ML20136B794
| ML20136B794 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/04/1984 |
| From: | Griffin H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20136B196 | List:
|
| References | |
| FOIA-84-779 NUDOCS 8511200289 | |
| Download: ML20136B794 (1) | |
Text
{{#Wiki_filter:_ b5 j#* " '% UNITED STATES -h~ E' , . ( [' 'g NUCLEAR REGULATORY COMMISSION ! $ '-j OFFICE OF INVESTIGATIONS FIELD OFFICE REGION IV
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April 4,19E4 MEMORANDUM TO: T. F. Westertan Inspection & Enforcement Officer FROM: H. Brooks Griffin Investigator SL: EJECT: RELEASE OF PORTIONS OF DILLINGE/F'S TRANSCRIPT The Region IV Of Field Office has completed its investigation in the Dillingham matter. Region IV is free to make use of the transcript for its reporting needs. If you require further information, please call me. YJ dw ' Os 9 8511200289 851025 PDR FOIA GARDE 84-779 PDR o f .. '
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, l Dockets: 50-445 MAY J g ;gg4 4
50-446 4 Texas Utilities Electric Company ATTN: M. D. Spence, President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dalla , Texas 75201 Gentlemen: Enclosed is a copy of the 60 allegations concerning the protective coatings at Comanche Peak Steam Electric Station. Copies of these allegations have previously been forwarded to Texas Utilities Electric Company personnel at the Comanche Peak Steam Electric Station, by our contractor, for their technical review, appropriate corrective actions, and preventative measures, Should you have any questions concerning these allegations, we will be pleased to discuss them with you. Sincerely,
.oristnal 31La*2 EY3 31 shard L. Ban 3an Richard L. Bangart, Director Region IV Comanche Peak Task Force
Enclosure:
As stated cc: Texas Utilities Electric Company Texas Utilities Electric Company i ATTN: B. R. Clements, Vice ATTN: H. C. Schmidt, Manager President, Nuclear Nucle'ar Services , Skyway Tower Skyway Tower 400 North Olive Street 400 North Olive Street Lock Box 81 Lock Box 81 . Dallas, Texas 75201 Dallas, Texas 75201 1 TL/TF , E0 v D D/TF 'q DRSP TF. 4 DMHun utt:je T ste'e W e, RLBa Ot RPDen e TAI o t 5ll8/84 5/)/84)pYn 5lll/ 5/$/84 5/G/84 5// /84
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ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE-COATINGS
- 1. Paragraph 4.3.1.2 of Procedure Number CCP 40 states " Imperial coatings may be applied in the following sequential order: #115/1201/115/1201 or 11S/1201/11/1201." Imperial letter dated May 8,1978. VBR-7697 to Mr.
Kelly Williams, second paranraph, states: "Although the resultant systems
#11S/4201/115/1201 or #115/1201/11/1201 have not been qualification tes-ted, there is no reason to believe that they are not viable systems."
Thus these two systems have not been DBA qualified.
- 2. Specific sequencing of coatings systems not required. For ex-ample, NRC No. C83-01752 dated 6/23/83, Disposition section, first para-graph, states: " Table A2 in Appendit A of AS 31 specifies acceptable coat-ing systems, i.e., primer and final coat product identification and vendors." It then goes on to say that full sequencing is not identified.
"This table does not identify full system sequencing or application para-rete rs . " Does a system's sequencin'g change for a repair? Why? Has the repair sequence been DBA qualified?
- 3. DCA, No.17,142, Rev. 2, allows Carboline 305 to be applied over another manufacturer's epoxy coating. Has this system been DBA qualified?
4 DCA, No.12, 374, Rev.1, allows inorganic zine primer (Carboline CZ-11 ?) to be top coated by Imperial 1201. Has this system been DBA qualified?
- 5. Procedure No. CCP-30A, Rev. 2, page 2 of 13, paragraph 1.3.1 allows the application of Carboline 305 over the primer Dimetcote 6 by A eron. Has this system been CBA qualified? -
- 6. Procedure No. CCP-40, Rev. 5, page 5 of 13, paragraph 4.1.1.3 states: "Re.
pair of embedded foreign objects such as nails, rebar chairs, bolts, wood, or plastic shall be repaired per the following guidelines before ap-plication of NUTECH 115 surfacer." Have these systems been DBA oualified?
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1/20/84 I
- ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE C0ATINr,S i
NOTE: Allegations 1 through 6 are concerned with the protective coating sys-tems not being qualified, for example for environmental (irradiation) con-ditions and DBA conditions, under ANSI 101.2-1972. (See letter to Doyle Hun- ; nicutt from V. Lettieri dated January 16,1984.) l
- 7. NCR No. C83-01986 discusses the cracking and flaking of concrete coatings i systems (NUTEC 11,115,1201). The disposition section of tnis NCR states "crackina of coatinos is due to excessive stresses in the coating i
riuring drying and curing." The allegation is that repairing these cracks will not remedy the condition which caused the cracks.
- 8. Paragraph 4.1.3 of Procedure Number CCP-30, Rev.11 states: ". . . sh adows t
or ticht residue of orimer which may remain in the profile of the l previously prepared substrate is acceptable." The allegation questions the integrity of an inorganic zinc primer which has been applied over a l steel substrate with metallic zine residue in the profile of the steel, f The concern is that there will be coatino adhesion problems, and that the zine is isolated from the carbon steel substrate; thus the necessary j calvanic action will fail to occur. , 1 [ 9. It is alleced that three coats of inorganic zine primer have been applied ] at Cc .anche Peak to ottain the recuired dry film thickness. Paragraph , j 3.2.4 of Instruction Nunber 01-QP-11.4.5, Rev. 27, state;: "Only two (2) f overcoats shall be aoolied." It is alleged that this syster would lack chemical attraction or intercoat adhesion with itself. Is this three coat pr!aer system qualified, for example for environnantal (irradiation) conditions and DBA conditions, under ANSI N101.2-19727 This is another exanole of the coatings systems not being qualified. i 1
- 10. Paragraph 3.2.2.3 of Instruction Number 01-0P-11.4-5, Rev. 27, page 8 of 27, states: " Surfaces that have been power tooled with '3M Clean-N-Strip,' 80 grit or coarser ' flapper wheels,' sanding discs, ' roto peans,' ,
or equivalent to provide acceptable surface profile. It has been alleged that:
- a. The coating system applied to surfaces prepared using the above specified power tool methods are not qualified, for example for en-vironnental (irradiation) conditions and DBA conditions under ANSI N101.2-1972.
- b. The above mentioned methods provide a snoothing or polishing action, rather than a penetrating action as obtained with sandblasting or with a needle gun.
l c. The profile that is obtained using the above-nentioned methods occurs in a sparse pattern and not a densely packed pattern.,
- 11. It is alleged that DCA No.18, 489, Rev.1, allows a primer thickness of i 0.5 mils. If this is so, is a coating system having a primer coat of 0.5
) mil thickness qualified, for example for environmental (irradiation) con-ditions and DBA conditions, under ANSI 101,2-19727 i
- 12. If maximum limits are used, paragraph 4.3.1.2 of Procedure Number CCP 40",
l Rev. S. , allows a 102 mil thick coating systen for 115/1201/115/1201. , Is this system thickness qualified, for exanple for environnental (ir-radiation) conditions and DBA conditions, under ANS! 101.2-19727
- 13. It is alleged that the coatinas applied to areas such as the reactor core cavity will not maintain their integrity due to neutron,and ganma ex-posure. It is further alleoed that water and flaled-of f paint will flow out of the reactor core cavity in the case of a LOCA. Are the coating systems applied to these area qualified under ANSI 101.2-197,2, e s pecially for environnental and DBA conditions? Which areas are qualified and which areas are not? If coatings in the cavity will come of f with ir-radiation, will this cause a problem post-LOCA? -
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14 a. It has been alleged that af ter a NCR is written, anyone can sian of f on it.
- b. It has been alleged that NCRs cannot be written, and that irs must be written with "unsats." It is alleged that NCRs must be dispositioned 4
by an engineer, while irs can be dispositioned by anyone. What - prevents itens identified on an IR from becoming lost, the problem not being resolved, or generic items not being identified? i
- 15. a. It is alleged that Paragraph 4.4.3.0 of Procedure Number CCP-30, Rev. j 11, allows CZ-11 or Carboline 191 to be applied over existing Pheno-line 305 topcoat and left intact, without sanding back to a " mottled" i
transition. - i
- b. It is also alleged that this paragraph allows Phenoline 305 to be ap-plied over Reactic 1201 and vice-versa.
i j Are these coating systems qualified, for example for environnental and ; l DBA conditions, under ANSI 101.2-1972? i
- 16. As a result of numerous allegations regarding inoroper pressure being ap-plied to QC inspectors, NRC Office of Investigations has written violations in this area and proposed two civil penalties. Are there any I j coating material deficiencies in the plant resulting from the improper
{ oressure acolied to OC inspectors (e.g., cressa. e not to write unsat re-i ports or NCRs, threats to lose job, use of verbal instructions to QC
- inspectors vs. written instructions, lack of supoort from OC r.anagement in technical disputes witn construction, ccnfusing instructions which do !
I not support unsats, such as 01-0P-11, 4-5, Rev. 27, page 5 of 27, Note 4 i and paae 19 of 27 paragraph 3.7.5.b). ! 1 i
- 17. It is alleged that the " air acceptability test" results are invalid be- '
cause cigarette butts are placed into the cheater valve of t,he spray gun prior to the test and removed after the test. Further, it is alleged that construction and OC nanagement was aware of this practice. i
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2/16/84 ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE COATINGS Note: For Allegations 1 through 17 see inspection report 50-445/84-03; 50-446/84-01, Attachment 1.
- 18. It is alleged that QC inspectors are not allowed to identify visual de-fects such as cracking or blistering during backfit inspections.
- 19. It is alleged that Instruction Number QI-QP-11.4-23 and QI-QP-11.4-24 are very vague regarding the way the backfit inspections are to be conducted.
- 20. It is alleged that adhesion testing of the protecti,ve coatings are not
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performed properly. The QC inspectors are instructed not to cut around the adhesion test dollies when conducting adhesion tests. The instructions that come with the machine tell you to do so (and Specifica-tion AS-31 references these instructions).
- 21. It is alleged that Brown & Root is doing tne calibration on these adhesion testers, and they are not using a corrected value curve (which snould hEve been supplied with each unit).
- 22. In the present backfit program, QC inspectors are required to take read-ings with adhesion testers nithout receiving formal training. ,
- 23. It is alleged that the Coatings QC program at CPSES is inferior to the sane programs at other nuclear power plant projects. bnereasonisthat standard inspection practices, used at other sites, are not used at CPSES.
For example, a sample adneston test used by a QC inspector regularly at another site, was not allowed at CPSES by one of the QC lead men. This is the ASTM tape adhesion test. i I
e 4 1 ] 24 It is alleged that Q coatings have been placed over rusty, scaly un-prepared metal surfaces inside pipe supports made of tube steel without i j end-caps. In these cases, the protective coating gets on the rusty inside of the tube. This coating material could later crack, scale, come off the l pipe, and then travel to the sumps. i l 25. It is alleged that a seal coat was accepted prior to the finished coat being applied, when in fact the seal c. oat should have been rejected. The area in question is just outside the Skimmer Pump Room, in Reactor Con-tainment Building-Unit 1, on the steel liner plate. The stains on the liner plate in the opinion of the inspector were n'ot acceptable per pro-cedure and should have caused the seal coat 09 be rejected for finish coat , application. The DC inspector brought the condition to management's at-tention and requested their opinion. Management stated that the stains were in fact rust stains and acceptable, while the QC inspector felt it was obvious that the stains were not rust and unacceptable. The QC in-spector stated: "The reason I accepted this was because I feared adverse action would be taken against me if I rejected it." The QC Inspector goes j on to say that this area has the finish coat on it now and none of the j stains are visible. t 1 1
- 26. It is alleged that Design Change Authorization (DCA) documents are not I
controlled. t i
- 27. It is also alleged tnat DCAs at CPSES are originated and approved totally by engineering. QA/QC nas no input in tne review and disposition of DCAs.
- 28. It is alleged that DCAs are used frequently and conveniently to cover up a l condition for which a Nonconformance Report (NCR) should be written. Tne alleger estimated that 40% of the DCAs are for NCR conditions.
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- 29. It is further alleged that DCAs are written to overcome a problem area which will take considerable time for repairs. In other words, the DCAs are used to facilitate the completion of a job even though this means that accepted procedures will not be followed.
- 30. It is alleged that on numerous occasions DCAs have been issued to down-grade the surface preparation from an SP-10 to an SP-6 standard prepara-tion. It is further alleged that DCAs are also written to downgrade Specification AS-31 requirements in containment to AS-30, which is the non-safety specification. The downgrading of an SP-10 to an SP-6 surface preparation is an example of DCAs being written to downgrade from an AS-31 to an AS-30 requirement.
- 31. It is further alleged $ hat QC management interpreted an SP-6 on a DCA to mean "do the best you can". For example, when difficult access areas were involved, QC management allegedly stated to the QC inspectors, if you can-not get to an area, do not worry about it.
- 32. It is alleged that after a reading list was signed by QC inspectors, the document that they read was removed and replaced by a different document,
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yet the reading list coversheet remained the same.
- 33. It is- alleged that many problems at CP!"S with coatings are due to a QC Coatings Lead Inspector's (Individual K) lack of experience in OC. An enar.ple of this was wnen he identified the rust on an A-frame in the cor,e area as being 0-6 residue.
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i f(.j i 3/;il5: L'.lG.i!Z5 CC.'CERN:G C0uGE K.fI PROTECTIE C0AT:%5
;!!: F:t alle;a:icas 1 through 33, see htters dated hauary li and 24 135t, ar.: February 16,1984, En:er; Lettieri te Doyle M. hunnic :)
3 *. It is alleged that the requirements of ANSI /ASE M5.2.21978 were no: c:t fc. c:terial storage.
'5. !! is a!!eged that Counche Ped has problems te the area of woricanst.ip, q:!!ity of wari, painter qualift:! tion, and ind:ctrination. Itisaise alleied that coccatntatice require ents were not beir-g met, for exaa.;1e de:;rtatati: cf painter qualifications and in-pro:ess work.
- 35. It is alleged that the traceability 0+ coatines caterials was not always I cain:aine:.
ii.' It is alle;ed that for the backfit 'pregrae, a eas that were sta:e: te have satisfactory priraer docu:sentation ended up having 10 mils of primr cr. ne:, which ex:eeded the allowed atxims. I: is t'.s: alle;ed that none of the saps showing areas of ade cate primt . c : amer.ta:ict. were correct, for the bacifft progras. Additionally,i:is allege that the documentation far the backfit prograc was forged and
'alsified. Further:;re, it is alleged that a 5 inspector for the ni;.'::
sr/.ft wr:te u: ac:e; table inspe: tion rescrts for the d:= area with:c: dser pt.f:r:ing the ins;e:tions.
- 5. It is alleged tha: high dry file thichaesses (DFT't) of CZ-11 are so.er gr;;nd to an at:e; table CFT. It is fe tner allepe that this would b,arn-ist. c. p list. t>.e zinc, and p:ssibly res. sit in peor adhesica of tne to;
. c.at. l l
- 11. It is alleged that old Phenollt.e 303 (between 1 anJ 2 years old) is being t;. ::ated with new Phenoline 3r,5 wit!r little or no surface preparation l . r......s..)
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G . i ':. ;r.st u:ticr. f.u:oer Ql-0A-11.4-5, paragraph 3.2.2.d. rev. 27, ca:ec , 11/5/23, page 7 of 27 states: "Verih the the blasted er power toole' 5 surfa:e has been brushed or vacuv:ed to the extent required for final ;* surfa:e inspection." It is alleged this has never been performed on {
;:v!r tool cleaned surfaces. It !s fu*ther alleges that in lieu of fol- I 1:xia; the procedure, the surface 3 are being bice down with c=:ressed ! ', ' ,
air cr wipes with a cloth rag. The concern with using coepressed air is . that the surface beco'nes contasinated with cil and/or water. The concern !
! with a clcth rag is that the serfcce becomes conta::inated with lint, ,
I i
- 41. It is alleged that when wiping a :griace leadiately prior to repairing that s;rft:e, the paint is wiped with a foreign cleaning solu:fon. Inis foreigt. cleating solution is alleged to be a hospital disir.fe: tant cen-
- tair.ing two (2) percent chlori
- es. The cere.ern is tnat this hosottal .
i j disinfectant is not allcwed by pretedure anc could cause stress corresion cricting of stainless steel.
\ .
- 42. It is allegen that duct tape has been pl'ced o over Ri hnond
. Inserts, leav- !
in; a hole behir.d the duct tape. Also, foam ruhber was left inside the . Ric.cs:dInsert. It is then alle;ed that 115 and 1201 are applied over
; the du:t tape. The end result is what appears to be a solic wall, b t in i
reality is a wall with holes in it entered with duct tape,115 and 1201.
- 42. It is alleged that zinc primer des nst sufficiently cured before a t:;
cost was appiled. It is also alleged that the pro:edures were not f:1-icved to deter::ine if the zine primer was preserly cured. } 4 It is alleged that the ' nickel' test was not performed properly due to , l instru:.i:r.s re:eived from QC sapervisors. It is alleged that O's;ner-visors instructed Q* f aspectors to lay the nickel flat on the surface of the cening; then to lightly rub the pickel, as lightly as the inspe:tst l c:vic, a:ros: the coating, te keep juat enough pressure on the nickel so that it would r.c fall out fres seder the fingers.
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"i. :: is alleged that repairs cf defects have been ec:caglisne: vi:r. ne re-
{ ins:e:tien f these ceft:ts. For exarple, a repair is made, someone co:- l es along and walks in that reMir, yod have accc;te:I that area as satis-f fa:t:.y with fact;rints, contacir.ation, sand, etc., and it is never re- 9 inspe:ted. It is further alleged that this repair is not given a final { its;e: tic?. cf the type that would have been performed had i: been a re-plar;toS:tiontypejob. {'
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- 45. It is alleged that during tooke gauge tests, it was observed that rust was seen on steel substrate, and grease, grime, filth, and other cen- {
ta:inants on concrete substrate. I* f
'7. i It is a'.leged that for an installation hanger for the steam generaters,
{ in viclation of a written instructly. OC irspe: tors were ins:ru:ted to > perfo;; c:proxi 4:ely 25 elcometer adhesim tests. I i e ti. f It is alleged that coatings have teen applied owr seismic joints. These f* jcints are filled with fon and wre so: to be coatet. I
';. It is allege:! that overspray fetc artu that has previously been j,,
inspe:ted has been allowed and is conexclace. 5 - r
- 50. It is alleged that coatings have tw applied without the benefit of evality c:ntrol ins:ettion. {
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!! is alleged that Phenolice 305 was thinned to a 53!!O mix with thir.ner.
[ t This 50/50 mix, when dried, beca= as brittle as glass. The Phenoline ; j ' 205 he:a:e s: trittle that it as not possible to ottain a to:ke cau;e ! rendirS. It lost its ic:a:t resistance and abrasion resistance. ! f k i .* . It is alleytt that ccatings have been placed over raw con: rete that ha: , t 9; surft:e pre:aration. g' l 8 f L 53, it is alleyed that E inspe: tors were not to write neovests for Info sa-
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or Clarification.
On la
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O ,y , j t 5;. It is alle;e: tha; during the lackfit Prograr, cnly the first unsa:11- - ft:::ry reading was re:orced, eten lf the folieving readings were e::ner i
).ig.er or icwer, eening further cut of t4: a::eptable range. 1;is hr:k.er alleged tha: the trend analysit was adverseiy affected by n:: ;
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i in:1:;:ir.g the a:tual readings. j
- I j i
- 55. 1: is alleged that areas identified durirg the Eacifit Program as being -
cutside of the a:ceptable range fc.r ailplied coatings were not removed as
. rt:: fred. .
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- h. E is allege that original doct-entatica rela:ed to the Backfi: Fro;rar cs destr:yed by ? nanage:ent.
57, h is alle;ed that in Unit 2, elevation MO, the roco directly off the slen::t hadan area ccated that wes covered with filth, weld spa:ter,
. : ta::o j: ice, and ether unsuitable material.
l 55. C hs:e::sr procedures such as Ql-QP-11.4-1 state: ' Ace:;ua:e lighting is defir.ed as the minimum ligirt pretted by a (2) cell battery flashlignt." h is alleged that the sintaa is cer, light. It is alleged that 0: l ir.s: :: ors were to perfore their inspections at ars's length, and if the li;r.: was bright, that wasn't the sir.ims. Ratner, it was the maxi um l and they sh :;ld obtain a weitar flashlight. ig. h is a*.*.e;ed that a 0; inspe::cr a:ceptee substandard coatings en :te l liner tiate, below and above the- pclar crane rail at a:i=uth 270' to O'.
!!. h is aIIe;ed that % Ins;ectors wre se*e:tively sent to vari:Us ins:e::i:ns so that the coatings woulc psss inspection. For exa:ple, l ;-::u:: ice : alls for C Inspection. W en the inspector arrives, he is t
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- 10:heyarenotready. P4 returns to the QC office. Dr. the way he 1
l res;5 a se: nd inspe: tor pro:ecing to the drea he was just told was not os .
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4 rs!fy for inspection. In this way, producion selec:s the 0" insoe::or ! d 0.'ite >!:: . It is als: alleged tRat QC canage ent would reassict at in- y I s:+=:r to a different tast if he was coing to reject a coating ae;11:a . t 6 tic:. It is frtner alleged that Z .snegment cid send two inspecors ! t b
- 1 s0== a: area, yet only one would sir tk inspection repart. It
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f 5 alle;ed that the inspector an signi;g tr,e repert would r.ot perfor as i ! I t.'.aro;;;. ar. inspection be:ause he did not want to anger E r.anage ent, I i l t Es:tcially since the ins etter did n:;t have to sigr the report, y . a l f 0 1 6 r i1-t
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In Reply Refer To: plF Dockets: 50-445 . 50-446 Texas Utilities Electric Comoany
- ATTN
- M. D. Spence, President, TUGC0 Skyway Tower ~
400 North Olive Street
, Lock Box 81 Dallas, Texas 75201
. Gentlemen: The attached enclosures are matters relating to alleged improper construction practices involving the Comanche Peak Steam Electric Station main condensers
. (Units 1 and 2) expressed by an alleger during an interview conducted on August 24, 1983 by members of the NRC Office of Investigation Field Office, , Region IV. Although the condenser units are components within the BOP j classification, the allegations expressed raise concern as to the quality of workmanship that could impact on reactor safety.
You are requested to provide this office in writing within 20 days, your l
' assessment of the extent that your quality control program was previously implemented during condenser unit fabrication and installation; a su mary of test results that will reflect existing leak rates; and an evaluation of tne impact of any expected cendenser tube leakage on y0ur ability to maintain satisfactory steam generator seconcary side water chemistry.
