ML20237L814
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e g'" *% g UNITED STATES p' ~ , D b,. NUCLEAR REGULATORY COMMISSION
, REGION IV
[8 611 RYAN PLAZA DRIVE, SUITE 1000
%, ,,8 ARUNGTON,' TEXAS 76011 April C9, 1996 MEMORANDUM FOR: T. Westerman,' Chief Comanche Peak Group FROM: H. S. Phillips, Senior Resident Inspector l Comanche Peak l
SUBJECT:
INSPECTION OF GA RECORDS During an October 1985 inspecti on, the NRC inspectors became aware of several questionable practices concerning the control and storage of OA records. This was documented in NRC l
Report Nos. 85-14/11 and applicable portions of this report are
, enclosed.
' ' The first issue deals with Te::as Utilities Generating Company (TUGCO) responsibility for DA records generated onsite by Chicago Bridge and Iron (CB&I). The NRC inspector found that l CBLI had shipped all original OA records concerning Unit 2 steel l
Liner, mechanical penetrations, and other miscellaneous l
mechanical work activities offsite without retaining a copy of the
. original records. These records were shippec in paper boxes.
l TUGCO was unaware of any inventory of the OA records shipped. Therefore, any audit of records returned by CB&I will
, depend on the CB&I inventory. No CB&I inventory was available onsite becuase CB&I had left the site. These findings were presented to TUGCO management and they disclaimed any l
responsibility for these OA records because they thought they j belonged to CBLI until the work was completed, and until all OA i records were copied and transmitted to TUGCO at which time TUGCO became responsible f or them. l TUGCO management also '
stated that CB&I was no different than offsite vendors who
! copied and sent TUGCO records after completing the contracted work activity.
t Comment: It is an unusual situation when an applicant j
states that all site generated records are not under their control even if a site contractor is the custodian during construction. It is also an unusual case when all original CA records are shipped without retainiaq a copy. The applicant stated that the loss of such r ecords would be at their own risk: however, this is an impractical viewpoint.
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because man / of tne cteel containment liner trecordt ( wh 2 c.l .
is now embedded in concr ete) and records of other work activi ties cannot be reconstructed if lost. Also, o f 4 s: Le vendors are different from site contractors as they usuells retain and protect GA records in accordance with ANS1 N45.2.7 until the contract is completed at which time they i make a copy and send originals to the site. In this case i no copy was made. Since CB&I has similarly handled DA I records at other sites, it is recommended that the NRC !
review these policies to determine if they are inconsistent with NRC regul ati ons. If thesv. practi ces vi ol at e regul a t :t r.n z , '
on (IE) Inf ormat ion Notice mev be necessary.
The other i ssue concerns TUGCO's comm3tment to ANSI N45.J.9, Draft 11. Revision 0 and Regulatory Guide 1.88 in Append 1:.
1A(N) and 1A(B) of the FSAR. It appears that TUGCO j committed to these documents without exception; however, the i storace facility described in Section 17.0 of-the FSAR and the j i
site storage facility deviate from the commitments in that TUGCO I did not install the fire suppression system, floor drains. and slope the floor as described in ANSI N45.2.9. Details are in the j enclosure.
Comment: The appropri. ate tections of the FSAR should be revi ewed for consi stencv and to determine if TUGCO has met the subject commitments.
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It is recommended that these issues be forwarded to the Office I of Inspection and Enforcement (IE) QA Branch for their review.
I If you have further atie s t i on s , please contact me at (81 7) 897-2201.
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H. S. Phillips Senior Resident Inspector Comanche Peak
Enclosure:
NRC Report Nos. 35-14/11 Pages 8 - 12 l
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l gotten shee^ 002 rather than sheet 001 by mistake and had returneditimmediayelywithoutinstallinganythingtoit.
These failures to follow design document control procedures are a violation of Criterion V of Appendix 8 to 10.CFR Part 50 (43/8511-V-02).
(2) The following examples were noted of practices 4Mg rollowed' 4 that were not covered in controlled procedures:
(a) The method used to issue drawing packages from the satellites to the field (e.g., crafts and QC) was not addressed in DCP-3. The actual practice is that a DCC ,
person and the recipient sign for receipt of all the proper ;
documents (e.g., DCAs) and the proper revisions on the computer printed "Open Design Change Log."
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" (b) ' Another practice of the DCC group is to log into the computer the status of the DCAs and CMCs. This status is classifed as open, void, or not included (NI) and indicates whether'a change is affecting all it9ms built to a drawing, j a single item utilizing the drawing, or no further use of
, the change. Drawing 2323-5-0910, Sht. CSR-2A, Revision 12, J t
had CMC 75003 issued against it. This CMC had status NI on
- Revisions 0 and 01 because it affected a single hanger utilizing the above drawing. However, Revision 02 did not q i
have NI input and it showed as open on the terminals. This 1 would require it to be included with the drawing package in I error. This was corrected on the terminal. This process of statusing the computerized document information is not ,
, described in DCP-3.
