IR 05000445/1980022
| ML19341C902 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/21/1981 |
| From: | Digaloma T, Driskill D, Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19341C896 | List: |
| References | |
| 50-445-80-22, 50-446-80-22, NUDOCS 8103040455 | |
| Download: ML19341C902 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Investigation Report No. 50-445/80-22 50-446/80-22 Docket Nos. 50-445, 50-446
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Licensee:
Texas Utilities Generating Company Facility:
Comanche Peak, Units 1 and 2 Investigation at:
Glen Rose, Somervell County, Texas Investigation Conducted:
September 8-11, 1980 and November 6-7, 1980 Investigator:
$3kt_h i h4 kN 0. D h ill, InvestTgation Specialist
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Investigator:
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T. L. DiGaloma,_ Investigative Aide (Co-op)
Date Reviewed by:
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Karl V. Seyfrit, Dir3c r, Region IV Date Summary Mvestigation on September 8-11 and November 6-7, 1980 (Report Nos. 50-445/80-22; 50-446/80-22)
Area Investigated:
Allegations were received by NRC that Brown & Root Quality Assurance Department was not ensuring that corrective action was being taken regarding documented nonconformances, that nonconformance reports (NCR) were being disapproved and the numbers issued for the respective disapproved NCR drafts were being reused, and that discrepancies identified in vendor manufac-tured components were being waived, by direction of a Texas Utilities Generating Company (TUGCO) QA auditor, in order that the equipment could be shipped to Comanche Peak Steam Electric Station (CPSES).
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Results The allegation that Brown & Root (B&R) QA Department was not ensuring that corrective action was being taken regarding documented nonconformances was not substantiated.
Investigation of the allegation that NCR'r were discpproved and the numbers issued for those NCRs were being reissued was substantiated; however, B&R had recently, prior to this investigation, issued a new procedure requiring that all disapproved NCRs retain their number and be maintained on file.
Investi-gation identified one instance wherein a vendor, Chicago Bridge & Iron (CBI),
Salt Lake City, Utah, manufactured components which were disapproved for shipmenc to CPSES, due to deficient manufacturing, were waived and shipped to CPSES.
The allegation that a TUGC0 QA auditor instructed waivers be prepared on noncon-forming components was not substantiated.
NRC inspection report (Notice of Violation) 50-445/80-20; 50-446/80-20, details the unsuitable weld surface con-ditions identified on the components which were delivered to CPSFS by CB _
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INTRODUCTION Comanche Peak Steam Electric Station (CPSES) Units 1 and 2 are under construction in Somerv' ell County, Texas, near the town of Glen Rose, Texas.
Texas Utilities Generating Company (TUGCO) is the construction permit holder with Brown & Rent, Inc. (B&R) as the constructor and Gibbs & Hill, Inc. (G&H) as the architect /
engineer.
REASON FOR INVESTIGATION On August 13, 1980, the Nuclear Regulatory Commission HQ's Duty Officer receivee a telephone call from Individual A who related various personal concerns regard 11g fabrication of pipe hangers and other safety related aspects of construction at CPSES, Glen Rose, exas.
SUMMARY OF FACTS Subsequent to the previously iden6f fied telephone call from Individual A, he was telephonically contacted on August 13, 1980, by Mr. W. A. Crossman, Chief, Projects Section, Reactor Construction ar.d Engineering Support Branch, Region IV, NRC.
During this interview, Individual A related various general concerns relating to quality and material traceability regarding fabrication of pipe hang-ers for CPSES and the termination of a CPSES QC inspector by Brown & Root, Inc.,
under unfair circumstances.
Individual A additionally related the following specific allegations:
1.
Between February and June, 1980, QA Site Surveillance S-009 was conducted anu numerous instances of nonconformances were identified.
Corrective Action Report (CAR) 41 was issued in response to S-009; however, no corrective action has been taken.
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In June, 1980, a vendor audit at Chicago Bridge & Iron Company, Salt Lake City, Utah, determined that required NDE procedures were not being accomplished in the manufacture of "Q penetrations."
These noted discre-pancies were allegedly waived by a TUGC0 QA auditor in order that the penetrations could be shipped to CPSES.
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Nonconformance Reports are being disapproved by a site QA supervisor and the NCR numbers issued to those respective NCR drafts are then reissued.
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A vendor inspection at Gulfalloy, Inc., identified that firm was sucplying weldolets of S160 material that have no heat number traceability.
