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aus= sL6vn, scumois so,37 October 25, 1985 MEMORANDUM FOR: Ed Fox, Allegation Coordinator, Office of Inspection and Enforcement FROM:
Charles H. Weil. Investigation anc Compliance Specialist Region !!!
SUBJECT:
BRAND INDUSTRIAL SERVICE COMPANY FIRE SEALS ALLEGEDLY FAILED FIRE ENDURANCE TESTS (AMS NO. RI!!-85 A-0143; IE-BS-A-0018; RI!!-83-A-0029) i
Reference:
Memoranda August 20, 29, and September 11, 1985, same subject.
The referenced inemoranda forwarded to you information pertaining to an allegation that, twelve-inch fire seals installed by Brand Industrial Services,
Company (B!$CO) at nuclear power plants throughout the country alleg(dly failed the required fire endurance tests. At that tima,the lead responsibility for resolving the allegation was transferred to the IE vender Branch. Subsequently the Illinois _fower_ Company _no.t ind the.NRC Restdent Inspector at~the ~Clinton~Powirr Station of a potential ~ O CFR 50.55(e)u reportable. deficiency involving the~acceptab m tf of B SC0~ fire seals." This information indicated that certain ~ cog;0M4-Cof~nTheheesp 81SCO seals withstood the fire exposure test for on y-two ho h and thirty five minutes instead of the three hours required b ASTM E-119.
- Enclosed is a copy of an inspection Report in which Region III eviewed th g otential 10 CFR 50.55(e) reportable deficiency (Paragraph 78), as M rs'a previous allegation involving BISCO (Paragraph 7A). This information't rovided for your information in resolving the instant allegation.
j Charles H. Weil
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Investigation and Compliance Specialist
- nclosure:
Inspection Report No. 50-461/85047 cc w/ enclosure:
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Electrical penetrations l
In NRC Inspection Report 50-445/84-22 dated October 11, 1984, the I
certification of BISCO electrical penetration seals (fire barriers) was questioned with respect to the testing of the seals.
During the followup of this item, which is discussed in paragraph 2.h above, the NRC inspector identified related but different findings.
The NRC inspector MEd the records to datamine if the doMfst10G for eight BISCO seals support the certification statement. The eight penetrations inspected were; AB-790-174-1022A, EC-854-150A-1018A and-1018B,
- i EC-854-151A-2003A and-2004A, EC-854-151B-2025A and-2026A, and TB-803-010A-1008A.
The following documents contained apparent conflicting information that the NRC inspector has identified for further followup:
BISCO letter to TUGCo dated November 13, 1984, answered the NRC certification inquiry and stated that the subject fire barrier seal (Test No. PCA-76, ANI No. S-26, 24"x42", floor / wall, material 6548, 9 inches depth, LAD or SLD tray, all cables, 40% loaded) met all test requirements of TUGCo Contract No. CP-0707, Gibbs & Hill Specification 2323-MS-38F, ASTM E-119, and IEEE 634.
American Nuclear Insurers (ANI) letter to' BISCO dated August 20, 1985, withdrew its acceptance of BISCO SF-20 (1977) Silicone or Dow Corning 3-6548 RTV Silicone foam for 2-and 3-hour rating without a damming board left in place.
The NRC inspectors ascertained that this withdrawal was based on BISCO not having corplete documentation of the test results and the recent failure of a BISCO sample tested at an independent laboratory employed by the ANI.
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8 ANI letter dated August 20, 1985, to TUGCo informed them of the rescinded acceptance and the test failure that occurred 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and p
35 minutes into the independent test performed in accordance with ASTM E-119.
Further, it stated that this fire barrier may not be i
adequate where'there is a strict requirement for a barrier with a 3-hour rating.
J1 4
Comanche Peak Final Safety Analysis Report (FSAR), page 9.5-223, @(
ge requires that penetration seals be tested in accordance with ASTM E-119 and IEEE 634.
FSAR Section 9.5, paragraph D.1.c. requires:
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(1) each cable spreading room should be separated from other areas of the plant by barriers with a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and J
(2) cabling for redundant safety divisions should be separated by walls having a 3-hour rating as a fire barrier.
Section 9.5, y
t paragraph D.3.c. requires a 3-hour rating for barriers for cable trays N) that contain cold shutdown cabling.
TI)GCo Design Deficiency Report (Tnno) un. rp.as-DE2 dated ATM 29, ON,
,1985, documelim R 4.fttTeiicy.
On the same report, the deficiency
' {C was marked not reportable in the 10 CFR Part 21 and Part 50.55(e)
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reportable block.
The corrective action was for BISCO to prove satisfactory testing of the failed seal and all oYner kiu accepted seals. _
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Note:
The evaluation of deportability is being reevaluated by TUGCo.
BISCO letter dated Sept' ember 16, 1985, stated that approval had been rescinded because the hose stream test data was destroyed or lost i
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during either a 1976 fire or a subsequent move to another facility.
[\\(r It also stated that the ANI testing standards are much more stringent and stated that BISCO seals meet and surnans the test standards of V
ASTM _f-119.
The letter further stated t' hat the ANI representative b\\ A.
wTt'nessed's test on 9-inch silicone foam using the same design J
configuration that failed in the ANI test.
However, the letter also g
stated that the success of this BISCO test was based on applying a i
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3/8-inch proprietary coating on the face of the silicone foam.
The i
letter stated that this retrofit corrective esasure can be employed by those who wish to upgrade this particular seal design.
Note:
It appears that the original seals that were tested had no coating.
TUGCo interoffice memorandum (creamer to Kennedy) dated October 16, 1985, discussed the rework of all seals affected by ANI disapproval l
of S-26.
BISCO memorandum to TUGCo (Trent to Anger) dated October 24 -1985, identifiedceTunt~penetra6iuna to oc rewerneo cruft g w-ep
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The letters discussed above appeared to contain conflicting statements.
i The BISCO letters dated November 13, 1984, and September 16, 1985, differed in that the first one certified to meeting ASTM E-119 and IEEE 634 test requirements, while the latter only mentioned ASTM E-119. The September 16, 1985, letter also stated that BISCO recently retested the original design
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configuration and it passed; however, in the same paragraph on page 2 they stated that they added a 3/8-inch proprietary coating, which according to TUGCo is not on their barriers that are installed.
In the same paragraph, BISCO discussed this coating as if it were a retrofit and/or a design change. Thus, BISCO's claim that their retest was successful appears to be based on testing an upgraded test sample. The ANI letter to TUGCo. dated August 20, 1985, stated that their test was in accordance with ASTN E-119; however, BISCO claimed that the ANI test exceeded ASTM E-119 requirements and thus is an inconsistency.
It is also unclear as to how many test failures have occurred.
Indications are that there were two recent
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failures, an ANI test and a Bistu test failure.
The'following items are unresolved pending clarification or resolution:
a.
Reevaluation of available 1976 test documentation and recent test failures for 10 CFR Part 21 and 10 CFR Part 50.55(e) deportability (445/8516-U-06,446/8513-U-06).
b.
Inconsistent test methods and/or test results documented by BISCO and the ANI test laboratories for the specific design configuration PCA-76 (ANI No. S-26) for which the ANI rescinded acceptance and also the completion of TDDR No. FP-85-063 required corrective actions (445/8516-U-07,446/8513-U-07).
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\\0 BISCO Electrical Penetration Seals Memoranda PHILLIPS stated to 01A that in Novem
,4 Region IV consultant, reported ta s by BISCO compa y officials s
which appeared to W,ts_EHILLIPS two with respect to C0 electrical etration seals meeting test requirements.
PHILLIPS initial cume__
is information in a November 25, 1985, memorandum to WESTERMAN (Attachment 8. Exhibit 19) with a reconenendation that the Office of Investigations look into the matter.
l WESTERMAN returned the memorandum to PHILLIPS and called it inflammatory. Per WESTERMAN's instructions, PHILLIPS rewrote the memorandum on December 2.1985 l
(Attachment B Exhibit 19), and addressed it through WESTERMAN to i
j Gary G. 2ECH, Chief, Vendor Program Branch, IE. This memorandum was taken by WESTERMAN to JOHNSON.
On about January 23, 1986, JOHNSON returned the memorandum to
, and he-also criticized it for being inflammatory. JOHNSON told PHILL PS th e
should have directed the mer.srandum to him (JOHNSON).
PHILLIPS accepte sthe cr',ticism and revised the memorandum as JOHNSON wanted. On, March 6, 19861 the i
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memorandum (Attachment B, Exhibit 19) was sent to JOHNSON.
PHILLIPS' concern over this incident was that he raised a potential safety issue in November 1985, and be:ause management was worried about the protocol in documenting the information, nothing was done with the allegation until March 1986 (Attachment B, pages 215-220).
YOUNG related to OIA that while conducting a follow-up inspection at CPSES concerning the BISCO electrical penetration seals, he uncovered infomation which indicated BISCO falsely certified to TUGC0 that their penetration seals
. ere tested:and met requirements. Additionally, YOUNG was told by a BISCO w
p official that test records had been destroyed in a fire during the sumer of 1976.
YOUNG stated this could not be possible because the test took place L.
during the fall of 1976.
YOUNG related that when he raised the issue of the validity of BISCO's certification of their seals, it was not well-received by WESTERMAN.
(YOUNG provided documentation concerning Bf tration seals -- Attachment I, Exhibit 2.)
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~ons of PHI LIPS' interaction with N
1 Region IV..Inanagement, _if. WFEDMa ha his way, PHILLIPS would just say "yes, s t Cto' WESTERMAN
, therebT, V iminate lot of problems.
YOUNG comented
<that the lar amount of time WESTERMAN spent alking to PHILLIPS, plus the
\\ direction to r1 write ald_fewrite reports, coul make PHILLIPS look k
unproductive as far as conducting inspections was concerned (Attachment I, i\\
pages'61;85).
With regard to the proposed violation pertaining to the certification of the BISCO electrical penetration seals, WESTERMAN related to 0IA that in draft inspection report 85-16/13, PHILLIPS had findings involving (1) TUGCO's failure to adequately evaluate, document and report a construction deficiency in accordance with 10 CFR 50.55(e), (2) insuffi
[PHILLIPS recomended an Office of Investigations successful testing of_BDC0_sedL and (3) the filing of a 1s C0 on which
!) investigation.
PHILLIPS had obtained information that the records for a fire rating test at B1500 were destroyed by a fire during the sumer of 1975, but BISCO maintained certifica-tion on these seals.
Regarding PHILLIPS' concern about the lack of an adequate engineering evaluation concerning the BISCO seals W ~ iCO's failure to report a deficiency in accordance with 10 CFR 51,.:.,,, WESTERMAN stated since the utility prepared a TUGC0 Design Deficiency Report (TDDR) on the lack of documentation pertaining to test results there was no violation concerning TUGCO's documentation of the deficiency. WESTERMAN stated he told PHILLIPS that if he wanted to cite the utility for not reporting the deficiency in accordance with 10 CFR 50.55(e) or 10 CFR 21 then he would have no problem with that violation. However, the conflicting paperwork involved with the certification of the BISCO seals WESTERMAN was not certain it was a clear violation, and he noted that there would be paperwork that indicated there was i
no problem. WESTERMAN stated he did not direct PHILLIPS to write the violation because PHILLIPS was the inspector and he signed the report.
WESTERMAN stated he used his prerogative and left the decision to PHILLIPS.
j If PHILLIPS wanted to look at something more, WESTERMAN stated he was not
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going to stop him.
1 Concerning the possible false report by BISCO regarding the certification of the BISCO fire seals, WESTERMAN related that PHILLIPS prepared a memorandum to him dated November 25, 1985.
Because the initial memorandum addressed actions and conclusions related only to CPSES WESTERMAN asked PHILLIPS to prepare a memorandum to go to the Vendor Branch, IE.
WESTERMAN asked that the memorandum be factual so the Vendor Branch could use it as a basis for reviewing potential BISCO generic issues identified by PHILLIPS. As a result, PHILLIPS prepared a December 2, 1985, memorandum through WESTERMAN to the Chief of the Vendor Branch.
- To the best of WESTERMAN's knowledge, WESTERMAN found the memorandum to be opinionated and to contain recommendations that WESTERMAN thought the Vendor Branch should decide.
WESTERMAN asked PHILLIPS to rewrite the memorandum and gave the instruction that correspondence with IE was the responsibility of the Division Director Eric JOHNSON.
He told PHILLIPS that anything going to IE should go through JOHNSON. WESTERMAN stated the next memorandum was still opinionated and contained unnecessary recommendations.
This memorandum was provided by WESTERMAN to JOHNSON and was the topic of discussions between PHILLIPS and JOHNSON.
PHILLIPS wrote the final memorandum, dated March 6, 1986, through WESTERMAN to JOHNSON.
WESTERMAN further opined that the decision to refer a, matter to 01 should be made by the Regional Administrator or Division Director and PHILLIPS should not have asked for the 01 referral.
WESTERMAN stated that JOHNSON had some discussions on this issue with the Region IV Allegations Coordinator (Attachment D, pages 526-527 and 642-643).
JOHNSON related to OIA that, in January 1986, he had a meeting with PHILLIPS concerning a memorandum that PHILLIPS had prepared on the BISCO fire seals.
JOHNSON comented that PHILLIPS had written several versions of a memorandum on the BISCO seals which eventually was sent to IE. JOHNSON stated the i
original memorandum was from PHILLIPS to Gary ZECH, Chief, Vendor Program Branch, IE. JOHNSON believed PHILLIPS should have sent the memorandum throu h h : L Region IV management.
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@s Additionally, JOHNSON comented the original BISCO memorandum t ECH which p
came to the Region requested an 31 investigation. JOHNSON did et think it was proper to request an O! investigation in a memor m to he Chief of the Vendor Granch, JOHNSON was also concerned that thrus f the memorandum was not the technical problems with the BIS ls, bu s ead was the possibility that BISCO may have falsified o destroyedfecor/s. _ JOHNSON did no believe thic g a e e Q utinn th t coul _ e arrived atAased on the 3
tation presented in the memorandum, ne w fev M he NRC did not nave nough information at that time to request an OI investigation of BISCO.
JOHNSON stated that, based on his reading of the memorandum, he did not discern a problem with a fire at BISCO in the sumer of 1976 which allegedly destroyed records created in October 1976.
JOHNSON stated that he asked Don DRISKILL, a Region IV OI investigator, whether there was sufficient infonnation in the PHILLIPS' memorandum to warrant initiation of an 01 investigation. DRISKILL told him the matter seemed to be a vendor problem. JOHNSON decided to ask ZECH to put BISCO on the inspection list.
He thought that the, Vendor Program Branch could use the i
information in the memorandum sent to IE Vs background to highlight sone of m
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the areas the Vendor Program Branch should inspect. JOHNSON comented that the purpose of the memorandum that he sent to NRC Headquarters (April 4, 1986) was to point out possib13 4eneric<oncerns (Attachment P, pages 15-18, 78-85 and 99-102).
Edwin F. FOX, Allegations Coordinator, IE' was interviewed by OIA concerning his involvement kith the issue involving he BISCO electrical penetration seals at'CPSES.
F0 h tated he had r ous involvement with respect to BISCO as part of the IE allegation agement system.
This resulted from problems
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identified by Region III.
FOX reviewed the April 4,1986, memorandum from j
'JOHNSONtoJ.G.PARTLOW, Director,DivisionofIns comented that the first problem IE had was the memorandum was sent to the 4
wrong office. Because there was a technical requirement at issue, the memorandum should have been sent to NRR. FOX ensured the memorandum went to 1RR for resolution. Based on his review of the memorandum, FOX stated there ppeared to be a safety concern which needed to be addressed by MRC, F0Y.
t further opined that the BISCO issue could be a generic issue (Attachment Q,'
g,
pages 7-13).
