).

The Project Manager, Records, has certified by inspection that 24 ISAs are in compliance with RMP 1.2.1.

The ISAs are areas within record releasing organizations where documents are accumulated and prepared for turnover to the RMP.

ANSI N45.2.9 does not define an intermediate storage area, the nearest definition is the temporary storage area.

The NRC inspection of the ISAs found a complete spectrum of controls; from preservation, protection, and storage consistent with ANSI N45.2.9 temporary storage requirements, to little more than a file folder that is turned over to RMP when it gets full.

Further, once RMP certifies an ISA there are no periodic surveys or audits to assure continued compliance with the certification requirements.

These observations have been discussed with TU Electric management.

The NRC inspector will review further the intermediate storage definition and the control of ISAs in subsequent inspections (445/8810-0-09; 446/8808-0-09).

In summary, the NRC inspection found that the RMP was being implemented in accordance with procedures.

Several items were identified that require further NRC inspection

,

j and are being tracked as open items.

t 6.

Senior Review Team (SRT) Overview of Corrective Actions for l

CPRT Findings (35061)

The CPRT is responsible for overviewing the corrective actions I

taken for CPRT findings.

The objectives of the overview I

responsibility are defined in Appendix H of the CPRT Program Plan.

Appendix H defines these objectives as:

1) identification and processing of discrepancies, 2) concurrence with the proposed corrective actions for each CPRT finding, and 3) overview of the implementation of the corrective actions.

The responsibilities and the methods by which the responsibilities are to be achieved are defined in CPRT Policy and Guidelines (PAGs) and in Program Directors Instructions (PDIs).

The CPRT accomplished the first of these objectives (identification and processing) during implementation of the Issue Specific Action Plans (ISAPs), Discipline Specific l

l l

.

.

Action Plans (DSAPs), and during the collective evaluations of the quality of construction and QA/QC programs.

The action plans and the collective evaluations have been completed and the findings identified either in the action plan results reports or in the collective evaluation report (CER).

These findings have been transmitted to the applicant for evaluation and action.

The second and third objectives (concurrence and overview of corrective actions) are to be performed in accordance with PAG-13, "Guidelines for Overviews of Corrective Action Related to QA/QC or Construction," and PAG-14, "Guidelines for Overviews of Design-Related Corrective Actions."

These guidelines require that:

(1) the applicable reports be reviewed to identify CPRT findings, (2) a list of the CPRT findings in those reports be compiled, and (3) a program of overviews be performed to assure that the correccive actions for CPRT findings are fully and adequately implemented.

The first two of these activities, review of reports and compilation of a list of CPRT findings, have been accomplished for the issued ISAP results reports and is nearly complete for the DSAP results reports and the CER.

The CPRT Commitment Tracking Report (CTR) is the system used to status and track CPRT findings.

Compilation of the CTR is controlled by PDI-03, "Instruction for the Maintenance of the CPRT Commitment Database," and PDI-04, "Instruction for Development of the CPRT Commitment Database for Design Adequacy Program Commitments."

The NRC inspector reviewed Revision 1 of the CTR and the dataforms from which it was compiled.

These dataforms document the results of the reviews performed to identify the CPRT findings.

By review of the dataforms and Revision 1 of the CTR the NRC inspector determined that the reviews had been performed in accordance with the requirements of PDI-03 and PDI-04.

To verify the accuracy of the reviews the NRC inspector compared the CPRT findings of ten ISAP results reports to the findings listed in Revision 1 of the CTR.

The NRC inspector determined that for each CPRT finding in the results reports the CTR correctly identified the finding, the proposed corrective action, and the status of CPRT concurrence.

For example, a CPRT finding from ISAP VII.a.5 was properly recorded in the CTR as a failure to provide a periodic review of the QA program.

The required corrective actions was for TU Electric management to implement a periodic review of the QA program as outlined in the NEO Policies and Procedures manual.

Since the required corrective actions were identified in the ISAP VII.a.5 results report, SRT concurrence of the corrective actions was provided by SRT's approval of the results report.

The remaining findings from the ten ISAPs

.

-

.

.

reviewed by the NRC inspector were also found to have been properly identified and included in the CTR.

In addition to CPRT findings, the CTR identifies CPRT recommendations; however, the applicant's actions on recommendations do not require CPRT concurrence or verification.

The CPRT recommendations along with the CPRT findings have been provided to the applicant and hr.'e been incorporated into the site commitment tracking system (CTS).

The Technical Audit Program (TAP) utilizes the CTS to identify those CPRT findings and recommendations for which the TAP verifies implementation or disposition.

The NRC inspector compared the entries in the CTS to the entries in the CPRI CTR.

The NRC inspector found no substantive differences in the entries of the two systems.

'

The SRT intends to verify proper implementation of CPRT findings by performing activity overviews and audits of the TAP and the Engineering Functional Evaluation (EFE)..This intention is stated in PAG-13 and PAG-14.

CPRT overview of the TAP audits and the EFE activities have not yet been implemented.

