ML17326B547
| ML17326B547 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/09/1988 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML17326B543 | List: |
| References | |
| AEP:NRC:1074, NUDOCS 8903090434 | |
| Download: ML17326B547 (17) | |
Text
mol3nd nllonlgJn Powor Company P,Q. Box 1663'otumbos,OH 43216 flag.
INDIANA NICHIGAN POWER AEP:NRC:1074 Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 ALLEGATIONS FROM A FORMER MAINTENANCE WORKER U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 September 9,
1988
Dear Mr. Davis:
Mr. E.
G. Greenman's letter of August 10, 1988, detailed several allegations from a former maintenance worker who had been employed at the Donald C.
Cook Nuclear Plant by Catalytic Industrial Maintenance Company (CIMCO).
The results of our investigation concerning the allegations are provided as an enclosure to this letter.
This enclosure is considered exempt from disclosure according to CFR Part 2 Title 10 Section 2.790 of the NRC's Rules of Practice, and we therefore request that this information not be placed in the NRC Public Document Room.
On August 24,
- 1988, NRC Resident Inspector Bruce Jorgensen advised W.
G. Smith, Jr. that the third item in Allegation No.
1 could be ignored.
He was advised by your office that a Region III Inspector had resolved t.hi issue during an inspection trip to the Cook Nuclear Plant.
8q03090434 8+o>~08><5 PDR ADOCN, 0500 G
Mr. A. Bert Davis AFP:NRC:1074 This document has been prepared following Corporate procedures
'hich incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, Vice President edg Enclosure cc:
D.
H. Williams, Jr.,
w/o encl.
W.
G. Smith, Jr.
- Bridgman, w/o encl.
R.
C. Callen, w/o encl.
G.
Bruchmann, w/o encl.
G. Charnoff, w/o encl,.
NRC Resident Inspector
- Bridgman, w/o encl.
ENCLOSURE 1 TO AEP:NRC:1074 ALLEGATIONS FROM A FORMER CIMCO MAINTENANCE WORKER
Pag
- 1074
(
'I I
I
'1\\1 RESPONSE" TO ALLEGATIONS (R-111-88-A-0053)
ALLEGATION NO.
1 I
During a maintenance operation which involved removal of a manway cover on either the number 2 or 3 steam generator in Unit 2, bolts for the cover broke as a result of the improper use of air-and/or motor-operated tools.
This apparently occurred during a Unit 2 outage in the Spring of 1987.
Review and disposition of these allegations should include the following information:
o An evaluation of the use of air/motor-operated tools by CIMCO during steam generator maintenance.
Please review the circumstance surrounding the allegedly broken bolts and address specific actions taken in regard to the alleger's concerns.
o An evaluation of the circumstances surrounding the alleged failure to drain the steam generator as required by the Radiation Work Permit.
o An evaluation of the use of respiratory equipment during steam generator maintenance.
Please address any changes in your policy which may have occurred between the alleged instance in 1982 and the present.
RESPONSE
o On March 10,
- 1987, the Cook Nuclear Plant Construction Department removed primary manway covers on Unit 2 steam generators (SG) Nos.
21, 22, 23 and 24 in support of SG primary side activities.
Removal of manway cover bolts is a generic problem throughout the industry.
Five bolts did in fact have to be drilled out.
The procedures for removing and replacing manway bolts is documented and follows accepted industry practice.
The use of air or hydraulic powered impact tools are also industry accepted methods for removal of manway bolts.
Details of the evaluation of the use of air or hydraulic powered tools by CIMCO is contained in Attachment 1 to this enclosure
.(Internal Memo, Steam Generator Manway Bolt and Bolt Holes, dated April 2,
- 1987, to the file).
Further corrective actions were taken during a refueling outage in the fall of '1987.
Attachment 2 to this enclosure (American Electric Power Service Corporation Mechanical Engineering Division Trip Report dated September 15-29, 1987) details SG Primary Manway Bolt Hole Inspection and Repair.
A review of this report reveals that we are aware of manway bolt problems and have an active program to track and maintain records of such problems.
A search of appropriate 1987 Control Room Reports, Condition Reports, Safety Event Reports, Licensing Event Reports and Radiation Work Permits resulted in no information about failure to drain a steam generatc
AEP:NRC:1074 o
This allegation wa resolved by a NRC Region III Inspector and reported to Cook Nuclear Plant Manager W.
