ML19344F297
| ML19344F297 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/10/1978 |
| From: | Crossman W, Foster W, Renee Taylor, Julie Ward NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344F268 | List:
|
| References | |
| 50-445-78-07, 50-445-78-7, 50-446-78-07, 50-446-78-7, NUDOCS 8009150100 | |
| Download: ML19344F297 (10) | |
See also: IR 05000445/1978007
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U. S. tiUCLEAR REGULATORY C0f011SSI0f:
OFFICE OF ItiSPECTI0il AtlD EtiFORCEliEt;T
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REGI0tl IV
Report tio. 50-445/78-07; 50-446/78-07
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Docket flo. 50-445;.50-446
Category A2
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Licensee: Texas Utilities Generating Company
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2001 Bryan. Tower
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Dallas, Texas
75201
Facility !!ame:
Comanche Peak, Units 1 & 2
Inspection at:
Comanche Peak Station and 2001 Bryan Tover, Dallas, Texas
Inspec' tion conducted: April 11-21, 1978
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Inspectors:
R. ~G. Taylof, Reactor inspector, Projects Section
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(Paragraphs 1, 2, 3, 6, 7, 8, 9, 10 & 11)
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W. E. Foster, Contractor Inspector, Vendor Inspection
Date
Cranch (Paragraphs 4 & 5)
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Jg. Ward, Ir#estigation Specialist
Date
(Paragraph 7)'
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Other
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Accompanying
Personnel:
E. L. Ross, Co-op Student, Vendor Inspection Branch
R. F. flaventi, !!RR Project fianager
S. M. Kari, t1RP,14IPC
W. H. Lovelace,ilRR,14IPC
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Approved:
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W. A. Crossman, Chief, Projects Section
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Inspection Summary:
- Inspection on April 11-21,1978 (Rooort flo. 50-445/78-07;'50-446/78-07)
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- Areas Inspected: . Routine, unannounced inspectio:s of the implementation of
10 CFR Part 21 requirerents; storage of electrical components; pipe fabri-
' cation activities; and vendor control activities. ' Investigation of allega-
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tions of-icproprieties in concrete testing activities and concrete test
' records. Also. included was an announced examination of construction
schedule activities by HRR. personnel. The inspection involved one-hundred
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and two inspector-hours by two IE inspectors and one IE investigator.
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Results:
Of the six areas inspected, no items of noncompliance or devia-
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tions were. identified in five; one apparent deviation was found in one
area.(failure to meet PSAR commitments regarding frequency of testing of
concrete. - paragraph 8).
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DETAILS
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1.
Persens Contacted
Princioa) Licensee Emoloyees
- J. B. George, TUS1, Project General Manager
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il. Chapman, TUGCO, Quality Assurance Manager
- R. G. Tolson, TUGCO, Site Quality Assurance Supervisor
- J. V. Hawkins, TUGC0/G&H, Provuct Assurance
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- D. E. Deviney, TUSI, QA Technician
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- J. T. Merritt, TUSI, Resident Manager
R. J. Gary, TUGCO, Executive Vice President
R. Camp, TUGCO, Lead Startup Engineer
E. G. Gibson, TUSI, Project Engineer
B. J. Murray, TUSI, Engineering Supervisor
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J. C. Kuykendall, TUGCO, General Superintendent
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Other Personnel
- U. D. Douglas, Brcwn & Root, Project Manager
- D. C. Frankum, Brown & Root, Assistant Project Manager
Individual A, R. W. Hunt Laboratory
Individual B, R. W. Hunt Laboratory
H. O. Kirkland, Brown & Root, Project General Manager
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L. Hancock, Brown & Root, Project Control Manager
R. E. Walz, Gibbs & Hill, Scheduling Engineer
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The IE inspectors and investigator also contacted and interviewed other
licensee and contractor personnel.
- denotes those attending the exit interview on April 20, 1978.
- denotes those attending the exit interview on April 14, 1978.
- denotes those attending the exit i,nterview on April 21, 1978.
- denotes those attending the exit interviews on April 20-21, 1978.
- denotes those attending the exit interviews on April 14 and 20,1978.
2.
Site Tour
The IE inspectors walked through various areas of the site to dserve
construction activities in progress ard to inspect housekeeping and
equipment storage.
No items of noncompliance or deviations were identified.
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3.
MRC - Licer.sino Meetinc
The IE inspector attended meetings on April 18 and 19,1978, between
representatives of the NRC and the licensee concerning the status of
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construction of the Comanche Peak Station.
