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Motion for Admission of Encl ANI Documents Into Record of Proceedings.Certificate of Svc Encl.Related Correspondence
	ML20096A409
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1984
From:	Ellis J; Citizens Association for Sound Energy
To:	; Atomic Safety and Licensing Board Panel
Shared Package
ML20096A405	List: ML20096A403; ML20096A409;
References
	OL, NUDOCS 8408310105
	Download: ML20096A409 (276)
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iC pmTED CO. ,d.v. 8/14/84-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00tKETED USNRC BEFORE THE ATOMIC ' SAFETY AND LICENSING BOARD In the Matter of' i '84 AG017 P3 U i

TEXAS UTIl.ITIES GENERATING l Docket' Nos. 50-445-1 ,, .

COMPANY, et al.' { and 50-446-l' gy@,/

g$73 l ;. . .g (Comanche Peak Steam Electric Station i Station, Units 1 and 2) l CASE'S MOTIONS REGARDING ANI DOCUMENTS CASE (Citizens Association for Sound Energy), Intervenor herein, files these Motions.Regarding ANI Documents pursuant to the Board's ruling during the 7/26/84 telephone conference call (Tr. 13,855/24-13,857/10, 13,859/20-13,860). (See full discussion at Tr. 13,845/6-13,860/16.)

Although we still believe that these documents should have been provided by Applicants under existing discovery requests some time ago (see discussion at Tr. 13,850/23-13,854/22), the Board has already ruled in this regard. However, the fact remains that we did not have these documents until we obtained them in the TUEC rate hearings, we do have them now (and are finally able to get them into the hands of the Board) and we believe that the information contained in them is too important for the Board not to consider.

CASE had hoped to be able to make this filing earlier; however, when we obtained a copy of the transcript of the conference call after it was received at the mini-public document room and we had an opportunity to review the Board's comments, it became obvious that information was required in addition to the very brief and somewhat skimpy summary we had already prepared. Therefore, we have done some very rough, brief, trending in an 8408310105 840814 i PDR ADOCK 05000445 g PDR

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, attempt to give the Board a more accurate picture of"why CASE believes the :

ANI documents are so important. ~This information'is contained in

-attachments organized by general'aubject matter. It should be remembered that the ANI' documents, in and of themselves,1(although[Important) represent

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only a part of the;overall picture of the des'gn'and i construction at:

Comanche Peak,,and should be: considered in that=overall context.. In addition, the attached summaries were done very hurriedly and (while,we havel

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' attempted to include sufficient information to allow the Board to understand the importance 'of the documents)1do not represent, our total arguments regarding these documents.-

One of the reasons these ANI documents is important is.because of'the position held by-the Authorized Nuclear Inspectors (ANI's) at. Comanche Peak.

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As stated by Applicants' counsel, Mr. Horin, during the 7/26/84 conference call "These SIS reports are . . . inspections by the authorized nuclear inspectors. . -. the authorized. nuclear inspector is.not a contractor or subcontractor, he's an independent inspector who'is out at the site." (Tr.

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13851/3-9, emphasis added.)

In addition, these documents are relevant and material to CASE's contention 5 because in some instances the-ANI has found problems with items which had already been inspected and accepted under Applicants' OA/0C program. Further, in several instances, the ANI specifically identified

, clear trends and patterns which Applicants' own 0A/0C program had f ailed to l promptly identify or correct. Additional points are contained in the discussions of each of the categories.

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'There are a couple of specific items to which CASE wishes'to call the-Board's attention. One has to do with the report discussed briefly during 2

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theLeonference call (at Tr.-13,850/2-22); this:is CASE Exhibit 1,058, ANI

. SIS Report- 932 10-032, . dated 2/17/84. It- is : included on pages 8 and 9 of f

.the> attached-section on "ANI REPORTS -- WELDING."1 We believe that this-

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-particular; report is relevant and material in several ways and deserves further comment.

As the ANI stated,'this report (which was dated 2/17/84) has to'do with hidden welds on a support,'in regard.to interpass te'aperature while welding to. embed plates.. The welder admitted that' he did not know the thickness o'f the embed plate'he was welding to, nor did~he check the interpass temperature during welding. Further, in Applicants' answer. to this report t

.(dated:3/9/84), they stated that the welder was retrained and that the OC department was instructed to monitor-preheat and interpass temperatures ,

2 days a week, to be implemented by 3/12/84..

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This report is important in several ways. One of the most important is regarding prompt identification ~and corrective action regarding nonconforming conditions.' Applicants had been on notice.regarding this problem not only through the February 1984 prefiled testimony of Henry and Darlene Stiner /1/, but also through the affidavit of IIenry and Darlene Stiner filed July 28,1983]2/. However, corrective action was apparently not taken until 3/9/84 when the problem was pointed out by the ANI, to be implemented by 3/12/84, and apparently consisted only of instructing the OC fif. see page 10, line 14, through page 12, line 10, bound in following Tr.

10,339, stricken at Tr.- 9955/21-9960/24

/2/ see Affidavit of Henry and Darlene Stiner, page 4, line 1, through .page 6, line 25, attached to CASE's 7/28/83' letter to the Board under .i subject of Objections to Board's Findings end CASE's Answer to' 1 Applicants' 7/15/83 Summary of the Record Regarding Weave and Downhill Welding.

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. department to monitor preheat'and interpass temperatures two days a week.

In-addition, this report and Applicants' response to it is contrary to

-testimony in the operating license hearings by Applicants' witnesses, and this ANI report was in' fact written up at almost the exact time Applicants' witnesses were testifying in the operating license hearings that they and.

everybody theyfever knew of or even heard of always checked the heat input when welding f3/. This ANI Report obviously calls Into question the testimony of Applicants' witnesses in this regard (as well as in regard to their other testimony).

(It should be noted that the NRC Staff is also looking into the matter of proper use of preheat at Comanche Peak.)

To CASE, perhaps the most important aspect of this is not that Applicants did not respond to the 7/28/83 allegations of Henry and Darlene Stiner, but the way Applicants responded to them -- by apparently ignoring the problem, thea by successfully (with the assistance of the NRC Staff) attempting to keep Henry and Darlene Stiner's testimony in this regard out of the record, then by attempting to mislead the Board regarding preheat at Comanche Peak, and next, by attempting to prevent CASE from getting the ANI Reports into the hands of the Board. Further, Applicants' counsel attempted to downplay the importance of this particular ANI Report (Tr. 13,855/3-7),

although Applicants' attorneys (even assuming that they were not themselves f3/ See, for example, testimony of Applicants' Witnesses Clifton R. Brown at Tr. 11,465-11,466, 11,468, 11,486; Fred E. Coleman at Tr. 11,535-11,537, 11,567, 11,570-11,571; Isaiah Pickett at Tr. 11,615-11,620, 11,643, 11,651-11,652; Armand M. Braumuller and Salvador Fernandez at Tr. 11,663-11,664, 11,668, 11,670; and perhaps others -- we are still working-on our welding findings and do not have the additional citations at this time.

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Haware of the contents of the r'eport earlier, were made-aware of it over a month ago,"with CASE's 6/30/84 letter to Mr. Reynolds under subject-of

" Documents Obtained by CASE in Rate' Hearings'Which Are Also Relevant a'nd-Material for Operating License Hearings," and CASE's.6/30/84 Request to.

< . Applicants for Admissions, toiwhich we attached a brief description of the

. portions.of the documents,'along with copies o' the documents themselves f4/. CASE' submits that Applicants themselves should"have called this.

February 17 report and Applicants' March 9 response and March 12' implementation date to the Board's attention as soon as it occurred -

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especially in view of'the' fact'that this matter was a subject discussed f l- 'during hearings which were underway at almost exactly the same time,.during l

. the weeks of February 20-24 and March 19-23.

j And finally, Applicants put in place a partial remedy'which,. CASE' submits, is too little too late -- not only because of the timing, but also because there is no indication-that Applicants have attempted to ascertain whether or not this is an isolated incident or has more widespread implications, or that they have even considered retraining any other welders.

To CASE, this entire matter and Applicants' actions regarding it call into serious question the testimony of Applicants' welding witnesses and the adequacy and effectiveness of Applicants' QA/0C program, indicates a lack of I candor and honesty with the Board on the part of Applicants, and strongly challenges the. adequacy-and intent of Applicants' management of the design and construction process at Comanche Peak.

f4/ We are attaching copies of the same' documents to this pleading.

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1 For this-reason, we believe that this ANI Report should be admitted !

-into'the record of these proceedings and that CASE'should be allowed to

-include it in;our proposed findings on welding.

As mentioned previously, although' CASE has tried'to. include sufficient

'informatica to allow the Board to understand the importance of the

-documents, the attached summaries do not represent our total arguments regarding'these documents. They will be addressed further in the context of the overall picture, in conjunction with other documents and testimony in the proceedings.

A brief example of this will serve to illustrate our point, and.can be found in the summary section "ANI REPORTS -- PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES." In our overall proposed findings, we will includethefactthat,althoukhtheproblemofviolationofrequirements that nonconforming conditions be promptly identified and corrected had been specifically identified by the ANI not once, but several times, Applicants never took action sufficient to correct the problem (see entire summary section). Further, although Applicants continued to " reinstruct" employees regarding the handling of nonconformances, Applicants' response was totally inadequate; the below-listed ANI documents (which cover a period from

-November 1982 through February 1984) clearly demonstrate that such reinstruction did not in fact correct the problem:

B&R is going to indoctrinate all employees in what is expected of them regarding reporting of nonconformances (1/20/83 B&R Answer). (See CASE j -Exhibit 1,026, ANI SIS Record 327, 11/18/82.)

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!. Everybody was reinstructed regarding NCR's. (See 11/8/83 answer,

! attached to CASE Exhibit 1,050, ANI SIS Record 366 and 366A, 10/21/83.)

I Need to reinstruct personnel regarding NCR's. (See CASE Exhibit 1,056, ANI SIS Record 939 371, 2/6/84.)

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CASE believes that the attach'ed summaries are self-explanatory (although the Board will h' ave to read the reports themselves to get the

. entire picture).

Initially, all CASE wanted to do was to be able to use some of the

[- documents obtained in the rate hearings, which we believed were relevant and t.

. material for-the operating license hearings, in the same manner in which we l.

would have been able to use any documents obtained o'n discovery in the operating license hearings (having to meet the same burden of proving .I relevancy and materiality as for any such documents). We did not at that time attach any other special significance to them. It is Applicants' actions which have now given these documents such special signficance and which necessitated CASE's filing this Motion; and, after having done this very rough trending, we now believe that they do indeed have special signficance and importance for these proceedings.

CASE's Motions For the reasons stated in the preceding, CASE moves thac the Board admit the attached AN1 iocuments (CASE Exhibit 1,023 through 1,060) into the record of these proceedings, to be used as any other documents so admitted can be used. It should be noted that this will not delay the proceedings in any way; we do not believe that testimony regarding these documents is necessary -- they speak for themselves.

In addition, we move that the Board accept into the record the attached

. pages from Applicants' FSAR (17.1-39, May 31,1979 ; 17.1-39, Amendment 41, July 11, 1983; 17.1-40, May 31, 1979; and 17.1-41, August 7, 1992). These documents are discusred on page 3 of the summary on "ANI REPORTS -- ARC 7

.. .v STRIKES", where it is stated in CASE's discussion:

"Further, Applicants' proposed handling of the problem by use of IR's and punch lists in some instances in effect removed this problem from the established program of using NC2's to report nonconforming conditions'(which was in effect until 7/11/83; see attached page 17.1-39, 5/31/79, and the revision to it, page 17.1-39, Amendment 41, 7/11/83, and pages 17.1-40, and 17.4-41 which were current as of 7/11/83), and is relevant to another portion of CASE's proposed new contention, use of inadequate or less restrictive (than NCR's) methods of dealing with nonconformances."

These FSAR pages are an important part of our c'ase. We believe that it is necessary to admit these particular pages into evidence. Although Applicants' FSAR is an Exhibit in these proceedings (Applicants' Exhibit 3),

it is our understanding that only the current FSAR pages are kept as part of the record. At least one page (17.1-39, 5/31/79), has already been revised; our FSAR copy is not completely up-to-date, and we do not know whether the other referenced pages are still current (we only know that they are the pages which were in effect as of 7/11/83). It is therefore necessary to admit these pages in order to have a complete record on this important point.

We further move that, since this pleading was prepared rather hurriedly, should the Board require further clarification before it is able to rule favorably on CASE's Motion, CASE be given the opportunity to supplement this pleading.

Respectfully submitted, g~ . E > ff jpfs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 8

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N ATTACHMENTS b

L' Summaries:

, 'ANI REPORTS ' ARC STRIKES

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. PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN,'.ETC.

DOCUMENT CONTROL VIOLATION OF' HOLD POINTS l i

' INTIMIDATION'

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MINIMUM WALL TESTS TRAINING WELDING I

i FSAR pages (discussed on page.3 of summary on ANI REPORTS -- ARC STRIKES):

17.1-39, May 31, 1979 17.1-39, Amendment 41, July 11,1983 17.1-40, May 31,.1979 17.1-41, August 7, 1981 CASE EXHIBIT NO. DESCRIPTION AND

SUMMARY

TO WHICH EXHIBIT IS APPLICABLE 1,023 ANI SIS Record 939 314, 10/14/82 DESIGN DOCUMENT CONTROL VIOLATION OF HOLD POINTS INTIMIDATION WELDING-1

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1,024- ANI SIS Report 932 11-006,.10/14/82'and 11-006-1, 10/27/82 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES ~l DOCUMENT CONTROL. l MINIMUM WALL TRAINING WELDING 1,025 ANI SIS Record 939 322A, 11/11/82 VIOLATION OF HOLD POINTS ,,

INTIMIDATION 1,026 ANI SIS Record 939 327, 11/18/82 ARC' STRIKES PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DOCUMENT CONTROL MINIMUM WALL TRAINING WELDING 1,027 ANI SIS Report 932 10-016, 12/20/82 DESIGN DOCUMENT CONTROL WELDING 1,028 ANI SIS Report 932 18-005, 1/10/83 DESIGN DOCUMENT CONTROL WELDING 1,029 ANI SIS Record 939 334, 1/13/83 PROMPT IDENTIFICATION AND CORRECTION 0F NONCONFORMANCES DESIGN DOCUMENT CONTROL 1,030 ANI SIS Record 939 339, 3/1/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL 2

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-1,031 ANI SIS Record 939 341, 3/8/83.

DESIGN TESTS 1,032 ANI SIS Record 939 346, 4/21/83

-DOCUMENT CONTROL

' TESTS 1,033- ANI SIS Report 932 9-002A, 4/21/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL WELDING t

1,034 ANI SIS Record 939 347, 4/21/83 DOCUMENT CONTROL TRAINING WELDING 1,035 -ANI SIS Report 932 G-044, 5/26/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL TRAINING WELDING 1,036 ANI SIS Record 939 353, 6/2/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES

-1,037 ANI SIS Record 939 355, 6/7/83 DESIGN DOCUMENT CONTROL 1,038 ANI SIS Report 932 4-003-2, 6/22/83 DESIGN DOCUMENT CONTROL WELDING 3

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1,039~ ANI. SIS Report 932 G-051, 6/29/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN.

. DOCUMENT CONTROL INTIMIDATION'

- WELDING I 1,040' ANI SIS Report 932 10-022, 6/30/83 DESIGN --

. DOCUMENT CONTROL 1,041 ANI SIS Record 939 356, 7/1/83 DESIGN DOCUMENT CONTROL ,

1,042 ANI. SIS Record 939 357, 7/2/83 DESIGN TRAINING WELDING 1,043 ANI SIS Record 939 362A, 8/3/83 VIOLATION OF HOLD POINTS INTIMIDATION 1,044 ANI SIS Record 939 361A, 8/11/83 DESIGN DOCUMENT CONTROL 1,045 ANI SIS Record 939 363A, 8/18/83 i

PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES I DESIGN DOCUMENT CONTROL INTIMIDATION TESTS TRAINING 4

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1,046 ANI SIS Record 939'364,'8/23/83 (follow-up to CASE Exhibit 1,032, ANI SIS Record 939 346, 4/21/83).

DOCUMENT CONTROL TESTS TRAINING !

1,047 'ANI SIS Report 932 16-009, 9/27/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN 1,048 ANI SIS Report 932 10-024, 10/5/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DOCUMENT CONTROL WELDING-1,049 ANI SIS Record 939 365, 10/7/83 DOCUMENT CONTROL WELDING 1,050 ANI SIS Record 939 366 and 366A, 10/21/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DOCUMENT CONTROL TRAINING 1,051 ANI SIS Record 939 369, 11/9/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL WELDING 1,052 ANI SIS Record 939 367-A, 10/31/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL INTIMIDATION WELDING 5

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'1,053 .ANI SIS Record 939-367-B,'11/18/83 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL--

INTIMIDATION-WELDING 1,054 ANI SIS Report 932 10-030, 1/5/84 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES

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DESIGN 1_,055- ANI SIS Report 932 10-031, 1/24/84 DOCUMENT ~ CONTROL k

1,056 _ANI SIS Record 939-371, 2/6/84 PROMPT IDENTIFICATION AND CORRECTION-0F NONCONFORMANCES DESIGN DOCUMENT CONTROL TRAINING 1,057 ANI SIS Report 932 5-002 and 5-002A, 1/23/84 and 2/10/84 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN DOCUMENT CONTROL TESTS WELDING 1,058 ANI SIS Report 932 10-032, 2/17/84 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES-DESIGN DOCUMENT CONTROL TRAINING

-WELDING i 1,059 ANI SIS Report 932 10-033, 4/13/84 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DOCUMENT CONTROL 6

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1,060~ ANI SIS Report 932 10-034, 4/18/84 PROMPT IDENTIFICATION AND CORRECTION OF NONCONFORMANCES DESIGN-DOCUMENT CONTROL VIOLATION OF HOLD POINTS TESTS' WELDING

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NOTE: The preceding is not an all-encompassing listing of categories-into which'each document falls; It is intended only to give a quick overview of"the applicability of the Exhibits.

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_.v-l ANI REPORTS - ARC STRIKES Arc Strikes represent a continuing problem at Comanche Peak which

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l Applicanta have_not corrected (or have not been able to correct) over a period of several years.

In addition to representing a continuing problem in and of itself, the fact that this problem has continued to recur over a period of many years, when combined and trended with other recurring problems, also indicates a breakdown in the Applicants' QA/QC program in that they have failed to take proper measures which would prevent recurrence (in violation of 10 CFR Part 50, Appendix B, Criterion XVI). As such, it is one of many possible examples which are important in the context of the global issues regarding Applicants' noncompliance with 10 CFR Part 50, Appendix B (see discussion in Board's 3/15/84 Memorandum (Clarification of Open Issues), bottom of page 4 continued top of page 5). This is also the type of information which would be included as part of CASE's Trends or Patterns of Non-Conforming Conditions (see discussion in CASE's 4/2/84 Motions Regarding Board's 3/15/84 Memorandum (Clarification of Open Issues), pages 18 and 19).

Also, this problem is relevant to portions of CASE's proposed new contention which we will be filing in the near future.

This problem cannot be viewed in a vacuum from other related information already in the record, and it is necessary to include enough of it here for the Board to understand the reason CASE believes the recently obtained ANI documents are important.

A brief scanning of CASE Exhibit 38 (admitted into evidence 5/9/82, at Tr.1349), the Brown & Root Quality Assurance Department Nonconformance Log, 1

reveals that this has been a' continuing problem identified on Nonconformance Reports (NCR's). In addition, we call the Board's attention to CASE Exhibir

~510, 12/18/78, NCR C-1296R1, especially pages 1, 3, and 4. (This is one of the exhibits which were accepted into evidence in accordance with the Board's 12/7/82 Order (Proposed Findings of Fact; CASE Exhibits) following i

submission of CASE's 10/18/82 Response to Board's Directive Regarding CASE Exhibits; these exhibits were accepted into evidence in the May 1982 hearings.) This document indicates one of the reasons it is so important to control are strikes, at least in regard to rebar. It states that according to the "CRSI Handbook for Placing Reinforcing Bars," Handbook Section 10-11 states:

"' Simply starting a spark against a bar . . . or any similar operation that concentrates high heat at one point of a bar creates what is called a ' notch' effect. Tests have shown that this can reduce the strength of a bar to 35 to 40 percent of its capacity'." (Emphasis added.)

The information contained in Reports and Records of the Authorized Nuclear Inspector (ANI) obtained by CASE in the Texas Utilities Electric Company (TUEC) rate hearings indicates the ANI's concerns regarding this continuing problem. The fact that the ANI had such strong comments I regarding this problem increases its importance, since these items should have already been inspected, checked, and verified under Applicants' QA/QC program.

As indicated below, this problem also indicates a failure in Applicants' training program and has serious implications because of the 2

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continuing receipt and use of pipe which has or is near to having minimum wall violations (see discussion in ANI REPORTS -- MINIMUM WALL, included herein).

Further, Applicants' proposed handling of the problem by use of IR's and punch lists in some instances in effect removed this problem from the established program of using NCR's to report nonconforming conditions (which was in effect until 7/11/83; see attached page 17.1-39, 5/31/79, and the revision to it, page 17.1-39, Amendment 41, 7/11/83, and pages 17.1.40, and 17.1-41 which were current as of 7/11/83), and la relevant to another portion of CASE's proposed new contention, use of inadequate or less restrictive (than NCR's) methods of dealing with nonconformances.

From ANI Reports and Records:

ANI: "Since surface defects no deeper than 1/16" need be repaired and these areas were ground upon, they must have been more serious defects or; ,

arc strikes." (See CASE Exhibit 1,024, ANI SIS Report 11-006, 10/14/82, and 11-006-1, 10/27/82.) (Closed with CASE Exhibit 1,026, ANI SIS Record 939 327.)

B&R 1/7/83 Answer: "In the past year or so, are strikes have been a major nonconforming condition as evidenced by the number of IR's and NCR's issued to identify and correct them." (Emphasis added.) (See CASE Exhibit 1,026, ANI SIS Record 939 327, 11/18/82.)

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ANI, page 2: "It is very evident that the training and indoctrination program outline'd in Section III of the QA Manual is not being implemented,

j. due to the number of are strikes and base metal non conformances being found i.

by ANI's and Q.C. Inspectors during walkdowns and at non destructive examinations...Due to numerous sections of pipe being received that are so close to minimum wall at time of receiving, it becomes even more critical that.all are strikes and base metal non conformances are reported and documented promptly." (See CASE Exhibit 1,026, ANI SIS Record 327, 11/18/82.)

1/7/83 B&R Answer: Arc strikes and base metal defects shall be handled as follows (see CASE Exhibit 1,026, ANI SIS Record 327, 11/18/82):

(1) Discovered on N-stamped components, ID'd and documented on NCR; (2) Discovered prior to system walkdown by QC, documented on IR (Inspection Report);

(3) Discovered during system walkdown by QC, entered on system punchlist and documented on an IR; (4) Discovered after system pressure testing, documented on NCR.

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ANI REPORTS - PROMPT IDENTIFICATION AND CORRECTION OF LONCONFORMANCES

' CASE has always.been concerned with the prompt identification and correction of nonconformances. Criterion XV of 10 CFR Part 50, Appendix B, is specifically titled " Nonconforming Meterials, Parts, or Components," and Criterion KVI is titled " Corrective Action." CASE believes that these are among the most important requirements of an effective QA/QC program. The Licensing Board also has always expressed concern with these matters (see especially Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 2-7).

Clearly a breakdown in this important aspect of Applicants' QA/QC program goes to the very heart of CASE's Contention 5. As such, it is important in the context of the global issues regseding Applicants' noncompliance with 10 CFR Part 50, Appendix B (see discussion in Board's 3/15/84 Memorandum (Clarification of Open Issues), bottom of page 4

-continued top of page 5). This is also the type of information which would be included as part of CASE's Trends or Patterns of Non-Conforming Conditions (see discussion in CASE's 4/2/84 Motions Regarding Board's 3/15/84 Memorandum (Clarificatio- of Open Issues), pages 18 and 19). Also, this problem is relevant to portions of CASE's proposed new contention which we will be filing in the near future.

The following summary of information contained in Reports and Records of the Authorized Nuclear Inspection ( ANI) obtained by CASE in the Texas Utilities Electric Company (TUEC) rate hearings indicates that there has been a serious, continuing, documented, problem of inadequate corrective action at Comanche Peak. We believe that the ANI information is of vital 1

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-importance to our case, since it represents the views of individuals who not only inspect, but who also. review documentation and construction after it has been reviewed by Applicants' own inspectors.

From ANI Reports and Records:

ANI: (Regarding base metal defects, grinding of welds, minimum wall,

-document control, etc.): Response does not address the larger problem of instruction to field personnel to prevent the same problem in the future.

- "I would like to stress that;this problem is-or-could be, larger than this single instance and warrants immediate attention." (See CASE Exhibit 1,024, ANI SIS Report 11-006, 10/14/82, and 11-006-1, 10/27/82.)

l ANI Corrective action - not promptly taken (see CASE Exhibit 1,026, ANI SIS Record 327,11/18/82).

Trainings- ANI not totally satisfied with B&R's response to #327; B&R is going to indoctrinate all employees in what is expected of them regarding reporting of nonconformances (1/20/83 B&R Answer). (See CASE Exhibit 1,026, ANI SIS Record 327, 11/18/82.)

Serious Breakdown - Reporting of Nonconformances -- ANI, page 2: "It is very evident that the training and indoctrination program outlined in Section III fo the QA Manual is not being implemented, due to the number of are strikes and base metal non conformances being found by ANI's and 0.C.

Inspectors during walkdowns and at non destructive examinations...Due to numerous sections of pipe being received that are so close to minimum wall 2

. _1

at time of receiving, it becomes even more critical that all are strikes and base metal non conformances are reported and documented promptly." (See CASE Exhibit 1,026, ANI SIS Record 327, 11/18/82.)

Reporting of are strikes and base metal defects: 1/7/83 B&R Answer:

Arc strikes and base metal defects shall be handled as follows (see CASE Exhibit 1,026, ANI SIS Record 327, 11/18/82):

(1) Discovered on N-stamped components, ID'd and documented on NCR; (2) Discovered prior to system walkdown by OC, documented on IR (Inspection Report);

(3) Disecvered during system walkdown by QC, entered on system punchlist and documented on an IR; (4) Discovered after system pressure testing, documented on NCR.

NCR's -- voided after being closed, without ANI notification, based on fallacious suppositions. (See CASE Exhibit 1,029, ANI SIS Record 939 334, 1/13/83.)

Document Control -- ANI: Response was returned unsatisfactory because:

no corrective action is addressed concerning this generic problem, or for the correction of illegible drawing in the files, nor the ones issued from DCC; the problem mentioned here concerns no, CMC with the documentation when presented for final review. A final review cannot be performed if you do not have the correct design document in hand. (See CASE Exhibit 1,030, ANI SIS Record 939 339, 3/1/83.)

3

Corrective Action - ANI: No action had been taken by B&R to stop further processing after the non-conformance was discussed; when discovered again, non-conformance was identified and resulted in generation of an NCR.

ANI requested a review of Unit 2 to identify possible other instances of similar nonconformances; and a demonstration of the control features of B&R's program that assure the issuance of conforming Class.1 attachment material in the field.

B&R 6/7/83 Answer: none in Unit 2; present control features will assure issuance of conforming Class I attachment material to the field. (See CASE Exhibit 1,033, ANI SIS Report 932 9-002A, 4/21/83.)

NCR's - thousands. (See CASE Exhibit 1,035, ANI SIS Report 932 G-044, 5/26/83.)

Corrective Action -- on process sheets, not NCR's. (See CASE Exhibit 1,035, ANI SIS Report 932 G-044, 5/26/83.)

NCR's "At this time, ANI's are receiving NCR's which have the 0.A.

review signed and dated prior to Engineering signing and dating . . ." (See CASE Exhibit 1,036, ANI SIS Record 353, 6/2/83.)

NCR did not correct nonconforming condition. (See CASE Exhibit No.

1,039, ANI SIS Report G-051, 6/29/83.)

Open SIS Reports listed; see especially p. 5 and 6 of B&R's answer regarding deficiencies in issue, revisions, and follow-up of corrective action requests; (see CASE Exhibit 1,045, ANI SIS Record 939 363A, 8/18/83).

4

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ANI's semi-annual ANSI N626 Audit, 7/13-14/83, (Attachment 8)

(especially regarding nonconformance reports' resolution and deficiencies.in issue, revisions, and follow-up of corrective action requests.

NCR's - generic (listing of open ones); page 7 of answer; improper closure-of outdated NCR's.

ANI's won't sign until corrected; CAR S-54; thousands of drawings were involved (page 9 of answer); CAR's voided (see Attachment 8, HSB. audit).

Established CP Pipe Support and Oversite Group which "will be responsible for organizing CP resources into an effective Hanger Team capable of moving hanger packages from their present location and status to the vault in the most expeditious manner possible, not foregoing any of the engineering or regulatory requirements."- new hanger team, "due to urgency of the pipe support problems" - Attachment 10.

3 Hanger Task Groups (HTG) established - Attachment 11; see CASE Exhibit 1,045, ANI SIS Record 939 363A, 8/18/83.)

Closure of NCR's affecting piping deviations - might have caused further distortion and/or movement, creating a problem of greater magnitude; Generic NCR M2807. (See CASE Exhibit 1,047, ANI SIS Report 932 16-009, 9/27/83.)

11 supports were fabricated without described " control of welding -

materials" -- should be reported as nonconforming condition (See CASE Exhibit 1,048, ANI SIS Report'932 10-024, 10/5/83.)

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NCs R (see CASE Exhibit 1,050, ANI SIS Record 366 and 366A, 10/21/83):

s

\'

voided;which should not be; ',

cannot' track; n .o '

being presented to ANI's for review without having the referenced drawings', revision No.; i Trend categories for NCR's are Jaconsistent; .

NCR had never; been reviewed by Action Addressee; being revised by organizations other than organization that originally prepared them; r

' info added without being revised; do not give required information; state closed when was voided; transferred to other area without being tracked; IR's issued after ANI acceptance of hanger packages; procedures. inadequate ret what is to be written up on NCR as opposed to IR; -

IR's not trended; IR trend categories inconsistent; no objective evidence QC Leads reviewing IR's; CP-QAP 11.1 says write. an IR on everything except N stamped and final accepted items; .

B&R's QA Manual 16.4.1; (August & September, there was no QAM

' requirement that adequately addressed final acceptance and the initiation of an NCR for the condition; on 10/10,83, B&R QAM Section 16, Paragraph 16.3.1 was revised to clarify this item; page 3 of 12/5/83 answer.)

6

)

Training - Everybody reinstructed (see 11/8/83 answer).

Trending - Amendment to Quarterly Report for 3rd Qtr. of 1983 issued

^11/1/83 for IR's; all future.Qtr. Reports will include an IR trend (page 2 of answer). (See CASE Exhibit 1,050, ANI SIS Record 366 and 366A, 10/21/83.)

Corrective Action -- has not resulted in correction of generic problem.

Major (generic) problem - non-conforming material used on attachments for Class I attachments. (See CASE Exhibit 1,051, ANI SIS Record 939 369, 11/9/83; see also: 939 360; 932: 9-007., 9-002A (CASE Exhibit 1,033), 9-002-1, 9-002-2, and 9-002B.)

. NCR's -- any discrepancies found in indepth search for possible usage on small and large bore hangers will be addressed on individual NCR's; see CASE Exhibit 1,051, ANI SIS Record 939 369, 11/9/83.

ANI: Corrective Action - response to 367 and 367A not acceptable; when one examines the impact of the items identified on B&R's programmatic compliance with ASIC Section III, there is cause for Inspector concern in the area of correct.tve action; an identified condition that renders hardware or supporting documentation unacceptable for ASME certification is in every case significant; nonconformance is corrected but the cause is not addressed. (See CASE Exhibit 1,052, ANI SIS Record 939 367-A, 10/31/83, and CASE Exhibit 1,053, ANI Sis Record 939 367-B, 11/18/83.)

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, _.n ANI stated (see page 2, CASE Exhibit 1,052, ANI SIS Record 939 367-A, 10/31/83, and especially CASE Exhibit 1,0'53, ANI SIS Record 939 367-B, 11/18/83, page 2 of 5):

s "I cannot comprehend the animosity and facetious of a response that makes reference to the (ANI) Inspector's ' personal assumptions',

. ' misconceptions' and ' blind-siding' . . . It should be understood that a 939 monitating report is not an ' indictment' of Brown & Root's program but is a required mechanism for the ANI to ascure full compliance with ASME quality requirements." (Emphases added.)

Welding - ANI (see CASE Exhibit 1,052, ANI SIS Record 939 367-A, '

10/31/83, and> CASE Exhibit 1,053, ANI SIS Record 939 367-B, 11/18/83):

"It is difficult to understand how 1727 identified welding discrepancies are.not deemed significant enough to warrant corrective action to preclude repetition." (emphasis added);

. hundreds of welds previously accepted have been rejected by NCR's and IR's and subsequently trended in category C-16; ANI: "The Inspector felt that considering the documente8 rejection of hundreds of previously accepted welds, B&R OA would be sufficiently concerned to evaluate those previous inspections."

(etphasis added);

"The large number of NCR's and/or Unsat IR's..." (Answer 12/27/83, page 1);

" Items rejected during final acceptance inspection were predominately pre-1982 fabrication and installation activities, and not subjected to the current acceptance criteria." (emphasis added)

(12/27/83 Answer, page 1);

8

"The greater than 50% OC rejecticn rate for pre-1982 work..." (emphasis added) (12/27/83 Answer, page 1);

"... proposed revision to B&R QA Manual will be submitted to the ANI's for review by 1/15/84, which will identify alternative methods for documenting corrective action." (12/27/83 Answer, page 2).

Monconforming material ;; Class 1 piping attachment material installed in the field; Class 2 pressure retaining material after installation in Class 1 fabrication. (See CASE Exhibit 1,052, ANI SIS Record 939 367-A, 10/31/83, and CASE Exhibit 1,053, ANI SIS. Record 939 367-B, 11/18/83; see also CASE Exhibit 1,051, SIS Record 939 369, 11/9/83.)

Major problem ; use of applied force during fabrication of component supports: unauthorized use of a porta-power to spread the horizontal members of a box support in order to achieve' required clearance. ANI stated: "I have been informed that Pipe Support Engineering takes exception to any corrective action... Engineering claims to ' factor' in stresses imposed on weldments and pipe support members by forcibly ' springing' thoso members. This rationale is not acceptable to the ANIA... Failure to address this problem will result in perpetuation of craft personnel using applied force and issuance of NCR's by QC." (Emphases added.)

Note by CASE: This ties in with and adds credibility to deposition of CASE Witness Bob Messerly regarding use of polar crane to force 32" main 9

steam line into position (see pages 25-32 of 4/14/84 Messerly NRC Dcnosition, attached to CASE's 8/3/83 letter to Board under Subject of Record Regarding Discouragement from Reporting Nonconforming Conditions at Comanche Peak Nuclear Plant);-also with testimony by CASE Witness Charles Atchison that he had observed " cold springing" of two lines from reactor coolant pump compartment number three (see discussion on page 46 of Board's 7/29/83 Proposed Initial Decision (Concerning, aspects of construction quality control, emergency planning and Board questions); closed with .

Board's 9/23/83 Memorandum and Order (Emergency Planning, Specific Quality Assurance Issues and Board Issues), page 36).

ANI: "This 932 closed based on PSE Chief Engineer Jay Ryan assuming 2

responsibility. (Signed) M. Coats 5/16/84" See CASE Exhibit 1,054, ANI SIS Report 10-030, 1/5/84 NCR's -- voided; used to upgrade supports from Class 2 to Class 1.

Major problem (though not specifically identified by ANI as such) ---,

upgrading supports from Class 2 to Class 1; possibly with non-conforming material.

Training -- need to reinstruct personnel re: NCR's. (See CASE Exhibit 1,056, ANI SIS Record 939 371, 2/6/84.)

4' Impact Testing -- Supports found which have welded attachments which require impact testing but the detail sketch does not specify this as a requirement. (See CASE Exhibit 1,057, ANI SIS Report 932 5-002A, 2/10/84.)

Subsequent revision of Design Specifications mandates material meet 10 1

5 impact requirements. Deficiencies were not ID'd until completion or near completion of fabrication. Some are being recertified; Answer 2/17/84, attached to CASE Exhibit 1,057, ANI SIS Report 932 5-002A.)

Re: hidden welds on support, in regards to interpass temperature while welding to embed plates. Mr. Lopez admitted he did not'know the thickness of the embed plate he was welding to, nor did he check the interpass temperature during welding. (See CASE Exhibit 1,058, ANI SIS Report 932 10-032, 2/17/84.)

Training -- 3/9/84: Welder retrained; OC department instructed to monitor preheat and interpass temperatures 2 days per week, to be implemented by 3/12/84. (See attachment to CASE Exhibit 1,058, ANI SIS Report 932 10-032.) .

Note by CASE: This ANI Report is especially important regarding corrective action because Applicants had been on notice regarding this problem not only through the prefiled testimony of Henry and Darlene Stiner (see page 10, line 14, through page 12, line 10, stricken at Tr. 9955/21-9960/24), but also through the affidavit of Henry and Darlene Stiner filed 7/28/83 (see Affidavit of Henry and Darlene Stiner, page 4, line 1, through page 6, line 25, attached to CASE's 7/28/83 letter to'the Board under subject of Objections to Board's Findings and CASE's Answer to Applicants' 7/15/83 Summary of the Record Regarding Weave and Downhill Welding).

However, corrective action was apparently not taken until 3/9/84, to be implemented by 3/12/84, and apparently consisted only of instructing the QC 11

3 department to monitor preheat and interpass temperatures two days a week.

In addition, this is contrary to testimony in the operating license hearings by Applicants' witnes'ses, and this ANI Report was in fact written up at almost the exact time Applicants' welding witnesses were testifying in operating license hearings that they and everybody they ever knew of or even heard of always checked the heat input when welding. (See, for example, testimony of Applicants' Witnesses Clifton R. Brown at Tr. 11,465-11,466, 11,468, 11,486; Fred E. Coleman at Tr. 11,535-11,537, 11,567, 11,570-11,571; Isaiah Pickett at Tr. 11,615-11,620, 11,643, 11,651-11,652; Armand M.

Beaumuller and Salvador Fernandez at Tr. 11,663-11,664, 11,668, 11,670; and perhaps others - we are still working on our welding findings.)

(It should be noted that the NRC Staff is also looking into the matter of proper use of preheat at Comanche Peak.)

To CASE, perhaps the most important aspect of this is not that

' Applicants did not respond to the 7/28/83 allegations of Henry and Darlene Stiner, but the way Applicants responded to them - by apparently ignoring the problem, then'by attempting to keep testimony by Henry and Darlene Stiner out of the record, then by attempting to mislead the Board regarding preheat at Comanche Peak, and next, by attempting to prevent CASE from getting the ANI Reports into the hands of the Board. And finally, by

, putting in place a partial remedy which, CASE submits, is too little too late.

Numerous IR's which are not being numbered. (See CASE Exhibit 1,059, ANI SIS Report 932 10-033, 4/13/84.)

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m 5/3/84. Answer (attached to 932:10-033): Sat IR's do not require an ID No.; Unsat IR's require assignment of serial Nos. traceable to a log, for tracking purposes.

Impact Testing -- welded attachments to Large Bore Main Steam and Feed

' Water Piping; ANI: "Due to repeated identification of non-compliance with-Design Specification requirements for notch toughness material to be used in above applications request that all packages on these systems be re-presented to the ANI for establishment of hold points." (See CASE Exhibit 1,060, ANI SIS Report 932 10-034, 4/18/84.)

5/8/84 Answer (attached to CASE Exhibit 1,060, ANI SIS Report 932 10-034): W. E. Baker, Pipe Welding Engineer, has instructed his personnel to route the subject packages to ANI.

5/16/84 (attached to CASE Exhibit 1,060, ANI SIS Repoort 932 10-034):

Acceptable for closure; PSE is in process of reviewing all affected-supports.

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ANI REPORTS - DESIGN, ETC.

. The ANI Reports and Records listed here may have applicability to the Walsh/Doyle Allegations (stated in the Board's 3/15/84 Order, page 20, to ,

be: "Now also referred to as Design Decision allegations, since the Board shares many of these concerns. Obviously a continuing, litigable concern."). In addition, there are some which may be pertinent and material to the Motions for Summary Disposition on design and design GA issues which Applicants have flied. We are asking Messrs. Walsh and Doyle to review them for applicability.

Further, some of these are important in the context of the global issues regarding Applicants' nonc'ompliance with 10 CFR Part 50, Appendix B (see discussion in Board's 3/15/84 Memorandum (Clarification of Open Issues), bottom of page 4 continued top of page 5). Some are also the type of information which would be included as part of CASE's Trends or Patterns of Non-Conforming Conditions (see discussion in CASE's 4/2/84 Motions Regarding Board's 3/15/84 Memorandum (Clarification of open Issues), pages 18 and 19). In addition, some of these are relevant to portions of CASE's proposed new contention which we will be filing in the near future.

Prom ANI SIS Records and Reports:

I ANI: Hundreds of modification hanger process control packages (both in process and completed) are in nonconformance with ASME NA-5241, NA4540, NA-4452; work done beyond the scope of work required by CMC or new revision to o

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' blueline = status of material varification and visual examination of welds is indeterminate and must be categorized as being deficient'(see CASE Exhibit 1,023,.ANI SIS Record 939 314, 10/14/82).

ANI.(page 1): "...why doe's open #8 address all welds, and what objective evidence exists in the field to indicate all other welds having-

~

been previously inspected?" 12/27/82 B&R' Answer: "As far as objective evidence existing in the field to indicate all other welds have been previously inspected nothing currently exists, as the original package is in the vault. The OC inspectors are inspecting to current modification packages, Lthat have been initiated by Welding Engineering." (Emphasis added.) (See CASE Exhibit 1,027, ANI SIS Report -932 10-016,12/20/82. )'

Grinding of CB&I Weld connecting the piping to the containment linar; in this case penetration piping is also the process piping.

No code data-report covering the welds connecting the pipe to the liner.

Code requirements not met -- letter from CB&I (copy attached) states that the penetration piping does not meet the requirements of the 1974 Code because of differences of NDE requirements. (See_ CASE Exhibit 1,028, ANI SIS Report 932 18-005, 1/10/83; closed 1/13/83 by issue of ANI SIS Record 939 334.)-

Code requirements not met (see CASE Exhibit 1,028,18-005, preceding);

ANI, p.,2: " Contrary to the above, the subject parts are not in ' full' 2

t

p 3 compliance with the ASME Code. They still do not meet the requirements of NA-1140 (c). (emphasis in the original). Answer: "DCA #16,054 to MS-100 and SS-14.has been issued adopting NCA-1140 of 1980 Edition Summer 81 Addenda.

This provides the Owner designating any parts of the Component applicable Code Edition and Addenda." ANI marked satisfactory, " Concur that NCA-1140 of 80 Ed. S81 Addenda will resolve the problem." (See CASE Exhibit 1,029, ANI. SIS Record 939 334, 1/13/83; reopens 939 51, closes CASE Exhibit 1,028, 932,18-005.)

(This ties in with CASE's concerns regarding Applicants' picking and choosing portions of the ASME code to comply with, without proper

~ justification or consideration of other aspects which might be affected, and with'a purpose which appears to be to lessen code requirements. See CASE's 4/25/84 letter to the Board, which was denied as a Motion for Discovery.)

Tests -- hydrostatic tests held at lower PSIG than design pressure.

(See CASE Exhibit 1,031, ANI S'iS Record 939 341, 3/8/83.)

Changes to controlled drawings, written in by hand in ink; drawing illegible.

Major (generic) problem -- drawing control -- ANI (page 2): "This has become a continuing problem with the DRG group, Control #83 drawings. This does not include the Iso's taken back for illegibility when presented with documentation or missing CMC's in packages." (See CASE Exhibit 1,030, ANI SIS Record 939 339, 3/1/83.)

3

Response was returned unsatisfactory because: no corrective action is addressed concerning this generic problem, or for the correction of illegible drawing in the files, nor the ones issued from DCC; the problem mentioned here concerns nct CMC with the documentation when presented for final review. A final review cannot be performed if you do not have the correct design docueent in hand. (See CASE Exhibit 1,030, ANI SIS Record 939 339, 3/1/83.)

Non-conforming material -- welded attachments to Class 1 piping -- see HSB 932 #9-002, HSB 932 #9-002-2, HSB 932 #9-002-2, NCR #M4311, NCR #N6735.

Corrective Action -- No' action had been taken by B&R to stop further processing after the non-conformance was discussed; when discovered again, non-conformance was identified and resulted in generation of an NCR. ANI I

requested a review of Unit 2 to identify possible other instances of similar nonconformances; and a demonstration of the control features of B&R's program that assure the issuance of conforming Class 1 attachment material in the field. B&R 6/7/83 Answer: none in Unit 2; present control features will assure issuance of conforming Class I attachment material to the field.

(See CASE Exhibit 1,033, AN1 SIS Report 932 9-002A, 4/21/83.)

Major (generic) problem -- support fabrication and subsequent inspection (e.g., undersized fillet welds).

Document (drawing) control -- uncontrolled drawings. (See CASE Exhibit 1,035, ANI SIS Report 932 G-044, 5/26/83.)

Document Control -- controlled stamp not used. (See CASE Exhibit 1,037, ANI SIS Record 939 355, 6/7/83.)

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Document Control and Welding -- vague weld symbols. (See CASE Exhibit 1,038, ANI Sis Report 932 4-003-2, 6/22/83.)

NCR did not correct nonconforming condition. Document' Control -- as-constructed drawings. ANI stated (pages 2 and 3) that pipe support engineer

" questioned the integrity and knowledge of Brown & Root personnel and myself. If this is to be a continuing eituation, perhaps it would be best not to explain reasons for our (ANI's) actions, since this is not the first time that an ANI has taken harsh verbal abuse from Engineering people. . . .

