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,p' %, UNITED STATES 8' '
NUC' TR REGULATORY COMMISSION , O
- REGION IV l $11 RYAN PLAZA DRIVE, SulTE 1000 n 4 ,, ,8 '
- ARLINGTON, TEXAS 76011 APR 67 !AG i .
l NEMORANDUM FOR: H. S. Phillips, Senior Resident Inspector FROM: T. F. Westerman, Chief, Reactor Safety Branch
SUBJECT:
DRAFT REPORTS In response to your memorandum of March 13, 1986, subject cs above, I have reviewed Regional Office Policy Guide (OPG) 0206, Rev. O with regard to maintaining draft reports. Paragraph C.1 of OPG 0206 states that ". . . the employee shall clearly note on the draft the reason for retaining it." Since you have already forwarded the drafts without notations, you are requested to provide within 10 working days, a memorandum identifying any substantive differences, for the record, to go with the draft reports.
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- 7. W T. F. Westerman, Chief !
Reactor Safety Branch l l i 1 i 8708210054 870819 PDR O ADOCK 05000445 PDR .
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U. 5. NUCLEAR REGULATOPY COMMISSION I l l J REGION IV ] i l 1 l 4 NRC Ins.pecti on f;eport : 5/-445/65-14 Permit: CPPR-126 1 l l 50-44 e, / 85- 11 CPPR-127 is Docket: 50-445; 50-44o f.4p p 1 2 c e n t ! Temes Uti12tien Elect-ic Comoany (TUEC) l SI:ywev Tower 400 North Olive Street i Dallas, Te::ss 75201 1 I Focility Nan,e: Comsnche Peat Steem Electric Station (CPSES) Units 1 and 2
Insporticre At: Gl en Fose. T e ; s. s. Inspection Conducted: October 1. 1985. through Octobe'r 31, 1965 I .
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. i C-FFT ES-14: 55-11
- 1. PE RE.ONS COtJTi,CTED MGCO FERSONNEl, J. Merritt. Assistant Project, General Manager P. Hal st ead . Manager Quality Control (DC)
C. Welch, DC Supervi sor R. Spang1cr, Corporate Duality Assurance Service J. Waller, Corporate OA Auditor 7, J. Marshall, Licensing J. Hicks. Licensing M. Strange, Supervising Engineer. Support & Project, TNE J. Rven, Technical Service, Super vi sor S. All. TNE DA StaH Engineer 1 B. Jones, Unit 2 Supervising Engineer, Ci vi l /Struc tural R. Hooten, Project Disc 2pline Engineer, Civil / Structural J. Hodgson, Computer Operator Supervisor, PMCS 1
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- 2. PEPEOf!? COU7 ACTED CONTPACTOR PEP 50tJNEL W. Bal:er , Welding Engineer, Brown & Root ( Bl<R )
W. Wright, Welding Engineer, B?eR G. Purdy, BLR J. Gore, Subcontract Supervisor, BLR l '. . Thornton, Warehouse Superintendent, BS<R C. Osborne, P. Patel, Unit 1 C2vil Lead. TNE Design 's D. Leach, TNE-DA-Bt.R L. Norman, Centeal Operations Supervisor, DDC-BtcR D. Bleeker, DCTG Supervi sor, BLR R. C. Iotts, Project Manager, Ebasco A. Smithey. Suoervaser IRV. Bt R R. Walters, ASME DA Super vi sor , BLR G. Macdgen, Welding Engineer, B8:R T. Gray, Document Control Manager P. Patel, Unit 1 Civil Lesd, TNE Design, GLH B. Jones. Unit 2 Supervising Engineer. Civil /Struct.. TUGCO R. Hooten, Project Discipline Engineer, Ci vil /Struct. , TUGCD B. Jones. Expediting Supervisor BtR L ., Barnard, PMG File Cl er6 B&R T. Mc Cormac 6: . Fire Protection Engineer, Impell S. Felman, Assistant Proje:t Engineer. S.W.E.C. H. Moscow, Supervisor Projects t Services. NY, S.W.C.C.
i 5 J. Tete. 304 DU 5+te112 te Super v2 s or. B8.R J. J .:ng e. 11 DL1 Setell2tc Superv2ser, Et h J. Wort.: el . 700/501 DU Satell2te Superv2ser. Eb.f< R. Flehcrtv. 307 DU Satellite Supervisor. DL.R
- 5. Har l e. 710 DU Satellite Supervisor. Bt R J. Dev. 200 DU Satellite Supervisor. ht.R J. Dickey. DCC Area Supervi sor, Engineer Satellites, B8 R
- 5. Bruce, DCC Aree Supervisor, Craft Sate 112tes, Bb.R l
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4 s C. At verlove times during the inspection pcried NRC inspectors conducted oenerel tourt of the reactor building. 'v:2 k"41Hir-1 4, d T LL ' saf eguar os building.j clectracci and control buil ding, ed Me t 2 "- M '- - . . A . cj . During the tours, the NRC inspector observed 4 n ; -i .-1 _ - - _m + 4 c. _ 7 .- - _1
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a sut.iects with personnel engeged in work activities. I
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No violations or deviations were identified. 0.. Action on Applicents identified Deficiencies + l
- a. The Applicantu procedures certeining to Signi ficant Deficienc y Analvsis Reports (SDAR) were rev1ewed to determine how the process of deficiency identification throdgh_ completion sign-off are controlled. Site procedures CP-OP-15.6 (Rev. ;) >
SDAR STATUD TRACKING. CP-OPG-16.1 (Rev. 6) SIGNIFICANT CONSTRUCTION DEFICIENCIES, C P-DF'- 17. 6 (Rev. 1) CORRECTIVE ) i ACTION. and TUGCO procedures DOP-CO-4 (Rev. 1) REPORTING OF SIGNIFICANT DEFICIENCIES, DOP-DA-12 (Rev. 2) . ADt11NISTRATION AND TRACKING OF SIGNIFICANT DEFICIEfJCY AIJALYSIS REPORTS i (SDARs), and DOP-CA-11 (Rev. 1) CORRECTIVE ACTION were j reviewed. Procedures CP-OP-25.o. CP-OP-16.1, DOP-CO-4, AND A meikes f4 CDP-CA-12 do not address the SDAR file coptents or gaddressO T+"rh d completion and sign-off for the i de rt :11EM corrective acti on. Procedures CP-OP-17.0 and DOP-OP-15.m address the documentation required for closing deficiencies. but do not
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(g ,,g cp.y -2h U- M-2% O ~ts"-R d W~ W, O ~K- il, U- Es*- t u , cf es"-t 5, m A. C)- ES~-l% i 0. er The Applicant classified th following reportable SDAR files
" Licensee Acet ion Cornplet e"*, All files listed here did not cocument that the corrective or reference actions where the haddocumentation been completed. was that verified the NRC inspector Tales.
did not perforni a Fielo Verification for anv of these hh 5 l I l l l E__ _mm__=. ,.__.m . . _ _ . _ . _ . ._ . _ _ . _ _ _ . _ . _ _ _ . _ _ . _ _ _ _ _ _
I i, 6 7 l l y l I l reference the SDAF: file contents. The applicants procedure; I de not spec 14 v the documentation necessar- to complete en SL,W l l file. 1 y Yt NY ) L S u i b. The followino T jeYORTAL S SDAR,were selected for review =tc.._ /_ hiiY t / da ss {*
- d W 4 L 'mt; '; cd W the Appli cantp as " Licensee action complete".
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(1) (Or "N) SDAR CP-54-27. The design ia11ure modenfor "somo
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Venti sti on E::haust Dampersjn Unit 1 & Unit 2 b ,Ound b , s.c., T r l LR W yj o.v W .e Ah l FICW S [f airborne contamination was present. I could be diverted from normal e::haust f l ow s, 4 to roarrs in w~ich cperator action was required. The NFst inspector revie d end evaluated the documentation maintained by the plicant in the si te SDAR file, The file documented the p oblem. corrective action to be t a l: e n . results of heet 1 ad anal ysi s, hydrogen ditfusion anal ysi s. Package Process rms 131, 132, 133, 24 134, engineering recommendations t operations, analys2s and wall. through checi. for ignition aurces. identification of speci f i c sti on revi si on. and FSAR evi si on. The fi1e p ~\ l' : 0 1:a $ l' !
- e .' C .I w.1 s J e . Cih 1 did not document or ref erente 4tha t .Ge correcti ve ett 2 ons f
had een completed and that the worf: had men inspected e-0 : ! . ., 4.< L. w+ h a verification sign-off. The file also did not reference whether or not the operations group h d acted (j f< C v.A u.r~1 ' , h v. . on the engineering recommendations. )Eield verifi 11 or. was not perf ormed f or this item. i l l
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i l l 1 l 6 8 (' - (Or an g r.fd~' C F - E 4 - C 9. A potential fire could greclude 5 S 7 u control room h,6batab111ty gnd cpntrolpfp,.lantfunctic,rt ]:
> - ,. = . y j Unit 1 fnd Unit O nacentary for sefe shutdow . The NRC nsnoctor r evi ewed the documentation maintained b. 1 the ap licant in the site SDAR file. The file documented the probl m, corrective action to be taken, evaluation of I
1 essential C HVAC components analysis, identification of 1 1 essentiel func 'ons, and proposed {echnical Specifications to satisfy Append 1; R concerns. The file i did not document or reference that the corrective actions j l had been cpmpleted an that the work had been inspected A- /' l
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w+4h a verification si gn -of f . The file also did not reference whether or not t t :- operations group had acted ( t)LL &is,N f * . fev n x l on the engineering recommenda lonc.f Eield verification # l 1 1 ar .~u -per f orms d f or .4.h1 s--t-tem (~) (OPEN) EDAR CP-85-04 The Containme
- Spray Header I sol et ion Val ves , i n Uni t 1 god Unit 2 _ere gesigned to
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open i n less ths.n 20 , seconds. If the va es open i ti less l
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than 11 seconds, it will trip the CS pumps overspeed. The NRC Inspector reviewed the documentation n 'intai ne d by the applicant in the site SDAR file. l he + 11 documented the problem, corrective action to be ta'en, and the release for construction (PPF 140). The fil- did not document or reference that the corrective actions c been completed and that the work had boc-n inspected w$th
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- f j, L' . 6 t* e'.* **C' e' verification s 2 gn-of f . , Fi el d veri f i c at i on was -not p riorm2d for this item.
