ML20141P072

Const Insp Repts 50-445/85-14 & 50-446/85-11 on 851001-31. Violations Noted:Failure to Establish Written Procedures for Control & Accountability of Shipment of Original Design Records to S&W & Failure to Document Pipe Violations

ML20141P072
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1986
From:	Barnes I, Kelley D, Norman D, Phillips H, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141P047	List: ML20141P046 ML20141P053 ML20141P054 ML20141P063 ML20141P072 ML20141P077 ML20141P083
References
50-445-85-14-01, 50-445-85-14-1, 50-446-85-11, NUDOCS 8603180517
Download: ML20141P072 (16)

See also: IR 05000445/1985014

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APPENDIX D -

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t'. CONSTRUCTION INSPECTION REPORT

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~U.'S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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12 NRC[InspectionReport: 50-445/85-14 Permit: CPPR-126

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- . . 50-446/85-11 CPPR-127

, Dockets:'50-445 Category: A2 '

, 50-446

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l; Applicant: Texas Utilities Electric Company (TVEC)

Skyway Tower

, 400 North Olive Street

Lock Box 81

_. Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES), Units'1 and 2

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Inspection At: Glen Rose, Texas

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' Inspection Conductedi October 1-31, 1985

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Inspsctors: . H.-S. .

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Phillips, Seniof Resident Reactor

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Inspector (SRRI), Construction, Region IV

CPSES Group

, (paragraphs 1, 2,-3, 4, 5, 6, 9, 10)

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D.L.'Kelley,SRRIK0peratpons,RegionIV Date '

CPSES Group (paragraph 8)

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D. E. Norman, Reactor Inspector

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3 Region IV CPSES Group

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(paragraph 7)

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8603180517 860306

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Consultants: EG&G - J. H. McCleskey

Parameter - T. H. Young

Reviewed By: 8am

I. Barnes, Group Leader, Region IV CPSES Group

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Date

Approved: 7 / 3/7/f4

T. F. Westerman, Chief, Region IV CPSES Group Date

Inspection Summary

Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14)

Areas Inspected: Routine, unannounced inspections of Unit I which included

plant tours, applicant actions on construction deficiencies, applicant actions

on previous NRC inspection findings, and storage and handling of QA records.

The inspection involved 204 inspector-hours onsite by two NRC inspectors and

two consultants.

Results: Within the four areas inspected, one violation (failure to establish

written procedures for control and accountability of the shipment of original

design records to Stone & Webster Engineering Corporation (SWEC),

paragraph 5.b) was identified.

Inspection Conducted: October 1-31, 1985 (Report 50-446/d5-11)

Areas Inspected: Routine, announced and unannounced inspections of Unit 2

which included plant tours; applicant actions on construction deficiencies;

applicant actions on previous inspection findings; storage, protection, and

handling of QA records; audit of QA records; welding material control; and

electrical cable tray / equipment walkdown. The inspection involved 227

inspector-hours by three NRC inspectors and two consultants.

Results: Within the seven areas inspected, three violations (a repeat failure

to document minimum wall pipe violations on a nonconformance report (NCR),

paragraph 4.c; a repeat failure to control issue of design documents,

paragraph 4.g; failure to establish written procedures for control and

accountability of shipment of design records to SWEC, paragraph 5.b) were

identified.

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1. Persons Contacted

Applicant Personnel

J. Merritt, Assistant Project General Manager

P. Halstead, Manager, Quality Control (QC)

C. Welch,.QC Supervisor

R. Spangler, Corporate Quality Assurance (QA) Supervisor

J. Walker, Corporate QA Auditor

J. Marshall, Licensing

J. Hicks, Licensing

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M. Strange, Supervising Engineer, Support & Project, TUGC0 Nuclear

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Engineering (TNE)