At this time, I am requesting that if Engineering has a problem concerning the ANI's they contact you (Gordon Purdy, B&R QA Manager) or your designee (s), and do not communicate directly to us. (Emphases added.)

8/1/83 Answer from G. R. Purdy, Site QA Manager: "I share your concern over the rather flippant response provided by Engineering . . . the Project environment is currently conducive to frustrations. . ." (Emphases added.)

(See attachment to G-051.)

Weld symbols on VCD do not show true weld configuration. (See CASE Exhibit 1,039, ANI SIS Report 932 G-051, 6/19/83.)

Document Control (removal and reinstallation of snubbers with an IRN).

(See CASE Exhibit 1,040, ANI SIS Report 10-022, 6/30/83.)

Document Control -- lack of control of stamps (numerous drawings in field). Major (generic) problem -- uncontrolled documents (drawings). (See CASE Exhibit 1,041, ANI SIS Record 939 356, 7/1/83.)

5

Serious-Breakdown -- ANI: "Upon discussion with QCI Lead . . . he

-understands the requirement for NDE (nondestructive examination) of full fillet welds is for only inprocess inspections. . . The O.C. Inspectors knew nothing about a requirement for PT- of full fillets. (These are/very knowledgeable' inspectors . ..) It is apparent that there~is a severe-breakdown of communication between 0A, upper management OC. and the QC inspectors in the field involved-in VCD walkdowns." (Emphases added.) "For this reason, and the hangers listed in this 939 ALL Class 1 VCD walkdowns are indeterminate. I am also requesting that ALL QC inspectors and their

, leads receive documented training into the criteria of inspecting Class 1 supports which' may have full fillet welds included in the hanger."

(Emphases in the original.)

Note: Closed because no Class I hanger packages have been presented to ANI for final acceptance; will be reopened if any discrepancies are found at that time. (See CASE Exhibit 1,042, ANI SIS Record 939 357, 7/2/83.)

No response to 361 received; CAR S54R1 has not been closed or extended; improperly marked drawings and uncontrolled drawings. (Document Control Satellites are identified, including breakdown of each satellite's location, etc.; see CASE ~ Exhibit 1,044, ANI SIS Record 939 361A, 8/11/83.)

N-5 -- ANI's have rejected majority of submitted N-5's; one subsystem I i

~ N-5 for SF-1 was submitted for ANI signature with an open CAR in effect against component supports fcr the Spent Fuel Heat Exchangers.

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T (Hanger Task Groups discussed - p. 8 of answer.)

LANI Access -- ANI's are consistently being denied access (hydro tests;

N-5; vault); incorrect interpretation of program was cause (Attachment 3, from Gordon Purdy).

(Open SIS Reports listed - p. 5 and 6 of answer.)

Document Control:

(ANI's can no longer accept inprocess inspections to unintelligible CMC's, etc.);.

drawings: many drawings ID'd shims as primary support members (page 10 of answer);

drawings: some drawings do not reflect other supports (including Class f

5) attached to the structure of the support (page 10 of answer);

design: early NPSI designs differentiate between primary and secondary t-members, some Class 1 drawings ID primary members (impacts material traceability requirements) while others do not (page 11 of answer);

ANI confidence in inspections performed to Engineering hanger sketches as revised by CMC is zero; hundreds of NCR's and IR's ID'd on final walkdowns to As-Built VCD/DRD drawings (answer, page 13);

the historical aspects of the CPSES pipe support program are a reality...the historical trail would often be confusing and cumbersome (answer, page 14);

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I see also Attachments 5 and 7; design change not-changed on VCD to indicate as-built condition

( Attachment 8, HSB audit), " Design analysis safety _ factors are -

Implemented to account for these dimensional difference." "Use-as-is." Common problem.

-Manual not found, not controlled, etc. (see Attachment 8, HSB audit);

(manual discontinued, see Answer, Attachment 9.)

ANI's semi-annual ANSI N626 Audit, 7/13-14/83, (Attachment 8).

Corrective Action (see also Document Control) --ANI's won't sign until corrected; CAR S-54; thousands of drawings were involved (page 9 of answer);

CAR's voided (see Attachment 8, HSB audit).

(DCA 18475, to Specification MS-100, to reflect that all embed. plate material.is A-36 unless noted otherwise on the drawing; page 10 of answer.)

(Established CP Pipe Support and Oversite Group -- new hanger team, "due to urgency of the pipe support problems" -- Attachment 10.)

(3 Hanger Task Groups (HTG) established -- Attachment 11.), see CASE Exhibit 1,045, ANI SIS Record 939 363A, 8/18/83.)

NCR's -- Closure of NCR's affecting piping deviaticus - might have caused further distortion and/or movement, creating a problem of greater magnitude; Generic NCR M2807. (See CASE Exhibit 1,047, ANI SIS Report 932 16-009, 9/27/83.)

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4 Corrective Action -- has not resulted in correction of generic problem.

Major- (generic) problem -- non-conforming material used on attachments for Class I attachments. (See CASE Exhibit 1,051, ANI SIS Record 939 369, 11/9/83; see also:'939 360; 932 9-002, 9-002A-(CASE Exhibit 1,033), 9-002-1, 9-00212, and 9-002t,)

4 Nonconforming material -- Class 1 piping attachment material installed in the field; Class 2 pressure retaining material after installation in Class'1 fabrication. (See CASE Exhibit 1,052, ANI SIS Record 939 367-A, 10/31/83, and CASE Exhibit'1,053, ANI SIS Record 939 36,7-B, 11/18/83; see-also CASE Exhibit 1,051, SIS Record 939 369, 11/9/83 )

Major problem -- use of applied force during fabrication of component supports:- unauthorized use of a porta-power to spread the horizontal members of a box support in order to achieve required clearance. ANI i stated: - "I have been-informed that Pipe Support Engineering takes exception i

ta any corrective action... Engineering claims to ' factor' in stresses imposed on weldments and pipe support members by forcibly ' springing' those members. This rationale is not acceptable to the ANIA... Failure to address this problem will result in perpetuation of craft personnel using applied force and issuance of NCR's by_QC." (Emphases added.)

ANI: "This 932 closed based on PSE Chief Engineer Jay Ryan assuming responsibility. (Signed) M. Coats 5/16/84" See CASE Exhibit 1,054, ANI SIS Report 10-030, 1/5/84.

9

FF NCR's -- voided; used to upgrade supports from Class 2 to Class 1.

(See CASE Exhibit 1,056, ANI SIS Record 939 371, 2/6/84 Major problem (though not specifically identified by ANI as such) --

upgrading supports from Class 2 to Class 1; possibly with non-conforming material. (See CASE Exhibit 1,056, ANI SIS Record 939 371, 2/6/84.)

Training -- need to reinstruct personnel re: NCR's. (See CASE Exhibit 1,056, ANI SIS Record 939 371, 2/6/84.)

Impact Testing -- Supports found which have welded attachments which require impact testing but the detail sketch does not specify this as a requirement. (Sea CASE Exhibit l,057, ANI SIS Report 932 5-002A, 2/10/84.)

(Subsequent revision of Design Specifications mandates material meet impact requirements. Deficiencies were not ID'd until completion or near completion of fabrication. Some are being recertified; Answer 2/17/84, attached to CASE Exhibit 1,057, ANI SIS Report 932 5-002A. )

Re: hidden welds on support, in regards to interpass temperature while welding to embed plates. Mr. Lopez admitted he did not know the thickness of the embed plate he was welding to, nor did he check the interpass temperature during welding. (See CASE Exhibit 1,058, ANI SIS Report 932 10-032, 2/17/84.)

Training -- 3/9/84: Welder retrained; QC department instructed to monitor preheat and interpass temperatures 2 days per week, to be '

implemented by 3/12/84. (See attachment to CASE Exhibit 1,058, ANI SIS

' Report 932 10-032.)

10 u_ _

r %

Impact Testing -- welded attachments to Large Bore Main Steam and Feed Water Piping; "Due to repeated identification of non-compliance with Design Specification requirements for notch toughness material to be used in above applications request that all packages on these systems be re-presented to the ANI for establishment of hold points." (See CASE Exhibit 1,060, ANI SIS l Report 932 10-034, 4/18/84.)

5/8/84 Answer (attached to CASE Exhibit 1,060, ANI STS Report 932 10-034): W. E. Baker, Pipe Welding Engineer, has instructed his personnel to I route the subject packages to ANI.

5/16/84 ,(attached to CASE Exhibit 1,060, ANI SIS Repoort 932 10-034):

Acceptable'for closure; PSE is in process of reviewing all affegted supports.

11

2 r 1 1

1 ANI REPORTS -- DOCUMENT CONTROL The problem of inadequate document control is closely related to the lack of prompt identification and correction of nonconformances.

Criterion VI of 10 CFR Part 50, Appendix B, is specifically titled " Document Control;" however, when CASE uses the term, we mean it in a very broad sense, to encompass other Criteria insofar as they depend upon accurate and adequate documentation in order to be effective. These additional Criteria include (but are not limited to): III, IV, V, VIII, X, XI, XIV, XV, XVI, XVII, and XVIII.

CASE believes that the extensive and continuing, uncorrected problems with document control and records retrievability have contributed to the construction and design of Comanche Peak's now being indeterminate at best and deficient at worst.

Clearly a breakdown in this important aspect of Applicants' OA/QC program goes to the very heart of CASE's Contention 5. As such, it is important in the context of the global issues regarding Applicants' noncompliance with 10 CFR Part 50, Appendix B (see discussion in Board's 3/15/84 Memorandum (Clarification of Open Issues), bottom of page 4 continued top of page 5). This is also the type of information which would be included as part of CASE's Trends or Patterns of Non-Conforming Conditions (see discussion in CASE's 4/2/84 Motions Regarding Board's 3/15/84 Memorandum (Clarification of Open Issues), pages 18 and 19). Also, this problem is relevant to portions of CASE's proposed new contention which we will be filing in the near future.

1

~

The following. summary of information contained in Reports and Records of the Authorized Nuclear Inspector (although only a part of the total

. picture which we plan to present to the Board soon) helps to indicate the

> sagnitude of the continuing uncorrected problems with document control.

From ANI Records and Reports:

Document Control -- hundreds of modification hanger process control-packages (both in process and completed) are in nonconformance with ASME NA-

.5241, NA4540, NA-4452; work done beyond the scope of work required by CMC or new revision to blueline = status of material verification and visual examination of welds is indeterminate and must be categorized as being

~

deficient (see CASE Exhibit 1,023, ANI SIS Record 939 314, 10/14/82).

~

Welding -- repairs accomplished (attempted) by grinding; no documentation found concerning these repairs being accomplished prior to release of material to field; areas not marked as required-and no documentation of PT, UT or minimum wall checked could be found.

CP-CPM 6.9D states that minor defects will be removed by grinding; however, minimum wall must be checked and documented; it was not. (see CASE Exhibit 1,024, ANI SIS Report 11-006, 10/14/82, and 11-006-1, 10/27/82.)

ANI Access -- ANI not given opportunity for involvement in installation or inspection activities re: snubbers (hold points); "If Brown & Root 2

t y

intendsLto present quality _ records documenting ASNE inspection activities to 1 the ANI at the time of execution.of N-5s those' records that'did not provide

~

' for - ANI involvement will be considered unacceptable." -(See CASE Exhibit 1,025, ANI SIS Record 322A, 11/11/82.).

Document Control -- ANI.(page 1): "

...why does open #8 address-all welds, and what objective evidence exists-in the field to indicate all other' welds _having.been previously inspected?" 12/27/82 B&R Answer: "As far as' objective evidence existing in the field to indicate all other welds have been previously inspected nothing currently exists. as,the original package is in the vault. .The QC inspectors are inspecting to current modification packages, that have been initiated by Welding Engineering." (See CASE

~

Exhibit 1,027, ANI SIS Report 932.10-016, 12/20/82.)

! Grinding of CB&I Weld connecting the' piping to the containment liner; in this case penetration piping is also the process piping.

Document Control -- no code data report covering the welds connecting the pipe to the liner.

Code requirements not met -- letter from CB&I (copy attached) states that.the penetration piping does not meet the requirements of the 1974 Code because of differences of NDE requirements. (See CASE Exhibit 1,028, ANI SIS Report 932 18-005, 1/10/83; closed 1/13/83 by issue of CASE Exhibit 1,029, ANI SIS Record 939 334.)

Document Control -- changes to controlled drawings, written in by hand

' in ink; drawing illegible. (See CASE Exhibit 1,029, ANI SIS Record 939 339, 3/1/83.)

3:

f Y '

_a

- Major (generic) problem -- drawing control--- ANI' (page 2): "This has become a continuing problem with the DRG group, Control #83 drawings. This does not include the Iso's take'n back for illegibility when presented with documentation or missing CMC's in packages."

_ Corrective Action -- Response was returned unsatisfactory because: no corrective action is addressed concerning this generic problem, lor for the correction of illegible drawing in the files, nor the ones issued from DCC; the problem mentioned here-concerns no, CMC with the documentation when presented for final review. ll final review cannot be performed if you do not have the correct design document in hand. (See CASE Exhibit 1,030, ANI SIS Record 939 339, 3/1/83.)

Corrective Action -- No action had been taken by B&R to stop further * -

processing efter the non-conformance was discussed; when discovered again, non-conformance was idsntified and resulted in generation of an NCR.' ANI requested a review of Unit 2 to identify possible other instances of similar.

nonconformances; and a demonstration of the control features of B&R's program that assure the issuance of conforming Class 1 attachment material l In the field. B&R 6/7/83 Answer: none in Unit 2; present control features will assure issuance of conforming Class I attachment material to the field.

i l (See CASE Exhibit 1,033, ANI SIS Report 932 9-002A, 4/21/83.)

I l

Control of Inspections -- Civil engineer was going to delete PT; concern'of ANI is that there are parts of welds on 4 units which have not been subjected to NDE; there is no objective evidence that root of weld joints was prepared properly; welds are not being examined properly. (See i CASE Exhibit 1,034, ANI SIS Record 939 347, 4/21/83.)

J-4 4

k

^

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)

Document (drawing) control -- uncontrolled drawings. (See CASE Exhibit 1

1,035, ANI SIS Report 932 G-044, 5/26/83.)

Document Control -- controlled stamp not used. (See CASE Exhibit 1,037, ANI SIS Record 939 355, 6/7/83.) l Document Control -- vague weld symbols. (See CASE Exhibit 1,038, ANI Sis Report 932 4-003-2, 6/22/83.) ,

Document Control -- ANI: "The disposition to their NCR did not, in my opinion, correct the non-conforming condition. -It states that Engineering had sufficient information. While this is good for their purpose, it does not satisfy 'the requirements of Reference 2 (NA 3355) or Reference 3 (NA 4420).- Also, since Brown & Root must now certify that all requirements have been met, it is essential that the people doing VCD walkdowns be in possession of clear and concise information to work with, (Reference 3)."

(Emphasis added.)

Weld symbols on VCD do not show true weld configuration. (See CASE Exhibit 1,039, ANI SIS Report 932 G-051, 6/19/83.)

Document Control (removal and reinstallation of snubbers with an. IRN).

(See CASE Exhibit 1,040, ANI SIS Report 10-022, 6/30/83.)

i Document _ Control -- lack of control of stamps (numerous drawings in field).

Major (generic) problem -- uncontrolled documents (drawings). (See ANI CASE Exhibit 1,041, SIS Record 939.356, 7/1/83.)

5 1

, .J

. -- - - . , -.- . .. - - . - --- O

Document Control -- no response to 361 received; CAR S54R1 has not been closed or extended; improperly marked drawings and uncontrolled drawings.

Document Control Satellites.are identified, including breakdown of each satellite's location, etc. (see CASE Exhibit 1,044, ANI SIS Record 939 361A, 8/11/83.)

Open SIS Reports listed - p. 5 and 6 of answer.

. Document Control: -

(ANI's can no longer accept inprocess inspections to unintelligible CMC's, etc.);

drawings: many drawings ID'd shims as primary support members (page 10 of answer);

drawings: some drawings do not reflect other supports (including Class 5) attached to the structure of the support (page 10 of answer);

design: early NPSI designs differentiate between primary and secondary members, some Class 1 drawings ID primary members (impacts material traceability requirements) while others do

'1 not (page 11 of answer);

ANI _ confidence in inspections performed to Engineering hanger sketches as revised by CMC is zero; hundreds of NCR's and IR's ID'd on final walkdowns to As-Built VCD/DRD drawings (answer, page 13);

the historical aspects of the CPSES pipe support program are a reality...the historical trail would often be confusing and cumbersome (anewer, page 14);

References:

Section III ASME B & PV_ Code

' (1)'INA-5241- .. " Stipulation of Inspections . . . . . . . . . " i Prior to is.suance of process sheets or controls required by NA-4451, the manufacturer or installer shall review them and the applicable drawings with the inspector who shall then ,

stipulate the inspections he intends to make in order to fulfill the requirements of NA-5210.

(2): NA-4540 " Examination of Process Status"

- During manufacture or installation, measures shall be established to indicate, by the use of markings-such as stamps, tags, labels, routing cards, or other suitable means, the Status of Examination and tests-performed upon individual items.

These _ measures shall provide for the identification of these iters which confom to examinations and test requirements and those that do not conform.

(3) NA-4452 " Process Control Check List" Proi:ess control check lists shall be prepared, _ including the document' numbers and revisions to which the process confoms, with space provided for reporting results of completion of specific operations.........

DISCUSSION:

hsi Hundreds of modification hanger process control packages, both in process and completed, are in noncomformance with references 1 thru 3 above.

EXAMPLES: In Process Work Hanger CC-1-028-024-S33R-- This package was presented for ANI preliminary review. . Hanger is;to be modified per revised blueline (BRH Rev. 4). By comparison of BRH Rev. 3 and Rev. 4 it became obvious that to rework th.is hanger to meet new design requirements requires removal from its installed location. Re- .

moval will necessitate cutting out welds in order for the hanger to clear interferences and supported pipe. There is no way to determine the extent of work required.

Hanger CC-1-057-010-A33R-- Thi~s package was presented for ANI preliminary review. Hanger is to be modified per revised blue-li'ne (.BRH Rev. 21. By comparison of BRH Rey,1 (.as amended by CMC 107471 and BRR Rey, 2 it appears that major rework (new material, replacement of brace and baseplates, etc.) will re-quire removal of this support by cutting out items presently installed. There is no way to determine the extent of work required.

EXAMPLE: Completed Work Hanger CS-1-007-015-CS2R-- fiultiple weld data card states

'." Nb, J

f'.w"'b . Page 3. 3 W .

" Modified per IRN 143876". The inspected item removal notice

+ ' states " Pipe Dept. Reworki- Line. Removing box assembly from pipe".' .

This support was fabricate to CMC 33079 Rev. 8.

- Rework was

. inspected to CMC 38079 Rev. 11. The MHDC was submitted to the ANI for rework review. This rework should have been nothing more than rebolting the hanger and making approximately 3 weldds to re-attach tube steel cat loose for the hanger to clear the pipe. However, after reviewing the package it is obvious that this support was virtually refabricated with at least 15 welds being made and new material installed.

FINDINGS:

(1) Contrary to requirements of reference 1 the ANI.was not given the opportunity to review, for purposes of stipulating inspec-tion hold points, that scope of work to be performed on hanger CS-1-077-015-C52R beyond that called for to bring the item in compliance with the latest applicable design. If a weld is cut (after statused as acceptable by examination) the ANI must have the opportunity to select an inprecess inspection hold point.

(2) Contrary to reference 1 the ANI has not been provided with in-formation that accurately defines the scope of work. Drawings, procedures, process control documents, and other documents applicable to the extent of work must be clear, understandable,

~

and without ambiguity.

- (3) Hanger CS-1-077-015-C52R is unacceptable for final review due to noncompliance with reference 2. The status of material O

verification and visual examination of welds is indeterminate.

The actual scope of rework perfonned is not defineo or described by drawings, CMC, IRN, or any other document within the package. Since all Quality Control Inspections are final' there is no objective evidence available that the Q.C. inspector was aware of the extent of examinations and verifications to be performed.

(4) Contrary to reference 3, all 3 examples listed were or are to ^

be inspected to revisions of bluelines anf these revision numbers are not listed on the inspection document (,i.e. MWDC)'.

In cases where supports are fabricated and installed to typical details (Cp-AA-XXX) these drawing numbers are not refer-

,enced on the inspection document.

CONCLUSIONS:

(1) In instances where modification packages are presented to the ANI for preliminary review and do not adequately describe all work (e.g. cut welds, replace material, etc.) to be accomplished, the ANI will be unable to review and forward the packages.

(2) During final revied of hanger packages, those that reflect work done beyond the scope of work required by CMC or new revision to blueline must be categorized as being deficient per finding #3.

. S

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.35-1195~

j INTEBOFFICE MEMO TO:.

Marvin Coats DATE: November 20, 1982

-FROM: P. C. Lahoti

SUBJECT:

35-1195, CPSES SIS Report #314, dated 10/14/82 B&R Response dated'11/18/82 wuhad T,he followinglcorrective action, in response to tihe SIS Report #314, is proposed for your concurrence.

Finding 2: Welding Engineering will list the construction operations re-quired and the scope of the work to be performed in detail on the Wald Data Card so that the ANI will have clear under-standing of the extent of the work involved. .

Finding 1

& 3: The ANI should have been provided the opportunity for pre-liminary. review of the activities performed on hanger r' ' CS-1-077-015-CS2R. The ANI shall be given the opportunity for reinspection of this hanger to assure that the hanger has been constructed to the requirements of the applicable drawing. The corrective action for the finding #2 will eliminate any future recurrence of this non compliance.' -

Finding 4: As agreed with the ANI, effective December 1,1982 the QC Inspector shall indicate the revision number of the drawing or the typical detail (CP-AA-XXX) used for the inspection of the hanger. The inspections performed prior to this date do not require backfitting for referencing the re-vision numbers. However, the Document Review Group (DRG),

when requested, will' assist the ANI in ascertaining the ADOED applicable revisions of the drawings used for the past inspections.

W P. C. Lahoti Procurement / Surveillance Supervisor PCL/cm cc:. G. R. Purdy '

, T. Blixt I

, Bill Baker (Welding Engineering)

R. Siever D. Leigh QA File ;

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CPSES, 35-1195 g.

M INTEROFFICE MEMO IM# 24,384 3

T0: Jerry Lytle , A[(,_f;,4.j DATE: October 19, 1982 FROM: G.L. Morr'is

SUBJECT:

SIS Report #11.-006

-In response to your SIS _ Report #11-006, it was observed that grind-ing was perfonned prior to QC notification. NCR #M-4194 has been issued for violating CP-CPM-6.90, Paragraph 3.19.4.2. Since grinding was perfonned prior to QC notification, checking of minimum wall and documenting VT/PT was obviously not performed by QC. This shall be performed, as applicable, in accordance with the disposition of the NCR. ,

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Site Mechanical Level III GLM/jku '

cc: G.R. Purdy P.C. Lahott 4

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SIS RECOR0 FOR MONITORING Q.A./Q.C. PROGRAZS

322A THE HARTFOP') STliA.%t BO!!.E]!NSPECTICN cd INStJRANCE CO.stPANY HAR tt ORD.CO ..ECTICUT p.Itu - CASE EXHIBIT NO.1,025 se an - r.u.,

en s,.w gg

! Mr. Gordon Purdy. 0A Manacer cwc=ns cow , == w pie November 11. 198? 1 lor1 w nce on rato couarn gj Brown & Root. Inc. Hn Houston L 'pgagi,ss newrea oatres , , U C38 "g 'nsetstion tocano" rield Repair /

CPSES Glen Rose. Tent 76043 SA00 Assuday Anendu Ci unia I, the undersigned have monitored your QA/QC manual on: and find the following sections:

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,,. ,e on oc ..~ . p. r.,,. ; o e ~,, . . - . . .. . . .,

This. follow up is to clarify the finding identified on 939 #322 dated

. November 5,1982.

W= . Paragraph 11.1 of the Quality Assurance Manuel statesi

- 3 .s lC _fThis section establishes the controls for inspections performed at specific stages in l . Brown and Root fabrication and installation activities to ensure that items meet the

_ applicable design documen's and the code." ."See attached".

COVER

!k. CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below. and give date for completion of corrective action, so that items may be remonitored by: November 19, 1982 ,

, s . .,

Please keep the Original of this form for your records and return a copy to inspector named below.

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"'8 "" 5*'8 '"8 8 '* ' ' ' ' '

LXw u nr/aorneatatin sis For.c 1.ra.o. November 11, 1982 > 3

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l the undersigned, have remonitored the above unsatisfactory condefions on:

p/j,,jp and found them: Satisfactory Cunutlefactory finstam cetow) * '

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References:

' 6*) c NA-4451 The ......... installer shall operate under'a controlled ,

system such as process sheets,' shop procedures, check- ,

ligh, travelers,orequivaTentp'rocedures~...............

-Example: Process sheet -

WDC, MWDC, MRS, etc.

Traveler - COT

, Procedure Check -. QI-QAP list- Hanger inspection 11.1-28A .,fom, snubber inspection check list.-

NA-4510- In process and final examinations and tests shall be

established to assure conformance with documented instructions, procedures, and drawings.

NA-4530 Check lists shall be prepared, including.........

with space provided for recording results of examinations, tests, and ins space for ....pections. The check list shall include

. . . . . . . . . . the inspector's signature , initial ,

or stamp, and date for those activities which he witnesses.

NA-5241 Prior to issuance of process sheets or controls reautred by .

NA-4451, the manufacturer or installer shall review them and r.

the applicable drawings with the inspector who shall then stipulate the inspections he intends to make in order to

( fulfill the requirements of NA-5210.

Discussion: The installer is mandated to establish a method of process control and to establish a method of documenting results of inspections & examinations. Both functions may be accomp-lished by utulizing a process sheet or traveler. NA-5241 requires that these. documents be presented to the ANI prior to issue and NA-4452 requires that spaces be provided the.

- ANI to sign or initial and date those' activities he witnesses.

Alternately, the installer may implement process control in the form of a procedure and inspection / examination verification in the form of a checklist. In this instance the requirements for check lists are delineated in NA-4530.

Again there is a requirement for providing space for the ANI to sign or initial and date those activities he witnesses.

This recognized alternate is the "other controls" discussed

in NA-5241.

It becomes obvious that the installer must provide for preliminary review by the ANI irregardless of which form of process control / inspection he chooses to utilize.

Conclusions:

(1) Brown and Root had implemented the controls for snubbar installation (aninstallationactivityundertheNAcertifi-cate) by issuance of Construction Operation Travelers. These I;, meet the intent ofreview.

AN! preliminary NA-4451 and NA-4452 and were submitted for tm

_ . . , . .- -. =

,, Ih,t : .

Page 3, of 3 (2) Brown & Root dis :tinued the use of COT'S and 1

I implemented the contr~ s required by NA-4451 and NA-4530 by issuance of a construction work procedure. QA inspection procedure, and QC checklist. These meet the intent of the code except that the ANI has not been given the opportunity for involvement in installation or inspection activities. ,.

(3) The hanger inspection report (HIR), Exhibit 11.1 of the QA manual, has been utilized by Brown & Root for some time in documenting hanger inspection activities.

However, for purposes of documenting code inspection activities-this document is redundant in that it repeats all inspection operations performed on the weld data card.

Ho..ever, the snubber installation checklist, attachment 16 to QI-QAP 11-1-28A contains inspection operations that go far beyond those indicated on the weld data card.

~

(4) If Brown & Root intends to present quality records documenting ASME inspection activities to the ANI at the time of execution of N-5s those records that did not provide for ANI involvement will be considered unacceptable.

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IM4 24,565

' Tof- M. Coats,~ ANI Imad DME: Novenber 19, 1982 1

FEM: D. Sanders SUE 7ECT: Response to SIS ,

Report #322/322A.

CPSES, 35-1195 1 The QC Ch=+14=t, Attachnent 16 to Quality Instruction QI--QAP-ll.1-28A,

, is an added device for otmpleting the hold points / inspection points identified on the Multiple Weld Data Card. The checklist is not used by itself, but in conjunction with the hold points already identified on the Multiple Wald Data Card.

In order to satisfy the ANI's requirements for establishing hold points for Mechanical A..- 2.icn insta nation activities with respect to snubbers, the fonowing actions are w.W:

1. A list of pipe suppw.i.s requiring snubber installation for small bore and large bore piping is attached for the ANI's use in selecting hold points for pipe suppw.u that he wishes f;.,; , to witness snubber instanation.

2. The ANI may mark the list showing the ,'ipe supports he has

selected to witness'the snubber installation, or he may sub- !

mit the selection en a separate transmittal. The list and/or j the 6 -7J.ttal should be forwarded to the QE Supervisor.

, 3. Catstruction nust notify the Quality Centrol Superintendent j or his designee prior to instal 1%g a spinhr that the ANI has established as a hold point.

+

t 4. The Quality Centrol Superintendent or his designee will be L responsible for notifying the ANI when Construction is ready l to instan a snubber listed as a hold point by the ANI.

. 5. After ocmpletion of the instanation activities, the QE Grt:mp i

!' shall subnit a h=nt package for ANI's acceptance. The package will include the pipe support Multiple Weld Data Card 4- for ANI to sign his hold point for the srn***r installation.

6. QI-CAP-ll.1-28A will be revised to identify establishment of j ANI hold points. ,

i

/M Di s t upervisor D8/b" (i -' ~{s cc: G.R. Purdy R. Siever G. Tanley- D. Imigh -

T. Blixt - QA File

, SIS File-

_ , . - - . _ _ - _ . _ _ _ _ ~ _ - _ , _ . _ . - _ ,._._._ _ _._

~

eN SIS

.N,,.flECORD FOR MONITORING Q.A./Q C. .-30 GRAMS -

", Tile HARTFCRD STEAM E OILER INSPECTION tud INST lRANCE COMPANY CASE EXHIBIT N0.1'026

, ll ANTl'OND. CONNECTICI,T 0tl':2 a327 so onen.. .no r.oo.

cart s,stis or

-*,$ ,__y*- J rW am DurbQLVanmor-cusicwos c;unar haut * '

MovAmbo ** 1R, 19R7 1 *)

.J saancM pNsp att;Cm ca # Cat.GN chh!av rascioudt uss omtrJ NFolics Up g5

'58 Erown & Pcot. Inc. i

' Houston lHousten " Reevired closed g asticace 43caric"

~ Field Repair /

CDAM nian nose. Texas 76043 Shop Asumbly OAltuation blasmin

1. the undersigned, have mordo' red your QA/QC manual on: 11 82 and find the following sections:

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Satisfactory: -

ria.no.sv oa:oc men . ner.on lue. .no r u3 on so nr.or on. wn o,. nan aneamanc. u noi.uos.,

1 Unsatisfactory O. A. Manual Section II Quality Assurance Program.

Peference: NA 4800- Corrective Acticn which states in part "non-confonrances are o

5g prcn:otly identified and reported".

85:

$E Feference: Brown & Pcot Q. A. Manual Section 16- tbn-conforTning Itans Paragraph 16.2 "It is the responsibility of all sita employees to report ite:rs of ncnconfontance to their supervision or to the Site Q.A. Manager".

See At W hed. 30VER CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, and give

{ dite for completion of corrective action, so that items may be remonitored by: Dec m hsr 1. 1992 s o.o.o PI:ase keep the Original of this form for your records and return a copy to inspector named below.

2*'*

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1 Reg ugr/ Representative 2 rile Nov. 19, 1982 ) w -_3 M, -

atsc.ture os :,ost irtus ctsca sto asevt as atmc unsansaconi rc n,,n

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l, the undersigned. have remomtored the above unsatisfactory conditions on:

and found them: C Satisfactory Unsatisfactory (Esplain below)

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$** h0" $l$ roteign insp. 8I 5*I8 58t8 i"s8 das8ut*<#

L. Reg. Mgr Representative CFile h

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327

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c. Page 2 of 2 w l l

Brown & Ibots procedures CP-GM 6.9D -

3.19.8 and 3.19.4 and QI-QAP 16-2 gives direction to field personnel on how to promptly and propc.rly, report and document are strikes and base metal non conformances.

It is very evident that the training and indoctrination program outlined in Section II of the Q A Manual is not being implemented, due to the number of arc strikes and base metal ncn conformances being found by ANI's and Q.C.

Inspectors duringwalkdowns and at non destructive examinations. It is a requirernent of both Code and Q. A. Manual that these non conformances be reported ct the tine they are first made or discovered and not left to a chance discovery during a walkdown or through casual observation as is now happening. Due to numerous sections of pipe being received that are so close to minimm wall at time of receiving, it becanes even more critical that all are strikes and base metal non conformances are reported and docunented prucptly.

It is recognized by this ANI that are strikes and damages to base metal is inherent during construction and that steps haw been taken to prevent this fran happening (i.e. CAR S-48), howver, even the most careful welder will make an are strike at times and mistakes are made during material handling.

This is also recognized by the Code, hence the requirement of NA 4800. Sinca Brown & Poots Q.A. Manual recognizes it also and makes provisions for the *

~ prapt reporting and docunenting, all that is needed is for it to be inplemented.

Exanples:

Cr-2-PB-30-3 Two are strikes ' Reported by MII to Weld Tech.

SI-2-SB-14 Rev. 1 Spool 1Q2, Pc 1 Arc strikes on base metal and grinding on base metal with no Q.C. involvment. ANI found it and reported it to Q.C. inspector who do::umented it and handled it prcperly.

MS-2-RB-20 Arc strikes discovered by ANI during Pr of weld excavation.

MS-2-RB-21 Numerous arc strikes discovered by RII and brought to 0.C.

inspectors attention. '

Also: NCR nutters' M4154S, M4211S, M4174S, M4177S, M4181S, M4190S, M4203S R1, and being insulated. M4199S. One of these NCR's was discovered while systen was This 939 closes SIS Peport # 11-006-1 O

ve .

' 9 0 W R O'Ik X3t.k1C.

, INTERCETIC. LT IM# 24,969

'IO: Marvin Coats, ANI DATE: January 28, 1983' FI M : D.L. Sanders SL%7ECr: . SIS Report 327/327A.

l CPSES, 35,1195 !

Raft 1. ANI Office Memorandtn to Rursell Scott / Rusty terris dated 1-27-83.

l

2. B&R 'Ihree Part Merno to M. Coats frm Russell Scott dated 1-27-83. .

Attachnents: 1. IM424,839 dated 1-7-83.

2. IM#24,935 dated 1-20-83.

l

['identifiv:Ib to further anplify Mr. Lythle's Office Murnorandta (Reference 1), Mr.

me that he was no SIS Report #327, dated 12-30-82(.) As a totally satisfied with result, IM#24,839 datedB&R's 1-7-83response to i

' (Attachment 1) was issued to supervisory WK4 cal requesting their assist-ance in informing personnel of the need to prevent arc strikes ard report are strikes and base metal defects praptly to the QC Group for proper kl identification, doctmentation and correction.

In addition, on 1-20-82, IM424 935 (Attachment 2) was issued by the B&R CPSES Construction Project Manager reinforcing management's support con-cerning the reporting of nonemformances. Construction's indoctrination l

of personnel regarding their responsibilities in the prapt identification and reporting of nonconformances should be empleted during the week of 1-31-83 to 2-5-83.

, Upon cmpletion of Construction's indoctrination, no further action is t

cmsidered necessary by B&R.

/.

D.L.

. ~

rs Le 5 Q. S ser 1 Dtsma oc: G.R. Purdy J.T. Blixt t P. Clarke, III SIS File 3.'q N - h is is e.f .J:,sly ease.et- I wn s lisC,d witk g,:,. op,,n f.a y did ;J,~ me. O. s, ).n + u z t t.~J.J s s. rL. A tJ u d . . /. ,

the e rsft en 6 .',- tra:a am . 1.; .a . F y, M SOME RfA5 , ONt.

.J . . : 1. J !a sed n s .J]d n ,s. se p fret Domo ru /ers?*L 7VIMG!

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. m l'- I!f!IN27 ICE MO 2M9 24,839 l

' TD: Distrih *4 = ,

DWs January 7, 1983 .

i FMM D.I,. Sanders '

2B33C2: CP M , 35-1195

, Reporting Mennonf -- !T Conditions.

1 i

In the past year ce so, are strikes have been a major nonconfczudag l acmditica as evidenood by the number of IR's and N:R's issued to ;

id=*4*y and correct them.

i i

-A marked 4-. = . A has been notiond in the efforts to prevent arc i strikes by the use of ;=----iive barriers and covers, proper suspension i of = WT leads, proper .--- aT, etc., and reindoctrination of

, personnel in the cease and prevention of are strikes. Howevne, there l

are concerns that Wisa are strikes are maae ce base metal defects t discovered, they may not be reported p-ly or be left for %ance discovery during QC *=1h or fond through casual cheerv cion.

k7 The ABE E Manual idonef fian that it is the responsibility ' all (

?. site esqdayees to report items of nonconformance. QA Instra icn i j QI-QAP-16.1-2 =M fia= the fbuowing conditions and methods for re-porting arc strikes and base metal defects: :

l 1. Base metal defects and are strikes discovered on N-starroei !

i ocuponents shall be identified and documented in accordance l i with a Norrumfamanna Report (NCR) .

1

] 2. Arc strikes and base metal defects discovered prior to i system walkdown by QC shall be doceented on an Inspecchn l maport (IR) . !

3. Arc striks.s and base natal defects discovered during system ,

walkdown by QC ahall be entered cn the systar. punchlist and !

documented on an Inspection poport. i

4. Arc strikes and base metal defects discovered after system !

pressure testing shall be doceented on a Nanconforume !

! B8 Port. !

4

, i I a requesting the assistance and cooperation of all QVQC and Craft i

(

mapervisory personnel to assure that their personnel are aware of not

only the need to prevent are strikes, but also the need to report are i j strikes and base metal defects prcmptly to the QC Group for proper

~

identificatim , decemntation and oceractim .as identified above. ;

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.g Page 2 of 2 maparting r= ---" - 'M Omditisms(Ctat'd)

Your zuspense id_*im that your .-1 have been made mere of and understand this amm is espected by 1/22/83.

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Distributicut G.R. Purd'f l J.T. Blixt R. Slaver D. Hoodyard l

J. Patten J. megen J. manline ,

W. Mansfield

. J. Shaver

-(.. .<; '

D. Doyle i- F. Przybylaki T. Mathany M. Todd ,

S. Ball ~ '

E. h_,1*4_

R. Marris

, D. Imigh

, V. ' ^4--:-z l R. Gray 4 P. Ashcraft f

G. Barmetzen P. Imhoti All Craft &_ M ? :'= (J

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35-1195 1-20-83 h&Roounc. .

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MEMORANDUM U M 24935

) . 1 TO: D stribution. DATE: January 20, 1983 .

FROM: D. C. Frankum SU8 JECT: Reporting of Nonconformances

, The purpose of this memo is to reinforce management support concerning the reporting of nonconformances. To ensure that all personnel are aware of their responsibility concerning this item, all employees that may have the opportunity to identify a nonconfomance shall be indoctrinated in what is expected of them, and the indoctrination documented in accordance with CPM-2.2.

All employees have the responsibility of reporting items of nonconformance'to .'

their supervisor or to the QA Department. Prompt identification of nonconfomances is required by the QA pro ;

! nonconfoming condition. gram, and in necessary for the timely correction of the l

l Everyone's cocperation in the reporting of nonconfomances is expected and appreciated. (}

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0. . C.-T ra rAwa s

Project Manager DCF/km CC: All Department Heads All Superintendents All Foreman l

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SIS REPORT O_ - CASE EXHIBIT NO,1.027.O as.oa THE HAMTFOND STEAM 180lLEN INSPECTION and ,'.st.*RANCE COMPANY 1:4seis sHess.t:ss.%%snt sert enseea 70 N:b.

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REASON FOR ISif , f n .

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INTERO m c' _ '3 0 IM# 24,780-TO: Marvin Coats, ANI DATE: M r 27, 1982 FIO4: J.T. Blixt SUBJECI: ^ Response To SIS Report

10-016 Dated 12-20-82.

CPSES, 35-1195 In response to your questions on this SIS Peport, the B&R QC inspectors performed the original inspection and sign-offs' on October. 21,1982.

On M r 13, 1982 a CMC was worked as a modification package by the craft to increase the size of two fillet welds frcm 3/16" to k".

On M r 20, 1982 a B&R QC inspector performed a visual examination of these two welds as addressed in the modification package, and found them acceptable.

The reason operation #8 addresses all welds is that it peh to the specific welds addressed on the modification MOC, and therefore not all welds en that specific hanger, are being examined.

As far as objective evidence existing in the field to indicate all other welds have been previously inspected nothing currently exists, as the e

original package is in the vault. The QC inspectors are inspecting to current modification packages, that have been initiated by Welding Engineering.

To further clarify the welding perforred on a modificatien package, .

Welding Engineering will enter in the Weld No. Block at the top of the MOC "As Per DOA" (Description of Activities), which is shown on the reverse side of the nodification MWDC.

] - .

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J.T. Blixt g.

[ QE Group Supervisor

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cc: G.IO Purdy

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R.-Siever M SIS File a rzE u

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SIS REPORT

/O-0/d i

THE HARTFORD STEAM BOILER INSPECTION and :.< SURANCE COMPANY

' HANTFOND CONNECTICt.Testo:

TO: -

OATE SHEET OF lA .

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REASON F u COPlES SENT TO: -

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                           , :S REPORT                                   @                                                  O - CASE EXHIBIT N0.1,028
        ',fy-THE II ANTFOND,HARTFORD       COWCULTTSTEAM  MH DOILliR INSPECTION and INSURANCE COMPANY m

10:- i! 18-005 DATE Mr. G3rdon Purdy Q. A. Manacer : SHEET OF

 '                                                                                                                               1-10-83                                               l j70M:                                                                                                                                                   1                   1 H.O./ BRANCH OFFICE Joe C. Hair                    ANI
        ,..aGANIZATION                                                                                                          Housten Brown & Ibot. Inc.                                                                                                                                                 I

_! 0 CATION STREET CITY COUNTY STATE ZIP COOE ' CPSES Glen Pose Sonervell Teyn,s

          ' t RSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) .                                                                                                       7604'1 Mr. Drem I'hoti                           PneaYuit Stgyilance Sticervisor
                                                                            -                                                                        CONTRACT /P.O. NO.
         ' EASON FOR Vi$lT Wil tim nnt' low mnt"Prt
         ; M1ES SENT TO:                                                                _
            .]s.O. En, cf.; , sis                  O Chi.t in ..c=               GR.gional Manager, $!$         @Other (Specif   y      ): Inso. file.
                          .On this date I was presented NCR M4609 Rl. This NCR pertains to grindinct done                                                                           ._

on a G & I weld connecting.the piping to the containrent _iner. In this case the. ... penetration piping..is also the_ process piping. . Unon investigating this tratter, there ._ is no code data report covering the 5 elds. connecting the.pice to tM liner. A letter. from G &.I states that the penetration piping.does not meet the recuirements of the . _ _ . 1974. Code because.cf_ differences.cf NDE require::ents.._The data report covering..t p fabrication..in the G .&_.I..shcp is to.the 1971.C;de Sumter 73 addenda. Attached is.a copy of G &.I's letter. . .. Until there.is a resolution to this SIS Peport, tm thines cannot ta.t e place:.. (1) __ Closing of NCR M4609 R1.

"~'

(2)

                                         . Signing any data repart v/nere a penetration is the proc.ess piping                                                       .

for any system. .

                                                               / Hj'd3                                          .

N& W W4.Y ..

                                                                                                                              .c~             ,.

[Q . . , , , _ _ _ . , _

DOVER na YA9 0

      .           to.7e esis:                                                                                           iTa m m / 10 10 0 'l
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                *                                          ~ Chicago Bridge & Iron :         .;pany 8900 Fairbanks north Houston road
               .d'I                                 i                               '

p o box coC55

                                                  .I                                ,

Houston. Texas 77o40

VBR-1237 COPY TO 8C \ J gJ terephogg7 gsgS1195 December 28, 1979 ~

GM JAN 021980 { B

Brown & Root, Inc. --

                                                                             .' 4 f"[Yb-                               y 9 ggq_,gNc ossf.

P. O. Box 1001 Glen Rose, Texas -l-75043 j. pga;ger 333, Attention: Mr. D. C. Frankum PSolECT Etica. l Project Manager 3 g' "riQUIRED READING' .i 9

                                                                                                                                      'PROJEckC0tlT. ENGR.j-J.,

g[][ RE: 2-135'9 C0ffrAINMENT LINERS COMANCHE PEAX STATION Tucco QA l

    ; -2'3g@                                                     .'       BROWN & ROOT *FOR TUSI PROJECT CEH .MR.

22 BROWN & ROOT SUBC0ffTRACT #35-1195-132 ga.,e

                                                                    .. GIBBS & HILL PROJECT #2323
                              )l[f GLEN ROSE, TEXAS                                                                                   I1 CBI~ CONTRACTS 74-2427/280 Dur rir,'Frankum:                           CBI LETTER NUMBER'HHC-473                                   < "-"M  i               ,
                                                                                                                                                                  .2.
                                                                                                                                                                            /O
 ~                                                                                                                                    // h                              I/_

Your letter BRV-9551 requested that CBI proceed with the certi. % _..J

                                                                                                                                                     .                          =

the ASME Class II penetrations in Units I and II containment liners to meet the sum:er 1974 addendum of Section III of the ASME Code. r.ade within the strict letter of the Code.After extensive research, o

                           'lies cation                  and welding procedures, meet theThesummer with the NDE requirements.                                                                                         problem of 19 The winter of 1973 addendum referencesTheSection                                                                  procedures
                                                                                                                                                           .           V for all used on the' work were inade to compiy with the summer of 1973 addendum                                                       The RT not.

procedure usedthey willdocomply with are:Section V; however, the MT and PT will The reasons not ccmply 1. The amperage requirements for MT by the prod method are different

                                    .. . Appendix IX-requires 100 amps per inch of pr:d                                   icir.c. m;ninum.

ar.d .'00 to 125 a: :s rer inch

                                                                                                                ~0r..icch'ene3r
                                                                                                                              &:sses up to as                  3/4 inchT. i-               2/ a J

6e C-12.