q;wl hwr i:,$ h (4) (OPEl SDAR CP-E5-05, the 4.re Engine Control Panel Air Filter owls in Unit i t< Uni t 2 ps 1.n st al l ed 5 .- : (polycarb nate) goul d f.ai l . The The NRC inspector i!: reviewed th documentation maintained by the applicant in the site SDA, file. The file documented the problem, and l the corrective etion to be taken. Th'e file did not document or refer 2nce that the corrective actions had j been completed and hat the work had been inspected with 1 y, l' :. cb ) & ! F * ~ i~ . - A. i a veri fication sign-o f . Fi el d veri fication was -not I l i performed for this item i I i (5) (OPEN) EDAR CP-85-11, Incor .ctly installed Instrument. I Fitting Locations in Unit I c Id cause failure of the l i n s.tr umen t during a seismic even . -The NRC inspector
- l reviewed the documentation maintai ed by the applicant in.
l l the site SDAR file. The file docume ted the problem, and i the corrective action to be taken. Th . file did not document or ref erence that the corrective actions had been completed and that the work had been i spected with. a verification sign-off. Field verification as not performed for this item. (6) (OPEN) SDAR CP-85-12, The Au::iliary Feedwater PressL *e Control Setpoznt for Unit 1 t< was incorrectly calculat i
i 10 l end did not properly reflect the pump curve. The NRC i 2 'roector r e .'l e we d the documentation maintained by thc. app 2 cant in the site SDAR file. The file documented the prob 1'm. and the correcti ve action to be taken. The file di d not document or reference that the corrective actiont had been empleted and that the work had been inspected with a veri ication sign-off. Field verification was not performed for this item. (7) (OFEN) SDAR CP-85 0, An-Undetectable Failure of the P-4 in Fermissive Safet Features Actuation System of Unit 1
- O Unit 2 could exist tring operation of the Peactor.
i l The NRC inspector revie 'd the documentation maintained by the applicant in the si e SDAR file. The file i documented the problem, the croctive action to be taken, and identified the affe ed test procedures and I l the changes to those procedures. The file did not d oc un.ent or reference that the corr -tive actions had l been completed and that the work had b en inspected with a verification sign-off. Field verifica ion was not performed for this item. (8) (OPEN) SLAR CP-85-14, Unauthori:ed Support Repai s l concerning welding on one pipe support and two cab = t r e r-supports were observed in Unit 2. The NRC inspector reviewed the documentation maintained by the applicant n the nite SDAR file. The file documented the problem, the
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i 11 l orrective ection to be taken. Identification of the non-c ormance reports, and inter views with applicable parties. The ile did not document or reference that the j f corrective actions been completed and"that the work I l had been inspected with a- ification sign-off. Field verification was not' performed for 's item.
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- c. The f el l owi ng NDu-Ref bhTiAE -Ei y 4 I + car.t Dcficienc5 ^ m e lgi s,
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R+por-ts--{3DAR r were sel ec ted for review eftm L u , , ,9 a L Li+ied f' c { c s s ' ,' - l C 5 :. , trs-- t h e Ap p l i 3c a n t as " Licensee action complete". l (1) (CLOSED) The NRC inspector reviewed the f ollowing SDAR's:-- - CP-84-05, CP-84-20, CP-84-23, CP-84-24, CP-84-26, y ,, ,, ', .
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CP-84 ~2, CP-85-02. CP-85-08, and CP-85-09. ,. The'se SDAR's are not reportable.s c b f 's m . (2) (OPEN) The NRC inspector reviewee the following SDAR's; CP-S4-30, CP-84-34, and CP-85-06. The files for these ' SDAR'S did not contain sufficient information or , documentation to determine whether- or not the SDAR was non-reportable. T h.a. b c.t . h D O / .- 04 < . t. s . -i s e. . . ' I a. I y ..,. I s. . ' '
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- 4. t sction 2ous (CLOSED) Unresol ved Item 445/8422-02: Inverter Transformer Common Fai l ure
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f l 12 l l The applicant es reviewed the events f ollowing the Inverter l Transformer failur t and determined that the event was not reportable under l OCRr(0. 55 ( e ) until the vendor failure report was l issued. The General Elec -ic report on the ferroresonant transformers identified a com n mode failure. When the report wat j received by the applicant, the de 'ciency was reported to the NRC \ l under 10CFR50.55(e). ' l 1
/ Th~ third tem 445/84*.-01 was losed in r_ port 445'8503, 4 , #.
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~4si (CLOSED) Un r esol v.ed Item (445/8226-U-07) Stress Analysis of l
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{ Fipe Support CC-1-107-OOB-ECOR: Last month a new analysis was requested by was unavailable. Sub sequen tl y , the NRC Inspector received a copy of the hanger' analysis by TUGCO for the sub.iect hanger ofter it had been remounted from a platform to tube steel. This analysis allows this specif2e item to be closed. Stone & Webster will generically reviewed reanaly e piping / hangers and the NRC will inspect this review at a later date.
- (b ) .- (CLOSED) Violation (445/0307-V-01) Excessive Welding Gap:
In 1980 NRC inspector identified an unacceptable fitting on + pipe support Mari: No. SW-1-102-106-YOOK. Recently the NRC inspector f ollowed up and reviewed NCR M5123-5. RPS 751947.
1 10 ( ! l WDC80668. related si etches and inspection reports. Correct 3ve I wor 6: was accomplished, OC perf ormed required inspections. An i engineering anal ysi s of the int tg.11ation originally cited M showed strength was far i r. excess of minimum design -l I requirements even though it violpted the procedure. I t' '* a gep .t.i3.c/"iktto al yaffected personnel,p l
* - " a-ie by. supervision 6.aa e l-e +-[/ h 0 Ib E' '
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April i 10, 198 e ( .. (c) (OPEN) Violation (445/8015-01) Failure to write a 6 5 E E E non-conformance geport(gcg.1 on Base Metal Repai r F In 1C/3 this violation concerned an ir, stance where the NRC I inspector observed minimum wall violation but no ,. I A/cg> 19/'S n ---n,4-r m -n l r e o m el- was written. On October- 8 and p W 4-J4 r-1 NRC inspector reviewed the violation of site procedure OI-DAP-16.1-2 (Rev. 4) dated May 20, 1982, paragraph 0.1'.1. O F L 4' The procedure scope had been changed to make further reference
/t to system walkdown, and the item in question was .me.t accomp1ished near this time frame. However, the applicant
( responded by documenting the questioned minimum wall violation and the repair of the adjacent weld on a common NR M 6611). These conditions had been found by separate NDE methods)one before and one after the base metal repair.
l
)
i 14 G.. The NRL inspector inspected t wo more recent base metal rep 62rt. to .erify thet the problems had been corrected.- One repe1r l performed in 1984 was found to have been in. compliance with 1 pp A W J The seconogwas completed. i the than current procedures. revi ewed, accepted, and sent to the vault in September and October of-1905. This second report showed an original weld completed, reviewed. and accepted in January and February, 1985. The weld was subsequently subjected to cosmetic work in a _, September 1985! h to interference with hanger i n st al l. at i oM. This cosmetic wori: resulted in a minimum well vi ol ati on. j Further wort. to repair was classified as a " Major Weld Repeir" I ac e s .s .< ..a c e' w .' h. 6 ~ C. f .-:L.' d t s'- C r *L PM C.9 G. p eng q l 3.3 in g , however. no NCR was generated. This . i f ailure to document a minim.tm wall violation on a . j non-conformance report.is a violation of 10 CFR Part 50 Appendix B Criterinn XV (44c/05[11-ob L-
).
It is to be noted that the inspector and preparer of the . Repair Procesc Sheet had recently received training on the newly revised procedures involved which required the NRC be generated. It zu.to be noted also that the Assistant Project l Welding Engineer who reviewed the Repair Process Sheet had not been so trained on the procedure as he had been exempt by his position. Thi s parallel s the f act that there was no documentation of training f or the writer of the NRC in 1 response to the original violation on the then recently revised procedure.that was yiolated.
i 15 , I i, j ( OF'EN ) Unresol ved Item 446/B502-01, Responsibl e Welding Supervisors j i Not Familier with Welding Pod Control Procedures and l Subsequent Training: In 1985 the NRC inspector i nt er vi ewed supervisors who were not familiar with welding rod control procedures which their crew of welders were responsible for implementing. No violation occurred in this instance, however, f oll owup on vi olation 5015-01 describcd in the previous paragraph identified an 1 l i nst ance where vi ol ati or, ma*.. have been prevented if training I
'r l had not been waiv7d and the supervisor was e::empt from such
' raining.
l l This item remains open pending a more in depth review of t training for supervisors. (CLOCED) Unresolved Item (445/8323-07), Incomplete Class V(5) Pipe Supports Record Package: i In 1983 the NRC reviewed packages into finali:ed packages. In 1984 the TRT reviewed a random sample of 11 Class V(5) support record packages. This review showed the packages with . inspection reports (by qualified inspectors) were in proper order. The TRT found the records satisfacto,ry. This was , reported on page N-252 of SSER 10 dated April, 1955.
