ML20141P072
| ML20141P072 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/03/1986 |
| From: | Barnes I, Kelley D, Norman D, Phillips H, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141P047 | List: |
| References | |
| 50-445-85-14-01, 50-445-85-14-1, 50-446-85-11, NUDOCS 8603180517 | |
| Download: ML20141P072 (16) | |
See also: IR 05000445/1985014
Text
r-
.
-
m
, ..-
.y
,
, ,
,
,
)
s
4
a
4
!
c>
- **
,
't
I
6
g .
a
-
-
-
APPENDIX D
>
-
, .; .
'
'
'.
CONSTRUCTION INSPECTION REPORT
'
t'.
,
u. . ' #
5
~
~U.'S.
NUCLEAR REGULATORY COMMISSION
..
.
'
'
'~.
'
'
REGION IV
,
'i '
i
.
-
,
12 NRC[InspectionReport:
50-445/85-14
Permit:
CPPR-126
..:: ' ' '
'
-
- . .
50-446/85-11
CPPR-127
Dockets:'50-445
Category: A2
,
'
50-446
,
s
.
,
l;
Applicant:
Texas Utilities Electric Company (TVEC)
Skyway Tower
400 North Olive Street
,
Lock Box 81
Dallas, Texas
75201
_.
^
Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units'1 and 2
'
Inspection At: Glen Rose, Texas
'
' Inspection Conductedi October 1-31, 1985
//Mb
2 - 2 Y - F4
~
Inspsctors: . H.-S.
Phillips, Seniof Resident Reactor
Date
-
i
.
Inspector (SRRI), Construction, Region IV
,
'
CPSES Group
(paragraphs 1, 2,-3, 4, 5, 6, 9, 10)
,
,
t
I
~
0ANC
l
dv1
2V b
~.
D.L.'Kelley,SRRIK0peratpons,RegionIV
Date '
.
CPSES Group (paragraph 8)
. ,
$ Wrn
2/2fk4
D. E. Norman, Reactor Inspector
DAte
3
Region IV CPSES Group
(paragraph 7)
<.
,
,
8603180517 860306
' '
gDR
ADOCK 05000445
.
y - _ . .
c
-
,,
'4
i
k
L
.
. .
. . .
.
.
.
.
,
-
-
.
-2-
,
Consultants: EG&G - J. H. McCleskey
Parameter - T. H. Young
Reviewed By:
8am
r/3/4* 6
I. Barnes, Group Leader, Region IV CPSES Group
Date
Approved:
7
/
3/7/f4
T. F. Westerman, Chief, Region IV CPSES Group
Date
Inspection Summary
Inspection Conducted: October 1-31, 1985 (Report 50-445/85-14)
Areas Inspected:
Routine, unannounced inspections of Unit I which included
plant tours, applicant actions on construction deficiencies, applicant actions
on previous NRC inspection findings, and storage and handling of QA records.
The inspection involved 204 inspector-hours onsite by two NRC inspectors and
two consultants.
Results: Within the four areas inspected, one violation (failure to establish
written procedures for control and accountability of the shipment of original
design records to Stone & Webster Engineering Corporation (SWEC),
paragraph 5.b) was identified.
Inspection Conducted: October 1-31, 1985 (Report 50-446/d5-11)
Areas Inspected:
Routine, announced and unannounced inspections of Unit 2
which included plant tours; applicant actions on construction deficiencies;
applicant actions on previous inspection findings; storage, protection, and
handling of QA records; audit of QA records; welding material control; and
electrical cable tray / equipment walkdown.
The inspection involved 227
inspector-hours by three NRC inspectors and two consultants.
Results: Within the seven areas inspected, three violations (a repeat failure
to document minimum wall pipe violations on a nonconformance report (NCR),
paragraph 4.c; a repeat failure to control issue of design documents,
paragraph 4.g; failure to establish written procedures for control and
accountability of shipment of design records to SWEC, paragraph 5.b) were
identified.
J
D
m ,
-
.--
.-
. - - . _
k;,
, a
.
o
,
e
t
'
,
- .
-3-
e
DETAILS
,
l
1.