' Thomas SCARBROUGH reviewed the concerns expressed by PHILLIPS that violations s
proposeWPHILTIPS and other inspectors in inspection report 85-16/13 were unjustifiably downgraded to unresolved items by Region IV management.
SCARBROUGH documented his technical assessment of these proposed violations on pages 23-27 of his July 8, 1986, memorandum and pages 4 and 5 of his November 25, 1986, memorandum (Attachment HH).
t Stephen G010EERG perfonned a review of the technical issues contained in inspectiorrrE#6ft 85-16/13.
He reviewed five issues that were specifically related to OIA as allegations by PHILLIPS. His assessment is documented on pages 14-18 of Attachment MM.
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PHILLIPS was concerned about potential wrongdoing by Brand Industry Services, Inc. (BISCO) in their certification of their design tests for fire seals.
PHILLIPS recomend an 01 investigation and IE vendor insraction of the matter in two draft memoranda. PHILLIPS' management criticized both draft memoranda because Regional management considered them inflammatory. On April 4, 1986, Region IV management did refer PHILLIPS' concern to IE management; this was at least six months after the finding. Also, PHILLIPS had identified in his 9 draf t inspection report (05-16/13) issues involving the filing of a false
_Ik report by BISCO,. insufficient evidence of successful testing of 81500 fire seals; and potential violations involving the utility's failure to adequately j
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evaluate and report a construction deficiency, per requirements in 10 CFR L
50.55(e) and 10 CFR 21. The failure of Region IV to promptly consider PHILLIPS' concern as potential investigative matter was communicated by l
However, PHILt.IPS' concern about downgrading violations and PHILLIPS to 0IA.
changing his findings concerning the BISCO seal problem was identified in his There matrix but wcs not addressed by PHILLIPS during his interview with OIA.
might have been potentially safety significant issues that were dropped and changed in the draft report (those should be referred to the E00 for his follow up andyot considered to~b^eWt of this investipitfo6V
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l PHILLIPS wrote two memoranda to his management and one memorandum to IE Vendor Branch about the generic implications of certification problems with BISCO According to PHILLIPS' and draft memoranda, the records for fire seals.
rating tests at BISCO were destroyed by a fire at BISCO during 1976, but BISCO maintained certification on these seals in the absence of these records.
JOHNSON told 01A that he did not discuss the technical issues with PHILLIPS but he did discuss the wrongdoing aspect with a Regional 01 official who chose p f((
JOHNSON was upset that PHILLIPS desired to comunicate -
not to pursue it.
s T) directly to IE's Vendor Branch and not through Region IV management.
WESTERMAN told 01A' that he chose not to pursue the violations concerning the utility's failure to file a 50.55(e) and the lack of an adequate engineering evaluation concerning these seals.
Technical Evaluation Of This Concern It was learned that, based on the April 4 Johnson letter, the IE staff did pursue the matter.The IE staff acknowledged that BISCO fire seal problem might have been a generic problem. The IE staff referred 01A to a Region III inspection report at the Clinton facility.
This report concludes that the inspectors found that the BISCO fire seals did satisfy the regulatory However, it is unclear whether these seals are similar to.the requirements.
ones at Comanche Peak.
' Conclusion For This Concern Based on the information in PHILLIPS' draft memoranda, the Region should have I
promptly referred the matter to IE.to determine the generic implications of f
the BISCO fire seal problem. Until a determination is made concerning the safety significance of PHILLIPS' findings and whether the resolution of the l
fire seal problem at Clinton applies to the seal problem at Comanche Peak, it l
is premature to detemine whether an 01 investigation is required.
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Recommended Disonsition of nIA Repnrt Pelated to L,
. RIV Inspectors' Allegations
,by David C..lena, PAER, PWR-A r
December P, 1986 4
U 1 have' reviewed'the subject report (summarv'only) and the reports prepared by g
.two OIA consultants addressing the same subject on December 6, 10R6. The followino represents summary of mv findings and recommended disposition of the report;
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Summarv of Findinas I.
The summary of the allegations can be highlighted as a.
Prior to 1084, the RIV OA inspection program and its implementation with respect to Comanche Peak Steam Electric Station (CPSES) was weak and inadequate, b.
There were indications of poor management Dractice and inadequate dispositions within RIV regarding determination and citino of CPSES QA/QC violations, and i
c.
Form 766 Used by RIV in tracking the OA/0C activities was inadequate and caution should be exercised in interpreting licensing implications of the Form 766 data.
i 2.
From my personal. perspective, the above listed three items are new information to me, although it is likely that some of the alleged l
RIV OA/QC activities may have been investigated under prior CAT or TRT efforts.
In any case, the three issues listed, in my.iudgement, should not and would not e#fect.the qualifiability of affected CPSES structures, systems and components. The acceptability or qualifiability of the a#fected structures, systems and components
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will be determined strictly based on the merits of the results of j
the on-going CPRT program.
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.Since.the credibility and acceptability of CppT orogram results i
depend, in part, on implementation of a competent RIV on-site staff QA/QC inspection prooran, the disclosure o' the above.three allegations may significantly damage.the credibility and acceptability of the CPRT. program results.
Proper measures should be taken by NRC to ininimize the damage to and restore the CPRT l
program credibility.
II.
Recommended NRC Dispositions 1.
From the technical review standpoint, the entire OIA reports and the consultants' report should be disclosed to the-public sub,iect to modification on the extent of disclosure by NRC lepal staff in crder to comply with F0IA and privacy Act.
Appropriate Roard notification of the information'as reouired bv regulations should also be promptly implemented.
2.
Appoint a qualified group of NRC 0A/0C staff to examine the soecific j
allegations delineated in the referenced RIV inspection reports and
. ensure that either all the affected CPSES structures, systems and components.have been included in the on-going CPRT program for i
evaluation or identify a list of the affected items for satisfactory evaluation and disposition by the applicant's CPRT program.
1 3.
NRC management should take necessary measures including, as needed, change of RIV OA/QC inspection staff, to minimize the damage to and restore the credibility and acceptability of the CPRT program results.
4.
Appoint qualified NRC staff to reassess the alleged CPSES 0A/0C-violations and cite the applicant for valid violations based on applicable regulations. Also take needed measures to improve l
RIV procedures for citation of 0A/0C violations and use of Form 766.
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Implement personnel actions needed to eliminate the peor manacement J
l cases which may exist within RIV, e
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July 9, 1985 TXX-4508 Mr.'D.R. Hunte'r,. Chief Reactor Project Branch 2 U.S. Nuclear. Regulatory Commission Office of Inspection & Enforcement-611 Ryan Plaza Drive, Suite 1000 Arlington,.TX 76012
' COMANCHE PEAK' STEAM ELECTRIC STATION UNIT NUMBERS NOT PROPERLY IDENTIFIED FILE NO.:
10110
Dear Mr. Hunter:
1 During a recent NRC Inspection, it was identified that certain letters advising the NRC'of the final determination of Significant Deficiency Analysis Report's (SDAR's) identified as' reportable or potentially reportable under 10CFR50.55(e) may not have properly. identified the applicable unit.
We have reviewed each of.these SDAR files and identified any discrepancies.
The following will clarify for your records the applicable unit for each item.
SDAR Applicable Unit 77-07 1
77-08 1
80-04 2
80-06 1
81-04 1
81-C 1/2 82-04 2
82-05 1
82-06 2
82-11 1
4 82-12 1
.82-15 2
83-06 1
83-16 1
83-22 1
84-01 1
84-02 1
84-17 1
84-23 1
84-29 1/2 85-12 1
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A RetVin24 N t>r TELane t*TILlTIEN ELECTotir rnntrogNg EXHIBIT 61
D l-0235 Breat Loss of Coolant in Mode 4 SMR-CP46-41 Phillips,S.
UNli ("L2 B6-11-04 1
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Operation of EM Core Cool Sys.
BT-6W2i(
T11 6062 DRSP 4
l D l-0238 Mis. Separation of O'elded Strips h{)6%d7' SDAR-CP46-44 Phillips,S.
UNIT 112 B6-11-03 1 l
on Esbeds not in Procedures.
0742-06 TII-6035 MSP 3
i D 14239 Design of Seissic Cat !! Change 0 B6-06-06 S UR-CP 4 6-45 Thillips,5.
UNIT 112 86-11-03 1 did not consider kontat ! Equip' ' B6-12-03 T!X-6008 BRSP 3
D l-0279 Battery Rack Engineering Changeg II6D12'SMR-CP46-46 Phillips,S.
UNIT 2 86-11-12 1 not forsally Evaluated.
Il7Ey T!!4052 DRSP 4
ff 1-0241 Fisher Control Hounting Bracket h {16-06-17@
SCAR-CP-86-45fhillips,S.
UNIT !L2 B6-11-03 1 Welding Unacceptable.
TII4036 DRSP 3
BFF F)
D l-0242 Replace Cra:et Module Sealant SMR-CP46-49 Phillips,S.
UNIT't&2B6-11-25 1 111 4 101 DRSP 4
caused by polar organic solvent Dl-0243UnistrutConnectionsidentifiedg'E e 7 SMR-CP-86-50 Phillips,5.
UNIT lL2 B6-11-03 1 Nuts Misaligned and Not Torqued l'
T11-6019 DRSP 2
D l-0244 Hilti Anchor Bolts say not seet Q '8 _07-2i SDAR-CP46-51 Phillips,S.
UNIT 112 B6-11-25 1 Avg.Ultisate Tensile Loads.
87-01-30 TII-6093 DRSP 3
Splice /ConnectorConfiguration$,6507pS',
D l-0245 Conforsance of Cable Tray SLAR-CP-86-52 Phillips,S.
UNIT 1&2 B6-11-04 1 186-2 12 T!!4053 DRSP 3
D 14259 Seissic Design of Ccnduit.
[0]%6"7,25' h-SDAR-CP-S6-53 Phillips,$.
UNIT 162 B6-11-04 1 13E1F10 T11-6054 DRSP 3
Cosply With FSAR:1RT RPT.
~,'BETB 0T '
5 SDAR-CP46-54 Phillips,S.
UNIT 162 86-11-25
.1 0 14246 Control Roos Celling Does Not *0:
86-12-19 111-6091 DRSP 4
D l-0247 Required 2' Air 6ap between An D. '06 0'SM' SMR-CP46-55 Phillips,$.
UNIT IL2 86-11-15 1 Y
& tantain.Bld.l. net saintained
^'87-03[13'.
111-6107 DRSP 2
1 D 1-0251 Verify documentation to supportg '7651E27.'
06 09103' '
SMR-CP46-!9 Phillips,S.
UNIT !L2 B6-11 03 1 Anchor Separation Criteria.
T11-5052 DRSP 1
D l-0252 Polar Crane Support Birder g 'dh9{0B" SMR-CP4640 Phillips,S.
UNIT lt2 06-11-03 1 D l-0254 PolarCrane Load Cases Not Consih [g'E6-Ci9 Brackets not Shissed.
2-lf' 111-6009 DRSP SDAR-CP46-62 Phillips,S.
UNIT 1L2 B6-11-03 1
+. -
dered in Design of SupportStruc 3M93 T114011 DRSP 1
D 1-0255 Cracted Cotter Pin in Reactor g@Q SMR-CP-8643 Phillips,$.
UNii i B6-11-03 1 Coolant Systes. 024 TII-6027 DRSP 1
D'l-0256 Tech. basis for repair of safety l FD9 bli SDAR-CP-5644 Phillips,S.
UNIT 112 B6-11-03 1
' related coating in TrainA tank g[
111-6013 DRSP 1
0 1-0280 Unconsolidated concrete on erte
--7 SDAR-CP-9645 Phillips,S.
UNii 2 B6-!!-12 1 T7 TII-6024 DRSP 2
Q - Y]
rior wall U-2 Reactor Cont. Bldg SMR-CP B6-66 Phillips,S.
UNIT 1&2.06-11-03 1 D 1-0257 No lap bar on sose vert. dowel D 1-0258 Pre-Operational Vibrational Teh g- "d
. bars in mall ci auxiliary bldg III4061 DRSP B6-09-26 EDAR-CP4647 Kelley,0.
UNIT 112 86-11-03 1 t criteria drI@
TII4072 DRSP 1
D l-0261 teather Protection of Class IE Q FF02SMR-CP-86-68 Phillips,S.
-2512 UNii 1&2 86-11-25 1 Components Located Outdoors.
D 14262 IEEE 420-1973 Requirements of [ L --f-111-6081 DRSP 1
SDAR-CP46-69 Phillips,S.
. UNIT 1 65-!!-03 1 Wire Bundle Supports.
DRSP D l-0263 Elevated Temperature on instrus h
}
- $2 SDAR-CP46-70 Phillips,S.
-2512 tmliIL286-11-64 1 ent tubing.
h-0-la, TII4067 DRSP 1
D 14264 Mar. length of lE Cable verticald [Y df' S MR-CP-86-71 Phillips,S.
-2512 UM T 1&2 86-!!-25 1 ly pulled alo Tension Measure.
86 3 6]
TII4065 DRSP 1
D l-02c5 Small Bore Piping & Supports. [0'66-10;15, SMR-CP-56-72Phillips,$.
UNIT ik2 86-!!-03 1 g-g1M 111-6042 DRSP D 14266 Proper Function of Rear Bractet M BF,0-2T"'
SMR-CP-06-73 Phillips,S.
UNiiIL266-11-03 1 s Supplied by NPSI.
~Y72]
DRSP D 14281 Unit 2 Roctuell Supplied (Oi
- -2 SMR-CP-B6-74 Phillips.S.
LRlli !L2 86-11-25 1 iIsolation valves.
tSGd TII4084
.DRSP 1
v D 14267. Contaminated ASCO Solenoid g %-: 0-21 SMR-CP-86-75 Phillips,S.
UNIT 1L2.86-11-25 1 f,'y V.
1 Valves, Seals, n 041ngs.
T11-6097 DRSP ii g,.!'-0268 fossible Vendor Related Deviati g SMR-CP46-76 Phillips,S.
UNIT.!L286-11-25 1 W jn. '
ans of Sould Battery Racks.
111 4 110 DRSP
,1 k* dB 4-4269 Mislaus Wall Requirements for g
-l i
SMR-CP46-77 Phillips,S.
cDNIT 112 86-11-25 1 Instrument Tubing & Fittings.
f) 111-6103 DRSP 1
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FILE NW'E : REPOR1 :.
NOVEMBER 26, 1985 5."~
STATU$ OF AUDITED SDAR's from h.
5}
TUCCo. QA/QC OPEN ITEMS REPORT cated 11/22/85
' M,, !
84-05 Not Reportable / NRC Agree
, {.7,;,
84-22 Not Reportable / NRC Agree d
'U 84-23 Not Reportable / NRC Agree 64-24 Not Reportable / NRC Agree 64-26 Not Reportable / HRC Agree p
[
fk....,[
,g 9 4-2 "'
10/29/65 - Reportable. Required rework / tests to be completec ah.;'f' y g 29 10/29 d5 - Reportable Ucrk not complete
,M g.30 2 N2C/85 - Not Reportable Recommend Closure h,T? J 3n$u ff icient Documentation to Determine Reportable
[fE* ',M S w.ur
- j. "
hl 84-52 Hot Reportable / NRC Agree
'W MW'NEN T i a.. 'O e4-34 10/29/85 - Not Reportable Recommend Closure Insufficient Documentation to Determine Reportable ta? ' '..,
Status f. js[ #
85-02 Not Reportable / NRC Agr++
85-04 10/29/85 - Reportable Unit 1 MDS 789S L Unit 2 MDS
..,. #:'E, V.,..
