ML20137P112
| ML20137P112 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/31/1986 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#186-949 CPA, NUDOCS 8602040340 | |
| Download: ML20137P112 (83) | |
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s;I UNITED STATES
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NUCLEAR REGULATORY COMMISSION EU FEB-3BSE"'~l v,
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In the Matter of
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TEXAS UTILITIES GENERATING COMPANY,
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Dkt. Nos. 50-445-OL et al.
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50-446-OL
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(Comanche Peak Steam Electric
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Station, Units 1 and 2
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CASE REQUEST FOR IMPOSITION OF FINE, FOR SUSPENSION OF CONSTRUCTION ACTIVITIES, AND FOR A HEARING ON APPLICATION TO RENEW CONSTRUCTION PERMIT On August 1, 1985, the construction permit for Unit 1 of the above-identified plant expired.
In direct violation of NRC regulations ($50.10), construction continued on the unit for six months, at least until January 27, 1986.
TUEC, in its filing dated January 29,1986, seeking an extension of the completion date of the expired permit, indicates that it has voluntarily halted some but not all construction on Unit 1 but that it may recommence construction without permission of the NRC.
The purpose of this filing is to request the Commission to act immediately on four issues related to these events:
1) appropriateness of imposition of fines against TUEC for its six-month violation of 50.10, its continued construction activities, and its reservation of the right i
to recommence any other construction l
activities at Unit I without a valid permit; 2) whether any construction can continue 8602040340 060131 ADOCK0500ggg5 PDR G
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at Unit 1, including CPRT work, when no construction permit exists; 3) the existence of a significant 4
hazards consideration related to the proposed continuation of construction at Unit 1 4)
The need for a full adjudicatory hearing on the requested amendment to the expired construction permit pursuant to 42 U.S.C.
y2239.
A.
Fines.
In its general statement of policy and procedure for enforcement actions, the Commission established a subste.ntial commitment to enforcement of its regulations and to the imposition of fines for willful violations of requirements, including careless disregard of regulations.
The six-month continuation of construction after expiration of its construction permit without even applying for an amendment to the permit is precisely the kind of careless disregard of requirements to which fines should be applied.
The admitted continuation of some construction activities and intent to reserve the right to commence other con truction activities is the wi11 fulness for which particularly severe penalties should be imposed.
In addition, as the following discussion makes clear, TUEC has extensively violated QA/QC requirements, has failed to i
properly design the facility and has consistently ignored the i
i warnings from NRC inspections and independent audits to correct I j
l
QA/QC and design problems.
Even today violations of procedures are occurring in the implementation of the CPRT and rework program.
All'of this conduct warrants the full imposition of the enforcement authority of the NRC.
The gross misconduct of TUEC requires swift, certain, and severe punishment.
B.
Halt Construction.
1 Because TUEC has filed a request to renew its construction permit for Unit 1, the Commission must decide a threshhold legal questions whether a request to renew an expired construction permit is in the nature of an application for a new permit subject to the obligatory requirement for a hearing under 42 U.S.C.
92239, or whether it is in the nature of an amendment and subject to the discretionary hearing requiremen'ts of 350.92.
We believe it is unavoidable that the filing being made by TUEC now, regardless of how it is titled, is an application for a new construction permit.
There cannot be an amendment unless there is something to amend.
By its terms the Unit I construction permit expired six months ago.
That permit concluded with the statement that "[t]his permit is effective as of its date of issuance and shall expire on the latest completion date indicated in paragraph 3.A above" (emphasis added).
50.55(b) provides similarly:
If the proposed construction or modification of the facility is not completed by the latest completion date, the permit shall expire and all rights thereunder shall be forfeited:
Provided, however, That upon good cause shown the Commission will extend the completion date for a reasonable period of time.
The Commission will recognize, among 1
other things, developmental problems attributable to the experimental nature of the facility or fire, flood, explosion, strike, sabotage, domestic violence, enemy action, an act of the elements, and other acts beyond the control of the permit holder, as a basis for extending the completion date.
Unlike the statutory and regulatory language, relied upon by TUEC in its application, related to the FCC, the NRC statute and regulations unequivocally require forfeiture of a license unless
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a good cause finding is made after an application for renewal is filed.
The relevant FCC language, relied upon extensively in the cases cited by TUEC, is that the FCC license may be extended "for such further time as the Commission may allow" or for good cause.
47 U.S.C.
319(b).
The NRC may only extend for good cause, and unless and until a timely request for such a finding is made the permit is forfeited.
This is the clear purport of 10 CFR }2.109 explicitly granting an automatic extension of a license if a timely renewal application iji filed.
Unless construction permits are deemed to be mere formalities, their expiration must make a substantial difference.
That difference is, at a mininum, that a new permit must be 1
sought to continue construction.
The facts already known about TUEC and the work at Unit 1 disclose an unparalleled failure to obey the most fundamental requirements for construction of a nuclear facility.
Thus there is a particular need here for the Commission to adhere strictly 1
The situation here is markedly different than in the more usual case of an application being filed prior to expiration of the permit but no action being taken by the Staff until af ter the permit expires.
