ML19208C813
| ML19208C813 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/30/1979 |
| From: | Creed J, Knop R, Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19208C808 | List: |
| References | |
| 50-329-79-14, 50-330-79-14, NUDOCS 7909270535 | |
| Download: ML19208C813 (9) | |
See also: IR 05000329/1979014
Text
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i
U.S. NUCLEAR REGULATORY C0hMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
.
Report No. 50-329/79-14; 50-330/79-14
Docket No. 50-329; 50-330
License No. CPPR-81; CPPR-82
Licensee:
Consumers Power Company
1945 West Parnall Road
Jackson, MI 49201
Facility Name: Midland, Units 1 and 2
Investigation At: Midland Site, Midland, Michigan
Investigation Conducted: June 12-14 and July 3, 1979
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Investigator:
. R. Creed
'(Date)
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Approved By:
R. d. Knop, Chipf
Reactor Construction Projects
(Date)'
Section 1
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C. E. Norelius
Assistant to the Director
(Date)
Investigation Summary
Investigation on June 12-14 and July 3, 1979 (Report No. 50-329
1
50-330/79-14)
Area of Investigation:
Special, unannounced investigation regarding a
report that a containment building spray pipe was intentionally plugged
in order to cause damage to the plant when it became operational. The
investigation involved 25.5 inspector-hours onsite by one NRC inspector.
Results:
Although one item of noncompliance with NRC requirements was
identified, (Paragraph 4, failure to properly follow a welding procedure),
on Unit 2 a determination was made that there was no apparent intent to
cause damage to the plant.
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INTh0 DUCTION
The Consumers Power Company (CPCO), Midland Nuclear Power Plant is located
near Midland, Michigan. This is a two unit pressurized water reactor
facility presently under construction and licensed by CPPR-81 and EPPR-82.
The Babcock & Wilcox-manufactured facility is being constructed by the
Bechtel Power Corporation (BPCO) and is approximately 60% completed.
Although there is no nuclear material onsite, and therefore exempt from
any NRC security requirements, the licensee utilizes the services of
Burns International Services, Inc., to provide 48 individuals for industrial
security and access control at the site. There are approxi stely 4,000
people presently authorized to work at thu site. Access to the site is
controlled by a combination of fences and a limited number of access
control points.
REASON FOR INVESTIGATION
On June 7, 1979, the NRC Resident Inspector learned that, durin8 the week
of May 21, 1979, a radiograph of a weld could not be properly read due to
the possibility that a ball of paper had been wadded in the welded pipe.
He was told that the weld was removed and the pipe opened or. Hay 23,
1979. A wad of paper was found lodged inside this verticle pipe run in
the Unit 2 containment building spray line.
Initial reports were unclear
as to whether the paper wad would or would not dissolve when the required
~
containment spray water was used. The possibility that the paper might
not be soluble could have caused the containment building spray nozzels
to become plugged and render a portion of a safety-related system less
than effective. The existence of this potential problem with this safety-
related system caused an investigation to be initiated.
SUMMARY OF FACTS
On May 11, 1979, field weld number 13 (located at t'a 724' level of a
vertical containment building header pipe, System
was completed.
In
order to complete this weld, argon gas must be pumped into the pipe in
the area of the weld so that the surrounding oxygen is purged from the
weld area.
In order to accomplish this, and achieve the correct concen-
tration of argon gas, a " purge dam" must be made which holds the inert
argon gas in the vicinity of the weld joint.
Procederes require that each weld on safety-related piping be radiographed
to certify the adequacy of the weld. Field Weld 13 was radiographed on
May 15, 1979 and when read on May 16, 1979, the film was noted to be
partially obscured by what appeared to be a ball or wad of paper located
inside the pipe.
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.
On May 23, 1979, the weld was removed and the pipe opened. Representatives
.
from BPC0 and an Authorized Inspector witnessed a wadded ball of paper
being removed from the 8" diameter pipe. The paper was tested and found
to dissolve in water.
It appeared to be the same type of paper normally
used to create a " purge dam".
Purge dams are normally made using a
single sheet of water-soluable paper taped to the inside diameter of the
pipe.