695 open
.y
[.., (*
S5-05 10/29/85 - Reportable 2-3004 Unit MDS 2S moved to G" h@@d 2-3003 Item 42S ff' tj';,,'d s.:
85-06 10/29/C5 - Not Report able NCR's E-85-10019S, y**';
Ly ',
E-84-100614. E-64-100616, & E-84-100620 open?
.,Ig{^t.;,
/,' J :b..
t Insufficient Documentation to Determine Reportab,
' hi.
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l S;atus
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- 7. 'N/MM I***/"
E5-05 Not Reportable / NRC Agree 4
- k,,-[f f
,?
@.'QM48,< M. '
B 5-L'?
Not Reportable / NRC Agree 3
.yfj,[,',
85-11 10/29/85 - Reportable NCR 1-85-100222 open'.
9)/
't?;;.
8r... s.>:.c, G5-12 10/29/05 - Reportable Status being updated A. t ',.
D'
..g.
$85-13 10'29/85 - Reportable Unit 1
.a.
- c..
action not complete y P'.-
85-14 Ir /29/85 - Reportable NCR M-15965 & M-85,-2OO233 y't 3,
- Fev. 1 open s
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..ur" EXHIBIT 57.b 1
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October 16, J1,985
~
.:,. A v+. *
~
'di
.,;. McCloskey, sumkary of activities for 10/14/85 through 10/16/885;,
- ' 515.
R SDAR FILE REVIEW
SUMMARY
OF PRELIMINARY FINDIHCS i$..f.K '.
SDAR's were chosen for review usin,9 the followin 4)iterial]'
g cr
- 1. Review'of open SDAR's 10/14/85 by H.S. Phillips
- r. '.-,'.i
- a. SDAR assigned to R IV Const., and
/N k.
'7 '
- b. SDAR' is Reportable
- 2. Station OPEN ITCMS REPORT 10/4/85, Open SDA Identified Date of completion has pass.R's a.
ed, or b.
Identified as Licensee action complete'
< this has been defined by the Licensee as the
'repo rt i ng cycle has been completed)
SDAR Files Reviewed (location)
HRC Welch l
T(4..
Baker in general these files are more complete 2b,
,.?f,' ' Begin SDAR File Review Summary
.'.'M' h,-
2 l
t' b..p.'
Conte nt s :
)
identifies the problem and lists corrective actions N '.
3 identifies process documents I
' s.
j i,$..
provides analysis of 1 E electrical supply o ff' '
identifies HVAC removal of gases' test E.'
provides heat load analysis of rooms
... J. 0"
' r.5 provides. analysis of room equipment operating times identifies rooms - operating temp - operating time identifies PPF packages 131 Aux Bids 132 Safe Guards 133 Primary Plant 134 Fuel Blde and 9 other specific items to be considered identifies additional dampers to be eliminated
~ ~ '
cover page for a CPSES final design package relocate local cont rol station directive to perform testing of HVAC af.ter rework identifies rooms requests the recording of flow rate and direction PPF 132 released for construction
.L PPF 133 released for const ruction
'w.. "f'v?
!.e.'
.1 S request for Operations to include appropriate trotnin's 4/ d[I' procedures L O T.
PPF 134 released for construction identification of t ripping room lighting analysis oflH2 accumulation in room room thermostat analysis as fi re ignition source 1
b
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4
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+
9" f?jjdt, room therrnost at set points to t rip lights hpEp%l' s,'j
.T analysis and walk U rough check for ignition sources requi red cornplet ion dat es identified I
4 Y/Df/..,8,
last date 11/2/85 a.tdMF., A m.
HVAC test
'g
.9l explosion proof lighting installed i
.;f ; '.
damper replacement by 7/31/85
, (..
[.'...l(
list of applicable specifications to be revised by 9/1/85j)f
]
Q.'-
for Safety Related equipment FSAR revisions identified
.,j.
..
- SDAR CP-84-29, Control of Plant Functions during Fire Y, hff, ',h',c,. Contentst
'J-..O'/ :.
identifies problem t.
M /# e:c.y/. ' ' identifies corrective actions a
.dh:~'[ANJ.
l 'y engineering and const ruct ion will be completed prio.r to.;P.. N..r.,:'
- 'g plant ascension to 5 */. power
. "1..
3, f;
re-evaluation of essential CR HVAC components analysis A.
identification of essential functions
't v
a y.. J identification of essential components W. '
I;[,'
jp proposed Tech Spec changes to satisfy AppendixRconcernspg tj y *
?"
@Q
- d,.,.
',* SDAR CP-65-04, Quick Opening Velves may t rip Cont. Spray Sys, $ tv.,4:.'
..' W..;sWA. Pumps
'Wnd, W '
.:.s<
v V
Contentsa v'
.' sDl, kp,,':
J identifies problem and corrective actions
~'*
I 'E lim.N schedule for work
.E hYN T ' implementation by DM IE' k
'h [$:jf.EIO released for construction 10/2/85 O.i F
'3,$9,i
.. [1 lp O' A' identifies work of Rev 2 t Rev 3 N 0Y Q sf specifies documents and drawings
' 1,
?
QM,,,,,
,PPF 140, Rev. 3
.Y, f$k:;',h!l! '
.y.
^
Contents:
identification of problem
. order parts
{
^
ma'Jter data base assignment
. 't description of adverse conditions s
l{'.,
' corrective action
- j.'
't...
g(g-*4/SDARCP-85-11. Seismic Problems with fittings between'
.h..a unsupported points and bends in tubing ci. Contents:
. &,1 8,
.w l[
ident fication of problem a
- J iden ification of corrective actions
' Q{3,',',.f*;
discussion of problem
.'Q 3,..g. t
- d/g;;.(,* SDRR CP-85-12, Aux Feedwater Flow instrumentation unacceptable JM'Y '8 Ffb set points k" T, h.
I' Contents :
i '.
.identif.ication of problem
.M '
.f..,
identification of corrective actions
.'y.n Y
'^
identification of inst rument setpoints
,',,{[
~
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j
- j.
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2
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- $sersee mPS hemum* *.sms **
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iT ": '
.F.
',s
,3,
/
fin /
identification of problem Kl M!;fVc identification of co,rrective action
% lll5)
- 0
- SDAR CP-85-14, Unauthori=ed Uelding repairs
- v. 2 d. '
Contents:
.Vr.. ',.
' i.. =6 *'
shi'((f.,N?
identification of problem identification of corrective action
,, j. l', p..,
' '.i h Hon-Conformance repo rt s jyjkhh{T overview of welding problem 3
interview t ranscripts
,r#,gp report of findings 9
additional interview report
\\
e f
SUMMARY
,y,,
The paper trail, for the above SDAR's does not-appear t'M' be
,J complete.
The files do not include any type of closing inspection or signoff verifications.
Fu rt he r discussions with the Licensee have identified
- that the NRC can not close an SDAR that lacks a comple'e
,,t he fact
'1, trail.
The Licensee has indicated that they will status the'SDAR t
P. ape r file contents prior to NRC review.
The NRC would be spinning its wheels cont inuing the review, unless the file status is performed
/'.l by the Licensee.
N[f.tw:.j/#4. A brief review of the applicable site procedures follows:
??%
. 'E N.l-* CP-QP-15.6, Rev. 3 Jan 16, 1985, SDAR STATUS TRACKING
- %li,.'.'( M
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. M.
u
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.
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(
/.[ ' '.,20 method for t rackins SDAR's
- '+
[f
[b-maintaining the OPEN ITEMS REPORT
?,, d:
'l.,..
- CP-QP-16.0, Rev. 18, September 4, 1985, NONCONFORMANCES
.s to establish a method of documenting the identification, resolution, and closeout of nonconformances identification of nonconformances numbering nonconformances nonconformance documentation review of documentation identification of 10CFR50. 5( e )
disposition enginee ring review and approval Quality Engineer review implementation verification / closure r
9
- CP-QP-16.1, SIGNIFICANT CONSTRUCTION DEFICIENCIES h.... <
f
.,. @Jj,: fi does not mention 10CFR SO.55(e) except on SDAR Torm
t'Yi%Qf,.
' 4 $ i ' '[
primarily directs how to complete the SDAR form i ?O 4
G
/
I i.
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.McCleskey,-summary of activities for 10/14/85 through 10/18/885.
l-1 SDAR's were' chosen for review using the 1b11owing criterial 1.
Review of open SDAR's 10/14/85 by H.S.
Phillips j-a.
SDAR assigned to R IV Const., and b.=SDAR is Reportable or Non-Reportable 1
- 2. Station OPEN ITEMS REPORT.10/4/85,'Open SDAR's Identified Date of completion:has passed, or a.
b.
Identified as Licensee action' complete
<this has been defined by the Licensee as the reporting cycle has been cospleted)
SUMMAW.
The SDAR review is being performed to formally. document t hat the l
HRC is
.in agreement with the Licensee action to resolve a specific SDAR.
Twenty SDAR's have been reviewed this weeke eight l
Reportable and twelve Non-Report able.
The results of the review are that nine of the Non-Reportable SDAR s are mutually agreed to e
be closed.
The remaining Non-Pepo rt able and Reportable SDAR's are to remain open with respect to NRC reporting considerations.
Review Findings 3 1.
The Licensee is assigning the SDAR as a category of " Licensee Action Complete" when the NRC reporting cycle is completed.
Th!s category assignment has little to do with whether or not the SDAR identified corrective action has been implemented or completed.
2.
The SDAR files referenced (for review by the NRC) by the Licensee report cycle letters to the NRC have not been reviewed by the Licensee for content to verify that the associated documentation is complete.
This is the major deficiency, the Licensee SDAR files contain insufficient documentation to support the corrective actions taken by the Licensee to resolve the SDAR.
The paper t rail for the SDAR's is not complete.
The files do not include any type of closing inspection or sign-off verifications showing that the work was completed as described.
3.
The Licensee is not complying with the requirements of 10CFR50.55(e) with respect to $DAR NRC repo rt content.
The report to the NRC should contain sufficient information to permit analysis and evaluation of the deficiency and of the corrective action.
i Where appropriate the SDAR files document Licensee Engineering 4.
Department recommendations for SDAR resolution to the Operating Depa rt ment.
- However, there is no documented follow up from Operations to verify that the recommendations have been implemented.
4 1
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FILE HAMEt REPORT.8 DECEMEER 04, 1985 4
STATUS OF SDAR FILES v'N October 14 L 15, 1985 - Audited eight of the CPSES site Reportable SDAR files which had been identified by the applicant as " Licensee action Complete".
Ali eight files
)
did not contain sufficient documented information or 4
reference other documents verifying that the corrective I
action had been completed.
October 17 6 18, 1985 - Audited 12 of the CPSES site j ^
- s.,
Honreportable SDAR Tiles which had been identified by the
[r!.
applicant as " Licensee action complete".
Three files did g/.
not contain sufficient documented information or reference other documents which contained sufficient information to y.
fi',' -
determine whether or not the SDAR was "Non-Reportable".
my' '
Hovember 24, 1935 - The Applicants OA/QC Open Items Reporte dated 11/22/85, was reviewed to -det ermine the current status of the'above <OPEN) SDAR's.
j Reportable SDAR's - The eight SDAR's are reported as Tol ows:
i ;
84-27 Required rework / tests to be completed V
84-29 Work not complete
+.
at 85-04 Unit 1 MLS 789S t Unit 2 MDS 69S open fy ;
- L -
7 85-05 2-3004 Unit MDSV2S moved to 2-3003 Item 42'8 i
%f W:5-Wr 85-11 NCR I-85-100222 open fffE;h;l ', ;,
J gg 85-12 Status being updated gA 85-13 Unit i action not complete
)
85-14 NCR M-15965 L M-85-200233 Rev. 1 open
?
Hon-Reportable SDAR's - The three SDAR's are reported as Tollows:
(
84-30 Recommend Closure f
i 84-34 Recommend Closure i
85-06 HCR's E-85-100193 1
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- 2 '. '. / 8 5 REVIEW IOc TL ',C'i
.I-~ I; i THE NRC W$ICH DOCUMENT THE'
,A g),,
1 OCFR5Q. 55( e > *Itc; N,E
- (y' y )
A.
in+
followins table, icentid ier tne
- SDAR, the related TUGCo.
d letters to tne NRC, end wh+tner or not the letters address 7 th'e p
ef
+.c
,, Tg' q* 3. &.y specific r+ qui renient s of 10CFR50. 55( e ).
g ;3.d.',
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- DESCRIPTION l ANALYSIS l CORRECTIVE IREPORT'CONTAINS e
- i. j '3' LETTEA UNIT :
QF IDF SAFETY
- ACTION I SUFFICIENT LATE lDEFF:CIENCY lIf*LICATIONS:
TAKEN 1 INFORMATION
^
...j '
63-20 i
C' WILL BE BY d-'ffc 40?!
10 2 YES YES 3/30/84 8.
YES
' " ^ '.
. D 184-.
g<
30 DAYS Poici l
.e,,.
~~
- ELlC.65Qhs. yi,,, ;-
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- t2 SUFFLEMENT LETTEF
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g6l.h;LBS-20 WILL BE *.:BYI,., ' "YES l~.40?!
I t.2 YES YES MID DEC/83-g M
.1*/;s/85 p
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1&2 SUPPLEMENTAL LETTER 2'. 4 K4;, *
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4042 1C SUPPLEMENTAL LETTER
[ J...i..
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WILL BE *RIOR
-6 1 t. 4 YES YES TO FUEL ' 01D
.YEST
$3.
.ILL BE'1Y.
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/E :
YES
- 1/c3 t,
- 9/ : 3
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I U.S. NUCLEAR REGULATORY COMMISSION 4
OFFICE OF INSPECTION AND ENFORCEMENT k
IE MANUAL 1
TITLE 10 CODE OF FEDERAL' REGULATIONS This chapter provides guidance on certain sections of Title 10, Code of Federal Regulations. Guidance presented herein does not constitute written interpretations by the Office of the General l
Counsel even though some of the guidance may have received con-currence by the legal staff and other Regulatory components.
Although not ofijcial interpretations, the guidance presented should be used' in. determining whether a person's activities con-stitute noncompliance with the regulations.
It is not intended I
that all sections of the regulations will be discussed; rather, the chapter will include discussions of those sections-that appear to require guidance to the Inspection and Enforcement staf f and for which a well defined position exists.
1 Each issuance in this chapter will contain an identification of the regulation and section for which guidance is provided. This identification will appear in the upper right corner of each page together with the date of issuance.
Examples are as'follows:
20.403 50.59 Issue Date: 5/17/76 Issue Date: 5/17 /76 Issuances should be filed according to the numeric sequence in the upper right corner. Pages will be numbered sequentially in arabic numerals within each section of the regulations for which guidance is provided.
6/1/76 I
EXHIBIT 54
10 CFR 50.55(e) o i
Issue Date: '4/1/80-n N -
Guidance - 10 CFR 50.55(e). Construction Deficiency Reporting 1..
PURPOSE
.I Deficiency reporting based on the requirements of Part 50,55(e) is designed to' provide the NRC staff with prompt notification and timely information i
of deficiencies encountered during construction of nuclear power plants.
The -intent of the Rule is to provide a basis for evalua' tion on the part of the NRC with respect to potential safety consequences of deficiencies and the need for further. action by NRC.'
2.
DISCUSSION - GENERAL The conditions of construction permits are contained in 10 CFR 50.55.