G. Smith, Jr. by the Plant Resident Inspector, Bruce Jcr'gensen on August 24, 1988.
ALLEGATION NO.
2 Following tne August 25, 1987 layoff, CIMCO only reta'ned inexperienced people who were not qualified'o" their jobs.
CIMCO used people from a gas di tribution plant and "instead of redlining drawings, CIMCO's got a young foreman who's learned political survival."
o An evaluation of the experience requirements used by CIMCO in their hiring process.
RESPONSE
was contacted and interviewed in the presence of The following is the policy of CIMCO:
It is CIMCO's policy that the employment according to existing agreement, such as General
- Foreman, Foreman, etc.,
comes under THE GENERAL PRESIDENTS'ROJECT MAINTENANCE AGREEMENT.
Article II states in part:
"Management right - The Union understands that the Contractor is responsible to perform the work required by the Owner.
Therefore, the Contractor has the complete authority and right to:
+
Plan, direct and control the operation of the work.
+
Decide the number of employees required.
+
Hire and lay off employees as the Contractor feels appropriate to meet work requirement and/or SKILLS required.
+
Name the foreman.
+
Transfer employees with special SKILLS.
+
Determine the need and number of foremen."
In August of 1987 CIMCO retained a young foreman
(
Local
¹190) and laid off (Local ¹190).
and all the pipefitters craft that CIMCO retained were MORE than qualified for the work that CIMCO was performing.
is, at this time, a
Catalytic Supervisor on another job site.. All of CIMCO's pipefitters are trained to 12 MHP 5080 SP.001.
This document established the program used to provide training to CIMCO supervisory and craft personnel.
Pipeficters are trained in the following Cook Nuclear Plant Procedures:
PMI-2220 System Internal Cleanliness PMS0.037 Concrete Drilling Permit PMS0.075 Opening of Possible Press.
Lines 12 MHP.5021:001.031-"-
Fire-Barrier-'Penetration Seals
Page 3
12 MHP 5021.001.033 12 MHP 5021.001.063 12 MHP 5021.002.005 12 MHP 5021.001.064 AEP:NRC:1074 Anchor Bolts Install.
& Fab. of Component
- Supports, Hangers,
& Restraints Steam Generator Manways Instrument
& Control Air Install.
ALLEGATION NO.
3 Employees can purchase drugs in the plant parking lot.
Urine samples can be purchased for the Fitness for Dutv program and the collection of the urine sample is not monitored.
Cranber"y juice is used by plant employees to thwart Fitness fo'r Duty testing.
o An evaluation of the alleger's concerns regarding the availability of drugs in the plant parking lot and the subversion of the Fitness for Duty testing program.
RESPONSE
o An investigation by Cook Nuclear Plant was completed by Duty (FFD) is an approved Cook Nuclear the same laboratory, as Cook Nuclear plant uses employees.
- Security, Report No.
CIMCO's Fitness for Plant program, and CIMCO uses in the chemical screening of The investigation commenced with the review of appropriate security program documentation and information and resulted in no evidence to support the allegations as stated.
The review included interviews with Cook Nuclear Plant security management and supervisors and the several Local Law Enforcement Agencies (LLEA) patrolling the Cook Nuclear Plant owner controlled area.
Special attention was given to the Unit Reports, the "ook Nuclear Plant Security Patrols, and the site visits by LLEA.
The Special, Investigator for t'e Berrien County Prosecutor's Office was also interviewed to learn if the
. had any knowledge of drug sales at Cook Nuclear Plant.
In conclusion, no evidence could be developed to support the allegation as stated.
The FFD Program is under continuous review and all employees are being monitored and observed by supervisors for any violations.
We are not aware of any clinical evidence to indicate any truth to the statement th,ic "cranberry juice use will thwart fitness for duty testing."
The chemical testing for drug screen urinalysis samples are handled with the utmost care.
The Laboratory processing collections at the site or at the ir nearby facility, involves comprehensive control measures from the; ime of collection, through handling and testing.
Appropriate identii ication is required from the time the specimen is excreted to the timi resting is completed.
The spec'men
Page 4
- AEP:NRC:1074 is signed for by everyone handl'ing 'the ~specimen and purpose g'ven or all said handling.
