ML20237L426
| ML20237L426 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/1986 |
| From: | Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Westerman T NRC |
| Shared Package | |
| ML20237F760 | List:
|
| References | |
| NUDOCS 8708200218 | |
| Download: ML20237L426 (40) | |
Text
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'? N UNITED STATES ,
p '; NUCLEAR RESULATCRY COMMISSION
$ I REGION IV 4 $11 RYAN PLAZA DRIVE, SUITE 1000 P X M i f6 I T M n, 9 ARUNGTON, TEXAS 70011 g
March 13, 1986 i MEMORANDUM FOR: T. F. Westerman, Chief Comanche Peak Group FROM: H. S. Phillips, Senior Resident Inspector Comanche Peak
SUBJECT:
DRAFT REPORTS Af ter performing inspections, I have always retained my draft reporis ,an'd field notes until I received the applicant's response and closed out the item. This has never caused a problem in the past because my reports always reflect the important information in the draf ts and fleid notes or there are explana-tions for charges. I see no need to change this practice. In light of the recent controversy over changes made to NRO Report 85-07/05, I feel that it is necessary to keep report drafts. Therefore, in accordance with Regional Office Policy Guide No. 0226, I am subnitting the copies of draf t report No. 85-14/11 to the file room. Since we have discussed all differences we have had concerning the report, there is no need to list them again. Y H. S. Phillips Senior Resident Inspector Cemanche Peak Cc: SRI file Docket file l
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8708200218 870819 PDR ADOCK 05000445 O PDR t__________----
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!!!E!il!D CONSTAUCfl0h thSPECTION REPORT oa f i l
U. S. NUCLEAR RE6ULATORY COMM!!$10N ' l REGION IV ' nnectionRepert: 50-445185-14 50446/8511 .ets: 50 445 Parait CFPR-126 50-44 CrPR-i:7 l 1 icants feias Uttlities Electric Company (TUIC) Skyray Tener 400 herth Olive Street Lock 9:x 61 i Dallal,Ittil 75201 tty Nase: Cosanche Peak Steae Electric Statien ICPSES) Unit I andUnit2 iettenAtt.81enRess, Texas stica Conductet October 1-31,1995
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j H. S. Phillips, Senler Resident Reactor Cate leapector (SRRll, Construction, Region IV CPSE5 Group (Paragraphs 1, 2, 3, 4, S, 4, and 9) l l D. L. Kelley, SRRI, Operaticas, Reglen IV, hte CPSES Srcup (Paragraph ) 1 l l l i l l D.f.Norsan,Beatterlespectcr Sate 1 Reglen IV CPSIS troup 7 (Pangraphy) l t , 3 Pe< 4 P. Consultantf Paraseterper-T. H. YoungJ. 64. ATCQuk I late l l w s.s . ,,
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- 1. larmes, Broup Leader, VCPSES6toup Date -
.edt T. F. Westefaan, Chief, Region IV CPIES Broup Date ih9B.htt!!!
- tion tenductedt October 1-31, 1995 fifreert 50 445/B5-18)
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1 bl del &DJs 1 l [XR90NG CON,1,A_CTED,'
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11.lGCO PF:RSONNEL t J. Merritt, Assistant Pro.iect. General Manager P. Hal stead. Manager Qual i t y CoM rol (DC) C. Welch. DC Superviator , j R. CM) SP A 4 er a Spengler, Corporate Duality Assuran o39- 11:2, J. Walkor, Corporate DA Auditor J. Marehell, Licencing J. Hicks, Licencing . lg) k C o f l V e$44 Wb 5 *.n) M. Strange, Supervising Enginner, Support bProject,[TNE) J. Ryan, Technital Sorvice. Super vi ser i S. All, TNE DA Staff Fngineer i B. Jones, Linit. 2 Super vi sing Enginner , Civil /Gtructurmi R. Hooten, Pra.i cc t Diccip12no Engineer, Civil / Structural ' J. Hodgson, Computer Operater Supervisor, PMCS J 90NTRACTOR PERSONNF*l W. Baker, Welding Engineer, Brown & Root (BLR) l W. Wright, WelcJing Engineer, PM l l l
s;u onmna+- w M U. Purdy, y Bt R J. Gore, S u b e. o n t r n e t Super vi r.or . DM. K. Thornton, Warehoutr.o Superintendent, B&R C. ocborne, G A. U M I- S y v o e,, , B!A l.:--
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D. Leath, TNC- DA B.SR K. Norman, Central Operationo Supervince, DDC- DLR D. Bleeker, DCTG Super vi s.or , DLR R. C. Iotti. Project Manager, Ebeuco l l A. Sm1they, Duperviror IRV, WA R. Wa l t rer s , ASME DA Supervinor. BLR l G. Mac:ugen, Welding Engineer. BLR T. Gray, Doc.ument Control Manager P. Pat el , Unit 1 Civil Lead, TNii Design, GLH _p 7, e , e im ; & > et , , n r. .. v 4 4 , . _., Finnin wr. f'4 vi l /ritrur t . re ct;
. . l an t. o . c r u.w s. 6 L . .. a p ' . . . I . 2, i : r . Ci H 1/ Sin.A. , ;)CCC B. Jonon, E:: pedi ting Cupr't visory li?R g_
L Bernard, PMG F'ila CJ ert. IAR T. McCormacl., Fire Frottn; tion Engineer, Impell i
$bx. W e.In S. Fr. I man , Accictant Project Engineer,dS/W/E/C) d.< Eay e a 54f*3 <
H. Moscow, Supervisor Projects & Ser vi ces, NY, h_U. /2 ' G,$.C. J. T a t *' , 304 DU Date 11 it ra Superv2nor. BLR J. Junge, 31 DU Sato11s te Gupervisor, B&R J. 'Womacl<, 3Or>/101 Du Satelli te Supt rvisor, B&R R. Flaherty, 307 DU Gatellite Gupervisor, B&R E. Ha::l e, 310 DU Sato111te Supervicor, BLR J. Day, 3Ori DU Sate)1ite Super vi ear, B&R
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J. Dickey, DCC Ar e,a Sup er vi '.or , Log i n teer Cate111tes, B&R S. Bruce, DCC Area Superva war ,, Craft Gate 111 tem, USR k 4__-- 4, %'Too v.s
- 2. At various times during the inspection period NRC inspectors conducted general tours of the reactor building, safeguards building, and the electrical and control building. During the tours, the NRC incpector observed ongoing construction work, and di scuswd vari ous sub.j ects wi th perconnel ongaged in work ac t i vi t i er..
j No violati ons or deviationn were identified. L Act i on ore i .2 : 1-i ' ' -d Drrf i c i enci as IdN b b Se IM' - l l
- a. The App'licants procedures portaining to Significant Deficiancy l Anal yui n. Repor t s (SDAR) wer ra reviewed to determine how the t
pt'ocess of deficiency identification through completion Ad d sign-oFf aru c on t r o11 e. d . Si t et* procedures CP-OP-15.6 (Rev. 3) SDAR STATUG 'fRACKING. CP-OPO-16.1 (Rev. 6) SIGNIFICANT CONSTRUCTION DEFICIENCIES, CP-QP-37.6 (Rev. 1) CORRECTIVE ACTION, and TUGCD proceduruv. DQP-CD-4 (Rev. 1) REPORTING OF SIGNIFICANT DEFICIE'NCIES, DDP-DA-17 (Rev. 2) ADMINISTRATION AND ! TRACKTNG OF SIGNIFICANT DEFICIENCY ANALYSIS REPORTS 469ARe+, and DDP-QA-11 (Rev. 1) CORRECTIVE ACTION were reviewed. Procedures CP-OP-15.6, CP OP-16.1, DOP-CD-4, AND CQP-QA-12 do not address the SDAR itle r.nntents or a methcid for addressing .n
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compl eti on and v.i gn -of t i or the required corrective action. i Proceduren CP DP -17 o anrJ DDP-QP-15. 6 address the documentati on
%g is M cross betwen$ DMhed required f or cl osi ng def i ci enci as, but d:. at reference jbl+o MW W5 W l I gSDAR file contents. 1he pp.ticants procedures do not specsfy 1 2 '
the documentati on n++crsmr.2r y to complete an SDAR fila. 1
- b. The Applicant classi fied the f ollowing reportable SDAR 'len v.,
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"1 i centde. 6d i ori Comp 1 ret e" 3 SDAR'sCf84-27, CP-84-29, CP-85-04 <$-
CP 05 CP 21., CP-e;-12, Cr..es-12, ane Ce-es-14. A11 f iles li ri,ted here di d not document or reference where ttreC NJ documentation was coa lk ss>-ft"4 that verified that the cor rective actions harl 3 I boon r. o m p i m t e d . Come,equeant J y, the NRC inspector did not l perf ortn a i al d Vur 2 f i r..ali on for any of thnse f11pu. c
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- e. T he' 4 c) 1owi ng non-repor L abl e SDARs iil es waro sel ected f or review w.ance the Ap p12 .a n t. tlassified these as "Licencee ottici, complete".
(1) (CLGELIN lhu NRW inspweter reviewed the f oll oe ng SDAR'51 CP 04-QS. CP-84 ~'2 CP--G4 - 23, CP-84-24, CP-84-26, CP-84-32, CP-sh-02, Cf-85-08, and CP-G5-09. The ppl i cant 's evetlu.et i on and decision that thur.e SDARc ar e e not reportable appe=sr u to be correct. (2) (OPEN) The NRC inspetter reviewed th. ':11:ni n;; SDAR's[ CP-84-30, CP-G4 -34, and CP-85-06. The filen for these i SDAR*C did not contain suf ficient inf ormation or
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l l The incomplete files are unrer.olved pending the completion of a TUGCD effort to make the files complete and a subsequent NRC j review. (445/0514-01; 446/8511-01). l i
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4- PP D I i G.au t. ,, fir,iz,9c.,,gn ,J1tp vigyyn,, NR,q,,jf,gspyd o n FindinarA I (CLOSED) Unr esol ved item 44S/01'O-02 Invertrer Transf ormer Common Failure 1 l l l l The NRC inspetitor reviewed the applicant's handling of the defective transf ormers and conc l uded that even though the actions taken to ! uvaluate and correct the cleficiency were correct and adequate, the deficiency won Si gni i i cant enough and the common component failure of nuch magn tude that more timejy reporting of the defect to the NRC was, required by 10 CPR Part 50.5S(e), i The applicant's handling and reporting of significant deficiencies will continue to be monitor ed by the M .nspectors. Thi s itamn; i rr, i closed. (C nresolved item (44L/8226-U-07) Stress Analysipipe I Support CC-1-107-000-E23Rt .. a new anal ysis was, requested v.u4abic. Subsequently. the NRC Ins eceived a copy h
_. _ __m ave ua~ aame w.w : 1 D6 f the hanger anal yr;2 u b. TUGCD for the cub.iecL hanger efter ii had beren ren , t rad from a platiorm to tube steel, an al y's i s a lJ ' ewta (-- -- thi r. opeci fi c item br; cloomt a one & Webster will generically reviowed reanelytm ' ing/ hang. - and the NRC will inspect this I rev' ' a later date. ! (CLOSED) Violation (44*S/0307 V-01) E::censive Weldino Gaps In 19G3 NRC inspector iduntified an unacceptable fitting on a pipe support Mark No. SW- 1 .102- 106-Y3:.'K. Recently the NRC inspector fallowed up l l and rev'iowed NCR M5173-$. Rrt 751.947, WDCGO669, related v, ketches end l i nspetti on reportis. Corr ac.ti ve uorL was Accomplished /A OC petr4 orme'd h roqua r ed i n sp ec t i on th . An engjiireeri ng analyu.is of the installation i or iginally citaad item shnwe:1 utrength was far in excess of mi ni mune desion requir omeents even though it violated the procedure. In browii
- 6. R oo t. memo -IM 325,200 dated April 13, 1903 supervision r asomph o ni z ed to all p er e onn rt ) alfocted the requirement to follow proceduren, CLOS C D i
(&f;4(el Violation (4 4S/831 t, '03 ) Failur a to Write a Non-conformance Report (NCil) on Base Met.al Rep.ai r : In 1983 this violation concerned an instance where the NRC inspector observed minimum wall vi ol .at i on but no NCR was h. iiton. On Octn'her G and 9, 199".,, another NRC , inspector revinwn.i thN vi olati on o f site procedure QI -QAP-16.1 -2 ! <(-- l (Rev. 4) dated May 20, 1982, paragraph ;;.1.1. The p m~"~e scope 4s pro A -y ofg Revision 4,had been r: hanged to maker f urther ref erence to system wal k down, and the item in question was accomplished near this t2 mrt
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_- ___ m- um~ a we,e w vcs : l I. i 67 frame. However , thre applicant responded by documenting the quest f oried minimum wall vi ul .a t t or. and the repair of the ad.jaceret weld on a common NCR 6611 . These conditions had been found by p separato NDE methods, one birf orta and one after the base metal repair. The NRC inspector inapucted two more recent base metal repairs to varify that the problemz had beren ecrrected. One repair performed in 1984 wan found to have tacen in compliance with the then current prowedures. The second r epair was completed, revi ewed, accepted, and wnt to tht+ vault i n Gopt embr.ar and October of 1985. This, stecond report s.hoWed en criginal wnld rompleted, t'evi e wed , and accepted in January and' February, 1985. Due to interference with hanger 2 nv.tal l at i on the wel d wan nobr.wcauen tl y wubjected to cosmetic work in September 1980.. Thi s; c c7,me t i c worl. res.ulted in a minimum wall
.iolation. WWW Further wort to reptur was classified as a " Major Weld Fiep a i r " in acc ordance wi t.h DW procedure CP-CP 6.4G paragraph 3.3, M however, no NC.R was, grenerated.