J. Ryan, Technical Service, Supervisor

S. Ali, TNE QA Staff Engineer

B. Jones, Unit 2 Supervising Engineer, Civil / Structural

R. Hooten, Project Discipline Engineer, Civil / Structural

J. Hoagson, Computer Operator Supervisor, PMCS

Contractor Personnel

W. Baker, Welding Engineer, Brown & Root (B&R)

W. Wright, Welding Engineer, B&R

G. Purdy, Site QA Manager, B&R

J. Gore, Subcontract Supervisor, B&R

K. Thornton, Warehouse Superintendent, B&R

C. Osborne, QA Vault Supervisor, B&R

D. Leach, TNE-QA-B&R

K. Norman, Central Operations Supervisor, DDC-B&R

D. Bleeker, DCTG Supervisor, B&R

R. C. Iotti, Project Manager, Ebasco

A.' Smithey, Supervisor IRV, B&R

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1 R. Walters, ASME QA Supervisor, B&R

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G. Maedgen, Welding Engineer, B&R

T. Gray, Document Control Manager

.P. Patel, Unit 1 Civil Lead, THE Design, Gibbs & Hill

B. Jones, Expediting Supervisor, B&R

L. Barnard, PMG File Clerk, B&R

~ T. McCormack, Fire Protection Engineer, Impell

S. Felman, Assistant Project Engineer, SWEC

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H. Moscow, Supervisor Projects & Services, NY, SWEC

J.--Tate, 304 DU Satellite Supervisor, B&R

J.'Junge, 311 DU Satellite Supervisor, B&R

J. Womack, 300/301 DU Satellite Supervisor, B&R

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R. Flaherty, 307 DU Satellite Supervisor, B&R

S. Hazle, 310 DU Satellite Supervisor, B&R

J. Day, 308 DU Satellite Supervisor, B&R

J. Dickey, DCC Area Supervisor, Engineer Satellites, B&R

S. Bruce, DCC Area Supervisor, Craft Satellites, B&R

2. Plant Tours i

At various times during the inspection period, NRC inspectors conducted

general tours of the reactor building, safeguards building, and the

y electrical and control building. During the tours, the NRC inspector

observed ongoing construction work and discussed various, subjects with

personnel engaged in work activities.

No violations or deviations were identified.

3. Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant

a. The applicant's procedures pertaining to Significant Deficiency

Analysis Reports (SDARs) were reviewed to determine how the process

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of deficiency identification through completion and signoff is

controlled. Reviews were performed of site Procedures CP-QP-15.6,

Revision 3, "SDAR Status Tracking"; CP-QP-16.1, Revision 6,

"Significant Construction Deficiencies"; CP-QP-17.0, Revision 1,

" Corrective Action"; and TUGC0 Procedures DQP-CQ-4, Revision 1,

" Reporting of Significant Deficiencies"; 'DQP-QA-12, Revision 2,

, , " Administration and Tracking of Significant Deficiency Analysis

i Reports'; and DQP-QA-11, Revision 1, " Corrective Action."

Procedures CP-QP-15.6, CP-QP-16.1, DQP-CQ-4, and DQP-QA-12 do not

address the SDAR file contents or provide a method for completion and

signoff of the required corrective action. Procedures CP-QP-17.0 and

DQP-QP-15.6 address the documentation required'for closing

deficiencies, but there is no cross reference between SDAR/ corrective

action with respect to SDAR file contents. This is an unresolved

ite.n pending completion of NRC review of SDAR procedural adequacy

(445/8514-U-02; 446/8511-U-01).

b. The applicant classified the following reportable SDAR files as

" Licensee Action Complete": SDARs CP-84-27, CP-84-29, CP-85-04,

CP-85-05, CP-85-11, CP-85-12, CP-85-13, and CP-85-14. The above

files did not document or reference the location of documentation

which would support the reported status of corrective actions being

complete. Consequently, the NRC inspector did not perform a field

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verification for any of these files.

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c. The following nonreportable SDAR files were selected for review, l

since the applicant classified these as " Licensee Action Complete":

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(1) (Closed): The NRC inspector reviewed the following SDARs: .

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CP-84-05, CP-84-22, CP-84-23, CP-84-24, CP-84-26, CP-84-32,

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CP-85-02, CP-85-08, and CP-85-09. The applicant's evaluation

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and decision that these SDARs are not reportable appeared to be

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correct.

(2) (0 pen): The NRC inspector reviewed SDARs CP-84-30, CP-84-34, and

CP-85-06. The files for these SDARs did not contain sufficient

information or. documentation to determine whether or not the

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SDAR was nonreportable.

The status of the files is an unresolved item pending the

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completion of a TUGC0 effort to make the files complete and

subsequent NRC review (445/8514-U-03; 446/8511-U-02).