In that case $2.109 authorizes continuation of licenses.
to the legal requirement that a utility without a construction permit must be subject to a construction permit hearing as a precondition to being allowed to undertake construction 2
activities.
Where, as here, there has already been a hearing and decisions on issues which could arise in the new proceeding, the prior decisions would be binding absent the existence of significant new evidence.
Such new evidence exists here and is disclosed in four ways:
1) inspections and audits of TUEC by NRC and independent organizations; 2) decisions and other memoranda of the Atomic Safety and Licensing Board; 3) the findings of Staff investigations of allegations by former workers at Unit 1 as detailed in the TRT reports, the SSERs, and the EG&G findings on harassment and intimidation of QA/QC inspectors; 4) admissions by spokespersons for TUEC or as contained in deficiency reports, NCRs, or other TUEC (or TUEC-agent) generated 2
TUEC seeks to invoke the doctrine of nunc pro tune to overcome its failure to file the extension request before the permit expired.
The doctrine is applicable only where the act in question was actually performed before and mere formalities were~
omitted.
Here the acts in question, timely filing for an extension and conducting construction activities only with a valid permit, were not performed.
Nunc gro tunc is not a substitute for compliance with substantive requirements of the NRC.
Had TUEC filed the request on time but deleted a required signature by inadvertence, perhaps nunc pro tune could apply, but surely not here. 4
e documents.
Attached to this letter is a detailed summary of the facts disclosed by these sources, all of which arose since the construction permit was issued.
All of this information demonstrates quite clearly that the findings made in the original construction permit that there is reasonable assurance that TUEC will conduct its construction
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activities in compliance with the rules and regulations of the Commission (Finding 1.A) and that TUEC is technically qualified to design and construct the proposed facility (Finding 1.F) were erroneous.
In addition, contrary to the requirement of the construction permit, TUEC has not constructed Unit 1 in accordance with the principal architectural and engineering criteria commitments contained in the application and the hearing record for the construction permit.
All of the events which have transpired since construction was authorized and which are summarized in the attachment to this letter, if known at the time of the construction permit consideration, would have resulted in a denial of the construction permit.
In a closely parallel situation involving the Midland facility, the Atomic Safety and Licensing Appeal Board sent a letter to the then Director of Regulation strongly urging the suspension of construction of the Midland facility because, after final action on the permit application had been taken, it was revealed that "first line quality assurance inspectors were allowing items to pass their inspection which, in fact, did not meet applicable OA standards."
Letter from Alan Rosenthal, Jack Buck, and William Parker to L.
Manning Muntzing (11/26/73),
p.
1.
In that case only one area of plant construction, Cadweld splices, had been found deficient.
In the instant case,the Staff has concluded in SSER 11 (Appendix P, p.
P-35):
The pattern of failures by QA and QC personnel to detect and document deficiencies suggests an ineffective B&R and TUGCO inspection system.
This pattern, coupled with (a) the past problems in the document control system, (b) deficiencies in the QC qualification program, (c) ineffectiveness of the quality audit and surveillance systems, (d) a rudimentary and ineffective trending and corrective action system, (e) QC problems as shown in QA/QC Category 8, AQ-50; and (f) instances of improper workmanship of hardware found by all of the TRT groups, challenges as the adequacy of the QC inspection program at CPSES on a system-wide basis.
There, as here, the issue is whether an applicant is capable of properly implementing a OA/QC program.
The full text of the Appeal Board letter is attached.
Virtually every conclusion contained in it can be made in this case many times over.
Significantly, the Staff issued an order to show cause why construction should not be suspended in that case, and eventually Midland was abandoned because the utility 3
was incapable of building the plant properly.
In this case the argument for not allowing construction unless and until a new 3
We are not seeking a show cause order here because none is required.
In this case no lawful construction can be undertaken because no construction permit exists.
Thus construction cannot legally recommence unless and until it is authorized.
Whatever special discretion may exist under {2.206 is inapplicable where no permit has been issued.
The fact that TUEC did not keep track of its construction permit expiration date is symptomatic of its careless disregard for the Commission's rules and regulations and destroys any possible presumptions in its favor.
construction permit is issued is even more compelling.
C.
Significant Hazard Considerations.
Should the Commission treat the TUEC filing as an application to extend the completion date of the expired permit, it still would have to hold a hearing to determine whether to grant the extension.
Pursuant to $50.92 and 42 U.S.C.
$2239, a hearing is required on every proposed amendment to a construction permit involving a significant hazard consideration.
Allowing TUEC, which has had an abysmal construction record, to continue construction would jeopardize the plant by allowing incompetents to construct, reinspect, and repair components essential for safe operation of Unit 1.
In authorizing an extension of the TUEC construction permit in 1981 without making a significant hazard consideration determination and without a hearing, the Staff relied upon facts and circumstances which are not present here.
