ML20198D377

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Partially Withheld Assessment of Allegation AQ-45 to Allegation Category Qa/Qc 3, Records Re Storage of Permanent Records Outside Fireproof Vault Between May 1982 & Jul 1984
ML20198D377
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V, Winczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230234
Download: ML20198D377 (4)
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1. ' Allegation Category: QA/QC 3. Records
2. Allegation Number: AQ-45
3. Characterization: It is alleged that between May 1982 and July 1984, persianent records were not stored in a fireproof vault.
4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) reviewed Texas utility Electric Company (TUEC) and Brown & Root (B&R) procedures and .the Final Safety Analysis Report (FSAR) chapters addressing fire protection of permanent records. The TRT compared these procedures and the FSAR statements with the requirements of 10 CFR Part 50, Appen-dix B, American National Standards Institute (ANSI) N45.2, and the American Society of Mechanical Engineers (ASME) Code for compliance and found them to be acceptable.

The alleger identified several instances in which permanent records were in an environment that was a potential fire hazard. A check of the loca-tions identified by this alleger disclosed that they were standard office

-trailers which did not have any special fire or security protection for the storage of records. The TRT learned that these were "inprocess". records.

~They were stored at "inprocess record stations" at a stage in the work cycle between initiation of the record and the final signoff by quality control (QC) personnel.

Record comp 1_etion was signified by the final QC signoff,.at which time the record was considered complete,1.e., no longer "inprocess." Completed records were then transmitted to a storage facility,-

as described in the records management manual (RMM) and in Chapter 17.1 of the FSAR.

ANSI N45.2.9 does not address protection of incomplete or inprocess records (documents). If these documents are destroyed or lost, the TRT has deter-mined that it is the utility / contractor's responsibility to reconstruct them, or the hardware must be removed and replaced. It should-be noted that re-cords are sometimes retrieved from the permanent plant records vault (PPRV) in order to record modifications to previously accepted hardware. At this point, the records again become "inprocess" records, which are not covered by. ANSI N45.2.9 until they are returned to the PPRV.

In November 1983, B&R established paper flow groups (PFGs) to initiate, distribute, maintain, and store inprocess documents. The PFG facility is protected from fire by overhead sprinkling systems and from vandalism by alarm systems. For additional protection, documents are stored in lockable

- fireproof cabinets; however, there is no requirement that these inprocess documents be treated according to the record storage requirements of ANSI N45.2.9.

The necessary types of records and the methods for record submittal, stor-age, and retrieval are addressed in the RMM. To ensure that TUEC complied with permanent records storage requirements, the TRT examined the records vault under custodianship of the TUEC quality assurance / quality control

-(QA/QC) organization. The TRT found that this vault is constructed of reinforced concrete block with fire-retardant insulation and has entrance doors that are 3-hour-fire rated. Environmental controls are achieved by 3

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a forced air heating / cooling system. The records are stored in standard steel file cabinets. Smoking is not allowed in the vault. The TRT deter-mined that both the vault and the procedures were in compliance with the requirements prescribed in FSAR Chapter 17.1 and in ANSI N45.2.9.

5. Conclusion and Staff Positions: Based on a review of applicable documenta-tion and records and a physical examination of the permanent records vault, the TRT concludes that there are no bases to substantiate this allegation.

In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of this allegation and the TRT's conclu-sions. No new concerns or allegations were identified.

7. Attachments: None.

Reference Documents:

1. ANSI N45.2, "QA Program Requirements for Nuclear Facilities."
2. ANSI N45.2.9, " Requirements for Collection, Storage, and Maintenance of QA Records for Nuclear Facilities."
3. ANSI N45.2.10, "QA Terms and Definitions."
4. ASME Code Section III.
5. Records Management Manual (contains both TUGC0 and Brown & Root procedures relating to permanent records storage maintenance and

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retrieval).

6. FSAR, Chapter 17.1, " Quality Assurance Records."
7. CPL-CPM-6.9.G, Rev 5, Appendix G, " Documentation for ASME Welding, Fabrication, and Installation Activities."
8. CP-CPM-7.1, Rev 1, " Package Flow Control ."
9. CP-CPM-7.1.G, Rev 0, Appendix G, " Piping Supports."
10. A11eg'er Testimony: A-1 Interview, pages 103-106, dated August 1, 1984.

A-1 Interview, pages 21-24.

11. TXX-4180, TUEC response to allegation number AQ-45, dated May 25, 1984.
12. Government Accountability Project letter, dated March 19, 1984.
13. A-1 closecut interview, December 10, 1984, pages 35 through 73.

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8. This statement prepared by:

V. Wenczel # ' Date TRT Technical Reviewer Reviewed by: dF ~

H. Livermore Group Leader ,. Date Approved by:

V. Noonan Project Director Date 0-115

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