4. Applicant Action on Previous NRC Inspection Findings

a. (Closed) Unresolved Item (445/8422-U-02): Inverter transformer common

failure. The-NRC inspector reviewed the applicant's handling of the

defective transformers and concluded that the actions taken to

evaluate and correct the deficiency were correct and adequate.

The applicant's handling and reporting of significant deficiencies

will continue to be monitored by the NRC inspectors.

b. .(Closed) Violation (445/8307-V-01): Excessive welding gap. In 1983,

the NRC inspector identified an unacceptable fitting on pipe support

Mark No. SW-1-102-106-Y33K. Recently, the NRC inspector followed up

and reviewed NCR M5123-5, RPS 751947, WDC80668, related sketches, and

inspection report's (irs). Corrective work was accomplished and QC

performed required inspections. An engineering analysis of the

installation which was performed in response to the violation showed

strength was far in excess of minimum design requirements, even

though it violated the procedure. In B&R memo -IM 325,208 dated

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. April 13, 1983, supervision reemphasized the requirement to follow

procedures'to all affected personnel.

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c. (Closed) Violation (445/8315-01): Failure to write an NCR on base

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metal repair. This violation concerned an instance where the NRC

' u inspector observed a minimum wall violation for which a NCR had not

'beenl written. On October 8 and 9, 1985, another NRC inspector .

reviewed this violation of paragraph 3.3.3 of site Procedure

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QI-QAP-16.1-2, Revision 4, dated May 20, 1982. The scope of'this l

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', procedure was changed to make further reference to system walkdown D

. . . 'and the item in question was accomplished near this time frame.

However, the applicant responded by' documenting the questioned.

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minimum wall violation and the repair of the adjaceiit weld on a

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common NCR (M6611). These conditions had been found by separate NDE

methods, one before and one after the base metal repair. The NRC

inspector reviewed two more recent base metal repairs to verify that

the problems had been corrected. One repair performed in 1984 was

found to have been in compliance with the then current procedures.

The second repair was completed, reviewed, accepted, and

documentation sent to the vault during September and October of 1985.

This~second report showed an original weld completed, reviewed, and

accepted in January and February 1985. Rework was performed on this

weld in September 1985 due to interference with a hanger installation

which resulted in a minimum wall violation. Further work to repair

the hang 3r was classified as a " Major Weld Repair" in accordance with

paragraph 3.3 of B&R Procedure CP-CPM-6.9G; however, no NCR was

generated. This failure to document a minimum wall violation en an

NCR is a repeat violation of Criterion XV of Appendix B to

10 CFR Part 50(446/8511-V-01).

It was noted that the inspector and the preparer of the repair

process sheet had recently received training on the newly revised

procedures involved which required the NCR be generated. The

Assistant Project Welding Engineer who reviewed the repair process

sheet had not been so trained on the procedure, as he had been

exempted from the training by virtue of his position.

d. (Closed) Unresolved Item (446/8502-01): Responsible welding

supervisors not familiar with welding rod control procedures. In

1985, the NRC inspector interviewed supervisors who were not familiar

with welding rod control procedures which their crew of welders were

responsible for implementing. The training program for supervisors

was conducted in May 1985 and covered helpers through general

foremen.

In 1984/85, the NRC Technical Review Team (TRT) extensively reviewed

and inspected weld rod control and documented their findings in

NUREG-0797, Supplemental Safety Evaluation Report (SSER) 10, Category

9. In addition, the RIV inspector inspected weld rod control during

this inspection period and identified no violations or deviations,

e. (Closed) Unresolved Item (445/8323-07): Incomplete Class V(5) pipe

supports record package. In 1983, the NRC reviewed packages which 1

had been combined into finalized packages. In 1984, the TRT reviewed l

a random sample of 11 Class V(5) support record packages. This '

review showed that packages with irs (by qualified inspectors) were j

in proper order. The TRT found the records satisfactory as reported  !