Th2s failurc to document a minimum wal) vi ol at i on on e non- c onf ormance report is a violation of 10 CFR Part BOj Apper.dt x Bj CriterJon XV M 46/G511 -02) . tNu It in t; 5 noted that the inspect <r and preparer of the Repair *- - Protes.s Shout had recently received training on the newly revised proceduren involved which required th- "y be generated. I t' .W4 s AAso i te tre noted als,o that the Assistant P. .s Welding Engineer who revi ewed the Repair Process !!heet had not been so trained on the procedure as he had buon e:: nmp t by htu position. W- n=--Miel_ '%
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MQ sob frL w64. thed NRC in *- p _- ' t2 - ~ : g: : ;_ ? .. dol.m.,. ir - --- - m. -y vn m . . _ e y .,-.. + n-,, ths+ o 1 'a - d. Co ose.P h (fibliQ4) Unr esol ve.'d I t e*#e 446/050* / 01 Responsible Welding Su' p or vihm Not Familiar wtth Wolding Rod Control Procedure s/ and Subt.eque% Training: 'i. 1985 the NRC inspector intepwfewed s4upervi uor s, who k o not i arni j 3 ar with welding rog,dbrtrel procedures which t he i r' ,,c r e w of weldel s wer e ,rAfspunbibl e f or i mp l e t..o o t. i rig . No vi ol at i in'.v.ccurred try4.his instance, however, ( followup on vi ol /uti on 0~15- 01 d&r.ribed in the previous j' s paragraph i d ent i f i ctd an inst'$nce whohq violation rnay have been
, N pr n.,nted it tr aint ne,.afed not been wai v.cNe the supervi nne wac, exempt f romdrh tr.uning. W i m A d . 9re y -
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~ (CLOSED) item (445/8323-07), Incomplete Clase V(5)
Pipu Supports Record Packege: Wh In 19M thr.' NRC reviewett packagou p into finalized packagen. In 1984 the TRT revi gewed a rando", s.ampl e of 11 Class V(5' support record pac L. ages >. This review showed the par t oges with Spect1on reporto (by qualified i n t.p m e ter $ ) were in proper
_- __ _. _~ ---o I S9 or cier . The TRT fou'ii1 the ror.ords satisfactory. This was gv AG(. -O'74 7j S q/h M F*f*h EdIdd*, k' ' reportert on page N- 2SO. olyGSER)10 dated April, 1985. (CLOSCD) Unreeolved Item (445/8347-01) Containment Eurface Area Coating: 1 hic iterm addressed sloughing of protective 3 coatings on Westinghouse supplied items. In 88ER 9 NRR staff states they have roeuonabler assurance that debris generated by the failure of all coat.Jngs inside the Containment Su11 ding under des.ign basis or;c i dent. conditions will not unacceptably deg r a d re the performance of .:'wt-accident fluid systems., This GCO / /u/?E6 -079 7/ war bed on TUEE- and other nLudi ec ref erenced ingSSER{an pagec k-L-17 and L-10. NRR re. qui ren a r.re-operational and post Glo apa r at. ici ee l L oatings program bcs proposed by TUEp in SSER 9, but thic cpecz fi c i i t, u t' of sinughioQ of coatings vo Westinghouse i t om r, im c . l a e,e d b .u. e d an t .' m SSER 9 conclusions. l I (CLOSED) V2clation ( 44 S / 0 416--V --02 ) Failure to Provide Controlled Issuanco of Deuiqn Documents and Changen Therreto: Detween May and (June N, 1904, an NRC inspector fCWnd that l design document, and changes worn not controlled by Operationu Document Contral Center (DCC). On October 11 and 14, 198.; iMe l NRC inspector con f i rmtad that the corpputer system and terminal % referred to in the TUGf0 November 1. 1994 response were in placo and in use, j l I i I I I 1 1 _ . . _ . _ _ . . . . . . 1 i
__ _ - -. -- . - . - . -vuvv -. I pkU hW gdi(M W Th te NRC inspector r evi nwm ' ' c ,[1 f)CA's and CC's\andkl f i ni 2 r Dat ersaw ;
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d i st r i but i onp t o sn44w 9/)1ccationu for a scorrective The s,o l vor t ous di sicipii nt.ra y veri f action. DCA's and Ctt - r e c c' trated in their routing at the central DCC l and then on t.n the matellito DCC's now they are distributed from them. All items cher:6.nd were distributed per DCP-3 (Rev
- 10) with DCN 1, 2, and 3 with the following exceptions.
q , h hv.-4. k fl% $Q4 h D* w Y \ ' A M ~j , C Component' Modifar.alsun Card ?C.J.i=96181 (Rev. 1) had been L l issued on Ottebr.=r G. 37R$ and natellite LCC 307 (craft) had ; p i c k ted it up at rent en1 Du . . however, they f ailed to sign f or it. Sign-off iw required by paragraph 3.1.1.1 of DCP-3 (Rev. i j 1 .dith DCN't. 2, 2, and 7. )F 7-- _ d ;r t ; ;. J t.t.;t ' l l 2
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_ r* ru rit t i r rad, There was a eami1ar occur r canc.ca on CMC 75CO3 (Rev. 2) as iss,ued
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to CCC notell i te 02/21.1 . (TUCCO). Thiu.ftilure to gn f or ' .
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l (446/O"' 1 -V-Q'". ') . F Tr_u r t her . DCA 21446 (Rev. 1) Was issued lJ q $ (1 October G, 198D and D 3:.e111 tee 007 was irt possession of i on October 14, 198S. It we.t u in one of two packages Fnr draw i
'"a!.-E i - 1702 3 ~d ( RFrv . 2). Or ies of these two packages had hath Mwv. O nal Rwv.i 3n' DCA 214+,an it and the other had only
- h. :n it. Bot h 'Revi ra an O's ar e not stamped " Void" d-l .o . . od in p ar agraph .3. 2. ?. "U o f DCP-3.
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m gr .;.9 2 . ' ' . ! . C " D r u ;; . : 5 2. , .,, .; , w ...i . i. 6 i on .nu urw . woori P be aanrroutuu nu noo = c, t m . . .J . 60- ..m. 1,,,c - t:r :: t'.r_ ___,f "
,t,y y m -i i m e.n e e. -
f t.- g ,,,,, ;, ,. ~ iu- - m n u ,- 0., oceotu , i _ 7 , ; , ;; ,,, , , , , , _ , , , ,
, ', _, 14, E
It, . I l 3 9G, , DF;C s.atol li te 307 iss,ved Dwo 2323-El-1702 Ght 002 r0 c, Revi sion 2 to an elorti-ician h h n im A v. ck s l4., ch s d e rmd4< o. c ut di%'4. M M for Class IE field work with 95 Reav i tr.l on O of DCA 021446 rather than the current Revi si on 1.hDn I R. t tet s u 14, 1905, TIJGCC und Brown 24 Root supervision contacF l the el ect ri ci .an. The e' J ectr ician indicated he had gotten t h e e t. - i 002 ra', thor than ph rae l ThU 11 M41 4 UW\a.i w,Ovi by miutake ,and return 3d dt, 4 /g y @p 'a i k8 wt W , 3d Pv
- M a M ~~^ -
immdiately without inr,tal}jng anything to it. However tru ! i m o n t.e e, o f t ir, r,?l octri ci an and hir., for man did emphasim a th.
- . . gn off on the fjp e Ut+si on Change Log f or reper reviv. ion .t desi gri ch.inge doc um9mtc, nr+ceds cl ari fi cati on.
,)- N- _
w - x P des,h clocmMh f
*dI q Thepe10f nilures C F R PN to f allow +c.c, procedures c~ -+ 4 "'6e a violation di I'
'446/0511 h h .4 SD Cc N . 4 E'.
- h. b -c. A b dl d Nw.CILAv' bt/ " HJ , +
mFurthur',it was noted that some practices were being f ollowed l that were neither in DCP-3 nor another controll ed procedur e., 0 0 u.1 I k ')0.v t,. So c y. n g, L-___________________________________._________._._ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _
- -- - - _a _
y + k:. % DCC J. ape.rvi si on staton thsT the practices are described in I.. dnterna) uncont rol l ed quidelincm. M'I / '
" " W ## h*". I o1,roraer <Yrn y h y 4 sVt few int,f
%$ L 4 s f f ro u de n.< H l The meathod usud to iusive dr= Wing packages from the satellitou to the field ( e. g. crafLL and U.C.) was not addressed i n DCP- 3.
A DCC person and the recipient sign f or receipt of all thie prepar dor.umente M0 DC4v. ) and the pr oper revisions on the computer printed " Orr.N DESIGN CHANGE LOG". Ane h aar pr .? Of the DCC. group is to 100 int.o the computer the st..tum of the DCA' v, anr1 CMC's. Thi s status is open, void (UNI). or at included (N1) and indicatec whether a change is of Fem ting all toms, bui l t t.o a drawing, a s, ingle item utili.ing the drowi ng or no irthur t i ., n of the change. 1)rawi ng
'7 F ~0910 Ght CLR-24 Rev. l'.' had CMC 75003 iEnued against tt.
1 %\ l This CMC had .3tatun NI on YV. O and Q1 because it affectud a ; s.i ng l e hanger utili: ng the at vn drawing. However, Revi s.i on '/ did not have NI input and 2t ashow - as open on the terminala. l Thiu would require it t o t'e i n c l ud sni.I ith the drawi ng packagn in error. Thi u wa., c .. r etteri on the teri nal. Th4o uh rsi e:i procesu or statuning i s, not described in DC- " . . k$ $f' - [
, v--- .g .i.e C. m t F O ' 1 "' d n r m r e edi i r a. t c- r m m 4. ., . . .
- 4. ,7 g6 p g.g,% 3 ,, ,_
l E*4 t c . . c '.' : , m - <- m e i ., ' Mi (446/9511- o)
,. 7
l 1 6 ! (Cl.05ED) Vi al at i on (G4--nR- Ol[5 G.aps, ()n Uni t i Polar Crene Bracket and Geismic Connections: In Novomber 1984 an NRC ine.pector found hat the gaps be t.wtwn the benc.ket and connectors er.ceeded futGG-0197 l tht-
- i gn tol er ance. Thir. itrem is addressed in g BSER 8 along l
1 wn related problemn with polar cranes. Discussion, conclus.2ons and acti ons to be taken are included in pages K-14,
. . u .%' 3 ' ~ ' '
15' , tr. >nd 121.123 of Appends:t k to,BSER B. Since these actiono will addreur, the specific concerns of item 84-04-01 and this i t arm 17. U ... . c ; . . c l ossred . e j I e5 The NRC inspector dr.-: i J tortviewthehpplicant'srecordkeepino l 5 nyr. tom after f indi nra that rocord':, were being ' shipp.ed off site without p r opre g controlh 'a) nd b
;. r - ': ct.-.
M t*WM.0g
-:::r ec.
g bt a- N MJ . In Finci Safety Analynic neport (FSAR) Volume 1, Section 1.0; App end i t: 1 4(N) and 14(B), the pplicant commits to Regulatory Guide: E 1.88; Collection, Storage, and Maintenance of Nuclear Power Pl ant Quality Accurance Recordt; and to Am t\fk %Q &or,ican n s'n National o elsk.<l OStandards. mn ey t*1s t423 Institute (ANSI) N45.2.9g On p.ngo 1A(B)-36 in the Discussion, the
/ clae4 Ni l ppplicant 1 it' .- takoy'oxception to this standard o *ir," ' : -ib...
2- 2:::pt nie w.4 y iw me e i. um . m . . _ ;: d r ^2 10 No D a' - N d' E m^ or cr e "~ r , m ,., m _. : .- - b ' - = 1 * => n a t i v - wM c t t-
;q r_ y t u ,- '
W. A brief description of Quality
.. u-vranco Recorris in F5AR Enction 27.1.17 (Amendment 50 dated uly 1994) b edM " C.V's }O C: de-% W i c.ticLv.4 5.s M W
. e. 4 4 . . . . . _ i_'., ^ . ;l 7e. ^ :; ;.- t C;;ti-- * . . 17 -
_ ~ -- _ 1 I l 64 (fu new ~,t
- e
- e ^; '
.pr, 1 " ' ' -- u mt_.frai- see " W t, a r* g 4 l
amtthu is.d i y .a a o r e r. a. nov . m d , m..m it ,f == ;& .e.y nwr m. J.o eo .--,.,,a m
,;:i(;; , - g ,,, , ; A . - a are storea.
()5%(Let.r,.)J ko'7l t ing-a) ~L-s-~ *l
, ? wi- l of3records-h ry)i; -~+ di rrrrrrd f or
-L. . e . ,
a:c17 ! 9, temporary storage the fgt.SOM6vdyn to stora ^ rr- -
#..cryF, Interim Record Vault (IRV), !
Par.. u,. t a n t Per:< i- d Vault (PPRV) and the Procurement Records c; t ,.u a. . . .,w e,. e rdj e \
.ai,ehouse n>j & & .