The NRC has previously inspected the activities of the TAP (see NRC Inspection Reports 30-445/87-24, 50-446/87-18 and 50-445/88-01, 50-446/88-01), and the EFE (see NRC Inspection Reports 50-445/87-19, 50-446/87-15 and 50-445/87-37, 50-446/87-28).

NR2 inspections of the implementation of CPRT overviews of the TAP and the EFE will be reported in a subsequent inspection report.

CPRT Procedure PAG-15, "Audit Policy for CPRT Overviews of Corrective Actions, Collective Evaluation, and Control of CPRT commitments," requires that audits be performed of the collective evaluation, the overview of corrective actions, and the control of CPRT commitments.

At this time three such audits have been performed.

The NRC inspector selected two of these audits (SRT-87-01 and SRT-87-02) for review to determine if the audits were in compliance with PAG-15 and that the audits were appropriate to verify that the above activities were properly implemented.

The two audits reviewed by the NRC inspector were found to comply with the requirements of PAG-15 for auditor certification, audit planning, audit team makeup, audit performance, audit reporting, corrective action, follow-up activities, and records.

The scope of audit SRT-87-01 was found to address the following attributes:

(1) organization, (2) QA program, and (3)

instructions, procedures, and drawings. Audit SRT-87-02 addressed the implementation of instructions, procedures, and drawings.

The NRC inspector found each of these audits to have been properly implemented.

In summary, the NRC inspector reviewed those procedures by which (1) CPRT findings are identified, (2) CPRT overviews of corrective actions are performed, and (3)

CPRT audits of

.

.

.

.

-

_ - _ _ _ _ _ _ _ _ _ _ _ _ _

.

'.

-

activities related to CPRT overviews are conducted.

In addition, the NRC inspector reviewed the current implementation of those procedures.

Based upon the above reviews, the NRC inspector determined that the procedures had been properly developed and that current implementation was at a satisfactory level.

While no weaknesses were identified, further NRC inspection of these activities will be conducted and reported as part of NRC inspections of the TAP and EFE.

No violations or deviations were identified during this inspection.

7.

QC Inspector Qualification / Certification Program (35061)

During this report period, the CPSES QC inspector qualification and certification process was inspected.

This process is performed by TU Electric for non-ASME inspectors and by Brown and Root (B&R) for ASME inspectors.

The qualification and certification of contractor inspectors not under the TU Electric QA program, such as BISCO or ITT Grinnell, were not reviewed.

The NRC inspector reviewed the Quality Assurance Manuals (QAMs) for TU Electric and B&R.

Both manuals were found to address the requirements for qualification and certification of QC inspectors found in 10 CFR Part 50, Appendix B, ANSI N45.2.6., and recommended practice No. SNT-TC-1A of the American Society for Nondestructive Testing.

In addition, each QAM provided for the development of procedures to detail the methods by which the requirements were to be implemented.

These implementing procedures were reviewed with the following results.

Procedure NQA 1.16, Revision 1,

"Indoctrination and Training of Quality Assurance Personnel," delineates the general requirements for all TU Electric quality personnel.

The specific requirements for the various types of QC inspectors (i.e., operations, construction, NDE, contract, and ASME l

Section XI inspectors) are delineated in associated Procedures

'

NQA 1.16-2.01, NQA 1.16-2.02, NQA 1.16-2.03, and NQA 1.16-3.02.

The NRC inspector determined that the following requirements were addressed by these procedures:

(1) training outlines approved by the Level III inspector, (2) classroom training with technical content approved by the Level III inspector, (3) on-the-job (OJT) training as determined by the Level III inspector, (4) examination of knowledge of QA requirements both general and specific, (5) proficiency demonstration of ability to perform typical inspection tasks, (6) ongoing training to revisions of applicable documents, (7) documented verification of required education and experience, (8) annual eye examination to assure acceptable near and far vision as well as color vision, and (9) issuance of discipline certifications subject to annual evaluation and triannial recortification.

These requirements

.

.

.

.

.

were in accordance with the site commitments to 10 CFR Part 50, Appendix B, and ANSI N45.2.6.

In addition, the qualification requirements to certify NDE inspectors were reviewed and found to be consistent with the requirements of SNT-TC-1A.

For B&R, ASME Administrative Procedure AAP-2,2, "QA Personnel Training and Qualification," delineates general requirements for all B&R quality personnel.

Specific requirements for the certification of NDE and mechanical inspection personnel were found in associated B&R Procedures AAP-2.3 and 2.4.

The NRC inspector reviewed these procedures and determined that except for requiring a demonstration of proficiency, the B&R procedures addressed the same requirements as the TU Electric procedures.

Since the B&R procedures did not require a proficiency demonstration, the NRC inspector discussed the issue with the site discipline Level III inspector.

Further review of the procedures and file records showed that proficiency is demonstrated during OJT and by acceptable scores on the practical examination.

The NRC inspector deems these actions to be an acceptable method for demonstration of ability.

Based on the above review, the NRC inspector determined that the site commitments relative to qualification and certification of inspectors were properly addressed in the B&R controlling and implementing procedures.