DCC supervision stated and showed that the practices are ;
described in internal uncontrolled guidelines. This item is unresolved pending incorporator.; the guidelines into a controlled procedure (446/8511-0-03).
- h. (Closed) Violation (84-08-01): Gaps on Unit 1 polar crane bracket and seismic connections. In November 1984, a NRC inspector found that the gaps between the bracket and connectors exceeded the design tolerance. This item is addressed in NUREG-0797, SSER 8, along with related problems with polar cranes. Discussion, conclusions, and !
actions to be taken are included in pages K-14, 15, 18 and 121-123 of Appendix K to SSER 8. Since these actions will address the specific concerns of item 84-08-01, this item is closed. !
- 5. QA Records System Review The NRC inspector reviewed the applicant's record keeping system after ascertaining that records were being shipped off site without proper N
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4 control and inventory.- In Appendix IA(N) and 1A(B) of Final Safety Analysis Report (FSAR) Volume 1, Section 1.0, the applicant commits to Regulatory Guide 1.88 (i.e. , Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records) and to American National Standard, Institute (ANSI) N45.2.9, lith Draft, Revision 0, dated I s January 17, 1973. On page 1A(B)-36 in the Discussion, the applicant makes t
' no exceptions to this standard. A brief description of SAmrds is . I contained in FSAR Section 17.1.17 (Amendment 50 dated July 13,1984). The description does not address the current QA records facilities and storage; i.e., temporary storage of records for the Paper Flow Group, Interim Record Vault (IRV), Permanent Plant Record Vault (PPRV),
procurement records storage area (Warehouse A) and the TUGC0 Records Center.
The applicant has not revised FSAR Section 17.1.17 to describe and reflect the current QA record system. This is unresolved pending the applicant's actions on the item described in paragraph a below (445/8514-U-04; 446/8511-U-04). ~
- a. Review of Corporate QA Manuals and Implementing Construction Procedure:
The NRC inspector reviewed the TUGC0 Corporate QA Program Manual, Revision 14, dated April 30, 1985, and Quality Assurance Plan, -
-Revision 14, dated August 30, 1984, to determine if ANSI N45.2.9 was referenced and if its requirements were translated into these
- documents, only TUGC0 construction Procedure CP-QP-18.4, Revision 5, '
was found to reference ANSI N45.2.9. Operations and TUGC0 Nuclear Engineering procedures were not included in the scope of this
- inspection. Procedure CP-QP-18.4, Revision 5, does not address all aspects of ANSI N45.2.9 such as (1) definitions; (2) all facility locations; (3) method for maintaining control of and accountability for records removed from the site storage facility to organizations located on or off site; (4) temporary storage facilities (fire rated cabinets versus duplicates in remot'e, separated locations); and (5) special process records such as photographs, negatives, and microfilm. The permanent facilities are discussed with respect to ANSI N45.2.9 requirements described in paragraph 5.6; however, the drain system and dry chemical / gas fire protection system is not discussed. The IRV system is a permanent records vault for Unit 2 records until sgch records can be transferred to the construction PPRV where Unit I records are now stored. TUGC0 Procedure CP-QP-18.6, Revision 3, discusses records turnover from B&R IRV to TUGC0 PPRV but does not address the issues raised above. Also, these issues are not addressed in the B&R QA Manual, Section 17.0 dated October 31, 1984, or CP-QAP-18.1, Revision 3, dated July 11, 1984.
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TUGC0 management stated that all of their QA manuals are in ' revision to improve their written program. This item is unresolved pending the completion of that review (445/8514-U-05; 446/8511-U-05).
. b. Storage and Transmittal of Design Records to SWEC, New York: On A October 16, 1985, an NRC inspector was inspecting.an.opsor. item .
j previously identified as unresolved item 8226-U;07. %s a result, the i requalification package for pipe support CC-1-107-008-E23R was !
requested and the NRC inspector was informed that this design records package had been included in a total of 5702(4654 for Unit 1, 1048 for 'Jnit 2) hanger packages that had been shipped to SWEC, New York,
- for a complete reevaluation.
