IR 05000445/1979012
| ML19208D581 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/1979 |
| From: | Crossman W, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19208D579 | List: |
| References | |
| 50-445-79-12, 50-446-79-12, NUDOCS 7909280641 | |
| Download: ML19208D581 (8) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No.
50-445/79-12; 50-446/79-12 Docket No.
50-445; 50-446 Category A2 Licensee:
Texas Utilities Generating Co.
2001 Bryan Tower Dallas, Texas 75201 Facility Name:
Comanche Peak, Units 1 & 2 Investigation at:
Comanche Peak Steam Electric Station, Glen Rose, Texas Investigati.on
' ducted:
April 12 through July 20, 1979 Y.
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Inspectors:
piR.G. Taylor,ResidentReactorInspector Date Projects Section Other Accompanying Personnel:
P. Bachi, Investigator, IE:HQ Approved:
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lW. A. Crossman, Chief Projects Section Date Investigation Summary:
Invesy gation on April 12 through July 20, 1979:
(Report 50-445/79-12; 50-446/79-12)
Area Investigated:
Special investigation of allegations received regarding improper implementation of a random radiographic program for determining welder performance.
The investigation involved fifteen inspector-hours by the Resident Reactor Inspector nnd the IE:HQ Investigator.
Results: The allegations concerned a program not required by the NRC nor otherwise committed to in the Final Safety Analysis Report.
The allegations, while possibly true, are not within the jurisdiction of the NRC as enforcement matters.
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INTRODUCTION Comanche Peak Steam Electric Station (CPSES), Units 1 & 2, are under construction in Somervell County, Texas, near the town of Glen Rose, Texas.
Texas Utilities Generating Company is the Construction Permit holder with Brown and Root, Inc.
as the Constructor and Gibbs and Hill, Inc. as the Architect / Engineer.
REASON FOR INVESTIGATION The Region IV Reactor Construction and Engineering Support Branch office received a telephone call from a Texas District Attorney in regard to a potential break-down in the CPSES Quality Assurance Program.
SUMMARY OF FACTS On April 12, 1979, the Region IV Reactor Construction and Engineering Support Branch received a telephone call from a party who identified himself as a District Attorney located in Stephenville, Texas. The District Attorney stated to the Chief, Projects Section, who took the call, that a person had approached him with certain allegations relative to CPSES.
It was further stated that the person had been an employee of Brown and Root, Inc. at CPSES until recently.
The allegations as received were:
a.
The alleger had been made a supervising documentation clerk, a position the alleger did not consider the alleger to be qualified for on the basis of experience or education.
b.
Welders were not certified for doing 1, 2, or 3 spots.
c.
The alleger was directed to falsify reports.
The above information was referred for followup to the CPSES Resident Reactor Inspector (RRI).
The RRI made arrangements through the District Attorney to interview the alleger. The interview was accomplished on April 26, 1979, in the private law offices of the District Attorney in Stephenville, Texas.
The RRI was accompanied by an investigative specialist employed by the NRC in a headquarters assignment. The District Attorney opened the interview by explain-ing that he was attending the interview as the personal attorney for the alleger rather than in his capacity as a District Attorney.
The alleger began by stating that a position of employment had been sought and taken with Brown and Root at CPSES for the purpose of determining first-hand whether various stories about site operations were true or false.
If true, the alleger indicated a grave concern for the health and safety of the alleger's family and home.
The alleger stated that the positivn occupied was in the Brown and Root Welding Engineering Section and covered a period of several weeks.
The allegations, as defined during the interview, were:
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a.
The alleger was hired and assigned to a position in welding engineering in an essentially clerical activity.
The alleger indicated that tha position had substantial responsibilf / but that no authority was givea to the alleger to carry out the functions of the position.
b.
The alleger stated that the position involved keeping records of welds accomplished by each welder and randomly selecting welds for radiographic examination. The record log sheets for each welder contained twenty entry spaces. Sometime during the accumulation of tuenty velds, the alleger selected a weld and sent a memorandum to tha welder's geacral foreman designating the selected weld and welder.