All results from testing are handled with th utmost in care and confidentiality, being hand delivered or mailed in a sealed envelope.
(g ~( N7 I o EhJ C LogU gg I 0 W I4<.RCy','o7f
"'5y~,.
"!~~~~
DIANA 8 MICHIGAN ELECTRIC COMPANY
<<t <'+y, 1
A,ER A+wge smear' Sue JECTK Toe April 2, 1987 I
Steam Generator Hanway Salt And Bolt Holes File IKO. E MICH. Ef.fCTPIC CP.
APf982 DORADO C. COOK PLAgr TECHNICAL ENGINEEIti On March 10,
- 1987, we were fn the process of removing primary manway covers on Unit 2 steam generators.
The Construction Department, which normally remaves and replaces these manways, first attempted to remove the bolts on steam generator f22 and 823.
In the first attempt they tried to use a one and one half inch 1mpact wrech which
fs normally used to break the bolts loose.
Mhen this dfd not work they received
'permission from maintenance to use a hydraulic torque wrench and to go up to approxi-mately 3,745 ft./lbs. of torque.
Even with the increase to 3,745 ft./lbs., bolts did not come loose.
After dfscuss1on with Mestfnghouse and AEPSC ft was dec1ded that to break the bolts "loose" it was acceptable to apply as much torque as we could (fn increasing increments).
Eventually, the ma)ority of bolts "broke loose" at approxfmately 9,800 ft./lbs.
After the bolts were broken loose, the majorfty of. bolts were able to be "backed out" without ex-ceeding 1,800 ft./lbs. of torque (they backed normally).
There were,
- however, 5
bolts on steam generator 823 that would not back out.
These bolts were eventually drilled out.
After the war k an steam generator 822 and 823, the Construction crew went to steam generators 821 and 824.
Although we anticipated similar dffffcult1es on these man-ways, the bolts broke free normally and backed out normally.
'rom discussions with Westinghouse and AEPSC, it was verified that other utilities have experienced difficultywith manway baits or studs (some utilities use stads;
. others use bolts).
Westinghouse personnel stated that "stuck" bolts can be attr1but-ed to overtorquing, improper lubrication upon installation, and installing the bolts/
studs into improperly cleaned holes.
The Mestinghouse personnel stated that when a bolt is stuck it could be dfff1cult to attribute the cause to any one specific item - all three. reasons/causes could have an influence.
From our work packages and log books, the manways were installed the last time on steam generators if22 and 123 on May 15, 1986.
It appears that steam generators 821 and 824 were worked after steam generators k(22 and 823.
From our work packages, all of the manways were signed off on Nay 16, 1986.
From 'these packages and from conversatfons with Constructfon, one crew worked generators 822 and
/f23 and a dif-ferent crew worked generators 821 and 824.
Steam generator pr1mary manway cover removal and installation is controlled by procedure 0""1ZNHP5021.002.005 (Rev.
5 was used for the sub]ect manway 1nstallation),
"Steam Generator Prfmary Cover Removal And Installat1on."
This procedure addresses use of lubricant, and a two step torquing sequence.
Additionally, it requ1res that, after the two step torquing sequence, all bolts are removed one at a time and relubrfcated and then torqued to the final torque value (1,800 ft./lbs.).
Additionally, there is KT RA SY ST Kll";.';"'
Steam Generator Hanway Bolt And Bolt Holes Page 2 - April 2, 1987 an inspect'ion hold point after these steps that states:
"verify that the manway cover bolts have been torqued to a value of 1,800 ft./lbs. by checking a minimum of 4 bolts in the. presence of the g.C. Inspector.
Record the tool number of the torque wrench and/or the torque converter as applicable.
Sign off when acceptable."
All of these steps were appropriately documented in the maintenance procedure.
In reviewing the overall processes, it appears that the removal, cleaning, lubrication and torquing of manway bolts at this time was consistent with practices established over the years.
The one difference this time was that a hydraulic torque wrench was used for the first time.
A hydraulic torque'rench appears to be a very good torquing device.
It is light, easy to use, and should consistently apply the same torque values.
The torque developed is depended upon the "head" used and the fluid pressure set by a regulator.
Per the technical description for the wrench, the pressure developed - which sets the torque delivered - must be set by first setting the pressure/regulator at zero and then increasing the pressure.
- Possibly, in working on steam generators 822 and 823 this pressure may have been set incorrectly.