on page N-252 of NUREG-0797, SSER 10 dated April 1985. j

f. (Closed) Unresolved Item (445/8347-01): Containment surface area

coating. This item addressed sloughing of protective coatings on

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Westinghouse supplied items. In SSER 9, NRR staff state they have

reasonable assurance that debris generated by the failure of all

coatings inside the containment building under design basis accident

conditions will not unacceptably degrade the performa r e of

post-accident fluid systems. This was based on TUGC0 and other

studies referenced in NUREG-0797, SSER 9 on pages L-17 and L-18. NRR

. requires in SSER 9 that a preoperational and postoperational coatings

program be proposed by TUGCO, but this specific issue of sloughing of

coatings on Westinghouse items is closed based on the SSER 9

conclusions.

g. (Closed) Violation (445/8416-V-02): Failure to provide controlled

issuance of design documents and changes thereto. Between May and

June 20, 1984, an NRC inspector found that design documents and

changes were not controlled by Operations Document Control Center

(DCC). On October 11 and 14, 1985, the NRC inspector confirmed that

the computer system and terminals referred to in the TUGC0

November 1, 1984, response were in place and in use.

The NRC inspector reviewed 12 Design Change Authorizations (DCAs) and

Component Modification Cards (CMCs) and followed the distribution of

25 packages to 9 locations for various disciplines and verified

corrective action. These DCAs and CMCs were traced in their routing

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. at the central DCC and then on to the Paperflow Group or satellite

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DCCs and a review performed of how they are distributed from those

locations. All items checked were distributed per DCP-3, Revision 18

(with Document Change Notices (DCNs) 1, 2, and 3),-with the

L following exceptions:

(1) CMC 96181, Revision 1, was issued on October 8, 1985, and

i satellite DCC 307 (craft) picked it up at central DCC. The ChC

was not signed for as required by paragraph 3.1.1.1 of DCP-3,

Revision 18, with DCNs 1, 2, and 3. There was a similar

" occurrence on CMC 75003, Revision 2, as issued to satellite DCC

202/211 (TUGCO). Further, DCA 21446, Revision 1, was issued

October 8, 1985, and satellite DCC 307 was in possession of it

on October 14, 1985. One of two packages for brawing

2323-El-1702, Sht 002, Revision 2, had both Revision 0 and

Revision 1 of DCA 21446 in it, with the other having only

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Revision C in it. Both Revision Os were not stamped " VOID" as

required in paragraph 3.2.2.5 of DCP-3.

On October 14, 1985, satellite DCC 307 issued Drawing

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2323-El-1702, Sht. 002, Revision 2, to an electrician for

Class IE field work with Revision 0 of DCA 21446, rather than

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the current Revision 1, which is contrary to the requirements of

paragraph 3.2.1.2 of DCP-3. On October 14, 1985, TUGC0 and B&R

cupervision contacted the electrician who indicated he had

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gotten sheet 002 rather than sheet' 001 by mistake and had

returned it immediately without installing anything to it.

These failures to follow design document control procedures are

a violation of Criterion V of Appendix B to 10 CFR Part 50

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(2) The following examples were noted of practices being followed

that were not covered in. controlled procedures:

(a) The method used to issue drawing packages from the

satellites to the field (e.g., crafts and QC) was'not

addressed in DCP-3.- The actual practice is.that a DCC

person and the recipient sign for receipt of all the proper

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documents (e.g., DCAs) and the proper revisions _on the

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computer printed "Open Design Change Log."

(b) Another practice of the DCC group is to log into the

computer the status of the DCAs and CMCs. This status is

classifed as open, void, or not included (NI) and indicates

whether a change is affecting all items built to a drawing,

a single item utilizing the drawing, c,r no further use of

the change. Drawing 2323-5-0910, Sht. CSR-2A, Revision 12,

had CMC 75003 issued against it. This CMC had status NI on

Revisions 0 and 01 because it affected a single hanger

utilizing the above drawing. However, Revision 02 did not

have NI input and it showed as open on the terminals. This

would require it to be included with the drawing package in

, error. This was corrected on the terminal. This process

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of statusing the computerized document information is not

described in DCP-3.

DCC supervision stated and showed that the practices are

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described in internal uncontrolled guidelines. This item is

unresolved pending incorporating the guidelines into a

controlled procedure (446/8511-U-03).

h. (Closed) Violation (84-08-01): Gaps on Unit 1 polar crane bracket and

seismic connections. In November 1984, a NRC inspector found that

the gaps between the bracket and connectors exceeded the design

tolerance. This item is addressed in NUREG-0797, SSER 8, along with

related problems with polar cranes. Discussion, conclusions, and

actions to be taken are included in pages K-14, 15, 18 and 121-123 of

Appendix K to SSER 8. Since these actions will address the specific

concerns of item 84-08-01, this item is closed.