1 The ppifcont ha's not rev2 ced f*S/4R Section 17.1.17 to dnscribe and
<*' wak tews'l< c%.*,$(.> c fren c e *e.ss'I M'O . Yk )
reflect the current DA Rucord system gi s unrosolved pending the aplicant's, actxans on the item des.cribed below (445 /0514-Q.?; j G- 5 : 446 /0511--Oy) . {
- o. Roview of Cor pnr :e u a l s. and $2te Implementing Procedura-The NRC inspector r em : . man, Utili.tieb Generating Company 1
(TUGCO), Cnrporate On , r egr am Manual, Revision 14 dated April f 1 Q, 198", and Duali t y Acc,ur anr e Pl an, Revision 14, dated August ) 30 1904, to determi ne i f ANSI N45.2.9 was ref ercenced and r r e qu i r emen t is wi+re tranrolated into these documentr,. CD IMy knMb) Frocodar e rP -OP- 18. 4, Rovisiien 5, reiserences ANSI N45.R.9 but ev4 t%*. > p you.Jur<a ele h dio J e '.ule to addresu all aspetts of ANSI N45.2.9, s,uch a a41 facil:+y locettons; method for maintaining control of and i l accountability for record :, removed f rom the si te stor age l facility to cegani::ations locate on or off site; tempe- u , storage facilities (fire rated cabinets versus duplic.ati. an
...te cp.r tod l oe.a t.i on . ;M-specia2 nrocess g re,ards u a 3 A
I 60 photographs, n eg a t. : v e m ,, an ti micraf1Im ; :. ,.. .. .i. of fpv m,"4 .o 4 M t,, . .. u i i u . The permanent facilities are y ,w; m e k > A e me.rA *L'*~ discussed with rer,poct to ANSI NC. O. paragraph 5.6, however. f thre drain system and dr y chemical / gas fire protection system m . . u - - ~4 4n m 4 i- g , *y 4 iu tiot discussed. The IRV System ! 4s i permanent records vault ior Unit 2 records until such ; Censhd* records can be transferred to.tho,PPRV where Unit i records are now stored. TUGCD F roceduro CP-QP-10. 6 Rev. 3 discusses rneneds turn-over f r om Brown & Floot IRV to TUGCO PPRV but does ' net .ns!d e u s s: the iusm = i > i aM ahnvn. Alsn, t h o v.ra i c.t one, ar e n ot addrt+cwd in Brown L iloot DA t1ano.t3 Section 17.C datead October 31, 1984 and Cf-DAP-10.3, Revi si on 3, dated Jul y 11, 19G4. L
\
Tem Utili ti es managemen t stated that all of their QA manuals are in reva ninn to jmpenvc their written progr.um. Thi s i t e-em i f,. 2 L unrev,c1ved pending the comp)4. tion of that review 3 W6/ 85' // - o f 3 (Wf[IS@"O 7) 9 b. Storcoca and Trannmi&lal of Design Records to Stone & Webs.ter, New Yor k -) On October 16, 1985, en INC inspoctor was inspecting an open i t em previ ousl y i denti f i r:ej /)> g e m it as unresolved item 8226-U-07.A ghe rn-quali fi entien packmoe ior pape r.,upport CC-1 107-OOB-E23R wah i L ! requested and ther NRC i ns,pector was informed that th m$ d e s,i gi . l retur ds package and about 3702 (4654 4or Unit i 1048 for uni' l M other hanger pach oes si.ad been shipped to Stone & Webster
I l 66 Engineering Company, ( SWi!C. ) . New Yor-k f or a complete re-ana3y.siu The NRC Senior Resident Inupactor inter viewed the TUGCO engineering supervitter who ans.wered quustions about whether l procedures controlled suc;h shipment, the number of recorde per l 1ssso u %*>ds j package, and how the r ecordc. woru prot:veted f romg ir:2, water, etc.) during fihipmrent . He stated that a first transmittal Wan cont roll ed by procador e CP- EI-10. 0-4 Revi sion 0, clated July 25, i i 1905 until Cornanche Poal h cioct F*n g i neer i ng (CPPE) ber.ame a part of TUGCO Nuciccar Enginec> ring (TNEonSeptember 1, 1 98", , at which time the proteriur a was dc+1 ct ed . SWEC pro.icet manager ta l. .d. wij t h eit St one tv Wob st ver proc:edure CPPP-3 covers the recea pt and indexing of theur par:Lacea, however, CPPP-11 that will l control the distribution ci ther.o packages to SWEC of ficou et Chur r y Hi) 1, NJs D o st on ., Mrh Denver, CD Houcton, TXg and l l Tor onto, Canad.w. will not be completed unti^1 lato October or l carly November, 1% ictord2no to SWEC Supurviser Project Ser vi ceu, N Y ,. i.tc. Thit. i,o lure t a have protectures which control m .. the rnhipment of r cr.ords i n a violation of 10 CFR Part 50 #' Appendin B, Criteria V. (445/8514- . ; 446/B511 07). l Further, the TUGCO enginet-ring ~ visor stated that the 5702 l packages (which containted all of the original calculation
,1,,, t . 3 needed by BWEC', the calculation checklist, a copy of Engineering Evaluation of Separation Violation (E.E.S.U.) for holes /Hilti boltu and the original covetr sheet awhich describced l
l
- _ _ - _ _ _ _ _ _ _ _ _ _ ~ _
67 package contents with cpproval sign.sture) were shipped in cardboard boxes. Duplicate copior,of thes,e records.Here not - made and retained en uite in caso the originals were lost, i Therefore, the records while in route were not afforded the minimum protection which was required ryW_i M for the years l'f*) they werr. on si tej They wer e shipped in cardboard containern W Ltl3 not meet g temporary ! whicih do. storags* requirements'.4 JV '
- two p alferes ii N b T"O hour fire rated container or g maintainW dupilcate copies at separatu and romoto l oc at i on s; . Protection from fire, watur, and ot her possi til e detri mr,'nt.a1 conditions during shipment is not direct.ly addec* sed in ANS1 N45.2.9 or 10 CFR 50 Appendin D but common cense di rt at nt; that such a large number of records .
m8 $was. cu%fnei c W'* (many which cannot be recanu.truct ed)gbe protectad 3 at all timo! , This items i s unresol ved ' u, s a w,% % a.eu-e % 5euc 1> i ng
&x?r rJIed s ew : W--
= ' ' "- i - f or .g .by Nhc l headquarter sh (4 45/ Wit hh0f: 445/IE11[OO).
et.e .d ieb W ' ipervjser, when questioned, also stated that they,do not I:m ew the number of pagin vhipped. That is they did not count V L oth,sim .. the number of pagen per package shipped. When askeg, he erot i mat ed that each of the S702 packages may contain an many as 50 pagen ti # f er r' 'U'd per packago or an estimated ks a v eof 700,000 pages. 4nventory chuet.s or package checklist were not
.evAil ebic on s.i te. The question was asked as to how ' ri could be sure they received all the contents et a package batt i and the reply wasa *1U1.500 will audit the packages when returned". The NRC inspector stated that a meaningful audit appnen io hrr i mpos.51 bl e si nc e no one knows how many pages we.'r' ,
1 l
~
.-. maammmmmme.
6 68 in uech package when they luit. hence, how would they know when
?
they are returned. i i This. failure to maintain .:en t r o) of and an accountability for records removed f ron. str r age in a L th a violation of 10 CFR Part 50 Appendix D, Criterion XVII 1d a d="4=+4e 3 ~ ~' 9 ^ *
-.. "+mont to ANST nom.' - o >< = > 9 ,% C.! 15 (445/8514-0 ; ,
1 446/0511-09).
#< L 'l 4 h b "$ '
The supervisor was ani.ed why copaes, wore not made and the responmu was ihat they decided to proceed at ri si, . Al s,o , it LAh.5 io was statted that SWEC W st/perf orm a totally new analysis 4sa. l c^- : r --t ,- C;"_'C and these would become the official design records i uM" c.4 % arrd would replace t.ho ol d don i . ..'. tN "b i rpod. I d(m C 0 3 kip % i S hv bh
- b m e -* 45 5h M $L L& ( e 4 M t)satedth.. ,
- t. Stor age and Tr annitii ttal of Construction Records to Chicago j l
Bridge
- and Ironf' o n de.io% (G, li Y .g p [r *)
/4thirdNRCinspectorgnot involved with the SWEC recordn ;
swSC 5 t r a n r-mi t t al hear d abot.it t.h,nAtransmi ttal and remeambered a cl in11 ar incident. In late s3uly, 1 9 8 "., he had asked for records l l pertatning to tinit 2 reat; tor containment liner and mechanical } l p+ . 1iinc but wan i h(nrmr'd t hat thny were nnt- v a i 1 at sa er i site etcause they had been shipped to CBI, Houston, Texas, t r.- ) i b a' copied. e ""4 * '" l i, , 1700, '* ""'-- 2'r~ r c' th: C t"' t- r--d't:1 .iiJ L i u.- i.c-t t h ,. s s . .g o o l , ,c cr i. ..;. : Mi;; d,
-. .s , m e t.g u , ,,. ; ., , , e ; , g , m ,,m ;, ; ' 17 C r , ; u ;, _ , , ;_
1 i
)
i
- - - ~--
pfeb dTI i 45 c$ y-M M ' 69 y m , . . ; .m 9. $"* ' i ~o the third NRC inspecto reinspected the CDI records tr,iinsmi t t.ed and found that the original const r uc ti on CA rocordri, were transmitted to Houston, Texas, l without retaining a copy. CBI procedure NRP-1 (Nucl ear Ratcordt. l l Procedura) s t at m, that corrugated cardboard packing is i satisfactory for smis11 shipmonts and that wood should be used for' largo freight s hi pments. The procedure further states that ! shipping by air freight, .:s t r cus p r es s , or UPS is required for I nhipmento cont 4ining documentt, difficult or impossible to l I i r erp l a c o N_ \ l
\
The NRC inv.pectorG Interviewed the TUGCQ civi1 engineering i Project Cuntact end B L R subcontract super vi sor to deter mine 4
- - =-
if the C131 rcecords Wore t.t nesmitted in accordance t*n t > v e L with w A Aa%A lilGr.D .
.kv t- t% CL 1 Msho k u e4 C 62 %& ov L l
oh hi.4 belong to the owner,asw1 removal from procedure M as these ##rot,WU h ' TOMO Alst.c is,' W sits
- whnul d bef trolled by %. Thog wes-e al so asked how t h[r ecor de wer e shipped and if a method of accounting for ett these r ecordo was descr ibeed in TUGCO procedurou ar.d ':11 .e d .
No TUGCC procedoro wM, t dentifi ed and there was nn record of a detai l ed inventory l i c t. or ac. counting f or records transmitted.
"TLI6do g e y m ,.c r. : a% r , ~- ,_,,g c. t 2t t ' - .~ i ' u mg : g.
e mn t- m.p_-+< .,7, >'at 4h .- n c- n ,4 - E -- 1 2., ; t r C;; , g L.s
~.
t ., qv.u. ejsM. TU. WO f: & The transmittal of recordu without a procedure and affording protection in trannit equal to temporary storage requirements e-is an unter,olved i tem pendi ng 4.he review by NRC headquarter v. 9 da 4s. s., .a % u p-.a4at*IAu s4 -L : . Ors eds 'a Jt(445/G534/#0/; 4 46, EiS 2 1[10 ) . y v . ., ,. -
.)
Ig
.- . ~ . . - ,
g
- - v vum on I
b.4. aW. 4v v 4edd. v 6 **.4. A The f ailure to maintain contlol is n d provide accountability of . l
^ l recor dr, r etnoved f rom v. tor age is a violation of 10 CFR Part 50 l
Appendiv Cri ter 2 on XV11 ('lt![lC'f:- lG W4/$5tl ~ /l) . l , The NRC in>.v. . tor reviewed two reveent TUGCO audits of'CBI to l detrermine if the OA recorde. T.ystem was audited. Audits TCB-S and TCP-6 dated March 22 and May 7, 1985, respectively, dr.1cumented audi ts of CDI construction organization on site and the Duality Ascur ance of f i co et Hnuuten, Texas. The NRC l i nsp+c t or contacted the T:lGCO Audit Group located in Da13at,, 1 Texan to find out if t.he y L.new tow records wer e retored on
/s site, transmitted f reim si t re to liouston, Texas, and dett'rmine if the Houtton faellity w.a c., a d e qu a t t+ and had procedures to r ecei ve, control and accuunt fai' thnse rocerds. P "' "EC
.5 e
m 4 -+ mr _ n n + e -+ w +, e n , - " subsequent to contactinq ' . -
%(O to k pod M ro W wt%h nLu s A 5 i
t-h* s .aud i t nr 3 s TUGCO QA enanager contacted thre NRC inspector and
; r.tated that he had met with TUGCOhi#EN1 o
l' (\ , d i fa c u u r, this i st ut- and hr:. rstated that the TUGCO deci sion to 46' As a ece.4H 4 Ni9 8 Y l p ;end records to CDT w.n at TUGCOs own risk , Jhn NRC innprector b
,.f..b &, . W, hr M i
;s ki
., u ided a n n w e r ';, to the qu sn t i on r. murhrd . 8 genusaw.e.
An additional r eason that. the NRC inspector contacted the Audi t Group, was to riret er mi ne why Audi t TCB-6 Audi t Secue i n c tiutt.tl f.' n Recerdr. as 9 . of the audit but the report failed to report on this suu. sect. MtW auri! inr who participated on this audit did i not know why thavi c.ubj ect was not covered in the audit. i I I..
- 4 C________________._
G 'd 03:60 SB/CO/21 ~l SG00-D B N S3Sd3 WO6- l
- k. ,
fajlure t.c do n b' a,,ts u Et!"" C' 1OCIR
' 9 \
Th i .<s mont audi.t o. , resulte is a . l p4 dir e;e ,6. fo I(.<w a y A "i~> , _ r 1. < ny e d; n rr ,& ,-i vottY- (445/0S14 l I IL I 446/ 511 -1}). p I
- d. Inspection ofStoragef~aci1ii1es.f .
l The NRC inspectors i nspected all elte storage f acilities to deter mi nn i f storage, preservation and safe keeping of r ec.or d c ; I are as r equi rod by 10 CFH P.u-t 50 Appendix D, Criteria XVII and ANSI N45.2.9, Draft 11. Revision O. parag" aph S. " Storage Preecervat ion and Saf e Unopi ng",, The facilities inspected i includo TUGCO Records, Center, Permanent Plant Record Vault , _ _ _ l (PPRV), Iter i m Record Vaul t. gg P(ow dro**[J (IRV), _ .r.ite Storage Areas N for
)
j Unit '2 Mechans e al and Electrscal " a p e., r T -- C r c '_; t , and
& 8 j
1 Procurement Rec ords Otorage Ar oa. The facilitien for the Paper 4 ( Fj ow Group and Procurement recordu are not diecuanmd w-os dosev. bed 1 identified ing 7UGCO or 13rown & Root procedure, however, t h se s e f acili ties, and the PPHV and IRV were evaluated and ros:ults are l cVi iel]OWG: (1) TUGCO Records t>nter 1 This vault is the final repository for Unit 1 recor ds ch doncribe completed consster'ction and Unit 2 record
..ackages for cystoma that will be completed and turned over to operatione.. This facility was completed about March 1993. The NRC inupector found that this vault had
. . . . . . . . . . =
t____________ _ _ _ _ _ _ _ _ _ _ _ . . __ __
-~ _ _ _
I 72 (G , accouw eniitroi: r ecordr, wer te st or sed in rpr - M containnrn y l Of b3U"> /\ or in binders nn top of . fuey1 de 2_-:ts. Radiograph 3and ottn=r j spec.i al procen.s recar do are protected by controlling temperature and humidity The dusign of this facility in ae discussed in paragr+ph S.6 " Facility" of ANSI N45.2.9 and i s conr.tr ucted ta protnet contents against fire, l flood, t or n ad o e .s , rodc+nts and deterioration caused by I ex tremo temptcr e.<t ur o humi di ty condi ti on. The facilities m eg e t the rnnuirementn of ANG1 N45.2.9 except au follows: l l 1
" i (a) The f1[?' pr ottuc t i on u.ystem discussed in ANSI N45.;"' 9 i
paragraph 5.6 i t rem (0) specifies a dry chemical or l l gas fir e pr at uti on myu. tem but TUGCO elected to i l I innta11 a water =,prinkler system. TUGCO personnel - ut et trd that a water v.prinkler system was installed inntoad of gas /dr y chtemi cal because water wou'a d ; l exi i ngui nh a deep e,oeded 4 ire. Thi:r, presents a j cme PM
- p. # ' m bin.aune thc. r ecords 4+m4. are stored in open l
A {. f ac ed cabi net 7. i ii f olders or binderc will be del uged l I wi tie water and will lip.ely deteriorate. The National F71re Protection Association (NFPA) -1982 states that filing erquipment shall be noncombustible througout. l l All records shall be ntored in fully enclosed j i noncombustible containnes. An additional j
' s consideration i o t hat records stored in a manila l fold r will b r.. . m ;
d c.<e wu washed flo mid = out 3 and cleg the drain in this n l j C __ fati)it) Ther e is no evidence that TUGCO submitted j ll
)
i i L
. .mmmimmarammmmmummmmmmmn e +m '
,i
1 4 'd P2860 E9/CO/21 SdO-0GN S3Sd3 GWs
~
f a ,it & ,si.u k n M in T2 0 a description c, . nis 4acilityjfor approval of this .