Persons Contacted
Applicant Personnel
J. Merritt, Assistant Project General Manager
P. Halstead, Manager, Quality Control (QC)
C. Welch,.QC Supervisor
R. Spangler, Corporate Quality Assurance (QA) Supervisor
J. Walker, Corporate QA Auditor
J. Marshall, Licensing
J. Hicks, Licensing
M. Strange, Supervising Engineer, Support & Project, TUGC0 Nuclear
,
Engineering (TNE)
!
J. Ryan, Technical Service, Supervisor
S. Ali, TNE QA Staff Engineer
B. Jones, Unit 2 Supervising Engineer, Civil / Structural
R. Hooten, Project Discipline Engineer, Civil / Structural
J. Hoagson, Computer Operator Supervisor, PMCS
Contractor Personnel
W. Baker, Welding Engineer, Brown & Root (B&R)
W. Wright, Welding Engineer, B&R
G. Purdy, Site QA Manager, B&R
J. Gore, Subcontract Supervisor, B&R
K. Thornton, Warehouse Superintendent, B&R
C. Osborne, QA Vault Supervisor, B&R
D. Leach, TNE-QA-B&R
K. Norman, Central Operations Supervisor, DDC-B&R
D. Bleeker, DCTG Supervisor, B&R
R. C. Iotti, Project Manager, Ebasco
A.' Smithey, Supervisor IRV, B&R
R. Walters, ASME QA Supervisor, B&R
-
1
-
G. Maedgen, Welding Engineer, B&R
T. Gray, Document Control Manager
.P. Patel, Unit 1 Civil Lead, THE Design, Gibbs & Hill
B. Jones, Expediting Supervisor, B&R
L. Barnard, PMG File Clerk, B&R
- ~
T. McCormack, Fire Protection Engineer, Impell
S. Felman, Assistant Project Engineer, SWEC
H. Moscow, Supervisor Projects & Services, NY, SWEC
s
,
J.--Tate, 304 DU Satellite Supervisor, B&R
J.'Junge, 311 DU Satellite Supervisor, B&R
J. Womack, 300/301 DU Satellite Supervisor, B&R
-
r
,
,
,
d
L
l
..
5-
>a
o
~
,
'
4_
>
R. Flaherty, 307 DU Satellite Supervisor, B&R
S. Hazle, 310 DU Satellite Supervisor, B&R
J. Day, 308 DU Satellite Supervisor, B&R
J. Dickey, DCC Area Supervisor, Engineer Satellites, B&R
S. Bruce, DCC Area Supervisor, Craft Satellites, B&R
2.
Plant Tours
i
At various times during the inspection period, NRC inspectors conducted
general tours of the reactor building, safeguards building, and the
y
electrical and control building.
During the tours, the NRC inspector
observed ongoing construction work and discussed various, subjects with
personnel engaged in work activities.
No violations or deviations were identified.
3.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant
a.
The applicant's procedures pertaining to Significant Deficiency
Analysis Reports (SDARs) were reviewed to determine how the process
!
of deficiency identification through completion and signoff is
controlled.
Reviews were performed of site Procedures CP-QP-15.6,
Revision 3, "SDAR Status Tracking"; CP-QP-16.1, Revision 6,
"Significant Construction Deficiencies"; CP-QP-17.0, Revision 1,
" Corrective Action"; and TUGC0 Procedures DQP-CQ-4, Revision 1,
" Reporting of Significant Deficiencies"; 'DQP-QA-12, Revision 2,
" Administration and Tracking of Significant Deficiency Analysis
, ,
Reports'; and DQP-QA-11, Revision 1, " Corrective Action."
i
Procedures CP-QP-15.6, CP-QP-16.1, DQP-CQ-4, and DQP-QA-12 do not
address the SDAR file contents or provide a method for completion and
signoff of the required corrective action.
Procedures CP-QP-17.0 and
DQP-QP-15.6 address the documentation required'for closing
deficiencies, but there is no cross reference between SDAR/ corrective
action with respect to SDAR file contents.
This is an unresolved
ite.n pending completion of NRC review of SDAR procedural adequacy
(445/8514-U-02; 446/8511-U-01).
b.
The applicant classified the following reportable SDAR files as
" Licensee Action Complete": SDARs CP-84-27, CP-84-29, CP-85-04,
CP-85-05, CP-85-11, CP-85-12, CP-85-13, and CP-85-14. The above
files did not document or reference the location of documentation
which would support the reported status of corrective actions being
complete.