5. QA Records System Review l

The NRC inspector reviewed the applicant's record keeping system after

ascertaining that records were being shipped off site without proper

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control an'd inventory. In Appendix IA(N) and 1A(B) of Final Safety

Analysis Report (FSAR) Volume 1, Section 1.0, the applicant commits to

Regalatory Guide 1.88 (i.e., Collection, Storage, and Maintenance of

Nuclear Power Plant Quality Assurance Records) and to American National

Standard, Institute (ANSI) N45.2.9, 11th Draft, Revision 0, dated

January 17, 1973. On page 1A(B)-36 in the Discussion, the. applicant makes

, no exceptions to this standard. A brief description of QA records is

contained in FSAR Section 17.1.17 (Amendment 50 dated July 13, 1984). The

description does not address the current QA records facilities and

storage; i.e., temporary storage of records for the Paper Flow Group,

Interim Record Vault (IRV), Permanent Plant Record Vault (PPRV),

procurement records storage area (Warehouse A) and the TUGC0 Records

Center.

The applicant has not revised FSAR Section 17.1.17 to describe and reflect

the current QA record system. This is unresolved pending the applicant's

actions on the item described in paragraph a below (445/8514-U-04;

_ 446/8511-0-04).

a. Review of Corporate QA Manuals and Implementing Construction Procedure:

The NRC inspector reviewed the TUGC0 Corporate QA Program Manual,

, Revision 14, dated April 30, 1985, and Quality Assurance Flan,

Revision 14, dated August'30, 1984, to determine if ANSI N45.2.9 was

referenced and if its requirements were translated into these

documents. Only TUGC0 construction Procedure CP-QP-18.4, Revision 5,

was found to reference ANSI N45.2.9. Operations and TUGC0 Nuclear

ingineering procedures were not included in the scope of this

, inspection. Procedure CP-QP-18.4, Revision 5, does not address all

aspects of ANSI N45.2.9 such.as (1) definitions; (2) all facility

. locations;,(3) method for maintaining control of and accountability

. 'for records removed from the site storage facility to organizations

located on or off site; (4) temporary storage facilities (fire rated

cabinets versus duplicates in remote, separated locations); and (5)

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. special process records such as photographs, negatives, and

microfilm. The permanent facilities are discussed with respect to

ANSI N45.2.9 requirements described in paragraph 5.6; however, the

drain system and dry chemical / gas fire protection system is not

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discussed. The IRV. system is a permanent' records vault for Unit 2

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records until such records can be transferred to the construction

, PPRV where Unit I reccrds are now stored. TUGC0 Procedure

L_ CP-QP-18.6, Revision 2, discusses records turnover from B&R IRV to

TUGC0 PPRV but does not address the issues raised above. Also, these

I. issues are not addressed in the B&R QA Manual, Section 17.0 dated

October 31, 1984, or CP-QAP-18.1, Revision 3, dated July 11, 1984.

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TUGC0 management stated that all of their QA manuals are in revision

to improve their written program. This item is unresolved pending

the completion of that review (445/8514-U-05; 446/8511-0-05).

b. Storage and Transmittal of Design Records to SWEC, New York: On

October 16, 1985, an NRC inspector was inspecting an open item

previously identified as unresolved item E226-U-07. As a result, the

requalification package for pipe support CC-1-107-008-E23R was

requested and the NRC inspector was informed that this design records

package had been included in a total of 5702 (4654 for Unit 1, 1048

for Unit 2) hanger packages that had been shipped to SWEC, New York,

for a complete reevaluation.