To evaluate if the procedural requirements were being properly implemented, the NRC inspector selected six B&R and six TU Electric QC inspector files for inspection.

These files were inspected and found to be in compliance with the procedures.

Based on the above review of the procedures and review of QC inspector files, the NRC inspector determined that the QC inspector qualification and certification process for B&R and TU Electric is satisfactorily prescribed by the controlling and implementing procedures and that the qualification and

,

'

certification of QC inspectors is being implemented in accordance with requirements.

No violations or deviations were identified.

8.

Qualifications of Engineers-Corrective Action Program (CAP)

(35061)

The current CPSES activities include various programs

requiring engineering services such as the Corrective Action Program (CAP), the EFE, and engineering support for ongoing

construction.

The organizations providing these engineering services were TU Electric, SWEC, Ebasco Services, and Impell Corporation.

During this report period the methods by which

.

.

.

'

.

each of these organizations verify the qualifications of their engineering personnel were inspected.

The following items were reviewed:

(1) the procedures, policies, or guides by which the above organizations verify qualifications, (2) the evidence documenting that qualification verification had been performed, and (3) audits by TU Electric of the above organizations relevant to engineering qualifications.

The NRC inspector determined that a procedure or policy guide requiring qualification verification existed for SWEC, Ebasco, and Impell.

For example, a SWEC personnel policy and procedure required that:

(1) the highest applicable degree be verified by the institution from which it was issued, (2) engineering licenses be verified by the issuing authority, and (3) work experience be verified for the five most recent years of employment.

The Ebasco and Impell procedures had similar requirements.

The NRC inspector found that a procedure requiring verification of personnel qualifications had been developed by TU Electric for their engineering personnel, but that procedure had not as yet been issued and was currently being circulated for comment.

Upon further investigation the NRC inspector determined that verification of personnel qualifications for TU Electric was being performed by the TU Electric personnel department and the corporate security department.

prior to employment the personnel department requires presentation of a valid diploma.

Subsequent to employment a security investigation is performed by an outside organization under a corporate security contract.

During the security investigaticn, the education and prior work experience of the employee are verified by contacting the institution granting the degree and the previous employers.

The NRC inspector found the procedural controls to be

'

satisfactory for SWEC, Ebasco, and Impell.

Since the TU Electric procedure is in draft form, the NRC inspector did not review its contents, per a discussion with the manager of corporate security the procedure details the responsibility for verification of personnel qualifications, as well as, i

defining the methods by which the verification is to be l

achieved.

The NRC inspector will inspect the procedure when I

it is issued.

l

'

To verify that the above procedures and practices were properly implemented, the NRC inspector selected six engineering personnel from the organizational charts maintained by each organization.

By selecting from these charts, the NRC inspector was able to identify those personnel

performing engineering services.

The selection of engineers also included those with degrees from other countries as the NRC inspector deemed that those qualifications would be more difficult to verify.

The NRC inspector determined each

,

.

,

organization had verified the educational degrees, the engineering licenses (if applicable,); and relevant work experience for the selected sample.

The NRC inspector noted that in two instances verification of education could not be performed.

The NRC inspector determined that in each case satisfactory evidence of engineering qualification was available.

For example, although a bachelors degree in engineering was unable to be verified for an individual, the individual had performed satisfactory engineering work for other companies and was certified as a professional engineer in four states including the state of Texas.

The NRC inspector considered the verification of engineering qualifications in the sample to be satisfactory.

The NRC inspector reviewed audits performed by TU Electric of engineering qualifications and discussed audit scopes with the audit supervisors for the TAP and the TU Electric internal audit and vendor compliance groups.

The NRC inspector determined that audits of the training and indoctrination of engineers had been routinely performed; however, TU Electric had not performed audits to verify that an adequate program existed to assure that engineers performing safety-related work were qualified.

The NRC inspector found the current programs to verify engineering qualifications and the implementation of those programs to be satisfactory.

No violations or deviations were identified.

Pending the issuance of the procedure noted above, and further clarification of the audits by which the applicant assures that such programs are implemented, this matter will be continued as an open item (50-445/8810-0-10; 50-446/8808-0-10).

9.

Plant Tours (92700)

The NRC inspectors made frequent tours of Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and in-process work activities.

No violations or deviations were identified and no items of significance were observed.

10.

Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both.

Ten open items disclosed during this inspection are discussed in paragraphs 2.c, 2.d, 2.h, 4,

i (5 items), and 8.

i

.

l

_ _ _ _ _ _ _ _

Q

.

.

• 11.

Exit Meeting (30703)

On February 29, 1988, R.

F. Warnick, H. H.

Livermore, and J. S. Wiebe met with L. D. Nace and A. B. Scott to discuss February inspection findings and other matters of interest.

An exit meeting was conducted on March 1, 1988, with the applicant's representatives.

No written material was provided to the applicant by the inspectors during this reporting period.

The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

During this meeting, the NRC inspectors summarized the scope and findings of the inspection.

!

l

- - - - ~ _ _ _. _ _ ___ __