Consequently, the NRC inspector did not perform a field
,
verification for any of these files.
.
^
c.
The following nonreportable SDAR files were selected for review,
l
since the applicant classified these as " Licensee Action Complete":
,
I
}:
a
_
.
,
__
_ _ _ _ _ _ _
[ <~*
-
_,
,
'
"
.
< , ,
,
,
,
'
.
.
,
-5-
V
f
'.
.
,
.
'
'
(1) (Closed): The NRC inspector reviewed the following SDARs:
.
,
CP-84-05, CP-84-22, CP-84-23, CP-84-24, CP-84-26, CP-84-32,
'
CP-85-02, CP-85-08, and CP-85-09.
The applicant's evaluation
'
and decision that these SDARs are not reportable appeared to be
'
correct.
,
(2) (0 pen): The NRC inspector reviewed SDARs CP-84-30, CP-84-34, and
CP-85-06. The files for these SDARs did not contain sufficient
information or. documentation to determine whether or not the
SDAR was nonreportable.
._
The status of the files is an unresolved item pending the
I
completion of a TUGC0 effort to make the files complete and
'
subsequent NRC review (445/8514-U-03; 446/8511-U-02).
4.
Applicant Action on Previous NRC Inspection Findings
a.
(Closed) Unresolved Item (445/8422-U-02): Inverter transformer common
failure.
The-NRC inspector reviewed the applicant's handling of the
defective transformers and concluded that the actions taken to
evaluate and correct the deficiency were correct and adequate.
The applicant's handling and reporting of significant deficiencies
will continue to be monitored by the NRC inspectors.
b.
.(Closed) Violation (445/8307-V-01):
Excessive welding gap. In 1983,
the NRC inspector identified an unacceptable fitting on pipe support
Mark No. SW-1-102-106-Y33K.
Recently, the NRC inspector followed up
and reviewed NCR M5123-5, RPS 751947, WDC80668, related sketches, and
inspection report's (irs).
Corrective work was accomplished and QC
performed required inspections.
An engineering analysis of the
installation which was performed in response to the violation showed
strength was far in excess of minimum design requirements, even
though it violated the procedure.
In B&R memo -IM 325,208 dated
'
. April 13, 1983, supervision reemphasized the requirement to follow
,
procedures'to all affected personnel.
l
c.
(Closed) Violation (445/8315-01): Failure to write an NCR on base
metal repair.
This violation concerned an instance where the NRC
-
inspector observed a minimum wall violation for which a NCR had not
' u
'beenl written.
On October 8 and 9, 1985, another NRC inspector
.
reviewed this violation of paragraph 3.3.3 of site Procedure
QI-QAP-16.1-2, Revision 4, dated May 20, 1982.
The scope of'this
-
D
'
',
procedure was changed to make further reference to system walkdown
'and the item in question was accomplished near this time frame.
.
.
.
However, the applicant responded by' documenting the questioned.
-
minimum wall violation and the repair of the adjaceiit weld on a
f
i
_
'
f
,
'
'
< <
a
.
.
,
h
!
'
1 -
I
<
a
-
.
-6-
common NCR (M6611). These conditions had been found by separate NDE
methods, one before and one after the base metal repair. The NRC
inspector reviewed two more recent base metal repairs to verify that
the problems had been corrected. One repair performed in 1984 was
found to have been in compliance with the then current procedures.
The second repair was completed, reviewed, accepted, and
documentation sent to the vault during September and October of 1985.
This~second report showed an original weld completed, reviewed, and
accepted in January and February 1985.
Rework was performed on this
weld in September 1985 due to interference with a hanger installation
which resulted in a minimum wall violation.
Further work to repair
the hang 3r was classified as a " Major Weld Repair" in accordance with
paragraph 3.3 of B&R Procedure CP-CPM-6.9G; however, no NCR was
generated. This failure to document a minimum wall violation en an
NCR is a repeat violation of Criterion XV of Appendix B to
10 CFR Part 50(446/8511-V-01).
It was noted that the inspector and the preparer of the repair
process sheet had recently received training on the newly revised
procedures involved which required the NCR be generated. The
Assistant Project Welding Engineer who reviewed the repair process
sheet had not been so trained on the procedure, as he had been
exempted from the training by virtue of his position.
d.