The NRC SRRI interviewed the TUGC0 engineering supervisor who

answered questions about whether procedures controlled such shipment,

the number of records per package, and how the records were to be

protected during shipment. He stated that a first transmittal was

controlled by Procedure CP-EI-18.0-4, Revision 0, dated July 25,

1985, until Comanche Peak Project Engineering became a part of TNE on

September 1,1985, at which time the procedure was deleted. The SWEC

project manager stated that Procedure CPPP-3 covers the receipt and

indexing of these packages; however, CPPP-11 that will control the

distribution of these packages to SWEC offices at Cherry Hill, New

Jersey; Boston, Massachusetts; Denver, Colorado; Houston, Texas; and

Toronto, Canada, will not be completed until late October or early

November 1985, according to SWEC Supervisor Project Services, New

York. The utility has taken corrective action that includes (1)

making duplicate copies prior to shipping, and (2) all records

initially sent to SWEC are being copied and a copy returned to the

site. Region IV is pursuing with IE Headquarters, QA Branch the

minimum protection that should be afforded records in shipment. The

failure to have site procedures to maintain control and

accountability of the shipment of records is a violation of Criterion

V of Appendix B to 10 CFR Part 50 (445/8514-V-02; 446/8511-V-03).

c. Storage and Transmittal of Construction Records to Chicago Bridge and

Iron (CBI): As a result of knowledge of an earlier shipment of CBI

records off site, the NRC inspector has asked the utility to provide

records to demonstrate the CBI record controls that were implemented.

It is CBI practice to ship all records off site for copying. This

matter is considered unresolved (445/8514-U-06; 446/8511-U-06).

The utility has indicated that the receipt of records from CBI was

handled in the same manner as the receipt of records from any vendor.

Region IV will inspect the receipt of vendor records and this matter I

is considered an open item (445/8514-0-01; 446/8511-0-01).

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d. Inspection of Storage Facilities: The NRC inspectors visited all

site storage facilities to determine if storage, preservation, and

safe keeping of records are as required by Criterion XVII of

Appendix B to 10 CFR Part 50 and ANSI N45.2.9, Draft 11, Revision 0,

paragraph 5 " Storage, Preservation and Safe Keeping." The

facilities inspected included TUGC0 Records Center, which is

committed by the FSAR to ANSI N45.2.9-1974 and not the Draft 11,

Revision 0 version; PPRV; IRV; Paper Flcw Group storage areas for

Unit 2 mechanical and electrical; and the orocurement records storage

area. The facilities for the Paper Flow Group and procurement

records are not identified or described in TUGC0 or B&R procedures;

however, these facilities and the PPRV and IRV were evaluated with

the following results:

(1) TUGC0 Records Center - This vault is the final repository for:

(a) Unit 1 records which describe completed construction, and

(b) Unit 2 record packages for systems that have been completed

and turned over to operations. This facility was completed

about March 1983. The NRC inspector found that this vault had

access control and records were stored in closed containers,

open face shelves, or in binders on top of furniture.

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Radiographs and other special process records are protected by

l controlling temperature and humidity. The NRC inspectors noted

l that a water sprinkler system had been installed in this

facility.

This presents a concern because those plant records which are

stored in folders or binders in open faced cabinets will be

deluged with water and will likely deteriorate. An additional

consideration is that records stored in a manila folder may be

washed out and possibly clog the drain in this facility, leading

I to flooding of the facility. This item is considered unresolved

pending applicant review of the facility with respect to the

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above observations (445/8514-U-07; 446/8511-U-07).

(2) PPRV - This vault served as the sole permanent vault from

approximately 1975 until March 1983. This permanent records

facility has controlled access. It meets the design features

for a pernanent facility, as described in Section 17.1.17 of the

FSAR; however, the NRC inspector had the following comments:

(a) There is no fire suppression system inside this vault. Two

hand-held extinguishers and a 2-inch fire hose are located

outside the vault. One hand-held extinguisher is located

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inside the vault. Fire' detectors and alarms are inside to

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, . alert the onsite fire department if a fire occurs.

'(b) IfEthe.2-inch fire hose is used to extinguish a fire,:the

vault may flood becaute there are no fire drains and the

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floor is not sloped. Therefore, water may potentially

enter the bottom cabinet drawers.

(c) NCRs and corrective action reports were stored in binders

in bookcases. If fire hoses are used, these documents

would probably be subjected to the force of water from the

hose and damaged. Therefore, it would be desirable to

store these records in closed containers. All other

, records were stored in nonfire rated cabinets which is

acceptable if located in a permanent facility that meets

ANSI N45.2.9 requirements.