An Audit Deficiency Report was submitted and a TUGC0 auditor instructed that the deficiency be waived in order that the materials could be shipped to CPSE i
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Individual-A was interviewed on August 22, 1980 at the Region IV, NRC, Office, Arl..igton, Texas, at which time a sworn statement relating to the above allegations was obtained.
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Persons Contacted Licensee Employees J. Hawkins, Project QA Manager, TUGC0
- R. Tolson, Site QA Supervisor, TUGC0
- D.
Chapman, QA Manager, TUGC0
- J. George, Vice President, Project General Manager, TUSI Other Persons Contacted Individuals A through F
- Denotes those attending exit interview.
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Investigation of Allegations Allegation No. 1 Between February and June, 1980, QA Site Surveillance S-009, was conducted and numerous instances of nonconformances were identified.
Corrective Action Report (CAR) S-41 was issued in response to S-009; however, no corrective action has been taken.
Investigative Findings On August 22, 1980, Individual A was interviewed and stated that between February and June, 1980, B&R QA personnel had conducted QA Site Surveillance S-009 which related to pipe hanger fabrication and installation for American Society of Mechanical Engineers (ASME) : ode applications.
Individual A stated this surveillance had identified numerous instances of material nonconformances which were later identified on CAR S-41 for corrective action.
Individual A stated no corrective action has been taken to date regarding these nonconformance items.
Review of QA Site Surveillance S-009 On September 9, 1980, QA Site Surveillance S-009 was reviewed.
S-009 reports inspections of pipe hanger fabrication materials and installation and documentation relating to the respective procedures involved in the manufacture and installation of the hangers.
S-009 identifies 35 instances of material nonconformances, the majority of which relate to the absence of required material traceability numbers and/or inadequate material traceability procedures.
Review of CAR S-41 On September 9, 1980, CAR S-41, dated June 9, 1980, was reviewed.
S-41 states "During ASME QA surveillances, S-003 (4-23-80) and S-009 (6-2 to
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date, 1980) identification of numerous discrepancies indicates there are significant generic problems in implementation of procedural and specifi-cation requirements." CAR S-41 goes on to identify 24 individual NCRs which were issued as a result of findings in surveillances S-003 and S-009.
CAR S-41 was forwarded to the " hanger group" with a " reply due date" of June 23, 1980.
Reinterview of Individual A i
On September 10, 1980, Individual A was reinterviewed and stated that 11 NCRs were prepared regarding material nonconformances during the period S-009 was being conducted.
Individual A stated that the remaining 24 identified nonconformances listad in S-009 were prepared based on the findings listed in that surveillance report.
Individual A stated that, to date, he is aware of no corrective action being taken regarding the 35 NCRs.
Interview of CPSES QA Supervisor On November 11, 1980, Individual B, a CPSES QA supervisor, was interviewed.
Individual B stated personnel have been assigned to work on corrective action relating to CF S-41.
Individual B stated the assignment of these duties resulted from the determination that satisfactory corrective action had not yet been taken regarding the NCRs on CAR S-41.
Individual B stated these unresolved nonconforming conditions primarily consisted of " house-keeping" problems which may result in CAR S-41 remaining open for a long period of time.
Individual B stated CAR S-41 has been recently revised and Field Deficiency Reports (FORs) relating to similar "nousekeeping" pro-blems were added to it.
Individual 8 stated that CAR S-41 has not been ignored and will not be in the future.
Allegation No. 2 In June, 1980, a Brown & Root vendor audit at Chicago Bridge & Iron Company (CBI), Salt Lake City, Utah, determined that the required NDE procedures were not being accomplished in the manufacture of "Q penetrations." These noted discrepancies were waived by a TUGC0 QA auditor in order that the penetrations could be shipped to CPSES.
Investigative Findings On August 22, 1980, Indiviaual A was interviewed and stated that in about June, 1980, a B&R vendor audit was conducted at CBI, Salt Lake City, Utah, at which time the B&R auditor determined that CBI had not accomplished the required NDE procedures in the manufacture of a number of "Q penetrations."
Individual A stated that the auditor's inspection of the Q penetrations determined that they contained slag and crater cracks, not in conformance with applicable NDE procedures.
Individual A stated the B&R auditor pre-pared an Audit Deficiency Report (ADR) concerning the noncompliances which i
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would make mandatory the correction of the noted deficiencies prior to CBI shipping the penetrations to CPSES.