(Closed) Unresolved Item (446/8502-01): Responsible welding
supervisors not familiar with welding rod control procedures.
In
1985, the NRC inspector interviewed supervisors who were not familiar
with welding rod control procedures which their crew of welders were
responsible for implementing. The training program for supervisors
was conducted in May 1985 and covered helpers through general
foremen.
In 1984/85, the NRC Technical Review Team (TRT) extensively reviewed
and inspected weld rod control and documented their findings in
NUREG-0797, Supplemental Safety Evaluation Report (SSER) 10, Category
9.
In addition, the RIV inspector inspected weld rod control during
this inspection period and identified no violations or deviations,
e.
(Closed) Unresolved Item (445/8323-07):
Incomplete Class V(5) pipe
supports record package.
In 1983, the NRC reviewed packages which
1
had been combined into finalized packages.
In 1984, the TRT reviewed
a random sample of 11 Class V(5) support record packages. This
'
review showed that packages with irs (by qualified inspectors) were
j
in proper order. The TRT found the records satisfactory as reported
on page N-252 of NUREG-0797, SSER 10 dated April 1985.
j
f.
(Closed) Unresolved Item (445/8347-01):
Containment surface area
coating. This item addressed sloughing of protective coatings on
L
,
.
-7-
Westinghouse supplied items.
In SSER 9, NRR staff state they have
reasonable assurance that debris generated by the failure of all
coatings inside the containment building under design basis accident
conditions will not unacceptably degrade the performa r e of
post-accident fluid systems.
This was based on TUGC0 and other
studies referenced in NUREG-0797, SSER 9 on pages L-17 and L-18.
. requires in SSER 9 that a preoperational and postoperational coatings
program be proposed by TUGCO, but this specific issue of sloughing of
coatings on Westinghouse items is closed based on the SSER 9
conclusions.
g.
(Closed) Violation (445/8416-V-02): Failure to provide controlled
issuance of design documents and changes thereto.
Between May and
June 20, 1984, an NRC inspector found that design documents and
changes were not controlled by Operations Document Control Center
(DCC). On October 11 and 14, 1985, the NRC inspector confirmed that
the computer system and terminals referred to in the TUGC0
November 1, 1984, response were in place and in use.
The NRC inspector reviewed 12 Design Change Authorizations (DCAs) and
Component Modification Cards (CMCs) and followed the distribution of
25 packages to 9 locations for various disciplines and verified
corrective action.
These DCAs and CMCs were traced in their routing
~
at the central DCC and then on to the Paperflow Group or satellite
.
DCCs and a review performed of how they are distributed from those
'
locations. All items checked were distributed per DCP-3, Revision 18
(with Document Change Notices (DCNs) 1, 2,
and 3),-with the
L
following exceptions:
(1) CMC 96181, Revision 1, was issued on October 8, 1985, and
i
satellite DCC 307 (craft) picked it up at central DCC. The ChC
was not signed for as required by paragraph 3.1.1.1 of DCP-3,
Revision 18, with DCNs 1, 2, and 3.
There was a similar
occurrence on CMC 75003,
Revision 2, as issued to satellite DCC
"
202/211 (TUGCO). Further, DCA 21446, Revision 1, was issued
October 8, 1985, and satellite DCC 307 was in possession of it
on October 14, 1985.
One of two packages for brawing
2323-El-1702, Sht 002, Revision 2, had both Revision 0 and
Revision 1 of DCA 21446 in it, with the other having only
-
Revision C in it.
Both Revision Os were not stamped " VOID" as
required in paragraph 3.2.2.5 of DCP-3.
On October 14, 1985, satellite DCC 307 issued Drawing
2323-El-1702, Sht. 002, Revision 2, to an electrician for
-
'
Class IE field work with Revision 0 of DCA 21446, rather than
the current Revision 1, which is contrary to the requirements of
paragraph 3.2.1.2 of DCP-3. On October 14, 1985, TUGC0 and B&R
cupervision contacted the electrician who indicated he had
l
-
- -
-
- - -
- -
- -
.
-
-
w
-
_
,
_ O _.
, o
.