The Maintenance Oepartment will be revising its procedure to require an additional check of the set pressure.
Ouring the inspections of the manways and bolt holes, it was discovered, as expected on steam generator 822 and 023, that several bolt holes required repairs.
These holes will be helicoi led.
Also, as expected, steam generator
)f24 bolt.holes were found to be acceptable (there was no indication that the bolts in this generator had been overtorqued).
However, it was found that all bolt holes on steam generator 821 were in need of repair.
Essentially, it was found that all of the holes were "oversized" (the no-go gauge went too far into the holes).
The reason for this is unknown. All bolt holes on steam generator
$21 are being helicoiled.
It should be noted that the condition of most of the "bad" holes on f22 and i(23 was no different than those on 821 (they were oversized and/or "bell-mounted" ).
Except for those few holes on 23 Hot Leg which had physically damaged
- threads, the "oversized" holes on those generators are indistinguishable from those on 821 and may have nothing to do with the overtorquing incident.
As an additional precaution to help preclude galling of bolts to the manway covers, washers will be used with all bolts.
The maintenance procedure will be revised to specify the use of washers and also to specify lubing of the washers.
Additionally, maintenance will be reviewing the need to further specify that bolt holes'will be only cleaned with a brush.
Presently, the procedure says "using a stainless brush" but may be advantageous to require a softer brush.
In sugary, other utilities have experienced problems with manway bolts/studs.
Our recent incident appears to be the first of its kind on the O.
C.
Cook Units.
Although the cause may never be precisely known (possibly a combination of overtorquing, improper lubrication, and/or improper cleaning of bolts and bolt holes),
the most likely suspect is over torquing of the manway bolts with a hydraulic torque wrench.
This resulted in damage to threads and holes on steam generators 822 and i(23.
The maint-enance procedure wi 11 be revised to further ensure that manways are properly re-placed.
On the. enlargements of the bolt holes on steam generator
- 821, (and 822 and f23) a question remains.
This condition may have existed for a considerable period
Steam Generqtor Hanway Bolt And Bolt Holes Page 3 - April 2, 1987 of time and may date back to the origiral manufacturing of the generator.
It i 1
o possible that during each manway removal the cleaning of th-bolt hole d
of an inconsequential amount of metal but, over the years, the accumulated t
1 al was sufficient to indicate nece sity for repair (Note: the condition on F24 is not consistent with the condition found on the other generators).
Additional precautions presently being investigated include gauging of the bolts themselves and considering the desirability of gauging Unit 1 manway bolt holes during the next refueling outage.
. J55II S4IIAP5D INOIANAANO MICHIGANELECTRIC COMPANY g DAM OC 25 NA.O C. COOK NUCLEAR PLANT 5
~
~
~~
TRIP REPORT SUBJECT.
D-C Cook Pl.ant Unit 2 Primarv Side Services taaCi'I
'4ttt p~
De<g Svttt P RIORITY LOCATION-Cook Plant FROM:
TO:
APPROVED TRIP DATE:
DATE CC:
r4.J.
S.
D.
P. Alexich J. Harkowsky/P.
G.
Schoepf H. Steinhart/R. I.'awliger R. Hafer/J.
R. Jensen N.
G.. Smith, J
Bridgman J.
F.
Kurgan R.
Rickman - Bridgman J.
Greendonner Bridgman E. Jackson, C.E.
Ni'ndsor, CT.
PARTICIPANTS'HE&P);
Combust'.on Engineering (CE) and P U R POSE OF VISIT
! z&r4);
(Conam)
To support the following steam generator (SG) primary side activities as performed b
Combustion En ineerin (CE);
Edd Current Testing ECT),
tube end repair, tube lu in
, and rimar manwa bolt hole inspection and re air.
RESULTS:
OBJECTIVE ACCOMPLISHED II YES NO ACTION ITEMS GENERATED~ YES NO DETAIL HE&P personnel were at the plant during this period to provide technical support for the following SG primary side services.
o SG ECT and Tube Pluq in As a result of ECT ins ection the total olu able tubes :or each SG is as follows:
14 in SG 21.
17 in SG 22; 17 in SG 23. an.'0 in SG 24.
o SG Primar Manwa. Bolt Hol Xns e
.ion and R
air the bolt hole ins:" ction performed on the primary manways (hot leg and cold leg) o'.~ch steam generator, a total of 22 bolt holes were repaired with a H '-Coil insert.