Individual A stated that subse-quently a TUGC0 auditor had waived the deficiencies on the penetrations in order that they could be shipped to CPSES.
Interviews of B&R Personnel On September 9, 1980, Individual C, a B&R Procurement Supervisor, was contacted and advised that the equipment identified as deficient dering the June 1980, CBI audit, identified by Individual A as "Q Penetrations,"
were actually moment restraints and not Q penetrations.
Individual C stated the B&R Project Quality Assurance Manager had waived all deficien-cies identified concerning the moment restraints in order that they could be shipped to CPSES.
Individual C denied being aware of any corrective action planned regarding the moment restraint deficiencies, which would be effected upon their arrival at CPSES.
On September 19, 1980, Individual 0, a B&R QA Engineer, was interviewed regarding his June 1980, audit at CBI.
Individual D stated that in June 1980, fabrication of the moment restraints was reportedly completed by CBI and they were ready for shipment to CPSES; however, the project QA manager (at that time) had insisted a release inspection of the moment restraints be conducted prior to shipment.
Individual D stated that an annual B&R QA audit of CBI was due at that time and D was selected to go to CBI to conduct both the audit and release inspections.
Individual D stated inspection of four of the moment restraints at CBI disclosed various unsuitable weld surface conditions which were unacceptable.
Individual 0 stated CBI management was advised that the moment restraints would not,be approved for shipment.
Individual D related having prepared audit defi-ciency reports (ADR) regarding the unacceptable conditions identified on the moment restraints which would require correction of nonconforming conditions.
Individual D stated that in about August 1980, the current CPSES Project QA Manager had shown them a copy of a CBI response to the ADR which basically stated that the unsuitable weld surface conditions, identified in the ADR, would not interfere with proper interpretation of the NDE.
Individual 0 stated this CBI response took exception with the inspection findings and was not approved.
Individual D stated that 0 has not, to date, been again contacted regarding any corrective action on the moment restraints.
Lastly, Individual D related having no knowledge of a TUGC0 auditor having instructed that the deficiencies be waived in order that the moment restraints could be shipped.
On Septemoer 10, 1980, Individual B was reinterviewed concerning B's knowledge regarding the waiver of deficiencies on the moment restraints.
Individual 8 stated that normally a vendor will notify B&R 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to shipping fabricated companents and equipment to CPSES.
Individual B stated B then prepares a B&R vendor surveillance document relating to the shipment and takes it to a QA supervisor who either directs that release inspection be conducted prior to shipment or waives inspection in order that
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the item may be shipped.
Individual B stated that the QA supervisor had
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waived the inspection of the moment restraints, knowing that the deficiencies were outstanding.
Individual B stated an assumption that the QA supervisor intended that an inspection of the restraints would be conducted upon their
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arrival at CPSES.
Individual B stated that if the moment restraints were not found acceptable, upon their arrival, they would be repaired on site or returned to CBI for repair.
On September 11, 1980, Individual E, a B&R Quality Control Receiving Inspector, was interviewed.
Individual E stated E's duties require that E inspect received components / equipment; however, E's inspections relate only to the scope of requirements included in thte purchase order and would not include any other technical QC inspection.
Individual E furthermore stated E would not be aware of ADRs reported regarding any specific item.
Individual E related having received no special handling instructions regarding the CBI manufactured moment restraints and they would be issued to the construction personnel, subsequent to their receipt, if they met specification requirements in the purchase order.
Review of CPSES/8&R Procedures t
On September 11, 1980, a review of B&R/CPSES QA procedures relating to
both vendor audit and vendor manufactured components release inspections i
was conducted.
This review determined that:
(1) no CPSES procedure was i
implemented prior to August 1980 providing guidance regarding vendor audit i
and vendor manufactured components release inspection.
QA/QC personnel at CPSES utilized the B&R corporate QA procedures manual as guidance at
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that time.
It provided for audit deficiency reports being used for adverse j
audit findings and NCRs for adverse product inspection findings.
(2) On
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August 6, 1980, B&R CPSES procedure CP.QAP 18-4, entitled " Vendor Qualifi-l cation and Surveillance" was issued.
Review of this procedure disclosed it provided no mechanisms for reporting of product deficiency during the surveillance action.