Thus, if the precedent of the prior decision is followed here, a finding should now be made that the proposed renewal of the construction permit does raise significant hazard considerations (i.e.,
whether TUEC is technically qualified and competent to construct a nuclear plant, whether there is reasonable assurance it will follow Commission regulations in conducting construction, whether it can and will implement a proper QA/QC program, and whether it can and will meet the architectural and engineering commitments it has made in the application, in the hearing record and to the Staff), that a hearing before tho ASLB should be conducted and that no construction should be allowed on Unit I unless and until
_a_
i it is authorized by the ASLB.
Unlike the 1981 extension, the present request for renewal is not based upon good cause.
Then the need for additional time was caused by factors allegedly beyond TUEC's control, such as delivery delays and regulatory changes.
Now the need for further time is a direct result of TUEC's failure to design the plant properly, to properly construct the plant, and to properly
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implement the OA/QC program.
These failures are detailed in Board decisions, in the TRT and SSER findings, and in TUEC's own description of the situation in its Case Management Plan and in its present filing.
The persistence of these problems is documented in past NRC and independent audits and in the disclosures and admissions from TUEC that even the current CPRT 4
and rework is not being properly conducted.
A significant portion of the work was done without a TUEC QA/CC program in direct violation of Appendix B.
Widespread use of illegal
" inspection quotas" has infected all of the reinspection and 4
TUEC alleges that all CPRT activities are outside the scope of its construction permit and thus it may pursue them irrespective of the status of its permit.
This outrageous view challenges thirty years of AEC/NRC practice and challenges the ability of the NRC to ever adequately regulate a nuclear facility.
TUEC intends to use the output of the CPRT to support its claim that the plant was properly constructed.
It has submitted the CPRT plan to the Staff for review and sought the ASLB approval of the plan.
It will eventually attempt to use the CPRT work as a substitute for the Appendix B requirements.
If the CPR7 is not within the scope of the permit, then all construction can be conducted outside the jurisdiction of the NRC and only the finished product submitted for approval.
The scheme of nuclear regulation is to assure NRC control of construction activities, including inspection of construction work, and the completed facility.
TUEC's attempt to evade NRC supervision of the CPRT is yet another manifestation of its disregard for both the letter and the spirit of the NRC regulations.
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rework efforts as partially conceded by TUEC spokespersons and found by NRC investigators.
Major deficiencies in the construction and rework of deficiencies found in the electrical 5
area have been revealed.
TUEC has conceded that the cause of this delay is not related to efforts to answer legitimate safety concerns but is a litigation device intended to be used for purposes of defeating
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contentions raised by CASE, which contentions TUEC deems to be without merit.
In its Opposition to " Motion to Compel Responses to CASE's November 15, 1985, Interrocatories" (1/27/86),
p.
18, TUEC states:
CPRT is, to state the matter again, the means by which the Applicants intend to present their case on the issues now before this Board.
The argument that CPRT is addressing itself to relevant non-litigation matters cannot be sustained.
This statement should be contrasted to the self-serving statement contained in TUEC's January 24, 1986, letter to Harold Denton (p.
1):
Physical construction on Comanche Peak Unit I was essentially completed in early 1985.
However, major efforts to reinspect and reanalyze various structures, systems, and components have been ongoing since the fall of 5
Although changes have been made in TUEC personnel since 1984, many key people still remain, particularly at the upper management level, at the level of Messrs. Brandt and Purdy and those supervisors working under them.
Moreover, recent disclosures about the conduct of CPRT and rework activities disclose that, while some faces have changed, the problems have remained.
lilegal inspection quotas, conduct of rework and CPRT activities without a TUEC QA/OC program, deficiencies in the records for cable tray supports, and other plant components and violations of confidentiality by and inef fectiveness of SAFETEAM activities demonstrate that with TUEC no matter how much things change they are still the same. __
1984 in order to respond to the questions raised by the NRC Staff's Technical Review Team ("TRT"), by the Board and parties in the ASLB operating license proceedings, and raised by other external sources.
The TRT was formed by senior NRC Staff management in March of 1984 to consolidate and carry out the various reviews necessary for the Staff to reach its decision regarding plant licensing.
Applicants formed the Comanche Peak Response Team and submitted a Program Plan to respond to the TRT's questions, the ASLB issues, and the other external sources issues.
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Which TUEC should the Commission believe?
Neither, since there is other evidence of nisstatements and misrepresentations by TUEC and its agents.
- See, e.g., Board Memorandum (Reopening Discovery; Misleading Statement), 12/18/84, pp. 1-2:
. we find Applicants' testimony [related to cinched down u-bolts] to be misleading, to reflect adversely on the credibility of Applicants' expert witnesses and to be cause for reopening discovery.
Board Memorandum (Reconsideration of Misrepresentation Memorandum), 11/25/85; In the Matter of William Dunham v.
Brown &
Root, Department of Labor Docket No. 84-ERA-1, Recommended Decision and Order, 11/30/84, finding as inherently untrustworthy witnesses certain key supervisory employees at the Comanche Peak facility.
Id.,
Slip op. p.
7.