On June 7, 1979, the NRC Resident Inspector became aware of the above
mentioned wad of paper, and determined that the paper was probably soluble,
however, an investigation was initiated.
(Note:
When brought to the
attention of the licensee's management on June 7, 1979, it was determined
that BPCO had not notified Consumers Power of the incident).
On June 13, 1979, the NRC investigator interviewed the individual who
made Field Weld No. 13 on May 11, 1979. The welder readily admitted that
he had wadded the paper and lodged it in the verticle pipe run in order
to create a dam to purge the oxygen from the area of the weld with argon
gas. He explained that because of the physical location of the weld on a
verticle pipe run, using a single sheet of paper for the purge dam was
extremely difficult.
The welder further explained that a wadded piece of paper would create an
adequate dam and that he had tested the paper for solubility before using
it.
He was not aware of the fact that the welding procedure specifically
prohibited that.
(Note: The radiograph showed that the weld itself was
probably adequate).
CONCLUSIONS
1.
The ball of paper was placed in the verticle containment spray pipe,
by the welder, to create the required purge dam. This represents a
failure to follow the welding procedure and is an item of noncompliance
(see Paragraph 4 of this report).
2.
Based on all available facts, it does not appear that the act of
wadding the paper was done in order to disable the safety-related
,
containment spray system, but more as a shortcut to complete the
weld. Before becoming operational, this pipe will be filled with
water which would probably dissolve the paper. Further, there are
two separate containment spray header systems, each capable of
performing the needed spray function.
3.
When notified of the paper in the pipe, the contractors took immediate
corrective action to open the pipe and remove the paper.
4.
When notified of the incident, the licensee took immediate corrective
action to prevent a recurrence of the incident, and to investigate
why they had not been notified of the problem by their contractor.
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5.
The fact that the licensee was not notified of the wadded paper
between approximately May 16, 1979 and June 7, 1979, represents a
weakness in the contractors quality control program. Although the
problem was corrected when identified, the licensee should have been
notified. This does not, however, represent noncompliance with
regulations or requirements. The licensee, and contractor have
taken action to resolve this weakness.
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255
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DETAILS
1.
Persons Contacted
D. Miller, Site Manager, Consumers Power Company (CPCO)
- C. Dechow, Construction Security Supervisor (CPCO)
-
- T. Cooke, Project Superintendent (CPCO)
- J. Corley, Section Head, IE &TV (CPCO)
- R. Wollney, QC Group Supervisor (CPCO)
- L. Dreisbach, PQLE, Bechtel Power Company (BPCO)
- J. Russell, Assistant Pipefitter Quality Control Engineer (BPC0)
W. Fish, Quality Control Engineer (BPCO)
B. Wright, Welding Foreman (BPCO)
W. Walter, Piping Superintendent (BPCO)
E. Stankawitz, Radiographer (BPCO)
T. McLean, Welding Supervisor (BPCO)
J. Corder, Lead Mechanical Supervisor (BPCO)
W. Puckett, Welder (BPCO)
H. Dapprich, Union Pipe Steward, Local 85
W. McDougall, Authorized Inspector, Kemper Insurance Company
- R. Cook, Resident Inspector, USNRC
- Denotes those present at the exit interview that was held at the
conclusion of the investigation on June 14, 1979.
2.
Description of Incident
A review of " Quality Control Inspection Report" (QCIR) No. 17875 and
interviews with personnel showed that Field Weld 13 was completed on
May 11, 1979, by a qualified welder employed by BPCO.
This Field
Weld joined pipe sections 15-S-613-2-11 and 15-S-613-2-12 at the
724' level of the Unit 2 reactor containment.
This pipe is 8" in
diameter and comprises the upper portion of the Unit 2 Reactor Con-
tainment Building Spray Header System "B".
The weld was physically
located approximately 65' above the 659' floor elevation. The
containment spray header system is safety-related equipment. This
system would be required to spray water, from nozzles located along
the roof, inside the containment building in order to reduce the
pressure which could be caused by the release of steam during an
accident. The sprayed water would condense the steam and reduce the
pressure on the containment structure's walls. There are two Spray
Header systems, either one of which is capable of performing the
entire function.