The response directed by this letter is not subject to the clearance procedures of the Office of Management and Buoget as required by the Paperwork i Reduction Act c' 1980, PL 96-511. i Sincerely. - ~' 1 N ' r. .n E -
- ..e w . ... .
R. L. Bangart, Director Region IV Comanche Peak Task Force Enclosures-Aliecer's Recorded Statemerts:
- 1. 6 ages 22 through 28 i 2. Pages 38 through 51, including MNj M.j_O 03pp-Exhibits 1, 2, 3, 4, SA, 53, ano 6 CONC'cRRENCE: -
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Texas Utilities Electric Company ' June 19, 1984 cc: Texas Utilities Electric Company Texas Utilities Electric Company ATTN: B. R. Clements, Vice ATTN: H. C. Schmidt, Manager President, Nuclear Nuclear Services - Skyway Tower Skyway Tower 400 North Olive Street 400 North Olive Street Lock Box 81 Lock Box 81 Dallas, Texas 75201 - Dallas, Texas 75201 bec to DMB (IE01) bec distrib. by RIV: RPS1 , RPB2 RRI-OPS RRI-CONST. D.Hunnicutt o J.T. Collins, RA R. P. Denise, DRSP RIV File . R. L. Bangart, D/TF S. Treby, ELD T. Westerman, EO Juanita Ellis, CASE Renea Hicks, EP Billie Pirner Garde, GAP Texas State Dept. Health R. Herr, OI W. Brown, RC 7~ f/W ' 9 d s.
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^ C: L : : :. , let's set. I c es. ' t knew new 3
ar ycu v: ant te get inte tnis, you x:.ow, as a fine line. Are you talking about extremely bac. Lixe the 4 concensers, fcr instance, 5 we took air nammers and sledge hanmers and ceat tubes. That is a no-no. Anybody would 6 know tnat. You taxe a copper-nickle I tuce about as thick as your wedding band and you take a 16 pound sledge hammer 8 and drive them. 9 We put ice on to shrink taem and put tnem in the condenser. That is a no-no. You are supposed to 10 ease them in witn our hand so they can expand. 11 MR. GRIFFIN: Was tnat particular instance in 12 your testimony or in your affidavit? 13 no,
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14 MR. GRIFFI6: That is new? 15 16 No, it is all new. We split tubes, belling the tubes and flaring tnem. We split 'tuce II sheets.
'I reported a tuce sneet split.to Westinghouse. -
18 They said on, my God, you Know, yeah, yeah, ye a h', 19 anc all tnis stuff. 20 The next day we had a meeting and we all went . there ana enere most have been 45 or 50 people, . 21 MR. GRI5 FIN: v'.'n en wa s th i s ? 02 3 Tnis was a couple of years ago. 3 1 24 MR. GRIFFIN: 3 Where are these tuoe sneets? , They are in tne condensers. ? i
. TAYLCE ASSOCIATE 5 162! l $TRt!T. N.W. - SWT! 1C04 WA!NlwGTCif. 0.C.. 200 $
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! 23 '
I t Ee: any-sy, wc nac a ;:::Is . Se v+ pr: :.c : c w::t nes n:ngneuse, and tney gc tna is net a h itir.gneuse , 3 preolem. Knat proclem? See, the cay cefore tney had a 8 problem that a tuce sheet was cracked. Then all at once , 3 they con't nave no more problem because they called their 6 1 home office and tney probably said you idi.ots, don't tell i
~
tnem. So they said tne only problem we have is the tubes 8 are not rolled up tight enough. I saio, we are cracking 9 ene tube sneets already and tney are rollec at a minimum i 10 and not a maximum. I said we would be in trouble if we had 11 to roll them to the max, or if we had to roll them over 12 tne max, superroll tnem.
. 13 (At this point intheproceedingsdlll I4
@ is rgferring to Exnioit 1.)
15 Bere is your water boxes right here and your condensers. All rigns, in condenser A on the inlet end on j' tne west oox and it is in three sections. You have go. I8 l so=e cracked tube sheets in here. Bacx there you have got 19 some cracked tube sneets. You have got overrolled tuces or 20 barely overrelled. They a.re supposed to be rolled 069
'23
- ncusand is a perfect roll inside reading. Tney allow us- t 2 to go to 071 tncusanc.
1 he went up 90-some enousands.
~I Ignad one hand come tell me and say my 1 24 expander run out. Manually ne rolled it so tight the t5 expander and motor jumped off. They just pop the= just I
f I ' t l j TAYLOE ASSOCIATES ) , 16*5 i STR!!T, N.W, = $Ul!! 103J l l W ASHINGTON. D4 20004 l l (202. 293 3950 i (
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1: 2s tne wrong type ci cencenser fer tne 3 wrcng type steam generator to start cff with. It was a Slu cillion goc -up. Westinghcuse said wait a minute, I :ning 5 we can straignt tnis proclem out since it is air 6 cendensers, waicn they went banxrupt anc are no more in i the concenser business. They deciced they had to 8 intergroove a tube sneet. They t:04 an in:h anc a cuarter 9 tu'ce sheet anc they cut it in half. Tney should have used 10 two tube sheets if they were going to do that and mace it Il twice as strong and not half. 12 MR. GRIFFIN: Are tnese things still tnere? 13 They are still there,, yes. All , 14 you got c to do is go in tnere.g It is,really terricle. Knat l.* ' I would suggest dcing is on the big ones lixe 90-some 16 t,ncusand is cutting the tuce out anc look at your sheet. 1 Tnere is a spider wed cracx. I snowed.tne people tne* 18 crack, and that is wnen I first starting getting tne ! 19 pressure, this is about three years ago, after I reperted ' 20 this stuff. I kept on insisting en tais crack, and taen - 21 everycody wculd go oo,c, and
, ne would sc, ycd 22 know, YEEEll, I am not for sure they are cracxed. I wculo 3
go I am not. Yec know, you can tnrow a cat enrough it, ans 24 he goes no, no, no. 25 Well, undouc' ted TUGCO told nam to eacx cf f . i i TAYLCE ASSOCIATES 1625 I STitt!", N.W. = $Ul71 1004 wA!HING?cv C.C. ::::t i
! f2C ' 293 29!:
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- c. . . ; c .. s c4. 00..ars. : they art t a ., .u .. ; a c c a t 1 c a r.:
3 tnEy Oct.'t want nothing to stop this plant. O These t.cces are titanium tuces and tnere
~
h should be twice as many support sneets in tnere and all 6 tnat stuff. So tney intergrooved tne tube sheet and tney [* still have got leaks over there on this section here and j 8 we are not supposed to have no leans at all. 9 MR. HER2: Sne can't see "rignt tnere" -- 10 i (Indicating tne reporter). So when you say section one, ! II i identify wnat you are pointing to. 12 i Okay. Condenser B, Unit 1, I3 west disenarge water box and you have got a cracKea tube ! e I4 sneet. Alsc, tne tuces are overrolled severely.
- 15 On the east water box, condenser B, discharge
'16 end, you are heavily overrolled and you undoubtedly nave i II got quite a few cracks in it.
I can swear tc '.nat. I knew ; 18 you do because it swelled up so cig. 19 . Overroll on the west box, condenser A, Unit 1, l 20 - discharge end. i 21 East water ccx, discharge end, : :..d e..s e r A , - S I you are still leaning, anc cverrciled. -
. n t1 ne more ycu roll, tne more tney leax. Tney !
04 i mode eney leak, the more you roll, and tne more your roll, 3 :ne more cacage you are doing. They just went nuts witn
. TAYLOE ASSOCIATES 1621 i STRIli h.W . $g.it 100,4 W A1HINr.iO N. D.C. 20006 J'2 293 3950 6
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1 *. . 2 Cenic..se: A, U..- 1, i..t a ke ::x, tne wcIt bx, 3 you nave got cracxed tube sneets. 4 It is very simple to checx because I put i . l 5 little plugs in enere. You can Just take a wrench and just i' 6 screw your two nuts loose and pull the plug out and loo.< l j 7 at it and put it right back in. It wouldn't take five 8 minutes to look. ' 9 M Exhibit 1 just referred to : 10 follows.) L' .j . 11 5 j i . 12 a 13 i 14
! 15 !
16 i II !
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18 i i 19 l 20 21 ,, ! 22 i 23 24 25
' l TAYLOE ASSOCIATES .
- 1823137Alli. N.W. = $Jift 1004 WASMiwCTON. D.C. 20004
- 1202,173 39$6 i i i i
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2 in. cvstrcill..g tacte t r. l .. g s ? he had an engineer tnere from i 3 6 . i,
# TvGCC saying get it a little more, get it a little more te my people. I went and told g . I said they are kalling 6
enat water oox. Nobody nad ever did the tuce werk before I and nooody knew. They are experimenting with an item. 8 in the first clace, the condenser wasn't a
' very gcod cesign'ed ccndenser, in my opinion. I have werxec l 10 on them since I was 15 years old. These was I woulo say 11 between 1 and 10 about a 6, you know, a so-se condenser.
12 Wnen tney intergrcoved tneir sneet, they macc the sheet 13 real, real enin. 14 MR. GRIFFIh: But did anyoody tell you or 15 inst.ruct you to do taat? 16 : I was instructed not to stop II leaxs, for instance. I was rolling tubes and I was I 16 stopping tne water box from leaking. I nave got a water , box over here leaxing an it is still leaking. I go tell 19 and I said 20 M , and Q says how does that box loon, 21 it loor.s gcod but the c ner one started leaking again, and' l U I have gc to get it. Ee goes goddacn, M , I can ge 3 enere any day and maxe tnings cetter than sney are. I 24 don't want you to do tnat. I go I am just trying to stop 05 :ne leans, you ,cnow. Yec ain'. supposed to have leans.
- TAYLOE ASSOCIATES 6
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bi I Ycur river water leaxs i r. c , ycu sn: , .nc- type sica- ! I t 2 r.c river water inside, it xe i genera or anc yoc car.'t al. low . . . . , . 3 So it is still leaning. My prociem was I of course ,! water. 4 coulcn't do a good joo. k i 5 P.R. GnliFIN: You are saying it is still 1 6 leaking today or it was still learing when you left? i 7 M: It was still leaking wnen 1 8 left and it is still leaking today because they didn't , t 9 rewor4 it. 1 l 10 P.R . HERR: Who was the engineer? l 11 12 MR. HERR: Let me get one thing straight. l 13 Excuse me for a second. M 2and , were ' 14 they your supervisors? l 35 was my I 16 supervisor. { 17 + F.R . dERR: hhat was nis title? 16li : He was the J \ 19 m. 20 MR. HERR: Who was the other guy, g Wnat 21 was nis ]cb title? l 0- : He was a tnree striper. I ! U don't knew wnere he come from. he don't know anything. He i 24 is suppond to be a g tnree striper. I 23 PJs. HERR Wnat is a three striper? l I I i 1 TAYLOE ASSOCIATES i It:1 1 STRt!?, N.W. = SV;7I 1034 f
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9 i 4 eneexe: tnc w e ' d r c r. it. he Teje::ed all tr.e wel:4. We had 5 a rig hooker. up. he ever. rejected the facter wels:. g i 6 . he said nave y u :.ot a condenser in that noie ! yet? I go no, I saic it dcn't look lir.e we are scing to cc 8 it eitner tecause a BOP inspector Just torned down all tne 9 wetos. 50'; ne started cussing. ne said I wan- t r.a t son cf I e i 10 a citen's name ans cadge numoer. Se he started making c&lis. So I dropped back 11 I I 1 tc the guy and r.e just ocught it off sittinc, in his 13 office. Well, at : matter of fact, it got to a point wnere 14 they w:uldn't even come'and look at ncne of the welds. 15 Tney woulc just buy them off. , 16 P MR. GRIFFIN: Wno is this guy again tnat bought
!* I 10 cf:7 i lt .
I
- I den't xnow his name. He is - !
I 19 { still Out .c.e r e . . g I tnink,it tr.e last na: e. MR. GRI! FIN: ? 20 , s '
- r. ;
- 1ed'. He get rur. off cf 537 a.d I t..:.nn r.e erded up ir. QC. I t h :. n r. n e n a. .e wa s Q. .
23 XR. HER?.: What year was tnat? j
- : This was pr:ca ly '79 or 'e0
;4
;3 wr.er. we wa4 retting Unit I co r.d e r.s e r s . C::.co..ser A was l 1 I
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- F.R . G RI FF I t. : M t r. i s is ce f er s r.e was a ;
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Yet. he was a 90P inspector. , 6 7 Fa. HERR: BCP?
- Rignt. ,
e 4- VA. GRIFFIh Anat is BOP? I don't xnow wnat I 10 tnat is. i. 11
- I can't xnow either.
1: M: Balance of plant. You said tnat tne 13 condensers here are non-Q, out they are Q at other plants? 18 They are Q in South Texas. It 15 is according if they want to make them Q or not. Iney are l 16 safety relatec because ycu can',t operate the plant'without 17 t'ne c ndenser. It is just'that simple. For instance, that .
- .s t..e rea.4or. ycu r. ave got che ir..ergroove ir. tne tu:e i ,
16 i 19 sneet cecacse you cannot allow the water in ene s.eam generator occause tney got problems, you xnow. I don't 20 kr.:w cw isst r.ey can cool a reac :r dewr. if s:.e ..ing , 6:.6 .a;,per te tne co,ndensers, lixe if tube sr.eets cast cit I i
- 3 with .ater pressure or something. l
- 4 I was going to show you how they weaxen a tube
- 3 ,
s.,ee t , but I des,' - guess that is necessary. i i o
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- Someentre d wn ners t c.e y .a a 4 nice tnics tuce sneet to sttrt eff.
5 (N it leafin; through his 6 ncteboc4.) This is a real 9000 example. Tnese tube 8 support sneets came in. We imid them on top of eacn other 9 and we put uowel pina in enem. Sc=e of t.1e neles waJ s 10 chree-eigntas o,f an inen of f; f rom tne otners, you know. 6 11 t56 I callec jglll Eland I told him, I saic we , 12 are going to have a proolem here. These hcles are way off. 13 hell, he calls Westinghouse, and Westinghouse says ch, 14 enere is nothing to it, g says, g , they are just 13 tnree-eighths of an inch off. I said well, you have got 16 three foot from the center of one sheet to the other, and i 1- , wnen you start off with three-eighths of an inch off you I 15 , are ofi quite a ways when you get to tne ct..er enc, y:o - i 191. know, tne three foot. 20 If you go enree-eighths of an inen off, over
- , cere you ..1;nt =e an in:a and a half eft, and cy tne tire
- y:u turn : sace. :n enen automatically you are going to 3l i neac the cener way. So you are binding overy rheet. You 24 are cutting into the tuoes.
25 Tnese tuba suppett sheets are made with a i TAYLOE ASSOCIATES 14 :1 1 $7tIIT, KW, . Swff IC:4 W AI M r ** : TON 0 C. ::::4 i:*: 2933910
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a.. 4 Tr.is is wr.at I ant b c onde n s e r s , t r.e tr.a in cor.de ns e r s .t r.e 5 taIxing nothing about talxing about. I ar. not 6 Everything is the main :endensers. . 7 Aur.iliary condenser. li'<e 39 tacesand Inere is supposed to be somethin? ycur tubes' 8 sheets so that 9 clearance i n ene tube support how your tr.ain binding. 10 can expand in its track without l tnese. is 10 thousand before they rol tube sneet 2, the docurr.ent just ( g Exhibit 11 1: reierred te, follCW58) ' 13 8 I *%,,, 1 14 0
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- Nc, I dicn't d:seuse 1. wit.
3 seemed 1:se snen you 'cring up a pr:cis-4 anycot,' ce:suce it 5 it is covered up. In my opinion, it is not corre:teu at 6 all. Tnat is the reason I wanted to cring it out and I nave i w:ulo like to snow people. They stuff nere cculon't 8 been ecvered up except by paperscr< be:huce 3:a ca.. ;o inside 9 cown enere any day of the ween anc read,the 10 diameter of your tube and you know you are overrolled. Everytning that I could actually put ,r.y finger 11 just lixe 12 on, like the letter, they automatically agree, 13 ene lignt poles, you know. That is a 15 cent item I brought up. Well, they jumped on that with botn hands and 14 and made a big deal out of it. They really 15 both feet 16 cleaned tnat up. l~ Well, you have got some spray pipes also down them 18 in snere, hell, it is going to ce a bigger joc to cut . Tney haven't even mentioned snat, see. I 19 lo:se to do it. Inat sces in ; 20 think I mentioned that one in my affidavit. four spray pipes tnat go down , 21 tne faal pools. Y:u nave got i in tnere. ihe heles cf it was undersi:es and ene pipe , t' in enere and redrilled them and tney used m department went 24 cutting material, luce oil or some type of cutting oil and l 05 tney sust pulle: it =ff ana enere it was. . 4 TAYLCE ASSOCIATES lt:11$fA117.M.W.. $ sit 1C04 . W ASHINGTCH 0C 20006 . (202; 2f 3 2930 E i
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he, tney ncver. and tney ; , 3 'M: i I e' i it. 4 prcetely wor.'t until you tell tnen aceut : f-i yR. GRIFFIA: Eut you have already proviceo , 5 I
- e 6 tna; in your affloavit? 1 l 5 1
I think So. I About the light poles? 8 Ms
- 50, tnis i s s o.T.e Inc r e . Tne ,
J 9 lixe so. 10 light poles, tney coulo take those out I tnink the light poles are all 11 M 12 that you talked about' g I believe. I don't recall the other. Sco, one day I watic to set 13 N: But I 14 down and just make a whole cook of it, you know. l 15 nave always been so busy and I don't nave the education 16 and I can't do it, you know.
- g: Tnere was an investigation cone by i 1
1
.r.e tiR;: Regier. IV of fice aosat tne tnings that were in .
i 16 ' a newspaper article snat were done. l 19 MR. HERR: Excuse me, was that an investigation
- 20 .
i
- 1, er a. insportic..? .
It was an inspection I celieve. I, .
- [
01 dor. ' t thin 4 it was cone by the investigators. ( Thank ycu. 24 MR. liERR This is one of tr.e things inat
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i, I 2 a.y 1:1.*e -a; :: t.. i t . nt we..: ..cen p ciar tr.c; s:.c::ti t, 3 ether sna.. One .;egion 2.' anspe :: t ge oJt and fcllow-up [. 4 cn tnis, i 5 ) : On your inlet tube sheets. 'i l 1 1 6 They are 1/32nd flush, tne tuces, and tr.ey are flared. If [ j 7 they are sticking out, ycu get a bulic-up between your i t a tuces. So when we flared these we testac a ... c.! tanet, I 9 or quite a few of them as a matter of fact. : s l l H) Now tnis chart, and it sticks out, but we cut < l ) 11 tnem down like a half inch so it would look nalf way l
~
l 12 decent. But when we was flaring tnese tubes tney was
- i j 13 busting pretty cad, and the reason they was busted so bad j . 14 in this one area ls' because tne counterbore'in your tube ;
1 ! 13 sheet wnere.ac. allows thes flare to flare out was way : i 16 overboard. So in order int us to flare it tight enough we f t i- . l 17 busted a tu:e, and the ones tnas clan't burt we hadn't ! i flared it tigns enough. *nen ycu don't flare tnem tight" It i t to enougn you get a build-uq between your sheet and your 3) i tuces and it eats the tube off. 7 i i 21 Just lir.e tne joo in Ncrtn Carclina, we na' "
,t 22 neles in a*1 the tuses before we ever got tne fuel in ji 2
i m tnere. *.no first two weeks it was eat up. So insteam of us i i 2 repairing it, we had several mentns before the fuel came lI i .a; in, they went aneac and poxied it in and used it as is and j ! g ; i i I ' TAYLCE A550CIATi$ leal i Statif, N W e $Ulf! 6004 "{ l! WalMtei4fOW. D C. :::M f t:1 393 3*lt ;
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6: Tne flare is tne antaxe eno of 6 all condensers and your water boxes. I , I
.sR . HERR Is this in Glen Rose?
8 6 Yes, Glen R:se, Texa2 at Cc..an:ne Pea 4. 6ost of the n is in consenser A on tne inlet lo end cast water box etidsle way of the shoot. II ( EXhiD4t 4 follOWSI) 10 13 14 g i 15 16 17 l 18 1 - I 19 \ 20 4 21 . C , n 23 I 24 23 . I TAYLOE ASSOCIATES 142 $ i 178 tf7, H W = l.lfi1004 W ASM
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tcese. 8 3 M: Oxay. We was we4 ding tne c:ndenser to tne turcine. Again, 1 nate to bring up 6 ex;erience, out wnen you are bringing tr.is conconser up, I you set une condenser low, out when you set the turbine in 8 g,L.ey can set it on the right elevation and not be in tne 9 way of tne conuenser. 10 When you get your turbino perfect within so Il many thousanoths, you bring your condenser up to meet. You 12 don't w make a contact with your turbine. You come ur lixe a I3 quarter of an inen or an eignth of an inch with your I4 expansion joints. You have an expansion joint in,between II it. 1nen you tie them together. ! 16 Well, the condenser was so neavy when you load U it with tubes and everything. It procacly weighs 6ut tons. , 18 kell, we toox all our jacks and put tae.v. on one end so we . 19 nad to rack it up. Of course, wnen you 3ack at one end it 20 tnrows it way in and then you picx tne other side up and 3 21 it tnrows it way in. so 1 old unis general fore.?an, and I was just 3 fere.7.an then, cut I told the other fore.v.an don't tie i 28 anything to tne turbine to tne condenser. I said we are 23 going to go up anj it is going to fall d: n, but when we l TAYLCE ASSOCIATES
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ne a: arts wel::n; all sin: of etuff te neld it to keep , t 5 from coming past it, well, what we did was we jacxed the ; turoine over, he went ahead and got it up. Well, instead of tnem mar.ing a final eneck to see whetner they was in 8 line or not, tney just assumed tney were and they was , three-aightns of an inch off. So we welced it all - 10 togesner. II They took a reading and tney was three-oighths II of an inch off alignment. So they went up here and they 13 took jacks and tney started jacking and, ccy, jacked it , i l' all tne way over to wno're they want it and they relaano j 15 it, that little old expansion joint, and pulled it back. I6 The little expansion joint was a one loop and it was an II oigntn of an inen snick and it had cne little fillet wele 38 on eacn sace of it, real weas. Tney put several, several I' l l tens on it. I will snow you what 1: looked lixo. 20 ( M Exnibit SA and 58 fo11owsil l 21 I l ! B 24 O!, l l l l ' TAYLCE ASSOCIATE 3 tell i Stilff N W . lui?l 1:04 g WalHINSTCN OC 30304 l 1303 393398" .
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ar.vt.1vv6 in all sc.28 w:.r x i 3 4 M Nu, a lot cf it tnere weren't, r.r . 5 MR. GRIFf1h Your crew was down tnere putting 6 tnis turbine en top of tnis condenser?
- Right.