. . - . . - . . . ~ - - . . - - - - . . . - . . . . . . . . . - . . . . . . ~ . . . . - - - - - . - . . . . . - . . - - - - - _ . -
1 l 16 l l (CLOSCD/ Unrert1ved Item (445/G347-01'> Containment Surface 1 Area Coot: r.g: Tht: item addressed sloughing of protective coatings on Westinghouse supplied items. In SSER 9 NRR staff states they have reasonable assurance thst debris generated by the failure of all coatings inside the Containment Building under design basi s accident conditions will not unacceptably degrade the performance of post-accident fluid systems. This was based on ) I TUEC and other studies referenced in SSER on pages L-17 and L-18. NFR requires a pre-operational and post operational 1 s contings program be proposed by TUEC in SSER 9. but this specific issue of sloughing of coatings on Westinghouse items ) is closed based on the SSER 9 conclusions. (CLOSED) Viclation (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 document, and changes were not controlled by Operations [DCL) Document Control Centej On October 11 and 14, 1985 the NRC inspector confirmed that the computer system and terminal s W44-ref erred to in the TUGCO November 1, 1984 response gAe-in place and in use. _ _ _ _ . , ., < _ . . , . , _ , .~., _ , _ . . _ . . . . . _ . . _ - - . . - . _ -.m_ . _ z __
I 17 1 The- tJRC inspect or r evi ewe d twelve (12> DC A's and CMC's and l
'1 twrnty-five (25> of their distributions to nine (9) locatiora 1
for various d i s ci p l i n e!1 to verify corrective action. These l DCA's and CMC's were traced in their routing at the centra) DCC and then on to the satellite DCC's and how they are ; distributed from thetrt. All items checked were distributed per DCP-3 (Rev 18) with DCN 1, 2, and 3 with the following exceptions. (, M6d.*hC ab bb yCMC)9c32C1 (Rev. 1) had been issued on October 8, 1985 and satellite DCC 307 (craft) had picked it up at central DCC,
's however. they f ailed to sign f or it. Sign-off'is required by paragrsph 3.1.1.1 of DCP-3 ( R n' . let with DCN"s 1. 2, and 3. !
1 DCC supervision stated that this was not uncommon and they he.d sent memos to the sete11ites when this occurred so that the s o n. f. . . - item would be signed for- as required. There was a p+r-allel occurrence on CMC 75000 (Rev. 2) as issued to DCC sate 111tc j L i..,a 1., s . . .: , :, ? . . . . J: p, , 202/211 (TUGCO). This r is a violation of criterion V of NCFR e - Appendar B (" i-E " A 446/85 - OJs) . [Further, DCA 21446 4r (Rev. 1) was issued October 8. 1985 and DCC satellite 307 was in possess, ion of it on October 14, 1905. It was, in one of two packages for drawing 2003-C1-1702 Sht 2 (Rev. 21. One of-these two. packages had both Rev. OandRev.jof DCA 21446 in at Y E and the other had cn1y Rc.. O in it. s..t. m Both go's were not ] stamped " Void" as required i n paragreph 3. 2. 2. 5 of 'DCP-3.
. - . . . . . . . . . . _ . . y . ,, . .- ,.._.m... .
____ __ _ _ --__ q l i l 18 I The DCC s.uper vi si on stated the practice was to check the packagrd e when thev were requested for +1 eld use (e.g. craft or' ) t inspector request in order to instell or inspect an item.$, and l n,ot necessarily as they were assembled. The two particular Rev. O's were discarded. Additionally DCP-3 states in part in paragraph C.2.1.2 " Design change documentation and CHN's shal) j be distributed to and maintained at the same location as the affected documents ... . GkvD" g)f73 pe &A W .# AW Contrerv to the above 3 DCC satellite 307 issued 9 #4ad 'r^ j Dwg 2323-El-1702 Eht 002 Rev. N 'C?::: !C) to an electrician h< Cfm af field W' f N n with Rev. O of DCA 21446 rather than the current Rev.
~
- 1. l On Odow dIWiTUGCOQ Sr e supervision l's n bM.
%the electrician ce!!ed i Tthi g c : rg e r-r-"- 't_ . c.o v du ., a J., ,c..;. b, th: "": C . . , g ; ; t _ .
The electrician indicated he had gotten sheet 002 rather than sheet 001 by mistake and returned it immediately without 1 installing anvthing to it. However, the responses of the i electrician and his foreman:'-fi::'_pptM d i 4 e w-d that sigri-of f on the Open Design Changa: Log for proper revi sion of design change documents needds clarification. These f ailures to f ollow the procedure constitute a violation 4LlG{9'Cil~ O({
<rr: t5 ff -
).
Further it was noted that some practices were being followed Nt b that were p c in DCF-O nor another controlled procedure. DCC z - _- rr :r r_:r-r- - - ~ - " ~ - - ~ ' " ~ ~ ~ - " " "
i 14 hncv'Y superv)zien st e t o s- that the practices are in i nternal her*.bk guidelinen. The method used to issue drawing pact: ages f rom the satellites to the field (e.g. crafts and D.C.) was not addressed in . DCP-0. A DCC person and the recipient sign for receipt of all b.'s> lab sed ? the proper documents ++ the *Eproper revision on the computer, printed "OPEN DESIGN CHANGE LOG". Another practice of the DCC group is to log into the computer ra the status of the DCA's and CMC's. This. status is open, void (VNI), or not included (NI) and indicates whether a change is affecting al) .itemc built to a drawing, a single item utilizing the drawing or no further use of the change. Drawi ng O! 0-5-0910 Sht CER-2A Rev. 12 had CMC 75003 issued against it. This CMC had status NI on REV. O and 01 because it affected a single hanger utili:ing the above drawing. i However. Rev. 2 did not have NI input and it showed as'open on ! the terminals. w, ll, & ,le c s * ** $ j' 'Jf:/ This would require it to be included in error. ]
/1 !
This was corrected on the terminal. This whole process of statusing is not described in DCP-3. Failure to describe activities affecting quality in a controlled procedure is contrary to 10 CFR50 Appendix B ' Criteria VI. This is a violation ( B5 / *~ ).4+r e
i 2Q I l (CLOSCDs Violetion 84-08-01. Gaps On Unit 1 Polar Crane l Erac;et and Sci smi c Connecti ons,. - In Ncvember 1984 an NRC inspector found that the gaps between ! l the bracLet and connectors exceeded the design tolerance. This item i s addressed in SSEF along with related problems with poler cranes. Discussion, conclusions and actions to be taler e are included in paget K-14, 15, 18 and 121-125 of Appendir K > Well to SSC 3. Since these actions, address the specific concerns of item 84-04-01 =d-t WI i s t '. r - '~a elosed. r, i ! 5. DA F&cordi Svetem Review . dec.i d .4 . W w h NA I'* diw 60 M h Mb - h
% uM'7*
l l Tky easepg.c.;rs d $4' <-pi h "' [S$3.,prok.'yH Q 4*m mf ce o ( hdFCuv4J eis h $
.%,.f., L,b so p, o k s.t. E.<, w n. e i n s e e.e r .
% Final Saf ety Analysi s Report (FSAR) % Vol ume 1, Section 1.0;
% 899IE l A Appendi:' 1 A(N) and 1 A(Dg commi ts to Regulatory Guide 1.88; Collecti n. Storage, and t1aintenance of Nuclear Power Plant Qualltv Assurance Records and to American National Standards, Institute (ANSI) N45.2.C. On page 1A(B)-36 in 4t.a. A - f p~& %'
i the Di scussi on.^- . _
&% tKC*( dese $s ki erm- takehto this standard ( which w an acceptable way to meet the 4 requirements of Part 50. Appendix B, a y 10ti,,ihCFR[ is k d N a.k Afrbrief m %description . 3 O dOARecords)nor f !
propose #' acceptable alternatives 7 of Duality Assurance Records in FSAR Section 17.1.17 (Amendment 50 dated July 15. 1984) and Preliminary Saf ety Analysis Report Section [ l 17.1.1.17 (Amendment 5 dated April 5, 1974) are identical, very g 1 brief, and d: nd M :: fully address the requirements of ANSI N45.2.4 j w ov- da$crsb4, S h el, p -
+ ( t t e d. S hv a, ag. . _ :. ;- fg.ciliMj E For example. temporary storege of records is not discussed f or the i
Satelite Storage Are.as ( t emp orar y ) , Interim Record Vault (IRW . ll
. . . , , .. _% - m..._.-. .~-,m......m .r..,-.. ,,m. , , _ . . . . . ,,..y,. .__....%- ..y.,_.....,- ,, , . , ,
I
' i 01 )
FermLnent Flent Record Vault (PPRV) and the Procurement Records , 1 St or dage ArE F (We"choust- A), 1 g ). gM kk 5 This '. _ to revi sedFSAR Secti on 17.1.17 to describe and reflect
%gplM ag
^
the current DA Record system is : --2:t. :- 1 IOC"R . I m -,,e,,,,,.m.a. m ,r.,, r4 <yrrw (', ae M n
% de s e n y L 4wlW f/NW; w/ wit-os) .