Admittedly, at this point it is not possible to conclusively determine what is the motive for the delaying events which necessitate the requested renewal of the construction permit.
What is clear is that TUEC's averments are inherently subject to question, that the work which is delaying construction has been caused by TUEC's past blunders, and that any extension could not 6
be for a good cause.
D.
Hearing.
Although in this filing we make a substantial showing that the construction permit renewal should be denied, our prinary purpose is to establish beyond any question that significant hazard considerations are involved and thus a hearing is
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required.
The distinction between whether a significant hazard consideration exists and whether there is in fact a significant hazard which would warrant rejection of the proposed permit renewal is extremely important.
We are not now seeking a ruling on the latter issue at this time.
All that needs to be considered now is whether there are legitimate issues that relate to significant hazards, thus requiring a notice of hearing under 92.105.
It will be for the ASLB to decide whether the facts warrant rejection of the application.
We believe it is overwhelmingly clear that the Staff's own findings, not to mention all the other data and Board orders, disclose a very substantial basis for questioning the technical competence and commitment of TUEC to build a safe nuclear power plant.
The SSERs and Board decisions particularly identify safety-related components whose design or construction was improper.
Obviously, if an applicant cannot properly build a nuclear plant and if, as here, the findings that underlay the original construction permit 6
TUEC must accept direct responsibility for all of these blunders as the overall manager of the plant.
In the Matter of Texas Utilities Generating Company (CPSES), LBP-74-88, RAI-74-12, pp. 1047, 55, Finding 23.
Moreover TUEC has never indicated that anyone else is to blame.
are no longer valid, that is a significant hazard.
In such a case there is no choice but to grant the relief sought here by CASE, make the significant hazard finding, and notice the
. hearing.
CONCLUSION This request and its attachments are intended to be included as part of the record to be considered in making the decisions sought here.
In addition, the entire record of the operating license proceeding, the TRT, SSERs, and EG&G reports, all transcripts of meetings between Staff and any of the parties, all allegations received by the Staff related to Unit I construction and investigations conducted by the Staff into those allegations, all SAFETEAM investigations, all NCR and other deficiency papers generated with respect to Unit 1, and any and all other material in the Commission's possession related to Unit 1 are also to be included as part of the record CASE puts before the Commission 7
for its determination on these requests.
Should the Commission receive filings from TUEC or others relevant to the renewal request or this request, CASE wishes to be promptly notified and copied through its undersigned counsel and reserves the right to submit further data in support of its 7
The scope of the record of what the Commission should review in deciding whether a significant hazard consideration exists may be broader than the scope of the record in deciding whether to approve the application.
The latter is controlled by the parties and the rules of practice.
The former calls upon the Staff to use all knowledge available to it.
See Office of Communication of the United Church of Christ v.
F.C.C.,
425 F.2d 543, 46 (D.C. Cir., 1969).
position at any time.
As the foregoing discussion reveals, the issues relevant to TUEC's request for a permit renewal involve the same facts and issues as some of the matters now pending before the ASLB.
There, as here, TUEC's competence in constructing the plant is at issue.
There the question of competence affects the quality of what has been constructed.
Here it affects whether TUEC can be
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8 allowed to continue construction.
In both instances, the record will consist of the same underlying facts.
For efficiency, we propose the issues raised by TUEC's application and the issues in the OL proceeding be combined for hearing before the sitting ASLB.
8 The Commission decision, Washington Public Power Supply System (WPPSS No. 2), CLI-82-29, lo dRC 1221 (1982), defined the good cause requirement in the context of an intervenor seeking to relitigate safety and environmental issues disposed of in the i
original construction permit proceeding.
Unlike that case, we are looking at facts which could not have been previously litigated because they arose out of construction activities undertaken af ter the permit was issued.
In this case the proper
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issue for good cause is the narrow one defined by the regulation i.e.,
did TUEC cause the delay -- and the general issue of whether they should be allowed to continue to construct Unit 1 in i
light of their past performance in constructing it.
It would I
turn logic on its ear to conclude that the Commission could find good cause for the extension necessitated by the delay for which TUEC was responsible without looking to see if the TUEC responsibility arose from its own incompetence.
A utility whose i
cause for delay is its gross misconduct should have to reapply for a license having lost the presumptive validity of its permit.
To the extent CLI-82-29 is deemed in conflict with this analysis.
j we respectfully submit that it was in error and urge its
' reconsideration and rejection as applied to thin case.
F For the reasons given, we request that the relief be granted.
Respectfully submitted, (1
3 kedsh 690-ANTHONJ Z,.
ROISMAN BILLIE P.
GARDE
'4 Trial Lawyers for Public Justice 2000 P Street, NW, #611 Washington, D.C.
20036 (202) 463-8600 Counsel for CASE Dated:
January 31, 1986
' },,_ ' fi s,@;1 }/... y NrOMIC CNC!d.Y COMMI:.GION
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november 2c, 1973 i
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L. Manning Munt::ing Director of Regulation 4
l QUALITY ASSURA'!CC DEFICII:t:CICS EMCO'JUTERED t
AT MIDLAUD FACILITY The Appeal Panel recently received a copy
- of the l
November 13, 1973 "otification of an incident or occur-8 rence issued by the Directorate of Regulatory Operations j
in connection uith the Midland Plant, Units 1 and 2.