8 MA. GrtIFFIh Is tr.is a non-Q area alho? Rignt, it is non-Q. We are 10 down here tarowing tnat turbine back. They started having ' II us Jacx it. We jacked it up and down putting all xind of l 12 stress on it, and well sideways. You know, you can tear I3
' l tnat little expansion joint out. - M So I finally told M and tne general 15 foreman over the turbine that I weren't going to jack it I'
no more witnout tnam giving me written permiasion to do it l' cr telling me to do it :.n writing because I says I magnt 18 want to worx another jco somewheres, and I saic 1 will - 19 never work for Brown anr. Rect again if we rip it out, but . 20 I might want to worx an tner construction joo, you know. - 21 So finally tney quit 34:xing at enen. O Alsc, as ao jacned the condensor up, tne pi;c 11 department was tied in with our pipe. They was also 28 supposed to tage a pipe up with us, wnich they didn't de, 23 and we put a lot of stress on tne pipe. TAYl.OE A550CIATE5 i un a stuir w w. . swt to:4 walp4fW D C. 33336
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n as, tr.e 03 c2 tr.c 7.e:e ar.: C:. el ne t.be L :. : ...a 1- :s 3 suppored to ce 1: 4e after we get tnrougn ro;1:ng it to ce [ 4 l a periect rola. _. i 5 ! MR. GRIFFIN: The condenser tubes? , 6 I
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l is tne minimum we are supposed to roll enem, tne ID l 8 reading. 5 PJs . GRIFFIN: Can we have tnis alsc so we can 10 give it to tl.e inspectors? II
- Yes.
12 MR. GRIFFIN's ac would appreciate that because l II if these guys can go signt to the stuff and lock at it, it I4 will sure be nolpful. l I 16 ( M Exhioft 6 follows:)
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( t r. s repcrter net:ee: a crc.c;.; e- :s t :: i 2 sice cf Exn;;1t 5 and cr:.upn- :: te l j 3 attention.) 4 M: (deterring to Exn:t: SE)Cn, 5 this is the expansion 3cint I was talxing aoout with the 6 fiAlet welds. It is a real small stainless steel 1/etn expansion joint and it has got two small, little fillet 8 w3165 nere, 9 MR. GRIFFIS: Okay. I tnink we nave got tnat 10 down in tne testi nony. 11
- We put several, several, I I2 thing t.o or tnree hundred tons against it.
13 okay, stainless steel liners. This is lixe the 14 reactor building and tne fuel building. he are supposed to 15 have a gap in here on our fit-ups. This is not in there. 16 Mh. GRIFFIN: This is sosething new? II *
- Yes.
18 MR. GRIFFIN: Okay. - 19
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U I MR. HERR: 'ahere is it? For une re:ord, t i describe wnat it is. U This is a stainless steel 24 liner Tnis is an embed floor plate tc, angle on the cottom 23 and side plate to an.;ia. I don't xnow exactly wnere, but i l TAYLCE ASSOCIATES
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l O hnhn l In Renly Refer To: Dockets: 445/84-08 50-446/84-04 , ,, r.%, '.e q .g .qp-th t'.h
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Texas Utilities Electric Company QC -l'E,n. V . C ; J ATTN: M. D. Spence, Pmsident. TUGC0 Skyway Tower Yf. .,. y . , , .) {j'd 400 Marth Olive Street $W(.y - Lock Box 81 Dallas, Texas 75201 Gentlemen: This refers to the inspection conducted under the Resident Inspection Progras by Messrs. J. E. Cimsins, W. F. Smith, L. E. Martin and C. R. Serg of this office during the period Novenber 14, 1983, through March 31, 1984, of activities authortzed by NRC Construct 1on Pemits CPPR-126 and CPPR-127 of the Comanche Peak facility, Units 1 and 2, and to the discussion of our findings with Mr. J. T. Merritt, and other members of your staff at the ! conclusion of the inspection. Areas examined during the inspection included if censee action on previous findings,10 CFR Part 50.55(e) report followup,10 CFR Part 21 mport follow-d up, allegation followvo (thit 1), independent inspection of coatings, train-ing of protective coatings inspectors, review of safety-related systems - (Unit 1), inventory of audit meterial in custody of NRC, and plant tours. Within these areas, the inspection consisted of selective examination of pro-cadures and representative records, interviews with personnel, and observa-tions by the inspectors. The inspection findings are decisnented in the .. enclosed inspection report. ' During this inspection, it was found that certain of your activities wem in violation of NRC requirements. Consequently, you are required to respond to this violation in writing, in accordance with the provisions of Section 2.201 l of the NRC's " Rules of Practim," Part 2, Title 10 Code of Federal Regula- .' tions. Your msponse should be based on the specifics contained in the - Notice of Violation enclosed with this letter. During this inspection, it was found that certain of your activities appeared to deviate from a coussitment made to the NRC. This item and reference to the cassnitment are identified in the enclosed Notim of g ;eC Deviation. You are requested to respond to this deviation in writing. -$pYi+ u. Your msponse should be based on the. specifics contained in the ice of Deviation enclosed with this letter. 3) h DRS&P g TF- iF-RI TF ; $ ', RPDenise T. A EG ardo man R rt hs p [/f/84 4/84 7 /8( _
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Texas Utilities Electric 2 Company
- In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Doctment Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
The responses directed by this letter and the accompanying Notices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96511. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. ' Sincemly. Original Sitesa 378 Riebard L. kwan Richard L. Bangart, Director Region IV Task Force
Enclosures:
- 1. Appendix A Notice of Violation
- 2. Appendix B Notice of Deviation
- 3. Appendix C NRC Inspection Report 50-445/84-08 50-446/84-04 cc w/ enc 1:
Texas Utilities Electric Company -- ATTN: H. C. Schmidt, Manager . Nuclear Services Skyway Tower 400 North Olive Street Lock Box 81 , Dallas, Texas 75201 . Texas Utilities Electric Company ' ATTN: B. R. Clements, Vice President, Nuclear Skyway Tower 400 North Olive Street Lock Box 81 . Dallas, Texas 75201 4
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APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Docket: 50-445/84-08 Comanche Peak Steam Electric Construction Permit: CPPR-126 - Station (CPSES) Unit 1 Based on the results of an NRC inspection conducted during the period of November 14, 1983, through March 31, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following violations were identified: A. Gaps on Unit 1 Polar Crane Bracket and Seismic Connections Exceed Design Requirements 10 CFR 50, Appendix B, Criterion V requires that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Design change Authorization 9872 required that all gaps on the Unit 1 polar crane bracket and seismic connections greater than 1/16 inch be shinsned. Contrary to the above on February 13, 1984, the NRC inspector reviewed the polar crane bracket and seismic connections listed below and observed that there were unshimmed gaps that exceeded 1/16 inch. Connection location on Girder (looking Approximate Girder Number from inside containment) Gap i 23 center 1/8" . 23 right 1/8" 26 right 3/16" 20 center 5/32" 20 left 3/16" 19- right 3/16" .. 17 center 5/32" ' 16 right 1/8" This is a . Severity Level IV Violation (Supplement 11.D) (445/8408-01). i B. Failure to Perfonn Inspections of Installation Activities Related to _ Unit 1, Main Coolant System Crossover Leo Restraints Criterion X of Appendix B to 10 CFR Part 50 requires that inspections of activities affecting quality shall be established and executed by or for the organizations performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity. _
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.I 4 2 J Texas Utilities Electric Company Quality Assurance Plan, in Section 10.0, I requires that planned written inspection procedures be utilized. It ' i further requires that inspection activities include the types of , characteristics to be measured, the methods of examination, and the criteria. - 2 Contrary to the above, it was determined that inspections were not made of
- the installations of the Unit 1 crossover leg restraints, nor were any documents requiring such an inspection issued. Specifically, the require-1
' ments for installation, as specified in Gibbs & Hill Drawing 2323-SI-0550, were not inspected and documented. The eight crossover restraints (2 per i loop) are major components of the main coolant piping seismic restraints and support system. j This is a Severity Level IV Violation. (Supplement II.0) (445/8408-02) 4 i Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company 4 is hereby required to submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the-corrective steps which have been taken and the results achieved; (2) correc-tive steps which will be taken to avoid further violations; and (3) the date 1 when full cmpliance will be achieved. Consideration may be given to extend- ] ing your response time for good cause shown. l Dated: July 26, 1984 1 1 4 9 d ep i e D d l 4
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APPENDIX B NOTICE OF DEVIATION Texas Utilities Electric Company Docket: 50-445/84-08 Comanche Peak Steam Electric Construction Permit: CPPR-126 Station (CPSES) Unit 1 Based on the results of an NRC inspection conducted during the period of November 14, 1983, through March 31, 1984, and in accordance with the NRC enforce-ment Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8, 1984, the following deviation was identified: Deviation from Design Infomation for Installation of Seismic Category I/ Seismic Category II Structural Steel for the Bolted Connections Between the W16x40 and the Wall on Platfonn OP-11 in the Pressurizer Compartment.
- 1. CPSES FSAR Section IA(J), on page IA(B)-26, states, "The quality assurance program for design and construction at CPSES incorporates the intended objectives of ANSI N45.2.11." (Draft 2, Revision 2 -
May 1973) Contrary to the above, the licensee did not incorporate the intended objectives of ANSI 145.2.11 into the design of certain personnel access platforms at CPSES. A review of the design documentation, including Gibbs and Hill Drawing 2323-51-0556, Revision 4, Design Change Authorization (DCA) 9764, Revision 3, and DCA 1090, indicated that the above platfom was criginally designed as nonsafety-related.
- 2. ANSI N45.2.11 (Draft 2, Revision 2 - May 1973), paragraph 3, requires that design input requirements be specified to the level of detail necessary to permit the design activity to be carried ot.t in a correct manner and should include basic functions, loads, and ,,
physical interfaces. ANSI N45.2.11, paragraph 8, requires that design changes be subjected to design control measures commensurate - with the above. Contrary to the above, the design documentation was upgraded to Seismic Category II with the particular beams supporting safety-related instrument tubing for two channels of pressurizer level upgraded - to Seismic Category I. DCA 1090 required that the bolted connections-between the W16x40 and the wall be " hand tight only", but did not address any locking device or thread upset to prevent nut backoff.
- 3. AISC Manual for Steel Construction in the Specification for Design, Fabrication, and Erection of Structural Steel for Building in --
Section 1.23.5 addresses the need for tightening high strength bolted connections to prevent the nut from loosening and falling off. .
&'b. b$h Opp. _
d 2 4 In deviation from the above, DCA 9764 upgraded the platform to Category I and changeout of material, but did not change the connection requirements specified in DCA 1090. This is a deviation (445/8408-03). Texas Utilities Electric Company is hereby requested to submit to this office within 30 days of the date of this Notice of Deviation, a written statement or
- explanation in reply, including
- (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further deviation from commitments made to the Commission; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
Dated: July 26, 1984 i I 1 .i 9e O 9 4 6 g- - -.
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APPENDIX C U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-445/84-08 50-446/84-04 Dockets: 50-445; 50-446 Construction Permits: CPPR-126 CPPR-127 Licensee: Texas Utilities Electric Company (TUEC) Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At: Glen Rose, Texas Inspection Conducted: November 14, 1983 through Parch 31, 1984 Inspec ors: b I /O,!8 Y
, J. E. Cummins, Senior Resident Inspector-Construction / Date (paragraphs 1,2,3,5,6,7,8,9,10,13) i h == &
W. F. Smith, Resident Inspector-Operations 9//O/Bf
/ Da te (paragraphs 1, 4, 13) .,
W 6 /) V L.1. Martin Aeactor Inspector, Engineering Section / p(te ' (paragraphsd.11,13) C. R. Oberg, Reactf Inspector, Reactor Project Sec. A
/off Da te (paragraphs 1,11.T3) e ye- a-
1 l 2 A if fv . IT r cn s b ('/bll*i/ D. M.' hunnicutt', Chief, Reacpor Pro @ct Section A Date (paragraphs 1, 3, 9, 13) g 4
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[ /V[J/h Approved: /(!id tiu ,:o , t D. M. Hunnicutt, Chief, Reacto Froject/Section A Date Inspection Sumary - Inspection Conducted November 14, 1983 through March 31, 1984 (Report 50-445/84-08) . Areas Inspected: Routine, announced inspection of licensee action on previous findings, 10 CFR Part 50.55(e) report followup, 10 CFR Part 21 followup, allegation followup, independent inspection of coatings, training of protective coatings inspectors, review of safety-related systems, inventory of audit material in custody of NRC, plant status, and plant tours. The inspection involved 190 inspector-hours onsite by five NRC inspectors. Results: Within the ten areas inspected, two violations (gaps on Unit 1 polar crane bracket and seismic connections exceed design requirements, paragraph 3 and failure to perform required inspections, paragraph 11) and one deviation (deviation from FSAR design requirement, paragraph 11) were identified. Inspection Summary Inspection Conducted November 14, 1983 through March 31, 1984 (Report 50-446/84-04) - Areas Inspected: Routine, announced inspection of licensee action on previous findings, 10 CFR Part 50.55(e) report followup, 10 CFR Part 21 report follow-up, independent inspection of coatings, training of protective coatings inspectors, inventory of audit material in custody of NRC, and plant tours. '-
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The inspection involved 44 inspector-hours onsite by two NRC inspectors. Results: Within the seven areas inspected, no violations or deviations were identified.
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9 3 i i i DETAILS
- 1. Persons Contacted r
Principal Licensee and Contractor Employees
- *B. R. Clements, Vice President, Nuclear Operations
*J. C. Kuykendall, Manager, Nuclear Operations
*J. T. Merritt, Site Project Manager
*R. A. Jones, Manager, Plant Operations
*T. L. Gosdin, TUGC0 Public Infomation Coordinator
*R. T. Jenkins, Operations Support Superintendent
*M. McBay, Engineering Manager, TUGCO Engineering and Construction (E&C)
*R. P. Baker, Staff Engineering Manager, TUGC0 E&C
*R. G. Tolson, TUGC0 Site QA Supervisor S. Spencer, QA Auditor (Corporate Office)
J. Marshall, Licensing Supervisor (Corporate Office)
*D. E. Deviney, Operations QA Supervisor
*T. P. Miller, Lead Startup Engineer. TUGC0 i
*C. H. Welch, QA Services Supervisor
*H. A. Lancaster, Startup QA Specialist
{ *J. C. Smith, Operations QA
*M. Riggs, Operations Support Engineer B. C. Scott, QA Supervisor 1 A. Vega, QA Services Supervisor R. Kissenger, Project Civil Engineer
- J. D. Hicks, Assistant Site QA Supervisor
- R. L. Moller, Westinghouse Site Project Manager G. Purdy, Site QA Manager Brown & Root (B&R)
H. Hutchinson, Project Control Manager . G. L. Morris, Site Mech. Level III ASME Qualiry Engr. B&R The NRC inspectors also contacted other plant personnel including members of the construction, operations, technical, quality assurance', and admin- ' 1strative staffs.
- Denotes those attending one or more exit interviews.
- 2. Plant Status ,
Construction of Unit 1 is approximately 97% complete with fuel loading scheduled for July 1984. There is presently a great deal of effort to complete areas and then turn the completed areas over to Texas Utilities Generating Company (TUGCO) operations. The turnover process requires two phases. The first phase takes place when construction - completes a specified area and turns that area over to the startup 1 group. The second phase of the turnover process is when TUGC0 opera-tions completes final acceptance of the area from the startup group. The licensee has identified 422 distinct areas which are .to be turned over. As of March 9, 1984, 158 of these 422 areas had been turned
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4 over from construction to the startup group. TUGC0 operations has made final acceptance of 66 of the 422 areas. The 422 distinct areas identified by the licensee to be turned over vary greatly in size and complexity; therefore, the number of areas turned over pro-vides an indicator that progress is being made, but to make a determina-tion as to the degree of progress, the size and complexity of each area must be evaluated. Construction of Unit 2 is approximately 65% complete. Fuel loading is scheduled for January 1986.
- 3. Licensee Action on Previous Inspection Findings
- a. (Closed) Violation (445/82-11): Failure to Perfonn Inspections of Installation Activities Related to Unit 1 Containment Polar Crane.
The licensee's Nonconformance Report (NCR) M-82-00894 documents the above violation. The disposition of NCR M-82-00894 directed that the polar crane girder connection finger shims previously installed per DCA 9872 were to be removed and inspected and any deviations from the requirements of DCA 9872 were to be identified to engineering for resolution. The licensee removed and inspected all of the finger shims associated with the Unit 1 polar crane bracket and seismic connections. During this inspection, any shim that did not meet the design requirements of DCA 9872 was replaced. This included the replacement of ten finger shims that were found to have clipped fingers. Operational traveler CE-82-370-8104 was issued to accomplish and document the shim inspection and rework directed by NCR !!-82-0094. Traveler CE-82-370-8104 also instructed that the new shims were to be installed per the requirements of DCA 9872. The shim inspection and rework was inspected and documented by . quality control (QC) inspectors on NCR M-82-00894. This NCR was closed on January 24, 1983. The quality control inspection of
. the shim rework satisfies the requirements which were previously i
not met and which resulted in the original violation. This item is closed. However, the NRC inspector performed a random inspection , of the polar crane girder connection shims and had the following two concerns: ' (1) Design Change Authorization (DCA) 9872 required that all gaps greater than 1/16 inch be shinined. In addition QC personnel verified that the gap for each polar crane girder connection was _ less than 1/16 inch and documented this on a shim documentation
- card which was attached to Traveler CE-82-370-8104. However, the !
NRC inspector observed that the following randomly selected ) girder connections had gaps that exceeded 1/16 inch: m.
,5 Connection Location on Girder (looking Approximate Girder Number from inside containment) Gap 23 center 1/8" 23 right 1/8" 26 right 3/16" 20 center 5/32" 20 left 3/16" 19 right 3/16" 17 center 5/32" 16 right 1/8" This is an apparent violation (445/8408-01).
(2) DCA 9872 required that the shims be tack welded as shown on Gibbs and Hill sketch SK82032 (Sheet 3 of DCA 9872). General Note 4 of SK82032 states that shims in the seismic connection may be welded to either vertical plate; however, on the seismic connections for girders 18, 22, 26, and 27 the tack welds which welded the shims together also tack welded the vertical plates together. This concern was discussed with licensee personnel. This is an unresolved item (445/8408-04).
- b. (Closed) Severity Level IV Violation 445/8323-02: Instructions.
The five jam nuts identified as being loose were reworked and verified by QC to be " snug tight." The inspection checklist of procedure CP-QAP-12.1 was revised so that jam nut tightness is verified.
- c. (Closed) Unresolved Item 446/8309-01: NDE Level III Certification The licensee inspector's NDE Level III certification was rewritten on -
May 27, 1983, to show that his certification was based, in part, on successful completion of examinations.
- 4. 10 CFR Part 50.55(e) Report Followup Inspection
~
The RRI (Operations) conducted a review of all reports made by the licensee pursuant to 10 CFR 50.55(e) since the CPSES construction permit was issued on December 19, 1974. During the period between December 19, 1974, and February 17, 1984 NRC reading files showed that 103 reports were transmitted to the Comission. TUGC0 logs were in agreement. Of these, subsequent correspondence indicated that the _ licensee, upon further investigation, concluded that 57 reports did not meet the reporting criteria of 10 CFR 50.55(e) and thus were "not reportable." - The balance of 46 10 CFR 50.55(e) reports appear to be reportable except for three recent items, which were under investigation at the time of the inspection. _
6 The RRI noted that 2610 CFR 50.55(e) reports had been closed by the r licensee. However, the status report published weekly by the site QA secretary indicated that they were awaiting NRC action for closure. The licensee's representatives stated that the item would be closed and removed from the weekly report as soon as the SRRI (Construction) reviewed the records submitted to him and specifically addressed each in an inspection report as satisfactorily closed. At the exit interview of March 2,1984, the RRI pointed out that this is not a 1 requirement of the NRC and as such the NRC should be removed from the , status report as actionee for closure of each item. The records submitted to the SRRI (Construction) should be retrieved and placed in the appropriate licensee-controlled file, subject to future NRC , audits. During the exit interview the licensee stated that this would be done. The RRI reviewed eight of the 10 CFR 50.55(e) report folders in detail. The licensee refers to them as "Significant Deficiency Analysis Reports" (SDARs). Attributes evaluated included followup correspondence, depth - of investigation, and compliance with reporting requirements. The eight folders were numbered SDAR 81-07, 82-03,82-07, 82-09, 82-13, 82-14, 83-03, and 83-20. Half were ruled "non-reportable" by the licensee, and half were " reportable." The RRI did not observe any deficiencies in any of the folders. In addition to reviewing specific SDAR records, the RRI reviewed the l following applicable procedures: CP-EP-16.3 " Control of Reportable Deficiencies" 3 DQP-CS-6 " Reporting of Significant Deficiencies" CP-QP-16.1 "Significant Construction Deficiencies" ! CP-QP-15.6 "SDAR Status Tracking" -- l The above procedures appear to meet the requirements of 10 CFR 50. The condition and tracking of each of the SDAR packages substantiate this. However, the RRI noted that the corporate office in Dallas, Texas, has one numbering system with their own log for SDAR's originated in i the corporate office. The CPSES site QA office has another numbering . j system, with their own log, for SDAR's originated at the site. The , corporate office tracks all SDAR's, but CPSES tracks only the SDAR's originated at the site. At the exit interview of March 2,1984, the i RRI coninented that Site status report addressees could be led into believing the site tracking system is complete when such is not necessarily the case. _. No violations or deviations were identified. 4 e
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- 5. Followup of Part 21 Report On February 3,1984, a licensee audit of one of it's suppliers, Gulfalloy, j Inc., identified an apparent falsification of inspector's eye examination i .
records. This apparent falsification of records was reported to the NRC by Gulfalloy, Inc., in accordance with the reporting requirements of
- 10 CFR Part 21. The falsification of eye exam records occurred when j the eye exam records from an eye exam given to three inspectors on November 13, 1980, were photocopied and the date changed so that it would appear that the three inspectors had also received eye exams on L~ October 22, 1981. Additional eye exams were given to the inspectors on September 15, 1982, and again on January 16, 1984. The Gulfalloy, Inc.,
employee responsible for ensuring that the inspectors received the required eye exam was also responsible for reviewing material manufac-
- turers chemical and physical test results.
[ The NRC inspectors discussed this event with licensee personnel and were informed that corrective action would. include a review of the records of i- material received from Gulfalloy, Inc. The NRC inspector will continue i to monitor the licensee's corrective action. ! No violations or deviations were identified.