The general foreman was then to make arrangements to have the selected weld radiographed and in turn notify the alleger of the results. When the results were negative, i.e.,
the weld was defective, the alleger was to select a second weld from the same group of twenty and again notify the general foreman to have that weld radiographed.
The alleger stated that the general foreman frequently ignored the memoranda to the extent that some welders were never tested and that the second request was in some instances also ignored.
The alleger stated that some welders never made an acceptable weld but were not retrained and requalified as required by the program.
The alleger stated that instructions to " fake it had been given by c.
supervision after the supervision had asked for a welder performance report and the alleger pointed out several reasons, including allega-tion b., as to why the report could not be generated.
d.
The alleger, without making further allegations, raised the following additional issues during the interview:
(1) Was it possible that Brown & Root implemented the quality program relative to radiography in other safety systems not in the random program in a manner comparable to the implementation in random program?
(2) Was it possibic that the alleged poor implementation of the random radiographic examination program could result in an unsafe condition during operation of CPSES?
The alleger indicated that allegation a. related to b. and in turn to c. in that the alleger felt that the alleger should have been given the authority to make the program function as intended.
CONCLUSIONS The following conclusions relate to items a.
through d. above as expressed during the initial telephone contact and the subsequent interview on April 20, 1979:
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a.
Allegation a., as originally received and as further amplified during the interview, could neither be subatantiated nor refuted.
Based upon the District Attorney's description of the alleger's background, it appears that the alleger may have beca over qualified for the position rather than under qualified. The matter of responsibility coupled with authority is also a very subjective area.
The alleger's responsibilities were derived responsibilities actually vested in the Chief Welding Engineer while the authority for rigorous adherence to the randon radio-Eraphic program is largely vested in the Mechanical Department General Superintendent or even in the Brown & Root Prcject Construction Manager.
The authorities and responsibilities are so substantial as to make it difficult for the RRI to envision that they could reasonably be vested in a single, largely clerical, position such as that occupied by the alleger.
b.
This allegation was in effect substantiated since the methods of accom-plishing production piping system welding are not compatible with concept of the random radiographic examination program the alleger was invclved in.
The randon program was conceived as a method of gaging the perfortance of individual welders by radiographing 5% of each welder's work. This would require that as soon as a given welder completed his assignment on a selected joint, the joint would have to oc radiographed before another of the usually several welders resumed welding on the joint.
In practice, the joint selected for random radiographic examinatien is not selected until all of the required welding is complete thus making it very difficult to determine which welder may have created any indicated defect observed in the radiograph.
Even though the allegation appears to have been sub-stantiated, it cannot be considered as an item of noncompliance with NRC requirements since the NRC has no requirements in this area. Neither is it a deviation to commitments since the random radiographic program is not in any manner discussed in the CPSES Safety Analysis Report nor is it an element of the licensee or Brown 0 Root Quality Assurance program.
The program must then be considered a production management tool that the production management can do whatever they wish to with, c.
The alleger was apparently directed to develop a report for Brown & Root production management that would give a picture of each velder's per-formance based at least in part on data developed by the random radio-graphic program. Since the program had not been f mplemented in a manner to fulfill the originally intended purpose, the report could not contain meaningful information.
The alleger was apparently told to do the best the alleger could do with the available data, hence " fake it."
d.
The following comments apply to the alleger's expressed concerns:
(1) The NRC requires, through adopted codes and standards, that all safety Class 1 and 2 welded pipe connections be radiographed to determine the acceptability of the weld.
Individual welder performance is not a factor in this determination.
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Monthly inspections by the RRI, during the past year, a _ several inspections by other IE inspectors have verified effective irple-mentation of these requirements since welding in this class of systems was initiated.
(2) The random radiographic program had some possibility for enhance-ment of safety and reliability of CPSES had it been implemented as intended in concept. Such enhancement, however, would have applied only to safety Class 3 and nonsafety systems where the NRC, again through adopted codes and standards, does not require radiographic examination of welds.
