ML20237L407
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See also: IR 05000445/1985007
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* ARLINGTON TEXAS 76011 -
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JAN 2 319BT
MEMORANDUM FOR: John G. Davis, Director
Office of Nuclear Material Safety
and Safeguards
FROM: Robert D. Martin, Regional Administrator, Region IV
SUBJECT: ERPATA REPLACEMENT SHEETS FOR REGION IV ASSESSMENT OF COMANCHE
PEAK OIA IDENTIFIED TECHNICAL ISSUES
In the haste to complete the Region IV assessment of the OIA Comanche Peak
identified issues, several typographical errors were left uncorrected. If
convenient, please insert the attached replacement pages. An Errata Summary is
also provided. /
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Robert D. Martin
Regional Administrator
Enclosures:
As stated
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B708200209 970312
PDR ADOCK 05000445
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PDR
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ERRATA SUFFARY . _ _
1. Report 85-07/85-05
Page 12 - last line.
Change: 50-445/50-84-32
To: 50-445/84-32
Page 21 - line 11
Change: complition
To: completion
Page 29 - last line
Change: form
To: from
Page 30 - line
Add closing quotation marks after components.
2. Peport 85-14/85-11
Page 2 - paragraph 3, line 1.
Replace with: There is no safety significance to this issue.
Page 16 - line 1.
Replace with: There is no safety significance to this issue.
Page 36 - line 9.
Change: than
To: then
Page 41 - last line. J
Change: not !
To: no
3. Report 85-16/85-13
Page 2 - line 13.
Change: addede
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To: added
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Page 3 - line 12 ;
Delete of i
. 1
Page 3 - line 16
Delete that
Page 6 - paragraph 2, line 2
Change: 44/85-14
To: (a45/85-14
Page 30 - line 3 ,
Change: hanoles l
To; handle j
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j - . Report 85-07/85-05 l
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Following Regional managements review of the initial version and based on
discussions with the inspector, the issue was changed to an unresolved
iteminthesecondversionofthereport(Attachment 4). It remained
! unchanged in the final issued inspection report.
3. Safety Significance of the Issue
This issue was found to have no safety significance.
The Region IV management position was that an audit of the reactor vessel
installation was not specifically required. 10 CFR 50 Appendix B,
Criterion XVIII, " Audits," requires audits of activities, such as
mechanical installation, but does not prescribe which specific activities
must be audited. j
In reviewing the Traveler ME-79-248a5500 (Attachment 1) for installation
of the reactor vessel, Regional management also found that the TUGCo QA
manager had witnessed and signed step 11 of the traveler. It should also be
noted that the previous NRC senior resident inspector had witnessed the
reactor vessel installation. Nearly every step of Traveler
ME-79-248-5500 required QC to verify, witness or write an inspection
y
report.
As a result of NRR Technical Review Team activities as described in
SSER 11 and the findings of the NRC Regicn IV in Inspection
Report 50-445/84-32, it was already determined that TUGCo audits
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Report 85-07/85-05
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valves and vessels, the furnished product is not complete with respect to
functional purpose ur.til after installation into a piping system.
Application of an NPT symbol by a certificate holder prior to any
hydrostatic test being perfomed does not constitute a violation of
NA-8231 (See Attachment 18), in that NA-8231 (a) permits to application
of a code symbol after hydrostatic test, if,the hydrostatic test is a
Code requirement. As discussed above, the referenced Code applies to
hydrostatic testing of components, which by definition do not include
piping subassemblies. Similarly, NA-8231 (b) is not applicable in that it
pertains to substitution of a system hydrostatic test for a component
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hydrostatic test. Application of the NPT symbol and completion of the
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NPP-1 form indicates that fabrication has been performed by an.ASME
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Certification holder and that Code rules for fabrication and examination
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have been complied with, including those applicable to other Authorized
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E Nuclear Inspectors.