- a. Review of Corporate DA Manuals and Site Implementing Procedure.
l I Ths NRC inspector reviewed Texas Utilities Generating Company 1
's (TUGCD). Corporate DA Program Manuel, Revision 14 dated April
/ -
- '.,0 . 1985 and Duality Ascurance Plan, Revision 14, dated August
/
- 00. 1904, t o determine if ANSI N45.0.9 was referenced and/or A '; t,
, reciuirements. were translated into these documents. TUGCO j q./// '
Revision 5. references ANSI'N45.2.9 but ProcedureCP-{F-18.4 fails to address all aspects of ANSI N45.2.9. such as, all fecility l oc a ti ons t method for maintaining control of and i accountability for records removed from the site storage en rr f acility to organi::stions located p off site; temporary storage j ! facilities Hire rated cabinets versus duplicates in remote 1 l separated locatiens); speci al process d recerds (photographs, negatives, and microfilm); and prohibition of food and drinF 6A in the vaults. The permanent iacilities is* discussed with . respect to ANSI N45.0.9, paragraph 5.6, however, the drain
- s. stem and dry chemical / gas fire. protection system discussed
\M '. .
in this paragraph, is not discussed. The Int:r.- ,'a i Svet cm i
" ' * ' * " ' ' "'~'~' '~ " '~
____________T__1'E_l_Y__I_'__. __.Pl'_I_' il_'_1_*___._ f_2Y'_T_~_5 ' *' I ' _TYT' - -
~ ~ ' ^ ~
---7-~-C
I i j ' 22 i in a permanert records S aul t f er Un4 t 2 records until such de h
'*b f recor ds c'an be transferred to the FPRV where Unit i records //-
ere now s+.ored. TUGC.O Procc. dure CP-OP-18.6 Rev. 3, discusscc recor ds tur n-over from Brown & Root IRV to TUGCD PPRV but does ,. I not address the issues raised above. Abo ghese issues h are not addressed in Brown 6 Root- !"._. OA Manual Section 17.0 dated October 31. 1984 and CP-CAP-18.1, Revision 3, dated Julv 11, 1981. M bysdHl.b me.r.=y d5Wd M M 7e e s 4 , , ,, e +-
--t n.-s ,,-,-a.. m-,.,
r ._j r ; , ,; , p.tt cT}- tf.Jutiv cA m w - L m. o.v. c., ik e.<. v U % hi :+ t ; : -- : .- P: e::: 'ir' er:: ._ -e 4- -' S 6 i L z..
.....a ev-,w. t M r,nwei% ,pva y % .-.. . . - T b' i iR 4 + ,. .*4-- .e ,, 1 r..: ,: s: -. .- : -
S+ - ; _M
~ " ' '
(3 W erss( M y Mgn.,~t%[ 'cAg L5.
%__. .- - _ . , _ . , + . - 4+m _ r ,, _
r-f us t W g.. .---+ e4m3 ;; ,, ~ n
.r 3 - 4 1 4 + 4 n - 4 1 14- 4 7 at ; ,
p - ,3 ., p. r 4 + - .. < . s a4 (445fg514_ ; 446/8511- ). l l
- b. Storage and Transmittal of Design Records to Stone & Webster.
New Yori. On October 16, 1985, an NRC inspector was inspecting ansfM f item u M,/+ed ab previousiy identi fi ed t. t': Mg/8226-U-07/. The re-qualif icati on package f or pipe support CC-1-107-OOB-E.93R was requested and the NRC inspector wasinformedthatth(sf
; E~NO2.- ( 48 6'll hv&l ' took.u S t s sdesign records package and about C 7"g other hanger packageh ~ -
% /%ks ;[ ea<'6" g c,,. s - ----
had been shipped to C.,WL-C/' New g York for a complete .k .,. i
.\ r-
\
re-an al ysi s.
,/ ( , y,7 AC .:
l
. - i s, . ,
(* . Lflps "G(
6 23 ! 9(A l 1 The NRC Senior Resi dent Inspector interviewed the jengineer:ng. superviscr who answered questions about whether procedures
]
controlled Euch shipment, the nuniber of records per packetge. I and how the records were protected from fire. water, etc.
$4. pkb5 M during shipment.A St first transmittal was controlled by
)
l procedure CF-EI-18. O-4 Revi si on 0, dated July 25, 1985 until l sd" .'CFPE) became a part of p;
r4 n
! ,"p;h,S '{f p' D C whik 6 j ( b f r>$ September 1, 1965[ f,t t+ms time the procedure was deleted. 5 ?. Webster pr edure CPPP-3 covers the receipt and indening of these paci:eges, however, CPPP-11 that will control these packages to SWEC offices at Cherry
'o ff[p' gc bHill.
the NJ: distributi Benton, MA: Denvei, on of CD; Houston, TX; and Toronto, t' - Canada, will not be completed until late October or early I .$LU E L j November, 1905, according to SWEC Supetvisor Project Services, O NY. Thi s f ailure to have procedures which control the I shipment of records is a violetion of 10 CFR Part 50 Appendi: 1 B, Criteria V. (445/8514- 03 ; 446/e511- o) ) . y
., ;1 .sY',' 7.
- e e E q d
5702 , Further, thc Jupervisor ~ stated that the 2:, . packages [which - WEC I contained all of the original c:alculation needed by SE*C, the .j l calculation checklist, a copy of Engineering Evaluation of ,1 Separation Violation (E.E.S.U.) for holes /Hilti bolts and the b original cover sheet which described package contents with "5. approval signature were shipped in cardboard boxes. poCopies pti c ah f, - i Mada, m L in C.& 54, bedy,Je W l od E of these records were not retained on sit Therefore, t 5 c- , 7 y rece'ds while in route were not afforded the minimum N dah.'d w u m b' N ;j Aec 5 TSM N A a uft . g,k A Jon d protectionrecuiredp@f, 4 shipped .in cont ainers with e tuc 3
- eudbou1.
_ .z. ._ _ . _ . , _ . . m - . . . , . _ . _. - - _ _ _ . . . _ - - . _ . - _
6 24 k .#sa' hour f i r e r at 4j e e.dor @ ai maintaining dup 12cate copies at separate and remot e l oc ati ons. "- - # = 4 1 ' "- e + " "'- ~ 4 ^ " hi protect 2ori f rom f i r e. water. and other possible detrimental conditions ,- go.ade w n i t ; r ,: Ts h. l C"" "..L 1. Arew .a. Lr da w + & ~ % o.4 a ~ , 4 o' f bes 'Y f o nn onom 3 % A.c o'n e __ : . A/U4'stlff* I. 4 e t o' O C S ( b Af __ s .
'g fg y G g ' Q s a s h A. lM y ot n ht O f M C!f D hw*m g ,
"'A$ f* *f *.T'*t).
w k ,'g,f en A.e-f alt. W W ! bas L &) bt frek& Ths's e /w s's L'm
- d of Y' ' M L .y JV n.c hand ** .! tst el = y Y < d! '***S/l o of t WG / T s *
- V )
- Q The supervisor, 1en ques ione , also sitated that they do not j l know the number of pages shipped. That is jthey did not count the number of pages per package shipped. When asked, he g70'2 estimated that each of the ..
-:' packages mav con {aj n as many ev D NNY - 2 5 0,o a s > ag.a as 50 pages (different documents) per packagg Inventory
's sheets or package checklist were not available on site. The question was asked as to how TUGCO could be sure they received i
all the contents of a package back and the reply was "TUGCO will audit the The NRC inspector a e saH_k L M., pac _e*1-t: ages when returned". steted that'~ % appears to be impossible since no one knows how many pages were in each packa_ gel I lg h h M i c.4/ b au/ WO64 I d i Knew u/4 ** K b ' This failure to maintain control of and accountability for I lee"tA. a. v'se t W e f t0C P A 4dre p J ,'4 /$,(re,l* b _l*% g records removed from storage i s,a devi ati on f rom FSAR commitment to ANSI N45.2.9., paragraph 5.3 (6)[ hkff/'/*#I) WkD/ Q The supervi was asked why copies were not made and the response wes j' thep : ' r- 1=rca =* - - ' ' they decided to
/
Std&C wt4 to p** k m proceed a.t risk. Also. it was stated thatpa totally new E' anal ysi s w=1 ? t. a. + v , js. and these,would becow the
, _ , . . . . . -. c- w - w te.-. a m. p.*-m -- < ~ ' ~ - - * =
. '- ' ' + .
i 25 usS official, design records and replace the old design M record b'fb
- c. Storage and Transmittal of Construction Records to Chicago Bridge and Iron.
E A third NRC inspector not involved with the SW[C records kr J<1...d % hi W N M trannmitta14 remembered a similar incident. In late July, 1985. he had asked for records pertaining to Unit 2 reactor containment liner and mechanical penetrations but was inf ormed that thev were not available on site because they had been r# . Shir to CBI. Houston. Texas, to be copied. On October 16. E 1 1985, he became aware of the SW/C transmittal and the fact l thatofrecords t'$ M were r:Sh*gp~M '- M u r ;; : t r- p :t::ti;r J,.'e s k i c ' f n _,
<...w in- _.44.~. ' and remembered that the -
g
% a M M % ft v transmitted to CBI. Houston, was similar.g y 4,*w % %,
A p r ei n sp ec t ed 4+,+-=
$ C SI recovd* T* % 3d. M jf m and found thet the original construction records were transmitted to Houston, Tenas. without retaining a copy,maei CBI procedure NRP-1 (Nuclear Records Procedure) states that corrugated cardboard packing is satisfactory for small shipments and that wood should be used for large freight shipments. The procedure further states that shipping by air freight, air express, or UPS is required for shipments containing documents difficult or impossible to replace. '
The NRC inspectors interviewed the TUGCD civil engineering R Project Contact and B t<.,F subcontract super vi sor to determine
. - . . . . . ~ ,,, .. - -. . - -_ - - -
d'
?
?
06 T o
.C .
bh if the CBI records were transmitted in accordance with a TUGC0
) 42f proced_ure es these records belong to the,,nwner and removal /[ -
( A el i s C.u p e t ad CA Tvko * ** st w W o '- '*
, . .. ." : ,. , W f r oc.. sate should be contr o11ec o r T. n e.Ti. iney were aIso ese.uu,..
how the records wer e shipped and if a method of accounting for these records was described in TUGCO procedures and f ollowed. No TUGCO procedure was identified and there was no record of a detailed inventory list or accounting for records transmitted.1 Tt _
~
M
; tu transmitirecords i- :-*-e with e 4 I
iM procedure and afford protection in transit equal to temporary storace requirements ::--as it tems ' c r "~-sold.::1^2
%~ wn j [ r .- .- 8 ) a [" #
N N 05) N fS/*/$'). 4 The failure to maintain control and provide accountability of t recordt. r emoved f r om st orag e i s r% r "t/r- s d_-..g. kik a f, IC,c Ftt Pav f **D
.. mi m ;
d.$ pgudh & , CviWa,,'22Zr .