The RRI, to an extent, shared the alleger's concern relative to safety Class 3 velds and braught this concern to the attention of licensee nanagement. After con-sultation with his Architect / Engineer, the licensee determined that some 2200 valds, in selected Class 3 systems, will be fully radio-graphed and repaired to the extent required, an effort which will take the next several months.
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DETAILS 1.
Persons Contacted Nonlicensee or Contractor Employees The Alleger: A former employee of Brown and Root, Inc., at CPSES.
ihe Alleger's Attorney:
The District Attorney for the State of Texas with jurisdiction in several counties including Sauer-vell County.
Principal Licensee Employees Project General Manager Site QA Supervisor Brown & Root, Inc., (B&R)
Construction Project Manager 2.
Interview of April 20, 1979 The RRI explained to the alleger that the program, for which the alleger was maintaining records and randomly selecting welds for radiographic examination, was not a program required by the NRC through accepted standards, Codes or a Quality Assurance Program as described in the Comanche Peak Safety Analysis Report.
The program, which required radiographic examination of one weld in twenty made by each welder (5% of each welder's work) f.
evaluation of welder performance in Class 3 piping systems, was not within the jurisdiction of the NRC inspection program.
Consequently, the RRI pointed out that the licensee could not be in noncompliance with NRC requirements through failure to properly implement the program.
The alleger, without making further allegations, questioned the integrity of B&R in the Safety Class 1 & 2 piping systems where all butt welded connections are radiographed.
Could B&R be disregarding proper program implementation in this area? The RRI explained that he and other NRC inspectors routinely monitor this activity and had found no evidence of improper or negligent implementation. The RRI also explained the involve-ment of the Authorized Nuclear Inspectors in the safety related piping systems QA program.
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The alleger expressed a concern that the welding in the Class 3 and other piping systems might be so poor as to render these systems unsafe. Thia concern, the alleger indicated, was based on the records of welders that had been maintained by the alleger. The RRI explained that the sys ems had been designed in accordance with NRC requirements and where necessary, redundancy had been provided to preclude total system failure caused by a single failure.
The RRI stated that in the matter of the Clast 3 welds the licensee was fulfilling all present commitments.
3.
Subsequent Actions Between April 20 and 24, 1979, the RRI discussed the random radiography program and Class 3 system welds with the licensee representatives denoted in paragraph 1.
The RRI indicated that the random program did not appear to be functioning as a welder performance indicator since several welders generally work on any given joint and therefore inadequate performance of one or more welders could not be distinguished and corrected. The RRI pointed out to the licensee that since high radiographic rejection rates had been experienced in the fully radiographed Class 2 system welds he may want to consider evaluation of the welds in Class 3 systems in this regard.
During meetings with the licensee representatives on July 19 and 20, 1979, the RRI was informed by the licensee that he and his Architect / Engineer had reached the following conclusions:
a.
The random radiographic program has certain weaknesses which will be corrected to the extent economically possible. The program will be continued on Class 3 systems, except as discussed below, and on nonsafety class systems.
b.
The engineer has identified the steam generator Auxiliary Feed-water and Component Cooling Water systems as having functions that are nearly as essential to reactor safety as the Class 2 systems in certain reactor failure modes. The balance of the Class 3 piping systems are less essential.
c.
Statistically, a substantial majority of the rejected welds in the Class 2 sy;tems have been those welds made in the field, i.e.,
within the facility buildings, as distinguished from those made in either the on-site or off-site fabrication shops where more ideal welding conditions prevail.
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d.
Based on items b. and c., the licensee has directed B&R to radio-graph all field welds made to date and all future field welds in the Auxiliary Feedwater and Component Cooling Water systems. The radiographs will be interpreted by B&R welding engineering personnel and by a representative of licensee's A/E who is also a welding engineer. The radiographic acceptance criteria provided to the RRI is comparable to ASME Code requirements.
Welds found unacceptable under the criteria will be repaired and reradiographed. The licensee estimates that approximately 2200 field welds are involved in this effort.
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