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M Region IV management believes these interpretations to be proper and would
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M refer the panel to Mr. Bosnak, Chief of the Pechanical Engineering Branch,
NRP., as the staff expert on the Code for further verification. Regional
management put the inspector into contact with Mr. Bosnak to discuss this
h
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H issue. In reviewing Mr. Phillips OIA testimony, page 113, it appears
that Messrs. Q and Phillips had talked to Mr. Bosnak earlier on
this same issue. Regional manacement was not informed of the results cf
h
b that conversation.
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Inspection Report 50-445/85-07; 50-446/85-05
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Item 7
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1. GIA Statement of the Issue (See Attachment MM)
None
2. Expanded Description of the Issue and Related~ Background Information
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The basic issue as understood by Region IV management is as follows:
The NRC inspector { ]found that the NPP-1 form certified that
the cold leg subassembly met requirements of ASME, Section III, 1974
Edition through Winter of 1975, and the FSAR, Table 5.2-1 specified ASVE,
Section III, 1974 Edition through Summer 1974. He considered this
discrepancy as an unresolved item.
This issue was initially identified in the first version of Inspection
Report 50-445/85-07; 50-446/85-05 (Attachment 3), as an unresolved item in
report paragraph 14. c. (2). It appears the same in the second version
report (Attachment 4) as report paragraph 14.c.11. After receiving
comments from NRR and OGC and based on additional review by Pegional
management, the item was remcVed from the final inspection report.
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Report 85-07/85-05
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l 3. Safety Significance of the Issue
This issue was found to have no safety significance.
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The second version of the inspection report, which was sent to NRR and OGC,
resulted in a comment from G.'Aizuno, OGC, requesting the Region to
determine if the reactor coolant cold leg pipe was in conformance with
10 CFR 50.55a, " Codes and Standards." Regional management, in followup
to OGC's coment, found that Section 3.2 of the FSAR " Classification of
Structures, Components and System" states in. Note 1, with regard to
Table 3.2-1 (Reactor Coolant System) "Later Code revisions may be
used optionally in accordance with 10 CFR E0.55a." The NRC letter of
July 3, 1985, from V. S. Noonan to M. D. Spence (Attachment 20) was
reviewed by Regional management. It states that as of July 3,1985, "The
most recent version of 10 CFR 50.55a, dated March 30, 1984, approved the
editions of Section III of the ASME Boiler and. Pressure Vessel Code,
through the 1980 Edition end Addenda through the Summer 1982, and is only
applicable to Code Class 1, 2, and 3 components." The reactor coolant
cold leg pipe is a Code Class I system. Regional management discusseo
the Codes and Standards Rule, the FSAR commitments, and the NRR July 3,
, 1985, letter with OGC. It was concluded by Regional management that there
! was no violation of 10 CFR 50.55a; however, there was a conflict in the
FSAR. Amendment 57 to the FSAR has been submitted, which revised the-
FSAR (Table 5.2-1). From the review of Mr. Phillips OIA testimony,
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pages 133 and 134 it appears as stated by Mr. phillips that he and
Mr g had earlier called Mr. R. Bosnak, Chief of the Mechanical
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Report 85-14/8S-Ik
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This issue was initially docurnented as a violation in draft 1 of the
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construction inspection report, paragraph 5 (Attachment 1) input to NRC
Inspection Report 50-445/85-14; 50-446/85-11. As indicated in
Mr. Phillips' " Matrix of Drafts for Rpt 85-14/11(appendix"D"),"
(Attachment 2) draft 2a, paragraph 5 (Attachment 3), was revised (in the
inspector's handwriting follwing discussion with Regional management) to
an unresolved item. It appears at: an unresolved item in draft 3a,
paragraph 5 (Attachment 4) and in issued NRC Inspection Report 50-445/85-14;
50-446/85-11 (Attachment 5).
.
3. Safety Significance of the Issue
There is no safety significance to this issue.
There is no hardware issue, only a d'fference in opinions as to the degree
of detail required for NRC previously reviewed and accepted (through
SSER 6) FSAR, Chapter 17.1.17 description of records.-
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The inspector apparently believed that a more detailed description of the
records system should have been contained in the FSAR, Section 17.1.17.