Subpart 10 CFR 50.55(e) imposes a reporting requirement on construction permit (CP). holders to report each deficiency found in design and construction which if-it were to have remain uncorrected could have l
adversely affected the safety of operations of the nuclear facility at i
any time throughout the expected lifetime of the plant.
Reporting is limited to deficiencies which meet certain other requirements as discussed below.
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RESTATEMENT OF THE REGULATION l
i The en' tire subsection of 10 CFR 50.55(e) is included here for convenience.
50.55(e)(1)
If the permit is for construction of a nuclear. power plant, the holder of the permit shall notify the Commission of-each '
deficiency found in design and construction, which were it to have remained uncorrected, could have affected adversely the l
safety of operations of the nuclear power plant at any time 1
throughout the expected lifetime of the plant, and which represents:
i (i)
A significant breakdown in any portion of the quality assurance program conducted,in accordance with-the requirements of Appendix B; or (ii)
A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit; or (iii) A significant deficiency in construction of or significant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in
.the safety analysis report or construction permit or to h'
otherwise establish the adequady of the= structure, system, or compobent to perform its intended safety function; or s
-...... -.... ~.. _ _
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Issue Date:
4/1/80
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7 when: (1) an intial prompt review of available information indicates that the problem could be significant (i.e. -
partial significance is established) but, for various reasons, additional time is required to complete the evaluation! and (2) the deficiency may be considered significant, but neither a prompt review or full evaluation can be completed within 14 days duto lack of specific e
information.
For examp1.e, an extensive evaluation period may exist when the licensee'cannot determine without testing and analysis whether the physical properties relative to the material used for a section of reactor coolant piping were met, the licensee should promptly notify the Regional Office of this matter.
If the results of the above analysis indicates that the material is not acceptable, extensive evaluation and/or rework may be required.
If this is the case, it is clearly a reportable deficiency.
Conversely, if the analysis in the above example confirms acceptability of the material, the licensee should document these results in his records i
and notify the Regional Office that this deficiency was determined not to be significant based on the results of further analysis or investigation.
Consequently, some matters which require notification may not, subsequently, require.a written report.
In summary, the intent is to require a prompt notification in cases where a potentially reportable deficiency has been identified but the. fonnal evaluation required to confirm whether the item is reportable can not be completed immediately.
(3)
Interim Report The CP holder may meet the 30 day written report requirement by i
submitting an interim report in lieu of the complete report if
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sufficient information is not available for a definitive report.
The interim report should specify:
j (a) the potential problem and reference the notific'ation (b) approach to resolution of the problem (c) status of proposed resolution (d) reasons why a final report will be delayed (e) projected completion of corrective action and submittal h
date of the complete report.
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,7 10CFR50.55(e) 1 Q
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Issue Date:
4/1/80 i
e
',,a 3
s (4)
Complete heport E
/
The regulation requires thafi the CP holder submit a written report to' the appropriate Regional office within 30 days after initial ~ notification. 'If an interim report is ' submitted the final report shall.be due on the date comitted in the interim report. The complete report.shall contain:
.(a). description of.the deficiency '
(b) analysis of the safety implications.
This should include an identification of interfacing systems and possible inter-actions.
-(c) corrective actions taken.
Corrective actions should be sufficihnt to correct the deficiency and prevent future idettics1 or similar occurrences.
To prevent future occurrerices the cause's of the deficiency must be fully explored and identified.
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I (d) sufficient information to permit analysis and evaluation of tne deficiency and of the corrective action.
7.
ENFORCEMENT If. a CP holder is aware ofa' reportable deficiency and it can be shown by objective evidence.that he has not raet the time reporting requirements, then he is in noncompliance with the reporting requirement of 50.55(e) and enforcement action should be.taken.
The licensee should be encouraged to discuss " deportability" with the responsible IE inspector whenever he has a question or doubt regarding this matter.
It is' appropriate for the inspector to indicate his views on whether a particular matter is reportable, but the licensee should l
understand that the ultimate responsibility remains with the licensee, i
and the inspector's judgement may change during a future inspection wherein he has an opportunity. to fully review the circumstances asso-ciated with the matter.
'Another aspect of this Regulation related to deportability determina-tion pertains to judgement--judgement used by the licensee in deter-mining whether'a matter is reportable. The licensee has to make a judgement based on his (or others)- evaluation / analysis. ~If the licensee decidas, on the basis of the above, that a matter,is not reportable he nay have satisfied the intent of this part of the Regulation. However, the inspector can exercise his option and f
challenge the licentee's degision of nonreportability. A challenge
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may be valid if.
the evaluation is cleahly faulty by way of omission of facts engineering or ottiercalculations are in err' r o
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Issue Data:
4/1/80 the evaluation is not supported by adequate records the evaluation has not considered interactions a
past IE experience (including that of the inspector) provide a basis as precedent for deportability the licensee has established a t end or pattern of habitually evaluating deficiencies as non-reportable evaluation is performed by a person (s) or organization without expertise in the subject.
)
The inspector has the right and the responsibility to examine the technical validity of the licensee evaluation and if an inappropriate or unsupported decision of nonreportability has been made by the licensee, enforcement action should be considered.
Regional management should review and, when valid, determine the appropriate enforcement action to take.
If there is evidence that superficial evaluations are being made to procedurally satisfy or bypass NRC requirements, strong escalated enforcement acticn should be considered.
(MC-0800 will be changed, accordingly)
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8.
RELATION TO APP. B REQUIREMENTS @ y@d g
10 CFR 50, Appendix B, requires procedures to be established and records meintained to handle required actions relative to resolution of identified deficiencies. Procedures and records (as in (1) and (2) below) are required to assure prompt notification and adequate reporting under 50.55(e). Means to do this should be a integral part of each licensee's QA program.
(1)
Implementing Procedures Although the specific requirements of 50.55(e) are few (notify, i evaluate, report), implementing procedures to assure that_these requirements,-are met should be established by the u no; derm For r
exam h, m.e means (such as procedures or instructions) are required to assure that deficiencies found in design and construction activities delegated by thb licensee to others are handled properly and reported in a timely manner to the CP holder. The procedures should assure
! ?x that the evaluation of the significance of the deficiency to the,
safety of plant operations is performed by a person (s).with adequate 1
expertise in the subjact and that adequate management review is provided.
- m.,.,
, (2) qt, cords Ths licensee dould maintain records to demonstrate that adequate
~
evaluation / analysis of all deficiencies was made regarding the impact on safe operations.
It is appropriate for the IE inspector to inform the licensee that without soch records the appropriate licensee management cannot establish whether such evaluations were made or whether the NRC requirements associated with this activity were overlooked.
[L
e e.
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e CAUTION NOTICE - This standard is being prepared or reviewed and has not been approved by ANSI. It is subject to revision or withdrawal before issue.
1 American National Standard Reactor Plants and Their Mainte' nance t',
Requirements for Collection, Storage, and N intenance of Quality Assurance Records for
~~' -
Nuclear Power Plants.
u o w-Sponsor The American Society of Mechanical Engineers I
lith Draf t - Rev 0 1/17/73 9,
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,1
1 AMERICAN NATf 0NAL STANDARD
,2 3
An American National Standard implies a consensus of those substantially 4
concerned with its scope and provisions. An American National Standard is 5
intended as a guide to aid the manufacturer, the consumer, and the genern1 6
public. TheehistenceofanAmericanNationalStandarddoesnot in any re-7 spect preclude anyone, whether he has approved the standard or not, from 8
inanuf acturing, marketing, purchasing, or using products, processes, or pro-9 cedures not conforming to the standard. American National Standards are 10 subject to periodic review and users are caution d to obt'ain the latest 11 editions.
12' 13.
CAITIION NOTICE: This American National Standard may be revised or with-
.14 drawn at any time. The procedures of the American National Standards Insti-15 tute require that action be taken to reaf firm, revise, or withdraw this 16 standard no later than five years from date of publication. Purchasers of 17 American National Standards may receive current information on all standards 18 by calling or vriting the American National Standards Institute.
Y s
4 S
th Draft - Rev 0 w*m
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FORE %*0RD 1-3 (This Foreward 'is not a part of ANSI Standard Requirements for Quality 4
Assurance Records for Nuclear Power Plante N45.2.9 -
).,
5 6
This standard provides requirements and guidelines for the collection,
?-
storage, and maintenance of quality assurance records associated with the 8
design, cons truction,.
asiatenance, and modification of structures,
~
9 sys tems, and components' of nuclear power plants. This stand'ard was developed under sponsorship of the American Society of HecEenical Engineers (ASFE) as 10 11-an ef fort by the American National Standards Institute (ANSI) Standards Com-12 mittee N45, Reactor Plants and Their Maintenance. This committee is charterec 13 to profoote the development of standards for the location, design, construct $cn, 14 and maintenance of nuclear reactors and plants embodying nuclear reactors, 15 including equipment, methods, and components specifically for this purpose.
16 17 In May,1969, the AS)E Boiler and Pressure Vessel Comittee's sub-18 cor=ittee on nuclear power expanded its scope of activities to include c:ajor,
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19 components of the nuclear power system of a plant. A new Section III of the 20 Boiler and Pressure Vessel Code has been prepared and was published as the 21 1971 Edition of the Code. Tha quality assurance provisions of that Code 22 apply directly to owners, manufacturers, and installers of nuclear power I
23 system co ponents and include provisions for the establishment and execution 24 of a quality assurance program including requirements for records on work 25 covered by that Code.
26
-27 In April of 1970, the N45 Comittee of ANSI established a subcommittee 28 N45-3 to guide the preparation of nuclear quality assurance standards. This
'29 subcommittee is responsible for establishing guidelines and policy to govern
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30 the scope and content of the yarious standards; sonitoring the status of 31 standards in process; reconsnending preparation of additional standards; and 32 final approval of standards prior to, their submittal to the N45 Consmittee 33 for balloting.
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In December 1970, the N45-3 Subcommittee of ANSI established en ad hoc 1
subcommittee, which was subsequently designated the N45-3 9 Working Group, 2
3 on Quality Assurance Records. The purpose of this Working Group was to prepare a standard for general industry use that would define requirements 4
for the collection, storage, and maintenance of records related to and assoc-5 6
isted with the location, design, and construction of nucicar power The Working Group was composed of representa-7 plant systems and components.
tives of key segments of the nuclear industry, including utilities, reactor 8
the standard con-suppliers, architect-engineer constructors, and the AEC.
9 tained herein was developed from this activity. $The initial draf t was pre-j 10 11 pared in August 1971.
12' The previously centioned ASKE Code, as well as other ANSI Standards, 13 have been considered in the development of this standard. and this standard 14 is intended :o be compatible with their requireme.its.
15 16 Working with the N45-3 Subcommittee and concurrently with the Quality 17 Assurance Records Working Group's development of this standard, other ad hoc 18 forth more "
committees of N45 are developing a series of standards that set 19' detailed requirements for certain activities tn assure quality of nuclear 20 These will be coordinated with the requirements of this
. i 21 power plants.
1 22 standard as they are developed.
23 In September 1971, these ad hoc Cone.ittees were changed to working 24 In November 1972 the N45-3 Subcommittee was renamed N45-2 and the 25 groups.
At this time these working 26 working groups were changed to N45-2.1, etc.
groups had the following associated standards in preparation:
27 28 Standard in Preparation 29 Working Group 30 31 N4 5-2 N45.2 Quality Assurance Requirements l
for Nuclear Power Plants 32 33 34 N45-2.1 N45 2.1 C1 caning of Fluid Systems and Associated Components during the Construction Phase 35 of Nucleas Power Plants jy 36 J6'th Draft - Rev 0
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1.Warking
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Standard in Prcor. ration 2
,3 N45-2.2 N45.2.2 Packaging, Shipping, Receiving, Storage 4
and Handling of Items for Nuclear Power 5
Plants During the Construction Phase 6
7 N45-2.3 N45.2.3 Housekeeping During the construction 8
Phase of Nuclear Power Plants 9
10 N45-2,4 N45.2.4 Installation, ' Inspection and Tes ting 11 Requirements for Instrumentation and 12 Electric Equipment During the Con-13 struction Phase of Nuclear Power Generating 14 Stations 15 16 N45-2.5 N45.2.5 Suppler.entary Quality Assurance I
17 Requirements for Installation, Inspection 18 and Testing of Structural Concrete and 19 Structural Steel During the Construction Phase 20 of Nuclear Power Plants 21 N45-2.6 N45.2.6 Qualifications of Inspection, Examination 22 and Testing Personnel for the Construction 23 Phase of Nuclear Power Plants 24 25 N45-2.8 N45.2.8 Supplementary Quality Assurance Require-26 ments for Installation, Inspection and 27 Tasting of Mechanical Equipment and Systems 28 for the Construction Phase of Nuclear 29 Power Plants i
30 31 N45-2.10 N45.2.10 Quality Assurance Terms and Definitions 32 33 N45-2.11 M45.2.11 Quality Assurance Requirements for the 34 Design of Nuclear Power Plants 35 36 N45-2.12 N45.2.12 Quality Assurance Auditing Program Requirements 37 for Nuclear Power Planta 38 '
N45-2.13 N45.2.13 Supplementary Quality Assurance Requirements for 39 Preparation of Procurement Documents for Nucient 40 Power Plants
// JBth Draf t - Rev 0 wmm- /-//-73 s
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Suggestions for improvement gained in the use of this standard vill 2
be veicomed. They should be sent to AMERICAN SOCIETY OF HECHNICAL ENGINEERS,
l 3
345 East 47th Stract, New York, NY 10017.
l 4
5 The following personnel are sembers of this group:
6 7
R. S. Bain, Chairman A. Breed, Secretary B
9 Name of Representative Organititton Represented 10 11 R. S. Bain Pacific Gas and Electric Company 12 A. Breed General Electric Company 13 J. C. Brodsky Burns & Roe, Inc.
'14 J. H. Curtis Duke Power Company
.15 A. E. Dohna Culf General Atomic Company 16 J. W. Hallovell Westinghouse Electric Corporation 17 J. I. Hartone Long Island Lighting Company 18 W. H. Morrison U. S. Atomic Energy Commission l
19 D. A. Quinn Stone & Webster Engineering Corporation i
1
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TABLE OF CONTENTS j
L 2
Face 3
Section 4
d 5
1.
INTRODUCTION 10 l
10 6
1.1 Scope 7
1.2 Applicability 11 8
1.3 Responsibility 11
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9 1.4 Definitions-11 10 1.5 Referenced Documents 11 11 12' 2.-
GENERAL REQUIRENINTS 12 1
12 13 2.1 Quality Assurance Record System 12 14 2.2 Categories 15 2.2.1 Lifetime Quality Assurance Records 12 16 2.2.2 Nonpermanent Quality Assurance Records 13 17 18 3.
TECHNICAL REQUIREMENTS 13.
19 3.1 Ceneral 13 20 3.2 Records Administrations 14 21 3.2.1 Generation of Quality Assurance Records 14 22 3.2.2 Index 14 23 3.2.3 Distribution 14 24 3.2.4 Identification 14 25 3.2.5 Classification 14 26 3.2.6 Supplemental Information to 27 Quality Assurance Records 15 28 3.2.1 Retention of Records 15 29 30 4.
RECEIPT OF RECORDS 15 j
31 4.1 General 15 16 32 4.2 Timeliness 16 33 4.3 Receipt Control 16 34 4.4 Status
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TABLE OF COMTENTS (Continusd) i 1 1
2 Pa1e f;
3 Section 16 STORACE, PRESERVATION AND SAFEKEEPING 5
5.
16.