                                                                                                                                                      -m--      "

              . ,.                               - - - . . gr -                                             -                                   _.
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                                                                            $.!. Chicago Bridge & tron Cnpany.
                . ..                                                .. w                                                                      .
    , _ f. . .                                                . . .f. ;.                                                                                                                                .

c .- - December 28,.1979 Mr. D. C. Frankum . c J't' ) Page 2

d,, -

a Y. ' "Y

                                                              .[. .:.;n 2.
                                       -                Under Section V, both.MT'and PT. r' equire that the surface preparation                                                                             [
                    .g                                  cleaning extend one inch onto the plate material frca the edge of
                                                      ;the weld. Appendix only requires cleaning of the weld.                                                                                               *

q. .

                                                                                                                                                                                                     . 1.-

While our Mi procedure only requires 100 amps per inch minimum, our actual Q.A. y. records indicate.that in most instances we did comply with the Section V require-ments. The only exceptions were on Unit II penetrations MV-4, MV-15, and MV-19.

s. Unfortunately the cleanfrng requirements of Section V were not part of the pro-

h cedures and for'this reason none of the penetrations can actually be certified to

            .:,n.-

the summer of 1974 addendum.

                                                           ..                 r           .                                                                                      .                                   .
              ~,                                                                                                                                                                               -

If we can.be .- of, additional help on this subject, please let us know.

                                     ;,, dg:p.=; A.. = .
                                    'RO,Ytc. ALEXANDER                                      g,,JN PROJECT MANAGER RCA/ln o..      .

cc: - Mr. L. A. 'Ashley . . . Brown & Root Inc. i

                                                     . c: . 7.V-*

Mr. D. A. Voves Brown & Root, Inc. - Mr. H. R. Rock -

Gibbs.& Hill, Inc. ~

                                                        . . .. .           .                                           .c             .                                                                                .
          ' .                               Mr. Homer . C. Schmidt                                                    . .'2
          *l?.y .

Texas Utilities Services, Inci . .

                                                        ;-:3 4                                                        . :y. :

Mr. 'J. T. Merritt U ~~

                                                                                                                      ; O .;)';:-                             :
             .--                            Texas UtiTitie's Services,' Inc.';.[~;?                                             .
                       +
                           ,..                                                                                        . .x . .                                                                      .7,l, L.-                                                     Q,.q -                                                                               .-
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                             ,;                                                                                                                                  Page H1 of 5

IT)RM Ne2 MANUFACRJRERS DATA REPO!!T FOR NUCLEAR PART AN As required by the Provis - of the ASME Code Rules Date 7A.hTl By - HS Chkd - DNG

c. i. (a) uanufaciured by Chicago Bridge & Iron Ccmpany Bimingham, Alabama g

m.me .nd .u,e.. e, m e nu,.ciu,e, e, ,e,u (b) Manufactured foc Brown & Root, Inc. Houston, Texas (Neme and addrese nr unnut.esurer et eenipseied nues ., eempenene)

2. Identification.Manufactuaer's Serial No. of Part 346-4 ne N u'l Bd. No. 1 346-2., 347-3, (a) Construered According :o Drawing No.3.48-0., 30-? D, awing Prepared by CBI Cont. 74-24270 (b) Description oI Part inspected 1 Piece SA333 GR6 6"D Sch 40 Pipe x 6'-6 long w/ attachments (c) App!Icable ASM E Code: Section !!!, Edicion l97I Sumer 1973

                                                                                          , Addenda due                      , Case No. 1493           Class 2 3,   a,,n.,w,,_ Fire Main. Customer Mark MV-16.                                  Item No. 4 thru 18 do not apply.                               The 1" (a,ier do.oi,is.n et .e,etce te, . men e mponent -e. decisned>

thick liner plate marked 346-1 is to be considered as an attachment. Hydrostatic test of this part shall be performed with the component hydrostatic test perfomed by others forms to the rules of construction of the ASME Code Section !!!.We certify thatthe stacements made (The applicable Design Specification sad Scress Report are not the responsibility of the part Manufsecurer. An appurrenance Manuf acturer is responsible for furnishing a separate Design Specification and Stress Report if the appurtenance is not in in the component Design Specification and Stress Report.) Due

                                           /'   1 19'71 signed Chicaoo Bridoe & Iron
                                                          '                                                             y   Cg N d d dr-t/d M ,e manut aur.,>

g)

              . Certificate of Authorization Empires             6/I6/78 '                                                                     N-1090 Certificate of Authorization No.

CEREFICATION OF DESIGN FOR APPURTENANCE (when applicable) Design information on file at N/A Scress analysis report on file at N/A ' Design specifications certified by N/A

p,of. Eng. Stat e Reg.No.

Scress analysis report certified by. M/a Prof. Eng. St at e Reg.No. CERTIFICATE OF SHOP INSPECTION t, the undersigned, holding a valid comanission issued by the Nacional Board of Doller and Pressure Vessel laspectors and/or the Scace or Province of Tonnocepp and employed bhEMartfned (itpam Rnil pe i 1. T rn i of Hartfnrd. Conn have inspected th part of a purssure vessel described in this f Manufacturer's Partial Data Report on

3-7 19 . and state that to che best of my knowled,te and belief, the Manufacturer has constructed this part in accordance with the ASME Code Section 111.

ing the part described in this Manufacturer's PartialFurthermore, Data Report.By signing this certificare, neither the shall be liable in an neither the Inspector nor his employer with this inspection. y menner for any personal injury or property damagt or a loss of any kind arising from or connected

Date - 19'

                                                                                                            - -~~'

pepegg, - Commission s ! AJ - Nationet Board, State. Prow 6nce and No.

Supplemental sheete lat form of tinta, sketehes ee drawinga may be used preoided (1) else is 4W' a 1I" (2) interrnerien i date report le itseluded en eseh eheet. and (3) each sheet is numbered and number of sheese le recorded in 8 tent 3 " n items 12 en this

        .                                                                                                                                . Re marke ".

f. AC

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                                    " SIS REPORT                                                                                                                   A'
                               '  - TIIE HARTFORD STEAM BOILER INSPECTION anet :NSt,*RANCE COMPANY H AHnOND. CONNECTICL"r unt02
            - 10:                                                                                                           . ~ ~                                                 a 18-005                                               {

DATE

 .,                           Mr. Gordon Purdy Q. A. Manacer                                                                                                                                      SHEET                 OF               ;

IOM: 1-10-83 1 1 ! H.O./ BRANCH OFFICE Joe C. Hair ANI

                 .'RGAN tZATION                                           ,_

Houston Brown & Ibot. Inc.

              ! OCATION                                  STREET                                          CITY                              COUNTY                               STATE                           TIP CODE CPSES Glen Fbse                        Semrvell                                    Te m

ERSON CONTACTED (CIVE NAME AND OFFICIAL TITi.E) 76043 Mr. Drem Iahoti CONI RACT/P.O. NO.

lEASON FOR VISIT Proctuaent Surveilanca Sumrviecr

           ~iOP!ES SENT TO:

Mill t% mv'leM* mnt*act

          ..C H.O. Eng Claim, 515                           Ochier in        ..c      ,

8 Regional Manager, 515 30eher (Specify): Inso. file. On_this date..I.was presented NCR M4609.Rl. This.NCR certains to grindinct done. _.. on a CB & I weld connecting.the piping to the containment liner. In this case the .. penetration piping is also the. process piping... Lyon investigating this ratter, there _ is no . code data report covering..the welds. connecting the. pitie to the liner. A letter. -

                        ._from CB .& .I states .that the penetration piping.does not neet the recuirerents of the .. .
                     . 1974. Code.because.cf differences.of NCE. requirements. ..The data report covering the .. .

, (c. . w. fabrication.in the.C3.& I. shoo is to the 197LCode Su:me.r 73 addenda. Attached is.a....- copy of CB.& I's letter.. .

                                                                                                                                                                                                                                   ~
                                 . Until there.is a resolution to this SIS Feport, two things cannot take place:

(1) . __ Closing of NCR.M4609 Rl. (2)

                                                    . Signing any data report where a penetration is the proce'ss piping
                                                    .for_any system.                             .
                                                         . _.            _ . . ~ .          . . . . .                .         . .
                                                                                                                                                                   -.s               .- -                    . . . _ . .
                                                                                                                                                          ~
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                                                           -                                                                                                                                                COVER                        {

l t.c.~v10 75 (565)p. t .

l. .. A iT amtav y ]O, } QM

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Gibbs S Eill, Inc.

        "m  W                                                                                             Specification 2323-55-14 Revision 3 January, 10, 1979 Page 11 shall het adequacy of the ite=s. relieve the Centractor of. respen*"ility fe: the 6.0                  MATEIAI.S FCR I.-MS 6.1                  MATSIAI.S TCR LL4r p-B seMeca-w                rr--ce
                                                                                                                             . A .ymla a;sN eettti     i dhseiEC?'CEft ~6'edEE Schsecticn NE cc=flict,'" C ~

~~c Whe wmECs~~
~~-' - re Subsecticu -- NC and Rev..?~~
~~cum 38Ch Nc, swn qf~~
b. Penetratiens MV-1 a=d M7-2 as shewn en 'the e=gistering drawi=gs shall =eet 7-nctch i= pact test in ace == dance the acceptance criteria, fc the charpy !
i g.. W Subsection NE and parag,raph 6.2 cf this with ASME Secticn III specificatic=. M1 4A'lP~4 cther crecess ci=ine eenetratiens shall =eet the acceptance V criteria in acco'da=ce hth ASMI Section III Schsection NC, ' and paragraph 6.2 of this specificaticn. )
-.Ncc:=a;.'-isri".'9'~I;.;.JP~:5?bWr.- mWMF -- ~ <L f * . .. '~~* /WM in '//W&/
c.p. -.:.v. ::NW.v.: 4 :.:c-wr#S.i!&4T.9 , d:74sEEGh' a .4 J M ; 'A. g _a f,.f}4 7/ 4" p k,,. g. n. =, -
~~.. . . u ;.:. . . .:. :: . -- -- .- - - -- - ., i. . . - .. . .-~~
i..,'=w$.~sSIS RECORD ' tpip.t@- FOE' j_4. w MONITORING Q.A.~ PROGRAMS.[/ g!
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A PA ,w. Omte a PROSEGPQ i--.-- C MANAGER . "r~+ma= am *.
. .- l BROWN & RC07~*INC 25 N **'. '-- . ~ ' AM-38->S ~~ '""'^^^
YP$5W$ HWY 201NOR$bEGtENROS$"YrYAS$DN 22k TH, E UNDERSICHED NAVENCNITORED .$_? ' '
'500$RV ASy5 caa5 ;B.. ....m.. . . . .m - - . ~.'l$. . . .'..
~~o cUA0TX.ASSURANCEMANUA.35^5 O GUAUTY ASSURANCE~~
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~~PRCC~~
~~.~. -- .--- ~ O NDE.e....... . PROCEDURES MANUAlu-..~~
~~O QUALITY CONTROL PROCEDUREE' MANUAl . - . l SECTIONA 'WC.)' ' ' ENTITLED~~
. THE. P.E3ULTS ARE : . - ~~'_ $'.*m.- tM 'iM75 0 CPb6 [b .. .
X
~ . . ~; . . O 'SATISFAGTORY~NO. CORRECTIVE ACTION REQUIRED ' - "~~ 5 ~ - ' ' O. ACCE?TAELE---EXCE?T AS ' USTED EELOW -
~~CORRECTIVE skCTION REGUIRED SY - ' ' f UNSATISFACTORY-IMMEDIATE' CORRECTIVE~~
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~~/~I a- . 'YY$ b.. Ul &f~~
(($ { f f } h $ U *%' b C W l ,. , fWb mon /I { f % ps mnazerzb % -I-her a.o.h& Shtm4 \ I mAU67# b 7 od fhs' GoP/T4k, . bd n . N: u -
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-~03M 9e Affu,c-sugacts " gcGw42Eh s... eTre. Ths fcd25'rgs r/od /hn ewbhe:s- to ('*~&r?!T* f'sft14 :
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' nAdufncruAmeb 7e Sowws7e '7S s~bmc^/ uS 5 ' .-lhe Gcvrponcer CPinas s;vs~) is SwwE2e 7" sAmri,=u /hc sum a W i& mw m a ,a.e u-n t e above'w.a:1c: s 12n teen eme:ed p. lease r. : *a-*-'r' carr be x::rd.t= =1 a;i;ai.7. - 1-7 ::e in e_cir:g so :tz: 3.e ateve i Signad 8y . / -
I' - 1 autsee red Nuclear Ir*we e t oe c;57C2ER/WanUFACT'JER t:5E Cr.t.Y (. %UTICN(the nMrse side, if son space is nquind} } x..e .s. g k oste g i
, ,+t. - CASE EXHIBIT N0e 1,029
[@pg/ THE SISHARTFORD RECORD STEAM FOR COII.ER INSPECTION MONITORING and INSURANCE Q.A./Q10, COMPANY PROGRAMS HARTFORD, CONNECTICt.~r 06:02
# 334 i roi1... ena r,ne, cari ,'r satit or Me rhen pnwiv tt A . venmr .Tamnvv 11, 14A1 - ' 1 ,d customers couramv maat insp. ananen inse. accica on tonoca couarny tascionet use outri y 'h Brown & lbot, Inc. Ibuston Houston d,~ Follow.Up Cl85'd -
Reavired "g - WsPection LoCAr10N [jeld Repair / CPSES Glen Ibse, Texas 76043 Shop hAssembly Alteration laservice
~~1. the undersigned. .. ave monitored your QA/QC manual on: and find the following sections:~~
~~eaave numoers one russess e~~
,- kUnsatisfactory:licentory Getc,,a manual sectoon [No. end reve} C!: identity the speestoe nonconformance as soolossorep Non conpliance with ARE. Code ta-ll40.(c) " Effective dates of Code Editions" --- -
~~a EE lbte: . . This rer: ort. recrens 939.4 51-(Attachnent J 1) and closes -.. ea~~
-E 2 .- 932 # 18-005 (Attachrent # 3) . --- - - - ---- -- - - - - - - - - - - - - - - - - - - -
See Attachmnts. COVER CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below. and give k. .'date for completion of corrective action, so that items may be remonitored by: Pohman.r 10. loa 1 (Cates Pl;ase keep the Original of this form for your records and return a co3y to inspector named below. X. eg. grNepreIs'ntative '" YF7l' 13, 1983 a Ris0Lurlom of rHost irtus DiscRI8to A80Vt As SONG UNsATTsFacicRY (coatsnee on Meyerse s,de #thecessary) DCA #16,054 to MS _100 and SS-1,4_ has, been issued adopting NCA--ll40 of,1980 Edition Sut:n::er 81 Addenda. _ This provides _the Owner de::ignating any_. parts ,of the_ Component _ _ .
= applicable Code Edition and Addenda. == _. _. --
h k._ QA Manual will be revised to include this_ provision of the Code. u. p , p cover cais ccancer:veyou au at cene.ttro cart si to sotore.tomer,peoe
/ l i t, eif OS Ln !!/ .i L d I, the undersigned, have remonitored the above unsatisfactory conditions on: J /jp/fd and found them: I sfactory Cunsatisfactory (Explaits cetow) o . A.(.. .. . . . - Ok. - -U .. YN**CA _
h. . . = /L Mr .. r?'-ae 4m .. . .
~~/ '" $15 Foreign 8'3.1*'~~
L Reg. Mgr Representative sp. oart soto File 2 -[/ g-"/c)'3 soto rusa insoectors h (( g ,<, f H9 aty. ting (srst # /
/
~~l L - l~~
~~.NNk , SIS REPORP # 334 Page 2 of 2 l~~
I h Findings:' HSB 939 # 51-2 was closed 12-16-78 based on initiation of Brown & lbot NCR M-ll44 (At*ehwant #2) . Homver, this NCR was voided on 1-21-80 by the Brown & lbot Q. A. Manager without ANI notofication. Discussion: Brown & lbot's justification for voiding NCR M-ll44 Fev.1
~~;is based on fa11einus suppositions.~~
~~(1) (a) Paragraoh 2 of page 3 (NCR M-ll44) states in part that:~~
~~"NE-1131 describes the jurisdiction. . . . . . . . . . . . . . .~~
(b) Paragraph 3 of ceae 3 states that "It's a logical inference from NA-1262 and NE-ll31, that a oenetration assenbly with its attached piping is part of-the containnent system (the cxxconent) . Contrary to the above, subsection NE is not acolicable (Containment liner is non AS"E Code) and therefore the
'" Containment System" is not the "Conponent" of which the penetration assenbly is a part. This part will be listed on the pipina N-5 Data Beoort. and therefore must be certified to the same Cbde Edition and Addenda date that the installation is certified to.
~~(2) Paragraph 8 of page 3 states ." Piping penetration, as~~
~~-. , - fabricated, are in full concliance with the subcon-~~
~~" ' tract, specification and ASME (bde requirements. Hence, no NCR condition exists and this NCR is voided. Cbntrary to.the above, the subject carts are not in~~
~~" full" cxmpliance with the ASME Cbde. They still do -~~
~~not meet the _requirenents of NA-ll40 (c) . i t e l O 1~~
~~. j~~
~~'hk .~~
~~g _. SIS RECORD FOR MONITORING Q A./Q Ce PROGRAMS THE HARTFORD STEAM BOILER INSPECTION cnd INS 1'RANCE COMPANY CASE EXHIBIT N0. 1,030 HARTFOND. CONNECTICt.7 ot10: g 10 tNeme ene torrey~~
~~# 339 ___~~
CAtt SHtti Cf Mr. Cordon Purdv v, ,.4 1 1on, ? CU$stute5 COMPANY 4AMt 1
.O ;"- 6NSP. 8AAhoe lhSP REG;CN 02 ICillGN COL,h[gy t4sGl0NAL Usf oMLF) gy Brown & Root. Inc. Enusenn Mnne:enn F0lIOuFUp ] closed "g INSPECTO LOCAlp gjglg Recuired ggggig/
~~CPSES Glen Rose. Ten s 7A041 Shop Assembly 04 te,,tio. Diaiervic,~~
~~l. th] undersigned, have monitorect your QA/QC manual on: 9 /?R /A1 and find the following sections; Toeie ,~~
toove Nume*re end T**el traentarcasoc menues sessen [no. ena rme) on scentury une noeca.e nonconoormme en soonceases . Unsatisfactory: Section VII Document Control , w w w -.--- _
~~/m .-n2 - !g d[~~
~~h { & )!~~
~~. l MW- 952/1w T~~
CCW h date for completion of corrective action, so that items may be remonitored by: 1/19/91 sceses Please keep the Original of this form for your reco'rds and return a copy to inspector named below. CtITA.5UT:Cg Qatt SiCht3 $1 gat 3 (M 8 inspectors Ener. MarN[crEeIfative YF"fe March 1, 1983
~~. _ . ,_ imm, _ .t.A _ e. _ ,m.n,.n_.n.~~
h
~~.e...e~~
[e
~~.e.een,y, SI-1-SB-022 - new copy ordered fran DCC and ~ d one-destrcycd.~~
FSI-1-2102-16-1-103 advise as to correct DWG - No record of this U$3 nurber in QA files or in DCC. Please nurber. 05 - . EE Further, it should be noted that if a 10 Day O C is issued, the centrol drawing 3}= o- is not stanped but when the controlled OC is issued it is referenced on the D43. DATE CCARICTvt ACTICM untt St Cou'Lifta DAlt 51CatD A Cou.9 SOE0tCuesomere Aearesease - . March 29, 1983 March 28, 1983 ) '
/
1, th] undersigned, have remonitored the above unsatisfactory conditions on: ym ,. A 7n tor 1 and found them: C satisf actory 3 Unsatisfactory (hplain cetow) a ( S:o page 2 of 2
**'amm $gg pg,,,g, g ,,, cart s:cato sichte (MS ..
~~Caes. u cr/ Representative d r,ii. March 30. 1983 Innescroft g~~
~~.,,n,., _.~~
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~~6 : . SIS REPORT # 339~~
~~, Pega 2 of 2~~
!." _ While monitorid'Section IV, I discovered two (2) isometric drawings with discrepancies: SI-1-SB-022 Changes to controlled drawings, written in by. hand in ink. FSI-1.2102-16-1-1Q3 Drawing is illegible. Also. reference 932 97 001A written 2/18/83 (CS-1-AB-213 & CS-1-RB-025) . Also 939 #313. This has become a continuing problem with the DRG group, Control #83 drawings. This does not include the Iso's taken back for illegiblility when presented with documentation or missing CMC's in packages. . If a drawing _ is illegible, or a CMC is missing, a final review for techinal acceptability is practically impossible. Your attention into this matter will be appreciated and if I can be of any further assistance, please notify. Response reply: This response is being returned unsatisfactory because:
~~' (1) On the SI-1-S3-022 drawing, no corrective action is addressed concerning this generic problem. ,~~
(2) W No corrective action is addressed for the correction of illegible drawing in the files, nor the ones issued from DCC. - (3) There is no mention of 10 day CMC's in this 939. The problem mentioned here concerns no_ CMC with the docu-mentation when presented for final review. A final review cannot be performed if you do not have the correct design document in hand. A response by April 15, 1983 will be appreciated.
T M gs'sy MM*';
& SIS RECORD FOR MONITORING Q.AdQ C. PROGRAMS Qi kTE HARTFORD STEAM COILER INSPECTION and INSURANCE COMPANY CASE EXHIBIT N0. 1'031 I s' HAR fFOND CONNI:CTICt.T otilir' +341 .
~~fo rw-. ..a r er,, '~~
~~; care satti os f%A n n N r,8 u C4*a nA V , n n e. a r gg ' tusroutes ccupan naut " ' '~~
~~=se saamcw M arr. h R 10A1 i.=ss atc ose ce ,dato coinrr., t ia~~
?
~~sQu; - E FQWn_.6.lo o E - Ine HQU.St.Dn _.!1oUSCQn M '@8d "g~~~
'"5PICf8 LcC*
~~Field Repair / CPSES nlen Rose. Texas 76043 @ Assernbly Aueration Insenrice~~
~~. 1. the undersigned, have monito' red your QA/QC manual m. on:.. 3/8/83,c.~~
~~and find the fo. lowing sections:~~
~~. ca... us,mo.as we r.on.s, t Satisfactory:~~
m
~~.lJ unsatisfactory:tscentary CL oc ,o.nus secroon (No. .ne rues.) on oa.nrary on. so. corse concento,muc. .s .conoe.oi.e Section 12 Test Control ~~~
~~Hydrostatic test # 's ICS-107-1. ICS-108-1, and XWP-102 indicate NX-6124 a~~
~~$E E ?,.~~
~~is not being complied with.~~
-E 2 Hydrostatic test #'s ICS-108-1 and ICS-107-1 were held at a test pressure of 56 PSIG. The design pressure is 220 PSIG. The basis for this reduction of pressure was " limiting components". The " limiting components", IPI-188 and IPI-187 are pressure indicating devices, which do not meet the criteria of components COVER
{ CUSTOMER: Picase describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section d te for completion of corrective action, so that items may be remonitored by: Anrfi 8- ' OM ramo Please keep the Original of this form for your records and return a copy to inspector named below.
"'5 ""8*
~~sis roreign S 5* =8 '"88 '"*'N 2 Reg. Mgr Representative ' insa. 3 File~~
~~' j / j Starch 8, 1983 h us.c. o, r m at.s m.c .a ... .s .- u,,s.ns,. cree, ,c , . ....,.. . ., ....,,, .idh' / &"[7 y~~
A C1C #72980 has been issued against rhe FSI drawing changing the Code boundrv. SIS 12-004 issued on 3-2-83 has resolved the hydrotest #ICS-107-1 and ICS-108-1. Hydrotest #L'P-102 was performed to test the entire system, and the test oressure ygOg' was linited to ll2PSIg. due to allowable maximum test pressure of sever ccmponents in the system. Therefore it was not necessary to isolate cart of
~~"" the system for testing at higher pressure. This subject has been discuss ,~~
~~with Mr. Coates and Mr. Tillman by P.C. Lahati on Mav 16, 1983.~~
/wO It was resolved that the test XND #10'2 is cceotable. 7 dyg care contcrivt ac::ca nu sr cowttrio cart saco sow NA Ylloli 3 ) .
aW
~~.,,,......,.,,..,M l p .l. the undersigned, have remonitored the above unsatisfactory conditions on:~~
f J e hf 3 . and found them; 3 Satisfactory somo ~ i a wUnsatisfactory (Explain below) L/w>s &it.u m >< ib/:. e A >y a .) p . ..'. v..., u v. x 1 d i M S u ayw p c ~ a M i y ...t z 4 , .~
~~. ta. . ..,~~
~~f5** sis roreign ,.gns,. 6'it an =a 'a 2 Reg. Mgr Representative afire i 2 v.,s 3 D -/;f* 'a'a+<'a's. M f . .vA , ns et, n,,, n t -~~
~~,e u-s s, y r,w. , - .. -SIS REPORT # 341 -~~
Page 2 of 2 h per NA-1210. Hydrostatic test # XWP-102 was held at a test pressure of 112 - PSIG. The design pressure is 150 PSIG. The basis for this reduction of pressure is also " limiting component". Piping in all four Iso. 's involved are welded to class 5 piping on both ends. The " limiting component" includes several vessels, at least one of which was fab-ricated to the rules of ASME Section VIII. It should be noted that
~~the attached piping on two of the Iso's can be isolated via valves and flanges as installed.~~
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. . . . .- .- l W SIS RECOR0 FOR MONITORING QsA./QA PROGRAMS ~ CASE EXHIBIT N0. 1,032 T!!E IIARTFORD STEAM DOILER INSPECTION and INSURANCE CO.NtPANY 11AM'rl-OHn Co.%I;CTH:t r osI02 - 5 346 to(Name ene rene, Cart setti Of ., 3 Gordon Purdy, Site O. A. Manager Aoril 21. 1083 l.
5y o Gustoutsrs couPANY nAmt usse gaAncn inst REGcm on icAt;cN COUNTRY 1 (AKGdONA& US$ CMLFJ ju y Brrwn & Root. Inc. Houston Houston {RecuiredF ollow-Up--.ctosedp g insrtctcm tocAre"
~~- Field ~ Regir/~~
~~CPSES Clen Rose. Texas 09 Assenibly Alteration ginseMee~~
~~l. th3 undersigned, have monitored your QA/QC manual on: 4/N /M and find the following sections:~~
~~s osie ,~~
~~, sa..e memooreena r, ness ,~~
~~Satisfactory:~~
~
~~b Unsatis!actory:tidennely CAICC manoes sect *on (No. ene rotre} On teennly tne specotee nonsensormenee as soonesates Section 12 Test Control o~~
~~$g See Attached.~~
~~R 8m U B i.~~
'Covr CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, and give dits for completion of corrective ac' ion, so that items may be remonitored by: hv 5- I081 ~ tcorer Plsase keep the Original of this form for your records and return a copy to inspector named below.
~~Ol#:Sul.c4 $15 foreign Msp. Cart s.cato soto gnsa iraspector* ~~~
~~.X. Reg. Ugr Representative k File atscLufem 0F rHcst i:~~
4/21/83 ) M/ M/[ Eus CiscRIBE3 A804 As 8ONG LmsAfisfAcicaY tContenwe on Ae,erse 3,ce nt A,eeessarys/ ~ 3 L r see Attac ed omr 30.10. - 6
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_ // U0is i-Cart CORettmt Ac!icN wtLL 61 CcurLEft3 Cart sota so(O rcestomer :Aa +a # I May 2, 1983 May 3, 1983 f ' i-
~~1. th] undersigned have remonitored the above unsatisfactory conditions on:~~
[.//.f'3 and found them: 3 Satisfactory UUnsatisfactory (Exotain Detow) b ~_* G1-QAP D.2.wf m.g & ,3;.f yQCwr.n uy MP 4 - Qa)14 mJ4dig ostaisurca ses yo,,,,, ,,,' cart soto soto , sa nn., e,.,, kRet. Mgr Representative ile [* //-O k - /j
~~. _ , ~-~~
~~P,, . 7 , w~~
~~..i/ I.L *N .~~
~~gj. SIS REPORT #-346 7~~
~~' Pcge 2 of 4 e~~
~~References:~~
~~ASME Section' III NA 4420. G Brown & Root Q. A. Manual 12.3 Brown & Root Procedure CP-CPM-6.9I iDiscrepancy:~~
NA ,4420 requires ~" instructions, procedures, or drawings of a type appropriate to the circumstances". Brown & Root Q. A. Manual requires that provisions 'are included which assure o monitoring.is performed by QE/QC and that a means for evalua- .
ting and documenting the test results are provided. CP-CPM 6.9I provides for inspection by QC and witness by ANI, Pres-sure Test Data Package includes applicable drawings marked to show test boundaries, system flow diagrams. will generally be used, and that additional information is recommended but not required. CP-CPM-6.9I is inadequate for.che following: ' (1) System flow diagrams do not provide location, elevation, configuration, nor means for identifying Iso's. Brown
~~& Root Iso.'s are used for all other phases of install-ation, and are used by QC personnel for the actual' ins-Pection of hydrostatic tests (copy of ANI file #12-002 attached).~~
t' (2) Inconsistencies noted at time of test walkdown are marked by QC on Iso. 's. On at least.two tests, valves which were shown on the flow diagram and valve lineup sheets as open, were in fact closed. As Iso.'s were being used for walkdowns, this was noted on the Iso. 's enabling the test to be continued as opposed to the test being shut down for modification to be made to the flow diagram and valve lineup ' sheets. This enabled only a small portion of the system to be re-tested. (3) Flow diagrams do not provide Iso, numbers, spool numbers, nor weld numbers. All Brown & Root installation records including inprocess documents and N5 Data Reports ref-erence Iso, numbers, therefore, all final review record including those maintained by site ANI's provide for 9 tradkng by Iso. numbers. As flow diagrams do not pro-vide this information, an adequate means for ensuring that all joints and modifications are subsequently tested.is not readily available. Thank you, l hW ' Billy Walker O
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p,i . . QC9I - No. 10 DATE: April 27, 1983 SUBJECr: QI-QAP-12.2 Fev. 5 Paragraph 4.1 Documentation Of Pressure Test. This is to clarify ASMS Quality Control's responsibilities for d m w ntation of pressure 'a.sts. Upon satisfactory empletien of the pressure test the QC inspector shall sign the block stm ped " Site OA" on all BEP's use for ir g en of the test betr/ary. I The above ctarp will be en the face or back of all BRP's used for pressure test and shall not ccver any drawing requirerents. * ' This clarification shall be used until paragraph 4.1 of CI-QAP-12.2 is revised. t l [ l' ' I.Siever
~~%s --~~
5' QC Group S % 9tisor PS/hnt cc: G.R. Purdy J.T. Blixt G. W rris, Jr. D. Woodyard J. Bagan l e 9
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CASE EXHIBIT NO 1,033 SIS REPORT b, .fm. d 853#Mf Tile }IARTFORD STEA.41 BOILER INSPECTION and !' nAaT oho,co.s.sirrn:cr onio: JRANCECO.\tPAN)gq[ulp f4 -4
^
TS* 9-002A O , DATE SH EET OF
, cunr-4e vachanical T_ ev e l TTT 4/21/83 FR;M: 1 2 ~
~~H.OdBRANCH OFFICE u3pffn cn,"e q _ T,pqd AMT~~
~~ORGANIZATION Houston Rrnun A Rnne- inc.~~
LOCA rlON STREET CITY COUNTY STATE ZIP CODi.~ CP9r4 Clen Rnse Seme*vell Texas 76043 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P.O. h REASON FOR VISIT BS 042007 re t11 e4-p ennermer COPIES SENT TO: OH.O. Eng ooim,51s D ow.r in...<io, OR., ion.i uon...,, sis Q Oth., (s,.ci fy): ANI File.
~~SUBJECT:~~
Welded Attachments to Class 1 Piping ' RE: HSB 932 # 9-002 ^'
~~/7 fi HSB 932 # 9-002-1~~
~~_a / HS3 932 # 9-002-2 , 0 ff f A .f NCR # M4311 (/ Y 4, .~~
~~. Om /~~
m.. . NCR # M5735 Per your recuest this date. I am documentine mv request that app ro criate enr-pa*4va ar* inn ha P a tr on hv Rrnun % pnn? Se a recult nf nhove referenced d n ett-on e c _ Ahnup *p f s.* on c o 0178e Amen-onrad
,7 enne ,n , pp,p ,, n n , e n ,., g n y , 4 ,, , ,,,, p p 74,3 had koon ualdad en ARvF rimee 1 ntning- A etthennuent rey.iew_,.hy Brcan & Pnot , e,,1eod f ., 4eensnea nf MF7 V6111 uh4eh AnCumented_SC e._faurteen._ @ instant,es n# fneen11sednn nf nnn..cnna neming mee.cfal in MaaCtor Unit _l-nn 1/?a/R1 T cignna nas F4""n knld - points _on_ lugs for__SL-2 1.0L-AQ1-C4_1S.. .
~~y .,nroa rho kone numher_of eka ing maravimi f r413P.3 Land _.pu11ed_.the_A12._packa;;e 4 .- rka van 1 7.utou ne rk. Fun~~
~~,,u,,1 ad char rhe_'-ara dal ha.d no t._heen "olumet.rically_ examined-.pe-n,uirements_of_N3_.2500_(.UI._ examination IAW SA-571b . _~~
p, _ T i-nediately identified-thie ea ehe._QC Croup._Supervisoc.._ On_3/30/83._Inspecto r Bill Par-r w.as.-notif.ied_Sor- -a D'" kald point._on the same._ lugs. . Mo action _had ?lGNED OOVER I s - y ~. . . . .. _.- . .- .
'e . * < _w wp 7- ' S ': SIS REPORT- -_;U U 4 THE HARTFORD S17.AM BOILER INSPECTI::N and !."URANCE COMPANY -. HANTFORD.CONNE("TMAT mle 70; 9-002A OATE SHEET !
~~G. Morris, Mechanical Level'III :OF~~
~~~ ~'- FROM: 4/21/83 2 1 2~~
Marvin Coats, Lead ANI H.O./8 RANCH OFFICE ORGANIZATION '- LOCATION STREET. CITY COUNTY STATE ZIP COD? PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P.O. Nd REASON FOR VISIT COPIES SENT TO: OH.O. En. C im, sis O oa.tla.. , OR :. u ,. sis Dos, (s,..ity): been taken by Breun & Rnnt to aton further nrocessing af ter thWon-coDfor"tAILC8 une diecussed. AP ehfm efma ehe nnn-enn fnmance uns aga in identified _and resultad in gan a rm ei nn nf McR uS715. A=m recule nf the ahnve T am ranuanting ynur assistance en accomplish the fn11mufne. __.. (IT A vavi a .1 s n f tin t e ? <n=en112e<nn. o hn,,1 d he inteinead en dicelnse uheehar ekova are nekar <neennea, nf e<,414,7 nnn_cnnenr .nc . (?) Domancermea *n Pha Tand ANT Pha ennerni fpmeur,q n f p rev., & pnne , s nrngram ehme mennra cha fecuanea of ennforming C1ngs 1 attachment mneerini en the ffald. TF T may he nf n==f=Panco_ n1a.ca ennence ma me ynny enny,nteng,. Thank vnu.
~~-m 4 Marvin Coats " ' '~~
Reseense requested by May 5. 1983 _- cc Cordon Purdy i l OOven [dGNED *
~~'t WEV.80 se t$ags , _ _ _ _ . _ . _ . - ~ . - _ -~~
~~. ty BrUwn& Root.inc.~~
~~TO: Marvin Coats, Lead ANI DATE: May 17, 1983 FROM: Ted Blixt IM# 25,570~~
~~SUBJECT:~~
SIS Report (932) No. 9-002A As requested, Brown & Root has initiated a total " review of Unit 2 installations..." for " instances of similar non-conformance," but since this review will require a manual search plus Q.C. field verification, we must request a 30 day extension to your requested
~~response date.~~
Ted Blixt, / ..~, QE Group Supervisor - TB/km cc: Gordon Purdy Ted Blixt SIS File QA File TO: Ted Blixt, QE Group Supervisor May 24, 1983 FROM: Marvin Coats Concur with requested extension.
<0 Ma'rvi6 Coats, j Lead ANI l -- l l
~~l /~~
~~, o~ !~~
~~J ry { i i I~~
~~.: J' .. . . o: - % .~~
~~hTFbot.k1C. INTEROFFICE MEMO IM# 25,676 -DATE: June 7, 1983 Toi. Marvin Coats 1 FROM: J.T. Blixt~~
~~SUBJECT:~~
~~'CPSES, 35-1195 SIS /932 No. 9-002A.~~
~~r A review of Unit 2, by B&R QE's has disclosed that there are no other~~
~~' instances similiar to NCR 5735. The present control features of Brown.& Root's CPSES program will assure issuance of conforming Class I attachment meterial to the field.~~
~~J.T. Blixt QE Group Supervisor JTB/bm cc: G.R. Purdy G.L. Morris, Jr. QA File~~
~~.~,+~~
~~.,.g g SIS RECORD FOR MONITORING Q.A./Q C, PROGRAMS THE HARTFORD STEAM BOILER INSPECTION end INSURANCE COMPANY~~
- CASE EXHIBIT N0.1,034 HARTFORD. CONNECTICt.T oblo: '1347 ,, sognen na r, ties cAss suits or ') Mr. Gordon Purdv. O. A. Manager Aoril 21. 1983 l 2 gg cusioutrs Courant =Amt inst. snAo imse nece ce scafo rounrnv t,aagagtuseontn 1
~~5j Brown & Root. Inc. Rouston Houston Utequired CClosed "g ~ INsetCm LoCAM~~
~~, [jg[g ggggjg/~~
CPSES Clen Rose. Ten a $ hop hAssembly Alteration laservice fl, the undersigned, have monitored your QA/QC manual on: la /?1/R1 and find the following sections:
~~, c e re ,~~
_ ta..e numee,e no rass m $atisf actory: osae,,urr anac menuer sauen tus un r.ue3 on sonurr une son r,e noneenremen u eso.:;su iX.! Unsatisfactory: Section II Control of Inspections. Paragraph 11.2 (c) Definition of Inspection sequence including types of a
!E characteristics to be measured, frequency of inspection (including in-process 85 $E surveillance or monitoring activities), establishment of Q. C. holdpoints, methods of inspection, and acceptance criteria.
See Attached. OVER ' CUSTOMER: Please describa the resolution of these items in the " CUSTOMER'S RESOLUTION" section below. and give date for completion of corrective action, so that items may be remonitored by: Mw 5. 1983 co m o Please keep the Original of this form for your records and return a copy to inspector named below. m 0esyiaum $gg p,,, g, cAtt sato
~~x. Reg. Mgr Representative S,,ile F~~
4/21/83 soto tasa ensentes hJoeC. Hair /AJ/] h. o A aucturica os inest alms cesCaisto Aaovt as sting unsArisincroav scene,nue on me.orse sa ,im cesserys " NCR M6039 was issued to resolve the lack of 100% visual examination. t should be noted that back gouging was performed in ccupliance with the WPS. CE jE ,
~~E a .~~
, , , , 00VER CAft CCAR4Cfivt ACTION jan 8t COMPLtito oAft siCatoff / s&to(Cussemer s neeres t ..
~~4/2&l45 i '~~
~~'f/21/s? > C~~ -~~
I ' - r I, the undersigned, have te,rtionitored the above unsatisfactory conditions on: f'/J//'y and found them: tisfactory CUnsatisfactory(Explaset calow) o h THe t $1(l'c/tr is &LofGr Okna <.a4 8cLs'Pn9ft.et 'Pa fbJa .-4 o.'*c AC> /C m f" NV PND JseAJ wss4M }2/sAJ7'.s%r%a~S. l DisIAisufe OAII IMEO IMEO
$l lAsp. 8 8# 8 Eneg. ugr/ne$ foreigm Orii.
oresent.tiv. . /-/gn b AIN38 ' ,p 919 Rfy Ithg esm
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~~SIS REPORT # 347~~
~~- Paga 2 of 2~~
~~[?T4 On-this date this inspector was called to the Hanger Fab Shop to~~
' witness a. final PT of a full penetration weld on support MSB-2634 DCA Unit 4. Upon arrival it was noticed _that the weld in question had been welded over on top and bottom by fillet welds. The full penetration welds-have unique weld numbers assigned on.seperate MWDC. -The fillet welds 'also have unique numbers assigned, and are on seperate MWDC's. . Mr. Bill Sims has told me that Civil Engineer, Tom Lutz is going to delete PT'because it is not required for a Class 3 plate and shell support. The~ concern of this inspector is that there are parts of welds on 4 units which have not been subjected to NDE. 3 units are completed and I unit still remains in fab shop.
~~ThIe following concerns should be addressed in response of this monitoring activity.~~
-(1). The requirements of IUL 4111 have not been met for; " controlled conditions include the use of appropiate equipment, suitable environmental conditions for accomplishing.the activity, and assurance that prerequisites for the given activity have t ejgnL satisfied".
(2) NF-4423 Before applying weld metal on the second side to be (e ;;ls, welded, the root of double weld joints shall be prepared _ by suitable methods, such as chipping, grinding, or thermal gouging to sound metal. There is no objective evidence that this has been done. The configeration of the joint will limit what can be done. (3) NF-4440 All welds shall be examined in accordance with the requirements of NF 5000. (4) NF-5231 ' Class 3 Plate & Shell type support welds. (a) Wald joints over 1 " thick shall be PT'd or MT'd. (b) All other welds shall be visually, examined.
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~~,, SIS' REPORT - CASE EXHIBIT N0.1,035 A~~
~~Tile nAu HARTFORD STEAM ri osu.co.wirricer mio:Boll.ER INSPECTION and !>~~
~~tANCE COMPANY T. C-044 '~~
l DATE ['_ Cordon Purdy Q. A. Manager 5/26/83 l SHEET OF I FhvM: 1
# 2 H.O./ BRANCH OFFICE Marvin Coats. Lead ANI ORGAHLZATION Houston Brown & Root. Inc. .
LOCATION STREET CITY COUNTY STATE ZIP CODE CPSES Glen Pose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME ANO OFFICIAL TITLE) CONTRACT /P.O. NOs REASON F R VISIT BS 042007 Full time contract COPIES SENT TO: OH.O. Eng Claim, $15 O CNel In specio, @R.gional Man g.r. SIS G Ceh., (So.chh MT, file. E"blacta Conpongat_Supporre Da? Vaeeing 9 /24 /M R. Enkar_ c . Pu rd p(_ Con e n . R __Ilalke r . AP Php referenced =nering up diernesad seizeral ANI enneema nheur the ereune aarknde in pince en idenrify problema uith supports and Muhse.quent rework Lcpnir en veen19e Phnen n rnbl em e . Per venuper T
~~nm dneu,aneing those enneerns_and veur nennnend re,ndini neeinn na T unanverana ek,. .~~
(1) E rn en & Rnne O. A. hae reengni?nd generie de fi ciengige. in Mupport (nbrieneinn nad euhnenunne inapeceinn (e g. undernired f f ! 1 e t __ugid s) . t'nvreceive neeinn ham been 4,niesentedpocedurally_in CP/QAP 12.1 me- n. ubich direnene a finni "un1kdnun"
~~'/,, 7 y% nf each support,_by_QC_tc yerifv '~~
v _ configuratica ueid size, pipe to hanger clearance,_etc,. fb ' dpackaga raviau hy OER and ANT it. predicated _on_thiS_documentRd_re-Final._haDge r 6/' __ i , 9 n m /i inaneceicn. Th4a U R '
~~,7U R ~~~
final _ inspection _has resultad in thousands. qf JCA'.s whtCh causes dunlication_nf_walkdgynt and a_lo_ss of.perspes.give in MCR. processing In vi.ew ql_abqye, Brown & Ro.ot has adopte.d a_poljgy._ of Weldine Engineering personngl_igsp.ect.ing_supp_ orts .tq_ final dr_ayings prior to the final _Q_C inspectiondoted discrepancies are worked _ _ _ ..
~~%. en_protesjtsheets_rather .than.. identified on_NCR'.s base 4_ on .3 .rac_ionale~~
! ehat_the_suppor.t is.still..in_proceas_. .. .This_is_an e_f fott .t_o._ rej.use l lGNED OOVER
~~., -(~~
~~P;33 2 af 2 -" Ty L. 2T lI.' initiation of NCR's and better as .re that Q-C will perform final~~
~~'- inspections on acceptable fabrication. This policy is understandable but is not supported nor the content of Section 16 of the Q. A. Manual.-~~
~~(2) Repair Process Sheets generated to build up undersize welds are being transmitted to craf t with an information copy of the vendor~~
certified drawing. Even though the RPS virtually stands alone and

the drawing serves only to provide location & material information '
l
~~.Section 7 of the Q. A. M. specifically precludes use of an uncontrolled ' drawing for fabrication and installation activities.~~
~~(3) Full fillet on Class 1 support primary members should be identified in -~~
process and not left to be identified during. the final walkdown. ! Your proposed action of the above islas follows: I (1) Prepara a Q. A. M. revision for subaittal to the ANIS to provide for policy _ outlined in item 1 above.
~~,( 2) R.P.S.'s will be ' issued with controlled drawing attached. -(3) Q C I identification of full fillet welds will be proceduralized i~~
~~to assure implementation. , f Your assistance in resolving the above is appreciated, f i,e 2 e h O J i 9 l 1~~
~~=i -~~
~~a. SIS RECORO FOR MONITORING Q.A./Q C PROGRAMS . - CASE EXHIBIT NO. 1,036~~
. . . THE HARTFORD STEA.\1 COILER INSPECTION tad INST;RANCE CO51PANY HARTFOID, CONNECTICL*T 06102 #353
_g to ruame una r.ue, oArt sum or e G Cordon Purav n A. %2m v. ,,, e 9 icot 2 gg custoutrs couric mut r insr. saAar.s msr. is; ion WrenoWeauniny < gegugt usa,o_utr> 1 s{
~~"g l Brown & Root. Inc.~~
~~msticnom tocArea Houston Houston " Required LJClosed~~
~ Field Repair /
Shop CPSES Glen Rose. Texas 76043 Assembly bAlteration binservice I, the undersigned, have monitored your QA/QC manual on: 6/2/83 and find the following sections: roare, C5atisfactory: 8 1
~~.anry omac man . seanan (no. ana r riq cA roonrary une smar,c noncentermance as sooo.<se.e>~~
unsatisfactory: S_ection l_6 Nonconforming Items Reference paragraph .16.,4.6 . Reference procedure CP-QAP.16.l_ l=5 8 g: See attached sheet 2 of 2 . . . . . . . _ . _ _ ._ . ._ _. ._ _ .__
~~. _ - - . _ . . . . _ . - . . . ._. . . - . - . . ~ _ . .~~
~~COVER~~
"' ' CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUT10Nsection below,'and give date for completion of corrective action, so that items may be remonitored by: June 16. 1983 soares Please keep the Original.of this form for your records and return 3 copy to inspector named below. '*:s mto mtC mpa sammrer, *5aunc" / sis Foreign 3 File 1 Reg. ur r Representative insp.
~~June 2, 1983 ResolutiGN Or THCst IIEMs GescRIStD A30Ve As StlhG UNsAftsFACICa7 (Conhaue on Aeverse s.de cessary) h -~~
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jf dC 6 OM . ._ __ . we ar as o _ _ ..... . _ _ . . _ . . . . . . .. _ .. ._ i!! S us . _ . . . _ . . _ . . .. . - . . _ . _ _ . .. . . - . . _ . . .. OVER CAft CCnRtCilVE Acn0N mtt 3E COMrLETED' Cart slGNED slGhtotCuaromer's Aeoresenterrves
~~> //4 W c. r_ n 4~~
1, the undersigned, have remonitored the above unsatisfactoty conditions on: g - ]- g3 g toares and found them: I,E. Satisf actory Unsatisfactory (ExpIain cetow)
$i. Ou e. fa es.<w a s. h .-> w .) A . p. i Lpe u ts.,e 5 el A/hct y +4:s a!ad is 6 be. ch. sad, AcceLa @pM LI decs coho l th;s -~-
was deainiv. 05ta surios $gg por,,gn cArtsuo n _ g ,3'p, suo she sese crois Reg. Mgr Representative hfile 6 P3 b : ~. /;a . /_ dn f) us arv. una $33 y / /.-
~~--,..e.-~~
~~_ b. NS-"~~
~~^~ SIS Report # 353 ,~~
~~Page 2 of 2 l ] i. . Accordin's to the references given, the Q. E. group is responsible~~
~~'for the_following: ~(1) Reviewing NCR's for clarity, correctness, etc.~~
~~(2) Assigning NCR to " Action Addressee".~~
~
(3) Reviewing disposition for adequacy and conformance to specification and Code requirements. A. If everything is satisfactory at this time, the following reviews and approvals are to be obtained: (1) Engineering.
~~-(2) TUGC0 operations Q.A. (under specified circumstances).~~
(3) - Q. A. review to indicate compliance. (4) ANI review. Summary: At this time, the ANI's are receiving NCR's which have the Q.A. review signed and dated prior to Engineering signing and dating, r'esulting in final documentation being put in the Permanent Plant Records Vault
~~showing that Q. A. review was performed prior to the- Engineering review~~
~~~[' ( ' and indicating the possibility of them being signed prior to disposition. Since it is Q. A.'s responsibility to' assure compliance with the Q. A.~~
. program, the Code,'and specifications, it becomes inherent they assure Engineering and-TUGCO review prior to their review, it being a Q. A. Manual and specification requirement for Engineer approval of disposition of " Repair orL Use As Is". NCR numbers with this problem are numerous and on file.
t
~~.# l 6 .%~~
i \.- -
o .o= e i - CASE EXHIBIT N0.1,037 SIS RECORD FOR MONITORING Q_AdQ C, PROGRAMS kh THE HARTFORD STEA31 BOILER INSPECTION and INStJRANCE COMPANY HANTFORD. CONNECTICt.*T 06102 l s.
# 355 s oisi ,e ana r,ose, , , cast setti cr v-d Gordon Purdy. O. A. Manager June 7. 1983 1 l 2 5 's oM cusroutts company haut insP. 8aAncu inse atGion on pontica counrav (Asodomat use omtrj *@j Brown & Root. Inc. Touston Houston I- Follow-Up -pClosed Reauired "g '"5PECTSa t0 CATS" Field Repair / r- i q Shop p:cAssembly CPSES Glen Rose. Texas 76043 " Alteration LJinservice
~~1. the undersigned, have monitored your QA/QC manual on: 6/7/83 and find the following sections:~~
eo.ve numoere ena r,nes Satisfactory: traentury onioC menuer section [No. ene route 3 on scentury one specuroc nonconrormance es sooncacies .~ . _m m1 Unsatisfactory: Section 7 .,- - d ,a Brown & Root Q. A. Manual. i A w
=y See Attached. [ r , ., l VAk l L8... ,N __
r-- LJOVER { - CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, and give June 21, 1983 date for completion of corrective action, so that items may be remonitored by: scorer Please keep the Original of this form for your records and return a copy to inspector named below. ots!#18ufioN g;g p CAft SGNED $GNtB (Msa inspector; 5 Reg. Mgr Repre entative b'F fe' June 7, 1983 h A REs0LUTICM Cf TNGst ITEMS CEsCRISED A80VE As StjhG UNsAll$f ACICaY (Conf 8nue on Aeterse Seae er fWeCess(EFJ y
=
5s 25 EC u as COVER Cait CORRECTWE AcilCM witt at COMPttit3 Daft SCht0 $2GhtalC.,stomer's Aspresent bb* O Men h ,-
~~\ \~~
1, the undersig.ted, have rem 'tored the above unsatisfactory conditions on: . {,/f ofy_y and found them: Satisfactory CUnsatisfactory (Explain below) 2 -
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*5.'.areurm" SIS Foreign m DCNt0 (Msa tas ector; Reg. Mgr Representative LFile insp. l*'t SGNt0
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~
~~SIS Report # 355 Page 2 of 2~~
~~;(^~~
Finding: During final review of hanger packages'this date, it was noted , that the majority of packages included VCD/FRD marked in the following fashion: In lieu of the red DCC stamp (indicating controlled copies) these drawings were obviously reproduced from the original controlled copies with the control. number
~~-(98) overmarked with red pen. Without benefit of stamping with a controlled stamp there is no objective evidence that -~~
the subject drawings are in fact " controlled". Additionally, several drawings that were included for information were not marked "information only" as required. f; :. - _t g u. l r
,-}, .;,- .~.: . _ ....- DN ~ )
~~DATE: JUNE 8, 1983 TO: MARVIN COATES~~
~~SUBJECT:~~
~~SIS # 355 Resoultion of the problem identified on SIS # 355~~
~~~w ill be handled in'the following manner.~~
~~A. All future preliminary review documents will have a red DCC stamp with the control~~
~~# entered.~~
~~B. At'the time of final review, a drawing that does not have a red control # stamp will be verified as the latest Rev. , and a red DCC control stamp will'be applied with 098 control~~
~~,, No." entered. Any questions feel free to contact~~
~~(_. ,.) me at ext. 270.~~
~
~~O g ing Systems Supervisor~~
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,. m p-- ' ' ' ~ ; sis REPORT B U E 1,038 .. . THE HARTFORD STEAAt lloll.ER INSI'liCTION and int l HAM:I! COAlPANY mie nmn.cossn:nn's e: 4-003-2 TO: DATE SH EET OF i.. G2rdon Purdy, Site Q. A. Manager June 22. 1983 1 5 FROM: H.O./ BRANCH OFFICE Billy Walker, ANI Hnumenn - ORGANIZATION Brown & Root. Inc.
LOCATION STREET CITY COUNTY STATE ZIP CODE CPSES Glen Rose Somervell Tovm. 7An61 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P.O. NO. Txd Blixt, Q. E. Group Supervisor M 047nn7 REASON FOR VISIT Full time contract. COPIES SENT TO: O H.O. E., Cr.i . sis . ER.,i.
~
OChi.f ra. , iu . ,. sis Eers., ts,.cifyb ANI file ____.RE L_ Brown. &. Root supports welded..to .the . containment liner. of Unit 1. . ._ . .--- _ _ . . _ _._ Meeting o f 6-15-83 . .. ._ . _. . _ .. Meeting _.Qf.6.17.-83 . _ _ . . .. NN M. . _ . ___ _.. My understanding .of the actio.ns. to be performed t / ve blems identified
. . . . ..fn.the meeting of 6-15-83.concerning. vague weld symbol re as 1 l .. -._. .(1) All. NF..suppor.cs we.lded_to...the.. containment - lineat"sustTIG. steel" . . . . . _ _ . ._.c.onstituents will be reinspected by QC to identify which welds actually exist. .._ _
~~(2)_. Engineering to perform calculations using only the welds designated by~~
.. _QQ.as existing. . ....._._ __. . . _ . _. . . . _ - .._ (3) . Supports failing to meet. the design criteria will be addressed on . NQ.R's , .and. ,, .. , . . _ _ , , _ , _ , _ _ . _ , _ _ , _ , _ _ . _
I
~~.. (4) Supports for which the wel.ds are accepted "as is" per calculation, . ._ .~~
I f_._..tigEngineerwillrevisethedrawing.toindicateexistingwelds. . . _ . . . _ , My understandirig of the, meeting of _6-17-83 with Ted Blixt, Engineering Repre- .._ _.._
~~. . . ,ssnatives and myself is that the supports discussed in the meeting do meet the original ..~~
dasign criteria, and Engineering does.not wish to revise these drawings.. . . . .
. _ _ , . _ . . , Although the weld symbols are still, vague for those supg rts listed. on pages 2.._,, _,
~~j thru 5, QC verification indicates that all the joints similar to the specified joint ._, .__~~
~~. . indicated on the drawing are welded; therefore, there is no question as to whether de- ,~~
~~OOVER SIGNED~~
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.X ~ CASE EXHIBIT NO.1,040 bile op is- ea a -l % SIS REPORT U bm / - Tilli11ARTFORD STI!A31 !!OII.liH INS!'!!CTION and r '.L*RA.NCt! COAT!'AM' H AM i t OHil.t:OMI 6 *l H L i an.luf 10-022 1: CATE SHEET OF Gordon Purdy, Site Q. A. Manager 6/30/83 1 1 FROM: H.O./8 RANCH OFFICE Jstry Lytle, ANI Houston ORGANIZATION Brown & Root, Inc.
LOCATLN STREET CITY COUNTY STATE ZIP cot ([ CPSES Box 1001 Clen Rose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME ANO OFFICIAL TITLE) CON TRACT / P O. .*!'" REASON FOR VISIT
,M dk 35-1195-C561 Full time contract /, S//
COPtES SENT TO: ~ O H.O. E., Cr i . sis O Chi.e inie.<io, Ga.i.e.iu.a...,. sis
~~, IP 0.h ., ( At. I file ,~~
~~S_ubj ec,t :_,QCWI-23 dated June 16, 1983 , _ , _ , , _ , _.~~
~
The_,subje_ct _QCWI states "that snubbers _,may be removed and reinstalled by _ construction with an IRN".__Q.C. must witness.th.is_ operation,and document it on rn Inspection Report. I do not understand how this fits in with the,. program,_since: , .. (1) Brown & Root ,qA JJanual. doe,s,,th,1.s *,_Se.ction 1.0 scates."an ,
....... _._. .. . . . .. Qperatignal Travel,er shall, be used, f.or non welding installation . . . . . . . . . . . .. .. .a c t ivi t ies," . ,_ , , , , , ,,, , , , , , , _ , ., ... (2) CP-CPM 9.17 paragraph 5_ st,at,es,",the, operation will be documented by ,Q.C. in accordance with 9.C._, procedures", _,
(3).._g,I-QAP 11.,1-28A , paragraph 10.2 states ,"the ,results of snubber inspections shall be,docum,ented,,on ,the,q.C._, checklist" (for snubber installations) . CPM 6.3 paragraph 2.1 "The Operational Traveler' . . . , serves
~~, , , , , , , , . ,, as a_ fabrication / installation / inspection checklist of operations . . . _ _ _ . .necessary to achieve a qua,lity,end, product".,, ,~~
According to these references, QCWI-23 falls outside of your program. ' /(d-~- - -- .. . . n OOvr. . >""') k to. K ds
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'BrownCrRootinc INTEROFFICE Y.EMO IM# 25,991 DATE: August 10, 1983 TO: Marvin Coats,.ANI -
~~FROM: -J.T. Blixt~~
~~SUBJECT:~~
CPSES, 35-1195 SIS Report 932 #10-022, 10-022-1. The following is in response to the referenced SIS Reports. QI-QAP-11.1-28A, Revision 4 Para.'10.4, titled REMOVAL / , REINSTALLATION OF SNUBBERS provides specific instructions to the QCI regarding the docu:nentation t.hich is required your receipt of
~~'an IRN for snubber removal.~~
~~J.T. Blixt QE Group Supervisor . JTB/bm cc: G.R. Purdy G.L. Morris, Jr. QA File~~
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. INTEROFFICE . DMO IMf25,991A[nended DATE: August 12, 1983 TO: Marvin Coats, ANI ' .FROM: .J.T. Blixt SUBJECr: CPSES, 35-1195-SIS' Report 932 #10-022 & 10-0221.
QI-QAP-11.1-28A, Revision,4, Para. 10.4, titled Removal / Reinstallation of Snubbers provides specific instructions to the QCI's regarding the documentation which is required upon receipt of an IRN for snubber removal.' Prior to the date of issue of Revision 4, QCI's were given specific direction to document on an IR only when rework was not-involved. J.T. Blixt / QE Group Supervisor JTB/bm cc: G.R. Purdy G.L. Morris, Jr. R. Siever e _,r.y_,m ,--.w,--..y-,.- . - , - , - -=~w----" + - - - * * * ~ " " ' '
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1 ,o, CASE EXHIBIT N0.1,039 SIS REPORT \> l l
~~% - Tilli iIARTI OHD STliAM !! Oil.liH INSI' lit COMI'.\NY nau u <>un.co.m us t I . ua ji 10 ' ana ;. ot.~~
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, DATE SHEET OF .Gordon Purdy, Q. A. Manager 6/20/83 FROM:
~~1 1 __ Jerry Lytle, A'NI f . H.O./8 RANCH OFFICE~~
'i Houston ORGANIZATIOP8 Brown & Roo t , Inc. [ p h s' LOCATi4_N - STREET CPSES P. O. Box 1001 CITYj k-_ _ QTY STATE ZIP CODE Glen Ef -- Mc=cruell Texas 76043 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P O. NC REAS2N FOR VISIT BS 042007 Full time contract COPIES SENT TO:
O H.O. Eng C1.im. 515 O Chi.i ia.... . OR......I u.a.s. sis 8 orh.- (seec4): ANI file. R7ferences: (1.) , Brown & Root, Quality Assurance Manual paragraph 16.4.1 - "Deficiences in
~~.characteris, tics, documentationi or procedur.e.,which renders the quality of an item unacceptable __or indeterminate. s. hall ,be identified.and documented .~~
~~by the. Site Q. A. Manager using,an.NCR"..~~
- . ._. . ( 2)., NA 3355 - The.last. sentence reads, "The, Stress Report.and,all. such revised drawings shall be filed and distributed so that there ,shall.be no ambiguity . ... _ . .... f*garding the correctness of as constructed drawings".
~~Note the definition 0f..Manuf,actureg, "As used'in,this Se,ction,, th,e,, term Manufacturer means the organization or combination of organizations whic,h constructs,any item to~~
. . _ . . . . . . . . . meet the, Design Specifications and, the requiremen,ts,,of this Section". (NA 3310) ..._. (31..NA 442,0 ,- Sec,ond_ sentence;,," Instru,ctions.,,,p,rocedures , or, drawings shall . .... include appropriate quantitative, or qualitative criteria for de_termining that importar3t act,1vit_i,es have b,een satisfactorily accomplished". ... (4).._NA 4510 (a) .First. sentence l'Ineprocess and final examinations and tests shall be established to assure conformance with documented instructions, procedures, and drawings. ._
~~(5) MA 4221 - "It shall be the responsibility of the Manufacturer or Installer~~
\,, of ite=s to assure that *all personnel performing functions, including sub-contracted services, within the scope of this Section are qualified as SIGNED OOvo
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+ ;~ . ' n . 8 10 '.C ' * -Sis'Repor*. C-051' s< .Page 2 of 3 b . } ?specified in this-Section". ~(6)";NA 5112 .'* Inspectors performing ' inspections required by this Section_shall be the Inspectors who have been qualified by written-examination under. the' rules of any State of the United States or -
~~Providence of Canada which has adopted the Code".~~
~~'(7) Reference NCR M8080S Rev. 'l My note giving my reason for not agreeing - 1with the disposition, and Mr. G. M.: Chamberlain's-reply.~~
When, reviewing NCR's, there are-times when an ANI feels he cannot sign either or both the review or concurrence. Due strictly.to professional courtesy and .as <a service to our customer, we try to convey our reason (s) for not signing. . It is .not required by Code or ANSI or any other standard I am aware of to do this, however, as you can imagine, just.not signing an NCR and not giving some reason would quickly create a very confusing situation for your people and not answer the ANI's concerns. It was this I had in mind when I wrote a note (attached copy) concerning NCR M8080S Rev.1 The' original NCR was written by QC Inspector Fred Evans-while revision 1 was written by' QC Inspector Thomas Ellis'. Both of these inspectors have been qualified by Brown & Root, and have many years of experience between them and both satisfy the requirements of Reference 5. In'this parti-cular instance both of them identified a problem and satisfied the requirements c of Reference 1 while they were working to satisfy the requirement of Reference 4 The problem was also discussed with their Lead Inspector to apprise him of the situation and get his opinion. He concurred with their decision. All of this I have first hand knowledge of since I was there at the time. formingThecondition. disposition to their NCR did not, in my opinion, correct the non-con-It states that Engineering had sufficient information. While this is good for their purpose, it does not satisfy the requirements of Reference 2 or Reference 3. have been met, Also, since Brown & Root must now certify that all requirements of clear and concise information to work with, Oteference 3).it is essential that ing it, Af ter reviewing the NCR and writing my note giving my reason for not sign-the.NCR was given back to'the Action Addressee. Apparently he did not agree with me and wrote me a letter addressed to me. While some of his reasons are valid, I have to take exception to'his last four sentences. NA 3355 does apply, a drawing should be clear enough to satisfy the requirements of Reference 2 and the ale,in 3, poetry has nothing to do with this situation, and the people involved industry. As stated before, the QC inspectors are qualified and certified and I myself have satisfied the requirements of Reference 6, in addition to formal schools, training, and years of experience in the fabrication and inspection industry. It is my understanding that Mr. Chamberlains position requires him to engineer him. pipe supports and not give his opinion of people who do not agree with i and myself. questioned'the integrity and knowledge of Brown & Root personnel He has If this is to be a continuing situation, perhaps it would be best not to explain reasons for our actions, since this is not the first time that an a e t
s ~ x-e _. * .. - , 1 SIS Report C-051 4 ~ Pagt 3 of 3 ANI has taken harsh verbal abuse from Engineering people. This does not ! stateLmy personal preference, since we are all in this together in order - to accomplish a common goal, just one solution to a given problem. Any help you may be able to give would be appreciated. At this time. I' am requesting that if Engineering has a problem concerning the ANI's they contact you or your designee (s), and do not communiesce directly to us. Thank you, 7 Jerry W. Lytle, ANI JWL/jah - 'l Response requested by 7/13/83. e 0 0 e S
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TAG /IO NUMBER LOCATICN OR E1.EVATION RIR NO. xa<2- .,4., cc.-I-04/-123-M 3R Mfn r~1 -ols' Et . G'n'El Rf2M / l10t: CONFORMING CONDITION COzys%#/cc.-4, W $/ DOCUMENT VIOLATED: Vo e, Cepfd1L REY. / PARA. L///# ORY t'-/4 Revl'- Wall c L, ols sk a.w ., d., V C <D, ' l h,d*/s -h iMs" / a d S* do uo+ c ou %e. voIA cdywa.hc.!c.", +9
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~~p 3, % fg MM h INTEROFF' ICE MEMO TO: J.W. Lytle, ANI DATE: August 1, 1983 FROM:- G.R. Purdy.~~
~~SUBJECT:~~
~~CPSES, 35-1195 SIS Report (932) G-051.~~
~
l I apologize.for being rather tardy in my response to the subject report; there was however, a degree of " footwork" to accceplish prior to completing my response. I share your concern over the rather flippant response provided by Engineering, relative to your observation on drawing CC-1-041-723-E63R.
~~'I have discussed this matter with Project and Engineering Management, who have reinforced the policy that Quality Engineering is the proper interface between the ANIA and other Project organizations.~~
Although the Project environment is currently conducive-to frustrations, I trust that proper implementation of the above interface function will preclude the recurrence of. venting personal frustrations, and enhance - ,. . thg cooperation between interfacing organizations. }\ ' s l O M G.R. Purdy I Site QA Manager { cc: J.T. Blixt R. Siever G. Bennetzen M. McBay F. Burgess B. Sims D. Snow
~~B. McNellie M. Coats SQAM File, 'w/ attach.~~
i i i f 1 6 w 1
.i 7
~ 'Q/ 51S RECORO FOR f.10NITORING Q.A10.u. PROGRAMS THE liARTFORD STEAM DOILER INSPECTION .ind INStJRANCE COMPANY CASE EXHIBIT N0. 1,041 si.wirono. conumccr een #356 ~
~~r.au.,~~
= - so rne.. ~ urn sous or ,.=E. CusroulasCordon Pur.dk 9fra 0- A- " = ga" 'Julv 1. 1983 1 . 2 O ccurans maut A V.ERanCn inV. al;;o. CR scal,Gn cogn:Rs intGionst usg onLrs r- r--Follow.Up gy Brown & Root. Inc. Houston Heusenn '-Reevires closed "E ~ '"S't'i 0* icC2'4a j.- Field Rspair/
~~CPSES Clen Rose. Tens d Sh00 Assembly Alteration binservice~~
~~1. the undersigned, have monitored your QA/QC manual on: 7-1-83 and find the following sections:~~
~~s a... nan,ws one rar..o u satisf actory:~~
.. .. . -- -~ - eia. aa, oaicc . n.. ...e n (n.. ene raa.} ca so.nory aae .o... .. a.o..nren,e.. .. .ooi. was L unsatisfactory:
Sect, ion VII Document Control . . _ _ , . ._ . Paragraph 7.2.2 (b) Design documents - Verify presence of a " Release for --- ja Construction" letter or that thb document contains..the release criteria . . . 85 g3 provided by the Engineer. . .. .- -- - Documents not approved for,use s, hall not_.be , issued _for construction, but may _ . .. _ be issued as uncontrolled documents for the, purposes. discussed in Subsection.'7.2.5.- .. COVEl CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, and give ? (.~ date for completion of corrective action, so that items may be remonitored by: ?" 1 " 19 1Q81 toer.o Please keep the Original of this form for your records and return a copy to inspector named below.
~~===a ari $= s = * ~ ~<~> '~~
~~L . u chsis c ro,e,n,,e ep,sienui usaur . o,1,.m irt.s nou. iu T rae,. o,. .s n 7-1-83 u.s.,,wo, ,c . . .,..~~
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l OVEF u,....u,,,,...-,,.. , , , - s - .,c.e .... .......... .., k I, the undersigned, have remonitored the above unsatisfactory conditions on: [),;//j'y and found them: C 5atisfactory hnsatisfactory fEsplain cetow) ly -
~~~j~5.s 12cna- 6t.oso 2 > /a-c o n 919 *.?Lt . . .~~
~~. = L, ' U 5~~
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c' des Mar! sis Foreigs Representative _j. sp. ju't SW File J/// h d. m eiv n.: rsis / '
"o ,. , c .' ' SIS Raport 9 356 * ., Pags 2 of 2
(: Paragraph 7.2.5 Uncontrolled Distribut;ca Documents may be issued for information purposes (i.e. , training, inquiries, and material take-off) . Such uncontrolled distribution shall be clearly identifiad as information type documents and shall not be used
- for fabrication or installation activities. Information type documents shall be marked as "Information Only", "For Training Purposes", " Bid DocumentM, or other phrases which identify the document as an information type document.
~~NA 4430 Document Control The last sentence states: "These measures shall assure that docu-ments, including changes, are reviewed for adequacy and release by~~
~~authorized personnel and distributed to and used at the location where the prescri, bed activity is performed".~~
~~According to Brown & Root's Q. A. Manual, the Document Control Center is the only department authorized to release and distribute design documents for construction, examination, or testing.~~
~~As of this date, I i '~~
~~have found numerous drawings in the field which have been stamped ,~~
" RELEASED FOR CONSTRUCTION" but have not been issued by DCC, since there ! have been no control stamps on them, nor any other indication of having been through DCC. Most of these drawings have been attached to MCR's to t.
give objective evidence that a drawing has been revised to clear a non conforming condition. This is a generic problem due to the number of k.. uncontrolled documents found and the time span indicated from following examples: (1) NCR M8728S Drawing GH X-080-004-3 Rev. 1 (6-29-83) (2) NCR M8097S Drawing CH-X-AB-066A-013-3 Rev. 2 (6-24-83) (3) Drawing VA-1-006-005-CS2R in hanger package for ANI pre-liminary review. (6-24-83) (4) NCR~M8183 Drawing CC-1-RS-007-002-3 (7-1-83) (5) NCR M8149S Drawing CC-1-RB-039B-003-3 Rev. 2 (.7-1-83) (6) NCR M8861S CS-1-RB-059-003-2 Rev. 2 (7-1-83) (7) NCR M8300S Rev. 1 Drawing CS-1-112-722-C51R Rev. 3 (7-1-83) (8) NCR M8193S Drawing CC-l'-R3-007-001-3 Rev. 2 (7-1-83) These drawings did not have any stamp on them to indicate they were for "Information On'ly" or any other stamp to indicate compliance with para-graph 7.2.5 of Brown & Root's Q. A. Manual. Again, let me emphasize that this situation leavus the status of a ; drawing indeterminate as to meeting the requirements of Section VII of the l Q. A. Manual or NA 4430. It also leaves a question of whether Q. C. Inspectors have a controlled copy of the drawing when they sign the Q.C. verification of a HCR. d l
~~- - - , . - , - y y - - - n - -, -y.- - - .y- - ---a +-<m-m-asy-m--rny,,e - - , , , - - w---ww-,,w-va'----- n v wr-~~
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.s. muuna ruw mJmTWul:M;fWW g .2 ~.,L CASE EXHIBIT NO.1,042 . _ g&. . ) n.vasio na u nnani onio<n.m smsn.nu socV1kl./u u.iussii:ina atu bcL:HMs<.u. h MUMAt0 7 18357 , i. ,: . .m. ,
_ bi lmt s ur ce Hr. Cordon Purdy, Q. A. Manager g . . . . - . _ , : July 2. 1983
~~-.m........., ]~~
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."- 3 3 Brown & Root. Inc. +inusenn lin un en n gg,,,L.ictos d -.-Ree vived ' ' $ mW:eex.im -heis ,- CPSES Clen Rose, Texas q - Shop sepair/ )
e LY.lAssernN, Daiie,,i... Oi.ier,ic. ; I !. the undersigned, have mo'n tored your QA/QC manual on: 7-2 83 rover and find the fol lowing sections:
, ea. n.,-e ermen - , L Satisfactory: ._. ,1<.n or on.ac .".,u ..non (ue. .-e rm.) on nr.nur r en. .ous nononov~~. .. .co,...m, t unsatisf actory:
~~Section II Inspection Procedures and Instructions~~
~~References:~~
~~SIS Report 939 # 311A 5 J~~
,3 I.M. # 24.719 NF 5212 QCWI-19 SIS 932 0 G-044A f CUSTOMER: Please describe the resolution of these ifems in the " CUSTOMER'S RESOLUTIONsectio OVER date for completion of corrective action, so that items m'ay be remonitored by: 7-20-83 -'. ,c.r.
~~Please keep the Original of this form for your records and return a copy to inspector named below. N 8U* $l$ foreit, 1889. SWB ,nse tas wree,~~
~~,X. Reg. Ngr Representative hfile g~~
~~.newm a ,*si iri s usu1=o .sm .s u=c ucauw ,c.n 7283 h~~
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1, the undersigned, have remonitored the above unsatisfactory conditions on: Julv 17. 1983 and foJnd them: $ Satisfactory CUnsatisfactory(Emplam estow) eo... .
*L. ,. See page 2 of 2 d " I, I t ., . .ii...ur.
sis ,, 3 wtvoo i.,,,s.,,,-,.,, See,uir/repr,n,,e,n,tativ. G r,a,,.," 7/18/83 - D [. N e, a ni nm assi ___ G L { Ple4WMIP"N 7"DW'MM
~~-hn ' - -~~
SIS R:psrc 1357 Pcg3 2 of 2 (' k' ' on 7-1-83 for hanger chis inspector was called to witness a PT on a weld buildup CS-1-112-734-C61R. Upon arrival only h of the weld was prepared for a PT examination. The top half was still covered with paint and met the requirements of a full fillet. The QC Inspector, James Lloyd did not know he was supposed to PT that part of the weld. Upon discussion with QCI Lead Larry Wilkerson, he understands the requirement for NDE of full fillet welds is for only inprocess inspections. Upon researching this subject when 939 #311A was written, A.R.M. Bill Tillman, Sr. Regional Manager Ron Howard, and SIS Manager Don Young were consulted for clarification of NT 5212 and the opininon of HSB is that if the weld meets the requirements of a full fillet, then NDE must be performed. Brown & Root Q.A. agreed to this on I.M. #24,719. Since the time #24,719 was written, other inspectors have had ANI hold points for Visual Examinations on Class I hangers. The Q.C. inspectors knew nothing about a requirement for Pr of full fillets. (These are very knowledgeable inspectors such as John Caldwell Tony Linsy, and Russ Hilton). Upon investigation of other hangers on CS-1-RB 029 the following hangers were found that have had a recent VCD attachment 5 signed satisfactory. CS-1-112-725-C61R CS-1-112-738-C71S CS-1-112 727-C615 , . CS-1-112-731 C61S These hangers were signed by a different i*nspector, Roger Walters. 1 It is apparent that there is a severe breakdown of communication between
~~. { i)7~~
~~' QA, upper walkdowns.~~
management QC, and the QC inspectors in the field involved in VCD For this reason, and the hangers listed in this 939 ALL Class ! VCD walkdowns are indeterminate. I am also requesting that ,ALL QC inspectors and their leads roccive documented training into the criteria of inspecting . Class 1 supports which may have full fillet welds included in the hanger. This 939 is closed based on the following: (1) No Class .I hanger packaces have been presented to ANI for final ; acceptance. When thev are, they will be walked down by MI to
~~' establish a confidence level that examination require::ents have been met. If any discrepancies are found, this 939 will be re-opened. -~~
~~This also closes 932 i G-044A. . e 9 L 1~~
i
_ , _ _ _ , ,- _ . - _ . . . , . . _ , . _ _ _ .,__,.,_.,m _ _ - - . - . . . ~ , , , - . - - . . . _ , . , , - - . . .
C g.8 . . .
~~..~h-F INTEROFFI L MEMO ,_c*. .~~
~~IM(25,852 ' DATE: July 12, 1983 d.70t Q;-( ,~~
~~,J. Mair, ANI' .f- .~~
o-
~~, .s .~~
~~PROMt ;R. Stever~~
~~. . .,.m. .. %... <SUaJECT: CPSES,?35-1195 * %/ /'~~
~~W. ,.y SIS Repor 357.~~
~~;) #'~~
w , RPS 705-604 was prepared to increase west portion of weld 13 on hanger y-' i t' . CS-1-112-734-C61R tot I"cas required by desian drawing.
~~? ..~~
~~Weld.13 on a d hanger was FT enamined inprocess and documented' s~~
*- # on WDC $321'4 by'J. McCosmaa on ^11/13/81. The only area requiring '. ,/ re-exa.nination by PT is'the repaired area. There was no reason to ~ require the additional work,of removing the paint and re-examination '
~~s Mof the ^' existing weld,:; g -~~
.y ? . ,Mr. James Lloyd'was cerrect. A did not have to PT that part of the / s. ,- x; .. g. ., weld that was.se repaired. , ~
e
~~" , The QC Lead was alse correct. PT examinations of full fillet welds~~
{9, .will:be done during inprocess.. inspections. ' At the time of final hanger,walkdown any efull fillet welds that have
~~p. t-not been PT or Mr. examined will.be documented on an unsat IR and Quality Engineering'will have Welding Engineering prepare an RPS to clean and FT or NF the weld.~~
~~All ASME Class 1 hanger packages that have had construction and/or QC inspections performed since October 1982 are being reviewed to assure the: ruguired NDE has been' performed.~~
. z. ,, It appears-that you have been talking to the wrons people or have been ',j misinformed'.in regards.co c'ommunications between QA upper management, QC and QC inspectors. All QC inspectors and their Leads do receive training'and.at thja time Stown & Root does not feel'any additional
~~j. [trainingisrequired'forClassisupportsorfullfilletveld inspections.~~
1
~~.c ,~~
r,- Brown G ioo3.. feels'thatsthe review of all Class 1 inprocese document packages prior tocche.finst VCD walkdown will assure that no full fillet welde get through the nystee6 without having the required PT/MT
~~,,aexaminations performed.- ,~~
~~e l ? f.- q~~
, s. - - - -4 f 's R. Stever QC Group Supervisor RS/ba' ' '
~~', cct C.R. Purdy ,~~
J.T.~Blixt /* !- 0.L. Morris, Jr. << f M. Coats.-ANI.
O M '.^ SIS# RECORD FOR MONITORINS g.A./SC. P . .aRAMg - CASE EXHIBIT NO.1,043 THE HARTFORD STEAAt BO!!.ER INSPECTION.tnd Inst.,*RANCE CDtPANY H 4MTFOND. CONNI:CTICt.T omstrJ se an .., r ,,., 8362 A
' c.is :m t Cordon Purdy, Site Q.A. Manager August 3. 1983 1 l o,2 d cui,c is: cvem a.m lase e <.. =se etc.c. ce ,o.t<,= uusin, .
3 Brown & Root. Inc. <aegp om Housto Houston C hes,gse ours,,, C 0esed g . r,.i. a.c.i,e CPSES Clen Rose. Texas thes ass.sary O***n,* *
~~'ai .at'ei.~~
~~1. the undersigned have monitored your QA/QC manual on: A-3-83 _ and find the fgilna . ; 4ect,nn.:~~
_ ,a, no. e rare.o L ,j satisfactory: I pX uns.ti.tacto<,:,re.~roa,ac .~., (n..et.s,.;onne.wrme..m.o em .~... ~.....m. .o Section 20 Authorized Nuclear Inspectors On many occasions ANIS have been refused access to areas in which Code related work was being performed. These areas are Reactor Building 1. Diesel 5
l3 Generator Building 1, and the Fuel Building on dates 1-16-83, 3 17-83, 7-10-83, 7-23-83, and 8-1-83, as well as other ocenatons not recorded. In some cases, cecess was subsequently achieved by construction personnel making an orange badge 004 3 CUSTOMER