- 6. Followup of Allegation The following allegation was relayed from the NRC Region IV office to the f,
NRC inspector for followup: " Fork lift ran into guide rods by missile shield. Rods were approximately s21" diameter stainless steel." Represen-i tatives from the Office of Investigations interviewed the alleger in order to obtain more details regarding this allegation, but were unsuccessful i in this effort. - The NRC inspector was unable. to identify an event that fit all the specifics in the above allegation. As far as the NRC inspector could detemine from discussions with personnel familiar with work in the reactor building, fork lifts have not been used in the reactor building. However, the following event could have been what was observed by the 4 alleger: - , On October 14, 1983, the refueling crane struck and bent a thermocouple I* column. This incident and subsequent corrective action were documented on Westinghouse Field Deficiency Report TBX-10285 and Brown and Root L NCR M-11438. The thermocouple column that was bent is a long (approxi- _, mately 17 feet) tube that provides support for incore thermocouple y tubing between the upper core internals and the reactor vessel head. The lower end of the thermocouple* column is attached to the upper core g assembly. { i , ~. - _. _ . _ _ ~
8 The refueling crane is a bridge type crane that spans the refueling cavity. At the time the incident took place, the upper core assembly was mounted on extension legs and stored in its nonnal storage location in the re-fueling cavity. The extension legs elevated the upper end of the thermo-couple column high enough to place it in the path of the refueling crane. The bent thermocouple was reported, evaluated, and straightened as reported in the two documents identified above. This allegation is closed. No violations or deviations were identified.
- 7. Independent Inspection of coatings Brookhaven National Laboratories (BNL) has been contracted by the NRC to conduct an independent inspection of the CPSES protective coatings l program and its implementation, and to investigate allegations of improprieties in the protective coatings area.
During this inspection period BNL inspectors performed three onsite inspec-tions at CPSES. The scope and findings of this ongoing inspection will be documented in a subsequent NRC report.
- 8. Training of Protective Coatings Inspectors On March 8,1984, the NRC inspector attended a training session given for protective coatings quality control inspectors. The purpose of the training session was to review and discuss recent changes to protective coatings Procedure QI-QP-11.4-26, " Inspection of Steel Substrate, Sur-face Preparation, Primer Application, Primer Repair Seal and Finish -'
Coat Application and Repair". The lesson plan for the training session was followed and the attendees were allowed ample opportunity to discuss the topics covered. No violations or deviations were identified.
- 9. Inventory of Audit Material in Custody of NRC ,
On March 9,1984, the NRC inspector took custody of a box containing file folders from the site quality assurance supervisor. The box of file folders had been collected by licensee personnel during an audit of quality control inspectors conducted on March 8,1984. An NRC repre- _ sentative subsequently made an inventory of the contents of this box.
- 10. Plant Tours -
At various times during the inspection period, the NRC inspector conducted general tours of the reactor building, fuel building, safeguards building, e g wa-. - 6m sm sw g m *e
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J 1 ! j 9 , j electrical and control building, and the turbine building. During the j tours the NRC inspector ooserved housekeeping practices, preventive l maintenance on installed equipment, and ongoing construction work. f No violations or deviations were identified.
- 11. Review of Safety-Related Systems (Unit 1) l a. Platfoms Inside Containment I I
- On December 14, 1983, the NRC inspector observed loose bolted
! connections on platfom OP-11 in the pressurizer compartment. Platform 0P-11 supports safety-related instrument tubing
- for two channels of pressurizer level on the under side of the platfom. A review of the design documentation including
- Gibbs & Hill Drawing 2323-S1-0556, Revision 4 DCA 9764, 4 Revision 3, and DCA 1090 indicated that this platfom was '
1 . originally designed as nonsafety-related. It was upgraded i to Seismic Category II with the particular beams in question '! being Seismic Category I as they were supporting safety-related . i instrument tubing for two channels of pressurizer level. DCA 1090 - i required that the bolts be " hand tight only" to allow for i lateral expansion of the platform, but it did not address any ! locking device or thread upset to prevent nut backoff. DCA 9764
! upgraded the platform to Category I and changeout of material but did not change the connection requirements specified
', in DCA 1090. Subsequent to identification of this problem by the NRC inspector, a DCA was initiated requiring the use of jam nuts or upset threads to correct this problem with the platforms shown on G&H Drawing 2323-51-0556. The NRC inspector advised the licensee that DCA 1090 affected more than one drawing --
.and that engineering would have to look at all similer connections .
( for general application and corrective action. [ i Thisisadeviation(445/8408-03).
- b. Main Coolant Looo Restraints .
I During an inspection inside containment, Unit 1. the crossover ' leg restraints of main coolant loop No. I were examined for con- ' formance to applicable drawings for materials, construction, and
- installation. Materials and welding were found to be as specified on the drawings. .,
- There are two similar restraints on each maid' coolant loop made i of ik inch ASTM A36 carbon steel. The mstraints were manu-
} factured by AFC0 Steel Corporation in accordance with G&H 0550, i 1 1-b- , ,. ' - . . , .. ._ _ - ., _ _.i,Ci C
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- Revision 4. The restraints are massive, approximately 11 feet long, 3 feet wide and 5 feet tall. Each restraint is fastened i to the base mat by 16 prepositioned 2\ inch-diameter anchor i bolts as specified on G&H drawing 2323-51-0551, Detail B.
Drawing SI-0550 required that each anchor bolt be pretensioned to "90 plus or minus 10 kips" and utilize a washer, two regular nuts and a jam nut made of ASTM A 540 material. The bottom nut and the washer required a tack weld as noted in the drawing. The tack welds were not found on any of the anchor bolts inspected. In addition, no record of a QC installation inspection of the restraints for loop No.1 or any other loop of Unit 1 could be found. I Thus, pretensioning of the anchor bolts could not be confirmed. The crossover leg restraints are major canponents of the main coolant piping seismic restraint and support system. Appendix B 1 of 10 CFR 50. Criterion X, requires that inspections of j activities affecting quality shall be established and performed to verify conformance with documented instructions, procedures, and drawings for accomplishing the activity. j TUEC QA Plan, Section 10.0 requires that planned written
- inspection procedures be used. No requirement for inspection of the crossover leg restraints had been issued. This is also contrary to 10 CFR 50, Appendix B, Criterion X.
This is a violation (445/8408-02).
- 12. Unresolved Items ,
Unresolved items are matters about which more information is required in order to determine whether they are acceptable items, violations .. p or deviations. One unresolved item related to polar crane shi.ms .
- (Unresolved Item 8408-04) is discussed in paragraph 3.
'. 13. Exit Interviews . The NRC inspectors met with members of the TUEC staff (denoted in para- .~ graph 1) at various times during the course of the inspection. The scope and findings of the inspection were discussed. " se j - e
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L i i i ". AN INVESTIGATION AND ASSESSMENT OF THE WORK CLIMATE AT THE COMANCHE PEAK STEAM ELECTRIC STATION Bruce L. Kaplan--Team Leader , ,
' Newton Marguiles Ph.D. -
Charles M. Rice G. Carl Andognini William E. Stratton Ph.0.
~~ '
l Publishe August 1984 j EG&G Idaho, Inc. Idaho Falls, Idaho 83415 Responsible NRC Individual anc Division Tom Ippolito . Docket No. ' TAC No. 4 Piepared for th'e ~' U.S. Nuclear Regulatory Commission . Washington, D.C. 20555 Under 00E Contract No. DE-AC07-76IO01570 FIN No. A6429-4 i
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ABSTRACT
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- NRC contracted with EG&G, Idaho, Inc., to investigate the work climate at the Comanche Peak Steam Electric Station (CPSES), and to develop an I
expert opinion as to whether or not a climate of intimidation was created by CPSES Management. To do this task, a study team of individuals with broad experience in the nuclear industry and specific knowledge and skill a in management and organization was formed. An additional independent expert in surveying organization climates and the analysis of survey questionnaires was selected to perform an independent survey analyses. 1 Experts on the study team agreed upon a working definition for a climate.of , intimidation and then proceeded independently to assess report, . 3 depositions, and survey data available in order to reach separate ) conclusions. Findings were that the extent of intimidation alligations i were very limited and that CPSES Management style and approach.fs to be < criticized. The study team and the independent survey rese' arch expert . unanimously concluded that a climate of intimidation did not exist at CPSES. h r r i 9 y el'
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9' l CONTENTS 1 ASSTRACT...................................,........................[. 11 i . t 1. INTRODUCTICN ...................................................,. 1 1 1.1 4 Overall Task ..........................................'..... 1 l 1.2 Team Assembly .............................................. 2 i 1.3 P r o b l e m Fo c u s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 . . i 1.3.1 Specific Problem Focus .......................... 3 ! 1.3.2 Definition of Terms ................................ ... 4 I 1.4 Procedures Followed ........................................ 5 2. DATA SOURCES ..................................................... 6 i i 2.1 Survey Data ...............................................: 6 1-o 2.2 Depositions ...................................... '......... 6 ! 2.3 Reports .................................................... 6
. 3.
i ANA LY S I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I. .8. . . . . . . . 3.1 i Work Climate ............................................... 8 3.1.1 Extent of Allegations of Intimidation . . . . . . . . . . . . . . 3.1.2 8 ., Emotional State of Work Force . . . . 9
- . 3.1.3 . Management Response to Intimidatio n Allegations.................
i 10
- 3 .1,. 4 Protection of A11egers............................. 14 3.2 Whi te Pa pe r Ana ly s i s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 .
3.3 Perceived Intimidation ...............'...................... 20 3.4 Management Style ........................................... 22 4. C ONC LU S I ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24. . . . . . . . . . .. APPENDIX A--RESUMES' .................................................. A-1 APPENDIX B--BOWERS SURVEY REPORT ...................................... B-1 . o 111
I i 4 i AN INVESTIGATION AND ASSESSMENT OF THE WORK CLIMATE AT THE CCMANCHE PEAK STEAM ELECTRIC STATION *
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- 1. INTRODUCTION ~ c, l.$~El *
{f i This section of the report describes the overall task undertaken in
- this study and the team assembled to conduct it. The specific problem i
focus, definition of key terms, and the procedures followed are also presented. 1.1 Overa*11 Task
- The NRC contracted with EG&G Idaho, Inc. to investigate and develop an expert opinion as to whether or not a climate of intimidation was created j
by the management at the Comanche Peak Steam Electric Station (CPSES). ) Allegations have been put forward by a number of individuals involved in the Quality Assurance / Quality Control (QA/QC) area that management created a climate of intimidation during construction of the plant which inhibited Quality Control (QC) inspectors in the performance of their duties according to written standards and regulations, to the extent that the t safety of the plant might be compromised. In the context of issuing an operating license to this plant the . (Nuclear Regul'atory Commission) NRC has taken depositions from those individuals alleging irregularities and from the applicant utility in u anticipation of a formal Atomic Safety Licensing Board (ASLB) hearing. - t These depositions, plus several NRC Office of Investigations reports, a Comanche peak Special Review Team Report, a number of internal reports and reviews conducted by the applicant utility, including a survey of QC -4 inspectors, and other reports and data seen as potentially relevant to making a judgement concerning charges of management intimidation constitute the data reviewed by the Study Team. A comprehensive listing of the data reviewed is presented in Section 2 of this report.
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The Study Team reviewed available material in order to advise the NRC as to whether or not, in their expert and independent opinion there ., ! appeared to be a climate of intimidation created by management among the f ] QA/QC personnel at CPSES. i . ,
- 1.2 Team Assembly l . ,
j The task team leader in charge of overall coordination of the study j was Mr. Bruce Kaplan. Mr. Kaplan has a masters degree in Organization j Development and has been involved with issues of general management, as i well as organizational climate and effectiveness, as an internal consultant . ! for EG&G Idaho for a period of fjve years, i-i j To serve as an interim coordinator during a portion of the review , l
) process, and as a contributor to integrating the separate part;s of the !
] study into a final report, Dr. William E. Stratton was contacted. He is an ! t j Associate Professor of Management at Idaho State University and has worked > I l previously with EG&G Idaho as a consultant. 1 [! l 1 The project coordinators, in consultation with NRC personnel, ; i concluded that individuals selected to review data to determine whether or i i not a climate of intimidation existed at CPSES should possess expertise in organization behavior and the functioning of large and complex ' i organizations and also have expertise in the particular milieu of the j nuclear power industry. ! I , r 1 1 1 The organization scientist chosen for the project was p Or. Newton Marguiles, Dean of the Graduate School of Management at the . ] University of California at Irvine. He is especially well qualified fo'r ! I the' study in terms of his past research and consulting experience. ]
- To obtain management experts with broad experience in the nuclear l industry, LRS Consultants, Inc. (LRS) of Idaho Falls, Idaho was contacted.
} LRS assigned Mr.' Charles Rice and Mr'. Carl Andognini. Each has ad - extensive experience and a long career in the nuclear power industry, and :
' currently works as a consultant in tht.t industry. !
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The Study Team chose to analy:e results from a survey conducted by the applicant uttitty among their QA/QC personnel regarding the climate within which they worked. Therefore, an additional outside expert was sought to render an independent analysis of the survey response. Dr. David Bowers of the Institute for Social Research at the University of Michigan was selected to perform this analysis. He is a nationally recognized expert in both the surveying of crqanizational climates and the analysis of survey questionnaires. Resumes' of all team members are appended to this report. 1.3 Problem Focus i The basic issue with which this study is concerned is whether or not ! management created a climate of intimidation among QA/QC persopnel at CPSES. In order to make such a judgement, a number of terms must be defined and the charge to the study team must be elaborated. l 1.3.1 Specific Problem Focus The basic question the Study Team must attempt to answer is: Old . management by its actions create a climate of intimidttion for the QA/QC 1 personnel such that they performed their duties in a way resulting in some . , I likelihood of adverse impact on the safety and quality of the plant. The i intent is to establish if a pattern of intimidation by management existed. Several clarifications are pertinent here, ,; i l j 1.3.1.1 Climate of Intimidation Versus Individual Intimidation. The intent is to estabitsh if a pattern of intimidation existed. This is ! distinct from whether or not certain individuals were intimidated.The team is concerned with an overall climate of intimidation indicating a systemic problem. 1.3.1.2 Intimidation by Management Versus Other Sources. The- ~ concern is whether or not management actions created the climate of 1
i , 4 I intimidation, if it existed. This is distinct from any intimidation that inspectors may have , felt frca actions on the part of crafts personnel.s j 1.3.1.3 Climate of Intimidation Versus Management Style. A distinction is also made between what is' called a climate of intimidation j ' and what might be described as an autocratic and rigid management style in 1 the plant. Such a style does not necessarily indicate an intimidating cifmate with respect to safety concerns. 2 1.3.1.4 Intimidatino Climate Versus Actual Safety problems. This ' I report deals only with the work climate in the plant which may have some ' potential to adversely affect the safety of the plant. It is beyond the scope of this Study Team's task to attempt to evaluate if safety problems exist, or to make any judgement about the resulting condition of the plant with respect to its safety.
- 1.3.2 Definition of Terms t
I In order to proceed, the team agreed upon definitions of the terms,
" intimidation" and " climate of intimidation." A discussion of these j definitions follows.
4 1.3.2.1 Definition of Intimidation. Intimidation is an incident, action, or sta'tement that causes an employee not to comply with written procedures or act in a manner that good judgement would prescribe. i 1.3.2.2 Definition of Climate of Intimidation. A climate of , intimidation occurs when a preponderance 'of the following exists: o .. Wide spread allegations of intimidation including numbers of cases, areas other than QA/QC, and over an extended period of time. This would include many different individuals alleging intimidation and would involve many different intimidators.
. l
[ Utilities headquarters in Dallas, to investigate allegations of QA management cover-up at the site by QA auditors. This particular. ' investigation led to an accusation of intimidation. Both the cover up and j intimidation investigations were conducted expeditiously and resulted,in a l report dated August 19, 1983 which concluded that there was no evidence to : support allegations of cover up or intimidation. Additional evidence of Texas Utilities' assignment of independent . investigators includes the use of a " hot line" to the corporate security offices and the availability.of an ombudsman, both established between i October and November 1983. As of June 25, 1984, corporate security had!
- I received 17 phone calls related to various allegations. Of these, six l
investigations were in progress, one had been partially completed, and the ! rest had been completed or referred to other officials as not being within i the purview of the hot line program and corporate security.
- T An individual contract employee (not a Texas Utilities employee) was hired *in November 1983 to serve as- an independent ombudsman for employees to uttitze for CPSES investigation concerns. The ombudsman also interviews all terminating employees and has been involved in several management and ;
organizational concerns which involve employees. j 3.1.3.3 Manacement Dedication to Quality. As described earlier, the August 19, 1983 report by Xeeley, Spangler, and Kahler documented an . investigation of intimidation and cover up by QA management. It is important to note that this investigation was initiated by . Mr. B. R. Clements, Vice President Nuclear at TUGCO. A thorough investigation was performed to ensure that QA was performing proper.ly according to the high performance standards expected by the company. fhe significance of this report is not so much the outcome of the _ investigation, but the process. For example, safeguards were taken to ensure the accuracy of information obtained in interviews. The i investigation reviewed several incidenth and noted their conclusions in l this document.
, The process represents a management attempt to thoroughly - '
investigate allegations, protect providers of information, and ensure - l l l l
- j. . . i 1 !
j accuracy and completeness of information obtained. It appears that the . report.is thorough and detailed, indicating the serious attempt on the'part i i ) of the management to deal with the issues at hand, i j i l In a follow-up memo dated September 9, 1983 to 0. N. Chapma~n by 1 Mr. Clements, it is perfectly clear that." intimidation....will not be a tolerated." In this memo, follow up questions and queries were identified - i and Mr. Chapman was charged with providing the additional information. Once again, this is a clear indication on the part of the management of their seriousness to pursue complaints and allegations in as much detail as ' possible, to thoroughly try to understand the basis of those complaints'and
- j to provide an analysis for taking action.
i {. In other documents, including minutes of a September 12, 1983 meetring j 1 between Mr. Clements and QA. personnel, the management position
- identified j above is again reiterated. ,
! 3.1.3.4 Relationship Between Safety and Schedule.
In a December 20, i 1983 memo to all personnel, Michael Spence, President of Texas Utilities l Generating Company, explicitly notes quality and safety as the highest priority of the company. He also states that compromises in safety and l qual'ty will not and could not be tolerated by the colhpany, and indeed he notes the consequences for any employee for not reporting any such t conditions that affect safety and quality at CPSES. i
.\
There is also a very clear corporate policy and attitude with respect , to the relationship between building a top quality safe plant as compared to the monetary impact of delay that was expounded by Mr. L. F. Fikar in ' f his deposition of July 11, 1984. Examples were given of cost'and schedule - tradeoffs that had been made to assure building a safe,-quality plant. It i ! was stated explicitly that the company would not jsopardize its 3.9 billion [ { dollar investment for a delay of a day or two, a week, or even a month or
! two.
1 1
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3.1.3.5 Promot and Appropriate Manacement Action. In cases involving claime<i or demonstrated intimidation of QC inspectors by craft
J
- journeymen, prompt action, including terminations, appears to have been
.taken on several occasions. No evidence was uncovered that would indtcate similar prompt action taken with regard to intimidators that were either '"
craft or QA/QC supervisory personnel. In several cases, it appears that QA/QC supervisors were belatedly counseled and subsequently removed from their positions. Examination, then, of management's response to intimidation allegations indicates that management tended to respond promptly to the specific alligations and provide independent investigators. They
, repeatedly stated their dedication to qualify and followed with prompt *
- corrective action at least in the case of inspectors. The same promptness and follow-through was not seen, however, where alleged intimidators were i craftspeople or QA/QC managers. -
l 3.1.4 Protection of Allegers The final elements in the study teams definition of climate of intimidation deals with the protection of those who made allegations of intimidation: Failure of management to protect the job saturity of individuals who allege intimidation while employed at - CPSES. Insufficient evidence was available on this point to reach a . substantial conclusion. In several depositions and the records of a number - of interviews it was clear that the company has urged individuals to take ' concerns to management or the NRC. A number of individuals, including both deponents and those interviewed in April 1984, expressed the feeling that .- one's job was more secure after becoming an alleger because of " whistle l blowing" regulations. On the other hand there were deponents who believed they had been terminated because they had alleged intimidation, harassment j or other potential quality problems. O $
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- 3.2 White pacer Analysis
-i s j The i~nformation provided for this project included an employee survey I administered to 160 QA/QC inspectors in 1983. The questionnaires returned ' as usable numbered 139; these were grouped into 5 subgroups of QC
- inspectors. The use of survey data is a very common method for f
understanding and identifying employee attitudes and opinions with regard to their job, supervision, work environment, and perceived attitudes and 1 philosophy of management of their organization. l l In this instance, the survey was constructed specifically for use in , , j, the QA/QC organization and was also specifically constructed around items ; focusing on the following categories: I o Supervision: A number of items asked for opinion and i perceptions with regard'to the technical capabilities of immediate supervisors, the perceived confidence in supervisory ] decision making, the amourtt of specific direction provided by supervisors, and the relative effectiveness of supervisory l communication. ] o Attitudes of Too Manacement: A second group of items asked for - opinions about the attitudes and receptiveness of top management - in the QA/QC organization and the receptiveners of those managerial personnel in dealing with problems identified in the ) QC area. ' i, - 4 o Relationship between OC and Craft: - Other 1tems asked for opinions about the relationship of QC inspectors to craft personnel.
! These items focus on the degree of receptivity of "
craft personnel to input, suggestions, and guidelines provided by l QC inspectors. i o Attitudes of Craft Personnel: Questionnaire items asked for . perceived attitudes of QC personnel with regard to the quality of work and the degree of perceived skill of craft personnel. [ ,
A total of 19 closed end questions requiring a checked response were included. There was also one open-ended question (Question 20) requiring a written response
.- on any aspect of the QC job which could be and should be changed in the service of improvement.
The survey is an important source of data; it provided wide coverage in eliciting responses which could be identified as attitudes and opinions of QC personnel on various aspects of their overall job environment. The following paragraphs briefly describe and summarize the analysis of the 1983 questionnaire sur'vey. The analysis proceeded on two levels:. Level 1: The questionnaire permits specific identification of the attitudes and concerns of people in the-QC organization. For example, the questions focus on feelings and perceptions of various work related factors (supervision, e'nvironment, etc.). Level 2: An analysis of item responses was performed specifically to ' ascertain whether or not a climate of intimidation existed at CPSES at the time of the survey. The counting of favorable and unfavorable responses, or counting the number -- of threatening questions unanswered are examples of this -
, analysis.
The focus and ; purpose of this investigation requires the second level '- of analysis to be performed as an independent perspective to the question ' under study. While the substance of peoples' attitudes and concerns may be of interest, it was nevertheless, secondary to our interest. The analysis of responses was designed to meet the specific needs. of this study. -- The detailed analysis of survey item responses, while not conclusive, may in fact allow us to provide some important and concrete inferences about the feelings and attitudes toward the issue of intimidation on the part of QC inspectors; this app. roach allows us to look at the relative a . '
distortion of responses, to examine deviations from " normal," and to provide some indication of the implications of this pattern with regard to the problem focus in this report. In this sense then, the analysis of the survey data examines a_nd bses as criteria for this judgement the following dimensions: o Examination is made to ascertain whether or not there is an overwhelming or unrealistic positive response to items on the survey questionnaire. Another way of viewing this is to see whether or not there is "an abnormal" absence of negative . , responses. o An examination is made to see whether or not there seems to be a distorted positive resconse to more " threatening items" on the questionnaire compared to less threatening items. That is, an examination is performed to determine whether or not respondents overcompensate positively on items they feel will be examined.