This notification relates to a Region III inspection of the Midland facility which took place on November 6-8, q
1973 and "identificci serious deficiencies associated with Cadwcld splicing of concrete reinforcing bars".
It is l
stated that "[t]hese deficiencies involved inadequate pro-i ecdures for inntaU ing Cadwold splices, for matcrial l.
control, and for documenting required quality parameters".
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In addition, the notification reveals that the inspectors dotcrained that " inspection techniques ucre inadequato and acceptance criteria used for quality requirements ucre heinc miSanr,liOd".
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.i.r t e n'.b d t o he a diplof.ditic. Jay of reporting that the first line j
quality assurance inspectorn ucre allouing itens to pass i
their inspection which, in fact, did not ncet applicable 8
CA standards, i*
The notification points out that Consumcrs Po.cr has suspended all Caduc]d splicing operations at the site and that those operaticas would not be rcuured until certain specified corrective action had bcon tchen.
It is further indicated, however, that "[ojther unrclated work uill continue at the site".
The !!idland construe: tion peruj t proceeding is, of course, no longer before the Appeal Board which had been assigned to it.
Indeed, the period or tir'e allott<F1 for Cocmission review cf the last,'.pcaal naard decision in the trocccding has nou clanced, uit.h the result t. hat there han iscen final agency action (whic'i is subject, of course, to the outcono W' 0 *M i '. !-..M...
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e of - the judicial review uhich in nou in progrer.s).
t ingly, the Midland Appeal Hoard c1carly lachs jurisdiction Accord-to take offE.GGognizance of the irregu]aritics dinclos d by the inspection, let alone issue any orders with respecte thereto.
s Honcthc1 css, the course of the adjudicatory prococding as uc11 a certain rulings which were made therein, the members o' the Midland Appeal Board fcc]
constrained.to record
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theiFci:t.remo dismay respecting this latcat devc1 cpi cat' and (2)
Consur. ors Poucr and its architect-engineer should b promptly considered.
i tion permit proceeding still been before our Board at theIn time that the results of the Novenbcr 6-8 insucction were j.
announced, it is a virtual certainty that oc vould have
-- to continue in effcct.at least until such t properly trained quality assurance inspectors pondent of the construction organization, ucre, fully inde-site.M have tal:cn that action.We shall bri,cfly outlino the reasons why we wouldav 1.
As you vill recall, in ALAD-106, RAI-73-3 102 (March 26, of one of the intervenor groups 1973), uc dealt specifically with th (the Saginaw Intervenors) is "inenpable of,that the evidence of record established that the applica adequate quality assurance and quality control".and cannat. hn r Midland sito perforced under an exception, uc made t Based express finding that "ncither the applicant nor the j
architect-engineer has provided reasonable assurance that the QA program vill be implcrented properly * *
- have in this project not der.onstrated their concern uith They maintaining OA programs in synchronization uith their con-struction programs, nor have they demonstrated that will have properly trained people on site to ir.iplement they OA program".
Id. at 105.
the led to this fiEding was the discionure in one inspectionOne of the report of record that "the OA and QC inspection personnel present at thc. concrete pour location did not promptly identity and correct apparent deviations f rom the ACI-301 Standard regarding consolidation of concreto".
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Manning Muntzing November 2G, 1973 s
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Decause of thc "no reasonable assuraticc" detcrmination found to be compelled by the record, we gave serious
, thought to revoking the construction permits which had l
been issued under the Licensing naard's authorization.
We did not do no only because (1) the prior failures of the applicant and the architect-engineer to obsc vc re -
quired CA practices'and procedures had occured in 1970
.(before the construction work under the exemption had 6
terminated); and (2) we had the solemn assurance of the applicant that all of those prior deficiencies were being rectified as construction was being resumed under the 8
' permits.
In the circumstances, we thought it would be enough to imponc specific reporting conditions which ucre designed to make certain that the applicant uns making j
good on its promise and that there vould be an adequate QA program for the resumed construction.
j On the basis of one of the reports called for by ALAN-106, and a number of inspection reports supplied by the staff in response to a later order of the Board (and a request of one of its mcabors), uc denied in ALAB-147, RAI-73-9 G3G (September 18, 1973), the motion of the Saginaw Inter-venors to revohc, or stay the effect of, the construction permits pending a definitivo determinatien that the Opplicent and the architect-argin - r.scro co.nsly.ing ar.d vould continue to comply eith the OA regulations in con-structing the Midland facility.
We found that "there is now a reasonable assurance that appropriate OA action is being taken by the applicant" and also that, apart from a deficiency which we perceived in its OA organir.ation, there was no QA problem pertaining to the architect-engineer requiring a direction of corrective action.-
Id. at G37, G40 (rn. 10).
2.