The NRC SRRI interviewed the TUGC0 engineering supervisor.who answered questions about whether procedures controlled such shipment, the number of records per package, and how the records were to be protected during shipment. He stated that a first transmittal was ,
controlled by Procedure CP-EI-18.0-4, Revision 0, dated July 25, 1985, until Comanche Peak Project Engineering became a part of THE on - {
September 1,1985, at which time the procedure was deleted. The SWEC
- project manager stated that Procedure CPPP-3 covers the receipt and indexing of these packages; however, CPPP-11 that will control the distribution of these packages to SWEC offices at Cherry Hill, New Jersey; Boston, Massachusetts; Denver, Colorado; Houston, Texas; and Toronto, Canada, will not be completed until late October or early j 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 . j minimum protection that should be afforded records in shipment. The failure to have site procedures to maintain control and accountability of the shipment of records is a violation of Criterion Y of Appendix B to 10 CFR Part 50(445/8514-V-02;446/8511-V-03). ,
- c. Storage and Transmittal of Construction Records to Chicago Bridge and Iron (CBI): As a result of knowledge of an earlier shipment of CBI records off site, the NRC inspector has asked the utility to provide records to demonstrate the CBI record controls that were implemented.
It is CBI practice to ship all records off site foricopying. This matter is considered unresolved (445/8514-U-06; 446/8511-U-06).
The utility has indicated that the receipt of records from CBI was handled in the same manner as the receipt of records from any vendor. ,
Region IV will inspect the receipt of vendor records and this matter i is considered an open item (445/8514-0-01; -
44'J/8511-0-01).
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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 B to 10 CFR Part 50 and ANSI N45.2.9, Draft 11, Revision 0, paragraph 5. " Storage, Preservation and Safe' Keeping." The facilities inspected included TUGC0 Records. Center, which is
% committed by the FSAR to ANSI N45.2.9-1974 and no.t thsJraft 11, Revision 0 version; PPRV; IRV; Paper Flow Group'st'orage 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 B&R procedures; however, these. facilities and the PPRV and IRV were evaluated with the following results:
(1) TUGC0 Records Center - This vault is the final . repository for:
(a) Unit I records which describe completed construction, and (b) Unit 2 record packages for systems that have been completed and turned over to operations. This facility was completed about March 1983. The NRC inspector found that this vault had access control and records were stored in closed containers, open face shelves, or in binders on top of furniture.
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 ar's stored in folders or binders in open faced cabinets'will be
,' deluged with water and will likely deteriorate. An additional i consideration is that records stored in a. manila folder may be washed out and possibly clog the drain in this facility, leading
' to flooding of the facility. This item is considered unresolved pending applicant review of the facility with respect to the above observations (445/8514-U-07; 446/8511-U-07).
(2) PPRV - This vault served as the sole permanent vault from approximately 1975 until March 1983. This permanent records l 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 L
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inside the vault: Fire detectors and alarms are inside to alert the onsite fire department if a fire occurs.
I (b) If the 2-inch fire hose is used to extinguish a fire, the j vault may flood because there are no fire drains and the floor is not sloped. Therefore, water may potentially j
w enter the bottom cabinet drawers. ,_
(c) NCRs and corrective action reports were stored in binders 1 in bookcases. If fire hoses are used, these documents '
would probably be' subjected to the force of water from the hose and damaged. Therefore, it would be desirable to store these records in closed containers. All other records were stored in nonfire rated cabinets which is acceptable if located in a permanent facility that meets ANSI N45.2.9 requirements.- i 1
The failure to install a fire. suppression system, drains, and a sloped. floor appears to be a deviation from ANSI N45.2.9 J 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 clarifiertion (445/8514-U-08; 446/8511-U-08).'
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(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 {
j 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 follpwing comments:
(a) Water had been leaking through the forced air system and beside a support girder. In a second location, approximately 2-3 gallons of water had leaked in through i the forced air ventila* ion duct and was caught by a i 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. ,
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(4) Psper Flow Groups - T'he NRC inspectors visited trailers where the electrical and mechanical Paper Flow Groups are located to determine if QA records are stored there.
In SSER No. 11, the TRT considered the documents in the paper
.. flow groups to be inprocess; however, SSER No. 11 also indicated N that the records are maintained in fire proof . cat @ets. The NRC <
inspectors found that there are some records' stored in nonfire-rated file cabinets. This matter is considered unresolved (445/8514-U-09; .-
446/8511-0-09).
(5) Storace of Procurement Records - In Warehouse A, procurement records were stored both in nonfire-rated and fire-rated cabinets. The NRC inspector found no master index of these 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 -
cabinets. This item is unresolved pending identification and description of this facility and 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). F-
- 6. Audit of OA Record Systems / Facilities !
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) the PPRV but failed to identify any of the problems noted above. Two auditors audited this area from December 17 through December 20, 1984, and their report did not identify any storage facility problems. ANSI N45.2.9 requires that periodic audits shall be performed to assure facilities are
' In good condition and temperature / humidity controls and protective devices are functioning properly.
An Ebasco review or study dated June 16, 1981, page 4 of.25, iten 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 l show action taken in response to the Ebasco finding. TUGCO's Project and QC organizations had no such documentation. This item is unresolved pending review of the response to this audit finding (445/85:.4-U-11; 4&fil.8511-U-11). The NRC inspector asked PPRV personnel if BhR 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-U-12). N
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