Regional management concluded that the FSAR description was adequate.
It is significant to note that the Office of Inspection and Enforcement
had performed a review of the TUGCo QA program, as documented in
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Chapter 17.1.17 for a plant based on both the criteria in existence at
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the time the construction permit for CPSES was submitted, and also based
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There is r.o safety significance to this issue.
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The CB&I records in question were for the Unit 2 reactor containment
i liner and mechanical penetrations. CB&I as a-subcontractor to Brown and
Root conducted the containment liner erection activities on site. CB&I
maintained their own independent temporary storage area on site for QA
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records in accordance with their own QA program, which was approved and
audited by Brown and Root and TUGCo. The CB&I records were never in the
possession of TUGCo during construction of the containment liner. All
CB&I records were, however, available for TUGCo review. CB&I was
contractually committed to adherence to 10 CFR 50, Appendix B and
,
ANSI N45.2.9. In accordance with the CB&I " Nuclear Records Procedure"
NRC-1 (Attachment' 13), on completion of the erection and engineering
activities, all records are indexed and sent with inventory to the CB&I
Nuclear Records Vault for storage and microfiching. The procedure
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recommends that records sent to the Nuclear Records Vault be placed in
suitable containers after first wrapping with plastic or sen'e other
waterproof material. The procedure allows the use of corrugated
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cardboard for small shipments and wood for larger shipments.
After processing at the Nuclear Records Vault, a set of records is sent
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from the Nuclear Records Vault to the owner of the project (e.g., TUGCo) l
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with a letter of transmittal identifying the items sent and recuesting
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signed acknowledgement.
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Report 85-14/85-11
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Unit I records were the first to be assembled. No records were
withdrawn from the Permanent Plant Records Vault for Unit 1.
In July 1984, the Unit 2 paper flow grcup was established. Work packages
for Unit 2 were assembled on the component level. A significant number
of documents were removed from the Permanent Plant Records Vault to
become a part of the component level work package for Unit 2 paper flow
group. The component level work packages and associated documents were
considered an in-process document until a particular work package was
complete. These were then forwarded to the Interim Records Vault, then
to the Permanent Records Vault. This process was in full operation when
the NRR Technical Review Team was on site. Regional man 1gement was
informed by TRT member Vic Wenzel (consultant to NRR) that the reference
to documents in lockable fire-proof cabinets in SSER 11 pertained to ASME
documents for which the N-5 walkdown had not been completed. These were
still considered in-process documents.
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The scope of ANSI N45.2.9, Revision 11 states, "It is not intended to cover
the preparation of the records, nor to include working documents not yet
designated as quality assurance records." TUGCo QA Procedure CP-QP-18.4,
Revision 5, " Quality Assurance Record Receipt Control and Storage"
(Attachment 8) states, "A document is considered a quality assurance
record and shall be controlled as required by Reference 1-E when the
document has been transmitted to the Permanent Plant Records Vault." l
Documents taken out of the Permanent Plant Records Vault yere considered
to be in-process since they became a part of a working ' document that had
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The violation was dropped by the inspectors (H. Phillips and
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in draf t 4a, paragraph 7c. This was confirmed in a memorandum from I.
Barnes to E. Johnson, dated June 10,1986(Attachment 20).
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4. Region IV Management Handling of the Issue
This violation was dropped by the inspector. This is appropriate since
the issue has no safety significance.
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Report 85-16/85-13
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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and
Drawings." The inspector was of the view that Criterion V and
ANSI 45.2.9 would require the licensee, in the file which contained
copies of their 50.55(e) reports to NRC, to have copies of the records
which tracked the corrective actions taken by the licensee on the issue
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in each of those reports or, alternatively, to provide a list of
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references to the same records.