The failure to install a fire suppression system, drains, and a

sloped floor appears to be a deviation from ANSI N45.2.9

requirements. However, this item is unresolved because this

facility is described in FSAR Section 17.1.17. Region IV is

forwarding this issue to IE Headquarters, QA Branch for

clarification (445/8514-U-08; 446/8511-U-08).

(3) IRV - This area is not a separate building, but is actually part

of the permanent vault that has been set aside as an interim

storage area prior to placing records in the area designated for

permanent records. This area has an access point that is

separate from the permanent area and is controlled. The

facility is the same as the permanent area, except a wall

separates the two. They share the same forced air system. This

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facility generally meets the requirements of 10 CFR Part 50,

Appendix B, and ANSI N45.2.9; however, the NRC inspector had the

following comments:

(a) Water had been leaking through the forced air system and

beside a support girder. In a second location,

approximately 2-3 gallons of water had leaked in through

the forced air ventilation duct and was caught by a

container placed under the duct. This is considered an

open item (445/8514-0-02; 446/8511-0-02).

(b) The NRC inspector observed a coffee pot, sugar, and

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evidence of food on a table adjacent,to the vault area.

These were immediately removed from the vault by the

utility.

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(4) Paoer Flow Groups - The NRC inspectors visited trailers where

- the electrical and mechanical Paper Flow Groups are located to

determine if QA records are stored there.

In SSER No. 11, the TRT considered the documents in the paper

flow groups to be inprocess; however, SSER No. 11 also indicated

that the records are maintained in fire proof cabinets. The NRC

, inspectors found that there are some records stored in

,s - nonfire-rated file cabinets. This matter is considered

unresolved (445/8514-U-09; 446/8511-U-09).

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(5) Storage of Procurement Records - In Warehouse A, procurement

records were stored both in nonfire-rated and fire-rated

' cabinets. The NRC inspector found no master index of these

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records and the facility is not described in the FSAR or

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procedures. There was no way to determine whether duplicates of

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these records exist and if they aust be stored in fire-rated

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cabinets. This item is unresolved pending identificatfan and

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, des:ription of this facility and indexing of records recently .

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received,from the TUGCO, Dallas, Texas, office to determine what

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records must be in fire rated cabinets (445/8514-U-10);

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446/8511-U-10).

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6. Audit of QA Record Systems / Facilities -

The NRC inspector asked if the unacceptable QA records storage and control

7 conditions . identified above in paragraphs 5.a and 5.d had been identified

by TUGC0 or B&R audits. TUGC0 audited (TCP-85-20 dated January 16, 1985)

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the PPRV but failed to identify any of the problems noted above. Two

auditors audited this area from December 17 through December 20, 1984, and

their report did not identify any storage facility problems. ANSI N45.2.9

. requires that periodic audits shall be performed to assure facilities are

in good condition and temperature / humidity controls and protective devices

are functioning properly. .

An Ebasco review or study dated June 16, 1981, page 4 of 25, item g,

states with respect to the PPRV, "It is an established fact that the QAR

vault does not meet the requirements for a single storage facility and

.that duplicate files are not maintained in lieu of single storage." On

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0ctober 23, 1985, the NRC inspector requested documentation which would

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~show action taken in response to the Ebasco finding. TUGCO's Project and

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QC organizations had no such documentation. This item is unresolved

pending review of the response to this audit finding (445/8514-U-11;

446/8511-U-11). . The NRC inspector asked PPRV personnel if B&R had audited

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lF the record . keeping / facility system and was informed that it 5as been

several years since B&R had performed such audits. Th'is item it

i unresolved pending the review of B&R audits (44E/8514-U-12;

'446/8511-U-12).

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, 7. Control of Weld Filler Material

This inspection was performed to determine wheth'er safety-related weld

filler material purchase, storage,.and distribution are in accordance with

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the applicant's work and QA procedures, and applicable ASME code

requirements. Implementation of the following procedures was examined

during the inspection: .