Please describe the resolution of these items in the " CUSTOMER'S RES01.UTIONsection below, and give date for completion of correctne action, so that items may be remonitered by: _Augune 17. IM1 g , c . ,. ,
~~Please keep the Orlainal of this form for your records and return a copy to inspector named below..~~
~~...so In., vi,hn..,,.f.% EEi,x,.. . .. ., . . .. . c.~~
~~8-3-83 > M,2,4/.,/J/, _~~
~~.i m,-o , ,. . . .. ,~,.. ~. .y. ... .f p 0-C LVA see Attached IMd26,055 [ '~~
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~~. u..bm . <,,l,H s . S.l.ls/s 1 >...,,..............f..e f ? $ O, f I, the undersigned, have remonitored the above unsatisfactory conditions on:~~
~~9 7.y) Xi.n...i.,,~~
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~~and tound inem: Cun..u.t...,,fa,s.,,.a.,0.o izw.a., ,3 ,y v.c~~
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~~3 .4deej .ne my L.A J. g amu .v,L,.J JM'c~WA aD.c/r) Tfh},ln..,,.dat 5noe u m ., .,~~
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~~y SIS REPORT #362 A Pago 2 of 2~~
~~. l ~ ,~~
T .' j. availab1e when 'ANI's c6maythe haveANI. The effect of this is that construction decides access. ' m Positive' action must be taken to ensure ANI's have access to all areas any. time Code'related work is being performed. f-In addition, ANIS should have access to all areas regardless of whether or not work is actually being performed. This is the purpose of performing random walkdown of items prior to final document review and to walkdown prior to signing N5 Data Reports. ANIS also-reserve the-right to walkdown systems prior to signing the system N5 even though NS Data Reports have already been certified for all subsystems. l f V $k j4 Billy W1ker I ... , - p . i. e A w eh _ , ,_ _ ..ne r - e ~ '" * '" " * " ~ ' ^ ~ ~"
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INTEROFFI?" :2MO IM1 26,055 TO: 'N.C. Smith DATE: August 18, 1983 FROM: G.R. Purdy - *
~~SUBJECT:~~
CPSES, 35-1195 i QA/ANI Access To Areas In Which Code Related Work Is Being Conducted. This memo is issued to confirm our previous discussions on the above subject. In accordance with Sectior. 20.0 of the B&R QA !bnual, and Subsection NA paragraph NA-5120 of the ASME B&PV Code, the ANI/ ANIS must have free access to all areas of the site during the period of assembly and testing. By Code terminology, this means that the ANI/ ANIS must be permitted free access to areas until construction (i.e., N-5 Certification and Sta= ping) is complete. I By our mutual agreement, it is not the intent or requirement of the "RWN" access control program to restrict the freedom of access for QA/ANI/ ANIS inspection personnel to perform inspection or cerification activities. b . ', However, due to incorrect interpretation of the program, several access problems have recently been encountered as outlined on * {
l>
~~the attached ANI SIS Report. To preclude recurrence of this problem, ' it is requested that copies of this memo be distributed to personne.1~~
~~responsible for implementation of the "RWN" access control program'.I rJmS/~~
~~G.R. Furdy / Site QA. f tsnager~~
~~' cc: B.J. Murray D. Deviney R.G. Tolson i M. Coats 4~~
esF
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.,w-) , SIS REPORT C Of #342 4 THE HARTFORD STEAAt BOILER INSPECTION and !' ';t;RANCE COAIPANY HARTFOND CONNE(Tf tCLT ont(C n^ l i
~~IROM: i1 f Ch Y,lls t a s'k f 0. f/ ppqu DATE f-7-$3~~
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~~939 AUDI1 aiECKLIST~~
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~~Sheet 2 of 2 MANUAL SECTIONS 2o DATE f2f3~~
~~- AUDIT # 362. -- 'g ' 'y~~
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~~V ('rTT SIS RECORD FOR MONITORING Q AdQ.C PROGRAMS - CASE EXHIBIT N0.1,044~~
) THE HARTFORD STEAAt BOILER INSPECTION and INSifRANCE CO31PANY HARTI-ORD. CONNECTICCT 06:02 8361 A p- Vo tName .nd Titter Dati snell Cr .. Mr. Cordon Purdv. Siro n_ _ w n n o n ,- A ,, o,, e
~~11 1o91 1 2 i~~
~ 'fg cus.cuers courant name mse saanCn vascaos ce ronbon Couarav ta I ' ga4j usetri say Marvin Coats. Lead ANI Houston i ouston -Required UClosed s ~ *5PECic" LOC 8'*" , Field CPSES Glen Rose. Texas Sh 9 Assembl, 0, Repair / ire,,,,..
~~Oi. service~~
~~1. the undersigned, have monitored your QA/QC manual on: A 11 A1 and fino the following sections:~~
~~ro ren~~
~~. .. e ,.r. .n. r.t ., ;;__, Satisfactory:~~
todent ty CAtCC manvas secton [No. and Tntre} OR teenney the specorse noncentormance as spot.csotes 1 Unsatisfactory: Section 7 Document Control Requested response date on 939 # 361 was 8/10/83
= ;;; g Findings: (1) As of this date, there has been no response to above nor has ES lE as extension been requested.
~~(2) Car S-54 Rev. I has not been closed nor extended. (3) AUl audit of packages in the field on 8/8/83 & 8/9/83 dis-~~
~~. closed the following. (see ne ent ho,0 R~~
-( ' CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, and give ^ date for completion of corrective action, so that items may be remonitored by: 8/1R/91 taster Pisase keep the Original of this form for your records and return a copy to inspector named below. o r- Insp. j art mt sto tasa saw.crois yaum
.x_. Ret./StS Mar Foreign Representative 2 File , 8/11/83 [g q assuru or ruost nus cesemsw ase L as at:nc casar.sracicar < cont,n .o. Ae.orie s,oe,ruecentry, See attached 1MJ 25,015.
s
** a a* $ 'E s 38 8E CATL CCanecityt ACr10N wu Bt CCMPLtilo cover Cait sich:3 / s3Ght0(Customer's Aeores araf,ve' /
~~Aug. 17, 1983 8//7/g3 > _ M;~~
l. the undersigned, have remonitored the above unsatisfactory conditions on: /)jp //3 and found them: btisfactory Unsatisfactory (Explain below) f,J ft., o,,n* /t/cN's Dil A J2C/urc, r ciJ w /sro c n-t'o sas.scwcc4
~~.O c,p /mp.cq a:ncQ- ./oMr.p D/24 J M . . Mgr Represe tative e _ _ _ p/M _~~
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~~SIS RGport # 361 A Page 2 of.2 ; k~~
~ Twelve hanger packages in Task' Force areas contained improperly marked - l drawings. Fourteen hanger packages in Unic 2 RB & DG contained draw- -
ings that had deficient " controlled" stamps. 1 l l I e 4 e 9 8 m 9 a - 9 M e
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~~, Brown & Root.Inc. ' .~~
~~t q:. INTEROFFICE MEMO IM - 26015 August 16, 1983 LTO: Gordon Purdy FROM: W.E. Baker~~
~~SUBJECT:~~
Response to. CAR #54 and SIS #361 Effective August 1, 1983 the new document control and distribution procedures were implemented at. CPSES. A description-of the new method of handling con-trolled-drawings is contained in the attached memo from J.T. Merritt to All Department Heads, dated August 8, 1983.
~~-In conjunction with'this, Document Control Procedure DCP 3 has been revised and all Document Control Satellite Personnel have been indoctrinated to the new requirements.'~~
In addition to the above, all Hanger Packages currently in the task force ko. areas or in Welding. Engineering are being reviewed prior to issuance to in-sure that all documents are current and that superceded documents have been removed or star. ped Void. The actions as described here should resolve the problems which were experi-enced with the previous program and have adequately addressed the concerns, expressed by CAR #54 and SIS #361. 4 I~ _l / $ > /? h ' W.E. Baker Sr. Project Welding Engineer kEB/ alt cc: .D.C. Frankum
~~(-~ , F. Strand .~~
~~J.P.-Clarke~~
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~~- ...~ 35-1195 8-8-83~~
TEXAS UTILITIES SERVICES INC. t P.O.DOX 1002 = Ct.EN Ro$E. TEXAS '6043 i August 8, 1983 T0: All Department Heads
~~SUBJECT:~~
~~Document Control Center Satellites - Effective August 1,1983 the DCC Satellites were in place and operational. Presently there are five locations as follows:~~
~~1. Satellite #300 (North of Const. Admin. Building) 301 This Satellite serves TUGC0 Start-Up, 302 , Completions and Area Management.~~
~~303~~
~~2. Satellite #304 (Pipe Shoo, Second Floor) a.) Slectrical Engineerin,g~~
~~('. .. b.) TNE c.) Mechanical Engineering~~
~~. d.) Damage Study ,~~
~~e.) Civil Crafts~~
3. Satellite #305 Adjacent to Combustible Warehouse) a.) Civil Engineering b ) I&C Engineering

c. Civil Q.C.

d. Field Engineering

4. Satellite #306 (Mechanical, Adjacent to " Church House") '
~~a.) Pipe Crafts b.) M111 wrights~~
. Insulation . HangerDept.(Fordrawingsotherthan Construction #98 Packages) i Instrumentation Craft 1MechanicalQC . .
~~5. Satellite #307 (Electrical, North of TG #2)~~
(a.) Electrical Craft (b.) Electrical Q.C. L. With this transition the old " control number / file custodian system" will be replaced by the Satellites which are staffed with DCC people. Several control numbers will remain for logistical or technical reasons but they will be controlled and audited by the DCC monitoring team. up
~~. I' ; ... - ; *1 4j ". - 7 1~~
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~~Page 2. August 8, 1983 7~~
~~/ '~~
The "Information Copy" will no longer be issued. All " Controlled" drawings will be issued and accounted for by the Satellites. The crafts will continue to check drawings in and out as in the past. Aperture cards and viewers will be available at each Satellite for viewing drawings when hard copies are not required. Documents will also be distributed for purposes other than production. (physical construction) or QC inspection activities. Issuance of these documents will be as authorized (see OCP-3 #3.1.3.1) by signature of the attached list of authorizing personnel. Documents distributed in this manner will be stamped "For Office and Engineering Use Only". Xeroxed copies of authorizing signatures will not be accepted. All " Controlled" drawings assigned to and issued from ~the Satellites are stamped with control numbers in the 300 series (300,301,302, etc.) in " red ink". Documents logged directly from the Central DCC will be stamped with the control , number "333" in " red ink". Any control documents presently in use .not bearing the control stamp in red ink, are not authorized documents and must be returned to DCC for proper disposition. As with any system change, we expect minor problems and frustration until the ' concept is understood and accepted. Your help and cooperation is essential to phase this new concept into being. Every effort should be made to keep your drawing requirements and requests to an absolute minimum and allow the Satellite.: to function as they are designed - reduce the number of drawings at CPSES and tighten the control of drawings. We have made a commitment -to the NRC to implement this program and make it work. Groups not addressed herein (PSE, Welding Engineering, Production Control, Mechanical Drafting, etc.) will continue to be served from the main DCC. Present exclusions to th:is concept are:
1. Procedures t