~
chango t o tiiu' commitment in the FSAR. , A'4. - S y c Y Alf t) A $ kl4 n at L
- ou.$ PA $* %
dlle% 54 dwy is YM gtkt 11 Pd A i/M) Q 2 Tl i u f a l l u r e.- tu instdl) a system ar, dancribed in ANSI N43.2.9, f or suppr es ing fire and protecting recordsr. is a deviation from FSAR commitments in Appendix 1A(B). FGAR Soction 17,1.17 and 17.2.17 4e .5et. IPAV18wi M4t' I describc0f the TUGCO Records r; och. (445/0514-D-DEM ; 446/D$11-D N). i l (2) Per manent Plant Rr,c or d Vaul t _
' Thin vault ser ved iam the rt. ole permanent vault from approx 1 mat el y 1975 unti1 March 1983. This permanent r ec or t:IS facility hat. controlled accean. It meetr the ;
6. donign f ea t u r tw, forgpermanent facility,in part but does j not fully meet s t l,a permanent facility design features as foilows: (a) There 17 no firra slipprecicl on syntem inside this vault. 'two hand-huld e;:tinguishers and a two inch fire hos,e are located outside the vault. One hand l held extinguisher in located inside the vault. Fire detector's and alarms are inside to alert the onsite
% wlyM y fire dupartment if a fire occurs 7 Chaper 5 6 of NFPA states that " Tot al dopendence on the combination of
. . .-- a - .g
I 74 smoke (1e t ric t. i ari and hand fire extinguishers still leaves t h e:- f .Ac i l i t y subject to a ma,ior disaster." (b) If the 2 inch +1re hose in used to extinguish a fire j { de ll lih h fh ke 1 e c . r)L-there are no fire drains and the floor is not 9 1 oped 4: p :- ~4 1? redi ..;. Therefore, water j w,1l IN 7 eethd en t car the bottom cabinet drawerr.. (c) Nonconf or marice and corrective action reports were st.or ed in binders, in b ook c cisen.. If firre hosus are ucu ri , they will tJe subjected to the f orce of water c~-dclm W feom the hoseh Therefcro, these recorda should be I t,t o r e d in c:Losed contanners. All other records werc' l l c,t o r e d i n non f a re rat.ed cabinets which is acceptable if i n c.o t ted iri a per mannnt facility that meets ANSI l N45. 2. 9 requi r ement m. Thee failure to install a fire suppression system, drainn and a uloped floor oppnar s to be a deviation f rom FSAR Appundin 1 A (19 ) which rommitu to ANSI N45.2.9 without enception. Heiwaver thic item is unresolved because this facility su described in FSAR Section 17.1.17 and is unresolved pending e written response,from NRC yepdm$ $~C ef 'li*S' PiO' jg) l headquartura eri .icecptabilityf (445/0514 -44; l ~ 14 446/0511 .R4). 1 (3) I ntotri m Rocce d Vaul t. - k
l
)
7 t;. .-t d n9*-*'b b_ Th a r., area i r. Si o t, a G U plu ci t e bu11 ding but is an' area f( the prir manc nt vault thet is y,e t, etside as an interim u.torage ar ea pr ior to placing records in thus area designated for per manent records. T hi.. ar ea har., an access point that i in separ ate f rom the periorws t area and is controlled. The iaci11ty it t h e s.a m ca e. the permanent area except a wall , I seporat en the two. They share thet same f orced air system.
"Ibi sfa.cil1f mrect) thre r requi t nmr. nts of 10 CF"R Part 50 Appendi x B and ANUI N45. '7.. r? e:: cept n 'a f ol lows: f (50 Water h art bren I ranl . ) ng tbrough the forced air syutom anel b r:ci da a t.upport girder. In a second location j
appr ox i mat.ril y 7 >.' cial l ons of watetr had Iraked in through t. b e 4arad ai r ventilat ion duct and was l 1 cought b y ei r.on t tii n or placc>d under the duct. Tho l temper atur e/husn2 e t.i t y control chart indicated high humidity (G:i 60%) from October 14 through Octobiar 20, 190S. Int erview. wi th vault and other site personnel ( l r eveal ed t h a t, t h ea roof and vont system have been l t l 1 eaking f or appr oulmatel y two years and perhaps l onger . R n d i ng r ap h g. , photographs, microf t im and 1 other senut tive, cer;ords were stored in the PPRV and IRV until appro::imattel y December 26, 1984 when they I J were tran>r.f er r ed tn the DA Records Center. (b) The NRC innpector observed a ratfizr pot, usgar, and crumbs on .a n adjacent table where food had been i 1 l L__________________________.________.___-__.________
me o oe mu vo evewo aaw- - acees avea i i Y 3 ev 7 !. ' brought i t.t o the v ;t a r ef a . Cof f sse pots ar'st rea1\ f i re har.or clu and olis*v J d not be allowod inside the 14.wru ., veau l t . *yrey k 1- 11 3,5 4+6 A MM 8 g c, s bi ' gyp e -< se e ds % M M m ' l This follaro to prol.ect recordh fr'om moisture and/or
- W c on d er.s.c t i or. Iorg c si t eridad pori od, and the (ailure to prer.)uda .E.(e e
-+ -Qa c,in M e.s',ca 1
- m;;r /.[ig :;;: L .:M J bb 3
..t , is,- 3 I
violation of 1u CFR Part 50 Appendix B, Criteria XVIlv
. l ' , )<
i Y- d \* O (445)(t4~ : 446/9511- 16 ) '. ' gr6' . r. w s NOTE: The NFFP Cetti ans quotud abr ve arar not Lomin[tmerite b u t- are quoted te de>monstrato that currernt practices d e.4 t mMt-,f i. 9.004.. Co - eve. M *)rac:( % , 7 A e's Cle m M s'/ g , ,o,, ,, t .c
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3 .,.
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ANst M 't T: 21 *) " 4 A f R' h ' #'" " '. " * (4) it? St.oroq3e Areat.: , N, j McL WEJO[bw 9 d ro '
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- s. ,
i
'1he NFIC inopoetero inspected trailers where the niectr W al ,.
and mechanical paper flow groups are located to detoMinre # I ;
(pg.
rocords tire si creer 'Ikt M/LC.'iMS 4:fr cords whir.t%+urnitih document.ary evidenen e#s - I the quality of itemc and of acti vi tion af f ecting , quality ss n>
for the purpesce of thi s standard.
A document'it),- !l -
+
C.onsidered a c;usliLy sw.urance record when l't has been completed. " Tho Taxas Ut .t 13 ti es GendatinO Company ~ t definition of 04. r ec ordo i n procadure CP-QP- 18. 4, Revi ci on 3 15, inconsantent w i t.h thin definitic . s\ ., 5s ,' > L 4' s s l U
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p9 ,5,
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/V ,y p<ogs4 /hM f {t in paper (1 ow .r oipt t o v ap p t'.' W4 g en, wifh complet.ed OA
(
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! c e .u d .. ~ a.s.....o nv mw r ucs. 2. 7 3 m3 nce $ n wi t h 1a ., ,. i I inr. ump]c+c dncommii . w', il r l i tlw;urnen t 1ha. war l- i ts i n >q I V
- hce NRC s nc,pei i or eev.ie$wed previous inspections 2 (,
pr or erar . c-h ~thi n arna.' NPl: Specidl f ; .3
'~- Tet.im Report dated July m$'
4
,. s%
1 3 ., ^i 9El4 ident 1. ect .* poi unti al en+orcoment iusue becaus.e
/
- s. ' 5 ,,
original A3ME recor+> . o tch as moment. restraint pact:4ges p rI
\
er e or ud in tr u i er 5 an non-fireproof cabanets without. e.,' f i f4)t.C. ge c6%./ L. u'e _ (T R T) ct Is e 'e vi w* d e- ailed ir -t hni imp t. op y fi.4 c.i:$ g . . r a i o and romotc lot:ati on. ^ Thuar l x docu.m M M t : nd t rig e, 2n ' w i n m "
- m-
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/t4 6 - 07 4 7
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N n ., 11 .-'" D-100 m' " A E O M 7. The NRC E , _ g pagw [ i ni;pret: t or contaclec the. T rt r membe'r who wau respone.ibin ior t . .o g l.i . - O c.it:W ant! +qii,,d i hol - TP! member considered stor aqe 2a ihiu area adio qiaat e hai:ause at t' 4 ti me i t ' ' Y, hiu
} 3 unrieret atuti,ng i h a t e nmp 1 eit e;t .documeret c as det a s eed by ANCI l
. . )
l C.:'.9 were .torrd lii f .i e e t .-and J i l e c ab i n e t t . l .,c I
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N .. On Oc t r,ber 71 ., 19 7.i., NRC i nnpoct ors inspected the f' aper
. 4. ,
i Fjraa Group n t cir .ag t.: +0rilittgs and determined th ait a laroc l 1 numbre of mechanic.nl and ei er: t r i c al records had bnen s 4 ;
/ F r omoved f rom ihe permanerit f.,toragre area a.nd had been '
Wh sid. 6 4 3 b < d l
'? pjaced in paper -f I 06 U+ie.v a g es, i n non-fireprcof cobinets, f b,
1 Pr avs aus NRC 1 nyp ec t.1 nd s in Shis arca documented i scil a t ed t - e s wn r e oc ,i.. car o. w , QU.A n ,,i n th. e . k' s s.i, uo. . . over , , 4( dmm n, o . m. , m . , .,m m. . , %_i _ o _ u, m , , ,, m _ ,. f, i I f $ 6 1 i
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si c I : E. O SG,00 21 SdO-Ddl4 53Ed? u . : -
,u (if .. I ! t *,i p t a e tt r e i. t ' .1 i te 1, t r H i ()n r Ff COr t15 .w t (3 GtQr Ltd lin
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r i h e ,.,e 'i1e . 1:4u ! ep.> riow Grcup pt .r a.onn el e r '" x1*' 5W d '
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record 6 of t r u,t ...d l o l i i in we' e c.tored 2n th urse W
% n Q w \es d,c uay ero '
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ccpt4f ("% 54-pevard.<.r=::J M WD /cCf 6 b t 'n <WI ) c 7 wi .- .. , re iE6 m i-d . L b p b c. a.-{-( t;. . v i o 1,, i; , t i (,f i o Li ' p e t, a, s. . (q:pi .n,j i . l , 9, 7 g ,,&h ,- n <g, n35 3 1 . j _.lh \ ,
- I'r i t. et 2 .a WI I (;' pn ,
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~ .- ,, a (b) S t or a gte of Fr ni Ur emer a l lie t. or ' d r..
1 ! In warehnune " li " n a. ui c mr.en t. records w s:tnred both t ii l *"T l 4. A)12.c. ia s p < fo d n.o u.>f* qrna w d.e x o f % <$< e ' <rv/s non fir.3 ratrzr; a r. cl 4 j r r.> r a t ed cabi n e t sd E = t ' . .. d k f.uilsty 11. n u i- ci<r ,r.r a h e d in the ifSAR or- procedurcs, irre e
#g; 4s no w.-ty t f.i Ll-- ku w L ev At 2 .
drtt < r mi nF w h e t. h r+r dup ! I ca t rer.[ m:1 r.t c and w+%!. ( { tr,ust be st.ored in ftre r al+d cabinets. Thi o i torn i ti unrenalved p<soding i dnr. t ) i i ca t i on and des.cript. ion of thi w fau2]ity and indensnq of rec.ords recentl y recr i ved from the *I UCC 0, D +.1 ) a n , l e u u v. , offito t.o determi ne wh.at r etor dL must bu i n fir re r o t rid e: ab i n et c (445/8514 14-) ; l *>- 4/16/0511 IE).
/7 C , g--- fat Audi t e r en bec o, ,1 r.,s.t-mvrocilit e u 4
CI'd 62860 58 00/Z1 SdO-DWN S 3 5 d 3 18. : - i l hrf NRt1 i n u pr.tr t nr fif
' ew l .i f O tlt.6'"r $J $
- 8. h te un ac e s?p t ab t re 3c :endi Y' M* l tion 5 tdent4i : t. d a b r e.- '
io I,.A r a g r e p lit.; La anri 5d had been ] i dcant i f i ed by 'l113r.O o, !!rowr i & Root audits. TUGCO audi t.
- d
( TCP- D'.t 20 riotod .ianuar y 16, 190".i) [ t.he pre,rmanent p l ari t- ; yd a f k el*Je tu) l recordr. vault f a11 red t o ident i f y any problems with the j 3 f ir/ - N fatility. ANb1 N45. 2. 9 siperi (i r.al l y ntlater, that. . pera odic audits shall be perf orenerd to assure facilitien are in goud condi t i nn and ten'pt$r ahire/humi di ty . controls and prot ect i vi' devices, tir e f urm i t oni nq p r oper-l y. Two auditor s audi ted ~. j than area from Dec emts er 17 through Dec en.b ur 2.0, 190/l, .M ii l t h r.i r repor L did i . o t. i d on i t. i i y o r y utorage 4aci11t.y problemn.
~
gblY OV $ Elsacco (, - t444 ria t ed June 16, f 1981, page 4 of 2L item o.
- r. t a t t'ri "It is an est a b] a shed 4act that t.hn QAR vault r!o e r.
I not merrt i *in requi rementr> f or a single utor . t aci 11 i y rand that dup]1 cot.c filtm we not maintained in lieu ci r.i n g l e storage f ac ili t:y and that duplicate files ar c no 4 1 i mai n t.wi n ed in J ir u ni ringle r,torage." On October 23, 19H A t hr$ NRC j nr.prar tor- reque- *d ris. ;umentati on whi ch i ' d LL ubM +0 h MU - 5 would r,h ow a r.t i on i .n e. r. to coreect t.hi s pr oblerrf TUGCOc t Pro. ject and QC organt iesti onst h.4d no riuch documentati on. Thic i t r=m i s .nreciol ved pending review of the response to- ) this antiit f i ndi rig. (440/0514 -#[a 446/0511 - 13 ff The NRC I ns.pec tor . nil. c:t t FPRV per sonnel if Brown F., Root had l
.lud i t trd thn r ee nc ri Leoping/ facility GyEtem and were l
I.