. CP-QAP-8.1, Rdvision 9, dated October 15, 1984, " Receiving

Inspection";

. CP-CPM-6.9B,' Revision 2,' dated September 21, 1984, " Weld Filler

Material Control"; and

. CP-CPM 8.1, Revision 3, dated July 2, 1985, " Receipt, Storage, and

Issuance of Items." -

The following areas were examined: ,

a. Procurement: Four purchase order packages which consisted of the

purchase order, procurement specification, and field requisitions

were inspected to verify that orders were properly approved and

included required technical, packaging, and documentation

requirements as specified in site procedures pertaining to weld

filler material purchases.

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No violations or deviations were identified.

b. Receivina Inspection: Receiving inspection records, for the filler

material purchased to the procurement documents inspected, were

examined to verify that all items required by Attachment 11

(Receiving Checklist) to CP-QAP-8.1 had been inspected. In each

case, the checklist and a receiving inspection report had been

completed and signed by a Level II QC inspector. In several

instances, NCRs had been completed and material returned to the

vendor as required by procedures. Certified Material Test Reports

(CMTRs) for each purchase were also reviewed to verify that required

inspections and tests had been performed and that material had been

purchased from a vendor with a current ASME certification. It was

also verified that heat codes and quantities of material shown on the

Material Receiving Reports corresponded to what was shown on the

CMTR.

No violations or deviations were identified.

- c. Main Storage Areas: Two' filler material storage areas located in

i Warehouse A were inspected for compliance with the above listed

procedures. One area was designated as a Quality (Q) area and the

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other one was both a Q and Non-Q area. The Non-Q material was

segregated as required from the Q material. Procedures in the

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storage areas appeared to be adequately implemented; however, the NRC

had the following observation:

Paragraph 3.2.1 of CP-CPM 6.9B requires that Q weld filler material

s . original containers be marked upon receipt and during storage with

the material classification, size, and heat / lot number. In the Q

area, labels on several containers of Sandvik welding products (weld

ro'd) had fallen off and others were loose. The material was still

identifiable, because of the storage bin marking and marking on the

shipping carton; however, a loss of identification is possible when

material is removed from the storage area. There were also several

unopened cartons of Sandvik material whose status could not be

determined. Loose or missing labels were identified on the following

material; Lot 101172-2, 1/8 inch, AWS/ASME SFA 5.4; and Lot 10149-1,

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5/32 inch AWS/ASME SFA 5.4. This matter has been referred to B&R '

Welding Engineering for followup,

d. Distribution Stations: Weld rods used in safety-related applications

are distributed from three areas (Rodhouse 2, 3, and 4). Each

distribution station was inspected to verify compliance with

requirements of CP-CPM 6.9B in the following areas:

. Storage facility (Level B);

. Identification of material;

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. Controlled access into storage areas;

. Control of stationary and portable rod ovens;

. Issuance, return, and accountability of material; and

. Completion and control of records.

Label problems were also noted in Rodhouse 4 during th's inspection.

8. Cable Tray and Equipment Walkdown

During this inspection period, the NRC inspector performed a walkdown

inspection of selected electrical components and cables to determine the

degree of protection of class IE items from surrounding construction

activities. The general level of protection appears adequate with the

exception of the B Safety Train Diesel engine control panel (20G02A). The

visqueen covering had come loose in several spots allowing concrete dust

from above to filter into the panel and settle on some of the installed

relays.

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In the area of. cables, it was noted that cable ends were neatly coiled and

the ends taped, cable tags.were in place and cable jacket repairs were

clearly marked. At one point in the Safety Train B switchgear room, a

cable exiting a tray and entering the.switchgear (cable No. C23G 06070

. above the HVAC chiller No. 14.) appeared to be bearing hard on the square

.> section of the cable. tray side. ladder at its exit point. In other places

where cable exits tray, a piece of discarded cable jacket is used as a

buffer. The observed point had no such buffer.

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No violations or deviations were indentified.

/ .9. . Unresolved Items

Unresolved items are matters for.which more information is required in

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order to ascertain whether they are acceptable items, violations, or

deviations. Twelve unresolved items disc'osed during the inspection are

discussed in paragraphs 3.a, 3.c, 4.g, 5, 5.a. 5.c, 5.d, and 6.

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10. Exit Interview

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An exit interview was conducted November 1,-1985, with the applicant

. representatives identified in paragraph 1 of Appendix E. During this

i interview, the NRC inspectors summarized the scope and findings of the

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inspection. The applicant acknowledged the findings.

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