When a field weld has been completed, procedures require that a
radiograph of that weld be taken so that the adequacy of the weld
joint may be determined and checked. Field Weld 13 was radiographed
on May 15, 1979. A review of the "Radi,,gaphy Report" showed that
the XRay was taken in .ccordance with established procedures.
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.
An interview with the Bechtel radiographer, who is responsible for
reviewing the films, showed that the radiographs were probably
processed the night of May 15, 1979, and read by him on the morning
of May 16, 1979. He stated that the radiographic pictures showed
lines and what appeared to be a wadded piece of paper inside the
pipe. Because the lines on the film obsecured the weld itself, the
weld was not accepted. The Radiographer notified the lead Quality
Control Welding Engineer who tagged the veld as being unacceptable.
On May 23, 1979, a second Quality Control Welding Engineer, during
his routine duties, noticed the tag.
He researched the cause of the
tag and discovered that the radiographer had " rejected" because of
what appeared to be a ball of paper inside the pipe. The QC Welding
Engineer informed the responsible Piping Superintendent and asked
that he be notified when the weld was opened and the paper removed.
The weld was removed by grinding on May 23, 1979. A ball of paper
was removed and witnessed by the QC Welding Engineer, the Piping
Superintendent and an Authorized Inspector. The Authorized Inspector
tested a piece of the paper wa
and found that it did dissolve in
x
water. Craf t personnel were re-instructed in proper purge procedures.
3.
Incident Reporting and Documentation
For each Field Weld onsafety related equipment, a Quality Control
Inspection Record (QCIR) must be completed.
QCIR No. M-613-2-13 was
initialed and completed for Field Weld 13.
A review of this document
showed that the QC review of the "Prerequisities" and "In-Process
Inspection" were completed on May 11, 1979. Note:
The "In-Process
Inspection" was also reviewed by the Authorized Inspector, as denoted
on the form by his initials.
A review of the QC procedure which was
used showed that " purge dams" were not physically reviewed. The
procedure only requires a review of the documentation of the completed
weld. This could allow an improper purge dam to be used and not be
noticed by the QC Inspector.
When a radiograph of a weld on safety-related equipment is performed
a " Radiography Report" is initiated.
This report shows specific
information regarding each weld and radiographic techniques.
It
also has a section i~or " Film Interpretation". The report for Field
Weld 13, dated May 15, 1979, contained no information regarding the
fact that the film could not be read because of paper inside the
pipe. An interview with the radiographer showed that because the
problem did not relate specifically to the pipe weld but to the
paper inside the pipe, a " defect code" could not be used on the
fo rm.
He decided that instead of forwarding the paperwork (which
would have been noted by the licensee) he would verbally notify the
When the " reject" tag was observed on May 23, 1979, the QC Engineer
took immediate action by going to the Piping Superintendent and
removing the paper wad. An interview with the QC Engineer showed
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that he felt that because the problem had been identified and corrected
.
(the paper was removed), no further action was necessary.
Bechtel
has procedures which allow for reporting of deviations from accepted
practices. These nonconformance reports (NCR's) are completed when
certain criteria are met.
The criteria were not specific regarding
a wad of purge paper found in a pipe. However, had an NCR been
initiated by either the radiographer (when he saw what appeared to
be paper on the film on May 16, 1979) the lead QC Welding Engineer
or the other QC Welding Inspector, the licensee would have become
aware of the situation much earlier.
On June 7,1979, while performing routine inspection activities, the
NRC Resident Inspector overheard a conversation between the Authorized
Inspector and other unidentified individuals. After obtaining the
above mentioned information, he questioned the licensee's Quality
Control Department and discovered that they had not been informed of
the incident. The initial reports received by the NRC Resident
Inspector indicated that the ball of paper would not dissolve in
water. An additional test of the paper was made and it was found to
be water soluble.
The licensee began an immediate investigation to determine the
circumstances. At the request of the licensee, the BPCo QC Welding
Inspector, who found the " reject" tag on the weld and witnessed the
removal of the paper ball, prepared a " Field Inspection Report" on
June 7, 1979.