2. S-910 Program

3. TUGC0 Operations

4. Mail out~ distribution

5. Conduit numbering drawings -
These will be addresed an'd folded into the System as time permits. An internal audit team from DCC will assume the responsibility for auditing the Satellites and other groups to assure file integrity and accurate drawing
~~.,,, status. ,~~
~~Authorization forms for " Office and Engineering Use Only" drawings will be distributed.through the Satellites and at the main DCC. s~~
~~.'.e~~
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~~'J 9 Page.3. August 8, 1983 !~~
~~l Any questions regarding this new concept should be directed to Frank Strand at Ext. #263. Your cooperation'is not only expected, but mandated. i~~
}
J.T t<erritt As . Project General Manager g"- .. JTM/tm .. e 4 e i
~~.,.= l pp~~
~~~8-15-83 w.. . ., e7 . . 35-1195 drewnf5 Root.inc. .#4 ..c INTEROFFICE. MEMO -~~
~~TO: Mr. W.E. Baker August 15, 1983 FROM: Frank ~ Strand, DCC Supervisor~~
~~SUBJECT:~~
~~Document Control Procedural Training '~~
~~REFERENCE:~~
~~CAR-54 Please be advised that Satellite Personnel have been trained in Revision 16 of Procedure DCP-3. Further, the orientation classes have now been organized and are in process,~~
~~b. .~~
MM Frank M. Strand DCC Supervisor FMS/tm CC: F.M. Strand H.A. Hutchinson
m .
~~;H GIS RECORO FOR MONIT0!!!NG Q A./Q.C. i% AMS 6%g '~~
~~Tric saaTrono srea3t soitua issrucric.. ana isst:aasen co3icaxy~~
- CASE EXHIBIT N0. 1,045 . IIAMTFONO COSNIEI'It:t ~r 8410; . ro , .... .., r.,,. . .N.]/7 .
~~.rc Q* sm ;%ow Su o.a. sam -~~
~~;j Ca sicutA s COWPANT 4A (~~
m.=- ririn ii m',P sRANCH tNsf f( 4 CA ICR(ICM COUhrav Ef AEGJONAL (,Ist C#LFJ hw ,-l /A f~ //,,) Sa msnCim tcCate U$n'u*h UClor. I 8d h/W /Nf d*, N. eld Repair / b$ho2 Assembly Alteration lass."h I, the undersigned, have ' monitored your QA/QC manual on: and find the following sections: s a.r., ea< . ~.u-o.n .ao rm..a G u ns.iisi.cio,,:tw.ar ry oatoc m nuu ..< ten (no. .no raI.) ch . :.nray ta. .oecor.c noncento,m.nc. .. .po~e.or.s
'~
p C. Lot.)t;ri;;> ~}~~O 353 ,. I2 o5 l5 , 41J/ 'r ' t.h u. /,l so,e. o Ar c.t. /% /. M J & > / a s./<* v c.: <.? A
/4df/L /d Ds(,,,or-$p hAJ/*W JM*
E .,- YN k /' CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION"jection bel , . date for completion of corrective action, so that items may be remonitored by: [/W/D ' Please keep the Original of this form for your records and return a copy to inspector r.amed below,
~~/ / us.r.o on.a. sura p ;*:t sota solo rase~~
~~s re,y Ieg, Ugr egresentative F le [ ,V f,f h 4~~
~~.s2 .. ., Cso,t.s . ..m .s ...o s.,_, ,.. . ... . ... ., .....,,,~~
~~I see eeswse to si3 3s3~~
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Om s e.a. wrwic, om es-./2s?S3 >s m o,... V E. >e %t~ 5 af . N, .,w /2/ _ I, the undersigned, have remonitored the above unsatisfactory conditions on: ff[J.f.,g) , and found them: ,_.s Satisfactory CUnsatisfactory fEsplain Delow) M SE l..,_,$ wt-b - f K # 543 C 8'stnieuN gi$ p,,,,gn can acato 3,, .soto russ ia.e.ciers ~ Ideg. Mgr Representative _ File ((,1./,//s k gy , ,7 n Ett. itt:) QJS ' l l ,
*- * ~.~ . w. .. .. ~=~dw e W .W ~ -- , SIS RECORD FOR MONITORihG Q1A./r s .u.
~~P30Ga%~~
~~Tile is.CnIIARTFOND NT1*e614' slatst. rsme e*TH.tT Ol 150f t.ER INSPECTION and INSURANC.c. w..tPANY~~
~~. torneae ene rses # 363 )~~
~~D. CCM E*d. /. SitO Q. A. M13acer cart 5,ttti u~~
~y CWo't '1 s*** ** susr re ncn Aucust 18, 1983 1 l*
P. m & ht, h.~ mse etc:cs on scato couens intasonar use onLrs 3 " Flouston Houston U ui e Ocior-
~~"h '""N Gleft R3Se, TeXa's Field Repair /~~
Shop hAssembly 04 te,stio. Orai - I the undersigned, have monitored your QA/QC manual on:_8/18/83 r o.,,, and find the following sections: sca ==e== .a ra s 1qUnsatisfactoey:ene*~~,r oncc =.a.e u u.aa (ua. ..e rm.3 r on ia.na,r en. .o.a,r,a aancan,armenee n none.a.. See Attached. ea= - g3 . w -
+
C :,' , Ms.- '. CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" sectio date for completion of corrective action, so that items may be remonitored by: . s c.r.s Flease keep tha Original of t!'is form for your records and return a ccpy to inspr.ctor named below. oW1 Ele'JI'oN
' 'nll slchio e $oGhto (Nsg uns..erers ., $ Pet. Mgr epreset tauve 3'7['
r e8/18/83 M sismunen or raest ersus casca.sto aeove as st.ac unsansracon rceaua.. h muu.. s,,,,, Au..u44 47 ' i ,' .. see ternc-seC> T r et.s M S G.- ...- . 05 M5 85 SO w a. wit contenic acnom wu se ccumrto COV sesa woem acaresoto s o totc.., .,. n.,,. .,.,,.., e /as4s > Aata <- --
~~1. the undersigned, have remonitored the above unsatisfactory conditions on:~~
8/26/93 and found them: O Satisfactory CUnsatisfactory (hplain calow) ' 3 Qc ' 8 ' u Brown & Pcot response to non ccrnpliances identified is accep, table except W for a few specific concerns. See 932 #G-062. Mgr egre entahve le ,Z.g,[ D f
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=l . SId tiepare # 363 .. . j e
r - rege 2 of 5 EXECLTTICN OF N-5 DATA REPORTS v. (1) ANIS have rejected the majority of submitted N-5's for in-accuracies, missions, inaccurate hydro pressure, BRP's un-acceptable. (2)
~~'Ihe Subsystem N-5 for SF-1 was submitted for ANI signature with an coen C.A.R. in effect against ccuconent supports for the Spent Fuel Heat Exchangers.~~
ACCIES FOR AUTHORIZED htCLEAR INSPECIGRS ANIS are forming consistently their duties (Ref.being denied access in the process of per-witnessing of hydro tests. 939 # 362A). Three occassions involved i hardware associated with an N-5 I was presented.On This is unacceptable 8/17/83 I was denied access to i l and is in non ccupliance with NA-5120. logical testing to satisfy requirements for security 'Ihree access.Six A othef ANIS have initiated caperwork to satisfy these requirements. j MAINTENANCE AUIHORIZED OF QUALI'IY NOCIEAR INSPECIORS D(XISENIATION AND AVAIIABILITY OF SAFE ' (1) i There are numerous instances of changes being made to 3.g , . control records, hanger packages, hydro test oackages, process and - F, other documents after final acceptance by the ANI without bene-
\
fit of concurrence of the ANI. 'Ihis is not acceptable. * (2) On 8/17/83 I observed Jam 1s Indexed hanger packages in Aux, l i Bldg.- Task Force that were retrieved frcm the Vault w.ithout voiding of the cover sheet signed by QES and ANI. l (3) Hartford Steam Boiler agreed that when ANI review of doctraenta-f.
~~tien was necessary for those records en file in the PPR Vault~~
~~; the ANI (a) would do that review in the Vault.~~
~~On 8/16/83 Inspector Harper requested a hanger package for review to reconcile an attaching hanger. Ha was~~
~~denied by vault perscrmel.~~
(b) ANI's consistently lack space in the vault area to review records and complete checklists. On 8/17/83 Inspector Hair and myself had to stand and attenpt to review for records associated with an N-5 submitted ANI signature. I FCIlD1UP REGESTS & VERIFICATION OF ACCEPTABIE RESOIUTICN OF CX RRECTIVE. A . (1) A.R.M. Tillman, a m nied by myself, identified during his seni emual ANSI N626 Audit of July 13 and 14 deficiencies in e.' e e . e ____ _ - - _ _ . _ _ _ _ _ _ _ . _ _ _ _ . _ ---_______________-__________-____-.___._m______
e =
~~, -%. e . am .. g O s Report t 363 ^~~
~~1; u. . page 3 og $. . l'~~
~~- l issue, revisicn, and foll 'p of C.A.R.'s S-54, S-55, and~~
,G S-56. Additionally 939's 361 and 361A requested orcnpt resolution to C.A.R. S-54, me status of these C.A.R. 's has .not changed as of 8/17/83. - '(2) C.A.R. S-55 addressed lack of. Drogram Control of ccuponent
~~supports identified outside the scope of Mechanical Design Drawings and Specificatiens (i.e. Civil) . -~~
-Q1e addressed result was that ASME NF seismic sucports for -Spent Fuel Heat Exchangers had not been installed. Engineer-ing responded that it could not accept responsibility for lack .of identification of required installatien work. Additionally Engineering stated that.MS 46A (Pipe Supports) was not a'ppli-cable to this scope of work-and stated the " Design Drawing" was. .in the form of sketches to a DCA.-
~~(a) If MS 46A is not applicable, what is the apprcpriate~~
~~, design specification? .~~
~~(b) Installation to sketches outside the scope of Brown~~
* & Root's Q.A. Program is not oermitted.
~~(c) Subsequent installation of these supports did not have ANI involvement. R ey are not acceptable for Code l Certification.~~
~~RESPWSE TO IIENI'IFIED PROGRANTIC (ASFE) 10N CMPLIANCE BY AUTHORIZE NUCIEAR INSPECICRS~~
~~;g and. Brown & Root has consistently failed to initiate corrective action \7 ,~~
respond ports (939, 932)in a timely manner to ANI nonitoring reports and SIS Pe-that identify noncemoliance. This was identified by A.R.M. Tillman during the ANSI N626 Audits. Since that tine,,1ANI's have , initiateql four (4) followup 939's due to lack of rescense. CCliTROL AND CICSURE OF }EN CT.NFORMING REPORTS
I 2ere have been sewiral instances of clesure of tG's by Quality Ccntrol that were not supported by adequate verification of comoleticri cf process crntrol dccuments. Additionally on 8/11/83 NCP. M7599 Pev.0 -
was presented to ANI for closure ccncurrence and was Signed by the ANI. A revisien Iaval 1 exists on this NCR and is still open. Ris is the - fourth instance of inproper closure of outdated NCR's in recent weks. The above has resulted in ANI review of "Hard Copy Documentation" prior to concurring with closure. RECWCIIJATICN OF NCN OWFCRMANCES BY QES GRCXJP . ANI's have been presented ntrnerous hanger packages for FINAL REVIEN that still had coen NCR's against them. These include supports that were generically identified on NCR's without reference to mark numbers. When rejected by ANI's these were subsequently revised. Included were supports that involved baseplates welded to the containment liner with no ANI involvement, supports (snubbers) that attached to ncn confor: ring 3 Fisher Centrol Valve brackets. Additionally, N 5 Data Peports have been signed when inpacted by generic NCR's. Even though these items identified , ,,,. J cn generic NCR's may have been reconciled it is not acceptable to execute
' gu , .' 1
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~~_ D %14~:.vka a l Zs 9~' M bg ra as ti3 p or e e .s & b~~
~~. rage 4 of 5 .~~
l s* Data Ecports in this manner. Prior a ANI acceptance of N-5 Data Peports ALL generic NCR's must be closed. *
~~.d PFESENIATICN CF HANGER PACWc.S TO ANI'S FOR FINAL s REVIN (1)~~
There have been several i;. stances of ANI final review and i acceptance of hanger cackages that were ItCCMPLETE. Sub-sequent to acceptance, Papair Process Sheets and other records have surfaced. In one instance the N-5 Data Peport had been signed. (2) ANI's have rejected hundreds of packages with discrepancies ranging frcm minor to major. These include no material-identification, material unacceptable (impacts en EW hanger), NPSI hardware in ITI hanger and vice versa, QCI walked hanger to wrong revision of VCD. - DPMING CCNIPOL AND DESIG4 CONIPOL (1) Site ANI's have receatedly identified en 939 nenitoring reports ncn ccupliance with drawing control. VCD/DRD revisions are . still heing cbserved in Task Force areas without prcoer sta:m - ing. (Paf. 939 # 361 and 361A). (2) VCD/DRD draaings have nu:mrcus inconsistencies. (a) .
~~- Not all drawings identify existing material (e.g. embed plates).~~
4
~~.T. (b)~~
( 7. Many drawings identify shims as primary support me:rbers. Shims are not within the scope of NF per MS 46A. (c) - Scrae drawings do not reflect other supprts (including (d) Class 5) attached to the structure of *.he support. Scxte Clus 1 drawines identify pri:rary treters (irpacts , (e) material trawability . w.nts) while others do nor. Scma drawings on Large Bore Main Steam and Main Feed identify irpact requirements while other do not. (f) Iarge Bora VCD's reference BRH1's for locaticn but we are toldstatus. revised that BEHL's are not available in centrolled ' (g) Small Bore DRD's are centrolled by GHH drawings but the GHH supports. dces not reflect the revisicn status of tvpical (h) Small Bore drawings with Iarge Bore numbers are not supprted by either GHH or BEHL. (i) Supportsidentified for revision due to Code non confor-irance have not been revised and are still being walked dcun and suhrnitted for final review. Specifically: (1) Supoorts whose baseplates were welded to the cen-tainment liner without ANI involve;mnt were tc be revised to change NF boundary. (2) Supports emnected to Fisher Centrol valves were to. he declassified to non ASME status. (3) Diesel Exhaust Supports were to be declassified to non ASME status. ? . l 1 i
~~" -i.2: a bd.GDiUN:~~
~~t.. : . '!M.E MEE$ , sI.9 neport a .M3~~
~~, , . oace 5 cf 5~~
~~'b,~~
\
g , . STNIUS CF SUPPORTS INSPECIID ADO VE~ ~ IED CN E7.,TIPLE hED DATA CA,TS 1 ANI confidence in inspections performed to Engineering hanger sketches as revised by GC is zero. This is a result of hundreds of non ecnformance reports and inspecticn reports by QCI's identifying on final walkdowns to "As Built" VCD/tPD drawings that the support in-stalled does not match the drawing. 'Ihis ranges frcm minor deviations to instances where configuration is totally different. The causes inherent in the discrepancies are a carbination of inadequate inspections and deficient design documents. The ANI's can no longer accept "inprocess inspections" to unintelligible CF.C's, many of which have undergene as many as fifteen revisiens. Additionally, a CC that totally enanges ccnfiguration of a support cannot be considered acceptable. CDtfrBOL OF TETIS - ANI's have recently been forced to decline to sign pretest Lence-rence due to various problems. These include no provision for adecuate venting or viable alternative flushing and atte:rmt to ccnduct a test with a known hardware discrepancy in the pressure test boun%. ! NA-346.0 CERrIFICATICN CF CCMPLIANCE
~~}'; In accordance with above paragraph the Site Authorized Nuclear Inspectors can no longer sign Data Paports, preliminaly review process~~
centrol dccumentation, review and accept final records, nor perform inprocess inspections until- Brown & Pcot has ingle: rented Corrective Action to resolve the ncn ecmpliances identified in this report. To do so muld constitute acceptance of activities that do not ecmply with the ASMS Code.
~~e G D 4 l V t as~~
~~; ty<~~
~~h&R30t.k1C. INTEROFFI; MEMO TO: M. Coats, LANI DATE: August 24, 1983 FROM: G.R. Purdy, SQAM~~
~~SUBJECT:~~
CPSES, 35-1195 Response To SIS #363. A. Execution of N-5 Data Reports-(1) " ANIS have rejected the majority of submitted N-5's for inaccuracies, omissions, inaccurate hydro press.ure, BRP's unacceptable".
Re'sponse:~ As of 8/19/83, 73 N-5 Code Data Reports have been processed by B&R and the ANI.' Of the 73 however, only 6 N-5's have been issued to signify the completion of construction (including application of the NA-Symbol . Code Stamp); the remaining 67 have been processed to certify completion of of individual isometrics, regardless of the relationship to Owner defined system / subsystems.
~~The total certification scope of Unit 1, Common, and Unit 2~~
. within the Unit 1 S,ecurity Boundry potentially exceeds 1800 isometric certifications, 150 subsystem certifications, and 27 system certifications. As such, B&R and the ANIS have processed less than 4% of the Unit 1 certifications.
Our experie'nce to date has precipitated the following action: * (a) QA Supervision has reemphasized the necessity of completeners and accuracy to personnel ir.volved in the preparation of Code Data Reports (Attachment 1); and (b) A program to reviev and correct iaometries (BRP's), prior to presentation to the ANI for certification, has been implemented from the beginning of the N-5 certification program (3/83). This effort has resulted in submitting to the ANI, drawings which B&R considered adequate definition. The Code requirements imply however, that a system of checks and balances be established between the Certificate Holder and the ANIA to resolve potential oversights. To reinforce the systematic completion of an ASME component, and to assure the proper drawing definition of ASME components when not completely addressed by the Component Design Specification, Senior QA Supervision has been assigned direct area responsibilities as shown on Attachment 2. This program is scheduled to be fully Laplemented by 8/30/83.
~~.e.-r , - - , ,w,, , e ,m. - -,. --, s . , , , , , , , ._ a - -,~~
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~~,,.> $ Ptsd 2 of 14 w ,; _~~
~~9 (2) "The Subsystem-N-5'for SF-1 was' submitted for'ANI signature with an~~
~
open C. A.R.-'in effect against component supports for the Spent Fuel Heat Exchangers". Response: The' root cause of this concern was communications and_the thoroughness'of QA review prior to submitting'the package
~~.to the-ANI for certification. The action described in item' A(1) should preclude recurrence and -addresses the latter.~~
~~Further discussions have indicated our interpretation of the~~
~ Engineering response-to C.A.R. S-55 was incomplete. As a- -result, the following are currently in process: * ' a) - The Engineering organization has reviewed C.A.R. S-55, and has provided QA with a tabulation of design and process control. documents for the identified components;-
~~b) QA will review.the documents for compliance and accept-ability 'to the B&R QA Program by 9/2/83. Any process or document not in compliance with the program will be~~
~~' individually identified on an NCR prior to closure of C.A.R.-S-55; and c) CP-QAP-12.3 will be revised by 9/2/83, co- require the~~
~~[ ,? QE group to verify that any applicable hardware related C.A.R.'s are closed,~ prio'r to processing an N-5 certification. B. Access for Authorized Nuclear Inspectors~~
'" ANIS are censistently b'ing e denied access in the process of performing their duties (Ref. 939 #362A). Three occasions involved witnessing of hydro test. 'On 8/17/83 I was denied access to inspect hardware associated >
vith an N-5 I vas presented. *his is unaccentable and is in noncompliance with NA-5120. Six AN!s have subjected themselws to background checks ' cnd psychological testing to satisfy recuirements for security access. Three other ANIS have initiated paperwork to satisfy these requirements". Response: The subject of ANI access has been discussed within our organi::a-tions on several occasions. In fact, A.R.M. Tilizan has participated in at least 2 of the discussions and R.M. Thompson was present in one of these. We and A.R.M. Tillman have agreed there is a distinct difference between " free access" (NA5120) and " controlled access" (USNRC Security). As also agreed, any ANI access problems should be immediately brought to the attention of myself or my designee in order to arrange access as required by NA-5120 and Section 20.0 of the B&R QA Manual. I was not
-aware of the above access problems until they were brought to my attention via SIS 939 - #362/362A. - To resolve the concern of access however, the following action l n - 'has been taken:
~~a) For those areas of the project under "RWN-Startup ' Access Control'!, the.previously submitted response to SIS 939 -~~
~~'#362A (Attachment 3) should resolve any ANI access problems.~~
=
~~, a. - . . .- ?.Vgn 3 cf 14 .' ~;~~
~~r-i:-~~
. J' I would reemphasize.however, that any access problems l encountered by the ANI' staff, should be brought to the l attention of any personnel shown on Attachment 2. ANI' utilization of this communication link permits us to resolve problems and preclude an accumulation of " frustration
~~factors".~~
b) For the " Fuel' Handling Building", in which total security has been implemented due to the storage of fuel, the Manager, Plant Operations, has provided B&R QA with a limited number l 3 of access badges (Attachment 4). These badges are to be used by ANI/QA personnel in the-verification, cer.tification, and NA-Symbol stamping of the~ remaining Fuel Handling Building Subsystems (3). These badges do'not permit access to fuel storage areas. Due to the sensitivity of fuel storage area sucurity, and the limited scope or remaining QA/ANI activity, ) it is best to limit access. Accordingly, we intend to issue access badges to yourself, Mr. J. Hair, or members of the QA staff directly responsible for building completion. l C. Maintenance Of Quality Documentation And Availability Of Same To The
~~Authorized Nuclear Inspectors (1) "There are numerous instances of. changes being made to process control "~~
y ' records, hanger packages, hydro' test packages, and other documents after final acceptance by the ANI without benefit of concurrence of the ANI. This is not acceptable". Response: B&R QA recognizes that it is unacceptable to change Code related ANI accepted documentation without concurrence et , the ANI. It is a Permanent Plant Record Vault (PPRV) procedure, that changes to Code do,cumentation must be made by B&R QA with ANI concurrence.. If B&R QA identifies Ccde i related documents that- have been changed af ter ANI acceptance, without ANI concurrence, they will be identified on an NCR < and accordingly included in the corrective action program. It is also B&R QA's position however, that it is not necessary to involve B&R QA ner the ANI in corrections to QA documents which are not code related. Additionally, B&R QA does not consider it is necessary to involve the ANI in the addition or deletion of documents from the Owners PPRV, which will
~~'not or have not- been used to document final Code compliance of a component.~~
(2) "On 8/17/83 I observed Arms Indexed hanger packages in Aux. Bldg. Task Force that were retrieved from the Vault without voiding of the cover sheet signed by QES and ANI". Response: When all hanger packages were returned to B&R QA custody in i,*-
early 1983 to implement the VCD/DRD Program, many of the packages had been Arms Indexed. Additionally, with the i '" Full Package Concept" discussed in item H, packages may
~~'be removed from the PPRV to accomplish nca-Code related activities.~~
f
v- :- ,
~ , . , , .Prga 4 of 14-To_ insure proper routing o'f hanger packages, when review is_ required, QA in the Task Groups will void the cover sheet previously signed by QES and ANI prior to resubmitting the package for ANI review. -(3) " Hartford Steam Boiler agreed that when ANI review of documentation was-necessary for those records on file in the PPR Vault the ANI .would do that review in the Vault. ' a)~ On 8/17/83. Inspector Harper requested a hanger package for review to reconcile an attaching hanger. He was denied by vault personnel.
~~b) ANI's consistently lack space in the vault-area to review records~~
~~'and complete checklists. On 8/17/83 Inspector Hair and myself had ~~~
to stand and attempt to review records associated with an N-5 submitted for ANI signature". Response: As discussed in the response to item H, B&R QA will issue an isometric N-5 schedule by 9/6/33. Additionally, B&R will implement the coordinated N-5 effort (i.e., support, pipe, and equipment) by 8/30/83. It is one of the objectives of this program, to establish an isometric status baseline acceptable to B&R and the ANI. By agreement with the PPRV, this review will be done on an isometric basis, with all necessary documents being made available in the CDR review area. It is requested that ANI Checklists be prepared at this time, in sufficient detail, to preclude multiple document retrieval cycles from the PPRV. D. Follow-up & Verification Of Acceptable Resolution Of Corrective Action Requests (1) "A.R.M. Tillman, acccmpanied by myself, identified during his semi-annual ANSI'N626 Audit of July 13 and 14 deficiencies in issue, ravision, anJ follow-up of C.A.R.'s S-54, S-55 and S-56. Additienally 939's 261 and 351A requested prompt resolution to C.A.R. 5-54. The status of these C.A.R.'s has not changed as of 8/17/83". Response: As discussed during the referenced ANSI N626 Audit, the ANI concerns relative to issue, revision, and follow-up of C.A.R.'s were'to be addressed by changes to the B&R QA Manual and CPSES QA Procedures. Concurrence with our proposed resolution to the above concerns was obtained when A.R.M. Tillman' approved the QA Manual changes on August 3, 1983. Additionally, the implementing Revision '5 to CP-QAP-17.1, Corrective Action Requests, was issued August 3, 1983.
~~.With respect to the specifically identified C.A.R.'s:~~
a) S-54: The original response was rejected by QA following discussions between B&R QA and the ANIA (Attachment 5). Due to the magnitude of the proposed mod-ifications to the Document Control program, the
~~" action addressee" requested a response extension - (Attachment 6) and, the response to the C. A.R.~~
was approved 8/19/83 (Attachment 7); *
/* 4 .- Pcg3 5 cf 141 b) S-55: This C.A.R. has been previously addressed in my response to item A(2); and c) S-56: As previously discussed during the referended ANSI N626 Audit, this C.A.R. was " Voided" and never issued.
To provide a more timely response to ANI concerns-(SIS 932 or SIS 939 R~eports), a new " Tickle System" has been implemented by the QE Group Supervisor, which will require response action 3 days prior to the requested response date. (2) "C.A.R. S-55 addressed lack of Program Control of component supports identified'outside the scope of Mechanical Design Drawings and Specifi-
~~. cations (i.e., Civil). One addressed result was that ASME NF seismic supports for Spent Fuel Heat Exchangers had not been installed.~~
Engineering responded that it could not accept responsibility for lack of identification of required installation work. Additionally Engineer-ing stated that MS 46A.(Pipe Supports) was not applicable to this scope of work and stated the " Design Drawing',' was in the form of sketches to . a DCA.' (a) If MS 46A is not applicable, what is the appropriate design specification? (b) Installation to sketches outside the scope of Brown & Raot's QA Program is not permitte (c) Subsequent installation of these supports did not have ANI involvement. They are not acceptable for Code Certification". Response: This C.A.R. has been previously addressed in my response to itcu A(2). E. Resparse To Identified Programmatic (ASNE) Noncompliance By Authorized Nuclear Inspectors
" Brown & Root, has consistently failed to initiate corrective action and respond in a timely manner to ANI monitoring re, ports and SIS Reports (939, 932) that identify noncompliance. This was identified by A.R.M. Tillman during the ANSI N626 Audits. Since that time, ANI's have initiated four (4) follow-up 939's'due to lack of response".
Response: A review of ANI initiated SIS-Reports (932's/939's) clearly shows that B&R has not failed to initiate corrective action when required. As indicated in the 7/13-14 ANSI N626 Audit Report (Attachment 8) however, B&R has not always been timely in responding to the reports to indicate what corrective action was being taken. The concerns expressed by A.R.M. Tillman during the 7/13-14 ANSI N626 Audit were addressed as indicated in our response, Attachment 9, prior to receiving his Audit Report on or about the 12th of August 1983. Currently, there are 6 SIS 939's which have not been closed:
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~~, IPtgE61of?14i l.~~
~~a [n .= i t v i Y w _~~
- e a).'385A.- B&R response requested by 8/24. ' b),. 359AT- Transmitted by.B&R forfANI' closure 8/17 c) 360A - B&R response requested by 9/10' 1 - d) _ 361A - Transmitted by B&R for ANI-closure 8/17 e)- 362A - Transmitted by.B&R for ANI closure 8/18 f) 363A'- B&R response 1 requested by 8/25 (this SIS)- - Our reco,rds also' indicate there are six (6) 932 SIS Reports that require response. = In order to provide a more timely response to inquires written on 932 forms, it would-aid B&R QA if specific - concerns were identified rather than generic observations.
To assure a more ' timely. response however, th'e1" Tickle System" addressed,in my response to item D(1) will provide more effective tracking of SIS Report closure, .or will permit a more expeditious request for extensions ta ANI' requested response dates. F. -Control And Closure-Of Nonconforming Reports' "There have been several-instances of closure of NCR's by Quality Control that were not supported by adequate verification of completion of process ; control documents. Additionally on 8/11/83 NCR M7599, Rev. O was presented ' to ANI for closure concurrence and was signed by the ANI. A revision Level 1 exists on this NCR and is'still'open. This is the fourth instance of improper cicsure of outdated NCR's in recent weeks. The above has resalted , in ANI review of "Hard Copy Documentation" prior to concurring with closure". Response: In a conversation during a.arly July 1983, we agreed that an excepticnally large numbers of NCR's were being generated against ' deficiencies that ceuld be corrected. as inprecess repairs in i accordance with the S/20/83 revision to the E&R QA Manual. The ! major ramifications of controlling inprocess deficiencies as - t
*ICR's were massive logistics and tracking problems. i To preclude these problems, B&R submitted a proposed change to-the
~~B&R QA Manual to clarify inprocess repairs. The proposed change was approved by the ANIA and issued on 8/3/83,:along with the~~
; necessary revision to the implementing procedure, CP-QAP-11.1. l Additionally, the following action is inprogress:
, a) The QE Group is auditing NCR status to: identify resolve, , properly status, or submit for closure all open NCR's with an es'timated completion date of 9/16/83; ' b) NCR'statusing will be directly provided by area groups
~~. commencing-9/16/83; and c) The implementation of the " Full' Package Concept" on 8/1/83, further discussed in my response to item H(1), should preclude recurrence of the above concern. .) -~~
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l G. Reconciliation Of Nonconformances By QE's Group "ANI's have been presented numerous hanger packages for FINAL REVIEW that ". 1still had open NCR's against them. .These include supports'that were generically < identified on NCR's without reference to mark numbers. -When rejected by ANI's these were subsequently. revised. . Included were supports that involved
~~' baseplates welded to the containment liner with no ANI involvement, supports (snubbers) that attached to nonconforming Fisher Control Valve ~ brackets.~~
~~!- Additionally, N-5 Data. Reports have been signed when impacted by generic-NCR's. Even though these items identified on generic NCR's may have been~~
~~. reconciled it is not acceptable to execute Data Reports in this manner. ~~~
l Prior to ANI acceptance of N-5 Data Reports all' generic NCR's must be closed". Response: With the exception of generic NCR's,~ all other items are repeated and addressed in response to items H and-I. Eight generic or multiple item ASME NCR's are still open at CPSES. The status and action on these-NCR's is as follows: , NCR # Component Status / Action 2690 Hanger Packages not reviewed by 'QE evaluating, but currently required ANI to stay open until end of job by ANI.
~~q ,~~
2807 " Unit #1 PDRF's QE to verify action complete and , submit for closure by 9/2/83. 3058 ' Unit #2 PDRF's i QE to revise CP-QAP-16.1 as required, and breakdown to isometic boundries by 9/30/83. j 3597 Redundant PDRF identification QE to clear and submit for closure by ' 9/2/83. 3134 Mechanical OT's without ANI review QE to complete rescarch 2nd disposician ' acticn. and submic for closure by - 8/26/83. s , 5647 AF/CC repairs Nonconforming welds identified on these thru NCR's will be reidentified on specific 5649 NCR's by 9/2/83. , H. Presentation Of Hanaer Packages To ANI's For Final Review (1) "There have been several. instances of ANI final review and acceptance of hanger-packages that were INCOMPLETE. Subsequent to acceptance, Repair Process Sheets and other records have surfaced. In one instance the N-5 Data Report had been signed". Response: As you are aware, the program for the design, fabrication , and' installation of Safety Class 1, 2, and 3 pipe supports ' e has evolved into one of the most detailed and scrutenized programs of any nuclear site. The changes in support criteria invoked through ASME Section III Subsection NF, i and the expanded Regulatory Requirements invoked by IE j
~~' Bulletin 79-14, has resulted in an extensive quantity of '~~
design change paper, process control documents and quality documents.
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~~.:PcsY 8 cf 14) -~~
9 l l k g, e e s In.the latter part of 1982, the Project recognized that the finalization of pipe support design, fabi-ication and install-ation had to be oriented to the VCD/DRD program. During the 1 first. half of 1983 chis program was implemented for each support as the initial VCD/DRD was issued by Engineering. '
.O However,.due to the expanded requirements resulting from the' topics discussed above many additional deficiencies were identified resulting in numerous process control documents.~
~~As'a result of ANI, B&R, and scheduled completions concerns, Project General Management has elected to implement an alternative management technique. On 7/20/83, charter was~~
~~.given (Attachment 10)'to establish a concentrated. effort to complete pipe support installation and inspection by an~~
~~, integrated approach using the same procedures. The~~
~~' involvement of.B&R QA, outlining interface ~ functions and objectives, was issued 7/28/83 (Attachment 11) to personnel directly involved in'the effort.~~
4 During program developement, we have attempted to keep the ANI abreast of actions and administrative decisions. As late as the week of August 15, 1983, the " Full Phekage Concept" was discussed with tha ANI, with the concurrent :
~~-unders'canding the process would be instrumental in~~
~~clir.inat.ing 'some concetus.~~
~~c-Although historical packages are not totally commensurate~~
~~with the current guidslines for format, these packages do in fact refJect "as-constru-ted" cond'tions and considering ;~~
~~the referenced attachments - address ANI concern relative to~~
~~. psckage completeness.~~
~~i l- -~~
~
~~Prior to 'this ANI SIS i-eport, Engineering Management and i B&R QA have pursued resolutions to concerns of revising items~~
.already in the process of certification. Attachment 12 ' # outlines .the program intended 'to preclude these issues. In addition, documented notice will be provided to the ANI of '
~~F all packages withdrawn from the PPRV. Such notice will s enable the ANI to be advised of " voiding" instances and~~
' l , monitor the " Full Package Concept" program. '
~~C , (2) ANI'h have rejected hundreds ~ of packages with discrepancies ranging~~
'l ' - ' , #, from minor to major. These include no material identification, l - material unacceptable (impacts on W hanger) NPSI hardware in ITT 7 hanger and vice versa, QCI walked hanger to wrong revision of VCD.
~~Y' R, , ^ , 7~~
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Response: With the implementation of the Hanger Task Groups, package review by QES is taking place directly in the area.- This review is conducted in accordance with procedure CP-QAP-18.2, and documented on a checklist, Attachment l3, developed and issued by QE. To establish a consistent package format, and resolve previously identified ANI problems, IM# 25,879 1 (Attachment 14) was issued 7/18/83, with your concurrence. ; We have conducted a statistical study of the last 660 packagds submitted by QES, from the Task Groups, for ANI acceptance- Of the 660 packages, 59 have been returned from the ANI (8.6%) for the following reasons: 8 Questions not problems 8 Missing load sheets & CPP's 2 '588 material ' 1 Need CNER's for Class I and impact items ' 3 Open QC Hold Points ' 4 Missing documentation 1 Material verified on MIL - not matching VCD - drafting 5 WDC in wrong side of package 2 VCD - Drafting errors 1 Material not verified 1 Need new VCD - Dwg unclear 1 incorrect Weld # for vcid attachment , 7 VT procedure @ and Rev. net on RPS 1 Incorrect Attachment 1 ' 10 Shims verified but no WFML 4 Existing steel Dwgs . Although B&R's goal is to provide a 99% ecceptance race, i it is felt that the problem is primarily documentation , I and not hardware related. To further minimize packages l rejected due to documentatien however, Document Reviewers ' will be retrained in the checklist requirements by 8/29/83. I. Drawina Control And Design Control (1) " Site ANIts have repeatedly identified on 939 monitoring reports i noncompliance with drawing control. VCD/DRD revisions are still u.ing ' observed in Task Tcree areas without proper stamping. (Ref. 939 #361 and 361A)". t Responses. The corrective action taken in response to C.A.R. S-54, was intended to resolve this problem and preclude further ' recurrence. It must be pointed out however, that when the l C.A.R. S-54 corrective action was implemented, literally I thousands of drawings were involved. It is not surprising that isolated instances occur in which hanger packages are
,. found which contain drawings issued under the previous i ,.n..e,....- - - - , ,-
~~z.c~~
~~?? - -~~
~~jPtss10of142 program, which had been in use and acceptable for years. In fact, we have been anticipating more drawings from the~~
~
~~previous program since the changes in the Document Control program were implemented in parallel to the new Task Groups-implementation, causing massive changes in logistics.~~
~~. Drawings issued under previous Document Control programs will be purged prior to submitting final. hanger packages for'ANI. acceptance, as this item is specifically identified~~
~~in step 3.C of Attachment 14. Attachment 15 has been dis-tributed to the. appropriate Task Group personnel, to preview hanger packages prior to distribution by the Package Flow Control Group.~~
~~'(2)- "VCD/DRD Drawings'Have Numerous' Inconsistencies".~~
(a) 'Not all drawings identify existing material '(e.g. , embed plates)". Response: A DCA has been issued to Specification, MS-100, to reflect that all embed material is A-36 unless.noted otherwise on the drawing .by DCA 18475. Engineering will review all drawings where embed material is not A-36 to insure the drawing reflects material 6 type and' grade; applicable drawings which do not reflect this will be revised prior to submission to the ANI. , (b) "Many drawings identify shims as primary support members. Shims are not within the scope of NF per MS 46A". Response: As the Component Design Specification is the controlling document established by Code, B&R does not consider it necessary to backfit all previously issued drawings which identify shims. As drawings are revised, or new designs issued, Engineering will remove shims which are identified as primary support members, unless they are primary support members.
~~, 1(c) . "Some drawings do not reflect other supports (including Class 5) attached to the structure of the support".~~
Response: By Engineering Procedure; anything attached,to a safety class pipe support frame must be authorized by design change to permit reanalysis of loads. Supports which have items attached to their frame, that I are not identified on the VCD/DRD have been and will continue to be identified as deficiencies by QA in
~~.accordance with procedure CP-QAP-ll.l.~~
i
~~~~ .- ?.< Prgp 11 of 14 m ~(d) "Some Class-1 drawing's identify primary members (impacts material traceability requirements) while.others do not".~~
~~Response: ;As previously discussed, early NPSI designs' differentiate between primary and secondary members. The remaining CPSES designs do not take credit for the increased~~
~~- allowables of secondary members.~~
Accordingly, although beyond Code requirements, material certifications for designs other than NPSI will continue to be submitted as. primary members. (e). "Some drawings on Large Bore Main Steam and Main Feed identify impact requirements while~other do not". Response: Engineering is reviewing all affected drawings to identify designs which require revision to indicate impact test requirements. Additionally, the review will identify which supports contain material accepted by " Appendix G" calculations in lieu of' impact, tests. Affected drawings have been reviewed, and will be rev1 sed if required prior to submission to the ANI. (f) Large Bore VCD's reference BRHL's for location but we are told that BRHL's are not available in controlled revised status. Response: Much like a " Piping Composite Drawing, which is referenced on a BRP (isometric), the BRHL is referenced on the BRH drawing at the time of final VCD. The piping composite and BRHL drawings are for Engineering use only. The BRHL is used to reflect support location which is not required during fabrication and installation since support location is shown on the BRH until the VCD revision is issued. (g) "Small Bore DRD's are controlled by GHH drawings but the GHH does not reflect the revision status of typical supports". Response: Small Bore typical drawings are issued by Engineering for incorporation into Hanger Packages by Welding Engineering. Engineering practice has been: (1) Not to revise a typical in a way which would physically impact previous revisions to the typical; (2) To issue as a "Special" any single typical which requires a configuration change or different installation criteria; (3) To issue as a new typical, any revision to a previous typical which generically requires changes to support configuration or installation criteria; and l l
~~., ii jPrgi12of'14i -~~
~~V+ f~~
~~'(4) [To-notify the ' constructor of any Small Bore Support that has been made unacceptable by revision to a typical.~~
Based on the above, the' appropriate typical revision for a Small Bore Support package is the " Controlled Copy" of the typical:placed in'the Hanger Package by Welding Engineering,-as currently issuad'by Engineering. Although generally practiced, Engineering has incorp-orated the above practices into'MS-46A by DCA 18,453 Revision l~.
" Additionally, QA, Procedure CP-QAP-12.1 requires the revision level of both the typical and location GHH -drawings to be recorded on the VCD/DRD Inspection Checklist. QES will continue to verify the recording of this data, during document review, in accordance with item 1.A. of Attachment 14. ~
~~(h) "Small Bore drawings.with Large Bore numbers are not supported by eith'er GHH or BRHL".~~
~~,, Respdnse: GHH and BRHL drawings are hanger location-drawings only.~~
Small Bore drawings with Large Bore numbers are Class 1 supports. The-support location-is shown directly on the drawing. , (i) " Supports identified for revision due to Code nonconformance have not been revised and are still being walked down and submitted for final review. Specifically: (1) Supports whose baseplates were welded to the containment liner without ANI involvement were to be revised to change-NF boundary. (2) Supports connected to Fisher Control valves were to be declassified to non-ASME status.
~
~~(3) Diesel Exhaust Supports were to be declassified to non-ASME~~
, status". . Response: Items (i)(1) and (1)(2) were reported on NCR's prior to this SIS. Engineering is completing the required drawing revisions, which will be accomplished prior to certification processing. l Item (i)(3) had been addressed prior to this SIS
~~_ by Engineering, Attachment 16.~~
. -Component' Design Specification MS-46A has been revised by DCA 18511, to reflect that the Diesel Exhaust supports are ANS Class III, and are not subject to the Code certification process.
~~1 1~~
~~..,:.,._, -.m -- , , - . , . - , , , , - ......-._v..~,. r,... a -. ,~,.mm..,- , , , .. , . . . . - . . ~ , . . . , , , , , , . . . . .-4,-.~..m---- . _ _ . , , - - ~..~~
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, - ,- 20 i Pcgn'13 of.14-1 \ ,x-C 'J. -Status'Of Supports Inspected And Verified On Multiple Weld Data Cards "ANI confidence in inspections performed to Engineering. hanger sketches as -revised by CMC is zero. This is a result of hundreds of nonconformance reports and inspection reports by QCI's identifying on final walkdowns to "As Built" VCD/DRD drawings that the-support installed does not match the drawing. This ranges from minor deviations to instances where configuration is totally different..
The causes inherent in the discrepancies are a combination of inadequate inspections and deficient design documents. The ANI's can no longer accept "inprocess inspections" to unintelligible CMC's, many of which have-
, undergone as many as fifteen revisions. Additionally, a CMC that totally changes configuration of a support cannot be considered acceptable". ' , Response: The historical aspects of the CPSES pipe support program are a reality, and must be dealt with by the best means available to assure Code and Regulatory compliance. Recognizing that the historical trail would often be confusing and cumbersome, the VCD/DRD program was implemented to:
(1) Identify the "as-constructed" condition; (2). Insure the "as-constructed" condition was properly defined-through the Component Design Specification and detailed drawings;~ (3) Assure the reconciliaticn of the "as-constructed" condition with design' stress and as-built loads; and (4) Correlate a documentation package which properly supports the design, fabrication, and installation of the "as-constructed" support. Unfortunately, many of the supports dealt with today are 1979 and 1980 vintage design, fabrication and installation. On those packages which are abnormally cumbersome, QES Document Review has been directed to implement a detailed index of documentation references to aid in ANI review of the package. K. - Control Of Tests "ANI's have recently been forced to decline to sign pretest concurrence i
~~.due to various problems. These include no provision for adequate venting or viable alternative flushing and attempt to conduct a test with a known hardware discrepancy in the pressure test boundary".~~
~~Response: QA Procedure CP-QAP-12.2 will be revised by 9/2/83 to more~~
specifically address QA and Construction responsibilities, in l accomplishing' prerequisites to hydrostatic testing, prior to i Ls submitting pretest packages for ANI concurrence or requesting
l ANI support to witness hydrostatic tests. It should be noted l l however, that the referenced hardware discrepancy (are strike) although within a portion of the system to see test pressure I
~
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n . .g ~ T ,t ".Pe gil4 'of 14 . pr during the retest, was not part of the boundary for which the test was being conducted. Although not the most efficient practice,
. the worst case condition could only precipitate in subjecting the same portion of the system, with a different area of interest, to an additional retest cycle. ;
l
~~L. NA-3460 Certification of Compliance i~~
"In accordance with above paragraph the Site Authorized Nuclear Inspectors can no longer sign Data Reports, preliminary review process control-documenta-tion, review and accept final records, nor perform inprocess inspections until Brown & Root has implemented Corrective Action to resolve the Noncompliances iiintified in this report.' To do so would constitute acceptance of activities thit do not comply with the ASME Code".
~~Response: Clearly recognizing the ANI responsibility and authority to ~ monitor and verify the NA Certificate holders compliance to the~~
~~. Code, and the approved QA Program, neither B&R QA nor Project Management totally concur with the text or implications of SIS 363.~~
~~Accordingly, B&R,'Inc., as the NA Certificate holder, intends to take the following action: {'~~
~~1. B&R will continue to perform Safety Class 1, 2, and 3 activities which by the Code and contracturally-the ANI is expected to continue monitoring as required. Should~~
-noncompliances-with the Code an/or QA Program be identified, we expect the ANI to specifically report these unsatisfactory conditions as required by the Code, the approved QA Program and ANI contract; .
~~2. Upon reaching an ANI hold point on process control documents, the ANI is expected to accept or reject the activity based upon compliance with the Code and approved QA Program.~~
~~Should the activity be rejected, the ANI is expected to specifically identify the noncompliance; and~~
~~3. B&R will continue to transmit to the ANI, documentation packages for final and inprocess review; the ANI is expected to accept or specifically reject these packages.~~
G.R. Purdy (/ GRP/ba B&R Site QA Manager cc: J.T. Merritt R.G. Tolson D.C. Frankum B.J. Murray F. Burgess R. Taylor J. Finneran G. Bunt Houston - R.J. Vurpillat, B&R J. Ryan J.T. Blixt W.D. Tillman, Hartford J. Dittmar R. Siever B. Baker SQAM File J. Johnson i
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~~4Bi6Wk,rRoot.inc. INTEROFFIC." 35D:0 JIMJ 26,055~~
~~'g LTO: 'U.C.-Smith DATE: August 18, 1983 FROM: ~C.R.-Purdy -~~
~~SUBJECT:~~
CPSES, 35-1195 QA/ANI Access To Areas In Which Code Related. Work Is Being Con' ducted. LThis memo is issued to confirm our previous discussions on the above subject. In accordance with Section 20.0 of the B&R QA Manual, and Subsection NA paragraph NA-5120 of the .*.SME B&PV Code, the ANI/ ANIS must have free access.co all areas of the site during the period of assembly and testing.
~~~ By Code terminology, this means that the ANI/ ANIS must be permitted f ree cecess to areas until construction (i.e., N-5 Certification and Sta= ping) is complete.~~
By our mutual agreement, it is not the intent or requirement of the "RWN" access control program to restrict the freedom of access for QA/ANI/ ANIS inspection personnel to perform' inspection or cerification activities. However, due to incorrect interpretation of the program, several access problems have recently been encountered as outlined on the attached ANI SIS Report. To preclude recurrence of this probics, '(dh 4 it is requested that copies of this memo be distributed to personnel responsible for implementation of the "RNM" access control program. TJmN G.R. Purdy [ Site QA Manager \ GRP/bm * . cc: B.J. Murray .
~~. D. Deviney ;, R.C. Tolson -W- '~~
~~H. Coats i . A b~~
~~. 4 9~~
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~~NJ . INTEROFF;CE MEMO~~
~~'IM#25,747_~~
~~DATE: June 15, 1983~~
TO

-
~~Frank Strand /BillLBaker lFROM: G.R. Purdy~~
~~SUBJECT:~~
~~CPSES, 35-1195 Unsatisfactory Response~~
~~-To CAR S-54. ~~~
_ As required by. the Brown & Root, Inc. Quality Assurance Manual, Section = -17.3 and 'TUCCO QA Audit Response Evaluation (dated 6/9/83),'CPSES _ Construction Document Control, QA Audit File: TCP-68 (OTN-714) Concern - No.2, "This office recognizes the fact that. in accordance with established - procedures activities affai: ting quality cannot be accomplished without controlled documents stamped with the validating desiana. tion. However, had existing procedures been adequately implemented and followed, the { document in question could not have ev.isted. 'TUGC0 QA recommends that
~~' an additional refresher course be ac' ministered to those personnel whose job activities include the distribution or duplication of controlled documents".~~
f. V Also, as required by Section 17.3 of the QAM, the corrective actions ! implemented to date are unsatisfactory and must be supplemented as recommended by TUCCO QA to include all personnel who distribute or duplicate controlled documents with a copy of the sign-in sheets for closure of CAR S-54, TUCCO DA Audit File: TCP-68 Open Concern No. 2 and Hartford SIS 939 No. 350. , p Should you have any questions or comments concerning this CAR, please contact Rusty Morris at extensiong207 or 743.
*'.; \
V d. O G3 . Purdy 0 8 Site QA Manager ' CRP/bm ' cc: D.N.Cha'pmbn,'TUCCoOA- '
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C, BrtNEf5 Root.inc.'- A l INTEROFFICE MEMO IM - 25974 August 4, ISd3 TO: Gordon Purdy FROM: W.E. Baker
~~SUBJECT:~~
CAR-54 Response Extensive changes in the document program are , currently being made including the. revision of the document control procedure DCP-3 which has been issued - for coment and approval. I am requesting a 10 day extension on the response to CAR-54 pending the approval of the referencid procedure. Y/2 J,l 4 W.E. Baker Sr. Project Welding Engineer WEB /tn , i l l r ,. . h
~~. - - _ ,__ _ - _ - . .~_----. _- . - _ , . . . , . _ . . _ _ _ _ - - _ . - _ - .~~
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~~"~ Brown &R: atJnc.~~
~~QUAUTY ASSURANC:. OEPARTMENT CORRECTIVE ACTION REQUEST CPSES te~~
~~' %CJECT:~~
e gog no 35 1195 1&2 UNIT: PAGE 1 CC 1 KECUEST No S-54 Rev. 2 Group caGANIZATloN B&R QA 6-14-83 RE*LY out oATE REFERENCE occuMENT: CP-DCP-3 Rev. 15 CONomoN DE5cniptioN: , Paragraph 3.1.2 Controlled copy Stamp Riproduced " Controlled" copies will be identified with the " Controlled Copy Stamp" tnd the control number entered in the shaded area of the stamp. , Contrary to this requirement, the following VCD's (current revision levels) issued . to control number 098 do not carry any stamping nor do they have a control number: (1) DO-1-DG-030-001-3 ,{ (2) DO-1-DC-030-005-3 i (3) DO-1-DC-030-007-3 - (4) DO-1-DG-030-009-3 (5) DO-1-DG-030-006-3 i (6) DO-1-DG-030-010-3 * (7) DO-1-DG-030-011-3 R';,v. 1 : R;v. 2: To identify additional Action Addressee. ! To incorporate corrective DCC's and Engineering's revised responses with proposed action. Epty DEcutsTEo snou _ Frank Strand / B. Baker ACrioN AooRESSEE iNmAfto av - 11 M' PAOJE'd Q A \t.4:1. gen G a rg 4 3 CAUSE ANo ConnECitvE ACTRON: Vi The investigation of this subject revealed that the uncontro
, - l issued to the hanger packages by Engineering and not by the DCC. However, reoccurrence of this type of contr'ol problem has been eliminated with the estab- !-
lishment of satellite DCC's. ,' trained in Revision 16 of Procedure DCP-3. Personnel operating the satellite DCC have been , P.S. 3 Engineering has notified and retrained its personnel (per CPP-12,322) that whenever any copy of a drawing off the originals that exist in the PSE. files, that copy is stamped by Cindy Moore's group.
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~~/ NAME AUTHOR 12Eo BY A M U~~
~~NAME' OATE CO2HECTivE ACriON VEAlt E0 By cA REVIEW ClosupE av _ oATE I~~
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~~9 HaAment 8 Houston Office !!104 West Airpe ~ d. Suite 200 The Hartford Stafford Texas 7~ '~~
~
~~Stearn Boiler Inspection (713) 530-9883 and Insurance Co. August 8, 1983~~
^
~~Mr. Gordon Purdy Site Quality Assurance Manager~~
~~Brown & Root, Inc.~~
~~P. O. Box 1001 Glen Rose, Texas 76043~~
~~Dear Mr. Purdy:~~
This vill confirm that an Audit was performed on your activities at the Co=anche Peak Steam Electric Station en July 13 and 14,1983. This Audit was performed to meet the requirece,nts of ANSI-N626.0 and the ASME Code.
. During the program was Audit, made. a review of varioua phases of your Quality Assurance required. Overall, I feel you are implementing your program as The or clarification: following items, however, vere noted and require correction .
~~A. Non-Confor=ance Reoorts (~~
l. NCR #M6988S-Revision 1

a. This NCR allows acceptance of a veld size smaller than that shown on the Vendor Certified Drawing. The veld shown on the VCD in 1/4 of an inch. The actual veld sise is 1/8 of an inch. Quality Control verified that 3/16 of an inch is the maximum possible veld size en three sides due to flange configuration. On the re=ain-ing side,1/k inch 1:s possible.

b. The resolution to this NCR is " use-as-is." In addit-ion, the NCR states " Design analysis safety factors are implemented ecces." to account for these dimensional differ-

c. The resolution does not require a revision to the VCD to indicate the " as-built" condition.
~~In ntf opinion, paragraph k.4 and 16.3.1 of the QA Manual require revision to design documents anytime the " ac-built" condition changes.~~
~~^ .~~
2. NCR #MT882S

a. This NCR referrences a drawing in which piece #1 en the drawing is 1 inch too long. the tolerance referrenced on the NCR is 1/4 inch.

b. The resolution states " Use -as -is."
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, M 2 M[;QQf:)yj)fQ ffQM $1 Houston Office !!104 West Airpr cd., Suite 200
~~_ The Hartford Stafford, Texas T . '~~
~~, Steam Boder Inspection (713) $30 9883 and Insurance Co.~~
~~1886 - August 8, 1983 Mr. G. Purdy Page 2~~
~~c. Again, there vas no leans to facilitate the revision of design documents in order to shov the " as-built" con-dition. .~~
As we discussed, the tolerance referenced on the NCR may have been incor-rect. If so, this NCR should not have baen generated. If however, the NCR is valid, steps must be taken to revise appropriate design documents. In a discussion with the Site ANI's it was determined that this is not an uncommon problem. A majority of the NCRs' of this nature that I reviewed vere resolved correctly. While the number of proble=s of this nature is being reduced, I vill recommend that you keep stressing to review people that " as-built" conditions must be addressed and specifications or draw ! ings must be revised in cases of this nature. B. Corrective Action Reports *
~~1. CAR-S-56-Revision 1~~
~~(' -~~
a. Neither the original nor Rev.1 vere signed by the Site Quality Assurance Manager. '

b. Revision 1 of this CAR vas voided.
~~While it is agreed that revisions to documents~~
a e covered in the Document Control section of the manual, this document is a special one. There is a description of both revisions and methods for voiding NCRs' and in ::7 opin-ion, there should be a similar method described for CARS'. According to QE personnel, they revised and/or voided CARS' as they thought best.
2. CAR-S-55-Revision 1

a. The same comment applies to S-55 concerning revisions and methods' of voiding as were made for S-56.

b. The due date for reply for Revision 1 was 6-15-83, how-ever, the Site Quality Assurance Manager did not si6n Revision 1 until 7-6-83. In my opinion, the due date 1 l
~~should have been revised as well as the CAR. {~~
~~c. If the due date of 6-15-83 is valid, Mr. Doug Frankum is 28 days overdue for a response. QA is well overdue for their required follov-up of 10 days after the reply due t ,~~
date has been established. e NNO k!$ e %I
P-
..' . j - 11ouston Offic7 11:04 Te9 AitTx>rt IMvd. Suite 200 *A The llattford Stafford. Tem 77477 ' 1 ~
Scearn Ben!ct inspection pl3) 5303.v 4 i 2nd Ituurance Co. ' ( . August 8, 1983 Mr. Gordon Purdy Page 3 - It is suggested a review of this CAR be performed and clarification or correction be made. C. ANI Monitoring
1. 'Ihe following monitoring forms must be answered or a re-quest for extensien be made.

a. Form #3h7 should have been answered by 5-5-83 There was no response as of 7-14-83, nor was there a request for extension.

b. Form #350 should have been answered by 6-1-83 An ex-tension was requested and granted to 6-10-83 There vas '
~~no response as of 7-14-83 and no additional request for extension.~~
~~c. Form #351 should have been ansvered by 5-31-83. There vas ion. no response as of 7-14-83 and no request for extens-~~
~~{..~~
~~d. Form #352 was to have been answered by 6-10-83. There was ion. no response as of 7-14-83 and no request for extens-Please respond extensian to thesedate.~~
~~on the response forms as acon as possible or provide a request for~~
~~, . .j . D. Instructions. Procedures ar.d Dravings~~
1. In a review of a document called Quality Control Work Instruction, the following items were noted:

a. The QA Manual requires Quality Control Instructions be placed in manual form with a table of contents. In a review of these documents with the task force, no man,ualinwas thefound.
~~auxiliary building In addition, Quality Control Instructions cust be approved by the QA Manager. No such approval vac found,~~
~~b. These documents vere not shown on the Controlled Copy Holders Listing.~~
h s; b.'h N $$ 9 + di
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--c=>- . . Houston Offic? ' 11104 West Airport Blvd., Suite 200 The Hartford Stafford. Teus 77477 gg Steam Boder Inspection (713) 530 9ti s and Insurance Co.
~~1806 a . August 6, 1983 Mr. Gordon Purdy Page 4~~
~~c. No Transmittals could be found for issuance of these documents.~~
In my opinion, these documents should be controlled in accordance with Section 6 of your manual. To me, a document that is incorporated into a Quality Assurance Procedure at a later date, is important enough to fall unde.r the title of instructions and as such, naast be controlled in an appropriate manner. In a discussion with Mr. Ted Blixt, it appears that these. documents are similar to DCNs'. If so they should be handled in a similar manner. If not, it is suggested that a description of these docu-ments be provided in the QA Manual. Please correct or clarify these items to the satisfaction of Lead ANI Marvin Coats. He is bein6 notified of these items by cojry of this letter. Your courtesy and assistance at the time of this Audit was greatly appreci-ated. Please thank all personnel involved. .f-( Should you have any questions or if I can be of further assistance, please not hesitate to call. Yours truly, -
* / / 4ev(
~~William D. Til n~~
~~/A Assistant Regional Manager SIS Division, Houston '07 .: p- . .. VDT/ad ~~~
~~Icc: Lead ANI Marvin Coats~~
~~4 h !~~
!H $ 99 4 8 .' 9 8 lE _... , yy <W F9 * %'Y *AI55 W- ' #~ ' - ' " " ' * * * ~ ~ ' ' " '
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~~INTEROFF' .. MEMO 'b ' IM# 26,056 DATE: August 18, 1983 TO: Marvin Coats, ANI TROM: J.T. Blixt~~
~~SUBJECT:~~
~~CPSES, 35-1195 Hartford CPSES Audit Of July 13, & 14, 1983. Af ter reviewing Mr. W.D. TillEan's letter of August 8,1983, Brown & Root, Inc. has the following responses: Response A~~
1. NCR #M6988S-Revision 1 is dispositioned to rework the under-size weld and to revise the VCD.

7. NCR #M7882S is dispositioned to rework / remove the excess length of piece #1.
~~Resoonse.B~~
~~1. CAR-S-56-Revision 1 was never issued as the lack of the Site QA Manager's signature would indicate. This Revision 1 was voided as verbally explained to the ANIS.~~
2. The due date of 6/15/83 for Revision 1 was a typing error. It should have been 7/15/83. The follow-up of 10 days, per QAM Section 17.3 and CP-QAP-17.1, paragraph 3.2.5, is for investigation / verification to ensure that the required corrective action has been completed. Response C
1. a. Form #347 was responded to on 4/26/83 by J.T. Blixt and was closed on 8/3/83.

b. Form #350 was responded to on 5/19/83 by J.T. Blixt and was closed on 8/3/83.

c. Form #351 was responded to on 7/14/83 by J.T. Blixt and was closed on 8/3/83.

d. Form #352 was responded to on 7/15/83 by J.T. Blixt and was closed on 7/18/83.
~~Response D~~
~~1. The use of Quality Control Work Instructions has been dis-continued.~~
0 ed s
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~~? .,. . .. . $.,,IM#26,056(Cont'd) -~: -Piga 2 ef 2.~~
s
.' h 2 l_r" Should you have any question or if we can be of further assistance, please do not hesitate to call G.L. Morris, Jr. at extension 743. -l ,. .n v' ')f J.T. Blixt QE Group Sup'ervisor JTB/bm cc: G.R. Purdy R. Siever G.L. Morris, Jr. -QA File 9
~~D I~~
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~~..- . AHbehmen: so : ..e ~~~
~~TEXAS UTILITIES SERVICES INC.~~
.; O FFICE M E M . .i AND U M To Fred Burcess Glen Rose. Texas July 20, 1983 sub).es COMANCHE PEAK STEAM El.ECTRIC STATION Purpose To establish the Comanche Peak Pipe Support and Oversite Group which will be responsible for organizing the Comanche Peak resources into an _
effective Hanger Team capable of moving hanger packages from their present location and status to the vault in the most expeditious manner possible, not foregoing any of the engineering or regulatory requirements. Charter The Pipe Support and Oversite Group will be headed by Fred Burgess.' He
~~. will be assisted in this effort by a full-time representative from engineering, construction, reactor building area manager, safeguards /~~
~~auxiliary building area manager, ASME QA, non-ASME QA and a secretary. The Group is to define a process and an organizational structure with~~
.each function being described by role, scope, responsibility and author- , ity. Once each function or position has been described, then the group t, is to. appoint the most qualified person to that position. All of Comanche Peak is available to fill these positions. The people for any position may come from any organization, but once assigned to the position, the person then is responsible only to the Hanger Team. The only exception to this would be the regulatory requirements.
The Group will meet as deemed necessary by Mr. Burgess, but due t'o the urgency of the pipe support problems, it should initially be a full-time effort. The Group will be required to establish a single job-wide report for tracking and statusing. Once the Group has been established the Hanger Team, it will be the responsibility of the Group to provide an oversite function for. the hanger effort and resolve and/or correct any problems. I am requesting that Mr. Burgess report on progress of this effort no later than July 25,1983 and periodically thereafter as required. N Ft d T. MerrTtt, Jr. st. Project General JTH: pew cc: B. J. Murray G. Purdy r M. R. McBay R. G. Tolson J. Dittmar D. C. Frankum J. C. Finneran R. O. Taylor F. Burgess BRJ s1699 i l l l
,-rn=, m ~.-.w... m - x..wan. :. = ~ c.u.:wa = m..,w. . .u :.~... u .c.:. a . \ 1 ' t. / ' x * , Sffochm'd .11 p w. . 3 , { *
~~WORoot.bC. '~~
[ : MEMO INTER 07 '0E yi ' DATE: July 29, 1983 l c T0 : .- Distribution ' b ,
~~.f- PRON: G.R. Purdy~~
~~SUBJECT:~~
~~CPSES, 35-1195~~
~~.g Hanger Task Group (HTC) p Assignment.~~
~~l . -~~
,i - .? Effective 28 July 83, three dedicated HTG's have been established to ;- complete safety related hanger design, fabrication, installation, and ; inspection in Unit 1 and Common.- The staffing, objectives, and basic - ,4 - process flow requirements for the HTG's have been developed and/or
endorsed by the PS&O Group; this group is comprised of all interfacing organizations involved in the pipe support program, including QA

j. management.
'l ; Figure 1, attached, depicts the required QA/QC-HTG interface organiza-j- ' tion. The QA/QC Lead within each HTG will, as normal, be receiving g day to day priorities 'and work scope 'astignment from Project Management, 4
thru the HTG Lead. As required by 10 CFA 50 Appendix B, and Section III Subsection NA of the ASME B&PV Code, the QA/QC Lead will report j - directly to the QA organization for implementation of the CPSES/ASME
,f, QA Program. Administrative matters will be directed to the QA organiza-( tion, except for HTG work schedule and' payroll timesheets which will i be coordinated within the HTG's by the QA/QC lead.
] Figure 2 attached, provides a Job Description for the HTG QA/QC Lead. 3 Each Lead shall insure that QA/QC personnel under their direct / indirect l supervision has a sufficiently detailed Job Description, endorsed by the HTG, to assure a) The ability to meet HTG objectives; i b) Time resolution to deficiencies which require QA/QC sction; and c) A primary review of hanger packages in sufficient detail to assure that only satisfactory packages are transmitted from [ the HTC to QES. The QES Supervisor shall provide the QA/QC Imad with copies of all applicable transmittals dealing with hanger package processing external to the HTG. Additionally, the QES Supervisor is responsible 1 for providing any additional information to the HTG which is necessary
~~for HTG evaluation of package processing.~~
S At A/ GRP/ba G R. Purdy (,) i Distribution: Site QA Manager T. Blixt B. Sims (4) 5. Baker
~~' R. Siever B. McNellie, (4) J. Dittmar G. Bennetzen F. Burgess B. Murray e'~~
~~D. Woodyard J. Finneran R. Taylor D. Snow (4) K. Liford 0 3~~
~~. Ry~~
y _ ._. _ m . . _ . . , _ . . . . . _ . . . . . . . _ ... l . ..1g SIS HECORD F0R MONITD. RING Q.A./Q C. PROGRAMS 3 ._. TIIE IIARTFORD STEASt 110!!.ER INSPECTION and INST *RANCE COAtPANY . CASE EXHIBIT NO.1,046 isAN a imo,cowcnet r sanne;: 3364
~~", ro an. .no ras.,~~
~~i cast soar u~~
'd Mr. Gordcn Purdy, Site Q. A. Manager IAucust 23, 1983 1 1 2 ,g y l cusicutss courw mast asr enamen mse etcios ce scatcm ccum:av t ri gaspswatuss d El Brcwn & Rcot, Inc. Houston Houston " Reavited JCI'5'8 ! '~
~~U } j msettlem tocare .~~
- . field Repair / ~l CPSES Glen Rose, Texas r*35 hop L. XJAssembly Alteration Ulaservice l1. the untiersigned, have monitored your QA/QC manual on:_,8-23-83 and find the following sections:
~~_ < an. n.a.s.,. .ao r.ri. u~~
~~~~o o.r.o~~
~~_ Satisf actory: t N~~
~
~~t-- r ca o'c5.a..o ..eu.aa (no .an v.h.} on oa.auar an.Tse~r.Tsacoara,a .ac. i. .cos.ew.o usaear.r~~
~~' .X Unsatisfactory:~~
~~Section 12 - Test Control On 4-21-83 site ANI issued 939 i 346 addressina inadec;uate test procedures.~~
~~i. = This report was satisfactorily closed with Bravn & Rcot resconse includino OCH #10 i?~~
~~it issued against QI-QAD -12.2 rev. 5, which was to be used until the crocedure was revised. This procedure was revised on 5-12-83 ivithout incorporation of this instruction.~~
~ . . See Attached. ._.OVER -* CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION'* section below, arid give dite for completion of correctivc action, so that items may be remonitored by: 9/6/83 r o.r.o Please keep the Original of this form for your records and return a copy to inspector named below.
~~cisie eur o cara sota Eres unr/Ie'eres'eItative Nrlle~~
~~~ 8/23/83 )sota rus[a ia. [crongg/' (~~
nsotuno= ce %st artus cascama et a mac unsansricroar sc a, . a .,.. s .a n. .u.,,,/ QI-QAP-12.2, Rev. 6 was inicially revised on 3/4/83 which is prior to the 4/21/83 ANI closure of 939 #346, but was not issued until 5/12/83. QI-QAP-12.2 is now being revised to include provision for stamping of ISO's
~~. (Para. 4.1) per QCWI 10.~~
(. [ The other items addressed on this SIS fall within parameters of CP-CPM-6.9I yy (Para. 3.6.6. & 4.2) and should be directed to Brown & Roots Staff Engineer. du - 8, J COVER o it conucnn acto .c n ccmtuo can nota 9/19/83 9/7/83 set o , :..,..., . a.,,...
)
~~p '~~
/
l the undersigned, have remonitored the above urisatisfactory conditions on: State $er 13. 1993 - and found them: O satisf actory IEUnsatisfactory (Esplain cetow) % '"
~~s 1__~~
~~n- _ - __~~
~~.I See Attached 30 ~ .;~~
~~e-, [ ' oss'aitwics 8'ait soto insp soto ensa ia.a.cron ines. uer/ggg p ,,,gn Gcrne '~~
. n, wn us,s, neoreientative 9/13/83 Y d O [ M; Im N ,,/ ,
~~G.,,- " " ' -~~
*' SIS Renort #364 Page 2'of 2 / Y 'Ihe use of a calculation sheet for deviations in gauge /oiping T, 4 3 4 elevations -is not 'proceduralized.
Se use of a calculation sheet for " air in solution" is not proceduralized. . 42 Iso. 's are not readily identified to the test package as test + 1 package does not list Iso.'s and in many cases test nunbers have not been referenced on Iso.'s. W e Iso.'s in many instances are not
; stanped indicating affected by design changes and OC's which are within the scope of the test are not highlighted (eg test # IVD-616, Iso. # VD-1-SB-004A & OC #87612 rev.1, and Iso. # VD-1-SB -003B &
~~C4C #87202 rev.1)~. It is the opinion of this ANI that Brown & Poot's test procedure~~
~~'does not conply with NA-4420. 'Ihank you, 1 / ,~~
~~( ) BillyWaper~~
~~O g~~
~~%.Il~~
K
~~~ ~ '~~
~~Attachment 2~~
. *?: 'T . SIS Report #364 'y ' , . Paga 1 of 3.
~~Qq< f.j ~~~
~~References:~~
~~Ref. # 1 - ASE Code, Section III, Subsection NA' ( as'adooted) '~~
~~Ref. # 2 - ASE Code,- Section III, Subsection NX ( as adopted)~~
'Ref.:9.3 - Brown & Root Quality Assurance Manual Section 3 , - Ref.1 if 4 Brown-&~ Root Quality Assurance Manual Section 6 . Ref..# Brown & Root Quality Assurance Manual Section 12 Ref. # Brown & Root Construction Drocedure CP-CPM-6.9I- 'Ref."# 7 - Brown & Root Ouality Assurance Procedure Cn-CAD-12.2 Brown & Root's response to 939 #364 is unsatisfactory as indicated by c
~~the concerns listed as items I thru VII. olease address these concerns as soon as possible so that I may remonitor this section of the Quality~~
~~. Assurance Manual by 9-27-83.~~
I
~~-Your response that other items should be directed to Brcwn &~~
Root Staff Engineer is in conflict with and/or is inconsistent with.ref. #3 (para.3.2.6) , ref. #4 (para. 6.3.1, 6.4.1, & 6.4.2) , and ref. #1 (NA-4210). II. - The use of a calculation sheet for' deviation.= in guage 1 ciping elevations is not proceduralized. Calculation, sheets have been used on nunerous test. 21s violates ref. #6 (para. 3.6.6 & 4.3) . Also on many tests the pressure guages have been directly connected to the test manifold, not the ccmponent being tested. 21s violates ref.15 (para.12.2.5) , ref. 96. (para. 4.3) , and ref. #2 (NX-6411) . ( ' III Ref. 96 (para. 4.1.2) indicates that flow diagrams will generally be used (see IV) and provides for stamping for test sign-off. 21s'is unacceptable as previously addressed in 939 #346. Your response to this is acceptable, but please note ref. #6 is in
~~. conflict.~~
IV Ref. 46 (para. 4.2) allows for minimizing air pockets bv flushing or by providing calculations to show that the entrapped air is dissolved. Ref. 87 (para. 3.8.1) also allcws this as an alternative when "it's highest point" is not vented. 21s violates ref. #2 (NX-6211). De verification of establishment of a " solid" system was one of the concerns which led to the issuance of SIS report
#12-002 and subsequently 939 #346. Prior to the issuance of SIS report 812-002 (10-12 82), only flow diagrams were -issued with test packages for preliminary review and final' acceptance. Since flow diagrans do not indicate changes in elevations, the ANI's weren't provided with adequate information to evaluate the existing con-ditions to decide whether or not venting was established at all high points as is required by ref. #2 (NX-6211). W e present practice of providing all Iso.'s within the inspection boundary still has a potential for error particularly in the case of multiple Iso.'s per test in which case venting may not be shown.
~~I have provided exarples of high points without vents at VIII. (.'s m._~~
.)
~~n. ~.~~
~~g;, p,.y_ g- Attachment 2-~~
~~. SIS Report #364 Page 2 of 3 It) ' ,~~
~~V - Ref. '#6 (para 2.4) -indicates that only a Pressure Data Sheet c and the acolicable drawings are required in a pressure Test~~
~~-Data Package. Ref. #6 (para. 4.1.3) -indicates that additional information is recw. ded. This is in conflict with ref. #7 (para.12.2) which stipulates additional documents as being recuired.~~
VI. Ref. #7 (para. 3.4.3) indicates that "other systerra" including the. Diesel Fuel Oil system may be tested with other test mediums, preferably the operations medium. The quality checklist (attache ment 2 of the procedure) as referenced by ref. #7 (cara. 2.3) references attachment 4 for test mediun recuirements. This . attachment 4 delineates seven systems as recuiring a test medium of oil. This violates ref #2 -(NX-6212) . VII Ref. #6 (para. 4.4.1) establishes the Test Engineer as the re-sponsible party for venting the system. This is inccnsistent with ref. #5 (para.12.2). VIII Exanple cf high points not vented.. A. Test # 100-007 - the line on DO-1-YD-008 at el. 806' slopes downward to 805'9" and rises on DO-1-Dr'-002 r to 812' and then drops to 806'6" before rising again. There are no vents at either high. point. B. Test # ISEC-001 .
1. Valve #IMS-259 at el. 885'1" cn MS-1-SB-047 was closed and not vedted.