6 5.1 General 17 7
5.2 Location of Facilities I
17 8
5.3 Storage 18-
'9 5.4 Preservation 39 10 5.5 Safekeeping 19 11 5.6 Facili ty 20
'12' 5.7 Audits 13 20 14 6.
RETRIEVAL 20 15 6.1 Cencral 21 16 6.2 Accessibility
.17 21 18 7.
DISPOSITION 21 -
19 7.1 General.
21 Accumulation and Transfer of Records 20 7.2 21 21 7.3 Disposition of Nonpermanent Records 22 22 REVISIONS OF REFERENCED ANSI STAND.*RDS 23 8.
24 23 25 APPENDIX A 24 26 A.1 Design Records 24
,,> 2 7 A.2 Procurement Records 25 28 A.3 Manufacturing Records 26 i
29 A.4 Installation-Construction Records 26 A.4.1 Receiving and Storage 30 26 A.4.2 Civil 31 28 32 A.4. 3 Welding 28 A.4.4 Mechanical 33
.29 A.4.5
- Electrical and IEC 34 30 A.4.6 General 35
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TABLE'0F CONTINTS (Continued).
1 2
- Page, 3-Section 4
31 5'
A.5 Preoperational and Startup Test Records 6
A.6 Maintenance, Modification and Test Records 32 7-8 A.6.1 Manuals and Proceduret'..
32 9
A.6.2 Maintenance and Testing 32 10,
A.6 3 Special Nuclear Material 33 11 A.6.h General 3h
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e CAUTION NOTICE - This Standard is being 1
prepared or reviewed and has not been 2
approved by ANSI. -It is subject to re-l3 k
vision or withdrawal before issue.
5 6
REQUIRD(ENTS FOR COLLECTION, STORAGE, AND MAINTDIANCE 0F QUALITY ASCURANCE 'AECORDS 7
8 FOR NUCLEAR,POWDI ILANTS 9
10 1.
INTRODUCTION 11 12 13 1h 15 16 1.1 Scope. The standard provides general requirements and guide- ~
lines ter the collection, store.ge, and maintenance of quality assurance 17 18 records associated with the design, construction, and maintenance of It is not intended to cover the preparation of ti 19 nuclear power plants.
. records, nor to include working documents not yet designated as quality 20 i
21 assurance records.
22 23 2h j
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25
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26 27 i
I 28 29 30 31 l
32 1
This standard is intended to be used in conjunction with ANSI Nk5 2.
l 33 1
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1' 1.2 Applicability. The requirements of this standard apply to the work 2
of any individual or organization that. participates in collection, storsgs, 3
or maintenance of quality assurance records associated with
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l 4
nuclear power plants, he extent to which the-
)
f 5
individual requirements of this standard apply will depend upon the nature 6
and scope of the work to be performed and the importance of the item or ser-7 vice involved. The requirements are intended to assure that records are l
8.
available when needed for their intended purpose.
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9 l
l 10 1.3 Responsibility. The organization or o,r.ganizations responsible for 11 establishing the applicable requirements for'the activities covered by 12 this standard shall be identified and the scope of their responsibilities 13 shall be documented. The work of est ablishing practices and procedures 14 and providing the resources in terms of personnel, facilities, and ser-1 15 vices necessary to implement the requirements of this standard may be i
16 delegated to other organizations and such delegation shall also be docu-17 mented.
It is the responsibility of each organization performing work 18 covered by this standard to comply with the procedures and instructions 19 issued for the project and to conform to the requirements of this standard 20 applicable' to its work.
21 22 1.4 Definitions. The following definitions are provided to assure a uni-23 form understanding of select terms as they are used in this. standard.
24 25 Quality Assurance Records. Those records which furnish documentary 26 evidence of the quality of items and of activities affecting quality.
For f'
27 the purposes of this standard a document is considered : quality =:::::::
28 er r ed wh;;. :h: I:::::n: h:: E rr x,12::d.
29 1
30 Other terms and their definitions are contained in ANSI N45.2.10.
31Property "ANSI code" (as page type) with input value "ANSI N45.2.10.</br></br>31" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 32 1.5 Referenced Documents. Other documents that are requiredeto be included 33 as a part of this standard are 'either identified at the point of reference 34 or described in Section 8 of this standard. %c issue or edition of the re-j 35 ferenced document that is required will be specified either at the po' int of l
36 reference or in Section 8 of this standard.
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2.
CENERAL.REQU7REMENTS 2
3 This section sets forth general requirements for the control of quality 4
assurance records.- The requirements include collection, filing, storing, 8
5 maintenance and disposition of records as required by other codes, 6
standards, specifications, or regulatory requirements. The procedures to 7
be employed to perform the required activities shall be planned and docu-l 8
mented.
9 2.1 Quality Assurance Record System. A quality assuranci records system 3,
10 shall be established by the organization responsible at the earliest prac-11 ticable time, consistent with the schedule for accomplishing work activities I
12 and in compliance with the general requirements of this standard. ' The 13 quality assurance records system shall be defined, implemented and enforced 14 in accordance with written procedures, instructions and other documentation.
15 16 2.2 Categories. Two categories of quality assurance records are established -
17 lifetime and nonpermanent.
18 19 2.2.1 Lifetime Oualitv Assurance Records.
Lifetime records are those which 20 meet one or more of the following criteria:
21 22 (1) Those which would be of significant value in demonstrating 23 capability for proper functionin6 of safety-related items.
2.
25 (2) Those which would be of significant value in maintaining, rework-26 ing, repairing, replacing, or modifying the item.
27 28 (3) Those which would be of significant value in determining the cause 29 of an accident or malfunction of an item.
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(4) Those which provide required baseline data for inservice
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2 ins pection.
3 Lifetime quality assurance records are required to be maintained 4
by or for the plant owner for the life of the particular item while it 5
6 is installed in the plant or stored for future use.
7 8
2.2.2 Nonpermanent Quality Assurance Records. Nonper9anent records 9
are those which noce all of the following criteria:
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10
'11 (1) Those of no significant value in demonstrating capability for 12 safe operation.
13 14 (2) Those of no significant value in maintaining, reworking, 15 repairing, replacing, or modifying the item.
16 17 (3) Those of no significant value in determining the cause of an 18 accident or malfunction of an item.
19 20 (4) Those which do not provide baseline data for inservice inspectior..
21 22 Nonpermanent records are required to show evidence that an activity 23 was perfermed in accordance with the applicable requirements. but need not 24 be retair.ed for the lif e of the item.
2$
26 3.
TECHNICAL REQUIRDIEhTS 27 28 3.1 General. This section provides requirements for the retention and 29 control of those records generated during the various phases of the project.
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1 32 Records Administratient l
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3.2.1 Generction of Quality Assurance Records. It is not the intent of *
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14 this standard to specify the preparation of the quality assurance records 5
to be generated. The applicable design specifications, procurement docu-6 ments, construction, maintenance, inspection and test procedures or other 7
documents chall specify the quality assurance records to be generated by, 8
supplied to, or held for the owner. The quality assurance records sub-9 mitted for retention shall be legible, completely fill,ed out and adequately 10 identifiable to the item involved.
r-e 11 r(
p_ -
12 The applicabic quality assurance records shall be considered valid only 13 if stamped or initialed or signed or otherwise authenticated and dated by 14 authorized personnel. These records may be either the original or a re-15 (produced copy.
16 17 3.2.2 Index. The quality assurance records shall be listed in an index.
18 The index shall indicate, as a minimum, record retention times, where the 19 records are to be stored and the location of the records within the storage 20 area. The index should be established prior to receipt of the records.
21 22 3.2.3 Distribution. The quality assurance records shall be distributed 23 and handled in accordance with written procedures.
24 25 3.2.4 Identiffeation. Quality assurance records shall provide sufficient 26 information to permit identification between the record and the item or 27 items or activity to which it applies.
28 29 3.2.5 classification. Quality assurance records shall be classified as 30 Lifetime or Nonpermanent.
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1' 3.2.6 Supplemental Information to Ouality Assurance Records. Quality
~ assurance records.may be corrected or supplemented in accordance with 2
I
-3 procedures which provide for appropriate review or approval by.che
'4 originating organization. The correction or supplement shall include l'
5 the date and the identification of the person. authorized to issue such 6
corrections or supplemer.ts.
7 I
8-3.2.7 Retention of Records. Types of quality assurance records with 9
reconsnended retention periods are listed in Appendix A of this standard.
10 It should be' recognized that the nomenclature.of t'hese records may vary. For 11- - records not listed in Appendix A, the type most nearly describing the 12 record.in question should be followed with respect to its retention period.
13'
.For records generated prior to commercial operation the retention )
l 14
- 15 period begins on the date of commercial operation For records generated t
16 'on'ite'ns installed after commercial operation, the retention period begins l
17
.on the date upon which satisfactory operation of the item, as part of a l
18 -system, has been demonstrated.
19 When a record is 20 generated as a result of a maintenance or modification activity, the 21 classification of those records will be the same as those types of records 22 generated during the initial construction period.
23-24 The organization responsible shall establish in writing the retention 25 times of records.
26 27-4.
RECE1PT OF RECORDS 28 29 4.1 Ceneral. This section defines requirements for receipt of documenta-30 tion during the design, procurement, manuf acturing, installation, startup 31 and maintenance of a nuclear power plant.
32
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33 The designated authority or authorities for receiving quality assur-34 ance records shall be svare of the value of such recorda and shall 35 control their safety during the time that the records are in their possession.
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.I 1-4.2 Timeliness. To assure their availability, a specific submittal plan J
2 shall be established for quality assurance records by agreement betvcen
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the purchaser and supplier.
4-5 4.3 Receipt Centrol. Each organization responsible for the rcccipt of quality assurance records shall designate a person or agency responsible 6
7 for receiving the tecords. The designated authority shall be responsible-contfoi of quality 8 'for organizing and implementing a systen of receipt 9
assurance records. This system shall apply torche receipt of records;into 10 a temporary working file and the permanent storage file.
f 11 12 As a minimun, a receipt control system shall include:
13 I
14 (1) A records check list designating the required quality assurance 15 records.
16 17 (2) A record of Quality Assurance records received.
18 19 (3) Procedures for receipt and inspection of incoming records.
f l
20 t
21 4.4 Status. Each receipt control systen shn11 be structured to pernit
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22 a current and accurate assessment of the status of quality assurance 23 records during the receiving process.
24 f25 5.
STORAGE, PRESERVATION AND SAFEKEEPING
, 26
> 27 S.1 Ceneral. This section establishes storage requirements for the 28 maintenance, preservation and protection of quality assurance record antil their ultimate disposal.
files {romthetimeofreceipt 29 l
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The quality assurance record files shall be f
1 5.2 Location of Facilities.
the requirements of stored in predetermined locations as necessary to meet 2
applicable standards.. codes, and regulatory agencies.
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Prior to storage of records in a quality assurance record Storage.
5.3 -
l SL file, a written storage procedure shall be prepared and a custodian shall i
6 This pro-be designated with the responsibility to enforce. the prdcedure.
7 cedure shall include the following as a minirum:
8 9
10 (1) A description of the storage area.
11 12' (2) Thefi)ingsystemtobeused.
13 14 (3) A method for verifying that the records received are in agree-ment with the transmittal document and that the records are in 15 16 good condition.
17 18 (4) A method of verifying that the records agree with the pre-established records check list (see Subsection 4.3 of this w
19 20 standard).
21 The rules governing access to and control of the files.
22 (5) 23 for 24, "/ (6)
.A method for maintaining c p r^1 o f and apn e =M 14 tv records removed from the stMeility.
j 25 n
N L/
26 A method for filing supplemental information (see paragraph 27 (7) 3.2.6) and disposing of superseded records.
28 I
I
//
16th Draft - Rev 0 f
ts#stf42
/-/f 7.0 I
C i i
t mm.
- r..
(..
l' Records shall be stored in a manner approved by the 1
5.4 ' Preservation.
In order to organization or organizations responsible for the files.
2 3'
preclude deterioration of the records the following requirements shall 4
apply:
1
.5 6
(1) Cont ainers. Within a permanent storage' facility (see Subsection
~
5.6 of this Standard) containers or shal.vingM11_ be used; stan-7 8-he cabinets are pr.e ose' records stored' L
'9 within a temporrry Ttorage facility shall be afforded protection use of fire resistant cabinets with a one-hour Underwriters' 10 -
easinf 6 ry alternative is reintenance of duplicate 11 rat 12 records stored in a separate remote location.
.33
'14 (2)' condensation. Provisions shall be made in-the storage arrange-15 ment'to prevent damage from condensation.
'16
~
17 (3) - Loose Documents. Loose documents shall not be stored on open surf aces such as tables or on top of cabinets. Records shall 18 be firmly attached in binders er placed in folders or envelopes 19 v
20 for storage in containers or on shelving.
- 21 22 (4) Special Processed Records. Special processed records (such as radiographs, photographs, negatives, and microfilm) which are 23 light-sensitive, pressure sensitive or temperature sensitive 24 shall be packaged and stored as recessnended by the manuf acturer
,/
25 26 of these materials.
//
3#th Draft - Rev 0
/=/f'73 :
Provisions'shall be established to preclude the
'1 5.5 Sarckeening.
2' entry of unauthorized personnel into the storage area and to guard 3 against larceny and vandalism.
k Record storage facilities shall be so constructed and located 5
5.6 Facility.
as to protect contents from possible destruction.by causes such as fire, 6'
flooding, tornadoes, insecta,, -odents and ffop,possible deterioration by a 7
combination of extreme variations in temperature and humidity conditions.
8 m
.9 At least the following features shall be considered in the design of 10 11 the permanent storage facility:
12 13 (1) Reinforced concrete, concrete block, masonry, or equal construc-14 tion.
l 15 if'a 16 (2) Concrete floor and roof with sufficient slope for drainage; floor drain is provided, a non-return check valve (or equal) 17 v'
18 shall be included.
19 20 (3) Fire retardant door (two-hour Underwriters'. rating minimum).
21 22 (4) Sealant applied over walls as a moisture or condensation barrier.
l 23 24 (5) Surf ace sealant on floor providing a hard-wear surf ace to rtini-25 mize concrete dusting.
l 26 27 (6) Foundation sealant and provision for drainage.
28 29 (7) Forced-air circulation with filter system.
30 1;.
31 (8) Dry chemical or gas fire protection system..
i
'f I
i k
\\
)8th Draft - Rev 0 g
- C
.L
_, ~..
}
19 N7-73
4 1
(9) No pipe other than those providing fire protection to the storage 2
facility is to be located within the facility.
3 Por. storage of film and other special processed records, humidity and 4
5 temperature controls shall be provided to maintain an environment as recom-6 mended by the manufacturer.
5 7
8-5.7
,A ud it s. An audit system shall be estab]fshed to assure that the 9
quality assursnee records' storage system is effective. The following 10 shall be performed as a minimum:
9 11 12 (1) Periodic surveys to assure that records logged in are avail-i 13 able and have been placed in their proper location within the 14 files, and to assure that the control system is adequate.
15 16 (2) Periodic audits to assure that the facilitics are in good con-17 dition and that the temperature / humidity controls and protective 18 devices are functioning properly.
, 19 20 (3) Periodic audits of the records to assure that the documents are 21 not deteriorating due to improper storage practices or rough 22 handling.
23 24 6.
RETRIEVAL
- 25 26 6.1 General. This section is intended to establish requirements for the 27 retrieval of documents that are stored within the quality assurance re-28 cord files.
4
//
46th Draft - Rev
!!/!?!?T s ce u
/-/7-73 i
l
1 i
1
~
1 6.2 Accessibility. Storage systems shall provide for the accurate 2
retrieval of information without undue delay.