'- - ' " - ' ' ' . . ' .- p . x ., . _f ; t - c _
The NRC inspector reviewed two recent TUGCO audits of CBI.to determine if the OA records system was audited. Audits TCB-5 and TCP-6 dated March 21 and May 7, 1985, resp ecti vel y, documented audits of CBI construction organization on site and l the Quality Assurance office at Houston, Texas. The NRC inspector contacted the TUGCO Audit Group located in Dallas. l Texas, to find out if they knew how records were stored on , I l site, transmitted from site to Houston. Texas, and determino l if the Houston facility was adequate and had procedures to receive, control and account for these records. The NRC
i 27 l
\
inspectorcontectedanauditor[hubsequent to contacting this L Tv W C m m p- ' e m* contacted the NRC inspector cuditor W DA &~ ': _ ; i and stated that he had met with two other TUGCO personnel to discus 5 this issue and he stated that the TUGCO decision to send records to CBI was at TUGCO's own risk. The NRC i nspect or was not provided answers to the questions as).ed. a An additional reason that the NRC inspector contacted the Audit Group. was to determine why Audit TCB-6 Audit Scope OA '"-w=. Ass tte 5 W included E -!!'- ' kccords,bu(*tthereportfailedto repcrt on this subject. An euditor who participated on this audit did not know why this subiect was not covered in the audit. This failure to document audit results it , ulolation of 10CFR Part 50 Appendix B Criteria XVIII (445/8514- 07 ; 446/8511-11 i
).
- d. Inspection of Storage Facilities. l 1
l The NRC inspectors inspected all site storage facilities to l determine if storage, preservation and safe keeping of records are as required by 10 CFR Part 50 Appendix D, Criteria XVII and ANSI N45[2[9[ Draft 11, Revision C, paragraph 5,
" Storage Preservation and Safe Keeping". The facilities inspected include TUGCC Records Center, Permanent Flant Record 'l l
Vault (PPRV), Iterim Record Vault (IRV). Satellte Storage l 4 i
, ,I
1 1 28 - l 1 Areas f or Unit 2 Mechanical and Electrical Faper Flow Groupc. 1 and Procurement Records Storage Area. The f acilities f or the Paper Fl ow Gr oup and Procur'ement records are not discussed or identified in TUGCO or Brown L. Root procedure, however, these facilities and the PPRV and IRV were evaluated and results are au f ollows: 1 (1) TL9CO Records Center This veult is the final repository f or Unit-1 records which describe completed construction and Unit 2 record D
& % utewe h syster.is that b' y bee
- completeg. "This
*% l packages for '
facility was completed about March 1983. The NRC inspector f ound that thi s vault had access control; l recordt were stored in approved containers or in binders on top of cabinett. Radiograph and other special processed records are protected by controlling temperature and humidity. The design of this facility is as discussed in paragraph 5.6 " Facility" of ANSI N45.2.9 and is constructed to protect contents against fire, d flood. tornadoes. rodents and deterioration cause by extreme temperature humidity condition. The. f acilities l meet the requirements of ANSI N45.2.9 except as follows: * (a) The five protection system discussed in ANSI N45.0.9 par agraph 5.6 i tem (8) specifies e dry chemical or gas fire protection system but TUGCO elected to I
- A wm = % %
u .< t' i Q( 6- r **O i kl
% d ,'I- T 5 E sf i I$, $*l wg
. .t
.g
, .f 4
.C s
l
. a a % 'W o .N i g ;J install e wat er- sprinkler system. TUGCO personnel .; g ,
h,I s stated that a water spri n kl er system was installed
.f r 1
,g instead of ges/ dry chemical because. water would hg<
d%w kw
- entinguish a deep seeded fire. This presents a d i e
I
=gt.. b).
Q p **"f v $ j problem because the records that are stored in open y e 4 f aced cabinets in f olders or binders will be_ deluged J.g As7 C { 7 with water and will likely deteriorate.g There is no 3e y ,g A i 4 g e n :tt i & evidence that TUGCO submitted a description of this- ]} i~- , f acility f or approval of this change to the ygy{' commitment in the FSAR. s This failure to install a system,as described in ANSI N45.0.9 a ': n - i i: cc :l'~ '..m ...mu.- M
,mr i
suppressing' fire protec records is'a deviation from FSAR commitmentfin Appendin 1A(B) p l l '). 2.11 A - t s + d e s e,*. b e it.a. huiaD havet L b,a*ws FSAR Section317.1.174(445/8514-og ; 446/9511- (2- ). (C) Permanent P1'an t Record Vaul t f
\ % ~l S' .
p -(p e m 8 $ {'* "' This vault served as the3 permanent vault3 until March j 3erso._ J 'a w ls i 190"J . Thi sdf acili ty h'es controll ed e c c e si s . It meats the j d design features for permanent fscility in part but doen jl not fully meet either permanent facility design features I as f ollows: k l 1 (a) There is no fire suppression system inside this
]
vault. Two hand-held ext 2nguishers and a two inch I i r
g.. ,.e >
.. h ' * 'w ( CO w '
34 , .t. l f~>j1)a
.a b l
.N.* - b fire hose are located outside the vault. One hand
{> *#*lgab$ e*
- d i?
- .! s d" .J i q , a
' '[ f v held extinguisher is located inside the vault. Fire j
sog., ,- ,P : detectors and alatms are inside to alert the ons2te s
, W . .: bh d '?, fire department if a fire occurs. O O
,, v '. 3 .r t.g *! .a
'.5
,y , g ,w '% 4t b ~ 4 ,, 6 ., J . . . . f
* ~
j .r - s ,.. w s. e f. . h4 xW dn <.e 3=; -t k.4. fav . 3 s = Me d +w s. m *Fee }u d*ys,a T J h.s s b 'l a *" I (b) If the 2 inch fire hose is used to extinguish a f; , )?:' s k m* d g5)Q I 5***kb 4 j.f [ kwse , f i r e ,, o therearenofiredrains,topreventflooding&
*mA % NH ,s ne f S fe
*# 'We rt h.L , m %Som ...
,fg $ g-.2 y ff y wat er :: A ' ;'- could, enter, cabinet drawers. f l
v., i ~ . . , . .: , , :..
;+ a
', s. 9 -
)Q) .
(3) interim Record Vault
? h .
This aree is not a separate building but is an area of I j l the permanent vault that is set aside as an interini d * [ istorage area prior to placing records in the area r 7
-w 4 I designated for permanent records. This area has an i
.. =
- h. Dj$. '
ac cess point that is separate from the permanent area and i : , -s s .e w g p 2.c -C .- 1s controlled. The facility is the same as the permanent ,
*5 . I 2
3.,. r %' area except a wall separates the two. They share the )
7 same f orced air system. This meets the requirements of f' [ ~ '* '*. b ".,29FR JOC$ f1*R.
Part 50 Appendin D and ANS N45.2.9 except as 1 . Q ,,, _ m :b,:IIfol1ows: l
- . % yys 1E*
y
~- (a) Water had been leal:ing through the f orced air, system 7n a. S e t sa d locaTa m and beside a support girder.p Approximately 2-3 is th r'amas k tL.a. Gru.4 oJ., v s4.ldn' d I
gallons of wster had leal:ed,and was caught by a pisu4 Me N d 4l containej. The temperature / humidity control chart indicated high humidity (55-68%) from October 14 l t i
i
. . l 31 through October 20. 1955. Interviews with vault and other site pers,onnel revesled that the roof and vent system have been leal:2 ng f or approximately two years end perhaps longer. Ra d i og r a p h s. , photographs, ,
microfilm and other sensitive records were stored in i the PPRV and IRV until approximately December 06. l bb 19S4[ M bA. c e < 4 s M .y 844 r t IN J b j (b) The NRC inspector observed a coffee pot, sugat, and l crumbs on an adjacent table where f ood had been broucht into the veult area. Cd ht f6f5 " '
- fta $ 6 L Ya bs v 0 A* *0 '
. A sid e % M. 3 Thi s f ailure to protect records f rom moisture and/or condensation for extended period, and the failure to preclude food materials which encourage rodents, i s:
a violation of 10 CFR Part 50 Appendix B, Criteria l l XVII (445- ; 446/8511- ). J 4*"
- 4
+4ti: % NFPA s< r da en .1 f
l t *
- 4- M fu c.e m m.'t W s +hs*.4/s uppe Pt /tws t 4.7 vs. 2 9.
C u e e %i p v a. c d***.esfr d YkI 1 l (4) Satelite Storage Areas: l j i trolers wh ' The NRC inspectors inspected,the electrical and mechanical paper flow rso s ava ler eied. sp to determine how records aio stored. ANSI N45.2.9 defines QA records ad "Those i A I records which furnish documentary evidence of the quality of items and of activities affecting quality for the purposes of this standard. A document is considered a quality assurance record when it has been completed." TL4 T.c cy uuf 4.k , 6 is sw rN 3f1,M; imitA %; ~) de Mit;en. dea etf,b. d e r<ce4
^
- G (.P.cu.
m V*i '. -4 tr.u 4.,.r.