Selective Examination of Moment Restraints t
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l On September 11, 1980, subsequent to receipt of information indicating the subject moment restraints had arrived at CPSES, a selective examination of the components was conducted by the NRC resident inspector, Individual D, and the investigators at CPSES.
The NRC resident inspector judged that there was validity to the allegation that the CBI manufactured components contained unsuitable weld surface conditions.
Subsequent to September 11, 1980, the NRC resident inspector made arrangements for, and had conducted, visual and metallurgical testing examinations of the selected components.
NRC Inspection and Enforcement Report (Notice of Violation) 50-445/80-20; 50-446/80-20, reports findings that on
" September 17, 1980, the NRC Resident Reactor Inspector, in conjuction with other NRC Inspectors, selectively examined four of the ninety-five components received at the site under subcontract 35-1195-0585 and noted
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discrepant conditions.
The examination, conducted in accordance with Procedures MT-3 and MT-4, revealed indications that were considered unacceptable in accordance with the criteria contained within the re-ferenced CB&I procedures.
Specifically, the welds in components...
were not sufficiently free from coarse ripples, grooves, overlap, abrupt bridges and valleys to render the surface suitable for proper interpreta-tion of the required magnetic particle or liquid penetrant examination.
This is an infraction."
Allegation No. 3 Nonconformance reports are being disapproved by the site QA manager and the NCR numbers issued to those respective NCR drafts are then reissued.
Investigative Findings On September 22, 1980, Individual A was interviewed and stated that the site QA manager frequently disapproves NCR crafts submitted by QC inspec-tors.
Individual A stated that the NCR number issued by the NCR clerk is then reissued for use on another NCR.
Individual A stated that the dis-approved NCR is returned to the initiating QC inspector.
Individual A stated that there is no procedure available which would allow the QC inspector to appeal the disapproval and no permanent record is maintained relating to the disapproved NCR.
Review of NCR Log On September 10. 1980, the B&R QA Department NCR Log was reviewed for the year 1980.
The NCR log is designed to sequentially identify, by NCR number, each NCR and provide various items of information relating to each respective NCR, such as the " issued" dated and the " disposition clo-sure" date.
Examination of the B&R NCR log noted numerous instances wherein the chronological order (dates issued) was not maintained, giving the impression that the NCRs, although listed sequentially, were not issued chronologically.
In most instances, the chronology varied only several days; however, a review of NCRs issued between June 1 and August 18, 1980 disclosed 19 NCRs which were issued seven or more days out of the normal chronological order.
Review of Acolicable Procedures On September 10, 1980, a review of applicable TUGC0 and B&R pro:edures related to handling of NCR's was conducted.
TUGC0 procedure numoer CP-QP-16.0 stated "The cognizant Quality Control Engineer may disposition an NCR to state 'Not a Nonconforming Condition' or similar wording.
He shall provide justification for such a disposition.
When a NCR is dis-positioned in this manner, the original is forwarded to the Permanent
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Plant Records Vault A review of B&R QA Procedure CP-QAP-16.1,
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entitled " Control of Nonconforming Items" was examined and found to
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provide no guidance relating to handling of a disapproved NCR.
B&R QA Procedure CP-QAP-16.2, dated August 28, 1980, was found to introduce specific instructions relating to the disapproval of an NCR and states
"The B&R Site QA Manager or his disignee may disposition a NCR to state
'Not a Nonconforming Condition' or similar wording.
He shall provide justification for such a disposition.
When an NCR is dispositioned in this manner, the original is fcrwarded to the Permanant Plant Records Vault....
In no case may a NCR number be issued, voided, then re-issued."
Interview of NCR Coordinator On September 10, 1980 Individual F, a B&R NCR Coordinator, was interviewed regarding the practices utilized for issuance of NCR numbers.
Individual F related having worked for B&R at CPSES for about 4-1/2 years and having worked as the NCR coordinator for about 13 months.
Individual F stated that while an NCR coordinator and while having the responsibility for issuing NCR numbers and maintenance of the NCR log, it had been a normal practice to reissue an NCR number subsequent to the disapproval of the NCR to which it had been formerly assigned.
The individual stated the disapproved NCRs were returned to the issuing QC inspector and not main-tained in B&R files.
It was also stated that this procedure was utilized by two former QA managers as well as the prM ent QA manager.
The individual did point out that, for approximately three months, from about November 1979 through January 1980, an acting QA manager had required that disapproved NCRs be forwarded to the records vault and maintained with their assigned NCR number.