Against this background, our present concern should not be difficult to understand; _The only reason'able conclusion which we can draw from the disc 1ccurcs of the Hovember G-0 inspection is that the assurances which uc had received from the applicant ucre falso and that, in point of fact, it and the architect-engineer still have not manifested both an ability and a willingness to tche the steps neccccary to insure proper QA activitien.
- Indeed, the OA deficiency referred to in the notification bearn a startling resembl.ance to the deficiency referred to in ALAu-10G respecting the OA and OC personnel present ct the t
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It concreto pour location (ultich is mentioned abova).
that would thus appear, uith the bancfit of 1.indcight, it was not enough for us sini! y to inpose reporting 1
It alno seems evident t.h a t, con-conditions in ALI.u-106.
(which necess:ir; Ly was trary to our finding in ALAN-147 then before uc), there is not a founded on the natorials renconabic assurance that appropriate CA action is nou If anything, there is a solid assurance being taken.
that exactly the c>ppocito is the casc.
t'uo of the members of this Doard 3.
A.fcu uceks ago, requested and obtained a meeting uith you and several 4
other regulatory officials to cxplore the question of the
' architect-engineer is taken into account by the staf in o
its appraisal of applications for construction pcroits.
While that discussion uas wholly gencric and intentionally
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van not addrcsced to any specific rccctor, it obviously has a special significance to the precent situationIf we recall regarding Midland.
that the point might bc reached uhcrc the staff uould bc compelled to conclude that incorrigibilit.y wan involved, Whether or not we uould and then to act accordingly.
agree that a bad " track record" should come into p. lay thIL caso uctild seua
~-
unly in u uvia e>.Liu.ae cir vuim i.once u,What uc have here is a pattern of to r.cct your o.:n test.
flagrant and significant GA violations of a non-routine character -- coupled uith an unredeemed promise *
- repeated, f
of reformation.
The staf f has dealt af firmatively uith this.most recently
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i detected serious OA shortec:aing by requiring the prompt l
suspension of all Cadwald solicing.pending thc taking of But there remains the
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neccesary corrective action. unresolved question as to uhother
?
serious OA shortcomings may be infecting other aspectsIt is diffic j
f of the construction vorh. construction activity can *be allowed to proce I
how any unti M hat question is settled.
i I
Uc would make only this onc further obe,crvation.
i "ctaff's enforcc-4.
Uc expresuly noted in ALAG-10G t. hat thement renpo j
[ reporting) condition herein prescrib.ut, J-is frca to taka any renadial action over and nbnvc theccRAI-73-3 at 10 1
conditionc uhich it may deem necessary".
1 dn "hw,T. 3 -u. as c.;,.,
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t t
1 ep.
8
U F Flc!;1.1_ ti.w G F._i y i
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1, -
I. Manning Muntzing November 26, 1973
~ **
i
.'i Wo did,not (and, of course, could not appropriately) attempt to direct that, if a particular situation ucrc to arise, the staff should pursue a specific cournc.
Once the adjudicatory proceeding is over, the on-goinq super-vision of construction activitien is your function and and in the not ours'.
But implicit in that statcioent --
choice uc made not to revoko the construction permit --
l was the assumption that the staf f would not countenance
{
for long a continuation of the deplorabic OA perforcance j
which the record revealed had obtained during the con-3.,
struction work under the excr.'ption.
s.
,e If
((.L.
.8 12auJhdl
^
Alan S.
Rosenthal j.
c., cSWx.i/
.Tohn !!. Buck f
~
/
, d.,
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0,s../
. wad W Illiam C.
Parlcr Cor.issioner William O.
Doub cc:
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e e e gi%'.i. iH GKf Il
l *k..:. 3. hl) #f ATOMIC ENERGY COMMISSION b '
d bldL-wA w soTen,o.c. so m g$' D b A. f D:cemb:r 3,1973 Docket Nos. 50-329 1
50-330 Alan S. Rosenthal, Esq., Chairman John II. Buck. Esq.
Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Appeal Board
, U. S. Atomic Energy Commission U. S. Atomic Energy Commission Washington, D. C.
20545 Washington, D. C.
20545 I
William C. Parler. Esq.
j Atomic Safety and Licensing Appeal 9
Board U. S. Atomic Energy Commission Washington, D. C.
20545
}'
RE:
QUALITY ASSURANCE DEFICIENCIES ENCOUNTERED AT l
MIDLAND FACILITY Gentlemen:
This is in response to your'. memorandum on this subject dated November
- '- 26, 1973. ble are al:o concerned 2: : quality assure.nca impicmcr.tation I
J, at the f.lidiand facility. It was for this reason that we initiated the action which led to the shutdown of cadwelding at that facility by Consumers Power Company. As a practical matter, the shutdown of cadwelding at-this site severely limits Class I construction at the site in that cadwelding must be completed before additional Class I structural work can proceed.
4 i
A reinspection of November 20-21, 1973, reveale'd that that which the licensee believed to be sufficient with regard to cadwelding procedures ctill was inadequate. This raised doubts about the licensee's overall imple-mentation of its quality assurance program.