" Threatening items" were defined as those questions which, if a critical response was given and the respondent identified, could potentially lead to punitive action taken against the respondent.
o The analysis explores whether or not the responses are highly -
~
nega.tive and reflect a highly negative opinion and perception of the QC organization. o An analysis of written comments from Question 20 (What aspect of ' your job would you like to see changed the most and how?) is performed to see whether or not such written comments indeed reflect an attitude and feeling of intimidation. A detailed report of this analysis is presented in the Appendix B of this report; it was performed by Dr. David Bowers of the University of Michigan, a nationally known expert in Survey Research and Survey . Analysis. The following summary analysis is derived from his report. I
*~ 1
.e. , , - ._.
i l i l l s I 4 Response rates on all items in the questionnaire would be judged as relatively high. That is, on almost all items, the response rate varies from 96 to 99%, indicating that people were clearly not reluctant or reticent to respond to any of the items. Further, one might infer that there is relatively little doubt concerning the protection and _ confidentiality of respondents. 4 Or. Bowers categorized items by degree of perceived " threat"; he is ' able to discern and analyze which items could be differentiated from other items based on relative degre,e of threat perceived by the respondent (see j definition above). He has categorized high-threat intermediate-threat, tand , low-threat items. On all items, regardless of relative degree of perceived . threat, tpe response rate was high (approximately 96%). Therefore, one might infer that people were able and willing to respond to perceived high-threat i items, much as they would to perceived intermediate- and low-threat items. A more detailed description and analysis of these item by item categor.ies j is presented in this report (see Appendix B). The analysis indicated that, in general, across all 5 subgroups, negative (or unfavorable) responses were common in about the same " proporti'on . This means that negative attitudes could not be identified as i predominant in any one sub group, but indeed were scattered among most respondents. Moreover, the unfavorable- profile .is deemed to be " normal ." gr With regard to the open-ended question (the write-in Question 20), responses were categorized by Dr. Bowers in five areas: 1. Complaints about working environment including wages, hours, .. benefits,' working conditions, etc.
- 2. . Complaints about organization bureaucracy including red tape, minor annoyances, interpersonal relations problems, etc. -
- 3. More serious complaints about work ' procedure and safe +.y.
i i d a 4 Suggestions of intimidation.
- 5. No response (respondents left this question blank).
1 i i Dr. Bowers ca.1cludes that in a content analysis of these responses,
- one might ascertain a relatively moderate tone, primarily focused on
" normal" work issues, problems, and complaints. Indeed, only three of 139%
respondents made comments which fall into the intimidation category (Category 4). , The overall conclusion of Dr. Bowers' analysis is that people fe.lt . , free to respond and did express their opinion on issues; additionally they
- were not reluctant to present a negative attitude when such an attitude was felt.
Two important aspects of this survey item analysis suppor this conclusjon. First, the response on items in the "most-threatening" category was not appreciably different from responses on the intermediate-
- and low-threatening categories; that is, that negative responses were broadly scattered across these categories and, moreover, were broadly
- j. scattered across participants in the survey. Second, in the write-in question, there is no documented pattern in responses.to indicate concern ~~
with intimidation. Three quarters (75%) of the participants in the survey ' did respond to.this open-ended question, and yet only three responses suggested anything akin to intimidation or a'n atmosphere of intimidation. d The above conclusion was arrived at independently and without benefit ' of other sources of data. Dr. Bowers interpretation of his analysis is as follows: "The findings ... disconfirm the existence of intimidation as a major factor in the survey results. The overall pattern is one of ^
, favorability, with normal and considered variation by question or issue.
Insofar as the questionnaire survey results reflect real conditions, there
- is little or no evidence of intimidation as anything but a relatively rare, coincicental occurrence." .
3.3 Perceived Intimidation From an organizational behavior point .of view, a climate of intimidation has many intervening elements that influence interpretation. Several questions identified below demonstrate the conplexity. . o What specifically is the unit of behavior that can be characterized as intimidating? What does the initiator say or do? o What triggering behaviors have precipitated that unit of intimidating behavior? That is, what conditions or situations
- initiate such behavior?
o To what extent is intimidation a product of the-receiver's . perception? It is possible that variations in perceptions and individual styles would lead one person to interpret the specific behavior quite differently from another, o What is the outcome of intimidating behavior? If a person feels threatened, but continues to perform his or her function, harassment may exist; however, by definition, intimidation may not have occurred. On the other hand, in the event a climate of " intimidation exists, a full range of responses from' ignoring ' potentially intimidating actions to being intimidated can occur on the part of different employees. During the extensive and in-depth review of information outlined in Section 2, the Study Team noted that several individuals who stated they , were intimidated may have perceived intimidation because of misunderstandings and/or miscommunication. Several situations were identified in which management actions could have been perceived as intimidation. One such situation was that in which individuals were not adequately ' trained to understand or perform assigned position functions. Some
inspectors had only minimal training for the duties and responsibilities
; expected of them. Several Individuals were hired as clerks and apparently became inspectors without any formal training.
l-I 1 l , Management's miscommunication, poor instructions or inadequate feedback constitute a second situation that could have been misconstrued to f be managements attempt to intimidate employees. ( A third situation that could have been read as intimidation occurred , with feelings by inspectors t. hat they should understand and/or concur with the disposition of the condition reported on the nonconformance report : , (NCR). Some inspectors felt their responsibilities included understanding i < and approving NCR dispositioned on items that engineering had approved to 4 use "as-is." They felt intimidated when told by their supervisor that , i engineering had made the decision and that the inspectors do no, t need to know why. Another indication of the extent of perceptions of intimidation is derived from the Quality Assurance Review Board Qustionnaire of 1979. A management decision was made to conduct interviews of the QA/QC department i personnel utilizing a developed questionnaire of forty questions-in an attempt to determine what types of difficulties confronted the individuals " in the d6partment. ' i As part of the Study Team's task, copies of the 1979 interviews were obtained and analyzed utilizing the methodology outlined as follows: ~~ 4: o The questions were reviewed in detail and those pertaining to a climate of intimidation were identified. This amounted to seven of the forty questions. ' 1 o Three classifications were created: intimidating t - potentially intimidating not intimidating-l1 \ - _ - .- = . - - . - -. - --- - -- -. -
1 6 1, o The responses to the seven questions from each of the 121 total interviews were reviewed in detail and categorized in the , classification outlined above. Upon completion of this process it appears that nine individual
- respondents (7P. of the population) indicated some perception of
, intimidation.
Although the task of the Study Team did not include the evaluation of whether or not actual intimidation did occur at CPSES, the Study Team has concluded that many of the alleged cases of intimidation clearly were cases , of perceived intimidation. This problem of perceived intimidation is also related to the management style prevalent at CPSES and will be discussed in detail in section that follows. 3.4 Management Style One factor that must be considered when discussing work climate is management style. Over the past 20 to 25 years, there has been an increasing interest in the subject of Management Style in the literature of organizational behavior. Some organizational research has already shown that in relatively stable, routine, and repetitive onganizational
' function's, a certain degree of " Autocratic /8ureaucratic" behavioral style -
seems appropriate. Moreover, such a management style is often associated with the most efficient and effective organizations. To some receivers, however, this management style may be perceived as intimidating. * ] 1 Research also shows that in a more complicated technical environment, ' (that is, one in which functions are non-repetitive, where various.
- disciplines and technologies are required to interface, and where the "
i ' environment is relatively unstable) a more participative and interpersonally oriented management style seems more effective and I appropriate. (This information was initially developed by Woodward in a - series of studies in the 1960s and 1970s.) _, 3
._r _
l The specific environment at CPSES resulted from a management style that might be described as autocratic. This produced organizational s tension and conflict and was viewed by various employees as aggressive, forceful, confronting, insensitive, and even intimidating. Management response to pro'blem situations is another aspect of managentent style. Where there is a discrepancy bstween the existing management style and the requirements of the technology, task, and mission of the organization, there seems to be one of two general responses in most organizations: ,
- 1. Fix the System: In some instances, the management of an 1
organization may elect to modify and change its own management i style and organiz'ational processes such that their methods , conform more appropriately with the organization's ta,sk and mission.
- 2. Fix the Problem: For the most part, management in large organizations is rigid and static. Thus problems are not addressed as a set of systemic and cultural issues, but are treated in a more narrow perspective, a more-short term 4
~~
orientation in which the approach is to solve the immediate
symptom.
~
i It is not surprising in the case of CPSES that management tends to fix the problem. They consider each complaint, or each set of allegations as a single and self-contained issue to be addressed and resolved. Indeed, they do not appear to see the relationship of recurring patterns of complaints and-the inherent difficulties wh.ich reside in.the management and organizational system in which they function. Criticism.should be directed __ at the rather narrow set of responses provided to resolve inherent 4 conflicts. This management must deal with ths general pcttern rather than I isolated symptoms in order to improve the relationship between superiors and subordinates, and to build a gpod strong working relationship between ~ QA, QC, and the crafts, i
.s ..
l: 6 i ? . 4 CONCLUSIONS 3 s
! The findings of the Study Team disconfirm the existence of a climate of intimidation. Upon completion of the extensive and in-depth review of I the information outlined in Section 2,-the Study Team unanimously cone'luded that a climate of intimidation did not exist at CPSES. Although, isolated cases of intimidation appeared to have occurred at CPSES, the stereotypical autocratic management style discussed in detail in paragraph 3.2.2 did prevail and ray have been perceived as intimidation. This does not, j however, constitute a climate of intimidation.
I 1 i l d a 1 a a i
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] b . I 1 J .. 8 a f
- i i
i I
h l APPENDIX A i RESUMES' . . O O e
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e o O e I 1 9 4F I e9 a, i 9
APPENDIX A RESUMES' William E. Stratton, Ph.D. Dr. Stratton is an Associate Professor of Management in the College of Business at Idaho State University. In this capacity he has studied and lectured about organization behavior and issues of organization development and effectiveness for the past 10 years. " Dr. Stratton received hf's Ph.D. degree in organization behavior from , Case Western Reserv.e University in 1974. His prior education consisted of a BS degree in mechanical engineering and a MS degree in Industrial Administration in 1963 and 1965, respectively, from Carnegie-Mellon University. He is affiliated with a number of professional organizations including membership in the Academy of' Management and the Amerfcan Sociological Association. Since joining the faculty at Idaho State University, Dr. Stratton has been involved in a consultant capacity with numerous organizations including hospitals, food processing companies, public agencies, small businesses, a power company, and the prime, contractor, at the Idaho National -. Engineerdng Laboratory. Issues dealt with in these involvements have - - included management training and development, organization structuring, organizational climate, team building and effectiveness, and productivity - improvement.
-a Dr. Stratton has been active in research in various areas related to the field of management; this'has resulted in frequent presentations at professional conferences, and in numerous publications. +
__ .A-2
G. Carl Andognini Mr. Andognini is a registered pro,fessional engineer with 25 years of experience in the nuclear utility field. His most recent position was Vice President of Arizona Public Service Company with responsibilities for' electric operations. He had responsibility for operations of all of the Company's generating facilities, including the staffing, training, establishment of management control systems, and startup of the Palo Verde Nuclear Generating Station, the transmission system and substations, including load and generation scheduling and control. From 1975 to 1980, Mr. Andognini was Manager of Nuclear Operations for Boston Edison Company, with responsibility for plant operation and licensing, nuclear fuel procurement and management, and technical support for pilgrim Unit I, plus operational design review of Pilgrim # nit II. From 1958 to 1975, Andognini was a member of the Yankee Atomic Electric Company organization, whose duties included positions from Reactor Engineer at Yankee Rowe (Licensed Reactor Operator by the Nuclear Regulatory Commission), startup responsibility at Connecticut Yankee, - startup and operational support for Vermont Yankee and Maine Yankee, to his last position of Assistant to the Vice President. . Andognini.was a member of the utility group that, immediately after the Three Mile Island incident, developed the organizational concepts that became known as the Institute of Nuclear Power Operations (INPO), and ~ served on the first Board of Ofrectors for INPO. He was a member and later Chairman of the American Nuclear Society ANS-3, the subcommittee responsible for the development of ANSI Standards pertaining to staffing, training, organizational support, and security for nuclear power plants. In addition, he served as a member of the American Society of Mechanical Engineers (ASME) Performance Test Development. Group. - A member of the American Society of Mechanical Engineers, American Nuclear Society ano the Edison Electric Institute's Nuclear Power Executive Advisory Committee.
.e
1 ] Charles M. Rice
- Mr. Charles M. Rice, President of LRS Consultants, Inc. , has had .
thirty-three years nuclear experience, initially in technical areas of shielding, criticality, radiation damage, and reactor design. Since I957, he has worked in project engineering, program management, and then general l management where he had the following specific responsibilities: i
- 1. President of LRS Consultants, Inc. since its founding in 1981.
} 1 This company and Mr. Rice provide consulting services to a number j of nuclear utilities, state agencies, industrial firms and . , { federal contractors in areas of reactor safety, quality assurance, radioactive waste management, radiation protection, ) energy alternatives, and both program and general management. i j 2. Principal founder in 1972, President for six years and then Chairman of the Board until early 1981~ of Energy Incorporated, a l consulting firm specializing in safety a'nalysis, quality assurance and nuclear plant startup.
- 3. Served for three and one half years as President and General
] Manager of Idaho Nuclear Corporation and Ael,rojet Nuclear Company [ with responsibility for management of the Nati.onal Reactor -
. Test,ing Station (now the Idaho National Engineering Laboratory),
i the USAEC's principal site for water reactor safety research and
- > test reactor operat.f on. ~
1 + j 4. Program Manager for the AEC/ NASA NERVA nuclear rocket development program. Also served, as Project Manager for the first successful nuclear rocke.t engine NRX/EST and the flight prototype XE-1. "! i j 5. Program Manager for the Army Gas Cooled Reactor System Program i i including design and fabrication of the ML 1, (the first complete system prototype), the Gas Cooled Reactor Experiment, the closed - {! cycle gas turbine power plant and all related research and '
- development.
4
- 6. Reactor Engineering Department Manager responsible for development and installation of several university training , ,
' reactors, consulting contract support to the AEC for central ,
station power plants, maritime applications of nuclear power, metallurgical research and food irradiation applications.
- Patented a Variable Moderator Controlled Boiling Water Reactor.
- 7. Head of the Atomic Power Engineering Group for an architect engineering firm responsible for the design of the first boiling water nuclear power plant.
1
- 8. For four years served as a Physicist with the Oak Ridge Operations Office of the U.S. Atomic Energy Commission.
AB Physics . MS Physics ' Oak Ridge School of Reactor Technology Fellow and Charter Member, American Nuclear Society G
*e e
e f ) A.C
Newton Marquiles. Ph.0 Newton Marguiles, Ph.D. is currently Dean and Professor of Management in the Graduate School of Management, University of California, Irvine. He received a B.S. in engineering from Brooklyn Polytechnic Institute, a'M.S. in
~
Industrial Management from M.I.T., and a Ph.D. in Behavioral Science from U.C. L. A. He has been on the faculty of the Division of Organizational Sciences, Case Institute of Technology, and in the Department of Management, University of Miami. Dr. Marguiles has had an opportunity to consult in the 4 area of organizational development and team building with a variety of - organizations including TRW Systems Group, Department of Water : ,
~ Resources--State of California, Northrop Corp., and the National Emergency Medical System. He'has written and lectured extensively in the field of organizational behavior and is co-author of Organizational Develooment:.
Values, Process, and Technology (1972), Organizational Chance:, Techniques and Aeolications (1973), Conceptual Foundations of Organizational Development (1978), Organizational Development for Health Care i Organizations (1982, and Human System Development (1985). .
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. _ _ _ - _ _ .._ _ _ _ _ . _ _ _ _ _ . _ _ _ m
9 Bruce L. Kaplan s Mr. Kaplan is an Organization Development Specialist for EG&G, Idaho. His work involves consulting, counseling, coaching and training. He deals with issues of management and organization effectiveness in areas whic'h include organization design and transition management, human resources and management development, interpersonal and intergroup conflict, team building, survey feedback, and business research. In his five years with EG&G Idaho, who's mission is providing research and development services for the government, Kaplan4h s consulted to scientific, technical, 3 administrative and service organizations on such issues as problem solvtng , and decision making, team-building, work climate assessment and improvement, productivity and quality of working life. Kaplan holds a Master's Degree in Organization Development from Pepperdine University, where he studied the relationship between organizational climate and task accomplishment. His courses included Consultation skills, Organizational Systems Diagnosis and Action Strategias . in including Management Development and Human Resources Planning. His prior education included graduate studies at Case-Western Reserve University in Organizational Behavior, and a Bachelor of Arts in Chemistry from the University of Cincinnati, His previous work. experience was in " adult and secondary education, where he held teaching, consulting, and - administrative. positions. m
. ~
1 .
. s i
i . Report to d. EG&G Idaho, Inc. 4 d I by David G. Bowers, Ph.D. Research Scientist ' ' i a i l
~
. August 2, 1984
* *
- t'- + W -
t -' t -'-T* m - w * - - ' -% v'! - Yv
I i . ,
- i J
e - INTRODUCTION J l This report contains an analysis of the responses of 139 persons to a questionnaire entitled Fhina Paper Report. The focus of the analysis was whether there is evidence, in.either the substance or the response pattern of responses, of the respondents having been intimidated. At the outset, some remarks about the issue of ni'timidation
; may be appropriate. The term refers to rendering someone i
timid, thereby inducing them to do something or to deter tihem from doing something, because of fear or apprehension. As such', i it has two principal components: (a) the act or words which Ij produce the effect, and (b) the feeling or emotion that is
) induced in the recipient.
3 The survey results analyzed in this report can contain no l 4 direct reading upon possible acts of intimi,dation. They also " can contain no direct reading upon the feeling or emotion of . { the respondents. What they can contain is evidence that the 4 responses were distorted, in ways congruent with intimidation i 'l having been felt. It is this hypothesis that the present
- analysis considered.
j The possible patterns for which the data were. examined were
- the following
- .-
- A pattern of " false positiveness," that is, an over-whelmingly positive response pattern in combination l with one or more of the following: -
.I
; An almost total absence of negative opinion A high non-response rate e w .
_ . , _ . - _ _ , . _ . _ _ _ . . _ _ , _ , . , _ _ . _ . . _ _ _ _ _4. _4 _.. _ _ - . - _ _ _. - - _ _ _ _ . . . . u . . ._, . . _ _ _ .,_._
, ~ . _ , , , _ . . , _ _ . . . . _
REPORT TO EGGG IDAHO, INC. 2. > o
- Skipping of items, especially more threatening 4
items i
- Uniform, intra-respondent positiveness
- A pattern of prevalent negative opinion
- A clustering of negative opinion within a significant minority of persons .
- Written comments suggesting intimidation
- An almost complete absence of written comments, suggesting
} fear of identification by test or handwriting ' [ ANALYSIS AND RESULTS
- .er.
- :11::t::::;'::::::::'t:'::::r:': :::: :l".'::":: .s. t i
) patterns. The following paragraphs describe what was done and the results: i
- The 19 closed-end items were examined for response rate, i
to determine whether non-response ra,tes would suggest " intimidation on certain questions. There was no such . effect. For all items but one, response rates ran between 96 and 99%. On that one item (Q. 5) the response ~ i rate was 89%. (See Table 1)
- Threat was defined as a situation in which, if a critical
- response were given and known, it could conceivably lead to punitive, negative, or disadvantaging action being ,
l taken against the respondent.
- Next, threat was judged in terms of whether, in my opinion, they were high, medium, or low potentially
personally threatening in their content. The categories !. were: i
t REPORT TO EG&G IDAHO, INC. 3. t HIGH THREAT MEDIUM THREAT LOW THREAT
; . Items 2 Items 1 Items.3
{ 4 13 S a . 9 16 -6 10 18 7 11 19 8 , 12 15 , 14 17
- It was noticed that the high threat items were all I i
worded in the negative; that is, a response of "Mostly No" would be considered favorable. The low threat items, j en the other hand, were all worded in the positive;~a response of "Mostly Yes" would be considered favorable. The medium threat items were of mixed wording, two in
- the positive, one in the negative. Any acquiescience i response tendency would therefore tend to bias in favor of the two opposite ends of the threat dimension / that is, a tendency on the one hand to agree with the negatively j
worded high threat items, and with t,he positively worded - $ ' low threat items. The results were: . i \ Percent Favorable (i.e., "Mostly No") to 79.5 l negatively worded high threat items '- i. j Percent Favorable to (mixed) medium 66.7 threat items . Percent Favorable (i.e., "Mostly Yes") to 83.3 positively worded low threat items j In fact, therefore, despite any acquiescence response - set, an overwhelming majority of respondents tended
REPORT TO EG&G IDAHO, INC.
- 4. ,
to disagree with the negatively worded high threat ' items. Any acquiescence response set that is pre'sent probably causes the observed percentage to understate l the true percentage disagreeing with these items.
- An informal check indicated no systematic referent differences among items in the high, medium, and low
- threat categories. Items in all three categories referred to managenent, supervision, craft, policies, and the like.
- There was also no concentration o non-responses in any of the three threat categories:
CATEGORY MEANRESPONSEPbRCENT High threat 97.4 Medium threat 97.0 Low threat 96.3
- Using a binomial, with a 54 confidence interval, the ..
. estimated true favorability percentages for the three threat categories would her High threat 70 - 88% ..
Medium threat 57 - 774 - Low threat 73 - 89%
- The overall favorable response percentage was 77. 5. The --
five subgroupings had favorability percentages as follows: Foote 75.8% JB 77.1% Lawrence . 88.3% Randall 76.4% - Williams 57.34-
i
- ?
REPORT TO EG&G IDAHO, INC. 5. I - :
- Since the confidence band for the overall favorabl'e response percentage would be approximately 68 - E8%, i all groups except Williams fall within that band. .
i
- Looking at the williams group separately, the following ,
was found: CATEGORY " PERCENT FAVORABLE RESPONSE
; High threat 60.5 !
2 Medium threat ' 50.0 ' Low threat 65.8
)
i j Because this was the smallest group (N = 12), the dif- , { forence between these percentages and those for the { I. overall percentages amounts to at most two persons. i' i i
- Although there was not time to do a complete item analysis, l a casual check in two of the largest groups was undertaken j to see whether unfavorable response tended to be consistent j for particular respondents. The results suggested that ,
this tended not to be true ' Q. 4 "Yes" = 11 Q 2 "Yes" 1 Q . 4 "No" = 9 4 (N = 21) N Q. 4 " Don't Know"-= 1 i - l Q. 11 "Yes" = 8 Q. 2 "Yes,, ' l N . 11 Q"No" = 13 .. t l In other words, unfavorable responses seem to have been ! f
- scattered generally among most respondents, not con-
} centrated among a few. - i t
1 s REPORT TO EGsG IDEAHO, INC. 6.