__ __ _ _ _ _ _ . --- -- ----- -mwe 00 I i n f ortnud that i t h a s, twen several years since Drown & Root had performed cuch audito. This item in unresolved pending the revi ssw of Brown & Root audits (445/0514 -hi fjl 446/8511 - ->6) . , 19
] p f71 Control of Weld Filler Moterials This inspects on won per f ormed to determine whether saf ety j s'
rel atect wold filler material purchase. Storage, and distribution are in accordance with the pplicant's work and QA procedures anc applicable ASME code requirement. Impl ement ats on of the> f ollowing procedures was examined during the i nspec t i on e C P - Q A P - tJ. 3 , Revi si on 9, dated October 15, 1984,
" Receiving I n sp ut ti on "
CP-CFM-6.9B. Revision 2, dated September 21, 1994, "WM d Fi 11er Material Control" l . CP-CPM 0.1, Revisien 3, dated July 2, 1905, l "Recolpt, Storage, and Issuance of Items" l i The f ol) owing areat; were examinedt - 1 (a) Procuenment: Four purchase ordur packages, which consisted of the purchase order, procurement specification, and field requi si ti onn were inspocted to verity that orders
51*d SE:60 68/CO/21 Sdo-D@N S3SdD U::: UI win e pr pp> m J v -opt ovril and included requieetl i or hol r.atl , par 1imAng. nrad dor t.tmentat j on requ2 r oanent % cpr?c.t f 2 eri i n 5. i i o pr Oct.aduren pertaining tc weld fillor mei t er i al p u r c h a sser.. No violatione, or unresolved items were i denti f i ed in thi n ar o.4. (b) Recejving J rirapoLL 2 no:
)
f(cceivj og i ni;.p er..t s ar. F r4c or d s . for the ( A J ier mat er .i r.) Pye(m.vteA.J[ d8f3 % fJ ; purch.n.od i n t b re t ' 7.e e ! r s i n sp ec i.er.t . were en: om i ned In vor i i y i hat. al1 itemn required by attachment 11 (Dec.miving Checklist) t o CP-+0AF' -Oc 1 h .p d l b rmn innpected In each caue the checklist and c receiving 1 n t4ppr.1 i on repoi-t- (RIR) had been completo.tl and t,igried lay a l.evel 21 C!C i nspractor . In sevrre) 1 l i nT.t ences Notic.onf or mance Repor ts (NCR) had been complet ed and mat er) al returned to the vendor no r c,q,.ti r ed b y procedureu. Certified Material icst - Reportn (CM1R) i nt each purchace were also reviewed . i t o t o ver2 f y that required inspections and tests h.Ari ! been per4 ar meci and that material had been purchat,erl 4 r om a vr-ncicer ..n t h .a 4.urr ent ASME certi fic.at s on. It a w.,v. al no vm i t i on! th st heat codes and quantfiiut. c' matersel *,.hnwn on the Mr.terial Retej ving Reports i, (MRR) cor respondad to what was shown on the CMTR. .
)
d
~ - _
rr' N o - V i u l .ii i m . <t'. 6 0 o 's ' ..o1 v ed i L emy, wer e ' i den t 1 f t r'd in Uti . Fr e. ( r. ) Main Utoraqo Ar o.a t. : Two fillur motor i ol storage areau located in War ehnuse A were inr.prect ad ior compliance with procedures, i ne loried in the above documents. One ar w Gua0 w a e. dr.in i gna t ed .ni a r area and'the* other ona wat, boi li h F. O and Non-D or am lho Non O ns..tt. 1.a i W4 r. $' va r rcq.. l s. a _, r eqiti red from tiiu D mater.i al . Protetlures n in .the c.. t or a g e a r ea' nr.peared to be adequately implemented cucopt for the in110 wing i taams : F'a r a g r ap h . 71 . 1 oi CP--cpl 1 6. 9D requi r e's, that. Q wel d ( 13 'J er snater l aj uraipnal cont ai ner ts be marked upon r na ci p t ' anti clar a ni,y stoiaga wi th thr+ material C
- c. .l aus s i t ca ll on. w2te, and heat /1 t numtsr . In the U l
ares l abel a, nn aci e r.T1 contai nerr., of Sanvich gr,1dinq j'rodor t 9(wra l d rod)had +4.llen off and athers werr ) l l oor.m The matertal wan *st i l l identifiable becauSU j l of the c.turaco han mar 6:ing and marking en the ) whi ppi ng r . art on ; 1.owever, a lors of i denti f i cat i on . i t, p ar.s. > b 3 rr when mot etr iol i t. removed from the storage a r e,:4 Thor r- wert. aic.o soveral unopened cartons ut Sanvich materiuj whi. ror c t.atus cott1 d not- be de t ermi n ed .. Lotm.o or missing labels were identified 1
*e +=..ma... ..
l
~ 4.1 ' d .'EiEO 68eCO/21 SdO-DbN S 3 E d ? 1 K .: !
I L fi-no L. h t- f al I owi ng matur i al; Lot 101172*2. 3/0 i nt:h l AWS/ADME SFA F. . 'I en ti ILu t; 10249-1, 5/32 i nch ALJD/ ASML SP A f,.ti. The f ni l or ei +o adequately snark t h e or mr.'w fwin id ki Yicai e. a j
.*m t er s a 1 i t. n vi ol a t i on in the requirements of CP CPM 6, '? D k de 6 CriSt< @ . / OC IO g (J ini 4 46 / 8"s 11/)l'- W) .
(d) Dis.tribution St.3 ionw: 4
]
W.n 1 #1 r od e; i is c. ei is. .(el:y related applications orto d 1 $ 1' r . b u l C it..i 1" r off1 016 f P lif' H a b ( b'O d h 0 U S C A,
'Y , untl 'I-C a r. l . d i r,t r i bi e l a ni t r.1:nt i on weit; inspected t.o verifyi :
1 Lomplianen tvi t h r eriui reme,nt s of CF-CPM 6.9B 2n t.h e 4 al l uwi ng Orcan: Storeoe iami1) 0y (Level EO I deint j 4 i c.a t i on of material i
. Contrn11cai ac c o u,t., into storage ar eas.
Coni.r al uf tstati anar y and por tabl e r od avrsnt. I <:, v.u .:u s t o , r eturn Anr1 accountability of material Com.pi rat i on and control - of recordt. i _ hun tyWBD e V Y A1 b L-1 2 r ' '- ' e *^ A
- Y^ l' e >
/i Gunviti mal er i di wts obt erveld in Rodhouse 1
4 h j'AT y l 1ahul pr ob i eme n<, drmeribud above : cl;t. 7. ;, +^ M (4%l TS7) Oh v= = . u ...: . . _ . .r w - 'r ' . a . : '.~, . ,w ,
-- -- i t ' i - ? :
b'd.T b2 4 hd__S.lQlP.0,13.li.l ,,M.M.l l .C.if},Wn 1 4.AAAA.=e *4e mm .
EI'd IC:50 56/C0/21 SdO-DdN S33d3 gh _ l 4
) i l'
;;4 Dur i ng i h i v: a n up er: L i can por i rarl t l i e' N T .' G incpoctor pet-f or med .a wal 6.down l inspecti on nf w.t l ec t ed el ect r a c.31 t.omponents and r;ebl es to driternii no 1
the degree of protectson of c. l .nh. I F.:. ;t tem f rom surrounding l 1 conr.truc t 1 on auti va ti (Ps. I T he gent,2rai) I cvril of p r o L c$c t. J on oppnaru adiequate with the exce=pt.ian ! of t he D S*d ot y Tr ai n D i e t.e 'l enginre control panel (2DG02A). Ti w i vi squnon tovuina had com:- l oow in wveral spots ellowing concrotr> ) dust from above t a fi1 Lor 1 n i r . p .a r.c l aind s.et t 1 t? nn snmte of ther installed relayn i i In the arc >u of cableu it wau teoled t ha t. cable ends were neatly l coiled and the end tapped, r:eb l e tugs wer e in pl ace and cable J acket i repairs were clear'Jy marivd AL inne point in the Safety Train D I swi tchguar room. a c abl e e:.: 2 1 i r ig a tray and ent er-i n g t.hu s.wi tchgear j (cablu number 1250 06070 .d ove the HVAC chiller No. 14.) appearett to be hearing hard on t he Mcptar e co . t.a on of the cable tray side ladder at its e: tit poi nt. In nthr r pl e,c es whcere cable exits tray a piece of discardr*d t.nble J .a r l i n g is uwd as a buffer. The point had none. No vi ela t ionn or deviationu we.w r- 1.p u n d . /(. DJrj,t I n tgr vi ew An at::1 t interviow wac conducter! Nr,vember 1, 1985, with the applir:anI represent at a vrn. i dent i f i eri in parigraph 1 of t h i s, app rendi t: . Duriny w.-
61'd 7?101 Gl'd It: 60 GB.'CO/21 Sdo-O'UN S33d3 WO : I l 1 Hb thir, inter tew, the tricp oi,t.-,r s 'a tmen.ar s t ed the scope and findinqu n( d the i n tip et. t. i on . T he. gppl1,-ant uti..iumij ndg,ad the f i n d i ngs>%'--f s d 1 1 f 1 l 1 1 i I i i
~~- - - --
- - _ _ )
~
In Reply Refer To: MAR 06 9 Dockets: 50-445/85-14 50-446/85-11 Texas Utilities Generating Company Frw,Aiy Alo . II ATTN: Mr. W. G. Counsil ^ ~ ^ Executive Vice President
'400 North Olive L.B. 81 Dallas, Texas 75201 Gentlemen:
This refers to the inspection conducted by Mr. T. F. Westerman and other I members of the Region IV Comanche Peak Group during the period September 30 ; through October 31,1985, of activities covered by NRC Construction Permits ; CPPR-126 and CPPR-127 for the Comanche Peak Steam Electric Station, Units 1 -. and 2, and to the respective discussions of our findings with Messrs. J. B. George and J. C. Kuykendall, and other members of your staff at the conclusion of the inspection. Areas examined during the inspection included. operations, construction' and Comanche Peak Response Team activities. An inspection was also performed by Region IV staff of Unit 2 cable tray support modifications during this report period. Within these sreas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and Observations by the inspectors. These findings are documented in the enclosed inspection report. During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to i these violations, in writing, in accordance with the provisions of I Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10. Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. During this inspection, it was found that certain of your activities appeared to deviate from commitments made to the NRC. These items and references to the comitments &re identified in the enclosed Notice of Deviation. You are requested to respond to these deviations in writing. Your response should be based on the specifics contained in the Notice of Deviation enclosed with this letter. With respect to item A in the Notice of Deviation, the NRC has ascertained subsequent to this report period that ERC lops for tracking of equipment / service requests have not been uti izing procedurally required unique numbers for individual requests. Accordinly, please address this as part of your response to item A in the Notice of Deviation. RIV: CPG / SRI / CON SRI /0PS M CPG CPG Y NRR DLKelley IBarnes TFWesterman JSHPhillipsq ENJohnson VSNoonan /
/3/86 3 / a> /86 = /ss s/ 3 /86 3/g/86 / '0b[55d0f0$
o., g. l Texas Utilities Generating Company ) Twenty unresolved items are identified as follows in the enclosed inspection report: Appendix C, paragraph 4; Appendix D, paragraphs 3.a. 3.c, 4.g, 5, 5.a. l 5.c, 5.d, and 6; Appendix E, paragraphs 6.g. 6.h, 6.j, 7.a. 7.c, and 7.e. We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is4 dent 4fied in paragraph 2 of Appendix C, paragraph 4 of Appendix D, and paragraph 2 of Appendix E of the enclosed report. The responses directed by this letter and the accompanying Notices are not subject to the clearance procedures of the Office of Management and Budget as : required by the Paperwork Reduction Act of 1980, PL 96-511. ' Should you have any questions concerning this inspection, we will be pleased to i discuss them with you. ) Sincerely, , original Signed By E. H. Johnson E. H. Johnson, Director Division of Reactor Safety and Projects
Enclosures:
- 1. Appendix A - Notice of Violation
- 2. Appendix B - Notice of Deviation
- 3. Appendix C - NRC Operations Inspection Report 50-445/85-14
- 4. Appendix D - NRC Construction Inspection Report l 50-445/85-14 50-446/85-11
- 5. Appendix E - NRC Comanche Peak Response Team Activities Intpection Report 50-445/85-14 50-446/85-11
- 6. Appendix F - NRC Cable Tray Modifications Inspections Report 50-446/85-11 I
cc w/ enclosures: (See page 3) I
* ,4 Texas Utilities Generating Company cc w/ enclosures:
Teias, Utilities Generating Con 1pany ' . . . _ ATTN: J. W. Beck, Vice President Licensing, Quality Assurance, and Nuclear Fuels Skyway Tower 400 North Olive Street Lock Box B1 Dallas, Texas 75201 Juanita Ellis President - CASE
. . 1426 Polk Street Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 76711 TEXAS STATE DEPARTMENT OF HEALTH bec to DMB (IE01)
{ bec distrib. by RIV:
*RPB
- MIS System
*RRI-OPS *RSTS Operator
*RR?-CONST *R&SPB
*T. F. Westerman, CPTG DRSP V. Noonan, NRR R. Martin, RA S. Treby, ELD *RSB
*RIV File J. Taylor IE
*D. Weiss, LFMB (AR-2015) R. Heishman, IE
'w/766
+ g APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Dockets! $0-443EF14 50-446/85-11 l Comanche Peak Steam Electric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127 During an NRC inspection conducted on October 1-31, 1985, six violations of NRC requirements were identified. The violations involved failure to maintain ;
sufficient chemistry records, a minimum wall violation not being documented on a nonconformance report (NCR), inadequate issue control for design documents, absence of procedures for controlling offsite shipment of original design records, signing of inspection reports by a noncertified electrical inspector, and revision of drawings without required review and approval actions. In. accordance with the "10General Enforcement Actions," CFR PartStatement 2 AppendixofCPolicy 1985),(and Procedure the violations arefor NRC listed below: : A. Criterion XVII of Appendix B to 10 CFR Part 50, as implemented by Section 3.8, Revision 4, of the Operations Administrative Control and Quality Assurance Plan, requires that (1) sufficient records shall be i maintained to furnish evidence of activities affecting quality, and (2) that the records shall include the results and acceptability of tests and analyses, and the action taken in connection with any deficiencies noted. Contrary to the above:
- 1. A significant number of instances of missing data entries was noted in water chemistry records covering the period March 1983 through September 1985, with respect to the chemistry sampling frequency requirements of Procedures CHM-501, " Chemistry Control of the Steam Generators," and CHM-508, " Chemistry Control of the Primary Cooling Water Systems. No annotations were made in the records to explain why the samples were not taken.
- 2. Review of the water chemistry records showed instances of failure to make required entries to indicate when the' Shift Supervisor was notified in regard to out-of-specification chemistry results.
1
- 3. The records did not identify what corrective actions were taken after 1
entry of out-of-specification results. Af Ana n al ^~ Q wwuouM1/ .. Q
.4. s
- 4. Inadequate reviews were performed of the acceptability of water chemistry data, as evidenced by the presence of review and approval signatures on forms containing discrepant data results.