The location of the reoaired bo' Signature Paga 1 Ol
Trip Re}
Page 2
holes is documented in Table I.
A more detailed discussion of each activity is as follows:
SG Edd Current Ins ection Daily job status reports (both tube analyses and production) were reviewed with plant ISI and AEPSC personnel.
Eddy current test results were transmitted daily to AEPSC for incorporation into the eddy current data base.
A few problems were encountered with data acquisition and tube plugging equipment
- however, these problems were resolved and did not significantly impact the overall schedule.
As a result of the eddy current inspection, the total pluggable tubes fo'r each steam generator are as follows:
SG 21-14; SG 22-17; SG 23-17; and SG 24-30.
SG Primar Manwa Bolt Hole Ins ection and Re air During removal of the Unit 2
SG primary manway bolts, the plant experienced 40 seized bolts at various locations in 7
.of the
- 8. primary manways.
Thirty-t;hree of the seized bolts
Trip Report Page 3
were located in bolt holes without Heli-Coils and 7 were
'ocated in bolt holes that were repaired with Heli-Coils during the Harch 1987 outage.
Of the 40 seized bolts, 5 bolts were removed with less than 3200 ft. lbs of torque and 1 bolt was removed with a torque greater than 3200 ft. lbs; 8 bolts were removed with an air operated impact wrench; and 26 bolts were removed by machining.
A visual inspection of the removed primary manway bolts indicated that a number of the bolts experienced severely galled threads.
A visual inspection of each bolt hole thread was performed to evaluate its condition.
This included, if possible, threading a bolt into and out of the bolt hole.
Table II documents the bolt hole locations that required Go/Not-Go gauging as a result of a bolt being removed by an impact wrench, a torque greater than 3200 ft-lbs', or machining.
As a result of the visual inspection, several additional bolt holes were gauged.
Final review of "he visual inspection and gauging xesults identified 22 bolt holes as requiring repair.
In all cases, bolt hole repair -as by a Heli-Coil insert.
Table I documents the loc,a" on of the repaired bolt holes.
Trip Report Page A series of meetings was held with CE,
- AEP, and plant personnel to discuss the'ollowing items:
0 CE's bolt hole inspection and repair procedures were reviewed against the Westinghouse procedures to ensure suitability of the CE inspect'on and repair criteria.
o CE was advised of the SG primary manway design parameters and AEPSC bolt hole acceptance criteria (thread engagement and condition).
o CE was informed that their scope of work, including bolt hole repair by Heli-Coil~did not represent an unresolved safety issue.
CE's scope of work did not deviate from the assumptions used by Westinghouse in their safety evaluation report for the initial Unit 2 bolt hole repair performed during "he March 1987 outage.
The project schedule for these activities was reviewed to reduce CE's inspection and repair time and to provide a smooth interface with other onco'nQ SG ac 1vl, les.
Trip Report Page 5
To provide the required thread engagement, it was necessary to use longer bolts on SG 24 bolt hole locations, HL No.
8 and CL No.
4.
Additional information pertaining to bolt removal by machin-ing, Hali-Coil installation, inspection results and pictures of galled threads from various bolt hole locations is retained by the Heat Exchangers and Pumps Section of the Mechanical Engineering Division.
Action Items o
Obtain Westinghouse recommendations for the SG primary manway bolt lubricant (Fel-Pro-C5-A vs Fel-Pro-N5000).
o MED is to update the Unit 2 SG Technical Manual to reference Heli-Coiled hole locations and thread lubricant recommendations from Westinghouse.
o C.E. to provide final ECT and bolt hole repair I
reports.
Table I Bolt. Hole Location" With Heli-Coil Inserts (1)
S/G 21 S/G 22 No Heli-Coils installed.
Installed Heli-Coil inserts for the following bolt holes.
S/G 23 H/L 2, 7,,10, ll C/L 4, 7
Installed Heli-Coil inserts for the following bolt holes.
S/G 24 H/L 2, 3
C/L 1, 2,
14 Installed Heli-Coil inserts for the following bolt holes.
H/L l~
3g 5i 7i Sg 9
C/L l~
5~ 1li 1'4i 15 (1)
Bolt hole number sequence 3q'.
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SG Z~
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