The purpose of the meetings
was to obtain information to facilitate and support an independent staff
estimate regarding the fuel load date for CPSES, Unit No.1.
The licensee
presented information regarding status of engineering, procurement, start-
up planning, and a planned accelerated program to assure completion of
construction as scheduled.
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The NRC personnel indicated that the licensee's scheduled fuel load date
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might well be attained if the construction acceleration is effective.
They indicated their intention to perform another review in late 1978.
4.
Inspection of 10 CFR Part 21
The purpose of this area of the inspection was to ascertain that measures
had been established and implemented regarding 10 CFR Part 21.
This was accomplished by reviewing Texas Utilities Generating C'ompany
Procedure entitled, " Safety-Related Defects and Noncompliance Pursuant
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to 10 CFR 21," dated December 20, 1977, various Brown and Root, Inc.
procedures and documents and observation of the bulletin boards in the
Administration Building and personnel entry / exit gates.
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No items of noncompliance or deviations were identified.
5.
Receipt and Storace of Electrical Components
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The purpose of this area of the inspection was to determine that hard-
w re had been received and stored in accordance with established speci-
f. cations and procedures.
This was accomplished by reviewing Gibbs and Hill, Inc. specifications;
CPSES Quality Assurance Plan and var,ious Brown & Root, Inc. procedures
and documents; and Westinghouse Nuclear Service Division (WNSD) Vol.1,
dated March 1976, with attachment 205k and De Laval Procedure entitled,
" Preparation for Shipment and Recommended Storage Procedure for Diesel /
Generator Sets," dated October 24, 1977.
Further accomplishment was
realized through observance of the storage of and review of the records
relative to: a) containment spray pump motors; b) safety injection pump
motors; c) diesel / generator set (engine only); d) termination rack;and
e) component cooling water pump motor.
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UtlSD, Voi.1, dated March 1976, with attachment 20% recommends that
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motor winding temperature be maintained a few degrees above surrounding
air temperature as protection against condensatior..
It further recomends
conthly measuring and recording of anbient air and winding temperatures.
The recommendation for measuring and recording of these temperatures had
not been incorporated into Storage and Maintenance Requirements flo.
33-1195-MEI-10-514. Rev. O, dated tiovember 7,1977, for Safety Injection *
Pump 140 tors.
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The manufacturer's procedure entitled, " Preparation for Shipment and
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Recomended Storage Procedure for Diesel / Generator Sets," dated October
24, 1977, recomends sealing of all openings prior to shipment and
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during subsequent storage.
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This recommendation had not been incorporated into Storage and Maintenance
Requirements flo. 35-1195-!4EI-10-511, Rev.1, dated !!ovember 4,1977, for
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-Diesel Engine and Associated Parts. The IE inspector observed four (4)
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openings in the engine-two (2) in the water cooling jacket and two (2)
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instrument lines.
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These matters are considered unresolved items subject to further evaluation
and inspection.
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6.
Safety Related Pipe Fabrication
The IE inspector selected pipe spool AF-1-SB-08 (8Q3) as representative
of a field shop fabricated spool and AF-1-SB-06-3 as representative of
an off-site fabricated spool piece. The spols were fabricated 'to the
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requirements of Project Specifications M-43B, " Shop Fabrication of Piping
in the Field," and M-43A, " Shop Fabrication of Piping 8" flominal Diameter
and Larger and Piping Material Supply Requirements," respectively.
Both
specifications reflect and incorporate the requirements of ASME Section III
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to the Surmer 1974 Addenda. The pipe spools selected will become part of
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the Unit flo.1 auxiliary feedwater system and fall' into subsection 110 of
the referenced code.
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The IE. inspector verified that all materials used met code and specification
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requirements, were welded by qualified weldere to qualified weld procedures
as determined from certified material test reports, shop process documenta-
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tion and code data reports.
No items of noncompliance or deviations were identified.
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7.
Investigation of Allegations of Concrete Test Records Falsifications
An employee of the R. W. Hunt Company, the site concrete testing labora-
tory, made allegations on April 14, 1978, that certain laboratory test
records had been falsified.
The licensee reoresentative stated that the
employee had initially made the allegation to his laboratory supervisor
who in turn notified the licensee.
The licensee notified the URC project
inspector who briefly interviewed the alleger (hereafter. identified as
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Individual A) on the afternoon of April 14, 1978. The IE inspector
assured Individual A that the f;RC would investigate his allegations and
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subsequently requested the licensee to take no action relative to the
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allegations until the llRC had an opportunity to investigate.