This is a Severity Level IV violation (Supplement II) (445/8514-V-01). s B. ' Criterion V of Appendix B to.10 CFR Part 50, as implemeriteiTy iUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31,-1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Paragraphs 2.3 and 3.1.1.1 of Brown and Root (B&R) Procedure CQ-QAP-16.2, Revision 25, require that nonconformances be identified, documented by , completing the NCR form, and dispositioned. Paragraph 3.19.5.2 of B&R , Procedure CP-CPM 6.9D, Revision 6, states, in part, with respect to NCRs ! for minimum wall violations, ". . . Welding engineering shall review the conditions stated on the NCR . . . ." j Contrary to the above, repair of a minimum wall violation associated with weld 21-2 in component CC-2-RB-053 was noted on October 9,1985, from i record review to have been performed without documenting the condition on ! an NCR form. This is a Severity Level IV violation (Supplement II) (446/8511-V-01). l C. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Paragraph 3.1.1.1 of B&R Procedure DCP-3, Revision 18, states, in part,
. . . Issuance and receipt of controlled design changes are documented on the Document Distribution Log . . . by signature or initial of the file custodian and dated." Paragraph 3.2.2.5 of this procedure additionally requires that the face of a rettined superseded document must be stamped
" VOID."
Contrary to the above:
- 1. Satellite document control center 307 was noted on October 14, 1985, to be in possession of a controlled copy of Component Modification Card 96181 for which receipt had not been signed for and dated on the Document Distribution Log.
. a- 3 i
- 2. A copy of superseded Design Change Authorization (DCA) 21446, Revision 0, was noted on the same date to be present in two packages for Drawing 2323-El-1702, Sheet 002, Revision 2. .Both copies of DCA 21446, Revision 0, were not stamped " VOID" on the face of the
( document. This is a Severity Level IV violation (Supplement II) (446/8511-V-02). D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that i activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
~
Section 17.1.17 of the Final Safety Analysis Report, Volume XIV. Amendment 50, dated July 13, 1984, commits to procedures requiring that records be controlled and accounted for during transfer between organizations. Contrary to the above, original sole copy design records were ascertained on October 16, 1985, to have been shipped to Stone and Webster Engineering Corporation, New York, without the establishment and implementation of j procedures that address required control and inventory measures. l This is a Severity Level IV violation (Supplement II) (445/8514-V 02, 446/8511-V-03). E. Criterion VI of Appendix B to 10 CFR Part 50, as implemented by i Section 3.8, Revision 4, of the Operations Administrative and Quality Assurance Plan, requires that (1) measures shall be established to control i the issuance of documents such as drawings, including changes thereto; and (2) the measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel. Paragraphs 2 and 4 in Revisions 7 and 8 of Station Administration Manual Procedure No. STA-405 require that all documented nonconformances, in which "use-as-is" dispositions are recommended, be forwarded to TUGC0 l Operations Results Engineering group for review to determine if as-built documentation changes are needed. Paragraph 4.0 in Revision 0 of Nuclear Operations Engineering Manual Instruction No. N0E-201-5 requires that proposed drawing changes be submitted to the Operations Superintendent for review, approval, and ' l authorization to distribute the revised drawing. l l
.o m I
l Contrary to the above, nine as-built drawings were revised and distributed ! by TUGC0 Nuclear Engineering to reflect NCR identified undersize welds, I without receiving TUCGO Operations review, approval, and authorization to j distribute the revised drawings. j i l gThis is a Severity Level IV violation (Supplement II) (445/851,4-V-03). J F. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 QAP, Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in acco Mance with these instructions, procedures, or drawings. Paragraph 3.0 of Procedure CP-QP-2.1, Revision 14, dated October 17, 1983, states, in part ". . . inspection personnel. . . shall have experience in and shall have completed a technical training course and examination in the area of inspection responsibilities." Paragraph 3.7 of this procedure states, in part, ". . . Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perfom their assigned tasks." Contrary to the above, it was noted on October 21, 1985, during review of documentation for Class 1E lighting system conduit EAB1-1 that the electrical inspector, who had signed inspection reports E-1-0024951 and E-1-0027419 had not been certified to the applicable Procedure QI-QP-11.2-25. Revision 17, dated February 13, 1984, " Inspection of New Installations for Class IE Lighting Systems." This is a Severity level IV violation (Supplement II) (445/8514-V-04). Pursuant to the provisions of 10 CFR 2.201 Texas Utilities Electric Company is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or l explanation in reply, including for each violation: (1)thereasonfor the violations if admitted (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to l avoid further violations, and (4) the date when full compliance will be l achieved. Where good cause is shown, consideration will be given to l extending the response time. Dated at Arlington, Texas this 6th day of March, 1986.
...s- m l l
APPENDIX B NOTICE OF DEVIATION Texu Utilities Electric Company - Docketsj.g_- Comanche Peak Steam Electric Pemits: CPPR-126 Station, Units 1 and 2 CPPR-127 Based on the results of an NRC inspection conducted during the period of October 1 through 31, 1985, of Comanche Peak Response Team (CPRT) activities, four deviations from commitments to the NRC were identified. The deviations involved ERC equipment / service requests not being controlled as committed, _ inadequate ERC document review and procedure criteria with respect to inspection attributes that are inaccessible or nonrecreatable, failure of ERC document reviews to both detect a lapsed electrical inspector certification and to record required information in a verification package, and inspection attributes being attested to as acceptable by ERC inspectors which were found by subsequent NRC inspection to be unacceptable. In accordance with the
" General Statement of Polit.y and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1985), the deviations are listed below: A. Section 4.1.6 of ERC Comanche Peak Project Procedure (CPP) CPP-012. "QA/QC Interface with Constructor /TUGCO," states, "The QA/QC Records Administrator controls requests for equipment / services and distributes and controls requests for technical information." Contrary to the above, the QA/QC Records Administrator does not receive copies of requests to provide for control of these documents (445/8514-D-01). B. Section 4.1 of CPRT Issue-Specific Action Plan (ISAP) No. VII.C. ! Revision 0, dated June 21, 1985, states, in part, ". . . Where required, documentation reviews will be utilized to supplement the reinspection for attributes which are nonrecreatable or inaccessible . . . ." Section 4.1.3 of the ISAP states, in part, ". . . The inspection procedure will provide detailed instructions to the inspectors and/or documentation review s for performing the reinspection and/or documentation reviews Contrary to the above, the following examples were noted of. inadequate procedural guidance and document reviewer performance in regard to nonrecreatable and inaccessible attributes: l l A ,M 2 / IO h '/i
.o w i
~2-
- 1. Quality Instruction (QI) QI-013, Revision 4, lists no specific attributes, but instead specifies that the inspector verify installations in accordance with one or more of a listing of TUGC0 procedures;i.e.,QI-QP-11.8-1,-5,-6,and-8. The list of
. appropriate procedures does not, however, indicate the applicable
% revision number of each procedure. In that the.numberw l ,. -
! nonrecreatable or inaccessible inspection attributes can very from revision to revision of a procedure (e.g., Revisions 0 and 1 of TUGC0 Procedure QI-QP-11.8-8), the absence of guidance on applicable i procedure revision numbers does not constitute detailed instructions. 2.. During the documentation review of Verification Package No. R-E-CDUT-064, in accordance with QI-009, Revision 0, there was no evidence that a documentation check was made of inaccessible I attributes for conduit C13016037 that were caased by the installation of separation barrier material (445/8514-D-02). C. QI-009, Revision 0, " Document Review of Conduit /R-E-CDiff," requires the 3 , ERC inspector to: (1) verify that inspection reports signed by electrical inspectors were dated after their date of certification and prior to their ~ date of expiration, and (2) document the $BM inspection report (IR) and/or latest construction operation traveler number at the bottom of the checklist. Contrary to the above: 1
- 1. Review of ERC accepted documentation for conduit C14R13047 showed that the ERC inspector failed to identify that the certification to the applicable Procedure QI-QP-11.3-23 had lapsed for the TUGC0 electrical inspector signing IR-E-46087.
l
- 2. The ERC completed inspection record checklist for conduit C13016037 in Verification Package No R-E-CDUT-064 did not contain documentation of the SBM IR or latest construction operation traveler .
number (445/8514-D-03). ) D. Section 4 of CPP-009, Revision 3, states, in part, with respect to ISAP No. VII.c, " Qualified QA/QC Review Team personnel perform field ; reinspection of specific hardware items and reviews of.ap documents in accordance with approved instructions . . t .gropriate 4 I Contrary to the above, the following examples were noted where field reinspection of hardware itees were not performed in accordance with approved instructions:
- 1. Attribute 4.5 in Section 5.0 of QI-055,' Revision 0, states with respect to spring nuts, " Verify that the serrated grooves align with the channel clamping ridge." Checklists for support No. 007D 1
s
,i 3
1 (Verification Package No. I-S-INSP-007) and support No. 028 (Verification Package No. I-S-INSP-028) were signed by two separate ! ERC inspectors that this attribute was acceptable. NRC inspections , showed, however, that the spring nut serrated grooves did not align with the channel clamping ridge on both of these supports.
'N 2. Section5.3.4.CinQI-027stateswithrespctto.disensinnal i
tolerances not shown on design drawings, Comp 6nent member length
+/-1/2 inch."
The bill of material on Rev.ision 2 of drawing No. CT-1-097-402-C52R in Verification Package e. I-S-LBSR-023 shows item No. 4 (2 pieces) to be 7 3/4 inches long. The applicable inspection checklist used during the ERC reinspection of this pipe support shows the installed configuration to be acceptable. NRC inspection determined, however, the actual length dimensions of the two pieces to be 6 5/8 inches and 6 1/2 inches, respectively, both of which are under the indicated
- . minimum dimension of 7 1/4 inches.
- 3. Section 5.0 in QI-012 states, in part, " Verify that the piping / tubing and components . . . material agree with the Bill of Materials shown on the Instrument Installation Detail drawing. Tubing is marked with longitudinal color coded marks for traceability. .Use applicable drawing to identify tubing . . . Verify that the installed tubing has the proper slope. The required slope for process wetted lines is one (1) inch per foot minimum. Thiis slope requirement may be reduced to 1/4 inch per foot when physical layout is a problem. Verify that there is a proper air gap. The minimum gap spacing shall always be 1/8 inch to allow each instrument sensing line to expand independently at all bends without striking adjacent sensing lines, other equipment, concrete or steel building members."
The applicable inspection checklist used during the ERC reinspection of instrumentation installation Verification Package No. 1-E-ININ-026 showed thet the above attributes were inspected and accepted, as evidenced by the inspector's signoff (initials). However, NRC inspection of the instrumentation installation revealed: (a) Six sections of tubing had no color coding for traceability; (b) Ten sections of tubings, in which physical layout was not a a problem, had slopes of 7/16 inch to less than 1/4 inch per foot I and one section had reverse slope; and (c) Two tubing sections had zero gap spacing between the high pressure and low pressure legs and the concrete pentration. I 1
.. a .
- 4. Section 1.7 in QI-012 requires that: (a) tubing bands be verified to have a minimum radius of four times the nominal tube size by using either a template, or by direct measurement and calculations; and (b) the measured and calculated values be entered into the Minimum Bend Radius Record, with date and inspector's initials.
(~ . _ . _ During NRC inspection of Verification Package No. 2-E-ININ-04, equipment tag No. 1-FT-156, it was noted that the inspection checklist was dated and initialed, attesting to the. fact that the 1 l tubing bends had been verified as having a minimum radius of four times the nominal tube site. However, review of the applicable Minimum Bend Radius Record showed that the ERC inspector had neither measured and calculated, nor used a template to verify minimum bend radius. In addition, the following notes had been entered by the ERC inspector: "Ist 90'. bend from instrument-(hi & lo side) . . . cannot be measured with existing tools. Four (4) other bends visually more than90'toaccommodateslope"(445/8514-D-04). Texas Utilities Electric Company is hereby required to submit to this office, within30daysofthedateofthisNoticeofDeviation,)awrittenstatementor u planation in reply, including for each deviation: (1 the reason for the I deviations if admitted, (2) the corrective steps which have been taken and the results achieved. (3) corrective steps which will be taken to avoid further deviation from comitments made to the Comission, and (4) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Dated at Arlington, Texas, this 6th day of March, 1986 l l 1 I l 1
. . _ _ - - - - . - - - - - - 1
I APPENDIX D CONSTRUCTION INSPECTION REPORT U. S. NUCLEAR REGULATORY ComISSION
'g REGION IV _
l NRC Inspection Report: 50-445/85-14 Permit: CPPR-126 ! 50-446/85-11 CPPR-127 Dockets: 50-445 Category: A2 l 50-446 1 Applicant: Texas Utilities Electric Company (TUEC) l Skyway Tower 400 North Olive Street j_ tock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (C?SES), Units 1 and 2 Inspection At: Glen Rose, Texas Inspection Conducted: October 1-31, 1985 Inspectors: / M kr
- h. S. Philliph, Seniof Resident Reactor 2 - 2 F - W.
Date Inspector (SRRI), Construction, Region IV CPSES Group (paragraphs 1,2,3,4,5,6,9,10) l I l t l kack.Ok D. L. Telley, SRRI,TUperattions, Region IV zlu/n, Date ' CPSES Group (paragraph 8)
$ WsLwm- - 2 /2 W F4 l 0. E. Norman, Reactor Inspector Date '
l Region IV CPSES Group (paragraph 7) I O 1 h .WD B(lp(f.vJ.J du? J / - I SV' -
Consultants: EG&G - J. H. McCleskey Parameter - T. H. Young Rev4 aged By: 8% "J4r/ dad. I. Barnes, Group Leader, Region IV CP5ES Group ' 12Te* Approved: 7 [ b<- T. F. Westerman, Chief, Region IV CP5ES Group
.3/p/f4 Date Inspection Summary Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14)
Areas Inspected: Routine, unannounced inspections of Unit I which included plant tours, applicant actions on construction deficiencies, applicant actions on previous NRC inspection findings, and storage and handling of QA records. The inspection involved 204 inspector-hours o6 site by two NRC inspectors and two consultants. Results: Within the four areas inspected, one violation (failure to establish written procedures for control and accountability of the shipment of original design records to Stone & Webster Engineering Corporation (SWEC), paragraph 5.b) was identified , Inspection Conducted: October 1-31, 1985 (Report 50-446/85-11)
- Areas Inspected
- Routine, announced and unannounced inspections of Unit 2 i
which included plant tours; applicant actions on construction deficiencies; applicant actions on previous inspection findings; storage.-protection, and , handling of QA records; audit of QA records; welding material control; and l electrical cable tray / equipment walkdown. The inspection involved 227 inspector-hours by three NRC inspectors and two consultants. Results: Withinthesevenareasinspected,threeviolations(arepeatfailure ' to document minimum wall pipe violations on a nonconformance report (NCR), paragraph 4.c; a repeat failure to control issue of design documents, paragraph 4.g; failure to establish written procedures for control and. accountability of shipment of design records to SWEC, paragraph 5.b) were identified.