2. N-1-SB-026 rises frcm 864'3" 'to 867'8 9/16" and drops to about 850' with no vent at the high point.
3. M-1-SB-033 rises frcm 864'3 3/4" to 869'4 15/16" and drops to 862'6 5/16". At the too of this high point N-1-SB-037 continues and rises to 869'11 15/16" and drops to!857'5 11/16" to valve im-245 which was the pressure source. -Also, N-1-SB-033 rises 7" to im -300 which was closed and not vented. There was no high point vent on N-1-SB-037.
~~4. On MS-1-SB-005, valve 1M -050 at el. 834'7 11/16" was used i~~
~~as a vent. The line rises above the vent to el. 841'10 3/16" and continues on MS-1-RB-010 where it drops to 838'10" and on MS-1 RB-008 to 833'3". It also cont'.nues on MS-1-RB-010A~~
~~.at el. 844' where it drops to 835'11 7/8" and 833'3". there was no vent at high point.~~
~~5. MS-1-SB-007 rises frca 877'5" at MS-1-SB-016 to 881'115/16" at valve lHV-2452-1 which was closed and not vented.~~
~~6. N-1-SB-014 rises frcm 856'3" to 857'6" at valve 1m-106 which was closed and not vented.~~
~~4 % ,~~
~- ~ ~ . . ,s'
~~g y. ;v: , '~~
~~'t * '~ Attachment 2 SIS Peport-#364 Page 3 of 3 i~~
~~'3 f, li. ' p~~
~~, 7.~~
~~' MS-1-2-002 rises fran 883'6" to over 883'11" at valve IMS-001 which was closed and not vented.~~
~~8. FSI-0122-03 Spool orientaticn not shown on this Iso.~~
~~Any of the 8 spools in which the valve run is vertical will apply. I BillyWa)Xer i e 5., ,~~
~~e 4~~
~~5 9 P g .f 9~~
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~~9$9 " M v '/;rtis yn A 464y _ ._ On.. /4'- Y-13 } ^te.txed.,w ,ds m / m WA1-01.6 13 t " 36 .~~
~~.[ut797?.24.2Y7sak.l./) $b.111;f.:, u.y)aw .4 xinae &Ji%Q. a,> .crL ' )</su ~~~
dnewn E .mo n/twro snah. .h .,uesisy f/-C/'/?) 4. 7z f. ,urdad. &,. u A. .ea./aJakas A Ankb., .Ak ,ipay .2 .)w m/ . 4auy ded, . d.A i> sJ.L/dy us ds</ d e & <apa.u),.<-si.4.~,6,,uss.4 w y .nsn tN/m t. 91.~ . i s % . s J . t l , u p u .ii i s ,>. A b ( p . g. i. i)
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~~'.mu.>t udeaL 4oadd4 a,,4,,,wiLL. &mn 2 AfA'-> mud a d4J ino..va.2n. .A acL wi, .4w ./ lag.'~~
~~O.n ,83 cke d , l .sid.uiil AL. '1$ 4 t 4 acWuss sy c'snew /S'.i~~
.a/ah' .lu .vasen ./n 24 4//uuu ,o, 4 apc~~t << <x Af.4 a.a a wa. swa, A ./ y s2. Rv.zd <p)~uty .A wn-a la m ) m n ~, A cy' >,y . dura ,,u g a >,4, -,A 93 9 4 , *4f *
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~~.% WM l I -INTERo m JZ MEMO ,~~
~~f; IMf'26,257 _DATE: October 4, 1983~~
*TO: M. Coats !
~~PROM: J.T.;Blixt i~~
~~SUBJECT:~~
~~,CPSES, 35-1195 SIS Report # 364.~~
~~l ! This meno.is written to confirm our previous discussions and as agreed~~
~~.between' Billy Walker, ANI; Pat Clark, B&R Staff Engineer; G.L. Morris, -~~
B&R Site Mechanical Level'III; and myself, the following responses are , made. i concern I " Agreed" l Concern II All QC personnel involved with the hydro testing program ' will be reinstructed as to correct use of calculation ' l sheets. i l Concern III No revisions or changes to CP-CPM-6.9I cill be made. CP-QAP-12.2, Para. 4.1 has been revised to include
~~. provision for ISO's.~~
~~Concern IV For 1980 Summer Addenda for NX-6211 has been adopted by i B&R (MS-100, Rev.'6, Para. 4.38.3.C) and CP-CPM-6.9I, N(%..* Rev. 6, Para. 3.*6.6 has been revised. 1~~
~~. Concern V No problem.,~~
l Concern VI Para. 4.38.3.A to M-100 implements Appendix 6 require-i ments. Note: 1983 3X-6212 allows "other'tese fluids" as approved by the design specifications (MS-100). Concern VII No changes or revisions necessary. Concern VIII "No response necessary". Should you have any questions or cos:ments concerning SIS Report #364 please contact G.L. Morris at extension 743. ,
~~.s ' J.T. Blixt QE Group Supervisor l~~
JTB/bn l cci G.R. Purdy R. Siever G.L. Morris, Jr. ir%, W*
T:. ..,
. SIS REPORT O O cast ex"tstr "o 1.o47 THE HARTFORD STEASt BOILER INSPECTION and * (JRANCE COMPANY nan rrnwo.cossu:8 nrr o.io2 16-009 TO:
~~OATE SHEET OF~~
~~,Cardon Purdy, Site Q. A. Manager 9/27/83 1 1 ~.~~
~~H.O./ BRANCH OFFICE Marvin Coats, Lead ANI - - - - louston ~ --~~
~
ORGANIZATION Brown & Root, Inc LOCATION STREET CITY COUNTY STATE ZIP CODE CPSES Box 1001 Glen Rose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P.O. NO. LEASON FOR VISIT 35-1195-0561 Full time contract
~~. COPIES SENT TO:~~
~~CH.O. Eng Cl im. 515~~
~~Ocw.s ia. c., SR.si.a.i u ,, sis Bo h., <s,.cify): ANI file Subiect: Closure of NCR's Affecting Piping Deviations (Documented on PDRF's)~~
~~Ret Generic NCR M2807 Prior to closure of subiect NCR's request your assistance in resolvine the fo11 ovine notential problem. Many of the documented J~~
; Fdeviations were identified orior to installation of component sunoorts. components. and ori~r o to hot functional testing. Any of the above minht have caused further distortion and/or movement of the affected otoinn creatina a problem of greater magnitude. - ' .. 4 y< A reinsoection by Brown & Root or assurance by Design Engineer- < 'i..
~~y, - t' h ' n r ' t h a t this' does nd't" nose i a problem'would be acceptable resolutions. .: ;., ,3 3, . . ' ~~~
~~. ;: , a, -3, . :.s~~
~~{* * . - * .~~
~~,, 6 II 1 -~~
j sicNEO COVER na aav ie-r isen f
BrownCrRoot.inc.
~~., INTEROFF ' MDIO IMil 26,295 - -- -- -- *? ATE : October IT,1983 - - ~~~~
~~TO: M. Coats, LANI FROM: J.T. Blixt~~
~~SUBJECT:~~
CPSES. 35-1195 SIS Report # 16-009. In response to your concern addressed t this SIS report . please see Engineering response attached. . If you should have any questions plass- contact me at extension 459. J.T. Blixt QE Croup Supervisor y /bn 1 cc: G.R. Purdy 1 R. Siever C.L. Morris, Jr. i b 5 ee %eef. . , , , , t 9 e h
~~,M -~~
~~TEXAS UTILITIE5 E'TICES INC. OFFICE MEM H .DUM '.e~~
.D M d M PtiMy Glen 17oca. 'l' ..s In/n7/R'I sei.ca ..' eno r c._..>,,.. ' .a RE:' SIS 16-009. dated 9/27/03 The referenced SIS report states a co. carn by the ANI .d:coc document %
~~deviations prior to installation of pem:.nent pipe supper':r. and prior to hot' functional testing.~~
~~C.c Engineering is presently ccmpleting the disposition of all Unit 1 PORF'r~~
. ---- by letter after evaluating each deviatic : per the latest as-built pipe stress analysis which provides deflections and moments of the piping' .--- system.. The As-built (79-14) group is al :0 finalizing its documentation in Unit 1 by verifying installation of. rapports which were. not installed l--.at the time..of survey. ..--.---.
e .g .u. .,= . %.. . 9-- The intent of the Hot Functional Test program was to insure that the 4' - - - hot piping systems moved as predicted during wam-up. Engineering walk - downs and evaluations were perfomed prior to HFT .a assure the piping was adequately supported to reduce the pcssibility of binding or over stress. - .
~~.; /~~
~~fc. ,~~
.. g g ? It. is therefore our opinion that the '"RF program is sound and being properly implemented. ... ..(Q: . .r - . ~: . . - - ...h......... .
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S REPORT O % : Tite nau rHawu. HARTFOND a NNI.cru:L.T STEAM win! UO!UIR INSPECT!UN .n.t "'iURANCli ANy COM:
~~, = . -~~
16-009 - Cordon Purdy, Site Q. A. Manager DATE SliEET OF
,- ~ . e.4: 3/27/83 i 1 Marvin Coats, Lead ANI H.OJBRANCH OFFICE fRGANIZATION fouston I Brown & Root. Inc ,
LCCATION STREET CITY CPSES Box 1001 Clen Rope COUN1Y M Somervei* Taxy T 5 0 '* .' PCH50N CONTACTED (GIVE NAME AND OFFICIAL. TITLE) r .ws'. ~~ C ^N TR ACY!!'.' it.9ASCN FOR VISIT ' ' " ' .1 * [ f, ': $ r
~~~ ~ ~ ~~~
~~a Full efme con e rac t~~
~~CQPIES SENT TO:~~
O H.C. Ea , cf i sis O o.l. ro.... , en.,;...i u ...,. sis eo.s . :5,.. a,): ANI fi1e _ Subiect? Closure o f NCR 's Affecting P f :s in g Deviations ? (Documented on PORF's) Re! Ceneric NCR M2807 '
?... ' . s.:. . ..g ~~. > , - ..
~~Prior to closure of subieet NCR's request your assistance :.Q ['.-~~
, s U in'"esolvine the followine ootential oroblem. Many of the do'eu'mented ..;,t;'" . ) deviations wereidentified orter to installation of comp 5nEnt' ' :-', c .r, e ~
~~suocorts.~~
.4 components. and orter to hot functional casting. Any of . ds.
the above minhe have_ caused further distortion and/or movement of i the affected piping creating a problem of g r e a t e r m a g n i t u.--d e . $.'.T' ';' t-
... .. T . . . ,_ 9 '. . - ..- -f rn:60s.p" f I Sc-. 'A reinsoection . . y 4: by .
~~Brown & Root or , assurance by Design'Enginear- i. . l~~
. .' .pg. .. ' ~ " . ., 5 ' ' i n e ' e..h a \.e ~ t1its ' *ii s7Fn'o ' tis ~e ' a ~so..,,.%..,
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.._.e ma* ~u a,g 2 A_ n 1 ,.h , up- ' ~ / \ + SIS REPORT l ' CASE EXHIBIT NO.1,048 eTalE HAM 11AllTi'OltD rumn.cossimSTI!A.M eirr aim!!Olt.!!H INSI'!!CTION and '
~~L'RANCliCO.Mt'ANY I~~
Tc: 10-024 _ . DATE SHEET O F. Gordon Durdv, Site n. A. Manacer lo /s /q1 ' FROM- 1 ..
H.O./ BRANCH OFFICE John S. Hareer, ANI '
~~ORGANIZATION s-Houston~~
~~.. ...~~~
Brown & Root. Inc. - LOCATION STREET CITY COUN TY U T,g s. -~~ ~ ~ r ," C ") .'- CPSES Box 1001 Glen Rose Scmerve'i,___ ""3:'n.;L._ _LC.D.il. PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) C ' * * ~ W ' . .' .. M f.EASON FOR VISIT '
~~~ d U 3.3-f.1 '~~
Full time contract -_ COPfES SENT TO: a OH.O. Eng Cleim, $15 Chi.I Inspecio, SRegional Maneo ,, 515 80,h., (So.cily): ANI File !- c ., contrary __to_.y.o.ur._Qyali.ty_ As s uranc.e_Manua L,_.10. 4 .5.,_. the_below ..
^
~~supports._wer.e._f abricated_wi.thout_discribed..". control.._of_Qelding i~~
~~. . ..- ?~~
ma terials."__: . I . t. E-CHel:SR .al.QA .00.22.3__ ,' -.. H:CH=1.SB.-010A=.00A -- - t
~~'~:; -~~
H-CH_1.S3_-Ol.0.A:DD5 -3 - H _CH-1 SR=.Q1.0A-0,06..3 - - . l . H:CH .1=SB._0.1.QA _QO_7-3
. 1^ ' s .t.
H-CH-1.SD- 010 A-qp.8__2. _ ' t H-CH-1 S.Br9).0A-009-3 H-CH .!_-EB-OlDA-9.10_-3 H-Cli _l-S_B-01.0A-0),1. .3 H-CH-1-SB-010A_0_12-3 1J. __. . H -CH-l'_-gB -_0.,1.0 A- 013 - 3 .:__ _ ,. It appears to this inspector that this is a nonconforming _.c.org- ____ '.s d_ij. ion and should be rep.orted as su_ch.
~
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_ _ y=. - -msa ww, .w..g.g .p- g9,3. q(z:ggg.Q,g.gfg.[Q} . l f,g,v- / SIS RECORD FOR MONITORING Q,A./i).C, F..sGRAfrfs
~~'" \~~
~~l s T!!!! HAllTI:OltD STHAM llOII.l!!! INSI'!!CTION ar.d INST.*!!ANCE COMI'F" H AN Fl OND. COBarl H:t/r amiha O~~
~~
4 365 1 a r.v.o a. + 4} run.-,.
~~~ ~ '~~
lws s>.w Gordon Purdy, Site Q. A. Manager 1.10/7/83 i cusicutes ccuraer samt mise 6aco 1 i
~~.d. ::: N* stcios ce scato cx=:av satmov.6L ust cut v.~~
pc Brown & R.qpA__Ip c . ; Houston f"'"l Up,,,,,,Oci.e u g onsrtcsa toesto
~~-,fellon - ~~~
e e v, erg - CPSES Glen Rose. Texas '" N' ' ' ~
~
~~f. the undersigned, have monitored your QA/QO manual on: 1 0 / 7 / 8 3 2 .,., .,n a ,,,,e t,. , ; -:*ine:~~
~~ro... nu ..as ena r.v.no . . . . . . . -- - - - - - Osamitaciory: e~~
~~. <>a.. or o ac ....a , a p.. ..a r.u.3 on ,a..a.or an. ,o.a,r., . . ,. . ., an.: , ' ~ ~~~~' ~ ~ ~ ' ~ ~~~
~~Unsatisfactory: Section 10 Paragraph 10~.4.5 " Control of Welc...tnc '4ntur u t" . . Re: SIS Report (932) # 10-024~~
~~..t FE EM~~
[& In addition to the objects reported on the above document, the following hangers are in the same category of noncompliance: H-CH-2-AB-009-004-3, H-CH-2-AB-009-007-3, and H-CH-1-SB-024-005-3 This appears to be a generic croblem. p' .' ' CUSTOMER: Please describe the resolution of these items in the ** CUSTOMER'S RESOLUTION" section below, and gi
.1 date for completion of corrective action, so that items may be remonitored by: October 24, 1983 . ,=...,
Please keep the Original of this form for your records and return a copy to inspector named below. cutesunca Cart seu sota rus 2 Reg. Ngr egrese tativ. EUl." 10/7/83 h f,7,[a e a.cren( g __ _ sisaura os sacst,utus o(scAi810 A83Vs As 8tJ8G LN;AIGACORY (C.ar.84s. .A A.w.'8. $aa. ,,N.g.gsaryj
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~~k5 A&U *l' ge,s,a.<.A, Al*'s f~~ L', M '~~
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~~T VWQ d.o LU 'f/??t.'.AAS g j& &w,,, <f1&j 'Dq p'f&..-"~~
~~hyg& -CL a El h h M )u4 p w.xAeMyw'AM f~~
~~= "~~
cast co stcrat acto ou Wccurttita cart sota sou s e..,. ., a.,,. ...,. -. h l0 lf b ' 1, tha untfersigned. have remonitored the above unsatisfactory conditions on: jo/2,o /y T
, , , = m ' /
so.,es end found them: L Satisf actory L or satisf actory f Enlairt colow) o - l : }- r7/tS Auo e<oras s .z s a vea (?.rQ # g _ g y [{j po ris: ns, o rrm.>)
~~- J . ' b ,9.52. R M y 7.g ,,~~
~~(tBT$',:,':, (~~
~~. , , ,, ( L~4l}ko, yW6"I"(~')d~~
/
~~ex:igenpgga .fi SIS RECORD FOR MONITORING Q,A,/Qec. PROGHAMS R b.~~
~~.? 4 Tiin stAntriono svu,ut norunt Inst'Ecrios ana INsL nasen co.sti> ass. CASE EXHIBIT N0e 1,049 narH*n. comencer o.nu~~
~~# 3GS cut f 1,7]to,nen.eener.,,e, Gordon Pugdy, Site O. A. Managey 3,,, ,~~
g. ~ Cusicutes ccwaar haut 10/7/83 1l ap 6Aanca .o secw ca scat'c, c,,unts,

v. s .
~~irasosonat vst outr**~ tt y Brown & Root,,_Inc.~~
"3 "'VICDC" LOC 8'*
~~Houston , Usecaires.mfolton tly Ccir.s '~~
~
l - field Repair / CPSES Glen Rose. Texas _. ___ 88 WAssemHy 04ny. t.ie_ q. .',sc' I, the undersigned, have monitored your QA/QC manyM on:,_.l.0 '5/I/ l3,,. .? -/M 4nd the W.,4- . :- go. non,eers ne ra,no '~"* ~~ Os.iist.cio,,: ~~~ ~ ~T -f' ' ~~~ ~ ? -p __ ~ tyv r b unsatisf actory:uraenu.or oncc menese neroon (se one rase) on ooenne une weca.s nonconoormA*Tn , W ff 57 -- Secti'on 10 Paragraph 10.4e5 " Control of Weldint-i
~~'o :l'.~~
~~Re: SIS Report (932) # 10-024 ' '~~
~~p. . : aw.:,~~
~~is_. 3, -~~
~~~-m,~~
[5 In addition to the objects reported on the above document, the following hangers are in the same category of noncompliance: H-CH-2-AB-009-004-3, H-CH-2-AB-009-007-3, and H-CH-1-SB-024-005-3. This appears to be a ceneric erablem. [ . .. '
*USTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" se . tion below, and gin .
1 eit cate for completion of corrective action, so that items may be remonstored by: October 24, 1983 i tceuer Please keep the Original of this form for your records and return a copy to inspector named below. cisr,wre cart s:cato i" sota rusa sasaurers ** E#eg. ugehepres[nt tive EF (('
~
~~10/7/83 h Q.6 r 7/'__ sisauro os p.ct,atus ogsr.s.sto accet as at.ac t,awcrac:osiv rcan,,no e en ne.e,se s,,e a,secoue ri~~
'N #f-ff y m ,3/Sgagy,k 939*36 S AL;dAu*'m S/3 4/d M'""UWd""-- , g'.1,q. A q J 440$$
yyy .,ry) t. st.*b* **~ ~