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' Individual A was interviewed by the fiRC RIV investigator and the project
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inspector on three separate occasions during the period April 17-19, 1978.
The resulting allegations are sucmarized as follows:
a.
Concrete test records for April 13, 1978, contained data which did
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not represent _ actual values of concrete slump measured.
Individual
A stated that another laboratory employee (Individual B) h,ad con-
sistently rneasured slump values in excess of the acceptance value
but reported them to Individual A, who was acting as a data recorder,
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as having values that were acceptable.
Individual A stated that a
Brown & Root employee (Individual E) could confirm the allegation.
Individual A stated that his superv.sion directed him to enter the
false data on the official test record and to sign the record.
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b.
Individual A stated that another laboratory employee (Individual C)
had on April 11, 1978, not properly conducted the slump tes'ts and
had also reported to Individual A, again acting as a data recorder,
test data not representative of actual measured values.
Individual
E was also to confirm this allegation.
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c.
Individual A stated that laboratory tests required for small place-
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ments; i.e.,10 cubic yards of concrete or less, had not been
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actually accomplished by hitself and other employees of the labora-
tory during the entire period 6f his employment even though the
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records would show that the tests had been accomplished,
d.
Individual A stated that he had been informed by yet another labora-
tory employee (Individual D) that a laboratory level II tester had
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signed certain test reports covering tests accomplished on September
3 and 4,1977, when the level II person was not on site and could
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have no specific knowledge of the tests.
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e.
Individual A stated that he had sign::d a pressure gauge calibration
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record that by laboratory procedures he was not qualified to certify.
f.
Individual A stated that he had on two separate occasions reported
situations to his supervision that should have resulted in issuance
of Deficiency and Disposition Reports (DDR) to Brown and Root for
engineering evaluation. He stated that on April 11,1978, he had
made a calculational error during slump testing record keeping that '
allowed concrete in excess of specification requirements to be
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placed.
This error was reported by him to his supervision who took
no action to issue a DDR.
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The NRC investigative team interviewed Individual E in regard to allega-
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tions a. and b.
Individual E stated that he could not actually see the
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slump measurements made by laboratory personnel during their test work
and relied completely on their verbal reports to him.
Individual E
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stated that he was not aware of any test not properly performed or re-
co rded.'
Review of the alleged falsified test report failed to provide
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any meaningful information.
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The investigator reviewed the personal log books of a number of laboratory
personnel relative to allegation c. and could not substantiate the allega-
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tion even though Individual A stated that such a review would be revealing.
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The investigation team interviewed a former laboratory foreman of testers
who is currently employed on site in another ctpacity by a different
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employer.
This person stated that he had heard shop rumors of such activ-
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ities when he was foreman and had attempted to ascertain the validity of
the rumor but had never found a tester not actually doing requir.ed test
work.
The investigative team interviewed Individual D regarding allegation d.
Individual D stated that he had heard the story from a former laboratory
employee no longer available' for interview.
He stated that as far as
he knew the September 1977 date was not correct and that sometime in
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December 1977 was when he thought the incident occurred.
The investigator
obtained the daily payroll records of all laboratory personnel for the
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first ten days of September 1977 and all of December .1977.
The level II
person was present every day in tne September period but was absent on
December 4, 5,11 and 18 through 31. The investigator reviewed all
pertinent test records for the days involved and found no records vali-
dated by the level II person.
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The investigative team followed up on the allegation e. with the result
that while the allegation was substantiated, there were no safety related
consequences.
The pressure gauge .in question was calibrated b'y the Brown
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& Root site calibration facility on August 15, 1977, in accordance with
Brown & Root procedures with Brown & Root equipment by Brown & Root
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~ personnel. 'Th'e clalibration record was a R. W. Hunt form signed by Indivi
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-dual A who. observed the test in accordance with R. W. Hunt procedures.
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The.se facts were gathered during an interview with Brown & Root
calibration facility personnel, including the facility supervisor..l/
The final allegation,
f., was unsubstantiated.
Individual A had stated
that on two occasions he had reported problems to his supervision. He
was uncertain as to the time frame of the first instance but was specific
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on the second which was relative to tests on April ll,1978.
The investi-
gators were provided a Deficiency and Disposition Report dated April 12, '
1978, initiated by laboratory supervision reporting the exact substance
of the allegation. The site procedural system for processing DDRs
indicate the DDP, was originated and subsequently logged in by the Brown
& Root document control desk on April 12, 1978.
fio items of noncorpliance or deviations were identified directly assa:iated
with the cliegations.
8.