... o I
DETAILS
- 1. Persons Contacted
% Applicant Personnel ,
. -y--
J. Merritt, Assistant Project General Manager P. Halstead, Manager, Quality Control (QC) , C. Welch, QC Supervisor R. Spangler, Corporate Quality Assurance (QA) Supervisor i J. Walker, Corporate QA Auditor J. Marshall, Licensing J. Hicks, Licensing , M. Strange, Supervising Engineer, Support & Project, TUGC0 Nuclear j Engineering (TNE)
- J. Ryan, Technical Service, Supervisor S. Ali, THE QA Staff Engineer B. Jones, Unit 2 Supervising Engineer, Civil / Structural R. Hooten, Project Discipline Engineer, Civil / Structural J. Hodgson, Computer Operator Supervisor, PMCS Contractor Personnel
- W. Baker, Welding Engineer, Brown & Root (B&R) l W. Wright, Welding Engineer, B&R !
G. Purdy, Site QA Manager, B&R J. Gore, Subcontract Supervisor, B&R K. Thornton, Warehouse Superintendent, B&R C. Osborne, QA Vault Supervisor, B&R , D. Leach, THE-QA-B&R l K. Norman, Central Operations Supervisor, DDC-8&R i i D. Bleeker, DCTG Supervisor, B&R ' R. C. Iotti, Project Manager Ebasco 1 A. Smithey, Supervisor IRV, B&R R. Walters, ASME QA Supervisor, B&R G. Maedgen, Welding Engineer, B&R T. Gray, Document Control Manager P. Patel, Unit 1 Civil Lead, THE Design, Gibbs & Hill B. Jones Expediting Supervisor, B&R L. Barnard, PMG File Clerk, B&R T. McCormack, Fire Protection Engineer, Impe11 S. Felman, Assistant Project Engineer, SWEC H. Moscow, Supervisor Projects & Services, NY, SWEC J. Tate, 304 DU Satellite Supervisor, B&R . J. Junge, 311 DU Satellite Supervisor, B&R J. Womack, 300/301 DU Satellite Supervisor, B&R
.- s 1
R. Flaherty, 307 DU Satellite Supervisor, B&R S. Hazle, 310 DU Satellite Supervisor, B&R J. Day, 308 DU Satellite Supervisor, B&R J. Dickey, DCC Area Supervisor, Engineer Satellites, S&R S. Bruce, DCC Area Supervisor, Craft Satellites, B&R 2.\ Plant Tours .. At various times during the inspection period, NRC inspectors conducted general tours of the reactor building, safeguards building, and the electrical and control building. During the tours, the NRC inspector observed ongoing construction work and discussed various subjects with personnel engaged in work activities. No violations or deviations were identified.
- 3. A,_ction on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant
- a. The applicant's procedures pertaining to Significant Deficiency Analysis Reports (SDARs) were reviewed to determine how the process of deficiency identification through completion and signoff is controlled. Reviews were performed of site Procedures CP-QP-15.6, Revision 3, "SDAR Status Tracking"; CP-QP-16.1, Revision 6, "Significant Construction Deficiencies"; CP-QP-17.0, Revision 1,
" Corrective Action"; and TUGC0 Procedures DQP-CQ-4, Revision 1
" Reporting of Significant Deficiencies"; DQP-QA-12, Revision 2,
" Administration and Tracking of Significant Deficiency Analysis Reports"; and DQP-QA-11, Revision 1, " Corrective Action."
Procedures CP-QP-15.6, CP-QP-16.1, DQP-CQ-4, and DQP-QA-12 do not address the SDAR file contents or provide a method for completion and signoff of the required corrective action. Procedures CP-QP-17.0 and DQP-QP-15.6 address the documentation required for closing deficiencies, but there is no cross reference between SDAR/ corrective action with respect to SDAR file contents. This is an unresolved item pending completion of NRC review of SDAR procedural adequacy (445/8514-U-02; 446/8511-U-D1). l
- b. The applicant classified the following reprtable SDAR files as
" Licensee Action Complete": SDARs CP-84-27, CP-84-29, CP-85-04 CP-85-05, CP-85-11, CP-85-12, CP-85-13, and CP-85-14. The above files did not document or reference the location of documentation which would support the reported status of corrective actions being complete. Consequently, the NRC inspector did not perform a field r verification for any of these files.
- c. The following nonreportable SDAR files were selected for review, !
since the applicant classified these as "Licen6ee Action Complete":
(1) (Closed): The NRC inspector reviewed the following SDARs: CP CP-84-05, CP-84-22, and CP-85-02, CP-85-08, CP-84-23, CP-84-24, CP-85-09. CP-84-26,s The applicant e-84-32, valuation and decision that these SDARs are not reportable appeared to be correct. (2) (0 pen): The NRC inspector reviewed SDARs CP C O S4-34, and CP-85-06. The files for these SDARs did not contain sufficient information or documentation to determine whether or not the SDAR was nonreportable. The status'of the files is an unresolved item pending the completion of a TUGC0 effort to make the files complete and subsequent NRC review (445/8514-U-03; 446/8511-0-02).
- 4. Applicant Action on Previous NRC Inspection Findinos
- a. (Closed) Unresolved Item (445/8422-U-02): Inverter transformer common failure. The NRC inspector reviewed the applicant's handling of the defective transformers and concluded that the actions taken to evaluate and correct the deficiency were correct and adequate.
The applicant's handling and reporting of significant deficiencies will continue to be monitored'by the NRC inspectors.
- b. (Closed) Violation (445/830?-V-01): Excessive welding gap. In 1983, the NRC inspector identified an unacceptable fitting on pipe support Mark No. SW-1-102-106-Y33K. Recently, the NRC inspector followed up and reviewed NCR H5123-5, RPS 751947 WDC80668, related sketches, and inspection reports (irs). Corrective work was accomplished and QC performed required inspections. An engineering analysis of the installation which was performed in response to the violation showed strength was far in excess of minimum design requirements, even though it violated the procedure. In B&R meno -IM 325,208 dated April 13, 1983, supervision reemphasized the requirement to follow procedures to all affected personnel.
- c. (Closed) Violation (445/8315-01): Failure to write an NCR on base metal repair. This violation concerned an instance where the NRC inspector observed a minimum wall violation for which a NCR had not been written. On October 8 and 9, 1985, another NRC inspector reviewed this violation of paragraph 3.3.3 of site Procedure QI-QAP-16.1-2, Revision 4, dated May 20, 1982. The scope of this procedure was changed to make further reference to system walkdown and the item in question was accomplished near this time frame.
However, the applicant responded by documenting the questioned minimum wall violation and the repair of the adjacent weld on a
o , [
. .: a '
l \ s 1 i comon NCR (M6611). Theseconditionshadbeenfound1hseperateNDE methods, one before and one after the base metal reptir. Thn NRC inspector reviewed two more recent base metal repairs to varify that the problems had been corrected. One repair performed in 1984 was-
. found to have been in compliance with the then current; procedures.- ,
%. The second repair was completed reviewed.. accepted._ %
documentation sent to the vault during September and , o er of 1985. This second report showed an original weld conipleted, revi~ewed and accepted in January and February 1985. Rework was performed on this weld in September 1985 due to interference with a hanger 1:ssta11ation which resulted in a minimum wall violation. Further work,to repair the hanger was classified as a ' Major Wald Repair" in accordance with paragraph 3.3 of B&R Procedure CP-CPM-6.9G; however, no NCR was generated. This failure to document a minimum wall violation on an NCR is a repeat violation of Criterion XV of Appendix 8 to 10 CFR Part 50(446/8511-V-01). '4 It was noted that the inspector and the prepare of the repair process sheet had- recently received training on the newly revised procedures involved which required the WCR % panerated. The. , Assistant Project Welding Engineer who reviewed the repair process ' sheet had not been so trained on the procedure, as he had been exempted from the training by virtue of his posittorq. A j
- d. (Closed)UnresolvedItem(446/8502-01): Responsible welding +
supervisors not familiar with welding rod control procedures. In 1985, the NRC inspector interviewed supervisors who were not familist with welding rod control procedures which their crew of welders were responsible for implementing. The training program fnr supervisors was conducted in May 1985 and covered helpers through general foremen. In 1984/85, the NRC Technical Review Team (TRT) extensively reviewed and inspected weld rod control and documented their findings in NUREG-0797, Supplemental Safety Evaluation Report ($$ER) 10. Category
- 9. In addition, the RIV inspector inspected weld rod c.ontrol during this inspection period and identified no violations er deviations.
- e. (Closed)UnresolvedItem(445/8323-07): Incomplete Class V(5) pipe supports record package. In 1983. the NRC reviewed packages whu h had been combined into finalized packages. In 1984, the TRT reviewed a random sample of 11 Class V(5) support record packages, This review showed that packages with irs (by qualified inspectors) were in proper order. The TRT found the records satisfactory as reported on page N-252 of NUREG-0797 3SSER 10 dated April 1985.
- f. (Closed)UnresolvedItem(445/8347-01): Containment surface area coating. This item addressed sloughing of protective coatings on
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i Westinghouse supplied items. In SSER 9, NRR staff state they have - reasonable assurance that debris generated by the failure of all coatings inside the containment building under design basis accident conditions will not unacceptably degrade the performance of post-accident fluid systems. This was based on TUGC0 and other studies referenced in NUREG-0797, SSER 9 on pages L-17 and L-18. NRR A requires in SSER 9 that a preoperational and postoper program be proposed by TUGC0, but this specifid issue,gipal o' sloughing of coatings coatings on Westinghouse itees is closed based on the SSER 9-conclusions.
- g. '(Closed) Violation (445/8416-V-02):' Failure to provide controlled issuance.of design documents and changes thereto. Between May and June 20, 1984, an NRC inspector found that design documents and changes were not controlled by Operations Document Control Center E(DCC). On October 11 and 14, 1985, the NRC inspector confirmed that-the computer system and terminals referred to in the TUGC0 November 1, 1984, response were in place.and'in use.
The NRC inspector reviewed 12 Design Change Authorizations (DCAs) and Component Modification Cards (CMCs) and followed the distribution of 25 packages to 9 locations for various disciplines and verified corrective action. These DCAs and'CMCs were traced in their routing at the central DCC and then on to the Paperflow Group or satellite DCCs and a review performed of how they are distributed from those locations. All items checked were distributed per DCP-3, Revision 18 (with Document Change Notices (DCNs) 1, 2, and 3), with the following exceptions:
; (1) CMC 96181,Rtvision1lwasissuedonOctober8,1985,and ;
satellite DCC 307 (craft) picked it up at central DCC. The CMC ' was not signed for as required by paragraph 3.1.1.1 of DCP-3, Revision 18, with DCNs 1, 2, and 3. There was a similar occurrence on CMC 75003, Revision 2, as issued to satellite DCC i 202/211 (TUGCO). Further, DCA 21446, Revision 1, was issued October 8,1985, and satellite DCC 307 was in possession of it on October 14, 1985. Ons of two packages for Drawing 2323-El-1702, Sht 002, Revision 2, had both Revision 0 and Revision 1 of DCA 21446 in it, with the other having only Revision 0 in it. Both Revision Os were not stamped " VOID" as l required in paragraph 3.2.2.5 of DCP-3. i On October 114,1985, satellite DCC 307 issued Drawing 2323-El-1702 Sht. 002, Revision 2, to an electrician for Class IE field work with Revision 0 of DCA 21446, rather than the current Revision 1, which is contrary to the requirements of paragraph 3.2.1.2 of DCP-3. On October 14, 1985, TUGC0 and B&R supervistor.( contacted the electrician who indicated he had N
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gotten sheet 002 rather than sheet 001 by mistake and had returned it immediately without installing anything to it. 1 s3 These failures to follow fissign document control procedures are t T~ a violation of Criterion V of Appendix B to 10.CFR Part 50 3
, (446/8511-V-02). , i s' i (2) The following examples were noted of practices tiiGTffTollowed ]
that were not covered in controlled procedures: .
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(a) The method used to issue drawing packages,from the- I i satellites to the field (e.g., crafts and QC) was not : addressed in DCP-3. The actual practice is that a DCC j personandtherecipientsignforreceiptofalltheproper 1 l documents (e.g., DCAs) and the proper revistsw pn the , computer printed "Open Design Change Log." s, 1 w :
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(b) Another practice of the DCC group is to log into thJ ) computer the status of the DCAs and CMCs. Thishstatu is < 4 classifed as open, void, or not included (NI) and ind cates ~ whether a change.is affecting all itans built to a drawing, a single item utilizing the drawing, or.no further use of
- the change. Drawing .2323-54910, sht. CSR-2A, Revision 12, had CMC 75003 issued.against it., This fAC had status NI on Revisions 0 and 01 because it affected e Mn le hanger utilizing the above drawing. Newever, Reds on 02 did not have NI input and it. sbwed'as open on the teminals. 'This would require it to be' included with the drawing package in error. This was corrected on the terminal.s This process.
, of statusing the computerized document Aformation is not described in DCP-3.
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DCC supervision stated and showed that the practices are I described in internal uncontrolled guidolines. This item is tidelines into a 9 unresolved pending incorporating the g;f controlledprocedure(446/8511-U43).'.
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- h. (Closed) Violation (84-08-01): Gaps on Unit 1 polar crane bracket'und '
seismic connections. In November 1984, a NRC inspector found that i thegapsbetweenthebracketandconnectorsexceededtht;dssibh tolerance. This item is addressed in NUREG-0797, SSER 6,"along with '
-1 related problems with polar cranes. Discussioncconclusions, ar.d actions to be taken are included in pages K-14, 15, 18 and 121-123 of -
Appendix K to SSER 8. Since these actions will ederess the specific concerns of item 84-08-01, this item is closed. 'i b
- 5. 0A Records System Review ,
a y y The NRC inspector reviewed the applicant's record keeping syhten after ascertaining that records were being shipped off site without proper i 1
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$ control and' inventory. $1n Appendix IA(N) and 1A(B) of Final Safety k
A: Analysis Report (FSAR) Volume 1. Section 1.0, the applicant commits to Regulatory Guide 1.#b (i.e. , Collection, Storage, and Maintenance of 1 Nuclear Power Plant > Quality Assurance Records) and to American National Standard, Institute (AKI) h45.2.9, lith Draft, Revision 0,' dated q , January 17, 1973. ~ On page 1A(B)-36 in the Discussion, the. applicant makes
- i. Sno exceptant, to this standard., A brief description of qa-Ws is - ;
t contained in FSAR Section 17.1M(hnendment 50 dated July 13,1984). The i
$ ,7u?^ description does not address the curmnt QA records facilities and
! y storage; i.e., temporary storage of records for the Paper Flow Group,
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Interim Record Vault (IRV), Perma %nt Plant Record Vault (PPRV), j s i) d' procurement recordcHstorage area (Wrehouse A) and the TUGC0 Records l ,E Center. . , w y, t (
, The applicant hadot revisef 75AR Section 17.1.17 to describe end reflect K ;iN the current QA recer( system. This>1s unresolved pending the applicant's actions on ths' item described in paragraph a below (445/8514-0-04; 1 l
Q- i 446/8511-0-04TJi
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- a. Review of'Coroch}te OA Manuals bnd Im>1ementino Construction Pr .