m%lJ,C""}X. && w <." *<. 17 !JL
~~g ,,jm m y/ J MAN 4t.4 Q - *^^ &w & wm m p~,# . Q3wc,&/m--~~
~~j .....,,,~~
~~a. .~~~
~~-e.fa' .<. L vLw< d'-~~
~~li ,8w dto. eu vt /A-,y M n rc C41.fu y .4~~
~~& yu % Q* ~A. p a.w t o s m i~~
~~s. A z 4 w -~~
.4 a.,~ v nct.,, w. m ^n ~. # [ j f m p k n , s o. ga gw Jeu..XAs 4. .i a &my'~ & 'A _
l # Whb * ! / Dait costCtivt aChom snit I6 CllMPtt!a3 Dart seCh($ sirht0 tc. aron.or s nearesente#~e > l0/l3, l3 h ' ~- ,', _
't, tha unticisigned, have remonitored the above unsatisfactory conditions on: g>/2_c / 6 = "
coeres end found them: C Satisf actory CUnsatisfactory(Esplein cetowl , ,, t- _ --
& po nS .' rWiS /it i so d < c>r a S c.z s m e,l r (b., Q Q _ -.a.' (Co/0 y ,,
~~s9 77// c///if.)~~
., '79 h s .r c- sis r.re. . i, waii >== sw o , ,. -
~~cre ;;ry-~~
' t. ~ egresent -- /[,ly.x (.l,Q - - ) Q ,e,f,, e,.,, -- '^ -
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~~i , 9, -SIS REPORT - -~~
~~"' ~ ~~~
~~I.4~~
- n.su THEri llARTFORD own.cossiniicer STIL\.st u,m Ilott.ER INSI'liCr!ON and 1.%NI.*RANCli CO.\tt'ANY ;
~~T" 10-024 ..~~
.e , *Gordon~ourdv. Site n. A. Manacer OATE SHEET OF. ~' I ,* A 10/5/93 1 1
I H.O./ BRANCH OFFICE John S. Marcer, ANI ..
~ OR,GANIZATION Houston '__. ,
Brown & Root. Inc. LOCATION STREET CITY COtjNTV ip3 r g ,, c't:7 'JN CPSES Box 1001 Glen Rose Somerve Q' ~ ~~ ~(~$ p _
~~.._ ~ El i .~~
~~PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) 7- ' 1 " C " ' ? * ' I'-~~
~~~ ~~ ~~. -~~
~~h - G u-iz_ i', LEASON FOR VISIT Full time contract COMES SENT TO: O H.O. Ez, CI.im, 515 ~ O cw.' ra.... ,~~
~ 9 a.ei.a. u.a. 9 o'h - (5s.cify): 'ANI File ~ <. sis s ,
~~si . \~~
~~,q!9.i{.~~
~~Con.trar,y__to_.y.o.ur.J1uality_ As suranc.e_. Manual.,_10. 4 5.,_.'.he_below~~
, . .> .ce-l suppor.ts_w.ere_ fabricated _wi.thout_discribed " control._of_ welding r c .-
m2terials."__: . _ . . y 1 c ic . R._CH 1.:5.B Ql.0A 002 ] -- - _ .
~~. ".m H-CH .1-SB.-010A .00.4-3._ . _ . .~~
~~( -~~
~~~ .u' u~~
H-CH:1:S.Brol.0A:.Q_05. .3 - H :.C.H 1 S.R Q1.0A .0.Q623- . . . . . _ _ _. HCH 1:EB._.02.QA-0.03- 3 - - _ _ _ - - [
=
~~__II _CE .1--SB-010A-0Q3 L_ l~~
.__EC.H._l-EB 91.0.6 _0.0.9- 3 -'
H-C.H:1 EB-QlQA 0,10-3 ,..
- H-_C.H:1 SA10. LOA .9.U n) '.._
H-CH-l_ .SR .9. LOA 9.12 f' m' H-CH SB-010A-013-3 _
. J._. .[ . 1 . * ,. h =
It appeals to this inspector that this is a nonconformin_g_,cg.n- - J .
~~,'r -~~
~~di_t_ ion and shguld be reported as such. _ Wi. .~~
~~..w. .~~
~~Hid,, 1 *. . . .g .. . _ _~~
~~$4_c .s- A o M <. .S*H 7' / tis'y o u se c>p 9 3 9~~
~~3_ C. S '~~
~~M .. . ._ D k w /.o h .c / O _ _. ._ - -~~
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i unsv. ie-n isisi b]m Y' ,
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1
. . . , , , , - . . .-._..,,..-_-_-,-,,..,,...,_.~.,..._.,my - - - , r..,, - _ , , . . _ _ . -
* 'g, ' SIS RECORD FOR MONITORING Q,AdQ. . PROGRAMS #366 f- e Tile !!ARTFOHD STEAA1110lt ER INSPECTION and INSURANCE COAtPANY 8 h (* A '*y/* *e se- M.s y . IIAH ri own.::oswcrn:t;'r oms: cf*et . - CASE EXHIBIT N0. 1,050 #366 so one-. e.,o r .e, om nu 1,'~ j Gordon Purdy, Site Q. A. Manager October ?! 1991 1 lori j Cwsrowts s (tweaar **wt w saanca msr acc.om ca scst.cn ccatar tarciondt usa outra -
~~n Folicw Up fk~~
*5 Brown & Root, Inc. *sPLC'Cm L7.Atca unnenn - Field - Reavires UClosed
_j CPSES Glen Rose, Texas C8 hop ' IAssembly Repair / Alteration laservice I. the undersigned have monitored your QA/QC manual on: 10/21/83
~~and find the following sections:~~
~~<cereu e a..e n.,,,e.,, maa r.ne.> '_.! Satisfactory:~~
~~treenoury caroc menoso sur>on ino saa race 3 on saeas rr une soec,ose noeconoormance as aoos.ceo.es~~
~~.,*J Unsatisfactory:~~
~~Section 16 Non Conforming' Items~~
The following listed findings were found to be unsatisfactorv. See *
~~(.. attached sheet. '.~~
~~.. s ,~~
[ii Although specific examples are given, the oroblems found are not ! limited to just these examples. f LJOVER CUSTOMER: Please describe the resolution of these items i'n the " CUSTOMER'S RESOLUTION" section bel' o w and give date for completion of jorrective action, so that items may be remonitored by: November 7, 1983 , i ccern Please keep the Original of this form for your records and return a copy to inspector named below. ggmaunca - XReg..ur/sig7,,,;g,
~~,,,,,, cart mio 10/21/83 ma sa ta ourors~~
() O) f CM, r Representative tX. Fila h _, tsotunca e, : cs: n Ms cesasto ansvi as souc usansricrsar / scoar,a..
~~/ .. no..,.e s..e,rg.'co.w,, ~~~
~~A$ " 7Tp dW n, !~~
~~.Ib a 4/k #/~~
~~Eill f()/~~
.yd C- . .. . COVER ' Cart CcaEigityt aCT:CN wiLL at CcMPLETED - CAf t stGNt3 sicNt0(c stomer's Aeorssentat,.e) i - ) ,l, the undersigned, have remonitored the above unsatisfactory conditions on:
~~toutes ' jand found them: Satisfactory CUnsatisfactory(Explain cetow) { S I~~
? - \
t - d'Y* *
Sis Foreign Insp. cm smo swa tusa sasse< sors l Reg. Mgr Representative File ,h r.w . .. . -
~~I 3 : . 3,t~~
/[ - - 1 SIS Rsport #366' Pagn 2 of 3 ' -(1) - NCR's are_being. voided that should not be. Examples: , ~M10,136 Rev. 1 - Should have been closed, M10,188 - This !
NCR -references _ another NCR . for justification when the two NCR's (and documents attached to them)'do not deal with the same problem and/or area. M10,193 - No 6bjective evidence given for justification. (2) 10 open NCR's were picked'at random from the log books in each task force-area. Only 1 Task Force NCR Coordinator could track the NCR's any further than through ANI review, and his tracking device was not -the one prescribed by Brown & Root.
~~-(3) NCR's being presented to ANI's for review without having the referenced drawing's revision number. Examples:~~
M 6752S Rev. 1, M 7116S Rev. 1. M 6577S Rev. 1,-M 6620 Rev.1, M-7119S Rev. 2,'M 6756S Rev. 1, M6619 Rev. 1, M 6188S Rev. 1. (4) Treud categories for NCR's are inconsistent. Example: Some NCR's written for missing welds were trended C-ll or C-12, while other NCR's written for the same reason were trended C-16. (S)' NCR M 7169S Rev. 0 - Action Addressee was Finneran (Engineer-
, . . , ing) . The review by Engineering was not' signed on Rev. 0 and the review blocks for Engineering had been NA'd on Rev. 1; therefore, the NCR had.never been reviewed by the Action Add-ressee, making the disposition indeterminate.
(6) NCR's being revised by organizations other than the organiza-tion that originally prepared them. Example: NCR 5803S Rev. 1 --Rev. O was written by Weld Engineering and was revised by the Action Addressee (Engineering) . (7) Additional information being added to NCRs without being re-vised (added after initial reviews). NCR M ll,006S. Example: (8)' NCR log books ' state NCR M 11,003 is void, but"no date was entered.
~~-(9) NCR log b.coks do not give' Action Addressee. Examples:~~
~~M 11,029, M~10,050, M 10,056,'and M 10,058. c~~
~~'(10) NCR' log books do not give trend category. Examples:~~
M 11,029, M 9650, and M 11,441. p 4 T- e l ~
r
/
SIS.Rrport #366 Pagn 3 of 3 s s' (11)' NCR log books state a NCR is closed when it was actually voided. (12) NCR's written in one Task Force area, and entered on that log book, then transfered to another arei are not being tracked. Example: M 10,205 logged in. Auxiliary Building Task Force, sent to Safeguard Task Force on 8-2-83, closed on 9-29-83 by Safe-guard Task Force, and log book in Auxiliary Building Task Force shows it to still be open.
~~'(13) Inspection Reports issued after ANI acceptance of hanger packages. Example:~~
CC-1-SB-035B-006-3;.CC-1-SB-035B-007-3; CH-1-AB-040-009-3; CH-1-AB-042-006-3. These were found during ANI re-review. (14) CP-QAP ll.l and CP-QAP 16.1 are inadequate in giving Quality Control personnel direction on what is permitted to be written u'p on,an Inspection Report and what must be written up on an NCR. Fxample: AM 03097 written 10-7-83 is,a clear procedural violation, but hasybeen n.r closed with an NCR as of 10-20-83.
~~. (15) Trend Analysis is not being accomplished for Inspection r ~' Reports. Reference CPSES Quarterly Report on Q. A. Depart- -~~
ment and Q. A. Program Activities for the Third Quarter of 1983. ' (16) Trend categories given to Inspection Reports are very incon-sistent. Example: C-16 is listed for missing welds, incomplete welds, welds needing NDE, undersized welds, slag in welds, etc., and 1 Insp'ection Report (AM-00027) is trended C-16 while the re-port has nothing to do with welds or welding. (17) No objective evidence found that O. C. Leads are reviewing Inspection Reports. Example: Safeguard Task Force. O t
~~\. . , = gaemma=e es. . . . . .. . .~~
L
0 ,, . .. . . - . h6 INTEROFFI' MEMO IM# 26,404 DATE: ' November 8, 1983
-TO: J.M. Lytle FROM: ~R. Siever: -l 1N3 JECT: CPSES, 35-1195 ! -SIS Report #366.
l
1. NCR 10,136 R.1 was void with justification. The above NCR was written against_ Sway Strut RR-1-002-013-C41R, Rev. 1. This strut was installed on Hanger CC-1-057-004-A33R, Rev. 4, which was documented on NCR 10,794A.
NCR 10,193S was void with justification. Field welds 2 & 3 are full fillet welds by application, not design and as such are not noncon-forming and do not need MT/PT examination. NCR 10,188S and Ref. NCR 5212S R.2 do reference the same problem. NCR 10,188S should not have been written on BRP-RC-1-RB-021 (piping). - The nonconformance' is on hanger lug for support RC-1-018-003-C51S. Justification for voiding NCR 10,188S will be revised.
~~2. NCR Log Books have been updated and Task Force NCR Coordinators -~~
~~... reinstructed as to their proper use.~~
3. Quality personnel have been reinstructed to include revision number of drawings on NCR's.

4. Trending codes are subjective and interpretive, the codes you described in this Item C-ll, component supports fabrication (incomplete / incorrect),
C-12 component support installation (incomplete / incorrect), or C-16 component support welding could all be used for missing welds. Quality personnel have been reinstructed on a more consistent use of trend codes.
~~5. At the time this NCR (7169S R-1) was written, our procedure required Quality approval.~~~
~~Engiaeering to disposition NCR's " Rework", without Engineering~~
6. NCR 5803S Rev. 1 was prepared to correct the disposition of NCR 5803S Rev. O. This revision was prepared by the engineer that made an error on his description of the disposition. We find no evidence of a nonconforming condition be'ing revised by other than the action /
~~addressee. .~~
7. Quality personnel have been reinstructed.

8. Same as Item 7.

9. This condition has been corrected and personnel reinstructed.
~~10.- Same as Item 9. ~ e' _ _ , - - _ - - - . . - _,'-,-. _ _ - ,- i. , _ _ . - . - , - - . - . _ . - , ~ , - , . - - _ - . - - - - , - - - - - -~~
.. l . ' s * ', Pega 2:cf 2 !
~~SIS Repsrt-#366 l l~~
~~l l 1 l Ell. iWhen an NCR is void, it is closed per CP-QAP-16.1, Para. 3.1.1.4.~~
~~12. -NCR 10,205 has been closed by Auxiliary Task Force on 9/29/83.~~
~~Currently in Safeguard Task Force for tracking.~~
13. As previously agreed to by Hartford Steam Boiler and B&R, any documentation that was generated after ANI review of a package would require the Attachment 1 to-be void and the package resubmitted to ANI for review.
~~- 14 . We do not feel CP-QAP-ll.1 and CP-QAP-16.1 are inadequate. FIR AM 03097 may result in an NCR,' but this IR has not been answered as of 10/20/83. ,~~
~~15. An amendment to.the Quarterly Report for the Third. Quarter of 1983 was issued on November 1, 1983 for IR's. All future Quarterly Reports will include an IR trend.~~
~~16.- This is the same finding sa Item 4.~~
~~17. There is no procedural requirement that QC Leads sign IR's to indicate their review.~~
We feel that most of the above items, if addressed during the Audit, , would have been corrected to the satisfaction of the Inspection Agency. We also request an exit meeting to discuss any future findings-identified during any of your monitoring actions. i -
^
W S11lFver QC Group Supervisor RS/bu cc: G.R. Purdy-J.T. Blixt G.L. Morris, Jr. QA File O e l l l l
M S;S RECORO FOR MONITORING Q AdQ Ce PROGRArdS s THE HARTFORD STEAAt ColLEH INSPECTION and INSURANCE CO.\tPANY , aux n tmn. cmsinneerinan: '
., .. Tc 4 A so,ne.e e, a r.,,e> ca;e ar peut u i
~~aE .Gpr_ don Pur.dy_ _Si.te_ Q..Ae Nanage.r nece::tha - 7 19 R H 1 '~~
~~' =~~
~~ar; wins courant namt .~~
Asp saamen safGeoaat use outrj dW* :nst asc.om ca scat.cs cuar
'~ g I 'Brown & Root, Inc g houston i'-' Follow-Up "p'CIC5'd -Recuired v w .ePtction toCAlion -
~~8 _. F ield Repair / e- .~~
~~. CPSES Glen Rose, Texas Sh0D -hAssernbly Alteration L J!aservice~~
~~1. the undersigned. have monitored your QA/QC manual on: December 7. 8 3and find the following sections:~~
~~roenes~~
~~<a..e n aea, na r.nono satisfactory:~~
This SIS. report is issued to indicate satisfactory response to the Remonitorinc r of SIS Recort S 366. troenta oa ac mueou neton (no one r.ue } on seenu.rr une secca e nuconcerncence n soon*ema=*> Unsatisfactory: 1 I l Mm
n:
~~2! S . 3= '~~
~~. ?-~~
COVER CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section belbw. and give date for completion of corrective action, so that items may be remonitored by: NA toeres Please keep the Original of this form for your records and return a copy to inspector named below.
~~3 ""~~
~~,d'*'*MgrSIS %,Reg. Foreign Representative bfile inso.~~
~~5"'8 8'"'" j 10 - ~/ - 8 3 h j a %- mL5dtulI04 Or rHGst artus DisCRIBlo 480V( As BliNG GNSAhs} Ai;If)RY (Cont.nge on neverge $.ge .# Ne[essary; b )- ~+~~
~~/ /~~
C/ E,I 5 ' M5 28 . S uE ,
~~. COVER~~
~~ca:t :castcrivt acro witt at comettito cart scato soco re.,. e,, ne,,neo,e,,,e, .~~
~~1 I~~
1. the undersigned, have remonitored the above unsatisfactory conditions on: e e a;1c found them Ll5atisfactory CUnsatisfactory (Explasn cetow) roares 3 'r- ~ .
~~g . kU~~
~~=5' i~~
i
,5 y Ii ' . I I i I t
j os Awfica jst$ Foreign I"59- it sicato solo russ inspector; r* y l w Reg. Mgr/ Representative _. File h . II blv !!sts isis t
p- g
,q . SIS RECORO FOR MONITORING Q,AdQ,Ce PROGRAMS ' . .[I THE HARTFORD ST!!A.41 DOILER INSPECTION rnd INS 11RANCE COAtPANY IRAH Il ONI), CE)N.Nt.tTIICLT 64102 to tuame eae r.,se, ~ #366 catt
( Gordon Purdy, Site O.'A. Manacer snitt et h) o-Ct.sicutes ccuraat haut pesP 4AaNCM octohar 21 Asp AICICN on ICAtaGN COL;higy 1997 1 tAEGJON4 usf owLr) l1 gg Brown & Root, Inc. un,,onn Ffollow up n u w asrtCre toCate JRecuired L ictosed 8 Field Repair / CPSES Glen Rose, Texas Ushop !EAssembly Afteration laservice I, the undersigned, ' ave motiito' red your QA/QC manum on: 10/21/83 and find the following sections:
~~,cere, eo..e u.a oe,s eae r.r,ess u 5atisfactory:~~
L ! Unsatisfactory:Iseenrary OsrQC manuar sect.on [No. ene tense} On scentely sne soecoros neatontermance es ecoorteotel Section 16 Non Conforming Items The following listed fi'ndings were found to be unsatisfactorv. See He at.t. ached sheet. 55 5: a 'Although specific examples are given, the oroblems found are not limited to just these examples. COVER M CUSTOMER: Please describe the resolution of these items in the ** CUSTOMER'S RESOLUTION" and give date for completion of corrective action, so that items may be remonitored by: November 7, 1983 toeres Please* keep the Original of this form for your records and return a copy to inspector named below.
""
~~Mgr js s Representative Foreis, - i n s a. 3 $'"'" * *8**"'~~
~~JiRet. At: tx rite 10/21/83 CLUllCM CF Thost I:tus Dis;A1510 45Cvt as ateG t,asaristacicar (Coat.a v e on Ae.orse 3,ee et ecesserrs / (; ) )c[b~~
/
W See attached IM 26,404. d*' N n ? /dV au 952/ Calt CCentCt;yt aCf,CN WRt It COMP.tito catt 5000 _ _ ,, dover s!ChtDiCustomers Aeoresea November 9, 1983 Nov. 9, 1983 ) ( ,y I, the undersigned, have remonitored the above unsatisfactory conditions on: i 11711fg3 and found them: LJ Satisfactory EUnsatisfactory (Explain cetow) toeneo l E a- 1
,.
~~s See Attached.~~
~~f. C as~~
~E "82seo" a , Insp. S'it so ta scN 2 Reg. Mgr/sls Foreita 1 File Representative 11/11/83 >
~~se sasoecro<s j~~
*a ns ning us,a % /M _~ /
(j j
r-
')
~~y-2 . < DATE: November 11, 1983 HTO: Gordon Purdy FROM: Jerry W.-Lytle~~
~~SUBJECT:~~
~~Response to IM# 26,404 SIS Report #366~~
~~~ .~~
Response given, IM5 26',404 is acceptable except for the following: items:- . - (1) NCR'10,193S -LNon conforming condition as written by the originator states the fillet welds in cuestion "are full fillets recuiring MT/DT". Justification for voiding would be referenced to a procedure. Code inter-pretation, etc.. not an evaluation bv a Q.C. Lead.
, (6) The non' conforming condition of Rev. O of NCR 5803S was also changed by Rev. 1, not'just the disposition. .- (13) Response as stated is correct; however, this response does not address the problem as stated - i.e. , deficien-cies discovered after final accentance is a non conform-ing condition per Brown & Root Q. A. Manual.
(14) CD-QAD 11.1 gives direction to q.C. Inspector to write an Inspection Report (unsat) on everything exceot "N" stamped and final accepted items. This is in conflict with Brown & Roots Q. A. Manual, 16.4.1, which states (among other things) "a procedural violation shall be identified and documented on an NCR". (17) CP-OAP 11.1 - 2.2 states "Q.C. Leads will review Inspection Reports". Without their initials or some other device, there is no objective evidence of their review.
' Most, if not all, of the listed items were addressed to the ~ involved'O.A. personnel in the field, as exemplified by item 2 of the report. -Additionally, as stated on the original
~~report. the problems extend bevond just these examples.~~
~~4 (. .~~
~~# e . g ,,._,,-.,-e om~~
~~p,j.~~
~~$ DUwn& Root.hc.~~
~~INTEROFFICJ MEMO EIM# 26,537 December 5, 1983~~
~~M. Coats, LANI~~
~~~FROM: J.T. Blixt~~
~~SUBJECT:~~
~~CPSES, 35-1195 '~~
~~. Unsatisfactory Remonitoring On SIS #366.~~
~~Finding #1.~~
"NCR 10,193S - Nonconforming conditions as writtan by the' originator states the fillet welds in question "are full fillets requiring MT/PT". 'Justifica-tion for voiding would be referenced to a procedure, code interpretation, etc., not an evaluation by a QC Lead".
Requirement: . QAM 16.4.4 Voiding an NCR ". . . . he shall provide justification for such a disposition on the NCR, and shall sign for closure". Requirement: CP-QAP-16.1, Rev. 20, Para. 3.1.1.4, Voiding an NCR -
~~"....he shall provide-justification for such a disposition on the NCR and shall sign for closure....".~~
B&R disagrees with the inspector's. statement that " Justification for voiding would be referenced to a proced.ure, code interpretation, etc., not an evaluation by a QC Lead". In fact, if B&R did comply with the inspector's request, it would be in non-compliance with QA Manual Section 16.4.4 which inpart states "The QE, cognizant supervisor or higher authority may, during processing, disposition an NCR to state "Not a nonconforming condition" or similar. wording. He "shall. provide justification for such a disposition on the NCR and shall sign for closure:. Further, as required by the " Document Violated" QE-QAP-11.1-28, Rev. 22, Para. 4.4.1.1 (ref. " Nonconforming Condition" entry NCR #10,193S), "QCI shall evaluate all Class 1 fillet welds to determine if they are full fillet welds", and per the reply to Brown & Root's ASME code require #N183-092, the QCE's justification that "Not designed full fillets" is a valid evaluation of the code and procedure requirements. Thus, unless the inspector can provide additional references, there appears to be no valid committments to substantiate the inspectors Concern. Since~all of the'ANI's " specific examples" of NCR's being voided that should not be" -were correctly voided, B&R feels that NCR's are being processed in compliance with QA program requirements, but to alleviate any further concerns, the B&R Site QA Manager has by IM dated November 17, 1983, restricted the voiding of NCR's to the QC/QE supervisors and the Site Level
~~'III's. +~~
~~l 1~~
~~- - - -o~~
~~( t> . l ANI Finding #6.~~
~~"NCR's being revised by organizations other than the organization that orginally prepared them".- Example: NCR 5803S, Rev. 1 - Rev. O was written~~
~~! by. Welding Engineering and revised by the action / addressee (Engineering).~~
Requirements: QAM 16.4.7 "NCR revisions shall be initiated by the same organization _that performed the original preparation providing they have signature authority. .NCR revisions shall receive the same review and approval cycle as the original NCR".
CP-QAP-16.1, Rev. 19,' Para. 3.1.5.1 "....NCR revisions can be initiated by QE/QC, ANI or Engineering providing they have signature authority. NCR revision shall receive the same review and approval cycle as the original
~~NCR".~~
~~B&R Response Finding #6.~~
' N(3L 5803S_ revision was' prepared to correct the disposition of NCR 5803S, Rev. O. This revision was prepared by the engineer that made an error on his description of the disposition. -We find no evidence of a nonconforming condition being revised by other than the action / addressee.
~~ANI Response Finding #6. .~~
~~The nonconforming condition of Rev. O of NCR 5803S_was also changed by~~
~~, Rev.1, not just the disposition. )~~
i The NCR #M5801S, Rev. I was submitted to the individual who reported the i nonconformance for concurrence with the correction made to the condition de.scription. That individual signed the revision indicating his concurrence. l ANI Finding #13. i
~~" Inspection Reports issued after ANI acceptance of hanger packages. , Example: CC-1-SB-035B-006-3 I~~
CC-1-SB-035B-007-3 CH-1-AB-040-009-3 CH-1-AB-042-006-3 These were found during ANI re-review". Requirements: QAM Section 16.3.1: "The final acceptance of supports shall be performed by QC per a Vendor Certified Drawing / Design Review Drawing 1 (VCD/DRD) walkdown, including dccument review, in accordance with site. procedures. The final acceptance of the piping system shall be performed on an N-5 walkdown, including document review, in the same manner. ' 4 CP-QAP-16.1, Rev. 19, Para. 3.2.2.2, Nonconformances - When a deficiency
-which can not be resolved by an unsat IR or any deficiency related to an N-Stamped component or any deficiency sdrich is identified af ter final . acceptance of piping system or support in accordance with Reference 1-E (CP-QAP-12.1)-(i.e., Hydro Release or VCD/DRD walkdown including document review), shall be reported on an NCR in accordance with this procedure.... '~
CP-QAP-11.1, Rev. 3, Para. 2.3.2 of Attachment 1 - Same as above. i 1 i
o .- .. . Brown '& Root Response. The inspection reports addressed in this SIS report were written during August and September. During this time frame,-there was no QAM requirement that adequately addressed final acceptance and the. initiation of an NCR for this condition. lta October (10/10/S3) the B&R QAM Section 16, Para.
'16.3.1 was revised to clarify this item. Therefore it is felt that the IR's were correctly implemented and that NCR's were not required. -QCI's have received documented classroom training on this subject and are fully - aware of this B&R QAM requirement.
ANI Finding #14. CP-QAP-ll.1 gives. direction to QC inspector to write an Inspection Report (unsat) on everything except "N" stamped and final accepted items. This is in conflict with B&R QA Manual, 16.4.1 which states (among other things)
~~"A procedual violation shall be identified and documented on an NCR".~~
B&R' Response. Attachment 1 of CP-QAP-11.1, Para.1.0, NOTE: was written to clarify IR's and direct. reference to Para. 2.3.2 which identifys NCR's. In CP-QAP-16.1, Para. 2.2.1 and 2.2.3 will clarify this inspectors concern. ANI Finding #17. CP-QAP-ll.1, Para. 2.2 states "QC Leads will review Inspection Reports", without their initials or some other device, there is no objective evidence of their review. . B&R Response. .
1. CP-QAP-ll.1, Attachment 1, Para. 2.2 requires in part, that: The QCI shall obtain the serial number for an IR from the QC Lead. Prior to assigning the IR number, the QC Lead shall review the IR.....

2. G.R. Purdy's IMf26,019 additionally requires that, "at the time of assigning the serial number.. ., the responsible QC Lead shall also assign the applicable deficiency trend code... and document the trend code in the comments section of the IR log".
Therefore the objective evidence of. the QCL's review was the IR number itself on the IR and the trend code indicated in the log and on the IR itself.- But to help porvide the " objective evidence" requested by the inspector, the QC Leads have received additional instruction to initial the trend code'in the IR comments section.
l
~~.,.... s...~~
4 It is felt by B&R QA Management that with better communications between ANI and B&R QA personnel, the type of concerns addressed in this SIS-Report would have been corrected or resolved prior to the initiation of many reports. Should you have any questions in regards to this response,-please contact me at extension 459.
~~/ !~~
3
/
~~( - J.T. Blixt QE Group Supervisor JTB/bm cc: G.R. Purdy R. Siever. G.L. Morris, Jr.- S r ('~~
~~s. , .~~
[
v, *
~~SIS RECORO FOR MONITORING Q AdQ1C. PROGRAMS - CASE EXHIBIT N0. 1,051~~
' - - e sis.:i Au i s.ouO s 1 ti.ut stols.itu Inst'su: TION and INSCHANCl! COMi*ANY n w t i . mi . . . w e . i n i i . i..: .:: =. . . . . .:=.= :=.= - . . -
~~4369 u.m i sntu 5 Mr. Gordon Durdy, Site. n. A. Manager~~
, o, E . ., . . . ve-an, uve Sf - IInsIe's'a'arn ; Nov. 9, 1983 - !1 l 2 i !asfistce ce erwts.= c6ere. Itat330 mat use omtri l Follow-Up -'
~~G,g , e Brown v nimeaama & Root, Inc. . Wo_u_s. t;o n Houston . . .._. l Reevired "C3d g .r~~
~ . . Field , , Reparr/ . . . ,
~~CDSES (:len Rose . Texas . p X Assenibly '~~
~~. J Altuation JHwWee~~
~~1. the undersigned. have monitored your QA/QC manual on: 11-9_-8 3 ._._ ._. and find the following sections:~~
~~. c. s s.,. - ui.e . .----.---'O.2L-.--..~~
~~Satistactory:~~
~~-i encent*tr tJA QC .an .:o seco.on (No and rotse } On noentsty one noecos.e noncentermso ce as aconcaotes X Urisatisfactory:~~
~~Section 17~~
~~'E v. =','*-~~
e => EO-o= a OVER e" l CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, i dit2 for completion of corrective action, so that items may be remonitored by: 11-16-83
~~,I Pliase keep the Original of this form for your records and return a copy to inspector named below.~~
~~asrawi.on~~
' soco susa inso.e, ,a f 3 Reg. Mgr presantative YF e '11-9-83 l' cart seta h f _4"4 ,
~~i. etsoture or raost utus otsca:sto aset as st.ac casarissacron ecoar.nvo on a. ,s s. ..e m.cus, I~~
gg . . . . . m_. . - - . . . -- a5 , _ , _ . _ . . , .- 23 EO u= i L 'OVER
- cars coattrivt acre weit et cowitrio part soro scita r c., , ., , a..,u.n, , ., ) )
fl. th3 undersigned, have remonitored the above unsatisfactory conditions on: and found them: , o.r. , Satisfactory Unsatisfactory iEnotano catows e --- - - - - - - - . - - --
~~-~ -~~
~~U' 3 ?$. ' _ .1~~
^ $15 foreign ~
~~inso. $:d'i~~
~~8' I seso eass .ase.ero,.~~
~~Ret Wr i IeDresentative frie~~
-===.-- fh 4 ett il '8 .A \
~~., . r , ,. SIS Report #369 Dage 2 of 2 1~~
On 11-9-83 this inspector was requested to witness visual examinations on Class I hanger CS-1-112-720-C41R. Upon verify-ing material, it was noted that the attachments do not meet the requirements for Class I attachments. Heat # 28550. Due to repeated identification by site Authorized Nuclear Inspectors as evidenced by referenced SIS Reports, the corrective action'takenby Brown & Root has not resulted-in'the correction ' ~
~~of this generic problem.~~
~~FSB 939 - 360 932 002~~
~
932 002A - 9 3 2 0 0 2 -l'~ -- ~ ~ 932.- 9-002-2 , 932 002B e
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~~_- " 27.'.~~
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e
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~~=- -~~
~~_ , . nw _ , ,,~~
'N.W7 . SIS RECORD FOR MONITORING Q1AdQ.C. PROGRAMS \" TIIH fIARTFORD STEA31 DOILER INSPECTION p.nd INSCRANCE CO3tPANY im/rnmn comern:cr a,auc ~ /'
~~369/B Response~~
~~, a ,mn. .ac r.ai.,~~
~~tais - smets~~
, cr igi Gordon Purdy, Site Q. A. Manager Feb. 1, 1984 1 1 5*
~~oM c'gsicutel Cou'an, navt ness saancu 1~~
~~nsP etcron Ce rosto COUnrav 14tcecuat ust oNtri g~~
~~ug B rown & Root, Inc. Houston r-Follow-Up -~~
-Required L CI'5'd ins *tcTC= tcC28C' Houston _ - Field Repair /
CPSES Glen Rose, texas Shop Z Assernbly Alteration Interve e I, the undersigned, have moritored your QA/QC manual on: 2-1-84 and find the following sections:
~~o. ,. ,~~
ra. u .. .,,a r.si. o satisfactory: Section 17 Corrective Action taken in I.M. 26,729 is acceptable and closes this 939 isa. a.,y oaioc ..a..o enu.o,, p .aa r.ui.3 on ,a.aa,r, as . .o...r., ,,,,,. ,s.,,,,.ac. ., .oor.a..,,, L Unsatisfactory: a
~~'l o~~
hin 5E ea i; Um/J LY i 3 JV-( bt 95N ! J _OVEr
~~..' CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, an data for completion of corrective action, so that items may be remonitored by:~~
~~ro.res Please keep the Original of this form for your records and return a copy to inspector named below. 3'i""C " /$l$ Foreigs "'i 5*ED~~
'""'"'"...,m - insa. *(3 '"8 XReg. Mgr/ Representative L.X File 2-1-84 h [Q ('
~~etsotunca os r,,o:t irtus ctsca.ata ascyt as stinc unsai.stac:cav rcoar,a.. e,, a. .,,e s.a., c.n.,rs ae aa 8~~
~~,OVE:~~
pri (cutctvt acnce wu et Ccurttito cart soto soto rcoaro.., n.o,.ua,.,.., f 1, tha undersigned. have rem 0nitored the above unsatisfactory conditions on: and found them: s o.,.s U Satisfactory CUnsatisfactory(Erplain cetow) i 8 . h 1. as
*)
~~3'5',s.euno' j$l$ Foreign cart sota y lnsp. soto ,wsa sa.owsoas~~
~~~ Reg Wgr/ Recresentative L File .,~~
~~h n,.... .~~
~~.- /~~
~~w ~ .,r x,.wa u ww mm -- amm6&JL4%hn:&nEW 422 .MQ x.n. -~~
~~.auwnCrR6ct.inc. .~~
~~INTEROFFICE .'i.M0 - {..5 IMU 26,729 January 26, 1984 M. Coats~~
~~. . . .-70t v~~
~~FROM: J.T. Blixt~~
~~SUBJECT:~~
35-1195, CPSES SIS #369B. NCR 12,542 was written to identify that Heat #28550 was used on hanger CS-1-112-720-C41R without meeting the requirements of N3-2121 for Class 1 material. In addition, Mechanical QE will perform an indepth search. both manual and computer, for possible usage on large bore and small bore hangers. If any discrepancies are found, they will be addressed j on individual NCRs. Further, B&R, QE and Receiving QC will review / annotate the " Heat Number-l Log" and the heat number card file (originated in accordance with ' CP-QAP-8.1), to include both the ASME Subsection (i.e., NB vs. NF) and the ASME class for plates only. This will include revising Para. 3.12 of i CP-QAP-8.1 to require including applicable ASME Code Class (i.e., [.,l NB-Class 1 or NF Class 1). ' J.T. Blixt QE Group Supervisor JTB/bm cc: G.R. Purdy R. Siever G.L. Morris, Jr. QA File t i, e U ' e
f-i s ' SIS RECCIID FOR f.iCUITCrill!G QJ../Q.C. Pr.0GRAr.lS
~~& . . M[ THE HARTFORD STEAAt 110!! EM INSPECT 10N and INSL*RANCE COAtPAST CASE EXHIBIT 1.052 F~~
Hun (86tp CmV.(mGtfr ni.sc ,,, , so,~n L t s,e . e u. -. .ae r . l cas. -
f
, . ,', h Mr. Gordon Purdv. Site O. A. Ma.neer i.e 6aana. .Oc-ebe M . loE? , ass. pI;;.cn on roato cou :a. i, ass,ona. us4 on.r; "M i cc:et r; c: men,. amas't - * .7ollow up E *!
I-asewee---Clas** g ,E i Brown T. Root, Inc. IMouston lHensts. 6* - a "*6:'a* N'L* g _ i eid - aemair - Glerk Rese . Te::a s 76043 I J 38ies LAsnmely waiteration linsernca l CPEIS b e and find the following sections: ti e 1. the undersigned, have monitored your QA/QO manual on: 10 /2 5 ;/E 3 c ... .
- l 1 ,
~~1 eo. m. aims , r.s . 4 Satisfactory: I 1 c~~
.ew, c,s. 2 m.m o< .na.n.emen.. u ..e. swr .h . eu.a . ~. . t.o.) on wenwr em .
~~1 . E unsaustactory: Se : ion 17 Corrective Action s. d u~~
~~.I See Attached I o .i~~
~~S ei s30;s:~~
$ 7; ._:0vtR i ! CUSTOMER: Please describe tne resolution of these items in tne " CUSTOMER'S RESOLUTION" section cetow, and give
~~{ 11 ' E .'8 3~~
. i date for completion of corrective a: tion, so that stems may be remonitored by: noew I Please keep the Original of this form for your records and retu n a cc:y to inspector named below.
~~1 sir.mte ,,ess asse.cs.,,~~
~~~7 M s~~
~~c staessinon j 2.. utr!!',5 'a','&, M't 'aa!!lo/31/e3 p.t a ,.. sw..,~~
~~!b Aw R~~
~~sisw.: w w i. ion intia: otsca.u: a on u um. w.3 i:vconi ,c g~~
~~< 1 /~~
~~r, i i y_ :~~
~~! As verbally dia. cussed with the inspector on November 2, 1983, no response ,,; necessary. !! =! '~~
aI
~~.I i-e, Ovi;:~~
~~omia countasi e:a u n con.e.ou. , sou, ,c m . n..,.~~
' jnart sau N/A i November 8, 1983 i) .s ~
I
~l1. the unoers!;;ned. have remonitored the above unsatisfactory conditions on: ' 2.n.,
lena found snem: s uu.cery aun..uit es ry is,o,,,a e.,.wi i 5Ej ia i NE i E l Tau = , sis so.. .. _i.... o ri scu. ; see -2. . ...,, i n.s usela.m s,.i.im. '._ % 3
.i .w oper esi 1 l ) - - - . ~ . _ . _
l l
I. '. N -
~~'j' ' , SIS Raport i 367-A Paga 2 of 2 g , -j .~~
~~t t~~
~~Since SIS Report 939 6 367 was written, the following g NCR's have been presented for ANI disposition concurrence.~~
They all have Class 2 material, or material that is not

certified to any Code Class installed, on the following Class jl I hangers.
u k (1) ll,294-S Hgr. RC-1-072-703-C41K HT 41688 RIR h 16312 RIR is unable te be located by PPRV oersennel, f (2) :ll,299-S Hgr. RC-1-161-001-C81K HT .4giuks00'PPRV personnel is unable te locate a RIR for this 4. - (3) 11,337-S Hgr. RC-1-035-704-C41R HT 41688 Same as (1). (4) ll,296-S Hgr. RC-1-018-016-C81K 80lP05170 R!F 17061 Class 2 with CMTR. (5) 11,297-5 Hgr. RC-1-052-019-C41R 80lP05170 Same as (4). (6) 11,293-S Hgr. SI-1-026-710-C41R 054302 RIR 14508 Material not certified to any Class; contains CMTR enly.
~
(7) ll,301-S Hgr. RC-1-146-001-C8'is 054302 Same as (6). (8) 11,338 Hgr. RC-1-163-009-C81S D27580 RIR 18530 Material not certified to any Code Class C cf C does not list type & grade of material. (9) 11,295-S Hgr. SI-1-090-08-C41K 801P05170 Same as (4). (10) 11,343 Hgr. RH-1-001-010-C41K 66190 RIE 17036 Class 2 with CMTR., (11) 11,344 Hgr. RC 1-161-005-CSlK 66190 Same as (10). (12) 11,345 Hgr. SI-1-182-007-C41R 69E706 17036 Same as (10). t O e W e4 e
~~" '*" **w . m. + ,,~~
G
~~- e~~
.] , 5.: T.ECOT.D TCG ffCEiTSTJG3 Q.A./Q.C. PG0 GRAMS T ;.M; a "" . . F t.1G I * !tD STEA.%1 ault.'JR INS! ECTION and INSCRANCE CC.%1PANY * "* * > : . er:: . 4. .s .1:ca int. r mic i
~~die-e'~~
,c --- f,-- ** ~ ~~ - , cars i .nt - , or *4' ' . * ~~ J ~ r _::. 3:.: -97. Site C.'A. 'ta.are- ;S-t-ba- M . 1 9
L

3 7~' imp e%n =; aga m vi . cat..s ... .ar . Aia.J a .a. 42 Ja sg
~~.1 1 - h ac=-tg **c.~~
~~y .~~
~~t. I:0, . : M S'2 5 *' S n M-"at-- - A t r. **8 **'8~~
~~..;E* - - isate - assaar. -~~
~~b **?* G*6. Rs e . "'e M a ? 08 : e e ry -Otuation JMm8 h.h <~~
~~. ; . r e:. ..a.e mcnitored your QA/QO manual en: 10/25/93 c .,. .~~
~~and find the fellewing sectic.ns:~~
~~! c.. . . i .,~~
~~e ..,...,. v 1.0~~
;-l . -- -- ..-...............,..r...--.-....-.. ' Se: tion 17 Corrective Acti:n r.
4 2 . 1 .t - See Attached: 5 e:= i =E. [ Scheduled monthly monitoring g . N _ t ]OVER s* - CUS"* *.,M it:
?' esse ces: :be the resolution of these items in the " CUSTOMER'S RESgLUTION" 1/8/83 section below, and g've .k *
~~e : ::-:ie:::- c: :=rrec:ive ac: ion, so that items may be remonitored by:~~
~~. Crease nes: *ne Orig .a. c':nts form for your records and return a copy to inspector named below.~~
~~ut a c l:.sais,as -.- -,~~
~~. : < i. .,. r.oteir' - se:s. )_~~
~~ma.aes. var. a.::::. isu.. .Z.ra. 10/25/83 i p . ho~~
~~.u a s .: w. :c.n.: ..t e u : v wsem ,c a .. s . ...mn e~~
~~s I See a:: ached IM i 26,407. l~~
~~.i 4 "E3 s=~~
25 . u'II : - .-
~~ovER cut .:n:: w . . -2 =t r.mn inus so.as m.,,... .. -~~
~~ll > soc . c . , .~~
~~' // / it.,lE ~$ \ // /d D (~~
l 1. the under ;ir,ned. *tave r'emonitcred the above unsatisfactory conditions on: i ._ _ e ~ m ra. .:
~~, and 'oi.;ne : .em: _ $atisf actory L Junsatisfactory tfralain eetows E~~
~~i G ::~~
=
~~> i E t~~
~
~~l 1 l s1;5 fo'e in _ insa. ' f *it "N so.is eass .a. mise, i , ' M* s.~~
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~~9.sf 5.ntative .w teg e~~
~~Filel _ s~~
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ri l ' .' ' sis .:.3:::: d267 l i Dago . :f 3
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1 l (1) S-55, S-56-R.1 l i These CAR's were not vcided in acccrdan:e with this Section of the C. A. Manual. l,
) Material Discrepancies h (if NCR Mll,284-S Class 2 bciting material y* installed on Class 1 hanger RC-1-075-054 C61P.
~~(2) NCR Mll,236-5 Same as abcVe CS-1-080-002-C41S. N w~~
~~!3; NCR.Mll,237-S Same as above RC-1 087-004 C31K.~~
("t .- There have been several NCR's issued identifying Class 2 tr.i 3 material installed on a Class 1 item or system. In these
~~}f -~~
~~ss as he material was issued from the warehouse and a Level I g :n.i ector signed saying the ccrrect material was issued frem the~~
~~,. Ireneuse and installed. To this date, no Corrective Acticn has * !!!n taken. ,, (T)~~
~~See: ion 17 states the ANI will receive copies of n Corrective Action Recuests. This has not been comelied g -~~
~~with. R . O 4 h wa~~
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~~3AII: ::cve=ber S.1933 s~~
~~!.: M. C:a:s i .~ .2:: J.T. Blix:~~
d
~~; !*.*1:207 : C75ES, 35-1195 SIS Leper: #367.~~
~~1 I"~~
~~n response to :he inspector's opinion thst ".. .there is no objec:ive h evidence :hn: any correc:ive action has been taken as prescribed in :his~~
[ 5-:: ion (17.2) of the QA Manual", Brown & Roc: feels that :his inipector - has not eseprehended the intent of the first paragraph in See:1on 17.2. Tha 3rown & Root Site QA Manager, has documented his " review of identified . nen:nnforming condi: ions" in the Quarterly Report "to decernine if significant conditions adverse to quality" exist. Further, as stated in
!=::ica 17.1 Scoce: "This section establishes the methods (plural) for 2nduring that conditions adverse to quali:y are promptly evaluated and repor:ed". Only those "significantly" adverse conditions which are identified as such by the Site QA Manager's reviews will have a CAR orepared. All others are reported to the appropriate levels of manage =ent "via IR's, NCR's,* CMC's, DCA's and the causes of the conditions are correc:ed".
a= A These figuras are correctly copied off of the last Brown & Root QA Quarteriv Repcrt furnished to you as informa: ion only and since the inspector has not identified a specific unsatisf actory ice =, B&R must assume that no response is required.