- The responses to Q. 20, the open-ended or write-in j ' question, were content-analyzed into five possible categories. Where more than one category was m'entioned,
; the category discussed most was coded. Where equal space was given to more than one category, the first mentioned was coded. However, any mention in categories 4 or 5 was coded there. ;
- PERCENT
. NO. MENTION j
- 1. Complaints about wages, hours, .
benefits, working conditions, . j advancement opportunities 36 25.9 {
- 2. Complaints about bureaucracy, red l tape, minor annoyances, interpersonal ,
j relations problems
, 58 ' 41.7 ;
]' 3. More serious complaints about '
- procedures, safety, etc. 2 1.4 e
i
- 4. Suggestions of intimidation 3 2.2
- 5. None, or blank
- 40 28.8 i
i It is apparent that much of the written material in ! 1 response to Q. 20 was relatively moderate in tene and .. j was concerned for the most part with what might be termed. -
" normal" work situation complainte., only two respondents made comments related to category 4 (More serious complaints). q j They were: '
"There has been a dramatic increase in ' hurry up'
; inspection. Most inspectors feel they have to rush 4
i through an inspection in order to satisfy somebody ,
~
or committee for schedule reasons. The end result is mistakes and oversights. I think this is a very ) [ 1 serious problem." - i 1 - 4 j i 1 - 2 {
- Typogr'aphical errors should read " category 3".
1
t 7 1 i I ' l t -
- l 1 REPORT TO EG&G IDAHO, INC. 7.
I l ' i "This plant is definitely production run. i hithout j the quality aspect this place won't get an operator's i license. The QC's need to do their jobs and to'do ( i this they need the supervisor capable of letting. ! ! them do the job right." i j l q
- Three persons made comunents coded in category 5 (Sugges-l 1
y tions of intimidation): ' ' i. { l . L j . . . On a personal level, I would like to see a.less , - j antagonistic, threatening, and insecure attitude from i managements i.e., I'm tired of being told to ' hit the {
. j j gate' if I don't like it here. That type of comment is i I ;
- usually a response to some inquiry as to prospects of j a weekend off or getting paid on time."
i ! . . . Many of us have worked at several additional ! nuclear plants, and we are appalled with the shoddy i program here which largely consists of cover ups,. ! i i smokescreens, intimidation, and harassment." I i ,,
* .c l . . . How can there he any Quality control when there ' '
is pressure from management to get gurnovers completed. . { Would the NRC approve?!?" ,,, ,i . j CONCIUSIONS ' 1 t
- Although the pattern is positive or favorable overall, ... ,
j it is not overwhelmingly so. Apprcximately one respondent, . 1' then, in four was negative. i { < ' There was not, therefore, an absence of negative t
- opinion.
Typographical errors should read " category 4". 1
1 . 1 j . .. . '
. c l i REPORT TO EG&G IDAHO, INC. 8. {
I
- The response rate was extremely high. s
+
!
- The most positive response was to the least, not i i the most, threatening items; the most threatening items were intermediate in positive response. l
- There was no prevalent pattern of skipping items, .
l j even more threatening ones. 1 l - t j r
- Negative responses seemed to be rather broadly *
- scattered across respondents.
5 i
- There was not a prevalent pattern of negative opinion. ,
! I i j
- There was no discernible clustering of negative opinion !
l l within a significant minority of persons. l }
- Only three responses to the open-end question (Q. 20) ;
suggested intimidation of any form.
- Almost three-fourths of the respondents responded in some . -l way to Q. 20. -
l The findings to the pattern points listed at the outset, there- '! j fore, disconfirm the existence of intimidation as a major factor' i , in the survey results. The overall pattern is one of favorability, I with normal and considered variation by question or' issue. Inso-far as the questionnaire survey results reflect real conditions, - "; [ there is little or no evidence of intimidation as anyt,hing but i i a relatively rare, coincidental occurrence. , e i . l
t REPORT TO EG&G IDAHO, INC. l , , i Tabt.e 1 i RESPONSE RATES TO CLOSED-END ITEM ! Question No. Responding f Percent (of 139) 1 135 97 $ 2 138 , 99 -i 3 137
- , 98 -
! 4 134 *
- 96 5 124 i
89 6 137 ' 98 7 135 .t 97 .
- ' 8 134
- 96 9 136 98 t
10 135 97 r 11 137 98 12 134 J 96 13 136
. 98 i 14 136 98 15 - 137 ..
98 . . .
- . 16 136 98 l
17 137 ! 98 18 133
- 96 ,
19 134 96 . I t t O6 i t e l ________._____._________________________._______o___________..__.____.___.__________._______.__________________:___
, p - y s - g-/ .3' In Reply Refer To:
pl.$ Docket: 50-445/84-05 ] Texas Utilities Electric Company ; ATTN: M. D. Spence, President, TUGC0 j Skyway Tower i 400 North Olive Street ;
- Lock Box 81 l
Dallas, Texas 75201 Gentlemen: ' l I This refers to the special inspection conducted by Messrs. L. E. Martin and I
. C. R. Oberg of this office during the period January 6-March 13,1984, of
! activities authorized by NRC Construction Permit CPPR-126 for the Comanche Peak l Facility, Unit I and to the discussion of our findings with members of your .' staff at the conclusion of the inspection. l The area examined during the inspection involved allegations of poor work ! practices pertaining to five safety related supports of the main steam system. ] Within this area, the inspection consisted of selective examination of
, procedures and representative records, interviews with personnel, and l cbservations by the inspectors. The findings are documented in the enclosed i
inspection report. l l l Within the scope of the inspection, no violations or deviations were ! identified. 1 In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure l will be placed in the NRC Public Document Room unless you notify this office, i by telephone, within 10 days of the date of'this letter, and submit written - i application to withhold information contained therein within 30 days of the - ! date of this letter. Such application must be consistent with the requirements ! I 1 of 2.790(b)(1). RIV-TF RIV-T j RIV-T F'N EO D RIV- F NRR-TF . CRCberg:)J LEMartin CMuannicutt TPa'e st a rman WCSeidle Ippolito j 4//i/84 4//T /84 4//f/54 '4/;,/84 ff / /84 g/g/84 l -TF ORSP h l JEc fardo RPn nise - RL:.,ap, Ra art de /,p. j J 6/jj/84 > _ i l i b G)
O Texas Utilities Electric Co pany . Sh0uld you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, c-:::r ::. - 7:1elva . .. ..:: u t . R. L. Bangart, Director RIV Task Force i
Enclosure:
Appendix - NRC Inspection Report 50-445/24-05 cc w/ enclosure: Texas Utilities Electric Cc pany Texas Utilities Electric Ccepany ATTN: B. R. Clements, Vice ATTN: H. C. Schmidt, Manager President, Nuclear . Nuclear Services Skyway Tcaer Skyway Tower 400 North Olive Street 400 North Olive Street Lock Sox 81 Lock Box 81 Callas, Texas 75201 Dallas, Texas 75201 bcc to Ov3 (IE01) bec distrib. by RIV: RPS1 Resident Inspector-Ops J. Collins, RA RPB2 Resident Inspector-Cons. C. Wisner, PA0 TPS 0. Hunnicutt, Task Force S. Treby, ELD ~ ' ' RIV File MIS System R. Denise, DRS&P -
, TEXAS STATE CEPT. OF HEALTH R. L. Eangart, Task Fcrce Juanita Ellis Renea Hicks L. 5'artin, RPSA Billie Pirner Garde C. Charg, RPSA 7 b).yi.4A'N l 4
0 0
2 APPENDIX 2 , U. S. NUCLEAR REGULATORY CCMMISSION [ REGION IV L NRC Inspection Report: 50-445/84-05 ' Docket: 50-445 Construction Permit: CppR-126 4 Licensee: Texas Utilities Electric Company (TUEC) Skyway Tower 400 North Olive Street 4 Lock Box-81 Dallas, Texas 75201 Facility Name: Ccmanche Peak Steam Electric, Station (CpSES), Unit 1 Inspection At: CpSES, Glen Rose, Te'xas' Inspection Conducted: January 6-March 13, 1984 Inspectors: * / 2 L. E. Partir, Reactor Inspector i
//#df/
Region IV Task Force OttV p i *
- 6. 4. &+ v/nky C.R.Oberg,ReacGrInspector . Date Region IV Task Forte Apprcved: w-M' f8N
- 0. Hunnicutt, Team Leader- '
0'a te / Region IV Task Force Ins ection Su : ary - 1 Ins;:ection Cenducted January 6-March 13,1954 (Report 50-445/84-05) Areas Inscected: Special, unancounced inspection of allegations of peor wcrk practices pertaining to safety-related supports. The allegations ccvered five separate items identified by the alleger to NRC personnel. All identified items pertained to the rain steam pipe supports. This inspection involved 290 inspector-hours onsite by two NRC inspectors.
- _Results
- Within the areas inspected . no violations or deviations were
_ identified. The specific concerns.could not'be substantiated. ' a t vi n ' ~ m o
'O Ep l yJWs' 19g?.
DETAILS
- 1. Persons Contacted Principal Licensee Employees
*J. T. Merritt, Assistant General Project Manager R. G. Tolson, Site Quality Assurance Supervisor B. G. Scott, Quality Engineering Supervisor
*J. D. Hicks, Assistant Site QA Supervisor Brown & Root, Inc. (B&R)
- 5. Rynders, Superintendent R. Heabert, Superintendent R. Johnson, Superintendent, Unit 1 .
B. Baker, Senior Project Welding Engineer Other Personnel A11eger In addition, the NRC inspectors interviewed othe- B&R labor force and QC inspection personnel concerned with the allegation.
- Attended exit meeting on March 13, 1984.
- 2. Allegations Relating to Poor Work Practices On November 22, 1983, an alleger made a sworn statement to the NRC ,
regarding poor work practices at Comanche Peak. Subsequently on January 6 during a site visit and a followup discussion cc. January 26, 1984, the alleger identified concerns on five specific sucports/ restraints. The allegations were as follows:
- a. Pioe Support MS-1-004-007-C72K ,
An excessive gap of 1" or more was noted caring the fit-up of the bottom kicker and outrigger. This gap was welded in violation of
- fit-up limitations.
! b. Pipe Whip Restraint and Pipe Support Structure M-17 The web of the structural support member (M-17) was cut out in the wrong location. Instead of reporting the problem and repairing according to procedure, it was filled in by unauthorized welding.
3 i
- c. Pipe Support MS-1-003-009-C72K The stanchions of this item were welded on the inside with "heliart and backwelded because of excessive gap. The upper stanchion had tou 4
much cutoff at " lower point." This was filled in by welding, grinding, and polishing.
- d. Pipe Suppcrt MS-1-003-010-C72K The bottom saddle was cut in four pieces. The left hand back piece did not fit due to curvature of the pipe. The piece was heated to a
" cherry red" with rosebuds. A 20 ton hydraulic jack, a "come-along,"
and hammering were used to bend the metal into place. This was alleged to have been done under direct orders of a superintendent, a general foreman, and the supervising foreman.
- e. Pipe Support MS-1-002-005-C72K There was an excessive gap in the steel of the support box. The gap was between shim plates but the shim plates were enclosed without the prpblem being reported or corrected.
- 3. Inspection Results
, a. Pipe Support MS-1-004-007-C72K (1) General The support members of MS-1-004-007-C72K were fabricated by NPS Industries and assembled onsite by B&R. This support is located on the Loop 1 main steam line inside Unit I containment. It 4s a large ASME Class.2 hanger (overall dimension approximately .
26'x 5'x 10') utilizing two SMA-35-SC snubbers. The main structural member is supported from the wall by two " kickers" and " outriggers." The kickers ar.s attached to the main members at approximately a 45 degree angle. The structural members are made of 1" CS plate. The two kickers are made of four plates . approximately 14" wide and 11' long and four plates 13" wide And 11' long. They were field trimmed to suit needs. l MS-1-004-007-C72K was constructed in accordance with Gibbs & Hill (G&H) Specification 2323-MS-46A. ASME Section III. - Livision I Subsection NF - Component Supports (Winter,1974 -- Addenda) is the applicable code. h A.
4 e (2) Description of Allegation _- The initial signed statement made by the alleger did not identify a specific problem with MS-1-004-007-C72K. However, during the site visit on January 6, 1984, the support was identified by the alleger as having an excessive gap (1" or more) between the main structural member and the kicker at fit-up. The kicker meets the main member at approximately a 45 degree angle. The excessive gap was welded closed. After inspection of the kicker attachment weld (described below), the alleger was informed.of the results. The alleger then indicated that the. fit-up was correct on one side of the attachment only, and that the weld prep tapered out to an excessive gap of greater than one inch on.the opposite side. See Figure 1. (3) Review of Documentation The documentation package for MS-1-004-007-C72K was reviewed and used as a basis for the inspection by the NRC inspectors. The following specific items were reviewed: QC Component Checklist Att. 5 Multiple Weld Data Card (MWDC) 57089 Weld Filler Material Log (WFML) , Material Identification Log (MIL) Hanger Inspect, ion Report, dated September 22, 1982 QC Checklist For Snubbers Snubber Modification Cards Inspection Report ANO 3525 .. MT/PT 17187 MT ' Repair Process Sheet (RPS) R-2194 Receiving Inspection Report (RIR) 18221 Material Receiving Report (MRR) CP10295 (4) Observation . At the request of the NRC inspectors, the licensee had B&R grind and etch two areas on the support. Figure 2 shows the areas examined and the observation noted. In addition to the two etched areas examined, the NRC inspectors found that the weld joining the lower kicker to the main support member was - consistent in appearance (approximately 1" wide) for the full length of both the upper and lower welds. On the inside angle of the kicker (45 degrees), a small edge of the weld prep (See Figure 3) was noted approximately 1-1/8" from the edge of l l
S plate A. The bottom weld was similar in appearance. The support had been painted; however, the size of the weld was noted to be consistent with the requirements of the B&R drawings and consistent with the experience of the NRC inspectors for similar type welds. Additional destructive testing was not done based on the evidence noted. The NRC inspectors also noted that to weld in the 45 degree angle and fill in a 1" gap would be extremely difficult. The alleged geometry of the gap and the positions from which a welder would have to work (overhead or on back) would suggest that the effort involved could not be done. unnoticed by other personnel working in the area. 9 e T-
-n -
Figure 1 PLAN VIEW OF LOWER KICKER JOINING MAIN STRUCTURAL MEMBER g ain M Structural Member
. 4 1
,,, Approx.45 degrees l
Fit-up correct Kicker Gap in excess of 1" l .. Y o, p e
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6 (5) Conclusions The NRC inspectors could not identify any evidence that would support the allegation regarding an excessive gap and unauthorized welding. There is evidence to support that the weld fit-up was done correctly. Observation of the etched areas and inspection of the remainder of the suspect weld confirmed that :he requirements of the drawings were met. The requirement for weld preparation for the plates in question show that a 45 degree prep on a 1" plate for the full penetration weld with 1/8" clearance will give a 1" gap at the top of the area to be welded. See Figure 3. This is normal and according to procedures. ASME Section III, Division 2, Paragraph NF5222 requires that all welds of Class 2, linear type supports be visually examined to the acceptance standards of NF-5360. No QC fit-up inspection is required. The QC inspection of welding on this support was completed on September 22, 1982, and found to be satisfactory. This was documented on the MWDC, No. 57089. The QC component support checklist also stated that all accessible welds were
" reinspected and are in compliance with VCD" (Vendor Certified Drawings), dated November 9, 1983.
The allegation could not be confirmed based on the inspection record, discussion with other personnel working in the area, and direct observation of weld area which included grinding and etching of two areas on the weld.
- b. Pipe Whip Restraint and Pipe Support Structure M-17 l
(1) General . Support Structure M-17 is a massive I-Beam made of 1-1/2" CS plates, 4' 3-1/2" tall, 2'4" wide and approximately 14' long. It is located inside containment, Unit 1, at elevation 905' level, azimuth approximately 345*. It supports two whip - restraints, MS-1-001-903-C77W and MS-1-001-902-C77W, as well as pipe support hanger MS-1-001-007-C72K. (2) A11ecation Description On January 6, 1984, during the site visit, the alleger identified a pipe whip restraint (MS-1-001-903-C77W) which he stated had i been gouged and repaired without a procedure. Subsequently, on January 26, 1984, the problem was determined not to be with the restraint, but with the structural member, M-17. The web of the beam member was alleged to have been cut in the wrong location. The opening was filled in by welding without approval , or authorization. No repair record or NCR was generated.
l Figure 3 0" To 1/8" 44 45' Lower plate has similar weld prep for full penetration weld 1 c , . -
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i ll / , S' 4[/ ,7. -'/ r./ i .' ' ',. - (4',,t,
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7 (3) Review of Documents and Procedures The following documents were reviewed as they were applicable to structural member M-17: Design Change Authorization (DCA) 14,115 Rev. 1-4 CPSES Inspection Report MI-1063 Construction Traveler MW83-6684-3400 Construction Traveler CD80-027-3401 Orawing 2223-S1-0583 Drawing 2323-51-0581 MP/PT Report T 1169 MP/PT Report 6242 Repair Process Sheet (RPS) WDC 707479 TUSI Ltr CPPA-31749 of July 8, 1983 G&H ltr GTN-66866 of July 21, 1983 DCA 14,115 authorized a cut in the web of the structural member and the insertion of a 12" diameter pipe. This opening was to allow the attachment of NPSI MS-1-001-006-C72K to the support structure. The snubber goes through the pipe to the 32" main steam line. (4) Observations The NRC inspector examined M-17 in the specific area of the allegation. The sleeve in the beam web was found to be a slotted hole approximately 18"x 12"x 4". The sleeve was welded in place with a 1/2" fillet weld. Punch marks were noted on the south side to the left of the existing hole in the beam, however, no cut had been made in the metal. There was no visual evidence of welding that would indicate filling in of an unapproved cut . or damage to the base metal. Review of the documentation indicated that DCA 14,115 Rev. 1, had been accomplished and inspected by August 24, 1982. Revision 3 to this DCA removed the assigned 12" round pipe and slotted the structural member to install an elongated pipe 18'jx l 12"x 4". Revision 3 was authorized on September 22, 1983. This I change was required due to the sleeve interfering with the snubber. This was noted during hot functional testing (HFT). (5) Conclusions - The original modification to the beam was accomplished in August of 1982. HFT identified interference with the snubber. This prompted another change, which was done in October of 1983, thereby elongating the hole approximately 6". This modification was adequately documented in the support package. - i
8 No physical evidence was found that would indicate a wrong cut and subsequent unauthorized welding to repair the base metal. The area in question was smooth and clear of weld material. It is conceivable that Revision 3 could have removed any evidance of the alleged cut and rewelding. However, based upon the information stated above, the allegation was not substantiated. 4
- c. Pipe Support MS-1-003-009-C72K (1) General
, MS-1-003-009-C72K is a large horizontal support utilizing two SMF-100-50 snubbers. It is attached to an interior wall inside Unit 1 containment at elevation 893' 10". The support extends out from the wall approximately 7' and is 6'4" tall and 5' wide. The snubbers are attached to a strong back which is fastened to the main steam pipe by an upper and a lower stanchion. The stanchions are made of 20" diameter SCH-80 CS pipe. They are welded to the 32" main steam pipe, of f center, giving one side of the stanchions a longer " lip" than the other.
(2) Allegation Description During the site tour on January 6,1984, the alleger stated that the bottom stanchion of MS-1-003-009-C72K had been buttered with a 1" weld after excess metal had been cut off. No NCR or repair procedure was initiated. The unauthorized work was done at the order of the foreman. Subsequently on January 26, 1984, the stanchion problem was characterized as pertaining to the top stanchion only. The upper stanchion was backwelded on the , inside to seal up excessive gap in the fit-up. The stanchion _ was alleged to have been punchmarked by the alleger, and sent to the fab shop for cutting. Too much was cut off the lower
" point". (By design, the stanchions are offset from the centerline of the 32" main steam pipe).
The supervising foreman was alleged to have filled in the ,
" point" by welding and then grinding down the weld beads to give the appearance of the original pipe stanchions metal. The l
stanchions were back welded because of the excessive gap in fit-up, i l l t I
~
l
. . - - - +
9 (3) Review of Documentation and Procedures The following documents were reviewed: MS-1-003-009-C72K Hanger Package QC Component Support Checklist Att. 5 VCD MIL MWDC 58332 Manager I.R. dated March 22, 1982 QC Checklist for Snubber Installation dated February 28, 1983, and March 17, 1983 Snubber Modification Card 77357 Snubber Modification Card 77356 MWDC 80155 Hanger I.R. dated February 17, 1983, per IRN HOU 6696 MWDC 86576 per CMC 93665, R0 Hanger I.R. dated August 31, 1983 I.R. AM03582 dated December 2, 1983, VCD MWDC R-1968 for VCD Hanger I.R. dated December 29, 1983 MWDC R-2104 VCD CMC 67872 CMC 88117 CMC 93665 IRN H006696 MS-1-RB-03-004-Pipe Spool Package MWDC 58333 ~~ Weld Filler Metal Log 58333 MT/PT Report for FW1 int./ ext. MT - MT/PT Report for FW2 " MT VT for FW1 WDC 58333 VT for FW2 WDC 58333 B&R Welding Procedure Specification 11010 Revision 4,
- September 12, 1979.
MWDC 58333 clearly indicates that E705-2 filler metal was to be used for the first two layers (root and hot pass). E7018 weld rod was ta be used for remaining fill - dated January 21, 1982. The initial root had to be background and backwelded. Both the ~ inside and outside welds were acceptable to QC per QI-QAP 10.2-1, Revision 1. l l
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e - _ . . ._.-- _,_ y # - . - .. -.. - N 10 i (4) Observations Visual inspection of the outside of the stanchions and their
- attachment to the main steam pipe did not reveal any abnormal conditions. At the request of the NRC inspectors, a hole was drilled in the cover plates of the upper and lower stanchions.
A borescope was then used to examine the welds from the inside of the stantions. A narrow bead of "heliarc" weld metal, E-705-2, was observed, (on the WDC 58333 - Weld 1 & 2). No excessive weld metal i denoting out of tolerances gaps was noted. These stanchions l had been visually inspected by QC at fit-up (February 22, 1982) and completion of the weld (February 24, 1982). No defects were
! noted. (Visual Examination Checklist WDC 58333).
The QC inspectors and welders (as available) who were involved with inspection of the fit-up and welding on the stanchions were questioned. The information contained in the support package ' pertaining to welding and fit-up was confirmed. Both the night shift and day shift worked on the stanchions. Backwelding was i accomplished and checked to be satisfactory on WDC 58333 ! (February 26, 1982) by QC. (5) Conclusions There were three parts to this allegation: excessive gap existed at fit-up. backwelding was done due to excessive gap.
- the upper stanchion was cut wrong and was repaired by --
buttering by an unqualified welder. . An excessive gap in the fit-up of a full penetration weld would be greater than 1/8".