. ) l
' S ce* )
J ( a s efeb E j y* The. paper flow groups have, W . records 4 mined in with . ,j
$ t ' % J h *% f sbv't w '?fk, incomplete documents wh isinproces'.pNRC e lD'a -
- C' ( f[ ."b. b 2 Special Review Team Report dated July 13. 1984,
*v it 'l.I identified a potential enforcement issue because original %k Y>
N U4x *
- l ASME records such as moment restralrit packages are stored 1 l
(Y4*t*4y q s '& in trailers in non-fireproof cabinets without a backup i 1 g eb\ copy in a separate and remote location.g d* dO -)4
** {)d 'f J 1 rgkuj* i l d._ g On October 21. 1985, NRC inspectors inspected the Paper \i I -
. Flow Group storage facilities and determined that a b- st 4 v
)4t}I1~6 S y4 8 E 'E. 'b larger number of mechanical and electrical records had I L, been removed from the permanent storage area and had been i? kh.9 *% yyH Psc non-fireproof placed in 3 P-e" W t's cabinets. Previous NRC
,5 g I urt b b Iy
& TI*f) inspections in this area documented isolated DC records ems M r\ { p however, during this inspection it became clear that l '.k c
j)4 large numbers of, all types of constructiorfrecordsare GM J v .f stored in those files. The Paper Flow Group personnel
} .*' y
, a i g %. were ast:ed if records of component installation were f'.2ggE 4le d
stored in these files and the a swer was af f irmati v'e. Cks=lk The NRC inspector asked if records such as steam 3 I generator records / packages were stored and the answer h- ' was affirmative, = e C !- r d , : ~ . nr,ros wEre 1
^~CI iG [ 'T "~ 2 k ! I C C Ui s id b a paid b ,', _ 'CCpOnce ,;;; thOt-y , ? d (i b--t_'L k'1-I g:::t tr:
i a I
i 30 Thi s. f ailure to protect records (as defined by ANSI N45.2.9) is a violation of 10 CFR Part 50 Appendix D. Criteria YNI I (445/8514-tb ; 446/8511-14 ). (5) Storage of- Procurement Records In warehouse "A" procurement records were stored both i n i non-fire rated and fire rated cabinets. Since this facility is not' described in the FSAR or procedures. l there is no way to determine whether duplicates exists I l $ and what must be stored in fire rated cabinets. This item is unresolved pending identification and description of this facility and indening of records recently received from the TUGCO, Dal l a s, Tenas, office to determine what records must be 2n fire rated cabinets (445/5514- Il ; 446/8511/ f f' ) . (6) Audit of DA Record Systems / Facilities: The NRC inspector asked if the unacceptable condition identified above in paragraphs 5's. wkid had been identified by TUGCO or Brown .L Root audits. TUGCO audit (TCP-85-20 dated January 16, 1985) of the permanent plant re- -ds vault failed to identif y any problems with the . facility. ANSI N45.2.9 specifically states that periodic audits shall be performed to assure facilities are in good condition and temperature / humidity controls and _m_m- _m- .u. .e-m .-----*_a.. ._---.**-a-.._--_...-i_.am.m.-rna--..---h.-..m.....h...--m.m m emm -mem s a---_.m_i-e..--sm..m.emam.um.me._*_ -w.mi.m_..m.- ____.__J
I
~4 l
protective devices are functioning properly. Two auditors audi ted thi s area f rom December 17 through . l December 20, 1984, and their report did not identify any f storage facility problems. Ebasco audit dated June 16, 1981, page 4 of 25 item g. stated "It is an established fact that the OAR vault does not meet the requirements for a single storage facilitv and that duplicate files are not meintained in lieu of . single storage f acility and that duplicate files are not mai ntai ned in lieu of single storage." On October 23, i' 1985, the NRC inspector requested documentation which would show ection taken to correct this problem. TUGCOs l Project and OC organizations had no such documentation. This item is unresolved pending review of the response to thi s eudit finding ( WI"/Pf/4- / 7. ; 446/ Ff//-tf )
- The NRC inspector asked PPRV personnel if Brown & Root l had audited the record keeping / facility system and were informed that it has been several years since Brown &
Root had performed such audits. This item is unresolved pending the review of Brown & Root audits (445/8514- 13 : 446/8511[ [6 ). (7) Control of Wel d Filler Meterial:
- _ _ _ - , _ , . ~ . :. . _ .,. .. - , - -.,.... . , _ . ~ ,. . _ , ~ . - , . . - , - . ~. . ~ . -
m .I t OS This inspection was performed to determine whether tsfety l related weld filler materi al purchase, storage, and i d2stribution are in accordance with the applicant's wort and DA procedures and applicable ASME code requirement. Implementation of the f ollowing procedures was e::amined during the inspection:
. CP-DAP-8.1, Revi sion 9. dated October 15. 1984,
" Receiving Inspection"
. CP-CPN-6.9D, Revision 2, dated September 21.
1984, " Weld Filler Material Control"
. CP-CPM 8.1, Revision 3, dated July 2, 1985,
" Receipt, Storage, and Issuance of Items" The following areas were examintd:
l tai Procurement: l Four purchase order packages, which consisted of the
~
purchase order, procurement specification, and field i requisitions were inspected to verif y that orders were properly approved and incl uded required technica11, packaging, and documentation requirements specified in site procedures pertaining to weld l filler material purchases. No viol ations or unresolved items. were identified in ! this area. _== _ _ m. = = , .-- e _ t-= v-n : ,-- ~ ~ ~ - - - ~ ~ . - - - - - - - - - - - -
i
!.6 (b) Feceiving Inspection:
F cce2 ving inspection records, for the filler material purchased to the purchase orders inspected, were e::amined to verify that all items required by attachment 11 (Receiving Checklist) to CP-CAP-8.1 had been inspected. In each case the checklist and a receiving inspection report (RIR) had been completed and signed by a Level II OC inspector. In several instances Nonconformance Reports (NCR) had been completed and material returned to the vendor as required by procedures. Certified Material Test i Reports (CMTR) for each purchase were also reviewed to to verify that required inspections and tests had been performed and that material had been purchased from a vendor with a current ASME certification. It was also verified that heat codes and quantities of material shown on the Material Receiving Reports ( RR) corresponded to what was shown on the CMTR. No viol ations as unresolved i tems were identi fied in this aree. (c) Main Storage Areas: Two filler material storage areas located in Warehouse A were inspected for compliance with procedures included in the above documents. One _ _ _ _ _ . . . . . . . . _ . _ , . . _ _ _ _ _ _ . _ . . , , ~ . _ _ . _ - -
r h I
~n area was designated as a 0-area and the other one was both a O and Non-D ares. The Non-O material wat segregete as required f rom the O material.
Procedurez in the storage areac appeared to be I l adequately implemented except for the f ollowing 1 items: Paragraph 3.2.1 of CP-CPM 6.9B requires that O weld filler material original containers be marked upon receipt and during storage with the material l l . classification, si:e, and heat 'l at number. In the O Ti area labels on several containers of Sanvich Welding Products weld rod had fallen off and others were ! locse. The material was still identifiable because j of the storage bin marking and marking on the shipping carton; however, te s.r ley #f S ec a1'*
- _. identity is possible when naterial is removed from the storact area. There were also several unopened cartons of S
Sanvich material whd'cc d ki bt or could not be determined. Loose or missing labels were identified on the f ollowing material; Lot 101172-2, 1/8 inch AWS/ASME SFA 5.4 and Lot 10149-1, 5/32 inch AWS/ASME 3 haflwwt10 g SFA 5.4. Thh led cf adequate) mat-k W of the v t al Ai dwt#I material is a de i r t i 1. tLa requirements of ; CP-CPM 6.9B (Item 446 85 4 11I (d) Distribution Stations: _ _ . _ . _ _ . _ _ . . ..__.m_._, _ _-m_,_-- m , _ . . -- -. ._ _ _m
I. l
'I I
)
38 L l Wald rods used in' safety-related applications are ! l-
~ distributed from three areas (Rodhouse 2, 3, and 4).
Each distribution station was inspected. to verif y , I compliance with requirements of CP-CPM 6.9B in the f ollowing areas 3 I
. Storage f acility (Level B)
. Identification of mat eri al .
. Controlled access into storage areas
. Control of stationary and portable rod ovens
. Issuance, return and accountability of material 4 1
. Completion and control.of records I J
1 Sanvick material was observed in Rodhouse 4 with
, label problems as described above relating to deviation . No additional violations or unresolved items were identified.
l ! j 1 l l i i
'9 - 3 9
d l 1. Allegation Category: QA/QC 3, Records
- 2. Allegation Number: AQ-137 I
- 3. Characterization: It is alleged that ASME N-5 welding recordt. and docu- ;
i ments were altered while they were in the permanent plant records vault, 1 and that such alteration could be determined because the welder or inspec- ; tor whose signature was altered was not onsite on the day these documents l were signed. l 4, Assessment of Safety Significance: Since the alleger could not supply the i cate or specifics of the alterations, the NRC Technical Review Team (TRT) i' selected a sample of documentation packages from 26 N-5 systems and re-viewed weld data cards (WDCs) for the field welds completed in each sub-system. The period covered by these documentation packages was from March q 1978 to October 1983. From these WDCs, the TRT determined the specific ! dates on which welders, quality control (QC) inspectors., and Authorized i Nuclear Inspectors (ANIS) performed safety system field welds and inspec- l tions. The TRT found no evidence of physical altering on any of the WDCs ) selected. 1 For each WDC, the TRT recorded the weld symbols of the welders who had l performed the field welds, the names of the QC inspectors who had inspected I the welds, and the names of the AN1s who had completed hold point inspec-tions on the welds. The TRT then cross-referenced each weld symbol , with a specific welder's name and badge number.
]
The TRT next obtained the badge numbers for the QC inspectors and to access personnel payroll records to determine if these employees were on site on the date the WDC entry was made. The TRT reviewed 194 entries made by welders on the WDCs. Payroll records showed that all of the welders investigated were on site on the dates that were taken from the WDCs, and the weloer entries were accurate. The TRT found that each ANI inspector entered his. shift activities in a bound record book entitled, "Special Inspection Services Daily Inspection Record," as required by the Hartford Steam Boiler Inspection and Insurance Co. The TRT determined that this record prov'ided satisfactory evidence of when an ANI was present at the construction site during the 5 year period under consideration. In the samples of WDCs reviewed, 47 inspections were performed by the ANIS. Numerous entries posted in the record book indicated that in all cases the ANI who signed the WDC was on site. However, the TPT noted that five of the inspection activities listed on the WDCs were omitted from the record book. This appeared to be an administrative omission. The TRT reviewed 99 entries on the WDCs which were made by QC inspectors. The TRT verified that all inspectors were onsite for the dates documented by the WDCs, with the exception of one inspector, a temporary employee from the Brown & Root Houston office. The record of the Houston employee confirmed that he was on site that week; however, their . records are kept weekly not daily. 0-95 h L_= = = - , - _ -- m . - - ~ ,.- --
- I
- 5.