2m B Inspection Reports QAM Section 17.2 - A documented review of 'dentified nonconforming conditions
^
(i.e. , IR's, NCR's, CMC's, DCA's as delineated in Section 16.0) shall be ac:cmplished by the Site QAM at least quarterly to determine if significant c condi: ions adverse to quality are developing and to further assess the adequacy of the QA Program. . 16.3.2...."These deficiences are identified and documented by the QC Group en an Inspection Report (IR: Ey. 16.2). These Inspection Reports are logged, issued to applicable construction discipline, and tracked by the QC depart-
=ent. At the end of each quarter, the QC department will forward a copy of the IR log to the OE Groun for Trend Analysis". If the inspector had inf::=ed the QE Group that he required the trending results, the trended c v of the IR log would have been =ade available for his review. I: is th6:afore requested that as a courtesy, 3&R QA/QC be offered the oppor: unity
s a: lesst p:cduce the back up material being monitored prior to receiving an 'Jnsst SIS 939.

1. Auniliary Building Task Force shows no trending to determine the cause of discrepancies. Examples:
~~a) SW-3-173-702-A33R Unsst IR #10 1 - C-1~~~
~~'c ) CC-1-EC-007-011-3 Unsat IR 1 5 6 - C-;s c) CS-2-038-007- A5 3R Unsat IR #:1. - C-16 & C-12 d) CH-2-AB-024-CCS-3 Unsat IR 0307c - (this quarter)~~
I i a 4 -- e
G......~ 3* . .'. a .--
~~, 2. .~~
~~t..u.ed Tazk For:e AT '. CG4-0C3-!"2R ':nss: IR #.212 - C-16 _g :i . -00 7-019- 5-.O R '~~
*~nsa: IR f '072 - C-16 L / C3-1-52-043-C0!- Ensa IR fills - C-16 Unsa: R #1260 - C-5
~~[ :i A7 *,-102-011-5332 fi~~
~~2. 7. '3~~
,, a) MS-1-150-0!.9-Cf2K Unsa: IR # 19 - C-ll . :) CS-1-R3-006-003-2 Unsat IR f 3 3 - C-16 5 c; RC-1-075-053-C61R Unsat IR ! 14 79 - C *.6 h* RC-1-075-053-ChlR Unsa: IR ! 104 - C-16 ') SI-1-CS9-009-C41S Unsat IR d 2195 - C-16, C-11, C-20 F . .C. ef :he examples above were trended (as shevn) in the Quar:erly T- - - ! . !?. *ag maintained by the QE Group, except foi #3076 which was iniziated f durin.3 the present quarter.
~~J e g Tha inspec:or's statement tha: "the unsatisfactory inspection reports are t ne: : rended to determine whether original faul:y inspec: ion or a design~~
~~! . :hanga triggered the follow-up unsatisfactory IR", is not tetally correc:~~
j sinca 319 IR's were logged against category C-5; that is "Dvg/ CMC (incomple:e' ls ine r ec:)". The inspec:cr is partly correct, in that some of these "unsa:' II's were written af:er the items had been acceptably signed off by the [ A':~'s and as such should have been trended as C-28, that is " Inspection / Surtuillance". The inspectors opinion that "There is no objective {
! evidance that QC inspec: ors are monitored to assure adequate inspections ! are being performed to reduce the nt=nber of NCR's generated for velding ,} discrepancies", is without merit.
~~e ' e i Contrary to the inspector's misconception, the performance of QC inspection~~
) personnel.is evaluated semi-annually by :he Site Level III's. Fur:her, j the Si:e Level III's have the authority and responsibility to revoke or & suspend' certifications when sufficient reason exis: to question the
~~{ individual's performance or capability. To date the ANI's have not iden:ified specific persennel who they feel are increasing "the number of~~
~~. NC?.'s generated for velding discrepancies", and since per QAM Section 20.4 C~~
~~y "The ANI shall be given the opportunity to reinspect and verify satisfactor'/~~
# . completion of the disposition prior to closure on the Nonconformance Report", it would be assumed that "the ANI's dated signature on the NCR" f . veuld substantiate this. The Level III's validate NCR's initiated by a d Level II after another Level II had previously accepted the item.
~~g NCTI: There is not nor has there ever been a requiremen: in the QAM Section 16 or 17 requiring " monitoring" QCI's to assure adequate inspections are being performed.~~
c . C

1. Thf s is a correct statement and is closed based on idiI remonitoring. .

2. ?TRV Log is not showing any CAR's after S42. S-43 thru S-56 are f*. led in :he book". QAM Section 17.0 does no: address F?RV and would i e ou: side the scope cf this see: ion of the CA'4. A: present BOR has no raquirements for monitorine; a PPRV Log for informa:icn or any c:her ecson.
~~" - .;.:: 4.t?~~
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i. . *tc ic rect:rs stati=cn: :hs: '.'Thsre is no NCR Coordina::: :o mzin::in b .!.a O*.: L:;", is corre:: bu: since JAM See:ica .17.2 (10/* 0/53) s:s:es N !!- da*.ity Ingineering (OI) Grcup. : hall ma n: in a . 0i_1.*.03 (I.nhibi:
~~( .'7.1)..." Brown & Rco: is sgsin unable to identify a spe:ific uns:: ite:~~
~~,'., :: take:a response to.~~
1
'J *** 3 .. '.*:ided CAR's S-55 & S-56 R.1 }[ . 3rown & Root disagrees with :he inspec:crs ocinion ths: ~!hcsc CAR's
9. sare no: voided in s:: rdsace with this sec:i:n of ::e "u'.. As j pieviously stated.in respense :c Mr. *.*.0. Ti".1=an's '_e::er :a:ed 4 Augus: 3, 1933, " CAR 5-5o R.1 was never issued as the 12 4 :f :he E . I:-AM's signa:ure would indicate", and CAR S-55 was c:::c- 17 veidad per

he require =ents of the revision in effect at the :L:e.
e= I ,
~~The opening statement is the only par: of the AN1's pers:sai ass ==ption~~
~~hs: is true. It would Qppear that he has not researched.c==: ehended~~
. :he NCR's (even though he signed them), oecause these NC1's *# --y "cciar c:ded" materials incorrectly applied, not incorree:ly issued =a erial.
~~The criginal nuts we're correctly issued on MR's No. 2020!*, li;TOS and 1030c3 for installation on their respec:ive hangers and were rerlaced by~~
~~he craf: vich the incorrect color coded ones. The inspe::::t -1:si:g~~
,- s:a::sent that, "..~.no corrective ac: ion has been taken"; is very =1sleading since NCR's have been vricten in each case. But if the insee:::: is re-ques:ing a CAR rather than just corrective action, B&R feels -'-- -his is nc: a "significantly adverse condi: ion". -
~~I:-tm F This inspeccio~n ::atement that "Section 17 states the ANT vill receive copies~~
- of CAR's" is correct. But the statement that this has not be== ce= plied vi:h is incorrect. B&R has and vill continue to distribute cc:Les rf CAR's as required by Section 17.2. Further, since no problem cf -'d =
~~na.urs was identified by Hartford CPSIS Audit of July 13, & 14, l?! , B&R must assume that again only this inspector " feels" this is ==r being complied with.~~
~~,In closing, B&R must re-iterate that as demonstrated in the above responses, if tne inspector had, as a cour:esy (if nothing else), offered B&R CA/QC~~
~~he_. opportunity to at'least produce the documentation being scu tored, prior to being " blind-sided" by and "Unsat" SIS 939, alot of :i=e ar.d er:ense c:ald be saved. _~~
./
~~Sheuld you have 'any question or if we can be of further assistance, please do not hesitate to call G.L. Morris, Jr. at ex:ension 743. __ f/ 9 J.T. Blixt~~
. !! ":= . _ QE Group Supervisor .~; ::.3. Tillman 'O.R. Purdy ,
~~T. Siever '~~
~~+ C'L. Morris, Jr. ,/ . /~~
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._. ' . T*SIS RECOP0 FOR MONITORING Q.A./Q C PROGRAMS !!E HARTFORD STEAAt BOILER INSPECTION cnd INStJRANCE COAIPANY H AZrFORD, CONNECTICt.T 06to2 - CASE EXHIBIT N0. 1,053 367-B ro ru. e .., r,u., care setti , Gordon Purdy,. Site Q. A. Manager November 18, 1983 1 lor 5-f)g cusrcutes Coura=, naut asp. sua mse nece ce santa counrar ras g L'ji gguss car.rJUCloS*d gg We, Brown & Root, Inc. douston Houston Reauired asp CION LoCArem Field Repair /
CPSES Glen Rose, Texas 76043 UShop '2 Assembly CAlteration laservice 1 the undersigned. have monitored your QA/QC manual on: 11/18/83 and find the following sections: ro.re, ocae numeers na r,usus _J Satisfactory: _ r oaioc m.auar sur,an (no. ana r,no} on seenury une son,1,e noncentara,ence u ecos uw.o creeau,r LX unsatisfactory: Section 17 Corrective Action See Attached E -.
~~-= @R Eu a~~
COVER f- CUSTOMER: Please describe the resolution of these items in the " CUSTOMER'S RESOLUTION" section below, and give t dite for completion of corrective action, so that items may be remonitored by: December 7. 1983 uoares Pl2ase keep the Original of this form for your records and return a copy to inspejtor named below. cart soto soco russiasow s laer. oisteugrsura /Eares'[n:'a"tue 3 '"I / F 11/18/83 nscu,ro os n, cst irtus ccscosto aseve as uinc unsar:sincica oc.or,,u. no..ru s....rneuwr/
~
~~G w CE E5 See attached IMd26,589~~
$5 Su p p dover cart ConetCrivt ACTION WILL se CCMPleita s3GNe aao e ' entarme 1/15/84 oArt 11,slGhen/2s[83) ([rcus o y 1, the undersigned, have remonitored the above unsatisfactory coriditions on: f /(, fyy- ! / roares and found them: Satisfactory Unsatisfactory (Explain Delow) h CM_o> Jh & M / 0J' Sdd'rJ hew) s'7 W G u l .
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~~SIS Rsport 367-B~~
'Page 2.of 5 p ; Brown & Root's response to 939 nos. 367 & 367A is not x acceptable. It should be understood that the Authorized Nuclear Inspector has.a statutory duty to. monitor the Certi- .ficate Holder's program for. compliance. -The above reports were initiated by virtue _of the Inspector complying with this mandate..-I cannot comprehend the animosity and-face-tious of~a_ response that makes reference to the Inspector's " personal assumptions"~,." misconceptions" and " blind-siding".
It should be understood that a 939 - monitoring report is-not an " indictment" of Brown & Root's program but is a re-quired-mechanism for the ANI to assure full compliance with. ASME-quality requirements. While the above reports were not written in1the context of'," findings"fof noncompliance, when one examines the impact of the items identified on Brown & Root's programmatic com-pliance with ASME Section~III, there is cause for Inspector concern in the. area of corrective action. Inkthe future Authorized Nuclear Inspectors.will initiate monitoring reports in a format of " Findings" and " Areas of Concern". ~ This should provide clarity for necessary responses, f' The above reports contained both areas of concern and findings. These are r'eiterated_as follows: FINDING: ASME III NA-4800 requires that " conditions adverse to quality-be promptly identified _and reported". Additionally " measures shall assure that the cause of the conditions ' adverse to quality be determined and corrected to preclude repetition". The identi-fication, cause,.and corrective action shall be documented". .In Brown & Root's response to 939 # 367, it is stated that "The Inspector has not com-prehended the4 intent of the first paragraph in
~~-Section 17.2". It r4.t be noted that the use of the term "significaat' is Brown & Root's own. The above Code parz a'ev a kes no mention of this term.~~
An identified ci di t ,- that renders' hardware or supporting docuteentation unacceptable for ASME' certification l's in every case significant. The aforementioned response also states that "All others (conditions adverse ' i quality) are reported to the appropriate levels ot ianagement via IR's, NCR's, CMC's, DCA's and the causes of the conditions are corrected". This is erroneous in tha? the noncon-formance is corrected by the above documents but
' the cause is not addressed.
s
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P. l SIS Report #367-B (- Page 3 of 5 FINDING: In items A & B of 939 #367-B the Inspector noted the volume of NCRs by condition as listed in' Brown and Root's Quarterly Report. Additionally,'he. listed examples of IR's that, in the manner trended, did not identify the cause of the adverse condition. Virtually all the NCR's and IR's were initiated on reverification inspections. The cause can logically be attributed to one of three (3) circumstances. (a) Inadequate design drawing and/or interim design change (CMC). (b) Inadequate inspections on initial process-packages. (c) Further work or damage incurred between initial
~~(, .~~
~~and reverification inspections. s. It is difficult to understand how 1727 identified~~
' welding discrepancies are not deemed significant enough to warrant corrective action to preclude repetition. . 1
~~,; .p . . -~~
e .*. p.. SIS Report # 367-B t- Page 4 of 5 f b .
' FINDING: The Inspector identified three Class 1 supports that_were installed with some items not accept-able_for Class 1 installation. He subsequently identift'd twelve additional supports with like noncontormances. In addition to the NCRs identi-fied, the Site'ANI's have repeatedly identified nonconformaning Class 1 piping attachment material installed in tne field. In. addition.to the above, it'has been necessary for Engineering to reconcile.
Class 2' pressure retaining material in accordance with NB-3673 after installation in Class 1 fabri-cation. In addition- to the above, the Inspector who initiated 939 #367 has previously identified non conforming Orifice Flange Plugs installed in the field via a previously issued 939. To-date, , there has been no documented determination of cause nor corrective action to address issuance of nonconformanby material to the field for-in-
~~.stallation.~~
~~hAREAOFCONCERN: .~~
~
('- The Inspector stated that "No objective evidence - exists that Quality. Control Inspectors are moni-tore] to.. assure adequate inspections are being
' perturmed to reduce the number of NCRs generated for welding discrepancies". .This statement was keyed by the fact that hundreds of welds previously accepted have been rejected by NCRs and irs and subsequently trended in category C-16. Brown and Root's response states " Contrary to the Inspector's misconception, the performance of QC inspection personnel is evaluated semi-annually by* Site Level III's". There is no misconception on the part of the Inspector. The Site ANIS have no knowledge of documented evaluation of MIFI/VT certified QCI's.
Brown and Root's response that " ANIS have not.iden-tified specific personnel...... Note: There is not nor has there ever been a requirement in the QA Manual requiring monitoring'QCIs to-assure adequate inspections are being preformed". The Inspector felt that considering the documented rejection of hundreds of previously accepted welds, Brown and Root QA would be sufficiently concerned to evaluate those previous inspections. r-
~~%J' .- . . ,. . .. _ _ _ _ . . . . _. ._.. _.._ _ _. _ _ _ _ . . . . . - . . . _ , . ~ . . _ . _ _ _ _ . _ _ _ _.~~
~~F ** - , Y ~' l ' ' '+~~
~~' ' SIS Raport #367-B Paga -5 of 5 i .~~
~~C/ AREA OF. CONCERN:~~
-Brown and Root has chosen to utilize a program of Trend Analysis to implement the requirements of ASME Section III, paragraph NA-4800. A review of all CARS initiated this calendar year (S-53, S-54, S-55, S-57) reveals that S-54 was initiated by an ANI monitoring' rep'rt, o S-55 by a TUGCO audit finding, S-57 by ANI monitoring report /932 SIS Re-ports. It is not considered by this Inspector that the only mechanism available to comply with NA-4800 is a Corrective Action Request. However, I can find no viable alternative in Secti'n o 17 of the QA Manual. It is also recognized that at times Brown and Root Q.A. has utilized Procedural revi-sien to effect Corrective Action. Again however, full' compliance with NA-4800 is not evident in that cause and resultant corrective action is not docu-mented.
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, . . INTEROFFICr. KEMO -IM# 26,589-I- -TO: M. Coats- December 27, 1983-G'.R. Purdy FROM:
~~SUBJECT:~~
CPSES, 35-1195 Response'To SIS Reports 367 And 307-B. Although the subject reports .specifically identify three(3) findings and - ' two(2) concerns, I interprete all items to be generically addressing the philosophy and implementation of.the B&R Corrective Action Program. After reviewing the data collected to substantiate the findings and concerns, I
~
~~can understand the resulting conclusions. To establish a permanent record for ANI-ASME reference, the following-is-submitted for your review and acceptance:~~
1. Implementation of an effective " Corrective Action Program" in accordance with NA-4800 requires the effective implementation of an acceptable " Examination, Tests, and Inspection Program' in accordance with NA-4500.

2. Due to problems encountered by B&R QA, the NRC and the ANIA, the " Examination, Tests and Inspection Program" began an
( ~ evolution of upgrading in early 1982, to establish conformance-with " todays" environment and criteria; the current procedures are the result of approximately 15 months of evolution.
~~3. The large number of NCR's and/or Unsat IR's is'the direct result of the corrective action taken to upgrade the " Examination, Tests, and Inspection Program":~~
a.) The cause of nonconformances is indicated by the numeric designator in the trend code, as defined on Attachment 4 to CP-QAP-16.1. Should further investigation of an apparent trend warrant additional action by QE/ Management, the " root" cause and corrective action are documented in accordance with Section 17 of the QA Manual; b.) The QE organization determined during Trend Analysis that the cause.of the nonconferming conditions were the same causes which precipitated the program upgrading thereby not warranting. additional corrective action; , c.) The items rejected during final acceptance inspection were predominantely pre-1982 fabrication and installation activities, and not subjected to the current acceptance criteria; and d.) The greater that 50% QC rejection rate for pre-1982 work as compared to less that 10% rejection for post-1982 work indicates that not only is inspection being properly ( conducted but that the action taken to upgrade the program has 6recluded recurrence. w vsw1 me r i--gw ,-,---y,,-w mw-=-.~.w,-- ..w w - u iterw m e% e- ee--v+--+,---+ww--e-a-cree **w+a-e--ee-e-est=++-ee-wwww-=-e-e-s--crm- vn *w--,v e s er e r -e---emy-,-e _.--v-w w--*+-cr-
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~~4. Following Laplementation of the "UnSat IR" program, the trend ,~~
, analysis.for these documents was inadvertently omitted from the following Quarterly Report, although the evaluation had been conducted by QE, and had to be issued as a supplement.
5.. A proposed revision to the B&R QA Manual will be submitted to the ANIS for review by 1/15/84, which will identify alternative methods for documenting corrective action. Should you have any further questions, or if I may be of further assistance,. please do not hesitate to contact me. s u M . Purdy Site QA Manager GRP/ba cc: W.D. Tillman J.T. Blixt R. Siever G.L. Morris, Jr. ( SQAM File M 6 4
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SIS REPORT. THE HARTFORD STEAM BOILER INSPECTION and I.%URANCE COMPANY ( { E E M B H NO. 1,054 HAu n.oun, ansarrurt war: 10-030 TO: OATE SHEET OF
. Cordon Purdy, Site Q. A. Manager Jan. 5, 1986 1 'l ._ [FRud: ti.O./8 RANCH OFFICE Marvin-Coats, Lead ANI Houst'on CRGANIZATION Brown & Root, Inc.
LOCATION STREET CITY COUNTY STATE ZIP COOE CPSES Box 1001 Clen Rose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME AND OFFICIAI. TITLE) CONTRACT /P.O. NO. 35-1195-0561 AEASON FOR VISIT Full time contract
~~- COPIES SENT TO:~~
~~O H.O. E., O.ini, sis Ochi.s io , En., .a.: u.a. ,, sis EOisi.,(s, ify): ANI fi1e~~
~~Subject:~~
Use of Applied Force During Fabrication of Component Supports Re; NCR M 11.809 (Support No. CC-1-048-001-A33R) This report is written in response to Brown & Root's request that I accept the disposition of the referenced NCR. __C.i I had requested that the disposition address Corrective Action to preclude repetition of the unauthorized use of a porta-power to spread the horizontal members of a box support in order to achieve reoutred clearance. I have been informed that Pipe Support Engineering takes e x c e p tiio n to any corrective act' ion. u ., Annarentiv. Engineering claims ~~to " Factor" in stresses idposed on - weldments and nine suonort members by forcibly "Sprinnina" those members. This rationale is not acceotable to the ANIA. It is our ooinion
~~'M e. .~~
~~that use of cover equipment...wednes, etc. to correcermisfabrication is s.n. a construction orocess ao defined in Section 10 of Bro 0'Eh& Root's,Q.A.M.~~
~~'t., .g FailureJ to address this problem will result in perpetu'ation o f:- -~~
E: l ernfe normannel unine ann 11md Fnrem and immunneo nf Mon Conformanca/ 3 l
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~~Bnwm&Roounc. INTEROFFICE SEMO IM#.27,150 ' May 8, 1984 TO: M. Coats FROM: 'J.T. Blixt~~
~~SUBJECT:~~
CPSES, 35-1195 SIS #10-030. In regards to the inspector's concern expressed in this-SIS Report, please find attached the response from Construction and Engineering. If you have any questions regarding this, please contact me at extension 459.
~
~~M Blixt QE Group Supervisor~~
~
JTB/bm cc: G.R. Purdy R. Siever G.L. Morris, Jr. QA File fpp,f f3L- l-4)0 $4Jdb CN $$ N/4A gawatc<- % izw .Ar r ~n.a s. 72kraxsun. m _ . - . , .
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~~I': ~ CASE EXHIBIT NO.1,055 ,~~
~~. SIS REPORT j. -~~
on s . . . THE HARTFORD STEAM UOII.EH INSPECI' ION ar. stJRANCE COMPANY l HAM Il OND.t:ONSI't;'t it:0 i tater: ifN$. 1 ,J ffuh WY&
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H.O./ BRAN H OFFICE FROM: -8. le)a}ki , AAI f out ORGANIZATIO A $40% l LOCATION STREET CIT.Y COUNTY STATE ZIP CODE bhY$ Y in $v PERSON CONT CTE (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P.O. NO.
~~. . Als~C td $ $ b itsleh j R $ L*w$m REASON FOR VISIT ' ' '~~
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~~t INTEROFFICE MEMO IM - 26701 January 23, 1984 TO: Gordon Purdy FROM: W.E. Baker~~
~~SUBJECT:~~
Q.C. Procedure Reference on Pipe Hanger Documentation Due to the issuance of Q.C. Procedure QI-QAP 11.2-28, Rev. O, the current Q.C. Procedure referenced on Hanger Weld Data Cards is obsolete. In order to use the existing cards'in stock, hold down construction costs, and avoid recall of WDC's in use; Q.C. inspectors are being authorized by this memo to line thru the Q.C. procedure listed on the Weld Data Card, initial and date the line-thru, and add the current procedure reference for those WDC's already issued to the field. Welding En prior to issuance.gineering personn,el will correct those cards left in inventory As needed, new card stock will be printed with the correct
~~'- reference. This action will facilitate construction and preclude the unneces-sary printing of new card stock for minor changes.~~
~~b'$ k ld / W.E. Baker Sr. Project Welding Engineer cc il s ]I a q e,~~
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~~SIS RECORD FOR MONITORING QAdQA PROGRAMS T1!!! HARTFORD STEAM BOILER INSPECTION ara S URANCE COMP.tNY~~
~ CASE EXHIBIT N0.1,056 n.utirom cossa rict.Tmaa: ./ ~ 371 . .~ r., ,, .. -., $: yMr. ic Gordon .u. Purdy, Site Q. A. Manager c.it suttr er y3 6rstents s ccumi aut Feb. 6, 1984 1 l 3, o -- msr. saAncM msr. arca os fontQ COUNTff IAf GdCNAL Usi oNLrl g
ug Brown & Root, Inc. Follow.Up avtCio touriC" Houston Houston R.avited . Cta58'8 Field Repair / CPSES Glen Rose, Texas 76043 US*** -- A 8 5"8'Y U Alt"8 tion O'":"h' l1. the undersigned. have monitored your QA/QC manual')on: -A
~~,A c~,d and find the following sections:~~
i ._. ,o,....,..,..,.r.,;.., _ l _ Satisfactory:
~~- ,o.,oc,,.~~
~~l 1 Unsatisf actory:ri...~~
~~,. , tu . r. ]om=,...,,,a.. ., . arco .=.... ..., "~~
~~Secta..on 16 Non conforming Items . _ , .~~
~~!g Brown & Root Q.A. Manual and O.A. Procedure _#CP-QAP-16.1 desigrats ES~~
( the Q.E. Group with the responsibility to review NCRs clarity,. adequacy, and conformance to Code requirements. The O.C. Superintendent / Lead in given the responsibility of ensuring activities required by the NCR f' A See Attached ~~Ir - CUSTOMER: data for completion ofPlease correctivedescribe action, so thatthe itemsresolution may be remonitored of these by: items 'M in the / . / #f
~~" CUSTOMER'S R s o.u.s Please keep the Original of this form for your records and return a copy to inspector named below. '2."*""~~
~~insp. satt mio sota tasa p...m,r 3 n .u rc e/Sl! Foreign eresenurse OFile Feb. 6, 1984 h -fC M /~~
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~~1. th? undersigned, have remonitored the above unsatisfactory conditions on:~~
~~3jdo/fy and found therrr batisfactory CUrmatisfactory fEsplam astow)~~
~~$., be zd 's.zbd/s.u)m.e.<. (.rPu m), a&d.J La amds, a-, d 1~~
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~~, Page 2 of 3 . (~~
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disposition are verified and/or witnessed, and to close the NCR after - cnsuring that sufficient documentation exists to verify completion of th; disposition, and that the supporting documentation is attached to or referenced on the NCR. Q.A. Procedure CP-QAP-16.1 further stipulates that questionable NCR conditions are to be resolved in accordance with the O.C. and/or Q.E. Supervisors. ' NCRs M-9946, M-9955, M-9956, M-9957, M-9958, M-9959, M-9964, M-9965, M-9969, M-9972, M-9980, M-9981, M-9985, and M-9987 were sub-mitted to me by the site Mechanical NDE Level III for ANI concurrence to closure. He stated that the voided documents (as required by the NCR) were located in the vault. All of these NCR's were verified by Q.C. as being complete. None of these NCRs made reference to the voided COT's. I could not locate the previous COT's for NCR # 's M-9985 (one only), M-9980 (one only) , M-9972, and M-9987. I did locate the pre-vious COTS for NCR #'s M-9985 (one only) , M-9981, and M-9980 and none of these travelers were voided. NCR # M-9743 was written to upgrade support GHH-RTS-1-7 from Class 2 to Class 1. There is nothing indicating that the list of welders was made from the welders symbols stamped on each joint. IR #AM04431 idantified a Code nameplate on a strut which was stamped Class 2. order to upgrade this strut to Class 1, the name plate was removed. In Tha IR was closed as satisfactory on 1/17/84. There is no indication on the NCR that a corrected data report was submitted. This NCR was varified as being complete by Q.C. on 1/23/84. NCR #M-9740 was writt,en to upgrade support GHH-RTS-1-3 from Class 2 to Class 1. There is nothing indicating that the list of welders was made from the welders symbols stamped on each joint. For welds 49, 50. 51, and 52, this would not have been feasible because these are hidden welds. (See IR #AM03612) . This NCR was verified as being complete by Q.C. on 1/21/84. NCR #M-9744 was written to upgrade support GHH-RTS-1-8 from Class 2 to Class 1. There is no indication that the list of welders was m:de from the welders symbols stamped on each joint. This NCR was varified as being complete by O.C. on 1/25/84. NCR #M-9739 was written to upgrade support GHH-RTS-1-2 from Class 2 to Class 1. There is no indication that the list of welders was made from the welders symbols stamped on each joint. This NCR was varified as being complete by Q.C. on 1/27/84. n e l l
" 2 ;*:.;.'ilt:'." y- -- . . . = ** ' ; 2 :.' .t i
~~= SIS Report 371 Page 3 of 3 s~~
/ D, i NCR #M-9742 2 to Class 1. Q.C.was written to upgrade support GHH-RT'S-1-6 from Class on 12/19/83 indicating that welds inspector J. Massey prepared an inspection report 1,2, 5,6,7,13,15,17,18,19,20,21,22, 33,34,35,36, (QC/E) & 37 were not stamped with a welders symbol. W. Sims issued an inspection report on 1/6/84 disclaiming the welder symbol stamping as not being required. This is in direct contrast with the disposition of the NCR. This NCR was verified as complete by Q.C.
on 1/30/84. Since these welds were not stamped with a welders symbol, the welders list could not have been made in accordance with the NCR disposition. NCR #9741 2 to Class 1. IRwas written to upgrade support GHH-RTS-1-5 from Class
~~#AM03611 was prepared by C. Saengerhausen on 12/19/83.~~
Item 3 of the IR walder. symbol stamps. stated that only welds 3 4,7, & 8 were identified with 1 made to NCR M-9741 rev.l.This item was deleted by W. Sims with a reference ravise NCR M-9741, for whichC. W.Saengerhausen issued an IR on 12/19/83 to Sims issued an IR on 1/6/84 disclaiming the need for an NCR revision because Welding Engineering had established walder to weld'joirt traceability. This is not in accordance with the disposition of the NCR. As stated in Saengerhausen's IR, welder to wald joint traceability could not be established per the NCR disposition. There is nothing referenced on the'NCR, included in the NCR, nor included in theas O.A. hanger being package acceptable whichfor indicates Class 1 that the material was verified by application. the O.C. On 1/9/84, I informed complied with. Group Supervisor that the disposition of thIis NCR could not be He stated that the only Code requirements are either walders joint. symbols stamped on the welds or a tabulation of welder: to each He also stated that craft produced a tabulation and that the acceptability with NA-4210. of the tabulation was not up to him. This is in conflict listed is indicative of a need to reinstruct personnel involved inIt is th prsparing, reviewing, and closing NCR's to ensure that NCR's are clear and that prior the disposition to Q.C. verification.is complete and completion is intelligible
~
1'- i l l
14 * '*
~~. hh INTEROFFIC: MEMO . IM# 26,916 March 13, 1984 TO: W. Walker FROM: R. Siever~~
~~SUBJECT:~~
~~CPSES, 35-1195 SIS Report #371 Amended Response. All NCRs referenced in paragraph-2 have been verified by QC and have the~~
~~. superseded Travelers and current Travelers referenced in the disposition.~~
The Quality Assurance Department has evaluated the meth6d used by Welding Engineering, to map the welds on the RTS (incore instrument) supports. j~ We have remapped all welds and identified welds that do not have welder traceability on an Inspection Report. i Process documentation has been generated to remove all welds and have them rewelded if traceability hcs not been established. The NCRs referenced on the above SIS bave been revised to reflect the
~~, above action.'~~
~~NCR coordinators and QC Leads will be reinstructed in the requirements for reviewing, closing and revising NCRs.~~
~~'If you have any questions, please contact me at extension 204.~~
~~s e =- C Siever QC Group Supervisor RS/bm cc: G.R. Purdy . 4 J.T. Blixt G.L. Morris', Jr. 4 4 6~~
~~~ _.._,.4 .-. ... _ . ,.... . . , _ , _ . . _ . . , .. - ., , - . , . , , , ,,e, , .... , , , - , , . y~~
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~~BrownD' Root.ine.~~
~~CASE EXHIBIT 1,057 INTEROFFI; EMO IM# 26,702 January 23, 1984 sTQ: B. Walker FROM: J.T. Blixt~~
~~SUBJECT:~~
~~CPSES, 35-1195 SIS Report 5-002.~~
1. Reference CPP 12,978 The following situation is a isolated case. CPP 12,978 addresses a list of all intergal attachments that require impact testing. In the letter which was generated by Large Bore Engineering, it stated that material requiring impact testing will be noted on the hanger detail sketch. This particular support is one support on this letter that the. detail. sketch has not been revised t.s of this date. The following detail sketch will be revised by Large Bo're Engineering.

2. The following support MS-1-001-00S-C77K was received pre-fabricated on the job site in the year of 1979 with. manufacturer's data report '
NF-2. Ar, thac. time MS-46A, Revision Z was applicabie and impact . testing wasn't required. Ref. 2323-MS-46A, page 358, para. 3.11.B. If there are any questions regarding this response, please contact me at extension 459. J.T. Blixt QE Group Supervisor JTB/bm cc: G.R. Purdy R. Siever G.L. Morris, Jr.
,;f- 4 . ....a ..u. } ; . .. . - -
~~SIS REPORT ' THE HARTFORD STEAAt Boll.ER INSPECTION ar. SURANCE COAlPANY n.uimmo.cossu:TuxT reic~~
' Ts: 5-002A ~
DATE SHEET Oi - Gordon Purdy, Site Q. A. Manager 2-10-84 1 ~. FROM: Robert Byers, ANI H.O./ BRANCH OFFICE LROANIZATION Houston __ Brown & Root, Inc. LOCATION STREET CITY COUNTY STATE ZIP CCO CPSES Box 1001 Glen Rose Somervell Texas PERSON CONTACTED (GivE NAME AND OFFICIAL TITLE) 760 Q CONTRACT /P.O. P'- REASON FOR VISIT 35-1195-C38 Full time contract
~~COPlES SENT TO:~~
OH.c. Ea. a.; sis Oo i.e ra. ER..i.a.i u <, sis 8 O'h., (s,.cify): ANI file REF: IM #26,702 __, (1) I disaoree with the statement "The following situation is ,_ a_ isolated case". In that two a'dditional sup, ports were ., found with the same deficiencies. . Hap _ger,__s_uppo rts MS-1-0 3-0 0 7-C72K and MS-1-002-013-C72K i both have welded attachments which require impact testing _ but the_ detail sketch does not sp,ecify this as a requirement. (2.)_,,Although this support did not orig _i_nally require impacted
~~,__ material. Subsequent revision of the Design Specificat-~~
, ions mandates this material meet impact requirements. In qi.,ummati_pn this Inspectors concerns are_ as follows: A. The number of additional supports that exists in the 1 fie__1_d_in which impact requirements have been overlooked. B. These deficiencies _were not identified until completion,__,, ! or near completion of fabrication. s Ob %u- --
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/'dy; REPLY o.ie is signed weeengeg,cge.av . . . - . . . . , RECIPIENT-RETAIN WHITE COPY, RETURN PINK COPY. -- = - - -
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~~_. . _ __. - ~~~
,. ;s . . . .. . .r l 6 , INTEROFFIC. . J.M0 IM# 26,856 March 13, 1984 TO: M. Coats FROM: .J.T. Blixt
~~SUBJECT:~~
CPSES, 35-1195 SIS Report 5-002A. A. Hanger Engineering has been notified of our concern with the subject addressed on SIS Report 5-002 and 5-002A. The attached list reflects the only hanger detail sketches left that have no't been revised as of this date, to indicate impact requirements on the sketch as stated per CPP-12,978.. B.- Engineering has notified me that these deficiencies were being identified on a case by case basis. Engineering has been notified that in order to certify these hangers, we need the detail sketches revised to indicate impact requirements. Engineering is now in the process of recertifying the hanger detail sketches that need impact testing on the sketches (Ref. attached letter). If there are any' questions regarding this response, please contact me at extension 459. J.T. Blixt QE Group Supervisor JTs/ba cc: C.R. Purdy R. Siever G.L. Morris, Jr.
~~&~r #M L w+ r- 0 3lM}W b~~
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.. ... m ,i .pyggy.g,yy ~-rg g3;p; m _ _, , .;,, ,,4 SlS ~ REPORT N E E M BIT N0. 1.058 1 HE HARTFORD STEAM BOILER INSPECTION an. ISL*RANCE COMPANY u.uirtono,rossu ru: cram 10-032 Tu DATE . SHEET Bob Siever, Q. C. Group Supervisor 2-17-84 1 lOF 1 FROM: -
H.O./ BRANCH OFFICE Robert Byers, ANI Houston ORGANIZATION - Brown & Root, Inc LOCATION STREET CITY COUNTY STATE ZIP COO CPSES Box 1001 - Glen Rose Somervell Texas 75041 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRAOT/P.O. tl REASON FOR VISIT 35-1195-056 Full time contract
~~COPIES SENT TO:~~
~~OH.O. Eng O.im, sls O oii.i io. GR..:.a. u. ,, sis BOis.,(s, iry): ANI file~~
~~'An inspection of hidden welds on support number CC-2-008-403-S33R .~~
disclosed the following discrepancy: " Welder A. Lopez, (welder's symbol "BGL") was questioned by my- _ self in regards to interpass temperature while welding to embed plates. _ Mr. Lopez admitted he did not know the thickness of the embed plate he ,, was_ welding to, nor did he check the interpass temperature during _ welding. Reference documents: 10.2 QAM WPS 11032
~~.e.~~
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~~p' s'&. bh INTEROFFICE MEMO TO: R. Byers March 9, 1984~~
~~,FROM: R. Siever.~~
~~SUBJECT:~~
CPSES, 35-1195. SIS #10-032. The welder. identified on the above SIS, has been retrained to the requirement of the WPS (see attachment). The Quality Control department has been instructed to monitor preheat
~
~~and interpass temperatures two days per week (see attachment). If you have any questions, please contact me at extension 204. . n~ RT Sie'ver QC Group Supervisor~~
~~'RS/bm w/ attachment ec: G.R. Purdy J.T. Blixt G.L. Morris, Jr.~~
A .8 ';*^ ^ ^ *
~~., -m- , - .,.u~~
.;,' ; Brownf5 Root.inc. STRUCTURAL WELDER ORIENTATION I have read the Structural Welder Orientation and I agree to follow the requirements listed in it and the requirements listed below; (1) - The requirements of the procedures used on the job site. (2) The requirements of the Welding Procedure Specification (WPS). This includes the preheat, interpass temperature, root gap, amperage, voltage, travel speed, maximum bead width, polarity, rod type and size. I understand.that if I have any problem with the above I am to report it to my Foreman or the Weld Tech. in the area. Nameb.E.wf-.
~~.L 3 D' ate A#f3 ~)UP [~~
~~Badge $ l$'l~~
~~. Symbol /$ /?_ l This copy is to be placed in each welders certification file, i~~
~~t' JEH/pam I i~~
~~, _ -___ _. _w. - -~~
~~., . . w B' CPM 1CT* Root.Inc.~~
~~INTEROFFICE .MO~~
~~-TO: Distribution March 9, 1984 FROM: R. Siever~~
~~SUBJECT:~~
CPSES, 35-1195 Preheat And Interpass Temperature. Quality Control shall monitor preheat and interpass temperatures at a minimum of two days per week. The QA/QC Building Supervisors shall prepare an assignment schedule for each unit and assign one QCI for this activity to each unit. Result of this activity shall be recorded on the inprocess documentation for the item verified. This activity shall be implemented by March 12, 1984. IC Siever QC Group Supervisor RS/bm
~
cc: G.R. Purdy J.T. Blixt D. Woodyard G. Bennetzen D. Snov , W. Mansfield L. Wilkerson
F .
~~^ -~~
~~SIS REPORT~~
~
~~THE HARTFORD STEAS1 DOII.ER INSPECTION HAu rroun. cos.wcr Ct.T unic~~
)
~~INSURANCE COA 1PANY~~
) CASE EXHIBIT N0.1,059 - Tg: 10-033 - DATE SHEET OF Gordon Purdy, Site Q. A. Manager 4-13-84 1 1 . .. FROM:
H.O./ BRANCH OFFICE Jerry Lytle. ANI ORGANIZATION Houston Brown & Root. Inc. LOCATION STREET CITY COUNTY STATE ZIP CODE
.[ C.P.S.E.S. Box 1001 Clen Rose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME AND CFFICIAL TITLE)
CONTRACT /P.O. NO. f.EASON FOR VISIT 35-1195-0561 Full time contract ~ COPIES SENT TO: . ON O. Ea, c. , sis Oo.l.s ia . v ER :.a.: u.a...<. sis E04., ts 4): ANI fi1e
~~.,_ Subject! Insnection R gyLo r t s .~~
References. CP-0AP-Il 1 9T9 Renort C-037 Cnntrary to the above references. there are numerous _ Tnnnectinn Renorte. fneluding Threading Insnection Renorts.
~~. that are not being numbered.~~
~~Examnie* Thrended Insnection Renorts written 4-11-84 and 4-12-84 for ISO. CC-I-SB-015 (found durine N-5 revieu by ANI).~~
~~~ ~*** ^M k. . .. _ . . 4.!. - f' ....~~
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~~n INTEROFF;m2 MEMO IM# 27,131 DATE: May 3, 1984 TO: M. Coats, ANI~~
~~TROM: J.T. Blixt~~
~~SUBJECT:~~
~~.CPSES, 35-1195 SIS Report 932 #10-033 and #11-011 .~~
In response to the above referenced reports the QA/QC Department has been instructed co'the following: Satisfactory Inspection Reports do not require an identification serial number. When a satisfactory inspection is performed on an item and the rasitics of that inspection are recorded on an Inspection Report (IR), the IR shall contain sufficient identification to maintain traceability to the . item and shall become part of the item's documentation package along with the process documents. Unsatisfactory inspections which cre reported on an "Unsat IR" require the assignment of serial numbers, traceable to a log, for tracking pur-poses to assure further processing and closure. If you have any questions regarding this response, please contact me at extension 459. - i 1 J.T. Blixt, QE Group Supervisor JTB/kdm cc: G.R. Purdy R. Siever G.L. Morris, Jr. 9 0 1
r S '* SIS REPOSI ---ST{F3P.3 73 .ag: h, CASE EXHIBIT NO.1,060 TH3 HARTFORD STEAM BOII ER INSPSET1;N cnJ 'NSURANCE COMPANY narroomo.coss ricero m . . - . . . 10-034
~~'TO:~~
~~DATE SHEET .0F,~~
- . Gordon. Purdy , S Lte ,0 A. Eanage r .-~ ~. ; ..~m . . - m. : 18-84 . -. . l~ - .- l . ; -
~~FROM: - - H.O./ BRANCH OFFICE Marvin Coats 1 L._ANI~~
~~_ . . _ . Houston . ..~~
ORGANIZATION - Brown & Root, Inc. LOCATION STREET CITY COUNTY STATE ZIP CODE C.P.S.E.S. Box 1001 Glen Rose Somervell Texas 76043 PERSON CONTACTED (GIVE NAME AND OFFICIAL TITLE) CONTRACT /P.O. NO. REASON FOR VISIT 35-1195-0561 Full time contract CaPIES SENT TO: - OH.O. Eae Cl.im, sis Ooii.e ia ., ER .a. u.a. ,, sis E0%, <s,. city): ANI
~~Subject:~~
~~Welded Attachments to Large Bore Main Steam~~
~~- - . u . - . . . . .. .. .~~
and Feed Water Piping Due to repeated identification of non-compliance with Desian Soecification recuirements for notch touchness material to be used in above acolications.recuest that all packaces on these systems be re-oresented to the ANI for establishment .. of hold coints.
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~~vaamanoaune. INTER 0FFI. :TM0~~
)
~~IM# 27,151 May 8, 1984 j TO: M. Coats ! i FROM: J.T. Blixt l~~
~~SUBJECT:~~
~~CPSES, 35-1195 SIS #10-034.~~
~~l i~~
Mr. W.E. Baker, Pipe Welding Engineer, has instructed his personnel to route the subject packages to ANI. J.T. Blixt QE Group Supervisor JTB/bm cc: G.R. Purdy R. Siever G.L. Morris, Jr. 44fl~AdGd / Qtt # LoJa/td , fff /c N S GCLb ose / b o e J w G , A L-A " ~~p s.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 a r 2-~~
~~.1}}~~

ML20096A409

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