The NRC inspector raiewed the TUGC0 Corporate QA Program Manual,' I }. Revision 14, dated Ar.6 1 30. 1985, and Quality Assurance Plan, Revision 14, dated August 30, 1984, to detensine if ANSI N45.2.9 was referenced and if its requirements were translated into these 4 documsts. ' Only TU*,CO construction Procedure CP-QP-18.4, Revision 5, warToondtoreferenceANS1N4k2.9. Operations and TUGC0 Nuclear
", Engiering procedures were;not' included in the scope of this A' inspydtion. Procedure CP-09-18.4, Revision 5, does not address all t( atserss of ANSI N45.2.9 such as (1)' definitions; (2) all facility lou tions; (3) method for maintaining control of and accountability
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. , for records removed from the site storage facility to organizations located og or'off site; (4) temporary storage facilities (fire rated 1 ,
cabinets Wesus duplicates in remote, separated locations); and (5)
' '( specip) process records such as photographs, negatives, and l s eierodim. The permanent facilities are discussed with respect to l ' 'A'BI M5.2.9 requirements described in paragraph 5.6; however, the l -drair ' system and dry chemical / gas fire protection system is not 4
! discussed. The IRV system is a permanent records vault for Unit 2 s - records until such records can be transferred to the construction PPRV where Unit I records are tw stored. TUGC0 Procedure
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m 'CP-QP-18.6, Revision 3, discumrb records turnover' from B&R IRV to
- <.* TUGC0 PPRV but does not address the issues raised above. Also, these l
issues are not addressed ir.the B&R QA Manual, Section 17.0 dated October 31, 1984, or CP-QA yl8.1 , Revision 3 dated July 11, 1934.
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TUSCO management stated that all of their QA manuals are in revision to improve their written program. This item is unresolved pending thecompletionofthatreview(445/8514-U-05;446/8511-U-05).
. b. Storage and Transmittal of Design Records to SWEC, New York: On
% October 16, 1985, an NRC inspector was inspecting An._oRABritem previously identified as unresolved item 8226-U-07. As a result, the requalification package for pipe support CC-1-107-008-E23R was requested and the NRC inspector was informed that this design records package had been included in a total of 5702 (4654 for Unit 1,1048 l
for Unit 2) hanger packages that had been shipped to SWEC, New York, for a complete reevaluation. The NRC SRRI interviewed the TUGC0 engineering supervisor who answered questions about whether procedures controlled such shipment, l the number of records per package, and how the records were to be
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protected during shipment. He stated that a first transmittal was J l controlled by Procedure CP-EI-18.0-4, Revision 0, dated July 25,
- 1985, until Comanche Peak Project Engineering became a part of TNE on
( September 1, 1985, at which time the procedure was deleted. The SWEC l project manager ctated that Procedure CFPP-3 covers the receipt and i indexing of these packages; however, CPPP-11 that will control the ! distribution of these packages to SWEC offices at Cherry Hill, New l Jersey; Boston, Massachusetts; Denver, Colorado; Houston, Texas; and t Toronto, Canada, will not be completed until late October or early November 1985, according to SWEC Supervisor Project Services, New York. The utility has taken corrective action that includes (1) making duplicate copies prior to shipping, and (2) all records initially sent to SWEC are being copied and a copy returned to the site. Region IV is pursuing with IE Headquarters. QA Branch the minimum protection that should be affordec records in shipment. The , failure to have site procedures to maintain control and ! accountability of the shipment of records is a violation of Criterion V of Appendix B to 10 CFR Part 50(445/8514-Y-02;446/8511-V-03).
- c. Storace and Transmittal of Construction Records to Chicago Bridge and (
Iron (CBI): As a result of knowledge of an earlier shipment of CBI Tecords off site. the NRC inspector has asked the utility to provide records to demonstrate the CBI record controls that were implemented. It is CBI practice to ship all records off site for copying. This matterisconsideredunresolved(445/8514-U-06;446/8511-U-06). l The utility has indicated that the receipt of records from CBI was ' handled in the same manner as the receipt of records from any vendor. I Region IV will inspect the receipt of vendor records and this matter l is considered an open item (445/8514-0-01; 446/8511-0-01). t i L-_---------------- - >
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- d. Inspection of Storace' Facilities: The NRC inspectors visited all site storage facilities to determine if storage, preservation, and safe keeping of records are as required by Criterion XVII of Appendix 8 to 10 CFR.Part 50 and ANSI N45.2.9, Draft 11, Revision 0, paragraph 5, " Storage, Preservation and Safe Keeping." -The
. facilities inspected included TUGC0 Records Center, which is
% .. committed by the FSAR to ANSI N45.2.9-1974 and no.t thgrAft 11, ,
Revision 0 version; PPRV; IRV; Paper Flow Group'stbrage areas for Unit 2 mechanical and electrical; and the procurement records storage area. The facilities for the Paper Flow Group and procurement records are not identified or described in TUGC0 or S&R procedures; however, these facilities and the PPRV and IRV were evaluated with the following results: (1) TUGC0 Records Center - This vault is the final repository for: (a) Unit I records which describe completed construction, and (b) Unit 2 record packages for systans that have been completed and turned over to operations. This facility was completed about March 1983. The NRC inspector found that this vault had access control and records were stored in closed containers, open face shelves, or in binders on top of furniture. Radiographs and other special process records are protected by controlling temperature and humidity. The NRC inspectors noted that a water sprinkler system had been installed in this facility. This presents a concern because those plant records which are stored in folders or binders in open faced cabinets will be deluged with water and will likely deteriorate. An additional consideration is that records stored in a manila folder may be 1 washed out and possibly clog the drain in this facility, leading to flooding of the facility. This iten is considered unresolved l ' pending applicant review of the facility with respect to the ; above observations (445/8514-U-07; 446/8511-U-07). 1 (2) PPRV - This vault served as the sole permanent vault from approximately 1975 until March 1983. This permanent records facility has controlled access. It meets the design features for a permanent facility, as described in Section 17.1.17 of the ' FSAR; however, the NRC inspector had the following comments: (a) There is no fire suppression system inside this vault. Two hand-held extinguishers and a 2-inch fire hose are located outside the vault. One hand-held extinguisher is located (
[ i inside the vault. Fire detectors and alarms are inside to : alert the onsite fire department if a fire occurs. (b) If the 2-inch fire hose is used to extinguish a fire, the I vault may flood because there are no fire drains and the
, floor is nnt sloped. Therefore, water may potentially enter the bottom cabinet drawers. ....
l (c) NCRs and corrective action reports were stored in binders in bookcases. If fire hoses are used, these documents would probably be subjected to the force of water from the ; hose and damaged. Therefore, it would be desirable to store these records in closed containers. All other ; < records were stored in nonfire rated cabinets which is ) acceptable if located in a persanent facility that meets l ANSI N45.2.9 requirements. 4 The failure to install a fire suppression system, drains, and a I sloped floor appears to be a deviation from ANSI N45.2.9 ! requirements. However, this item is unresolved because this facility is described in FSAR Section 17.1.17. Region.IV is , i forwarding this issue to IE Headquarters, QA Branch for clarification (445/8514-U-08; 446/8511-0-08). (3) IRV - This area is not a separate building, but is actually part of the permanent vault that has been set aside as an interim storage area prior to placing records in the area designated for permanent records. This area has an access point that is separate from the permanent area and is controlled. The facility is the same as the permanent area, except a wall separates the two. They share the same forced air system. This facility generally meets the requirements of 10 CFR Part 50, Appendix B, and ANSI N45.2.9; however, the NRC inspector had the following comments: (a) Water had been leaking through the forced air system and beside a support girder. In a second location, approximately 2-3 gallons of wster had leaked in through the forced air ventilation duct and was caught by a container placed under the duct. This is considered an open item (445/8514-0-02; 446/8511-0-02). (b) The NRC inspector observed a coffee pot, sugar, and evidence of food on a table adjacent to the vault area. These were immediately removed from the vault by the utility. s
I (4) Paper Flow Groups - The NRC inspectors visited trailers where ' the electrical and mechanical Paper Flow Groups are located tc determine if QA records are stored there. .
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In SSER No.11, the TRT considered the documents in the paper
. . flow groups to be inprocess; however, SSER No. 11 also indicated
% that the records are maintained in fire proof sat &ets. The NRC inspectors found that there are some records'storec in nonfire-rated file cabinets. This matter is considered unresolved (445/8514-U-09; 446/8511-U-09).
(5) Storace of Procurement Records - In Warehouse A, procurement recorcs were stored both in nonfire-rated and fire-rated cabinets. The NRC inspector found no master index of these records and the facility is not described in the FSAR or procedures. There was no way to determine whether duplicates of these records exist and if they must be stored in fire-rated 1 l cabinets. This item is unresolved pending identification and i description of this facility aM indexing of records recently received from the TUGCO, Dallas, Texas, office to determine what records must be in fire-rated cabinets (445/8514-U-10)- 446/8511-U-10). I
- 6. Audit of OA Record Systems / Facilities i
The NRC inspector asked if the unacceptable QA records storage and control conditions identified above in paragraphs 5.a and 5.d had been identified ) by TUGC0 or B&R audits. TUGC0 audited (TCP-85-20 dated January 16,1985) l the PPRV but failed to identify any of the problems noted above. Two auditors audited this area from December 17 through December 20, 1984, and their report did not identify any storage facility problems. ANSI N45.2.9 t requires that periodic audits shall be performed to assure facilities are ' ! in good condition and temperature / humidity controls and protective devices are functioning properly. An Ebasco review or study dated June 16,1981, page 4 of 25, item g, states with respect to the PPRV, "It is an established fact that the QAR vault does not meet the requirements for a single storage facility and that duplicate files are not maintained in lieu of single storage." On October 23, 1985, the NRC inspector requested documentation which would i i show action taken in response to the Ebasco finding. - TUGC0's Project and QC organizations had no such documentation. This item is unresolved pending review of the response to this audit finding (445/8514-U-11; 446/8511-U-11). The NRC inspector asked PPRV personnel if B&R had audited the record keeping / facility system and was informed that it has been several years since B&R had performed such audits. This item is unresolved pending the review of B&R audits (445/8514-U-12; 446/8511-0-12).
1
- 7. Control of Weld Filler Material This inspection was performed to determine whether safety-related weld filler material purchase, storage, and distribution are in accordance with the applicant's work and QA procedures, and applicable ASME code requirements. Implementation of the following procedures was examined g uring the inspection:
d
. CP-QAP-8.1, Revision 9, dated October 15, 1984, " Receiving Inspection";
. CP-CPM-6.9B, Revision 2, dated September 21, 1984, " Weld Filler Material Control"; and
. CP-CPM 8.1, Revision 3, dated July 2,1985, " Receipt, Storage, and Issuance of Items." -
l - The following areas were examined:
- a. Procurement
- Four purchase order packages which consisted of the purchase order, procurement specification, and field requisitions were inspected to verify that orders were properly approved and included required technical, packaging, and documentation requirements as specified in site procedures pertaining to weld
! filler material purchases. l No violations or deviations were identified.
- b. Receivina Inspection: Receiving inspection records, for the filler material purchased to the procurement documents inspected, were examined to verify that all items required by Attachment 11 (Receiving Checklist) to CP-QAP-8.1 had been inspected. In each
! case, the checklist and a receiving inspection report had been l l completed and signed by a Level II QC inspector. In several l instances, NCRs had been completed and material returned to the l } vendor as required by procedures. Certified Material Test Reports ) (CMTRs) for each purchase were also reviewed to verify that required ' inspections and tests had been perfomed and that material had been purchased from a vender with a current ASME certification. It was also verified that heat codes and quantities of material shown on the Material Receiving Reports corresponded to what was shown on the CKTR. No violations or deviations were identifiad.
- c. Main Storage Areas: Two filler material storage areas located in Warehouse A were inspected for compliance with the above listed procedures. OneareawasdesignatedasaQuality(Q)areaandthe i
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. I other one was both a Q and Non-Q area. The Non-Q material was segregated as required from the Q material. Procedures in the storage areas appeared to be adequately implemented; however, the NRC i had the following observation:
Paragraph 3.2.1 of CP-CPM 6.98 requires that Q weld filler material (' original containers be marked upon receipt and during storage with the material classification, size, and heat / lot nush7in the Q ' area, labels on several containers of Sandvik welding products (weld ; rod) had fallen off and others were loose. The material was still identifiable, because of the storage bin marking and marking on the shipping carton; however, a loss of identification is possible when material is removed from the storage area. There were also several , unopened cartons of Sandvik material whose status could not be determined. Loose or missing labels were identified on the following material; Lot 101172-2, 1/8 inch, AWS/ASME SFA 5.4; and Lot 10149-1, 5/32 inch AWS/ASME SFA 5.4. This matter has been referred to B&R Welding Engineering for followup.
- d. Distribution Stations: Weld rods used in safety-related applications are distributed from three areas (Rodhouse 2, 3, and 4). Each distribution station was inspected to verify compliance with requirements of CP-CPM 6.9B in the following areas:
. Storage facility (Level B);
. Identification of material;
. Controlled access into storage areas;
. Control of stationary and portable rod ovens;
. Issuance, return, and accountability of material; and
. Completion and control of records. ;
Label problems were also noted in Rodhouse 4 during this inspection.
- 8. Cable Tray and Equipment Walkdown During this inspection period, the NRC inspector performed a walkdown inspection of selected electrical components and cables to determine the degree of protection of class IE items from surrounding construction activities. The general level of protection appears adequate with the exception of the B Safety Train Diesel engine control panel (2DG02A). The visqueen covering had come loose in several spots allowing concrete dust from above to filter into the panel and settle on some of the installed relays.
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I In the area of cables, it was noted that cable ends were neatly coiled and the ends taped, cable tags were in place and cable jacket repairs were clearly marked. At one point in the Safety Train 8 switchgear room, a cable exiting a tray and entering the switchgear (cable No. C23G 06070 above the HVAC chiller No. 14.) appeared to be bearing hard on the square section of the cable tray side ladder at its exit point. In other places s'*where cable exits tray, a piece of discarded cable jacketJenseed as a - buffer. The observed point had no such buffer. No violations or deviations were indentified.
- 9. Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, violations, or
! deviations. Twelve unresolved items disclosed during the inspection are discussed in paragraphs 3.a. 3.c, 4.g, 5, 5.a. 5.c, 5.d, and 6. l 10. Exit Interview l An exit interview was conducted November 1, 1985, with the applicant i ! representatives identified in paragraph 1 of Appendix E. During this interview, the NRC inspectors summarized the scope and' findings of the inspection. The applicant acknowledged the findings. l j 4
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