Conclusions:
The TRT concludes that since none of WDCs appeared in L.( altered and the attendance records of the individuals sampled reveai tu . ) discrepancies, the allegation that ASME N-5 welding records and docu ,,.. ' tation were altered while in the permenent plant record vault is not . stantiated. Accordingly, this allegation has no generic implication; In a meeting with the alleger on December 10, 1984, the TRT prestnue p < results of the assessment of the allegation and the TRT's conclusic- .
. k major items of disagreement and no new concerns or allegations were identified. k Reference Documents:
- 1. Brown & Root Procedure, CP-QAP-12.1, Rev. 11, "ASME Section III 5 Installation, Verification, and N-5 Certification." *
- 2. Brown & Root Personnel Payroll / Time Records.
- 3. B&W Welder Qualification Records.
- 4. B&W Quality Control Inspector Records.
- 5. A-5 Interview, dated August 2, 1984, page 18
- 6. A-5 Closecut Interview, dated December 10,1984, pages 35 throug', 72.
i E I. a k m i 1 0-96 l
.---c. , , , .,.q
g~ 1ka"""~~ 4 3 , l A11ecatiw Lategory: QA/QC 3, Records g Aileoation Number: AQ-49, AQ-74 and AQ-125 l 4 Characterization; It is alleged that permanent QA/QC construction, fabri-j cation, installation, and inspection records were lost during various
< stages of record completion.
E : Assessment of Safety Significance: Because these allegations were general l in nature, the NRC Technical Review Team (TRT) assessed them for both iso- ! lated and generic implications. The alleger's concerns addressed the loss l or misplacement of QA/QC records which documented inprocess and completed-
- f abrication and inspection activities performed at Unit 1. These records l typically documented activities for welding, process control, inspection, installation, testing, nonconformance, and corrective action disposition, s !
l Allegations AQ-49 and AQ-74 addressed the loss of individual weld data i
- cards, as well as the possible loss of hundreds of entire documentation packages for ASME Code hanger. The specific weld data card cited was CC-1-087-004-A33A. Typically, a documentation package contains weld data j
[ cards, inprocess and final inspection reports, drawings, vendor documenta-l tion, nonconformance reports (NCRs), and ASME Code data reports. In an
-' interview with the TRT, the alleger disclosed that the lost recorc' were
} on-l l
ap::arently found. Notwithstanding the* resolution of the alleger's ! cerns, the TRT assessed the potential loss of QA/QC records for generic i".ol i c ati ons . In mid-1983, a joint Texas Utilities Electric Company (TUEC) and Brown & Root (B&R) task force was organized for the control and management of ASME . component supports (hangers). The task force mission was to verify that I design, fabrication, installation, inspection documentation, and assembly activities were performed adequately and in the correct sequence. Part of the task force responsibility was to initiate and/or track documentation
~ f ASME Code, Section III, subsection NA, requires that ASME in-l packages.
stallations and hardware be certified in accordance with Code requirements. At Comanche Peak Steam Electric Station (CPSES), this effort included assuring that QA/QC records were generated and completed to support con-struction and inspection activities. In addition, the ANI (the Authorized l Nuclear Inspector, an independent third party) was required to review, l concur, and approve ASME documentation / records requiring certification. Prior to certification, the records were placed in the construction records vault. To assure aceouate control of the records, appropriate processing was established to prevent unauthorized removal from and updating to docu-mentation packages in the vault. If documentation could not be locateo during record's inspection prior to certification, an NCR was generated and resolved in accorcance with approved procedures. The dispositioning of NCRs has resulted in the removal of hangers and piping (or portions thereof) and their replacement. Of the approximately 17,000 ASME Code pipe supports for Unit 1, 15 have been totally or partially prefabricated because of lost records. (The reconstruction of weld data cards is addressed in allegation AQW-67 of Mechanical and Piping Category 25 and allegation AQ-67 of Mechanical and 0-97
~__._____A _
i Piping Category 8 in " Safety. Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station" (NUREG-0797, Supp. No. 10). The reconstruction t f the lost weld data card (No. CC-1-087-004-A33A) cited ir this allegation was reviewed and found acceptable by the TRT. The f"ethcc used for examining records accountability for support hangers was also used for ASME piping and related hardware. For non-ASME documentation, a similar verification program was establisne; for Unit 1. Non- ASME documentation deficiency resolution was accomplisne: either by constructing new records frcm reinspection and supporting docu-mentation or by harrNare removal and replacement. Allegation AQ-125 concerns construction travelers that were possibly lost by the paper flow group (PFG). Construction travelers were issued to the craft personnel and controlled by the PFG. Included in the packages were f abrication, inspection, vendor documentation and other supporting docu-mentation. Excluded were design documents, such as drawings, component modification cards (CMCs), and design change authorizations (DCAs) which were provided by the document control center or satellite. i Traveler packages were prepared in accordance with B&R procedure CP-CPM 6.3
! Revision 10, " Preparation, Approval, and Control of Operational Travelers."
The PFG listed package items in the computer data base as inprocess and I completed an inventory card identifying each document in the package. When the package was issued, the inventory card was removed, the name of the person to whom it was issued was entered as the package holder, and the card was filed in the package " outstanding" file to account for the package. The contents of the documentation package were checked against the inventer card by PFG personnel prior to issuance and again upon return or completier of work to assure required documentation was present and correct to the cur-j
- rent revision. Under normal conditions, packages were issued at the begin-
[ ning of each work shift and returned at the close of the shift. Complete; i, packages were forwarded to the QA/QC records review group for final Q4/QC review. The data base was then updated to reflect its completed status, j For documents found missing during the PFG inventory of package contents, i an NCR was written to document the discrepancy and to initiate corrective action. I
' Each new or transfered PFG employee received training that covered job
, responsibilities, scope of work, specific assignments, and procedures I directing work activities. On-the-job training was also given until the
; employee was adequately trained to function independently of supervision.
The TRT reviewed documentation verifying that PFG personnel received this indoctrination and training. In assessing AQ-125, the TRT determined that PFG personnel had received
, adequate classroom and on-the-job training to be competent in performing their work. Because of the self-regulating document accountability syster any loss of records would have been detected by the PFG, as previously I described.
l l l
- ! 0-98 a
____y-____
. --~~-% .-- - - --.* <-r ~-- -
-- ~
i ! 1
- 5. Conclusion and Staff Positions: &R's proce-1
. Procedure implementation was verified by TRT reviews of documents and records supporting the construc-tion and inspection activities for selected ASME hangers, components, and piping. Document deficiencies relating to the partial or complete loss of work packages were reported on NCRs for corrective action. In these cases, reconstruction or replacement of lost records was done in accordance with approved procedures. Such documentation was subject to the same review and approval as the original records received. Accordingly, an effective program exists for the accountability of permanent records supporting construction and inspection at CPSES.
The TRT found that the allegations that construction, fabrication, instal- i lation, and inspection records were lost has been substantiated. However, the losses were not of the magnitude first alleged, (i.e., " hundreds" of entire documentation packages), nor were losses attributable to the lack of competence of the PFG. Accordingly, these allegations do not have generic implications. , 4 On December 10, 1984, the TRT met with the alleger and presented the AQ-74 findings and conclusions. The alleger presented further examples of lost document packages. These document packages were a part of the review conducted by TRT, as reported above. The alleger associated with AQ-49 declined further contact with TRT, thus no meeting was conducted. The source o' AQ-125 was not an alleger. Reference Documents:
- 1. ASME Section III, " Nuclear Power Plant Components."
- 2. ANSI N 45.2, "QA Program Requirements for Nuclear Facilities."
- 3. ANSI N 45.2.9, " Requirements for Collection, Storage, and Maintenance 4
of QA Recorcs for Nuclear Power Plants." Precedures:
- a. QI-QAP-11.1-25, Rev. 8, "QA Review of ASME III Documentation."
- b. CP-QAP-12.1, Rev. 11, "ASME Section III Installation, Verification, and N-5 Certification."
- c. CP-QAP-11.1-28, Rev. 25, " Fabrication and Installation Inspection of Safety Class Components."
- d. CP-QAP-18.2, Rev. 3, " Quality Assurance Review of ASME Documentation."
- e. CP-QP-18.2, Rev. 2, " Implementation of the Permanent Plant Records Management System."
- f. FP-QP-18.3, Rev. 2, " Permanent Plant Records Systems Organization."
- g. CP-QP-18.4, Rev. 2, " Permanent Plant Records Receipt Control and Storage."
- h. CP-QP-18.5, Rev. 2, " Automatic Records Management System Implementation."
- i. CP-QP-18.6, Rev. 2, " Record Turnover to TUGC0 Ope' rations. Group."
- j. CP-QP-18.7, Rev. O, "N-5 and N-3 Code Data Reports."
- k. CP-QP-18.8, Rev. 1, " Records Verification."
- 1. CP-QAP-11.1, Rev. 3, " Fabrication and Installation Inspection of Components, Components Supports, and Piping."'
0-99 m.
. _ , _ _ . .._ - ~ ~ - - --- - -~ " **""*7' * * " ' ~ ' ' ~ ~ ~ ' ' ~
f I
- m. CP-QAP-16.1, Rev. 20, " Control of Nonconforming items."
- n. CP-QAP-12.1, Rev 8, " Inspection Criteria and Documentation Requirements Prior to System N-5 Certification."