[~
We are today issuing to this licensee an order confirming the continuing suspension of the cadwelding and ordering the licensee to show cause why all activities under the construction permits should not be suspended.
i. Il I
l,
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- k 0
L. Manning Muo.t:ing Director of Regulatten e
^ - - -
4
)
APPENDIX B
{
SUMMARY
OF NRC INSPECTIONS AND INDEPENDENT AUDITS FROM 1976 TO J ANUARY 1985 In 1976 an internal NRC trend analysis of Comanche Peak stated:
During the early part of 1976, it became apparent to the principal inspector that the effectiveness of the licensee's OA/QC Program was in a state of degradation as a result of a domineering and over-powering control by the contractor's site construction management.
(NRC Trend Analysis 1976, Staf f Exhibit 184, p.
1, Hems 3, f,
and g) y In 1979 the NRC found that the QA/QC program was ineffective because the Applicant has been led down a poor path by Brown and Root during past years.
It appears to [the RRI] that Brown and Root has, in many instances, provided construction procedures to fulfill Appendix B that provide a minimum amount of direction to the construction force and yet comply to the words, if not the spirit of Appendix B.
What I have begun to see, but have difficulty proving is that the Brown & Root construction philosophy is to build something anyway they want to and then put tt up to the engineer to document and approve the "as built" condition.
If the engineer refuses, he is blamed for being too conservative and not responsive to the client's needs and thus the driving force behind my request for a special engineering audit of site operations.
Only recently has there been a real effort on the part of the licensee itself or on the part of Brown & Root, to write explicit instructions to the line inspectors on what they were to inspect.
Previously, the procedures were frequently pretty general, again not too bad if the inspectors were knowledgeable in the subject being inspected but terrible tf they are not.
In a couple of cases I have been able to show them that their people are essentially incumpetent, even though they have been through the site training and cartified as competent.
too often an installation clearly accomplished other than as originally designed and buildable has been approved the licensee's onsite engineering are as fulfilling requirements.
In effect, the engineer has approved a non-conforming condition in advance of QC being called.
QC has
_1_
been signing for the as-built condition and the underlying problem is not addrecsed.
(NRC Staff Exhibit,
- p. 2(f))
The report continues on page 3 about trends indicative of poor performance, It seems likely to me that the licensee will use his full powers to be less open with us in the area of identified construction deficiencies than he has in the past.
I think he will take maximum advantage of part 50.55(e) and the
[NRC] guidance to go through the necessary formalities but avoid, if at all possible, having to report to us.
(supra)
}
In 1980, the first annual Systematic Assessment of Licensing Performance report (IE Report $80-25, NRC Staff Exhibit 181),
continued to report problems with the QA/QC program, unqualified personnel, and attitude toward regulations.
The report concludes the following about the effectiveness and attitudes of licensing personnel in complying with NRC requirements:
Licensee construction and engineering management -- the NRC personnel stated that it appears there is a continuing tendency to engineer away construction problems rather than enforce compliance to drawings and specifications.
Again the Applicant promised to reform and correct its programmatic and personnel weaknesses by taking unspecific
" management action with the engineering and construction personnel to alleviate this situation."
(p. 5)
In 1981 Comanche Peak underwent a survey conducted by the American Society of Mechanical Engineers (ASME) in connection with obtaining an extension on Brown and Root's Authorization (N-stamp).
That survey failed to provide Brown & Root the sought-after extension.
Instead the survey team decided that a re-survey was required.
In a November 23, 1981 letter from ASME Manager of Accredidation to then QA Director R.J.
Vurpillat, the
-2_
following observations were noted.
(CASE Exhibit 590)
The deficiencies noted in your program in,clude, but are not limited to, the following items which require corrective action:
I.
Quality Assurance Manual (A)
The manual was vague, failed to establish required controls, responsibilities, or provide for objective evidence that required activities were satisfactorily performed.
(B)
The manual established the Summer addenda 1974 for
)
piping and Winter addenda 1974 for component supports as the Code effectivity.
The manual addressed activities only permitted by later Code addenda; such as NC-2610, NA-3867.4(f) and supply of material - NCA-3820(e), without any identification of the applicability of these provisions.
(C)
The manual control system did not include the exhibits displayed in the manual or any manual approval method.
(D)
The program elements of process control, nonconformity control and document control required significant changes.
(E)
The design control element (control) of field change design information and feed back of construction information to the Owner) was missing from the manual.
(F)
All elements required changes to provide definitive information since few auditable controls were included.
II.
Implementation (A)
Document Control - The manual requires that the File Custodians in each department ma intain a log of design changes received from the Owner.
The File Custodian is to mark the involved document to indiente that a design change had been received and then the document user checks the log to find the applicabl<
design change (s).
The log being maintained by the QA Department File Custodian contained numerous mistakes and was missing information.
Three of three design packages, chec<ed by the team, contained design changes not proper 13 identified in the log.