-8-
,
k
gotten sheet 002 rather than sheet' 001 by mistake and had
returned it immediately without installing anything to it.
These failures to follow design document control procedures are
a violation of Criterion V of Appendix B to 10 CFR Part 50
(446/8511-V-02).
-
(2) The following examples were noted of practices being followed
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
4
_
computer printed "Open Design Change Log."
(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 items built to a drawing,
a single item utilizing the drawing, c,r no further use of
the change.
Drawing 2323-5-0910, Sht. CSR-2A, Revision 12,
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
have NI input and it showed as open on the terminals.
This
would require it to be included with the drawing package in
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
i
described in internal uncontrolled guidelines.
This item is
unresolved pending incorporating the guidelines into a
controlled procedure (446/8511-U-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
i
.
>
>
, .
l
.
-9-
control an'd inventory.
In Appendix IA(N) and 1A(B) of Final Safety
Analysis Report (FSAR) Volume 1, Section 1.0, the applicant commits to
Regalatory 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, 11th Draft, Revision 0, dated
January 17, 1973.
On page 1A(B)-36 in the Discussion, the. applicant makes
no exceptions to this standard.
A brief description of QA records is
,
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;
_
446/8511-0-04).
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 Flan,
,
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
ingineering 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 remote, 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 such records can be transferred to the construction
'
PPRV where Unit I reccrds are now stored.
TUGC0 Procedure
,
L _
CP-QP-18.6, Revision 2, discusses records turnover from B&R IRV to
TUGC0 PPRV but does not address the issues raised above. Also, these
I.
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.
..
i
t
u
_
.
-10-
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; 446/8511-0-05).
b.
Storage and Transmittal of Design Records to SWEC, New York: On
October 16, 1985, an NRC inspector was inspecting an open item
previously identified as unresolved item E226-U-07.
As a result, the
requalification package for pipe support CC-1-107-008-E23R was
requested and the NRC inspector was informed that this design records
package had been included in a total of 5702 (4654 for Unit 1, 1048
for Unit 2) hanger packages that had been shipped to SWEC, New York,
for a complete reevaluation.
The NRC SRRI interviewed the TUGC0 engineering supervisor who
answered questions about whether procedures controlled such shipment,
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 TNE 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
November 1985, according to SWEC Supervisor Project Services, New
York. The utility has taken corrective action that includes (1)
making duplicate copies prior to shipping, and (2) all records
initially sent to SWEC are being copied and a copy returned to the
site.
Region IV is pursuing with IE Headquarters, QA Branch the
minimum protection that should be 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
V 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 for copying. 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
is considered an open item (445/8514-0-01; 446/8511-0-01).
-
-
.
-
-
-
-
'
.
-11-
d.
Inspection of Storage 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 not the Draft 11,
Revision 0 version; PPRV; IRV; Paper Flcw Group storage areas for
Unit 2 mechanical and electrical; and the orocurement 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 1 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
'
l
controlling temperature and humidity.
The NRC inspectors noted
l
that a water sprinkler system had been installed in this
facility.
This presents a concern because those plant records which are
stored in folders or binders in open faced cabinets will be
deluged with water and will likely deteriorate.
An additional
consideration is that records stored in a manila folder may be
washed out and possibly clog the drain in this facility, leading
I
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
facility has controlled access.
It meets the design features
for a pernanent facility, as described in Section 17.1.17 of the
FSAR; however, the NRC inspector had the following comments:
(a) There is no fire suppression system inside this vault.
Two
hand-held extinguishers and a 2-inch fire hose are located
outside the vault.
One hand-held extinguisher is located
i
- ~ ~ ~
--
- - - - -
9
.
.
&
.9 .
w
'
,
-12-
.,
inside the vault.
Fire' detectors and alarms are inside to
, .
alert the onsite fire department if a fire occurs.
<
'(b)
IfEthe.2-inch fire hose is used to extinguish a fire,:the
vault may flood becaute there are no fire drains and the
floor is not sloped.
Therefore, water may potentially
~
enter the bottom cabinet drawers.
(c) NCRs and corrective action reports were stored in binders
in bookcases.
If fire hoses are used, these documents
would probably be subjected to the force of water from the
hose and damaged.
Therefore, it would be desirable to
store these records in closed containers.