3 4
A list shall be generated designating those personnel who shall 5
have access to the files.
6 7
Quality assurance records maintkined by a manufacturer at his 8 facility or other location shall be accessible,.to the/Suyer or Owner, 9 in the case of lifetime records for the life p,f the itens involved or 10 for the designated retention periods for nonpermanent records.
11 12 7.
DISPOSITION 13 14 7.1 General. This section is intended to provide requirements for the 15 transfer of quality assurance records to the Owner, who has ultimate 16 responsibility for these documents, and their disposition.
17 18 7.2 Accumulation and Transfer of Records. Qaality assurance records accumu-19 lated at various locations prior to final transfer to the Owner shall 20 be made accessible to the Ovner directly, or through the procuring organi-
~
21 ration. Examples of such records are vendor manufacturing records, con-22 struction documentation, and startup data. Upon final transfer, the Ovner
'23 shall inventory the submittals, acknowledge receipt and process these ree-24 ords in accordance with this Scandard.
25 26 7.3 Disposition of Nonpermanent Records.
Records classified as nonpernar.ent 27 should be retained for at least the minimum period of time as recommended in 28 Appendix A.
Af ter this time, these records may be disposed of by or with con-29 currence of the Owner.
//
Asth Draft - Rev 0 WS7/M
{
g
'/-/7-73 )
.~
k 1
8.
REVISIONS OF REFERENCED ANSI STANDARDS 2
ifhen the following standards referred to in this document are super-3 seded by a revision approved by the American National Standards Institute, 4
5 the revision shall apply.
6 7
8 e.
9 10
'11 12 13 II.
15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 i
//
t#th Draft - Rev 0 1417/72
/-/? 75
,,gg_
)
APPENDIX A 1
2 The following is a list of types of records with the retention 3
For defi-periods indicated. (see Subsection 3.2.7 of this standard).
4 nition of lifetime records see paragraph 2.2.1, and for nonpermanent j
5 6
records see paragraph 2.2.2.
In the nonpermanent column the number indicates the retention period in years after,.which the' record need l
1 8
not be maintained.
9 16 The 0 years minimum retention period is intended to permit dis-l positioning of the records on the day following the date of commercial 11 12 operation. One year retention is intended to require maintenance of f
13 the record for the customary periods of warranty. Two year retention is intended to require maintenance of the record through the first 14 15 overhaul or reload.
Six year retention is intended to achieve com-16 pliance with the regulatory requirements.
17 18 4L-19 i-20 21 22 23 24 25 26 27 28 29 30 31
//
14th Draft - Rev 0
$8i47/?t L
/-/ 7-73 ___ _ __ -_ -
e.
l 1
1 a
~
Record Types L'ifetime Nonpermanent j
1 2
1 A.1 Design Records.
4 i
X 5
Applicable Codes and Standards Used in Design X
6 As-Constructed Drawings X
7 Design Calculations and Record of Checks 8
Design Change Requesta
/
1 9
Decign Deviations
' f,,
X 2
10' Design Procedures and Manuals' I
11 Design Reports 1
12 Design Review Reports 2
13 Drawing Control Procedures 14 Purchase and Design Specifications and X
15 Amendments 6
16 QA System Audit Reports 17 Reports of Engineering Surveillance of
~
1 18 Field Activity X
19 Saf ety Analysis Report X
20 Stress Reports s-X 21 Systems Descriptions X
22 Systems Process and Instrumentation Diagrams 23 Technical Analysis, Evaluations, and Reports X
24 25 A.2 Procurement Records.
/
26 6
27 Audit Reports 0
28 Procurement Procedures X
29 Procurement Specification 30 Purchaser Order (Unpriced) Including Amendments X
2 31 Purchaser's Pre-Award Quality Assurance Survey 0
32 Receiving Records 2
33 Supplier's Quality Assurance Program Manual
//
tech Draft - Rev 0 M/"/ 9
" f./ f f.5 i
l s<
3
)i
1 Record Types Lifetime Nonper-anene t
2 3
A.3 Manufacturing Records.
4 s
5 Applicabic Code Data Reports X
.l i
6-As-Built Drawings and Records X
7 Certificate of Inspection and Test Personnel 0
~
8 Qualification 9
Certificates of Compliance X
10 Cleaning Procedures C,.,
0 i
11 Eddy-Current Examination Procedure and l
12 Final Results X
13 Electrical Control Verification Test Results 2
14 Ferrite Test Procedure and Final Results X
0 15 Forming and Bending Procedure Qualifications 16 Heat Treatment Procedures 0
17 Heat Treatment Records X
0 18 Hot Bending Procedure 19 Inspection and Test instrumentation and 20 Tooling Calibration Procedures and Records (Until Reca11brated) 21 Liquid Penetrant Examination Procedure and 22 Final Results X
23 24 tbgnetic Particle Examination Procedure and 25 Final Results X
26 Major Defect Repair. Records X
27 Material Properties Records X
28 Nonconformance Reports X
0 29 Packaging, Receiving Storage Procedures 30 Performance Test. Procedure and Results Records X
X 31 Pipe and Fitting Location Report X
32 Pressure Test Procedure and Res'alts 33 Product Equipment Calibration Procedure (Until Recalibrates)
(
'34 Product Equipment Calibration Records (Until Recalibrates) 35 QA Manuals, Procedures and Instructions 2
36 QA System Audit Report 6
//
teth Draft - Rev 0 L
ft940f-?t
! /-/f-73
~l' l
c.
e.
1 Recerd Types 1.ifetime Nenparmantnt^
2-3 Radiographic Procedures, Review Porms and
]
4:
Radiographs X
5' Ultrasonic Examinscion Procedures and 6
Final Results X
7 Welding Materials Control Procedures 2
8 Welding Personnel Qualification 2
9 Welding Procedure Qualifications and
/
10' Data Reports 2
11 Welding Procedures X
12 Work Processing and Sequencing Documents X
i 13 14 A.4 Insta11at, ion-Construction Records.
15 16 A.4.1 Receiving and Storage.
17 18 Inspection Reports for Stored Items 0
19 Nonconformance Reports X
~
20 Receipt Inspec tion Reports 'on Items 1
21 Receiving.. Storage, and Inspection Procedures 2
v 22 Storage Inventory and Issuance Records 0
23 Vendor Quality Assurance Releases 0
J 24 1
25 A.4.2
- Civil, b
26 27 Aggregate Test Reports 1
28 Batch Plant Operation Reports 1
29 Cement Grab Sample Reports 0
30 Check-Off Sheets for Tendon. Installation X
31 Concrete cylinder Test Reports and Charta X
//
l Wth Draft - Rev 0 f
W 4747f 1
4 / /'A")L3 g
_7_
i 1
1 1 l l
1
I,.
1.
f 1-R cord Types Lifatimt Nenpe rmanent l
2 3
Concretc Design Mix Reports X
4 Concrete Placement Records X
s; -
5-Inspection Reports for Channel Pressure Tests X
6 Material Property Reports on Containment 7
Liner and Accesscrics X
,8 Material P7operty Reports on Metal Containment 9
Shell and Accessories X
j 10 Material Property Reports on Reinforcing Steel '.
X 11 thterini Property Reports on Reinforcing Steel 12 Splice Elseve tkterial X
13 ' Material Property Reports on Steel Embedments 14 in Concrete X
15 Material Property Reports on Steel Piling 1
16 Material Property Reports on Structural Steci 17 and Bolting X
18 Material Property R,eports on Tendon 19 Fabrication Material X
1 20 Mix Water Chemiesl Analysis 21 Pile Drive Log X
N-22 Pile Loading Test Reports X
23 Procedure.for Containment Vessel Pressure-24 Proof Test and Leak Rate Tests and Resulta X
25 Reinforcing Steel Splice Operator 0
26 Qualification Reports
' /,, 2 7 Releases to Place Concrete 0
28 Reports for Periodic Tendon Inspection X
1 29 Reports of High-Strength Bolt Torque Testing 0
30s SJ. ump Test Results 31 Soil Compaction Test Reports X
i
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//
>Fth braf t - Rev 0 hb/4772)
- /-/7;r5 s--
'c
^
Record Types
)
Lifetime Nonpermanent
-(,
1 "i.
-s 2
N 1
4,.,
User's Tenef.le Test Reports on Reitdorcing Steel 3
4 User's Tsn>fle Test Reports on Reinforcing
- m..
s.y 1
5 Steel spitees 6
7' A.4.3 Welding.
8 m
C
'I 9
Territe Test Procedures and Final Results 4
0 10 Heat Treatment Procedures
(
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4 11 Heat Treatment Records 12 Liquid Penetrant Test Procedures and I
13 Final Reruits 1h Magnetic Particle TEyt Procedures and Vs X
15 Fine,1 Results e
X 16 Major.k' eld Repair Procedures and Results,
~
^
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17 ' RMiographie Test Procedures and I
18, 4 i'Iins.1 Results' 19 Ultrasorde Test Procedures and 20 FineJ,. Results I
1 21, Veld Fit-Up Reports m
22 Weld Location Dingrams X
x 23 Weld Procedures 2
c 2h Weld Procedures Qualifications and Results s
s g
p 25 Welding Filler H tal Hi+,erial Reports
~
2 26 Weldisg Materinia control Precedures i
/-
2, 27 Velding Personnel Qualifications 28 l
29 A.4.4 g Aanical.
l 30 s.
s %
i 31 Che.icci composition User'R Test (Crab Suples) for Tharmal Insulation 1
4 32 n
Chemical Tests of Water $ sad for Mixing 31 3(,'
'Inculation Cement 1
.e.
1 35 Cidaning Procedures and Results y
n
~
//
j 4sth trait - Rev 0 I
wnn
'a
- /-j7 75 4-
[w L,
4
~
1-Record Types Lifetime N*nparmanent 2
X 3
Code Data Reports 4-Construction Lifting and Handling Equipment
'5 Test Procedures, Inspection and Test Data 0
6 Data Sheets or Logs on Equipment Installation, 2
7 Inspection and Alignment.
.8 Documentation of Systems Check-Off j
1 9
(Logs or Data Sheets) 1 10 Erection Procedures for Fkchanical Components <-v.
1 11 Hydro-Tes t Procedures and Results X
11 Installed Lif ting and Handling Equipment 13 Procedures, Inspection and Test Data X
14 Lubrication Procedures X
6 15 Lubrication Records 16 Material Property Records X
17 16 haterial Property Test-Reports for 19 Thernal ' Ins ula t ion X
20 Pipe and Pitting Location Reports X
21 22 Pipe ond Pittings Material Property Reports X
23 Pipe Hanger and Restraint Data X
24 Safety Yalve Response Test Procedures X
25 Safety Valve Response Test Results 6-26
/-
27 A.4.5 Electrien1 and IEC.
28 0
29 Cabic Pulling Procedures 1
30 Cable Separation Check Lists X
31 Cabic Splicing Procedures l.
l
~
//
36th Draft - Rev 0
- /
- 7/72-
- /-/ 7-73
L..
j l
Lifetime Nonpermanent Record Types 1
1
~
(;
2 X
3 Cable Terminating Procedures X
4 Certified Cable Test Repotts 5
Documentation of Testing Performed After 6
Installation and Prior to Systems
'2 7
Conditional Acceptance 1
8 Field Workmanship Checklist or Equivalent Logs (Until Recalibrates) 9 Instrument Calibration Results X
10 Relay Test Procedures and Results 2
11 Reports of Pre-Installation Tests X
12 Voltage Breakdown Tests on Liquid Insulation I
i 13 l
j 14 A.4.6
- Ceneral, 15 X
16 "As-Built" Drawings and Records Calibration of F.easuring and Test Equipment and 17 (Until Recalibra 18 Instruments Procedures and Reports s.
19 Certificate of Inspection and Test Personnel 1
20 Qualification 6
21 Field Audit Reports 2
22 Field Quality Assurance P.anuals I
23 Final Inspection Reports and Releases X
24 Nonconformance Reports g
(Until Recalibrates) /
25 Special Tool Ca?ibration Records l
X 26 Specifications and Drawings 27 28 29 30 31
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~
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//
c
.MTch Draft - Rev 0 Mf1W
/-/7-73
, i u __
1 Record Types Lifetime Nonpermanent't 2
3 A.5 Preoperational and Startuo Test Records.
4 5
Automatic Emergency Power Source Transfer 6
Procedures and Results X
7 Pinal Systems Adjustment Data X
2 8
Flushing Procedures and Results 9
Hydrostatic Pressure Test Procedures and Results X
10 Initial Heatup, Hot Functional and Cooldown 11 Procedures and Resulto X
12 Initial Plant Loading Data X
13 Initial Reactor Criticality Test Procedures 14 and Results X
15 Instrument AC Systems and Inverters Test 16 Procedures and Reports X
17 Main and Aux. Power Transformer Test Procedures 18 and Results X
19 Off-Site Power-Source Energizing Procedures 20 and Test Reports X
v 21 On-Site Emergency Power Source Energizing 22 Procedure and Test Reports X
23 Plant Load Ramp Change Data X
24 Plant Load Step Change Data X
25 Power Transmission Substation Test Procedures 26 and Results X
27 Preoperational Test Procedures and Results X
28 Primary and Secondary Aux. Power Test 29 Procedures and Results X
30 Reactor Protection System Tests and Results X
31 Startup Logs X
32 Startup Problems and Resolutions 6
33 Startup Test Procedures and Results X
34 Station Battery and DC Power Distribution "35 Test Procedures and Reports X
36 System Lubricating 011 Flushing Procedures 2
s--
37 Water Chemistry Reports X
77 46th Draft - Rev 0 M/43/-?1 ) /7-73
1 Record 'upes Lifetime nonpericanent v
2 3 A.6 Maintenance, Modification and Test Records k
5 A 6.1 Manuals r.nd Proecdures.
6 6'
7 Component, Equipment and Systems Test Proceduras 68 8 Equipent Instruction Manuals, Drawings, Eter 6e 9 Inservice Inspection Program Procedures 10 Inspection and Test Instrumentation 6'
11
- Calibration Procedures 6'
12 Maintenance Procedures 13 Nondestructive Test Personnel Qualification 6'
1h Procedures 6'
15 Nondestructive Test Procedures 16 Quality Assurance Program Manual and 6'
17 Procedures 6'
18 Radiologice.1 Survey Procedures 19 Reactor Vessel Material Surveillance 6'
20 Test Procedures 6*
21 System Cleaning Procedures
,X 22 Welding Procedures 23 2h A.6.2 Maintenance and Testing.
6*
25 Personnel Training Manuals X
y/
26 Containment Leak Rate Test Records 27 Engineered Safeguards Systems (Surveillance)
I 28 Test Data Sheets Engineered Safeguards Systems (Surveillance) 29 X
30 Test Record Cards 6
31 Equipment and Systems Holdorf (Tagout) Logs 6
32 Equipment History Cards
' EMe'r of years after made obsolete or superseded.
33 lith Draft - Rev 1/17/73
./
32 t
1
' Record Typec Lifetime Nonpermanent't 2
1 i
3 A.5 PreoPerational and Startup Test Records, 4
5 Automatic Emergency Power Source Transfer 6
Procedures and Results X
7 Final Systems Adjustment Data X
8 Flushing Procedures and Results 2
9 Hydrostatic Pressure Test Procedures and Results X
d 10 Initial Heatup, Hot Functional and Cooldowri 11-Procedures and Results X
12 Initial Plant Loading Data X
13 Initial Reactor Criticality Test Procedures 14 and Results X
15 Instrument AC Systems and Inverters Test 16 Procedures and Reports X
17 Main and Aux. Power Transformer Test Procedures 18 and Results X
~!