As a result, the licensee initiated three " Quality Action Requests"
(QAR) on June 8, 1979, to document the identified problems and
corrective actions. These QAR's are sent from the licensee's Quality
Control Department to responsible contractor and licensee personnel
in order to receive information regarding corrective action:
a.
QAR SD-207, completed July 3, 1979, Subject:
Improper use of
Water Soluble Purge Dam.
This QAR requests that the situation
be reviewed to determine if it is formally reportable to the
NRC as required by 10 CFR 50.55(e). The determination was made
that because testing procedures require that the spray header
pipe be filled with water to the 745' level (21' above the
point where the ball was found) the paper would have been
submerged and dissolved prior to any actuation of the spray
system. The licensee had verified this information verbally on
June 8, 1979.
,
b.
QAR SD-208, completed June 22, 1979:
This QAR requested that a
determination be made as to why a nonconformance report (NCR)
was not issued to document the presence of foreign material in
a piping system and document the violation of Note 3, Sheet of
GPS-1, Rev. 4.
The determination was made that a NCR should
have been initiated at the time the paper was noted on the
radiograph and that a Field Inspection Report should have been
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,
initiated when the pipe was cut and paper removed. An
.
additional NCR sitould have been initiated when it was
determined that the welding procedure had been violated.
c.
QAR SD-209, completed June 29, 1979, Subject:
Improper Use of
Purge Dam Material. This QAR requests that the situation be
evaluated and a determination be made as to how the ball got
into the pipe, assure that the situation doesn't exist in other
pipes and take appropriate corrective action to prevent
recurrence. The welders wtre questioned and it was determintJ
that no other instances of this type occurred.
They have been
instructed in proper purge dem installation techniques.
4.
Failure to Follow Welding Procedure (Noncompliance)
10 CFR 50, Appendix B at Criteria V, states in part:
" Activities
affecting quality shall be prescribed by documented instructions,
procedures, or drawings, of a type appropriate to the circumstances
and shall be accomplished in accordance with these instructions,
procedures, or drawings..."
The Bechtel Corporation, " General Purging Sp( cification," G27,
GPS-1, " Internal Gas Purging" at drawing number GPS-1-4 (Rev), which
is entitled " Water Soluble Paper or Film Dams" states, in part:
" Wadding of the paper or film into the pipe is prohibited."
Contrary to the above, a review of records and interviews with
personnel showed that on May 11, 1979, Field Weld 13, which joins
8-inch pipe runs 2G-CB-15-613-11 and 2GCB-15-613-2 12, was made
using a purge dam which consisted of wadded, soluble paper. This
weld was made in the Unit 2, Reactor Building Spray :2ystem headers.
On June 13, 1979 the investigator interviewed the individual who had
made Field Weld 13.
He verified that a wadded ball of soluble paper
had been used as a purge dam, and stated that he was noc aware that
the procedure specifically pr shibited the practice.
He .itated that
the reason he placed the paper wad in the pipe was because it was
the simplest most effective wa/, under the circumstances c f achieving
an adequate purge.
This finding represents apparent noncompliante (infraction) with the
above stated requirements.
5.
Exit Interview
On June 14, 1979, at the conclusion of the investigation the inspectors
met with the licensee and contractor representatives denoted in
paragraph 1.
Discussed in detail were:
(a) the reason for the
investigation (b) summary of facts, (c) the item of noncompliance,
(d) corrective action, (e) items of concern and (f) conclusions.
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,
,
During the meeting the investigator described concerns which do not
,
represent noncompliance, but which could, if not corrected, lead to
additiona l problems. These items were:
No ritport to the licensee was made by Bechtel personnel when
a.
the problem was initially identified.
Bechtel managemen_t and
Quality Control management have been instructed to be continually
aware of their responsibility to report incidents and, if
necessary, corrective action.
b.
The Quality Assurance and Quality Control procedures do not
specifically address inspection of purge dam practices so that
this specific incident would be detected.
The licensee will
instruct QC personnel to watch for this and will review the
procedure for possible revision.
Aduitionally, the licensee's management stated that corrective
action had already been initiated to prevent recurrence and that
this matter was being reviewed extensively.
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