_ Concrete Testing Activities
During the investigation of alleptions as outlined in paragraph 7, the
IE inspector reviewed records of 1: lump, air content and temperature
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testing of fresh concrete. The " Concrete Placement Report" and the batch
plant delivery tickets revealed that on April 11, 1978, one thousand and
sixty (1060) cubic yards of Design Mix t;o.133 concrete was placed in three
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separate areas, two of which were safety related. The safety related place-
ments comprised a total of four hundred-seventy (470) cubic yards. Analysis
of concrete acceptance test data indicated that while all twenty-two (22)
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required tests had been accomplished for the entire days batching, only
five (5) tests had been accomplished on concrete placed in the s,afety
related structures.
The two safety related concrete placements were for containment interior
walls and slabs which are addressed in paragraph 3.8.3.2.D of the PSAR.
The referenced paragraph indicates that containment interior concrete work
will be accomplished in accordance with "ASME-ACI-359." The"ASME-ACI 359"
document referred to requires the above tests to be ccnducted for every
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one'hundred-fif ty cubic yards of concrete placed in the containment.
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Specification 2323-SS-9 modifies the ASME-ACI requirements by stating that
tests will be conducted for every fiftp cubic yards.
The Concrete Placement
Report indicates that the initial test series was conducted on the concrete
being placed that day, but no other test was conducted until two hundred-
ninety (290) cubic yards had been placed.
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This was pointed out to be a deviation from PSAR commitments.
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described the situation as' a detected prebexisting and continuing problem
and provided corrective action.
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Vendor control Activities
It was brought to the IE inspector's. attention / that elements of the
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Itcensee's quality assurance program involving vendor control activitics
appeared to be breaking down.
Responsibility for vendor control for
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components purchased directly by the licensee had been delegated to
the architect / engineer, Gibbs & Hill, Inc. with licensee participation.
The IE inspector had previously been informed by the licensee that the
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delegated responsibility to Gibbs & Hill was being directly assumed by
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the licensee's Quality Assurance Department. The inspector selected
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five purchase orders to review as follows:
a.
CP-0450 with General Electric
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CP-0613 with Westinghouse
c.
ES-24 with Forney Engineering
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CP-0074 with Gulf & Western
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e.
CP-0082 with CVI-Pennwalt
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Of the five orders inspected, the inspector verified that required pre-
award surveys had been conducted in each instance; but in three instances,
the vendor had not been placed on the approved vendor list.
Each of the five pre-award surveys resulted in quality assurance defi-
ciencies in the vendor QA program requiring correction prior to initiating
any work or manufacturing work only.
These hold points appeared- clear in
the licensee documentation but did not appear in the purchase documents
issued to the vendors.
Gibbs & Hill purchasing expeditor reports were
found in a document package indicating that each vendor had not initiated
work beyond a hold point except for CVI-Pennwalt, where Gibbs & Hill
waived any further audit on February 23, 1977.
The vendor (CVI-Pennwalt)
provided the licensee with a list of corrective actions in a letter dated
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March 28, 1978, resulting from the 1.nitial pre-award audit conducted in
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November 1976.
The licensee, without Gibbs & Hill participation, conducted
an audit on April 10-11,1978,. finding that the corrective actions had been
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implemented except in one instance and communicated this directly to the
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vendor. Discussions with licensee personnel revealed that the licensee
intends to. perform all vendor control activities except for those situations
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where Gibbs & Hill has not concluded a previously initiated action.
licensee was not able to identify just what orders the exception applied
.to or what the magnitude of the exception was.
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F.lE Inspection Report f;o. ,9990524/ 78-01
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It was clear that the-licensee.and his architect / engineer 'have a general
understanding of each party's
responsibility, but no specific under-
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standing-on a purchase order by purchase order basis. The IE inspector
wassinformed that a definitive interface agreement was being generated
to specifically define Lresponsibilities,
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.This' matter will be considered unresolved pending review of such an
agreement and verification of program effectiveness.
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10.
Unresolved Items -
Unresolved items are matters about which more information is required in
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order to ascertain whether they'are acceptable items, items of noncompliance,
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or . deviations.
Unresolved items disclosed during the inspection are dis-
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cussed as indicated below:
Paragraph 5: Storage of Electrical Components
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Paragraph 9: Vendor. Control Activities
11.
Exit Interview-
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'The IE inspector met.with licensee representatives (denoted in paragraph
1) on. April 14, 1978, April'20, 1978, and at the conclusion of the
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inspection on April 21, 1978.
The inspector summarized the purpose and
scope of the inspection and the findings.
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