19 Off-Site Power-Source Energizing Procedures 20 and Test Reports X
w 21 On-Site Emergency Power Source Energizing 22 Procedure and Test Reports X
l 23 Plant Load Ramp Change Data X
l 24 Plant Load Step Change Data X
25 Power Transmission Substation Test Procedures 26 and Results X
/
27 Preoperational Test Procedures and Resulta X
28 Primary and Secondary Aux. Power Test 29 Procedures and Results X
30 Reactor Protection Systcra Tests and Results X
31 Startup Logs X
32 Startup Prob 1 cms and Resolutions 6
33 Startup Test Procedures and Results X
'34 Station ' Battery and DC Power Distribution
~35 Test Procedures and Reports X
36 System Lubricating 011 Flushing Procedures 2
l v
37 Water Chemistry Reports I
jj 46th Draft - Rev 0 Mf45/-P2 /./7-75
9 Record Types Lifetime _
Nonpermanent 1
v 2
3 A.6 Maintenance, Modification and Test Records 4-5 A.6.1 Manuals and Procedures.
6
/
6' 7 Component, Equipment and Systems Test Procedures 6'
8 Equipment Instruction !!anuals, Drawings,,Etc'.;,
6' i
l 9 Inservice Inspection Program Procedures 10 Inspection'and Test Instrumentation 6'
11 Calibration Procedures 6'
12 Maintenance Procedures
- 13 Nondestructive Test Personnel Qualification 6'
Ik Procedure 6'
15 Nondestructive Test Procedures 16 Quality Assurance Program Manual and 6'
17 Procedures 6'
f
'18 Radiological Survey Procedures 19 Reactor Vessel Material Surveillance 6'
20 Test Procedures 6*
21 System Cleaning Procedures
.X 22 Weldin6 Procedures 23 24 A.6.2 Maintenance and Testing.
6' 25 Personnel Training Manuals X
y/
26 Containment Leak Rate Test Records 27 Engineered Safeguards Systems (Surveillance)
X 28 Test Data. Sheets 29 Engineered Safeguards Systems (Surveillance)
X 30 Test Record Cards 6
~
31 Equipment and Systems Holdoff (Tagout) W s 6
32 Equip =ent History Cards 33 Num$e'r of years after made obsolete or superseded.
~
lith Draft - Rev 1/17/73 32
5*
Record Tyves Lifetime _
Nonperrnnent 1
i 2
6 3' Equipment Hours Iog 6
1.
Equip.ent Inspection Checkoff Sheets 6
$ Equipment Performance Test Records X
6 Inservice Inspection Procedures and Reports 7 Inspection and Test Instrumentation 6
8 Calibration Records 9 Installed Lifting and Handling Equipment X
10 Procedure, Inspection and Test Data 6
11 Instrumentation Calibration Records 6
l2 Maintenance Records 6
-13 Protection Relays Calibration Data and Setting 1h Reactor Trip System and D.ergency Pover System X
15 Test Data Sheets 16 Reactor Trip System and D:crgency Pover System X
17 Test Record Cards
\\
j 18 Reactor vessel Idaterials Surveillance Procedures X
19 and Reports X
]
20 Systems Decertification Logs 6'
21 Weld Procedure Qualification and Data Reports X
22 Welding Procedure 6
23 Work Permits 6*
{
2h Refueling Procedures J
25 A.6.3 Special Nuclonr Material.
l
/
26 f
X 27 Certificate of Fuel Conformance 28 Fuel Bundle Assembly Record and Fuel X
29 Bundle Packaging Inspection Sheet X
30 Fuci Inspection Records X
31 Material Balance Account Transfer Form 32
- Eumber of years after made obsolete or superseded.
33 lith Draft - Rev 0 v
1/17/73 33 i
j 1
Record Types Lifetime Nonpermanent f
g 3 Material Status Report (Form-AEC-742) x h Nuclear 14sterial Transfer Report (Fprm AEC-7hl) x 5 Special Nuclear Materials Accountability Records x.
6 Special Nuc1 car Materials Inventory Account X
7 Special Nuclear Materials Inventory Suncary X
8
/'
9 A.6.h General.
10 11 Abnormal Occurrence Reports to AEC X
12 Audit Reports 6
13 Certificate of Inspection and Test Personnel lh Qualification 1
15 Corrective Action Reports 6
16 Reports Required by Regulatory Bodies X"
17 Technical Specifications X
i 18 Updated, Corrected, and As-Built Dravings X
19 20 21 j
22 23 a
2h 25 i
26 l
27 28 l
29 I
30 31 50r as required by regulation 1
lith Draft - Rev 0 1/17/73 I
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l January 21, 1987 MEMORANDUM FOR: Robert Martin Regional Administrator FROM:
Victor Stello, Jr.
g Executive Director for Operations m
E&'
SUBJECT:
OIA REPORT REVIEW. CIA FILE #86 10 g
i have reviewed your memo to me of December IS,1966, which outlines your proposals for dealing with actions necessary to respond to the points raised in the subject report.
By separ. ate memo (see Enclosure 1) ! have established a Review Group, with John Davis Director Office of Nuclear Material Safety and Safeguards as Chaiman to conduct the review of technical issues as you recommended. I approve your suggestion to deta O T. Westerman and H. Phillips full-time to be at the disposal of the Review Group until their work is complete on or about January 30, 1987.
I approve the actions you recommend in regard to initiating remedial action within Region IV staff to assure a proper understanding of regional policies in regard to resolution of staff / supervisor problems, supervisory responsib(11 ties and to develop an improved inspection report tracking system. You will advise me separately of specifics of implementation of these actions.
I am withholding a decision on Allegation I (Managenent issues). Allegation II (the adequacy of the inspection program at CPES) and Allegation !!! (Data documented in Inspectors Reports) until the completion of the Review Group's efforts.
CrJgira1 sig.e4 by 21stor stenog Victor Stallo, Jr.
Executive Director for Operations
Enclosure:
As stated Distribution:
V5tello EDO 2475 JRoe Sniezek TRehm EDO r/f Od o "
"7 W' W ~ 'tT ~
OFC :AD/EDO
- ED I
........:............:...........:............:..........--:.......~..
HAME :TRehm
- V llo DATE :1/21/87
- 1/3j/87 OFFICIAL RECORD COPY.
________________D
.(
5.
Copies of the report and enclosures will be provided to you by separate cover.
6.
I would like to have your report in my hands by February 20, 1987.
A d'
b tor te o.
r.
Executive Director
- for Operationy cc:
E. Beckjord R. Martin G. Arlotto R. Scroggins J. Taylor
'H. Denton J. Keppler C. Paperiello C. Heltemes 1
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' NhCLEAR REGULATOMY COMM198 TON r
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January 21, 1987 e-8 NEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM:
Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
OIA REPORT REVIEW: CIA FILE #86 ESTABLISHMENT OF REVIEW GROUP 1
In order to resolve issues which OIA Report 86-10 has raised, I as taking the following action:
1.
You are assigned as Chainnan of a Review Group to evaluate the safety significance of OIA findings in CIA File #86-10 and reconnend resolution of the items.
G. Arlotto, J. Heltenes and C. Paperiello are assigned as men.N.rs of the Group. This effort is not intended to duplicate the 01A effort.
l 2.
The task of the Review Group is to review the technical issues identified in O!A report 86-10 and to determine and document in a reart to me (1) the safety significance of those issues for Comanche Jaak, i.e.,
whether actions should be taken to rectify any unsafe conditions; (2) whether the issues when identified were appropriately handled as to process and disposition; and, (3) detemine whether the current augmented review and inspection effort at Comanche Peak is sufficient to compensate for any identified weakness in Region IV's Q/A inspection programs.
3.
In addition, you should (1) review the purpose and significance of NRC-Form 766 and make appropriate recommendations concerning its use, (2) without expanding the tasks described in paragraph 2, offer me any judgment you may have on whether it is likely that there are broader implications in Region IV.
l 4.
You may task other NRC staff or utilize contractors as mquired, although I recommend that you keep your requirements to the minimum possible.
Necessary funds will be inade available at your request by RM.
T. Westerman and H. Phillips will be detailed to support your independent review on a full-time basis; other members of RIY are at your full disposal as you may require. Similarly, IE and NRR staff working on Comanche Peak are available to assist.
1 l
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'o UNITED STATES y" -
NUCLEAR REGULATORY COMMISSION
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i W ASHINGTON,0. C. 20555
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DRAFT 12/17/86-A MEMORANDUM FOR: Robert Martin Regional Administrator, RIV FROM:
Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
OIA REPORT REVIEW - OIA FILE (86-10 l
1 have reviewed your memo to me of December 17, 1986, which outlines your proposals for dealing with actions necessary to respond to the points raised l
in the subject report.
By separate memo (see Enclosure 1) I have established a Review Group, with John Davis Director, Office of Nuclear Material Safety and Safeguards as Chairman to conduct the review of technical issues as you recomended. I approve your suggestion to detail T. Westerman and H. Phillips full-time to be at the disposal of the Review Group until their work is complete on or about January 30, 1987.
I approve the actions you recommend in regard to initiating remedial action within Region IV staff to assure a proper understanding of regional policies l
in regard to resolution of staff / supervisor problems, supervisory responsibilities and to develop an improved inspection report tracking system. You will advise me separately of specifics of implementation of pk1 these actions.
I I agree with your comments in regard to the OIA conclusions on Allegation III (Data documented in Inspectors Reports). I am withholding a decision on Allegation I (Management issues) and Allegation II (the adequacy of the inspection program at CPES) until the completion of the Review Group's efforts.
i l
Victor Stello, Jr.
Executive Directnr for Operations
Enclosure:
As stated ENCLOSURE 2
QUALITY ASSURANCE PL N or SECTION 17 2
-P hs,
DATE: 7/18/86 I
g e
RECORD RETENTION AND STORAGE EWSION :
3 PAGE 1 OF 1 17.2 Record Retention and Storage Quality Assurance records shall be stored under the conditions and for the period specified by the' Code and by procedures. QA records requiring QA/QC verification generated or received at the plant site during the construction phase shall be filed in the Permanent Plant Records Vault until the phase of construction necessitates transfer of these documents to the TUGC0 Records Center. Other construction, procurement and design documents designated as QA records shall be stored as identified by program procedures issued by the procurement and engineering organizations.
l 8
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-r TUGC0 PROCEDURE XAS UTILITIES GENERATING CO.
P CP-QP-18.4 Rev. 7
- CPSES -
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CD9 QUALITYASSURANCERECORDRECEIPTCONTRh'ANDSTORAC
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ARED BY:
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- 1. 0 REFERENCE 1-A CP-CPM, 7.1, " Package Flow Control"
(
6 1-B ANSI N45.2.9,
" Requirements for Collection,
- Storage, and 4
l Maintenance of Quality Assurance Records"
'1 I
1-C STA-302, " Station Records" f
1-D CP-QP-18.6, " Record Turnover to TUGC0 Operations Group" b,
l t
2.0 GENERAL 2.1 PURPOSE AND SCOPE The purpose of this procedure is to detail the methods used to receive quality assurance records into the records storage vault, identify the records to a predesignated file location, and control the records to prevent loss or alteration.
This procedure is not intended to cover the preparation of records, nor to include working documents not yet designated as quality assurance records. Document preparation and controls are identified in Reference 1-A.
l 2.2 TERMS AND DEFINITIONS 1
Quality Assurance Records Any item of documentation that is applicable to an item permanently installed in Comanche Peak structures or systems as identified in the PIMS Coding Manual in accordance with Reference l
EXHIBIT 48
)
1 TUGC0 PROCEDURE q
Page 2 of 8
)
CP-QP-18.4 Rev. 7 EXAS UTILITIES GENERATING CO.
P I
- CPSES -
SEP 111986 t
1-A.
Documentation includes Lif etime and Non-permanent Quality I
Assurance Records as identified by Texas Utilities Generating Company. A document is considered a quality assurance record and.
shall be controlled as required by Reference 1-B when the document has been transmitted to the PPRV.
[
2.2.1.1 Lifetime Documentation Lifetime records are those records identified > in the PPRV l
Records File Index which meet one or more of the following criteria:
d Those which would be of significant value in demonstrating a.
g capability for proper functioning of safety related items.
i b.
Those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying an item.
Those which would be of significant value in determining the l
c.
cause of an accident er malfunction of an item.
d.
Those which would provide required baseline data for in-
'1 service inspection.
Lifetime records shall be maintained for the life of the particular item while it is installed in the plant or stored for I
future use.
2.2.1.2 Non-permanent Documentation Non-permanent records are those records which do not meet the criteria mentioned above but do show evidence that an activity was performed in accordance with applicable requirements.
Retention shall be identified in the PPRV Records File Index.
I 2.2.2 Valid Documentation Documentation shall be considered valid and processed into the Permanent Plant Records Vault only if all of the following criteria are satisfied:
a.
The document is legible.
b.
The document is completely filled out and signed and dated.
1 g
c.
The document is adequately identifiable to the item g.
involved.
i
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_ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _., - - - - - - - - - - - - - ~ - - - - - - --- - -,
n a
1 BROWN'& ROOT, INC.
PROCEDURE EFFECTIVE CPSES NUMBER REVISION "DATE PAGE JOB 351195 CP-crH 7.I 3
12/15/86 2'of 7 7.1D CIVIL 7.lE INSTRUMENTATION 7.1F INSULATION I
7.10 PIPIUC SUPPORTS 7.lH INTERIM RECORDS VAULT 7.11 (HUN-ASME) Q DOCUMENTATION PACKACE REVIEW 7.lJ REVIEW OF DESIGN DOCUMENTATION 7.lK RELEASE OF SEALS
- 7. lL' HVAC c.111 ATTACEIENTS 1.
Package Inventory Card 2.
Documentation Package Request
- 3.
Interim Records Vault Transmittal
1.0 INTRODUCTION
1.1 This procedure and its appendices have been prepared to delin-eate.the requirements for the preparation, temporary storage, and control of documenta tion packages for CPSES construction activities.
1.2 Protective coatings documentation shall be excluded from the scope of this procedure.
1.3 Documentation packages required for construction activities on systems and/or areas accepted and/or controlled by TUCCO Plant
. Operations shall be processed in accordance with CP-CPM 1.2 in addition to this procedure.
2.0 CENERAL 2.1 ABBREVIATIONS m.
IRV
- Interin Records Vault PFC
- Paper Flow Croup DS
- Distribution Satellite l
DP
- Documentation Package e
PPRV
- Permanent Plant Records Vault TUCCO
- Texas Utilities Cenerating Company I
~
4
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t BROWN & ROOT, INC.
PROCEDURE
' EFFECTIVE CPSES NUMBER REVISION DATE PAGE JOB 351195 i
CP-CPM 7.1 3
12/15/86 3 of 7 2.2 TERMS / DEFINITIONS Paper Flow Group
- The group assigned the respon-sibility of preparing Documen-tation Packages, and transferring completed packages to the Interim Records Vault, Permanent Plant Records Vault, or TUCCO.
Interim Records Vault
- The physical location where completed in-process packages i
are maintained until required for system turnover.
Distribution Satellite
- The physical location where incomplete packages'are maintained and issued to craft on a daily basis for required work.
2.3 GENERAL DISCUSSION All responsibilities shall refer to the personnel specified or their designee.
Documentation packages for piping shall be prepared in accord-ance with other applicable site procedures. Distribution of ther? documents shall be in accordance with this procedure.
Documentation packages for Unit 2 piping supports shall be pre-pared, distributed, and maintained in accordance with CP-CPM 7.1G.