~
The fit-up was inspected by QC personnel and. documented as " satisfactory". Nothing out of the ordinary was noted by the QC inspector. . Backwelding inside the stanchion was documented on the WDC and found to satisfactory per QF-QAP 10.2-1 (NDE-Liquid Penetrant Examinatlon). Backwelding was accomplished in accordance with-an approved welding procedure. _. No evidence was found to indicate that the upper stanchion was cut incorrectly. None of the QC personnel or welders interviewed noted anything wrong with the fit-up or any other condition that would indicate incorrect cutting on the stanchion. It was determined through interviews that when a stanchion did not fit, l grinding was done as necessary to achieve the correct fit-up. .
~
h . l pppq - - - * - .p--em9%, q -y gypor
- 11 The geometry of the stanchion (in the area of the lower tip) required the final weld to be wider in that area when compared to the remainder of the weld.
The conclusion, based on the evidence collected through direct inspection, review of applicable documents and interviews with labor and management personnel, was that the allegation could not be substantiated.
- d. Pipe Support MS-1-003-010-C72K (1) General This support is a large ASME Code Class 2 pipe support located on the 893' 10" elevation of Unit 1, Containment Building. It extends approximately 4' out from the wall. The two support members parallel the 32" main steam line, one on top and one below. There is an upper and lower stanchion welded to the pipe, made of 20" schedule 60 pipe. The stanchions are, in turn, reinforced by 1-1/2" x 29" x 31" CS " saddle" plates also welded to the pipe. Two SMF-100-BA snubbers connect the main structure to the stanchions. See Figure 4.
(2) A11ecation Description The alleger identified MS-1-003-010-C72K during the January 6, 1984, site tour. The specific problem identified i was that the lower saddle had been heated to a " cherry red" condition and bent into shape around the main steam line using,, a come-a-long and a porta power hydraulic jack. During the January 26, 1984, discussion, th alleger stated that the lower saddle (on MS-1-003-010-C72K) had been cut into four - pieces, and that the left hand, back quadrant piece had been heated and bent into position with a porta power unit, a 1 ton chain "come-a-long," and hammering. The heating and bending operation was not an approved method or procedure. I n' addition, the alleger stated that he, in company with a welder, went to B&R management with this allegation. To the best of the alleger's knowledge, nothing was done by B&k to resolve the - probl em. l
Figure 4 DETAILS OF MS-1-003-010-C72K m ) STANCHION - 20" PIPE Detail 1 eld No. 5 SADDLES 1 x 29 x 31 CS PLATE s -..... ' y Weld N 2 We d No. 1 32" MAIN STEAM LINE --+ pidNo.4 1 1 ( , 3.---- .. , Weld No. 3 # Weld No. 6
~ -
"y' NOT TO SCALE
( _ -g e Detail 1 PARTIAL PENETRATION FIELD g Weld No. 5 7 MJ W STANCHION WALL SADDLE % 2 FIFt WALL $ $ FULL PENETPATION WELD (Weld No. 1) m Q
12 (3) Review of Documents and Procedures The following documents were reviewed: MS-1-003-009-C72K QC Component Support Checklist Att. 5 dated February 2,1984 MIL (Material Identification Log) MWDC #58332 $ WFML Hanger I. R. dated March 22, 1982 QC Checklist for Snubber Installation dated February 28, 1983, and March 17, 1983 Snubber Modification Cards 77357 & 77356 MWDC 80155 & WFML Hanger I.R. dated February 17, 1983 MWDC R-435 Hanger I.R. dated August 31, 1983 MWDC 86576 & WFML I.R. AM03582 dated December 2, 1983 MWDC R-1968 Hanger I.R. dated December 29, 1983 MWDC R-2104 Hanger I.R. dated February 2,1984 IRN M-1407 Traveler CS-2-483-902-A47W CMC 93665 QCA 17,934 CMC 67872 R7 Drawings 2323-51-0576 CMC 88117 R1 2323-51-0581 IRN H6696 Also looked at Spool MS-1-RB-03-04 for attachment of stanchion. MWDC 58333 & 58333 MT/PT for FW1 (Upper Stanchion) inside & out
- MT/PT for FW2 (Lower Stanchion) inside & out FW1 Backweld inside VT Checklists -
MS-1-003-010-C72K QC Component Support Checklist Att. 5 MIL MWDC 45201 - Weld Filler Metal Log 45201 MWDC 45197 & WFML MWDC 45120 & WFML MWDC 64147 & WFML 9 1
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1 . 13 Manger IR dated May 24, 1982 Snubber Checklist I.R. AM03597 dated December 10, 1983 MWDC R-2000 per NCR 12,500 R-3 & IRAM 3597 Hanger I.R. dated February 8, 1984 MWDC R-2019 MT/PT Report 17145 MWDC 45202 WFML CMC 53580 R11 MWDC R-2001 MS-1-002-005-C72K - Package was reviewed for drawings only. (4) Observation and findinas ' The NRC inspector examined the documentation packages and inspected the support. The following was determined: MS-1-003-010-C72K stanchions were welded in place from i-July 13, 1981, to July 23, 1981 (WDC 45201) The upper saddle was cut in two pieces and repaired in accordance with CMC 53580. The item was cut incorrectly in fab shop. The lower saddle is one piece, with no visual indications
, that the saddle was split. It is smooth, without marks 4
indicating that a chain or hydraulic jack was used to bend the saddle. The saddles were welded in place between August 11, 1981 - to August 19, 1981 (WDC 45197). QC inspections of fit-up and welding indicate welds are
" satisfactory."
l t The NRC inspector discussed this allegation with B&R personnel - in order to clarify the issues. It was determined that a lower and upper pipe saddle had been cut in four pieces, but on a support identiff,ed as MS-1-003-007-C72K. This support is attached to the main steam piping by stanchions and 2" thick saddles similar to MS-1-003-010-C72K. However, the saddles, or l reinforcing pads, were cut into four pieces as authorized by CMC 65236. This support was examined by the NRC inspector. The saddles had been modified, as indicated in the CMC; however, l there was no evidence that would indicate heating and bending l of the left rear quarter of the lower pad. There was also no visible evidence of bending of the pipe in the area of the saddles. _
14 Identif ' ation c of the problem to upper . management in B&R appears to have be done as indicated by the alleger. Thjs was confirmed by one B&R Superintendent. However, any further action taken on this matter by B&R management could not be identified. The supervisors involved do not remember any action, and the problem was not documented. It can only be assumed that none was taken. (5) Conclusions Based on the information obtained from B&R personnel, review of the support packages and direct observation of the supports, the allegation could not be substantiated. The original support identified did not have a saddle cut in four pieces. The support that did have a four piece saddle also had clear and direct authorization to make such a change. Lack of response by B&R management to this concern identified by the alleger, indicated a lack of an effective system for followup on concerns noted by a laborer and there was a weakness in their management system. More recently, however, a system is inplace to provide for identification and followup of this type of concern. No technical issue appears to exist.
- e. Pipe Support. MS-1-002-005-C72K (1) General During the site visit, the alleger indicated to the NRC inspector that MS-1-003-903-C77W had been constructed with excessive gaps between shins. They were subsequently covered by plates,so that the excessive gaps could not be seen. ~
Upon close inspection of MS-1-003-903-C77W and review of the restraint package, it was determined that the gaps between shims installed as part of the restraint support structure had been identified by QC on an NCR. Engineering had determined the as-built condition to be acceptable. This was told to the alleger on January 26, 1984. He then stated that , MS-1-002-005-C72K was the support (identified from a drawing) in which there was a hidden gap in the steel that made up the support box. Review of the drawings for MS-1-002-005-C72K was done. No support box was found containing shfes. Inspection of all pipe supports in the general area identified by the alleger - was done by the NRC inspectors. No supports or restraints were found that would have fit the description of the type of structures of concern to the alleger.
- mm
15 (2) Conclusion This allegation could not be confit9med based on the general information provided by the alleger or by inspection in the general area.
- 4. Exit Meetina On March 13, 1984, the NRC inspector met with the alleger to discuss the findings of this inspection. The alleger stated that he was satisfied that his concerns had been considered sufficiently to determine if a valid problem had existed. He had no further concerns or questions. The NRC inspector offered to send the alleger a copy of the inspection report.
This offer was declined. Also on March 13, 1984, the NRC inspector met with licensee representatives identified in paragraph 1. The findings were discussed and acknowledged by the licensee. The senior resident inspector (construction) was informed of the findings.
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- enginte:Ing pers-en,el, iUCCo Operations raintenance perse:.ne'1, velding eng!n e Ing perro..nel and vender ; creer.ac1 ra r.it c red -the activit ies involved in the c..n%t ruc- - tien of the cend. nu rs; e.g. , velding ei.i;ineering i., nitored the field welding on the cea.!. n scr v c11s; TreCo Oper.it is.ns r.ointennnce ronitor ed the er.nect icn of the 1 co nde .c.trs t o the 'ov pr. .ne r. .M ion of the turbine; TUCCo ore nc. i r f ng e.r6d 0,i. r.. t i.e.s : c. ' .;t e n.c.r e : . it ed t'.c t u'.c ins t all..t i. n and tuhe coll ing pros e .s;
.:ad the vender . enit ored all of the i.irrtion activit ies. ,
the cc .de.:r.or desit ,n pr evides for i rcwu Ivat ien, wi th c t...! carate , of t '.c tl.te 81.ee t s t o p: . c l ude any 14. e water 1..4 pge int o t he :. team side f r e'n _ the wat e riox . side. 71.i s design was ef.~ .ct ed using the integral gr oove. The gruve vas i.acbir.ed
;.er, cadicular t o the longitud *nal a .is of tl.e tube ble in the t ube shc et cnd at the cent er of t he thici.:. : s of the t ube sheet., The dit. eter of the st rove s.ns r'uch-t o allev for overinp b..t . ..n adj.n < nt i;recves, thus providing a flev p.sth 's.r t he
. o. & : r o t e . i'uring int t f al filling r. pes at ions, lon' age f ron t he v..t erbox vas ob etved going into the t ube shr et pre 2surization annulus.. T1.e tubes vere re-rolled and Ic..k tc ted. No Ir.4 age was obrerved going firm the vat.ubox into the
..anu l u s . It; ion prc::surir.itirn of the annulus with cendenrate, lo.uage t ates of 0.5.
gal ./hr. and 0.4 gal ./hr. were obc.cived going fien Anntilus to t he :.tr.r n side of . cenJur.r.ers A and B respectively. - O ~da4"'d' p r-.* yg g w I /.,L ) DPP- bh[
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;.. c i f f ed a s e.t i.: - eri the t .: . i.*e ...d I..1.< t e.t i r en i1.c t ut e ide. The ren-
.'.:... rs ;...ced ihir. /.c.;.t. ire Test. Puring 1:Ot To:n t is nal T< r i : .g of t bc t . ..m
.u;. ply, c; c t s.t in,c r i i.d i t i o ns. I n t he c. n.>. n r.c r v. re ... h i. ved , r.n ;gg t hi s t ir.c ,
t che 31.ect p: ccr io ir.at ion vas in e r: s it e. 71.c e. t t ..: s i s'e < ! . : : tiy s e.r. i ...n i t e n ed
. r.d no e vi d. :.r e o f ? ct 1.ge viir, ni t ed .
In e.:.!. r t o ;. . rli:de u r.. t i s f... t i . a y v.. ! .. r . '.. .I t t i y en t :.c : . r < r..'.o y 1de i.f i t.c
..: < c.r. g. :.. t . t o r , I va o i :. re s 1..v c 1 ..n a c.' . n . 1) Th e t 6.1.c . *.. -. t i i c: ut iv..it it.n , e y e t . . .'. , s.s <.5.ri!cd al. eve, vill prer'n.?e 2..10 v. t er f r em ler.i l:.g int o t he i t .: in 1-s t ric of t l.c e n:. '. r .o r 1 y i .j..c t ing r . : .'. ..t c it.t o 11.e . miu]ur ..l eund c... h t ube in 1<.th tube .h...tc. Since t !.c ..:.de s.r . t e in t he .it.n rlus area is : t a high..r prer.rurc , .! .n t he Ic.1 r. s :> t . r , ..ny 1. .k vi l l 1.c f a e:- t he t ube : hee t pre. o r t : ..t ii.n :. : . . m t o the 1:J.c rirb. . 2) A cc ,!. : . ..t c ;.nl i r !.i:.g s; t . n is s r.pl e. y..d t o prov ide a . . n-t:nc.us . cut.u 'ne.nt r ec . . a1 pi ..c. ::s , t '.::s : . I nt i.i c i eg r: t i > f t.i t e.ry - t < :c: 3 . : .. :. t ..r 4
- < c. :..'.s ry side va t e r cl.< : 's t ry. 71.e ;< lis h f *.r, syst en t re i t s 1 r"si of tl.e r e:.. ..n. s t e. .
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t. i l Ycurs truly,
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7 In Reply Refer To: Docket: 50-445/84-12 50-446/84-06 Texas Utilities Electric Company ATTN: M. D. Spence, President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen: This refers to the inspection conducted under the Resident Inspection Program by Mr. J. E. Cummins and others of this office during the period March 20, 1984, through May 18, 1984, of activities authorized by NRC Construction Permits CPPR-125 and CPPR-126 for the Comanche Peak f acility, Units 1 and 2, and to the discussion of our findings with Mr. J. T. Merritt and other members of your staff at the conclusion of the inspection. Areas examined during the inspection included plant status, action on previous findings, 10 CFR Part 50.55(e) report followup, allegation followup (Unit 1), Inspection and Enforcement Bulletin followup, preservice inspection ,(Unit 1), and plant tours. Within these areas, the inspection consisted of selected examination of procedures and representative records, interviews with personnel, and observations by*the inspectors. The inspection findings are documented in the enclosed inspection report. Within the scope of the inspection, no violations or deviations were identified. _ In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the , date of this letter. Such application must be consistent with the requirements ' of 2.790(b)(1). RPSB/2h TF h TF e.. ,
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WFSmith/1 DMHunnicut WCSeidle TFWesterman RLBangart h /,1,l/84 RPDenise h /1)/84 k/tA/84 / /84 . k/$(/84 84 h/ TF l d k Tips @i N.c5 - ; Gklh\l0#N jjQ']}~ -
. M' ? .
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Texas Utilities Electric Company . Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely,
.. . L. tc ,s. ;
Richard L. Bangart, Director Region IV Comanche Peak Task Force
Enclosure:
Appendix - NRC Inspection Report 50-445/84-12 50-446/84-06 cc w/ enclosure: Texas Utilities Electric Company ATTN: H. C. Schmidt, Hanager Nuclear Services Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Texas Utilities Electric Company ATTN: B. R. Clements, Vice President, Nuclear 3 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 -- bcc to DM8 (IE01) bec distrib. by RIV: RPB1 Resident Inspector-Ops
- RPB2 Resident Inspector-Cons TPB R. Bangart, D/TF ,
J. Collins, RA W. Seidle, 00/TF R. Denise, D/RRP&EP T. Ippolito, NRR S. Treby, ELD D. Hunnicutt, TF MIS SYSTEM T. Westerman, EO RIV File J, Gagliardo (CPSES) TEXAS STATE DEPT. OF HEALTH (.///,*- J Juanita Ellis Renea Hicks Billie P. Garde TRT (2) (CPSES)
f APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-445/84-12 Construction Permits: CPPR-126 50-446/84-06 CPPR-127 Dockets: 50-445; 50-446 Licensee: Texas Utilities Electric Company (TUEC) Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection at: Glen Rose, Texas Inspection Conducted: March 20, 1984, through May 18, 1984
'Inspeckors .
aW J. E. Cummins, Senior Resident Inspector
$f2ff8f
, /t,
' Datef Construction (paragraphs 1, 2, 4, 7, 8, and 9) b hr JL =LM W. M. McNeill, Reactor Inspector, db2/l84 Dite /
~
l Project Section A (paragraph 6) b?nJM 2 D. P. Tomlinson, Senior Resident Inspector 4/.u/87
'Date /
South Texas Project (paragraph 6) bh nW D. M liunnicutt, Team Leader, Region IV $ N Bf Date ' Task Force (paragraphs 1, 3, 4, 5, 7, and 9)
2 Inspection Summary Inspection Conducted March 20, 1984, throuch May 18,1984 (Report: 50-445/84-12) Areas Inspected: Routine, announced inspection of plant status, licensee action on previous findings, 10 CFR 50.55(e) report followup, allegation followup, Inspection and Enforcement Bulletin followup, and plant tours. The inspection involved 170 inspector-hours onsite by four NRC inspectors. Results: Within the six areas inspected, no violations or deviations were identified. Inspection Summary Inspection Conducteo March 20, 1984, through May 18, 1984 (Report: 50-446/84-06) Areas Inspected: Routine, announced inspection of plant status, licensee action on previous findings, 10 CFR 50.55(e) report followup, Inspection and Enforcement Bulletin followup, and plant tours. The inspection involved 26 inspector-hours onsite by two NRC inspectors. Results: Within the five areas inspected, no violations or deviations were identified. i 1 6 o 9 6
DETAILS SECTION
- 1. Persons Contacted
*J.T. Merritt, Assistant Project General Manager, Texas Utilities Generating Company (TUGCO)
*A. Vega, Site Quality Assurance Manager, TUGC0 R. G. Tolson, Staff-Project Manager, TUGC0 G. Purdy, Site QA Manager, Brown & Root (B&R)
H. Hutchinson, Project Control Manager, B&R G. L. Morris, Site Mechanical Level III ASME Quality Engineer, B&R F. L. Powers, Electrical / Control Building Manager, TUGC0 S. Spencer, QA Auditor (Corporate Office), TUGC0 J. Mars'.all, Licensing Supervisor (Corporate Office), TUGC0 M. RidII, Operations Support Engineer, TUGC0 T. Taylor, Engineer, Battelle Pacific Northwest Laboratories K. V. Cook, Research and Development Engineer, Oakridge National Laboratory J. Enriotto, Manager, Material Technology, Westinghouse D. Adaomis, Senior Engineer, Westinghouse R. Dacko, Licensing Engineer, TUGC0 J. Keller, Field Engineer, TUGC0 The NRC inspectors also contacted other plant personnel including members of the construction, operations, technical, quality assurance, and administrative staffs.
- Denotes those attending one or more exit interviews. -
- 2. Plant Status Construction of Unit 1 is approximately 97% complete with fuel loading scheduled for the end of September 1984 The licensee continues to complete and turnover systems and areas from construction to operations. .
The turnover process is accomplished in two phases. Tha first phase takes place when construction completes a system or area and turns that i system or area over to the startup group. The turnover process iy completed for a system or area when operations makes final acceptance of the system or area from the startup group. The table below indicates the status, as of April 27, 1984, of the 423 distinct areas identified -, by the licensee for turnover from construction to operations: I
- l
- l. I
4 Total number of areas 423 Number of areas submitted to startup 226 Number of areas accepted by startup 199 - Number of areas submitted to operations 116 Numbers of areas accepted by operations 82 The table below indicates the status, as of April 27,1984, of the 332 distinct subsystems identified by the licensee for turnover from construction to operations: Total number of subsystems 332 Number of subsystems submitted to startup 314 Number of subsystems accepted by startup 313 Number of subsystems submitted to 57 operations Number of subsystems accepted by operation 27 Construction of Unit 2 is approximately 65% complete with fuel loading scheduled for March 1986.
- 3. Licensee Action on Peevious Inspection Findinos ~~
(Closed) Severity Level V Violation 445/8324-01 and 446/8315-01: Failure to Provide Adequate Procedures, Instructions, or Drawing for Installation of Major Items of Equipment The NRC inspector reviewed the licensee's stated corrective actions by - reviewing and evaluating the following licensee procedures: , QI-QAP 11.1-39, " Mechanical Equipment Installation Inspection", Rev. O, dated February 2,1983 CP-QAP-12.1, " Inspection Criteria and Documentation Requirements Prior - to System N-5 Certification," Rev. 8, dated August 3,1983 The NRC inspector's review determined that the specification and the i construction installation procedures for mechanical equipment installation j were revised by requiring that the engineer specify the requirement for d
safety-related mechanical equipment. A reinspection program has been instituted to verify mounting details on safety-related mechanical equipment by requiring an additional step in the inspection walkdown and maintaining an appropriate checklist. Licensee has completed reinspection, walked down systems, and checked "as built" conditions. The Master Data Base is up to date. The NRC inspector verified that the licensee's corrective actions as stated in their response dated June 28, 1983, have been adequately implemented. (Closed) Severity Level V Violation 445/8324-02 and 446/8315-02: Failure to Provide Adequate Maintenance of Materials and Equipment in Outdoor Warehouse Areas The NRC inspector reviewed the licensee's stated corrective actions by reviewing and evaluating the following licensee procedures: QI-QAP-11.1-26, "ASME Pipe Fabrication and Installation Inspections," Rev. 11, dated March 18, 1983 QI-QAP-11-28. " Installation Inspections of ASME Component Supports *
- Class 1, 2 and 3," Rev. 8, dated January 15, 1982 QI-QAP-11.1-28A, " Installation Inspections of ASME Class 1, 2, and 3
' Snubbers ' ," Rev. 2, dated April 28, 1983 CP-QAP-16.1, " Control of Nonconforming Items" i
- QI-QAP-2.1-5, " Training and Certification of Mechanical Inspection Personnel" I ..
