ML20198D391
Text
- _ _
1.
Allegation Category: QA/QC 3, Records 2.
Allegation Number: AQ-129, AQH-16 3.
Characterization:
It is alleged that records stored in the permanent plant records vault (PPRV) were changed and removed without authorization.
4.
Assessment of Safety Significance: The NRC Technical Review Team (TRT) evaluated the Texas Utilities Electric Company (TUEC) and Brown & Root (B&R) permanent quality records storage procedures and found them to be in compliance with the ASME code, 10 CFR Part 50, Appendix B, and ANSI N45.2 requirements.
To verify procedural implementation, the TRT reviewed numerous hanger and piping records stored in the vault for adherence to the permanent records control procedures. The TRT also interviewed vault personnel to assess procedural adequacy and personnel job functions.
A records management manual (Reference 4) addresses TUEC's methodology for the identification, collection, processing, computer indexing, microfilming, and storage of plant construction and operating records. As a result of the interviews and the records reviewed, the TRT found that work packages contained the following types of quality records: QC inspection reports; nonconformance/ corrective action reports; certified mill test reports; supplier data packages, including code data reports; process control docu-ments; heat treatment records; design disclosure documents (i.e., drawings /
specifications); ASME N-5 code data reports; and QC checklists. The vault also contained other supporting documentation for ASME Code activi-ties, such as welder qualification / certification records, hydrostatic l
and pneumatic test reports, and nondestructive examiner qualification /
certification records.
The TRT determined from the records reviewed that approximately 950 hang-ers were voided or superseded as a result of field or design changes. The TRT also found that when a work package was ASME N-5 certified, formal methods existed for the retrieval and updating of the package.
Updating of packages resulted from field changes or design changes to an item or from a related interface with a system, subsystem, or component. The packages were either updated in the vault document review rooms or with-drawn for additional field processing based on approved written requests.
The N-5 data reports were then amended upon completion of the work. The TRT also learned that when additions or updates to documentation for items I
already accepted and processed by QA and the ASME authorized nuclear in-spectors were necessary, they received the same reviews required initially.
In addition, obsolete or superseded records were not destroyed, but were removed from the work packages, separated, and retained as historical re-cords.
In interviews with the TRT, TUEC personnel were asked if they had any knowledge of lost or missing traveler pac.kages or documents. None of those interviewed was aware of any unauthorized removals, losses, or docu-ment changes.
Individuals identified by the alleger were included in this interview sample.
[ g g 860512 f*
7 L9ARDE85-8R _,JDR - -- '
0-117
The TRT performed a special unannounced inspection of the activities taking place in the vault during the second work shift (2:30 PM to 11:00 PM) on August 9, 1984.
The TRT observed no record removal or screening taking place during that inspection.
5.
Conclusion and Staff Positions:
Based on an assessment of this alle-gation, the TRT concludes that no unauthorized changes or removals of records occurred for those records stored in the vault.
Accordingly, these allegations were not substantiated.
(Details of the TRT review of alleged alterations of ASME N-5 welding records are contained in QA/.QC Category 3, allegation AQ-137.)
In a meeting with the allegers on December 10, 1984, the TRT presented the results of the assessment of allegations AQ-129 and the TRT's conclusion.
There were no major items of disagreement, and no new concerns or allega-tions were identified.
Another alleger associated with AQH-16 has declin6d further contact with the TRT, and no further meeting was conducted.
(- _
7.
Attachments: None.
Reference Documents:
1.
ASME Section III, " Nuclear Power Plant Components."
2.
ASNI N 45.2, "QA Program Requirements for Nuclear Facilities."
3.
Brown & Root Procedures:
a.
CP-QAP-12.1, Rev. 11, "ASME Section III Installation Verification and N-5 Certification."
b.
~CP-QAP-11.1-28, Rev. 25, " Fabrication and Installation Inspection of Safety Class Components."
c.
CP-QAP-18.2, Rev. 3, " Quality Assurance R'eview of ASME Documentation."
4.
TUEC Records Management Manual Procedures:
a CP-QP-18.2, Rev. 3, " Implementation of the Permanent Plant Records Management System."
b.
CP-QP-18.3, Rev. 2, " Permanent Records System Organization."
CP-QP-18.4, Rev. 2, " Permanent Plant Records Receipt, Control, c.
and Storage."
d.
CP-QP-18.5, Rev. 2, " Automated Records Management System Implementation."
CP-QP-18.7, Rev. O, "N-5 and N-3 Code Data Reports."
e.
f.
CP-QAP-18.1, Rev. 2, " Management of QA Records."
g.
QI-QP-18.5-1, Rev. 2, " Verification Records ARMS Indexing."
5.
NCRs M-14524N, Rev. 1, M-14531N, Rev. 1, M-14370N, and M-14374, Rev. O.
6.
Office Memorandum to Permanent Plant Records Vaults Employees, from C. H. Welch, QA Supervisor,
Subject:
" Retrieval of N-5 Data Packages from Vault," dated July 9,1984.
l 7.
AQ-129:
A-1 interview, August 1, 1984, pp. 141 and 142, August 2, l
1984.
8.
Field notes of August 9,1984, interviews with vault personnel.
9.
AQH-16:
GAP witness I and A-47.
10.
Closecut interview with A-1 and A-5, December 10, 1984, pp. 35-73.
0-118
8.
This statement prepared by:
k M'
d[
V~. Wenczel,C'RT Date Technical Reviewer Reviewed by:
g 67,gf H. Livermore, Date Group Leader Approved by:
V. Noonan, Date Project Director 4
i e
r f
l f
l 0-119 w--
-r w
e em m-
<------n aw
-r
ew--
..w.
4 This page intentionally left blank 9
1 0-120