, o. CP-QAP-18.1, Rev. 2, " Processing QA Records."
; p. CP-CPM 7.1, Rev. 1, " Package Flow Control," and Appendices 7.I' through 7.11
- q. CP-CPM 6.3, Revision 10, " Preparation, Approval, and Control o' Operation Travelers."
- 5. NCRs M-12988, M-12997, M-12820, M-12807, M-7368, M-6953, M-7370, M-7371, M-10156, M-10403, M-12816, M-10814, M-7369, M-7372, M-10419..
M-13319. M-13241, M-13566, M-6440, M-6435, M-9767, M-14560.
- 6. AQ-49; Interviews with alleger A-13, page 20, and alleger A-1, pages -
and 9, dated August 1, 1984.
- 7. AQ-74; A-1 Statement A-1 Interview pages 24-37, dated April 6, 1984, A-1 Interview pages 4-9 dated August 1, 1984, TUGC0 letter TXX4180 (B. R. Clements to D. G. Eisenhat) dated May 25, 1984.
l AQ-125; NRC Special Review Team Report, dated July 13, 1984, page 70. li; 8.
~
l: l i I Il l ll il i i i.! ll t! ' 0-100 i 1
---- _ _. .__- . - _ _ ,.. ,. ,._.. , _ ,.,, ,. , , , w , _ _, , , ,
i
- Allecation Cateoory: QA/QC 3, Records 2 Allegation Number: AQ-45
- 3. Characteri2ation: It is alleged that between May 1982 and July 1984, permanent records were not stored in a fireproof vault. !l
- 4. Assessment of Saf nificance: i 6a I, l i!!
il 1 ij l The alleger identified several instances in which permanent records were ' in an environment that was a potential fire hazard. A check of the loca-tions identified by this alleger disclosed that they were standard office ; trailers which did not have any special fire or security protection for the j storage of records. The TRT learned that these were "inprocess" records. g They were stored at "inprocess record stations" at a stage in the work cycle between initiation of the record and the final signoff by quality [ control (QC) personnel. Record completion was signified by the final QC i. i signoff, at which time the record was considered complete, i.e., no longer "inprocess." Completed records were then transmitted to a storage facility, !j as described in the records management manual (RMM) and in Chapter 17.1 of the FSAR. ill: L Q W "- -
,, .uu.+:
- T< - s
( CW"kS -- L
~
d A . g. e s _ 1 ,1, .- - r - - - -
.~ .
...[ 1; 4 ,
Q
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j,s. ., . ,- - - o I 1 In November 1983, B&R established paper flow groups (PFGs) to initiate, distribute, maintain, and store inprocess documents. The PFG facility is protected from fire by overhead sprinkling systems and from vandalism by alarm systems. For additional protection, documents are stored in lockable fireproof cabinets; however, there is no requirement that these inprocess documents be treated according to the record storage requirements of ANSI N45.2.9. l The necessary types of records and the methods for record submittal, stor-
, age, and retrieval are addressed in the RMM. To ensure that TUEC complied l with permanent records storage requirements, the TRT examined the records j vault under custodianship of e TUEC quality assurance / qual con 1 j (QA/QC or j
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i 5. Conclusion and Staff Positions: Based on a review of applicable documentE. tion and recorcs and a physical examination of the permanent records vao'. the TRT concludes that there are no bases to substantiate this allegation In a meeting with the alleger on December 10, 1984, the TRT presented l I the results of the assessment of this allegation and the TRT's conclu-sfons. No new concerns or allegations were identified. 1 Reference Documents: l
- 1. ANSI N45.2, "QA Program Requirements for Nuclear Facilities."
;, ANSI N45.2.9, " Requirements f or Collection, Storage, and 2.
Maintenance of QA Records for Nuclear Facilities." j 3. ANSI N45.2.10, "QA Terms and Definitions."
- 4. ASME Code Section III.
- 5. Records Management Manual (contains both TUGC0 and Brown & Root procedures relating to permanent records storage maintenance and
, retrieval.). .
- 6. FSAR, Chapter 17.1, " Quality Assurance Records."
- 7. CPL-CPM-6.9.G, Rev 5, Appendix G, " Documentation for ASME Welding,
' Fabrication, and Installation Activities."
- 8. CP-CPM-7.1, Rev 1, " Package flow Control."
- 9. CP-CPM-7.1.G, Rev 0, Appendix G, " Piping Supports."
Alleger Testimony: A-1 Interview, pages 103-106, dated p 10. August 1, 1984.
., A-1 Interview, pages 21-24.
- 11. TXX-4180, TUEC response to allegation number AQ-45, dated May 25,
- 12. Government Accountability Project letter, dated March 19, 1984.
- 13. A-1 closecut interview, December 10, 1984, pages 35 through 73.
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. J.!1egation Cateoory: QA/QC 3, Records l
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M iecation Number: AQ-129, AQH-16 il naracterization: It is alleged that records stored in the permanent plant i.
.ecoras vault (PPRV) were changed and removed without authorization.
Ik
- Assessment of Safety Significance: ) l
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( n h 3 Te verify procedural implementation, the TRT reviewed numerous hanger and
-iping records stored in the vault for adherence to the permanent records
;catrol procedures. The TRT also interviewed vault personnel to assess ,
;rocedural adequacy and personnel job functions.
< ecorcs management manual (Reference 4) addresses TUEC's methodology for
!(
[ he identification, collection, processing, computer indexing, microfilming, ' 2no storage of plant construction and operating records. As a result of d ne interviews and the records reviewed, the TRT found that work packages l
- crtained the following types of quality records: QC inspection reports; l nconformance/ corrective action reports; certified mill test reports; ?j
,.D;iier data packages, including code data reports; process control docu- W
" u . neat treatment records; design disclosure documents (i.e., drawings / Pj
! ' # 'i:ations); ASME N-5 code data reports; and QC checklists. The i
aiso contained other supporting documentation for ASME Code activi- .:
.ei sucn as welaer qualification / certification records, hydrostatic ,
ma oneumatic test reports, and nondestructive examiner qualification / P't:fication records.
' -v MI determined from the records reviewed that approximately 950 hang-
-s '.,ere voided or superseded as a result of field or design changes. ;
P The !, also found that when a work package was ASME N-5 certified, formal C ,c5 existed for the retrieval and updating of the package. Updating [
' Lackages resulted from field changes or design changes to an item or.
' 19 a related interface with a system, subsystem, or component. The P
' ices were eitner updated in the vault document review rooms or with-
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' ~ *cr additional field processing based on approved written requests.
l '<-5 Cata reports were then amended upon completion of the work. The learned that when additions or updates to documentation for items a,50 reauv accepted and processed by QA and the ASME authorized nuclear in-t e:*. rs were necessary, they received the same reviews required initially. h:cition, obsolete or superseded records were not destroyed, but were
ac f r0m the worn packages, separated, and retained as historical re-
- ";i.
In interviews with the TRT, TUEC personnel were asked if they had 9cwledge of lost or missing traveler packages or documents. None of ose interviewed was aware of any unauthorized removals, losses, or docu-
'e't cnanges. Individuals identified by the alleger were included in this "terview sample.
0-105
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t The TRT performed a special unannounced inspection of the activities takir.: place in the vault during the second work shift (2:30 PM to 11:00 PM) on August 9, 1984 The TR1 observed no record removal or screening takir.g place during that inspection.
- 5. Conclusion and Staff Positions: Based on an assessment of this alle-gation, the TR1 concludes that no unauthorized changes o'r removals of records occurred for those records stored in the vault. Accordingly, these allegations were not substantiated. (Details of the TRT review of alleged alterations of ASME N-5 welding records are contained in QA/0C Category 3, allegation AQ-137.)
In a meeting with the allegers on December 10, 1984, the TRT presented the results cf the assessment of allegations AQ-129 and the TRT's conclusion. There were no major items of. disagreement, and no new concerns or allega-tions were identified. Another alleger associated with AQH-16 has decline further contact with the TRT, and no further meeting was conducted. 1 Reference Documents: i
- 1. ASME Section III, " Nuclear Power Plant Components."
l 2. ASNI N 45.2, "QA Program Requirements for Nuclear Facilities." l
- 3. Brown & Root Procedures:
I ! a. CP-QAP-12.1, Rev. 11, "ASME Section III Installation Verification and N-5 Certification."
- b. CP-QAP-11.1-28, Rev. 25, " Fabrication and Installation Inspection of Safety Class Components."
- c. CP-QAP-18.2, Rev. 3, " Quality Assurance Review of ASME Occumentation."
- 4. TUEC Records Management Manual Procedures:
a CP-QP-18.2, Rev. 3, " Implementation of the Permanent Plant
, Records Management System."
- b. CP-QP-18.3, Rev. 2, " Permanent Records System Organization."
l c. CP-QP-18.4, Rev. 2, " Permanent Plant Records Receipt, Control, I and Storage."
- d. CP-QP-18.5, Rev. 2, " Automated Records Management System I implement ation. "
l e. CP-QP-10.7, Rev. O, "N-5 and N-3 Code Data Reports."
- f. CP-QAP-18.1, Rev. 2, " Management of QA Records."
- g. QI-QP-18.5-1, Rev. 2, " Verification Records ARMS Indexing."
i
- 5. NCRs M-14524N, Rev. 1, M-14531N, Rev. 1, M-14370N, and M-14374, Rev. O.
l 6. Office Memorandum to Permanent Plant Records Vaults Employees, l from C. H. Welch, QA Supervisor,
Subject:
" Retrieval of N-5 Data l Packages from Vault," dated July 9, 1984.
- 7. AQ-129: A-1 interview, August 1, 1984, pp. 141 and 142, August 2, 1984.
- 8. Field notes of August 9, 1984, interviews with vault personnel.
- 9. AQH-16: GAP witness I and A-47.
- 10. Closecut interview with A-1 and A-5, December 10, 1984, pp. 35-73. ,
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