The NRC inspector determined that QC inspection instructions have been - revised to specifically address the verification of material conditions of items prior to installation and that storage conditions preclude deterioration of materials and equipment. Outside storage is monitored on a periodic basis by QA to determine the adequacy of storage and a preservation program has been established to clean, preserve, and/or paint any items showing signs of dirt or corrosion. The licensee has - prepared a standard warehouse procedure that addresses storage requirements and conditions. The NRC inspector verified that the licensee's corrective actions as stated in their response dated June 28, 1983,'have been adequately implemented. .. (Closed) Unresolved Item (445/8214-02): Review of Licensee's Method of Inspection of Skewed Welds, Dated November 8,1982 t An allegation that the licensee's QC inspection procedure for welding did not contain written instructions for examining skewed fillet welds was j i reviewed. (NOTE: Skewed welds are defined as those welds joining two - structural members that are not in the same plane and are not perpendicular l
'~
to each other. A typical example is two members jointed at an angle of 45 degrees with a weld at the joint toe of 135 degrees and another weld at the heel at a 45 degrees angle). The NRC inspector completed a detailed review and evaluation of four procedures and the results of the licensee's reinspection efforts for skewed fillet welds. Procedures reviewed are listed below: QI-QAP-11.1-26, Revision 15, "ASME Pipe Fabrication and Installation Inspections and Requirements Prior to System / Subsystem N-5 Certification" QI-QAP-11.1-28, Revision 24, " Fabrication and Installation Inspection of Safety Class Component Supports" QI-QAP-11.21-1, Revision 6, " Requirements for Visual Weld Inspection" CP-QAP-16.1, Revision 20, " Control of Nonconforming Items" The NRC inspector reviewed licensee / contractor records for 27 of the 640 supports with skewed fillet welds. The records were reviewed primarily for final as-built configuration and the results of the licensee's reinspection effort. The licensee originally committed to a reinspection of randomly selected skewed fillet welds with selection based upon statistical sampling techniques (reference: Inspection Report 50-445/82-14, paragraph 4). However, the licensee performed a 100% reinspection of the 640 affected supports with skewed fillet welds, rather than a randomly selected statistical technique. The NRC inspectors reviewed the licensee's drawings to determine the extent of inspection requirements for supports with skewed fillet welds. The NRC inspector's review and evaluation determined that the licensee's reinspection did not identify any skewed ' fillet welds that were undersized or otherwise did not meet appropriate - requirements. No nonconformance reports (NCRs) were issued by the licensee or contractor during or as a result of the reinspection effort. The NRC inspector performed visual inspection of the following Unit 1 supports and found no undersized skewed fillet welds: - RC-1-099-001-C86R RC-1-101-002-C86K RC-1-115-020-C66A RC-1-115-025-C66K DD-1-109-035-C46R VD-1-1p*001-C46R SF-1-022-005-C46R SF-y i$c 700-A35R CA-1-028-021-C46R EMS',4LS* 005-C86R -- No violations or deviations f.sre .c.r,tified. (Closed) Severity Level IV Violation 445/8324-03 and 446/8315-03: Failure to Remove Obsolete Drawings from Construction Work Areas
'W
The NRC inspector reviewed the improved process for reproducing drawings and determined that the new process results in an improved drawing, both in-quality and legibility. The drawings reviewed are current and no out-of-date. drawings were located in the work areas. The licensee's
" Satellite" system for Unit 1 is complete and operational. This system is composed'of four separate " Satellite" areas. The licensee is approxi- ,
mately 98% complete on a fifth " Satellite" area that is designated for Unit 2. From this review, the NRC inspector concluded that the four
" Satellite" areas meet FSAR Section 17, paragraph 17.1.6 and B&R Procedure DCP-3, "CPSES Document Control Program," requirements.
The NRC inspector verified that the licensee's corrective actions as stated in their response dated June 28, 1983, have been adequately implemented.
- 4. 10 CFR 50.55(e) Report Followup and Evaluation The NRC inspectors conducted a review of 26 licensee reported potential '
10 CFR Part 50.55(e) packages. Of these 26 reports, 10 were found to not require a report (nonreportable) and the other 16 required the licensee to submit a report in accordance with 10 CFR Part 50.55(e) requirements. The licensee refers to 10 CFR 50.55(e) reports as "Significant Deficiency Analysis Reports" (SDARs). The licensee's SDARs were reviewed for content, compliance with NRC requirements for reporting, corrective actions, appropriate evaluation, timeliness of reporting, and completion of documentation. The following 26 CFR Part 50.55(e) reports (SDARs) and related licensee documentation were reviewed by the NRC inspectors, were found to meet the requirements, and were closed: 50.55(e) Licensee Evaluation Licensee or Reportable (R) or Date Letter SDAR Subject Not Reportable (Ne') Closed Number -. CP-81-01 Ceficote 658-N Epoxy NR 2/17/81 TXX3279 Testing and Calcula-tions for " Compressive Strength of Epoxy Grout" CP-82-A Installed Borg Warner R 3/18/82 TXX3495 Valves (Containment ' Spray Valves) CP-82-02 Design of Horizontal R 5/28/82 TXX3523 Fire Dampers
.~
CP-82-06 Unit 2 Emergency Diesel R 1/10/84 TXX4095 , (EDG) Generator Auxiliary
- Skid l
50.55(e) Licensee Evaluation Licensee _ or Reportable (R) or Date Letter SDAR Subject Not Reportable (NR) Closed Number CP-82-15 Defective Piston Skirt R 1/30/84 TXX4101 Castings for Unit 2 EDG CP-83-01 Borg Warner Valves R 9/7/83 TXX4043 (check valves - disen-gaged parts) CP-83-10 Letdown Heat Exchanger R 7/7/83 TXX4001 Anchors (mounting confi-guration) CP-83-15 Cable Tray Clanips (mild R 7/12/83 TXX4005 steel bolting acceptable) CP-83-17 Inadequate Overpressure R 8/9/83 TXX4023 Protection for Spent Fuel Pool Cooling Hx Components Cooling Water (relief valves incorrectly set) CP-79-09 Installation of Major R 8/6/80 TXX3173 Conduit Supports Without Benefit of an Approved Instruction, Procedure or Drawing CP-83-18 Containment Building R 9/26/83 TXX4054 - Cooling (neutron detector - well Reactor Cavity Cool-ing System) CP-83-21 Transmitter Calibrations R 12/28/83 TXX4091 (excessive errors due to . , calibration techniques corrected) ' CP-83-04 Potential Defect of NR 2/28/83 TXX3635 Radiation Monitoring System CP-83-06 Vendor Installed HVAC R 7/29/83 TXX4016 i System CP-83-07 New Fuel Storage Racks R 5/31/83 TXX3677 r- v
50.55(e) Licensee Evaluation or Licensee Reportable (R) or Date Letter 50AR Subject Not Reportable (NR) Closed Number CP-83-08 Control Valve Brackets R 4/21/83 TXX3657 Unqualified Valve Attachments CP-83-12 Class 1 Material NR 6/21/83 TXX3691 Deficiencies (NDE specified was not performed) CP-83-13 Strut Jamming Devices NR 6/21/83 TXX36692 (jam nuts on rigid struts) CP-83-14 (W) Loop Power Supply NR 6/21/83 TXX3693 (NLP) Printed Circuit Cards - no cards of type with defects found at CP CP-83-16 Welded Attachments to NR 7/20/83 TXX4012 Piping Af ter Hydrostatic Testing CP-83-19 Service Water System NR 10/17/83 TXX4064 Valves (safety function not adversely affected) CP-83-22 Chlorine Detection and R 1/18/84 TXX4098
~'
Control Room HVAC (not - per NRC Regulation and FSAR) CP-84-07 Deficient Lug Crimping R 3/29/84 TXX4139 CP-82-05 Concrete Void in Unit 1 R 8/24/82 TXX3561 Steam Generator Compart- , ment #2 Exterior Wall CP-82-01 Material Procured by NR 2/19/12 TXX3480 AFC0 Steel - - . I CP-82-08 Defective Limitorque NR 10/12/82 TXX3580 Pinion Keys The above 10 CFR Part 50.55(e) reports are closed. No violations or deviations were identified. -
l Selected NRC inspector observations of licensee reported items (10 CFR Part'50.55(e)) that the licensee is presently investigating or performing corrective a'ction on are discussed below:
- a. Rodent Damage to Class IE Electrical and Control Cables The licensee verbally reported damage to electrical and control cables between the Service Water Intake Structure (SWIS) and the safeguards building to the NRC and subsequently documented the information in SDAR CR-84-10.
The NRC inspectors observed portions of the licensee's inspection, corrective actions, and repulling of repaired cables or replacement of electrical and control cables at the SWIS and manholes MH 1A1 and MH 1A2 locations. The licensee removed all 28 cables (24 control cables and 4 instrumentation cables) in the Orange (A) Train. The licensee found considerable rodent damage to the insulation on several of these Instrument and Control (I&C) cables, and replaced each of the 28 I&C cables with new cable. The licensee pulled each of the nine 480V AC electri, cal cables out of the conduit and raceways; visual inspection identified some minor surface damage caused by rodents on two of these cables. The licensee repaired each surface damaged area and returned the cables to their original locations. The licensee performed visual inspections, meggered each of the 3 cables for the 6.9KV AC circuit, performed high voltage (hi pot) testing on each cable, and determined that the 6.9KV circuit was satisfactory. Licensee and NRC inspectors determined that the major rodent damage occurred near the junction of conduit C-130 01711 and junction box
-JBIM-2070 and between manhole E1A2 and E1A1 and safeguard cable A4009242A. Inspections of junction box JBIM-2060 and conduits ~
C-12005538, C-1205539, and C-12001693 in the SWIS were also performed ' by the licensee and NRC inspectors. The licensee issued the following NCRs as a result of the rodent damage to electrical and control cables in the Orange (A) Train: s E-84-00954, Rev. 3 E-84-00962, Rev. 1 E-84-00974, Rev. 2 E-84-00975, Rev. 1 E-84-01309, Rev. 0 Prior to reinstallation of the cables, each conduit was cleaned and no evidence of rodents was found. The licensee has completed replacement, repairs, repulling, and testing of the above cables. , The licensee included the following preventive measures to assure the integrity of the cables:
-g ,, 4 y w r-
(1) All areas adjacent to manholes were baited with rat poison. (2) All conduit openings in the manholes are covered with temporary protective covering to preclude rodent entry. Permanent coverings are to be installed as specified in ~ Design Change Authorization (DCA) 20397. (3) All conduit openings at the entrance or exit of the ductwork have been sealed with elastomer caulk or firestop foam. The licensee investigated the Green (B) Train cables between the SWIS and the safeguards building to assure that the integrity of this train could be verified. The licensee personnel pulled oversized cloth swabs through each conduit. The NRC inspectors observed portions of this swabbing from both the SWIS and the manhole entrances. Possible rodent entry was identified in one conduit. The licensee removed the 28 (24 control and 4 instrumentation) cables from the ductwork as required by NCR E-84-01434.
~ The licensee inspected these cables and determined that two active cables and one spare cable had sustained minor damage. The licensee repaired the minor damage. The NRC inspectors observed portions of the inspection and repair in the Green (B) Train. The licensee reinstalled the 28 cables and initiated the preventive measures stated above for the Orange (A) Train.
No violations or deviations were identified.
- b. Thermo-lag Installation On May 2,1984, the licensee verbally reported to the NRC, that ~
contrary to CPSES construction procedures, construction debris in - the form of scraps of thermo-lag material was found lying loose in electrical cable trays. The licensee subsequently documented this
- incident in SDAR CP-84-11. Prefabricated sections of thermo-lag material are being installed around electrical cable trays for fire protection. The strips of thermo-lag material had apparently been '-
placed inside the cable trays to support the prefabricated sections , of thermo-lag that were installed over the cable trays. When the problem was discovered, the licensee stopped the installation of the thermo-lag and evaluated the problem. The licensee's corrective action included the retraining of individuals involved in the installation of thermo-lag, the reinspection of cable trays 24 inches -- wide and larger that had already had the thermo-lag installed, and additional quality control inspection of cable trays immediately prior to sealing the prefabricated sections of thermo-lag. i No violation or deviations were identified.
,, - - , .x .--
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- 5. Followup of Allegation Concerning Bolts for Steam Generator (SG) Upper Lateral Supports An allegation was received in the Region IV office that some bolts holding the SG laterial supports to the wall plates had been cut off and, therefore, were incapable of securing the SG lateral supports to the imbedment plates in accordance with design requirements.
A review by the NRC inspector of the materials, drawings, specification, purchase orders, travellers, material received records, and related records documents indicated that the licensee purchased 144 AS40GT 823 Class 4 2-1/2-inch diameter bolts 9 inches in length. The licensee purchased these 144 bolts 1-1/2 inches too long and then cut each of these bolts to 7-1/2-inch length to meet delivery and scheduling requirements. The rework (cutting 1-1/2 inches off the 9-inch ler.gth of each bolt) was authorized by the licensee and is documented in work package MRB-0550-013-RB. The licensee did this allegation wascut 1-1/2 inches off each bolt; therefore, in substance, substantiated. However, there is no technical merit nor bolt. safety concern related to cutting 1-1/2 inches off the length of each The original design required hex head bolts 7-1/2 inches in length and 2-1/2 inches in diameter. The NRC inspector reviewed the following documents related to the above information:
- G&H Orawing 2323-17. Rev. 1
- AFC0 Steel Drawing 303 Purchase Order (PO) 35-1195-14915 C07 .,
Material Received Records (MRR) 060860, 61000, and 61150 ' Material Test Reports (MTRs) for Charpy Impact, Tensile Strength,
- Chemical Analysis, Heat Treatment, and Magnaflux Testing Receiving Inspection Reports (RIR) 6008, 6256, and 6428 No violations or deviations were identfied.
- 6. Preservice Inspection - Unit 1 ,
A previous NRC inspection (50-445/82-19) reported witnessing of preservice ultrasonic inspection of Unit l's reactor coolant system piping. It was noted in the above report that: (1) adequate penetration of the longi- tudinal wave was not achieved as evidenced by the sporadic loss of back reflection and (2) a full volumetric examination was not achieved as evidenced *by the saturation of the cathode ray display screen such that w m
A indications in the outer half of the pipe th'ickness could not be identified by the refracted longitudinal wave. A demonstration by Westinghouse was requested by the NRC Division of Licensing based on recently reported successful ultrasonic inspections at the Callaway and Wolf Creek sites. The demonstration was requested to establish if these improvements in the ultrasonic testing instrumentation could result in a successful ultrasonic inspection at CPSES, Unit 1. On March 20 and 21, 1984, the confirmatory demonstration ultrasonic inspection was performed at CPSES, Unit 1 by Westinghouse. The demonstra-tion was witnessed by NRC inspectors and their consultants (Oak Ridge and Pacific Northwest Labs). The inspection was performed by Westinghouse Level II and III personnel (qualified to SNT-TC-1A) to Procedure ISI-206, Revision 0, " Manual Ultrasonic Examination of Welds." The demonstration. included a longitudinal wave and a refracted (41 degrees) longitudinal wave of weld joint numbered 13 on Isometric Drawing TBX-1-4200 of Unit 1 and several weld joints; 1.e. , 27 and 29 of Unit 2. The demonstration confirmed the previous NRC observations in regard to Unit 1. On weld number 13, only a sporadic back reflection could be achieved from the longitudinal wave. With the refracted longitudinal wave, considerable saturation was observed, approximately one-half the material thickness. On Unit 2, a consistent back reflection from the longitudinal wave was observed which indicated adequate penetration. After searching for a counter bore on the inside diameter of four different joints, one joint was found which consistently showed the counterbore by the refracted longitudinal wave. The saturatien of the screen was less however, about 1/4 of the thickness near the outside diameter still could not be inspected. It was noted that the procedure, equipment, and some of the personnel were the same as previously used in the 1982 preservice inspection. The differences found between Units 1 and 2 could be accounted for by the - observed differences in surface finish condition and preservice inspection weld preparation. The chemical composition of the heats, grain size, and other geometrical factors could not be visually determined, but could have been significant contributors to the ultrasonic differences observed during the demonstration. *
- 7. Plant Tours At various times during the inspection period, the NRC inspector conducted general tours of the reactor building, fuel building, safeguards building, electrical and control building, and the turbine building. During the -'
tours, the NRC inspector observed housekeeping practices, preventive maintenance on installed equipment, ongoing construction work, and discussed various subjects with personnel engaged in work activities. { No violations or deviations were identified. l +
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- 8. Inspection and Enforcement Bulletin (IEB) Followup The NRC inspector reviewed the licensee's IES files for selected IEBs to verify that the licensee had conducted an adequate review of each IEB to determine its applicability to the CPSES facility and that the licensee had taken appropriate action when the IEB was applicable. Through discussions with licensee representatives and reviewing records, the NRC inspector was able to determine that the licensee had satisfactorily responded to the IEBs listed below. These IEBs are closed.
Licensee Closure IEB No. Title Letter No./Date 78-05 Malfunctions of Circuit Breaker TXX2908/11-16-78 Auxiliary Contact Mechanism Model CR 105X 78-06 Defective Cutler Hammer, Type M TXX2959/02-19-79 Relays with DC Coils TXX2869/08-04-78 78-10 Bergen-Patterson Hydraulic TXX2894/10-19-78 Shock Suppressor Accumulator Spring coils 79-03 Longitudinal Weld Defects in TXX2983/05-01-79 and ASME SA-312 Type 30455 TXX3204/10-07-80 79-03A Pipe Spools Mfg. by Youngstown Welding and Engineering Co. 79-04 Incorrect Weights for Swing TXX3000/06-14-79 Check Valves Manufactured by TXX2989/05-23-79 Velan Engineering Co. - 79-09 Failures of G.E. Type AK-2 TXX2988/05-22-79 Circuit Breakers in Safety-Related Systems 79-11 Faulty.0vercurrent Trip . TXX3013/07-16-79 Cevice in Circuit Breakers , for Engineered Safety Systems 79-23 Potential Failure of Emergency TXX3056/10-17-79 DG Field Exciter Transformer .. 79-25 Failures of Westinghouse BF0 TXX3191/09-08-80 Relays in Safety Related Systems m f t ._.
Licensee Closure IEB No. Ti tl e Letter No./Date 80-16 Potential Misapplication of TXX3172/08-08-80 Rosemount, Inc. Models 1151 and 1152 Pressure Transmitters with "A" or "D" Output Codes 80-21 Valve Yokes Supplied by Malcolm TXX3250/12-22-80 Foundry Co., Inc. 80-23 Failures of Solenoid Valves TXX3246/12-17-80 Manufactured by Valcor Engineering Corp. 80-19 Failures of Mercury-Wetted TXX3189/09-08-80 Matrix Relays in Reactor Protective Systems of Operating Nuclear Power Plants Designed by CE , 80-04 Deficiencies in Primary Con- TXX36687/06-14-83 tainment Electrical Penetration Assemblies NRC inspector observations of activities related to IEB 82-04 are discussed below: IEB 82-04 licensee action item 1.a required the licensee to inspect all supplier provided electrical penetration terminal boxes and verify that the,, conGactor terminations were satisfactory. The licensee determined that there were 4 supplier provided penetrations (IE80, IE81, 2E80, and 2E81) with - attached terminal boxes involved each with 8 terminations for a total of 32 terminations. Due to the small number of terminations involved, the licensee replaced all 32 lugs in these boxes which had previously been terminated by the supplier. N IEB 82-04 licensee action item 1.b required the Itcensee to inspect - electrical penetration conductors as they enter and exit penetration modules and verify the integrity of the insulation around the conductors. The licensee inspected all of the accessible conductors on safety-related penetrations for Units 1 and 2. At the time of the ifcensee's inspection, the Unit 2 safety-related penetrations were stored in a -' warehouse and the Unit 1 safety-related penetrations were installed in the plant. The licensee's inspection included all of the Unit 2 I - I t b L
4 16-safety-related penetration conductors and all of the Unit 1 safety-related penetration conductors where these penetration conductors enter / exit the penetration modules on the reactor building end of the penetrations. The licensee's inspection verified the integrity of the insulation around the conductors. The Unit 1 penetration conductors on the end of the penetra-tion located outside of the reactor building were not accessible. The licensee's inspections were documented by quality control personnel. IEB 82-04 licensee action item 1.c required the licensee to conduct detailed examinations of all supplier provided in-line butt splices having a wire size of #2 AWG and smaller, and to ascertain acceptability of these connections. The licensee inspected a random sample of the vendor provided in-line butt splices. The sample size was a minimum of 25% of the total number of vendor supplied in-line butt splices for each size conductor. In addition to the inspection of butt splices, the licensee selected a 10% random sample of the in-line butt splices, inspected and performed a pull test on them. The in-line butt splices for all wire sizes except #2 AWG passed the pull test. Due to the failure of the #2 AWG conductor in-line butt splices to pass the pull test, the licensee is replacing all #2 AWG in-line butt splices on safety-related penetrations. l The NRC inspector performed the following inspection activities to verify that the licensee's response and corrective action fulfilled the i requirements of IEB 82-04:
- a. Reviewed the licensee's sample size and found that it met or exceeded the minimum required by Section 2.b of IEB 82-04.
- b. Reviewed licensee's documentation and connector vendor (Amp Incorporated) catalogs.
- c. Inspected a random sample of licensee installed connectors and '
j verified that the connectors were installed properly. The connectors and crimpirg tool were as specified by the connector vendor. The crimping tool was calibrated (the calibration included the performance of a pull test on a similarly installed sample connection).
- d. Inspected the conductor insulation of a random sample of conductors at, the point where the conductors exited / entered the epoxy of the penetration feed thru modules.
Selected portions of the accessible conductors on the safety-related penetrations listed below were inspected: ~ ! i Unit 1 (penetrations installed) IE6, IE9, IE10. IE11, IE12, IE13. IE15. IE16, IE17. IE47, IE39, IE56 IE60 IE64, IE62, AND IE63. I ~ i i
- - - ,-- ~ ,,,,w- .- - s ---4 -.--1,,-. -y--,--. ,-, - -_,,,g--+ +.y-w,r..--- , -- ,,---w, --r --,,---.-.+-,-,m - ,. .-- -
I I Unit 2 (penetrations stored in warehouse) 2E12, 2E13, 2E18, 2E40, 2E56, 2E57, 2E58, 2E59, 2E62, 2E64, 2E76, 2E77, 2E78, 2E79, 2E80, AND 2E81. Selected NRC inspector findings are discussed below:
- a. In attachment 2 to enclosure 1 of licensee's response letter TXX-3687 dated June 14, 1983, the licensee incorrectly listed penetrations 2E78 and 2E79 as the penetrations inspected for #12 AWG conductors.
The penetrations actually inspected were 2E76 and 2E77 and the licensee's documentation confirm these inspections.
- b. During the manufacturing process, a piece of sleeving was placed over some of the conductors on the section of conductor that is embedded in epoxy. This sleeving extends approximately 2" on either side of the epoxy. This sleeving in some cases is cracked at the juncture of the sleeving and the epoxy. The conductor insulation inside the sleeving was intact in all except one instance observed by the NRC inspector. This instance was on conductor E3 of penetration IE10.
This conductor had insulation damage; however, this damaged conductor had been identified by the licensee, and the licensee had issued revision 4 to sheet 10A of drawing 2323-EI-0511 which classified this lead and two adjacent leads as damaged.
- c. During the licensee's inspection of the in-line butt splices, the licensee found that the vendor had failed to crimp one end of a splicing lug on lead E6 of penetration 2E-58. This condition was documented on licensee's traveler No. EE83-0136-9301 and corrective action (splicing lug to be replaced) delineated on nonconformance report E83-00424. This failure of the vendor to crimp the lug was not interpreted by the cognizant licensee representative as being an ~'
under crimped condition and, therefore, this instance was not - identified in the ifcensee's response to IEB 82-04. The licensee inspected 424 conductor splices and this is the only crimp that was identified as not being made. The Unit 1 penetrations are installed with most of the related work being completed on them. The NRC inspector did not find any evidence of conductor deterioration or damages that would make the integrity of the Unit 1 penetrations , questionable. The licensee is still performing work on the Unit 2 penetrations. Some of the work being performed is restoration from the inspection, testing, and corrective action related to IEB 82-04. The NRC inspector will monitor -- selected portions of this work and also the installation of these penetrations.
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- 9. Exit Interviews The NRC inspectors met with members of the TUEC staff (denoted in paragraph 1) at various times during the course of the inspection.
The scope and findings of the inspection were discussed. The Itcensee , acknowledged the NRC inspectors' statements. d I i i .. 4 i i-a i e k
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