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This issue was initially identified in draft 1.a. paragraph 3,
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(Attachment 2) as a violation of Criterion V, " Instructions, Procedures,
and Drawings." In draft 2a, paragraph 3a (Attachment 3), the issue is .
documented as unresolved. In draft 3, paragraph 4, paragraph 2f,
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(Attachment 5) the items remained unresolved but information concerning
the TUGCo commitment to upgrade files by March 1,1986, was added. It
remained unresolved in the final report.
3. Significance of the Issue
There is no safety significance *o this issue. ,
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~10 CFR 50.55(e) is a reporting requirement for significant deficiencies
identified during construction or design activities and does not
j specifically address record keeping requirements. ANSI N45.2.9,
Revision 11 designates only the 50.55(e) report itself as a permanent
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record.
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Report 85-16/85-13
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The applicant's quality assurance program requires that conditions
adverse to quality be identified and corrected as called for in
Appendix B to 10 CFR 50. The records identifying those conditions and
attesting to the corrective actions taken relative to those deficiencies,
such as nonconformance report:;, TUGCo Nuclear Engineering Design Deficiency
Reports, design changes and the like, are quality assurance records and
are maintained in accordance with ANSI 45.2.9. These records would be
maintained in whatever filing format the licensee chooses to use. There
are no regulatory requirements that specify the content or cross-indexing
protocol these files should utilize. Prudent records management
principles would suggest the adoption of systems which establish record
file content suitable to the licensee's needs, but there are no
specific requirements in this area. It has long been a practice of IE
and its predecessors that NRC will not require records to be kept in a
i ! form only for the convenience of NRC inspectors.
It should be noted that, the 2512 program includes the review of
50.55(e) reports as part of the inspection program. Since the NRC
inspection efforts on these must be completed prior to reaching a
licensing ' decision, it clearly would be prudent fer a licensee to have a
cross reference in the 50.55(e) file to the related QA records to
facilitate NRC inspection and his own audits. If this prudent course in
not adopted, the licensee runs a risk of slower NRC closecut of these
reports with a concurrent risk of delays in the issuance of an operating
license.
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. i Report 85-16/85-13
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Inspection Report 50-445/85-16; 50-446/85-13
Item 2
4
1. OIA Stathment of the Issue (See Attachment MM)
Issue Resolution in Final Report
2. Failure to revise implementing Violation Downgraded
procedure containing 50.55(e) to unresolved
reporting. (445/8516-U-01;
446/8513-U-01).
2. Expanded Description of the Issue and Related Background Information
The OIA statement of resolution is incomplete. This item was originally
an unresolved item in a previous inspection report (445/85-14; 446/85-11).
The inspector proposed to cite the licensee during this inspection.
Regional management concluded that this item should remain unresolved.
The basic issue as understood by Region IV management is as follows:
The inspector (H. Phillips) believed that the failure to revise all
associated implementing procedures prior to issuance of corporate
f procedure NE0 CS-1, " Evaluation of and Reporting of Items / Events Under
10 CFR 21 and 10 CFR 50.55(e), was a violation of 10 CFR 50, Appendix B,
Criterion V, " Instructions, Procedures, and Drawings."
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because TUGCo had no procedure which described the construction
organization responsibilities or how the construction organization was
to handle IE Bulletins requiring action or established a specific
" construction IE Bulletin focal point coordinator" that TUGCo was in
violation.
Initially in draft 3, paragraph 5 (Attachment 4), the inspector
identified this issue as unresolved. In draft 4, paragraph 4, Regional
management replaced the inspector's paragraph with a paragraph which
indicated that TUGCo had committed to perform a review of related
procedures and records to determine adequacy of the procedures and
completeness of associated records as an unresolved ite:a. ,
3. Safety Significance of the Issue
Regional management concludes that there is no safety significance to
this issue. Management viewed the actions of the inspector as
establishing requirements for which there was no regulatory basis.
The Nuclear Operation Engineering Manual, Procedure N0E-205, Revisiori 1,
(October 1985) " Licensing" ( Attachment 15), clearly established
responsibilities within the TUGCo organization for handling IE Bulletins
requiring action. In summary:
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