3.0 PROCEDURE 3.1 PROCEDURE IMPLEMENTATION The implementation of this procedure shall be the responsib'l'ity i
of the PFG under the direction of the PFC Supervisor.
It is the intent that the applicable Appendix to this procedure be used in conjunction with this procedure for the preparation and control of documentation packages.
4.0 DOCUMENTATION STORAGE AND MAINTENANCE Q
4.1 Unit 2 completed in-process documentation shall be stored and g
maintained in the Interim Records Vault under the direction of the IRV Coordinator in ai:cordance with CP-CPM 7.1H.
i
6m
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h BROWN & ROOT, INC.
PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE JOB 351195 a
CP-CPM 7.1 3
12/15/86 4 of 7 4.1.1 Completed Unit 1 documentation shall be transmitted to the PPRV or TUGC0 in accordance with CP-QP-18.4 and CP-CPM 1.2.
p 4.2 In-process documentation shall be stored in the Distribution 0
}
Satellites under the direction of the PFG Supervisor.
]
L P nc K a. p a n c>.. 0., c e p W A c-er k 4.3 Only authorized personnel shall be permitted into the IRV storage area. A designated area shall be maintained for the purpose of reviewing documents.
Smoking shall not be permitted in the records storage area.
4.4 The filing system shall be organized by equipment categories and filed in alpha-numeric order.
Unit 2 documenta tion Packages shall be maintained by the IRV until final transmittal in accordance with CP-CPM 7.1H.
Copics and/or originals of completed documentation will be released from the IRV in accordance with CP-CPM 7.1H.
Big h '. L [r o u4- - M h m cgk 5.0 PACKAGE FLOW gg 7 tq w% ( tv Q h.i.e.
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- s u I w v J G fe' s M 'h',+-s.,
5.1 Upon the initiation of this prog, ram, the Unit 2 documentation for those items which are statused as complete on the' room inventory will be retrieved from the PPRV and packaged onder the format as described in the. applicable appendix to this procedure. The PFG will review the DP, insert the required in-process documentation and request inspections where necessary to fulfill documentation
.and inspection requirements.
5.2 Documentation Packages shall be prepared by the PFG for all work items identified as incomplete and for any new work items as they are released or identified.
NOTE:
No documentation package is required for Balance-of-Plant work activities that do not requir'e documentation per applicable procedures, drawings, or instructions.
5.3 Packages shall be prepared in accordance with the applicable appen-
[
dix to this procedure.
l t
5.4 I
When the package is prepared the items shall be statused in the applicable tracking data base as working and the package shall be transmitted to the Distribution Satellite to be filed until f
j I
' b-i
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4 COMANCHE PEAF, STEAM ELECTRIC STATION STATION ADMIIIISTPJ. TION MANUAL a-.v...miivd ONLY b
CON 1dulLl0 COPY 110.
4 STATION RECORDS PROCEDURE NO. STA-302 REVISION NO. 11 i
NOV.2 619Bb ISSUE DATE i
)
SUBMITTED BY:
[/71[2d DATE:
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ADMINISTRATIVE SUPERitJENDENT APPROVED BY:
/
M DATE:
// M N
V MANAGER. PLApT OPERATIONS
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- ..*.
CPSES PROCEDURE NO.
STATION ADMINISTRATION tWJUAL
-STA-302 STATION RECORDS REVISION NO. 11 PAGE 2 OP 31 i
i 1.0 Purpose l1 This procedure prescribes the bandling and control of operations phase quality-related. records at CPSES.
It prescribes central file j
indexing, records center interfaces, and satellite file requirements in addition to maintenance, receiving and storage of construction records after they are turned over to TUCCO Operations.
[,lt i net'tfiAfintent of this procedure tc, address the generation" orN f
i preparation of reccrds, only the handling and maintenance of them once l
hey are complete.
~.
It is the responsibility of the preparer to insure that all records
{
are legible, completely filled out and adequately identifiable to the l
item involved.
l 2.0 Applicability 1
i
{
This procedure applies to the control and handling of all quality i
related records generated by any activity at CPSES which is controlled by the CPSES Operations Administrative Control and Quality Assurance Plan. This procedure may also be utilized for the control of non-quality related records as directed by the Manager, Plant g
Operations. This procedure applies to the identification. indexing and retrieval of design and construction records after they have been
~
turned over to TUGC0 Operations and prescribes the method for turnover of records to the Records Center by entities other than TUGCO Operations. This procedure becomes effective when issued.
3.0 Definitions i
3.1 Plant Information Management System (PIMS) - The computerized l
record indexing and retrieval system in use at CPSES.
(formerly j.
the ARMS system) t, 3.2. Document - An approved procedure, checklist, blank log, drawing, etc., to be used or in use in the performance of station operations nctivities.
3.3 Record - A completed document or other appropriate materiwi that turnishes evidence of activities performed.
3.4 Oua11tv-Related Record - A record which furnishes documentary evidence of the quality of safety related items and of activities affecting quality.
3,5 Records Center - A central facility for the storage and control 4
of CPSES records located in the TUGC0 Administration Building l
Annex.
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_ _ _ _ _ _. _ _ _ _. - - - _. _ - _ - _ - - - -. _ _ ~
mvmm c7gesu m
Dd A
HEMORANDUM FOR:
Jack R. Goldberg Deputy Assistant General Counsel for Enforcement A
John G. Davis, Chairman Comanche Peak Report Review Group (cFRAG)
FROM:
SUBJECT:
ISSUES RAISED BY OIA REPORT 86-10 HAVING BROADER IMPLICATIONS FOR REGION IV In the Chairman's January 15, 1987, memorandum to the EDO, the Commission requested the CPRRG t,o offer.the EDO its judgement on whether the problems identified at Comanche Peak are isolated or there are broader implications in Region IV.
The CPRRG requests OGC assistance in addressing this issue.
Specifically, based on OGC's completed review of the OIA report, what issues, if any, are raised which the CPRRG should consider as potentially having
" broader" implications for Region IV7 OGC's suggestions, as well i;
as those of others, will be valuable to the CPRRG in reaching its
~ l judgement on which issues, if any, have broader implications.
The CPRRG appreciates your assistance on this matter.
j NOTE:
OGC's response will identify four issues:
1.
Regional management's interaction with inspectors and I,
management's role in reviewing, revising, and approving j!
inspection reports.
2.
Any identified failures of Region IV to carry out inspection modules.
f 3.
Whether Region IV treated Comanche Peak differently from other plantst 4.
The state of the NRC Forn 766 system at Region IV.
i 7MA i9&so nuesrs' sevives.snmAt DM6V/~:-
aves a re no a ccmy.
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Stollo DEC 171986 h'
Rehm EDO R/F RMartin
,JDavis
~DIA Ch'irman Zech ft MEMORANDUM FOR:
a Paperiello, RIII FROM:
Victor Stello,.lr.
Executive Director for Operations t
SUBJECT:
OIA REPORT REVIEW. OIA FILE #86-10 3ndler I have reviewed with staff the above referenced DIA Report which addresses the issue at Comanche Peak.
Attached is a memo from R. Martin, RA, RIV which he has written at my direction.
That memo establishes a general basis on which to deal with the OIA Report. I believe it is self-explanatory.
My proposed actions to proceed on this matter are outlined in the two draft memos, also attached. Essentially, I am implementing a Review Group to assist me in making further conclusions on Allegation I and II of the OIA letter. I believe no further action is necessary on Allegation III. I have also approved the Regional Administrator's recommendations to resolve some of the 7
issues involved in Allegation I, and I have approved his recommendation that Messrs. Westerman and Phillips be detailed full-time to be at the disposal of 44cp the Review Group in the resolution of the issues in which they were involved.
I would appreciate your prompt review of my planned actions and approval of draf t memos (Enclosure 2 and 3)y above, and in.more, deta.jl in the attached
]
those actions es noted generall
)
'p.~ n'.:-
V Victor Stello, Jr.
Executive Director for Operations
Enclosures:
1.-
Martin to Stello ltr dtd 12/17/86 2.
Draft Directive to RIV 3.
Draft Directive to Review Group 4.
Draft Press Release cc: Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Carr o-?n{Gt M d> 4CL 01A h c_,c.c.Q d b.tu U'T"~-
'~"'f OGC 47-
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- 12/h/86
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l DEC I T Y l
-MEMOPANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM:
Robert D. Martin Regional Administrator
SUBJECT:
01A REPORT REVIEW: CIA FILE NO. 86 This memorandum contains my proposals for dealing with the implications of the OIA Report's findings.. In this regard, I reserve the right to propose and take j
additional or alternative actions as I explore the matter more thoroughly with the staff.
.The OI A-report is broken.into three main sections.. Each section pertains to
.one of the allegations as generally formulated by OIA. The allegations and my
' recommendations are as follows:
Allegation I:." Region IV management harassed and intimidated inspectors to pressure them to downgrade or delete proposed inspection findings at CPSES."
This allegation was not substantiated by OIA. There was no evidence of such action by Region IV management, indeed, upon examination of the record, it is clear that, insofar as particulars go, the allegation was directed solely at one supervisor by one inspector.
The review by OIA of the several specific technical issues which were in contention between certain inspectors and this supervisor does not provide a definitive. determination as to first, their safety significance, and second, the appropriateness of their handling. To provide me an independent
. view on these matters, Isrequest that you convene a suitable, high level s
review group, supported by appropriate technical staff, to do a comprehensive review of each issue in contention. To support that effort, I will temporarily detail Messrs. Westeman and Phillips from their present duties to be at the disposal of that review group on a full-time basis until the review of the issues is complete. Other Region IV personnel, as identified by the review group, will be made available as requested.
Upon completion of that review-group effort, I will be able to finalize iny recommendations as to any further actions.
_.., m,
,.o. n,,,.,
However, there are a number of issues in the report which are sufficien'tly developed to make clear the appropriate corrective actions. In this regard,
'I have initiated the following actions:
. Dnds o, 1
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ENCLOSURE 1
.(
[]
1 Re-training of all technical staff and supervision will be conducted on
. Regional Policy Guide 2201, which was issued in August 1986, and which affirms the positive obligation on both the staff and supervision / manage-ment to escalate disagreements promptly to achieve resolution. This should.if followed, preclude protracted discussions on such issues.in
.the future.
I have instructed the Director of my Division of Resource Management and Administration to develop en improved inspection report tracking system that.wi11' identify those reports that are experiencing unacceptable delays in the various stages of-their preparation, review, approval, and distribution. This is to be operational by February 15, 1987, and will alert senior regional management to possible instances of protracted review.
- ' Training for all Region IV supervisors will be conducted to remind them of their proper supervisory responsibilities, including the need.to give adequate direction and guidance, and identify and document weaknesses they discern in their subordinates. Supervisors will also be held accountable for developing, in such cases, suitable Individual Development Plans to address the problems. The assistance of.the Office of Administration will be requested in conducting training in this area.
Where training and guidance is indicated, I intend to pursue same.with i
The OIA report and its attachments are being reviewed.
. appropriate v gor..
again to identify those several inspection practices for which further detailed These consist of guidance and retraining of technical staff is indicated.
practices about which the transcripts and>other attachments clearly show non-uniform understanding by members of Region IV staff and supervision.
. Allegation II: "The Region IV QA inspection program at CPSES was inadequate."
I believe that this conclusion can' be accepted as written. It reflects adequately one of the very purposes of the effort now underway at Comanche Peak which is to establish an adequate confidence level about the design and construction of the Comanche Peak Units.
l Base:i on the available information. OIA finds that it appears that at CPSES Region IV did not satisfy the frequency requirements for the IE Manual Chapter 2512 QA inspection procedures. DIA noted that the requirement changes over the years made it difficult to make such a determination. Consequently, OIA i
states that it " appears" that it would not be possible to rely on the Region IV QA inspection effort as evidence of the safe construction of CPSES.
This will necessitate reliance lar0ely on the detailed technical inspections of various structures, systems, and components that have recently been conducted by the NRC at CPSES.
Over the past several years NRC has become increasingly concerned about TUGCO's QA program at CPSES and, as a result, a number of steps were begun j
When this
.to address those concerns culminating in the present review effort.
present revier effort is completed. there should be reasonable assurance thet l
CPES has been constructed in compliance with safety regulations irrespective of earlier QA problems.
l
1 o
'i A11ecation Ill: " Data documented in Region IV's NRC Form 766 Inspector's Report was inaccurate."
OIA found that, based on the information it developed, the data recorded on the NRC Form 766 pertaining to CPSES were inaccurate and unreliable.
In order to establish the significance of this finding, en analysis of the history, purpose, maintenance, and limitations of the 766 system would be needed. I do not believe the significance of this subject warrants further efforts because substantive agency safety decisions are not based on the information ' contained in the 766 system.
Summary I am satisfied that the report basically reflects a series of prolonged disagreements between a supervisor and his subordinate. While future reviews may suggest the supervisor may not have always been right, no intimidation or harassment has been substantiated. No improper intent or wrongdoing has been shown. While there were some derogatory comments made by several people other than the involved inspector, such comments are, in my view, unwarranted.
The overwhelming majority of Region IV personnel interviewed had no such problems in their dealings with management.
I am prepared to discuss my conclusions with you at your earliest convenience.
In the meantine, I will go forward with my current reconnended actions. When the review group completes its efforts I will be prepared to carry out any appropriate actions that are identified by that review.
/s/
Robert D. Martin Regional Administrator ENCLOSURE 1 i
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NUCLEAR REGULATOHY COMMISSION
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j January 21, 1987 MEMORANDUM FW: John G. Davis, Director Office of Nuclew Material Safety and Safeguarts-FRON:
Victor Stello, Jr.
Executive Director for Operations SUBRCT:
OIA REPORT REVIEW: CIA FILE #86 ESTABLISHMENT OF i
P.EVIEW GROUP i
I N
In order to resolve issues which OIA Repc,rt 8610 has raised, I as taking the following action:
l' You are assigned as Chairman of a Review Group to evaluate the safety significance of OIA findings in 01A File f86-10 and recomend resolution of the items.
G. Arlotto, J. Heltenes and C. Paperiello are assigned as members of the Group. This effort is not intended to duplicate the OIA effort.
2.
The task of the Review Group is to review the technical issues identified in OIA report 86-10 and to. determine and document in a report to me (1) the safety significance of those issues for Comanche Peak, i.e.,
whether actions should be taken to rectify any unsafe conditions; (2) whether the issues when identified were appropriately handled as to process and disposition; and, (3) detemine whether the current augmented review and inspection effort et Cenanche Peak is sufficient to compensate for any identified weakness in Region IV's Q/A inspection programs.
3.
In addition, you should (1) review the purpose and significance of NRC Fortn 766 and make appropriate recoe.mendations concerning its use, i
(2) without expanding tae tasks described in paragraph 2, offer me any judgment you may have on whether it is likely that there are broader implications in Region TV.
4.
You may task other NRC staff or utilize contractors as required, although I recomend that you keep your requirements to the minimum possible.
Necesserj funds will be made available at your request by RM.
T. Westerman and H. Phillips will be catailed to support your independent review on a full-time basts; other members cf RIY are at your full disposal as you may require. Similarly IE and NRR staff working on Comanche Peak are available to assist.
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5.
Copies of the report and enclosures will.iHt provided to you by separate cover.
6.
I would like to have your report in my hands by February 20, 1987.
F
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Executive Director for Operationy cci E. Backjord t L? Martin
]
E.,'-
G. Arlotto-R. Scroggins 3
J. Taylor H. Denter,
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J. Keppler
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C. Paperielloi C. Heltemiss,
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