All other
records were stored in nonfire rated cabinets which is
,
acceptable if located in a permanent facility that meets
ANSI N45.2.9 requirements.
The failure to install a fire suppression system, drains, and a
sloped floor appears to be a deviation from ANSI N45.2.9
requirements. However,
this item is unresolved because this
facility is described in FSAR Section 17.1.17.
Region IV is
forwarding this issue to IE Headquarters, QA Branch for
clarification (445/8514-U-08; 446/8511-U-08).
(3) IRV - This area is not a separate building, but is actually part
of the permanent vault that has been set aside as an interim
storage area prior to placing records in the area designated for
permanent records.
This area has an access point that is
separate from the permanent area and is controlled.
The
facility is the same as the permanent area, except a wall
separates the two.
They share the same forced air system.
This
!
facility generally meets the requirements of 10 CFR Part 50,
Appendix B, and ANSI N45.2.9; however, the NRC inspector had the
following comments:
(a) Water had been leaking through the forced air system and
beside a support girder.
In a second location,
approximately 2-3 gallons of water had leaked in through
the forced air ventilation duct and was caught by a
container placed under the duct.
This is considered an
open item (445/8514-0-02; 446/8511-0-02).
(b) The NRC inspector observed a coffee pot, sugar, and
evidence of food on a table adjacent,to the vault area.
,
These were immediately removed from the vault by the
utility.
s
4
%
.
- m
-
.
-
-
~
.,
,
,e
-
.
.
,
J
'
-13-
(4) Paoer Flow Groups - The 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
that the records are maintained in fire proof cabinets. The NRC
inspectors found that there are some records stored in
,
,s
-
nonfire-rated file cabinets.
This matter is considered
unresolved (445/8514-U-09; 446/8511-U-09).
'
(5) Storage 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 aust be stored in fire-rated
,4
'
cabinets.
This item is unresolved pending identificatfan and
(
4
>
l:
des:ription of this facility and indexing of records recently .
,
'
received,from the TUGCO, Dallas, Texas, office to determine what
1
-
records must be in fire rated cabinets (445/8514-U-10);
'
446/8511-U-10).
<
l
'
'
'
i
6.
Audit of QA Record Systems / Facilities
-
,,
The NRC inspector asked if the unacceptable QA records storage and control
7
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.
. requires that periodic audits shall be performed to assure facilities are
in good condition and temperature / humidity controls and protective devices
are functioning properly.
.
An Ebasco review or study dated June 16, 1981, page 4 of 25, item g,
states with respect to the PPRV, "It is an established fact that the QAR
vault does not meet the requirements for a single storage facility and
.that duplicate files are not maintained in lieu of single storage." On
0ctober 23, 1985, the NRC inspector requested documentation which would
,
~show action taken in response to the Ebasco finding. TUGCO's Project and
. , '
~
QC organizations had no such documentation.
This item is unresolved
r
~
pending review of the response to this audit finding (445/8514-U-11;
446/8511-U-11). . The NRC inspector asked PPRV personnel if B&R had audited
'
lF
the record . keeping / facility system and was informed that it 5as been
several years since B&R had performed such audits.
Th'is item it
unresolved pending the review of B&R audits (44E/8514-U-12;
i
'446/8511-U-12).
,
-
.
w
s
r
!.
.
3;y--
-
-
. . -
7
,
b
"
'-14-
, 7.
Control of Weld Filler Material
^
This inspection was performed to determine wheth'er safety-related weld
filler material purchase, storage,.and distribution are in accordance with
~
the applicant's work and QA procedures, and applicable ASME code
requirements.
Implementation of the following procedures was examined
during the inspection:
.
CP-QAP-8.1, Rdvision 9, dated October 15, 1984, " Receiving
.
Inspection";
CP-CPM-6.9B,' Revision 2,' dated September 21, 1984, " Weld Filler
.
Material Control"; and
CP-CPM 8.1, Revision 3, dated July 2, 1985, " Receipt, Storage, and
.
Issuance of Items."
-
The following areas were examined:
,
a.
Procurement:
Four purchase order packages which consisted of the
purchase order, procurement specification, and field requisitions
were inspected to verify that orders were properly approved and
included required technical, packaging, and documentation
requirements as specified in site procedures pertaining to weld
filler material purchases.