When questioned regarding the quantity of NCR numbers reissued, Individual F stated that in recent months there have been very few; how-ever, prior to the sun.mer of 1980, a great many NCRs were being regularly issued, therefore, turnaround time for the reissuance of NCR numbers was shorter due to a greater emphasis being placed on NCRs, simply by virtue of their volume.
When queried concerning the chronological order relating to the issuance of NCRs, Individual F stated that when a QC inspector prepares an NCR, he obtains an NCR number from Individual F.
Individual F stated that the NCR number and related data were noted on a blackboard; however, the NCR is not entered in the NCR log until "F" receives the approved draft.
Individual F then enters the date when the NCR draft is received as the date " issued" for the NCR number.
Individual F stated that this practice accounts for the variation in chronological order for NCRs in the NCR log.
Individual F pointed out that a new QA procedure was issued on August 28, 1980, which specifically states that disapproved NCRs will be forwarded to the records vault and, under no circumstances, will an NCR number be reissued.
Finally, Individual F stated the B&R procedure used formerly to control NCRs was folicwed.
Individual F stated that Revision 3 of the August 28, 1980 procedure, would alter the policy formerly followed.
Individual F claimed to not be awore of the TUGC0 QA manual or its provisions for maintaining disapproved NCR,
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Interview of a QA Supervisor On November 7, 1980, Individual B, a CPSES QA Supervisor was interviewed.
Individual B stated that 8 assumed the duty as a CPSES QA Supervisor in August 1980, and at that time B was not aware NCR numbers were being reissued.
Individual B stated B had never personally disapproved any NCR without discussing it with the preparing QC inspector.
Individual B stated that when the practice of reissuing NCR numbers was brought to B's attention, in August 1980, a revision to Comanche Peak Quality Assurance Procedure 16.1 was prepared instructing that disapproved NCRs retain their NCR number and be maintained in the CPSES records storage vault.
Lastly, Individual 8 stated B was unaware that the CPSES procedure, regarding control of NCRs, conflicted with the TUGC0 procedure regarding NCR number accountability.
Allegation No. 4 A vendor inspection at Gulfalloy, Inc., identified that firm was supplying weldolets of S160 material that had no heat number traceability.
An Audit Deficiency Report was submitted and a TUGC0 auditor instructed that the deficiency be waived in order that the materials could be shipped to CPSES.
Investigative Findings On August 22, 1980, Individual A was interviewed.
Individual A stated that in the summer of 1980, Individual D, a member of the B&R QA Department, CPSES, had conducted a vendor audit at Gulfalloy, Inc., Houston, Texas, and found Gulfalloy had been supplying weldolets of S-160 material which had no heat number traceability.
Individual A stated Individual D had sub-mitted an audit deficiency report concerning this shortcoming, however, a TUGC0 QA auditor had directed that the deficiency be waived in order that the weldolets could be delivered to CPSES.
Interview of Individual 0 On September 10, 1980, Individual 0 was interviewed regarding the vendor inspection at Gulfalloy, Inc., Houston, Texas.
Individual D stated the July 9-10, 1980 inspection at Gulfalloy was to inspect their compliance with B&R QA procedures, B&R purchase order requirements, and ASME com-pliance for finished products which were ready for shipment to CPSES.
Individual 0 stated the inspection of items disclosed three discrepancies relating to sockolets (vice weldolets, as alleged).
Individual 0 pro-vided a copy of the inspection report which identified these discrepancies as (1) No certificate for material test report, (2) physical demensions of fittings and CMTR do not correspond, and (3) heat lot number fitting and CMTR do not correspond.
Individual D related having no knowledge re-garding disposition of these discrepancies, and stated D had never heard t
that a TUGC0 QA auditor directed the discrepancies be waived.
In-dividual D stated that if such directions had been given, D would be aware of it.
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Review of B&R Records
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On September 10, 1980, a review of B&R records was conducted with the assistance of Individual D to ascertain the disposition of audit deficien-cies reported subsequent to the July 9-10, 1980 vendor inspection at Gulf-alloy.
This review disclosed documents from Gulfalloy which resolved each of the aforementioned deficiencies by substantiating that each was the result of an administrative recordkeeping error rather than any material deficiency.
Also located were B&R receiving department quality control inspection reports for these items which confirmed each was received at CPSES in conformance with all applicable QA, ASME and purchase order criteria.
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