No violations or deviations were identified.
,
b.
Receivina Inspection:
Receiving inspection records, for the filler
material purchased to the procurement documents inspected, were
examined to verify that all items required by Attachment 11
(Receiving Checklist) to CP-QAP-8.1 had been inspected.
In each
case, the checklist and a receiving inspection report had been
completed and signed by a Level II QC inspector.
In several
instances, NCRs had been completed and material returned to the
vendor as required by procedures.
Certified Material Test Reports
(CMTRs) for each purchase were also reviewed to verify that required
inspections and tests had been 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 corresponded to what was shown on the
CMTR.
No violations or deviations were identified.
- c.
Main Storage Areas:
Two' filler material storage areas located in
i
Warehouse A were inspected for compliance with the above listed
procedures. One area was designated as a Quality (Q) area and the
?
i
+
J,
,
y
t
-
-15-
.
other one was both a Q and Non-Q area.
The Non-Q material was
'
segregated as required from the Q material.
Procedures in the
storage areas appeared to be adequately implemented; however, the NRC
had the following observation:
Paragraph 3.2.1 of CP-CPM 6.9B requires that Q weld filler material
original containers be marked upon receipt and during storage with
s
.
the material classification, size, and heat / lot number.
In the Q
area, labels on several containers of Sandvik welding products (weld
ro'd) had fallen off and others were loose.
The material was still
identifiable, because of the storage bin marking and marking on the
shipping carton; however, a loss of identification is possible when
material is removed from the storage area.
There were also several
unopened cartons of Sandvik material whose status could not be
determined.
Loose or missing labels were identified on the following
material; Lot 101172-2, 1/8 inch, AWS/ASME SFA 5.4; and Lot 10149-1,
'
5/32 inch AWS/ASME SFA 5.4.
This matter has been referred to B&R '
Welding Engineering for followup,
d.
Distribution Stations:
Weld rods used in safety-related applications
are distributed from three areas (Rodhouse 2, 3, and 4).
Each
distribution station was inspected to verify compliance with
requirements of CP-CPM 6.9B in the following areas:
Storage facility (Level B);
.
Identification of material;
.
!
Controlled access into storage areas;
.
Control of stationary and portable rod ovens;
.
Issuance, return, and accountability of material; and
.
Completion and control of records.
.
Label problems were also noted in Rodhouse 4 during th's inspection.
8.
Cable Tray and Equipment Walkdown
During this inspection period, the NRC inspector performed a walkdown
inspection of selected electrical components and cables to determine the
degree of protection of class IE items from surrounding construction
activities.
The general level of protection appears adequate with the
exception of the B Safety Train Diesel engine control panel (20G02A).
The
visqueen covering had come loose in several spots allowing concrete dust
from above to filter into the panel and settle on some of the installed
relays.
,
I
&
%
0
1
..
-
.
..
.
.
_
.
a
&
,
-16-
'
In the area of. cables, it was noted that cable ends were neatly coiled and
the ends taped, cable tags.were in place and cable jacket repairs were
clearly marked.
At one point in the Safety Train B switchgear room, a
cable exiting a tray and entering the.switchgear (cable No. C23G 06070
. above the HVAC chiller No. 14.) appeared to be bearing hard on the square
section of the cable. tray side. ladder at its exit point.
In other places
.>
~
where cable exits tray, a piece of discarded cable jacket is used as a
buffer. The observed point had no such buffer.
-
,
~
No violations or deviations were indentified.
/
.9.
. Unresolved Items
Unresolved items are matters for.which more information is required in
order to ascertain whether they are acceptable items, violations, or
,
deviations.
Twelve unresolved items disc'osed during the inspection are
discussed in paragraphs 3.a, 3.c, 4.g, 5, 5.a. 5.c, 5.d, and 6.
10.
Exit Interview
,
l
f
An exit interview was conducted November 1,-1985, with the applicant
i
. representatives identified in paragraph 1 of Appendix E.
During this
interview, the NRC inspectors summarized the scope and findings of the
l
inspection. The applicant acknowledged the findings.
.
e
w
$ .
$ ,
e
'
'
-
.
f
r
,
e
.x.
a
-
-n
- - - - - - - - - - - - - - - - - - . --