(B)
Instruction Procedures & Drawings - B&R Construction Procedure 6.9G, reviewed by the Site QA _
Manager, was in direct conflict with the QA Manual and the Code (NA-5241) in that it stated that the ANI would sign a blank process sheet and then D&R would add the ANI hold points.
The AIA representatives stated that this procedure was not honored by them and that they had requested the procedure to be revised.
The procedure has not been revised.
The~ purpose of the Site QA Manager's review is to assure that the procedure complies with the Code and the QA Manual.
(C)
Control of Purchased Materials, Items and Services (1)
Vendor Control - B&R procured plate material from a vendor that they had surveyed and qualified as a Material Supplier of bolting and plate materials.
The material had been formed into a saddle configuration by this vendor.
The B&R survey and qualification of this vendor did not address review of any operation relative to forming and the B&R purchase order did not define a forming process or procedure.
(2) 'The same material addressed in Cl was observed in the production shop with work in process.
This material had not been receipt inspected in non-compliance with the QA Manual and the material was not identified as required by the B&R purchi.se order.
B&R had divided the material and transferred the material identification incorrectly.
B&R does not verify the transfer of material identification and during the review of the manual stated that this verification was unnecessary. (et tasis added)
(D)
Control of Construction Processes (1)
Process Sheets were observed in production that had not been reviewed with the ANI for establish-ment of hold points in noncompliance with the B&R QA Manual and NA-5241 of the Code.
The process sheets CC-068-002-S33R and AF-035-023-S33A are included in this finding although numerous such process sheets are in production.
(See B above)
(2)
Welding Procedure Specification 11012 for welding wih impact test requirements did not specify the travel cpcod but instead controlled the heat input by Volt / amp range and maximum bead width for a given electrode diameter.
The Procedure Qualification Record 010AB127 for this WPA recorded a beam width greater than that allowed by the WPS.
(E)
Nonconformity Control - Nonconformity Control Report (NCR) M-2952 reported that a spool piece had been welded into the system backwards.
B&R QA t
determined the disposition to be rework and not repair and thereby the disposition to cut the spool piece out and reweld it in the correct configuration was not reviewed by welding engineering, as would have been required by a repair designation.
There appeared to be no consideration of the heat input effects on the material, etc. as would be expected with this type of nonconformance.
(F)
Identification and Control of Material and Items -
Component Supports are procured as stamped items by the Owner.
The Code Data Report does not list Code Case N-225.
The Component Support is supplied to B&R with only the Code Data Report by the Owner.
B&R then cuts
)
the component support, removing the welds, and uses the material to fabricate other component supports.
B&R does not have the Certificate of Compliance (C of C) for the material.
(G)
Authorized Nuclear Inspector Involvement - The ANI hold points on process sheets have been bypassed on numerous occasions.
The ANI logbook documents these conditions and the volume would indicate a significant breakdown of the program and interface between B&R and the Authorized Inspection Agency personnel (See B and D-1 above).
According to a Brown and Root interoffice about the ASME Resurvey team's exit interview held on January 20, 1982 (CASE Exhibit 604), ASME still found problems with the QA program.
That was confirmed by a letter from Hartford Steam Boiler to ASME dated February 8, 1982 (CASE Exhibit 605) which detailed three findings of the ASME Resurvey Team which required resolution.
Finding #1 of ASME Resurvey Team; consists of deficiency, proposed corrective action, and summary of verification of actual corrective actions taken.
[ Clearly shows B&R QA Program problems with vendor supplied items, although problem was supposedly taken care of after ASME identified problem.]
(CASE Exhibit 606)
Finding #2 of ASME Resurvey Team; consists of deficiency, proposed corrective action, and summary of verification of actual corrective actions taken.
[This finding is another indication whereby B&R procured items from a supplier not on the approved list.
The corrective action was to verify that the supplier held ASME N stamp and to then add them to approved suppliers list.
Again, raises questions about how many other vendor items were procured by B&R from non-approved suppliers that were not caught by either ASME or B&R QA program, neither of which are designed to catch each and every problem.]
(CASE Exhibit 610)
Finding #3 of the ASME Resurvey Team; consists of deficiency, proposed corrective action, and summary of verification of actual corrective actions taken.
Finding relates to welding materials received from vendor which were receipt inspected and accepted but not identified and documented as having had the receipt inspection.
[The material was scrapped (see CASE Exhibit 613).
However, as a result of this finding, it was necessary to retrain receiving inspectors in proper use of procedures.
Seems to be somewhat late in the game to be training inspectors in receiving inspections (Feb. 1982).]
(Case Exhibit 611)
The 1982 SALP reviewed the following noncompliances, during the 1981-82 review period.
The following deficiencies were identified by Region IV IE inspectors:
Personnel not properly trained and indoctrinated Failure to follow procedures for verification of the performance of automatic welding machines Failure to follow nonconformance procedures for electrical cable Failure to follow procedures for hoisting safety-related components Failure to update procedures Failure to provide appropriate instructions for installation of Class IE equipment Failure to follow welding procedures Failure to provide instructions and procedures appropriate to installation of Class IE battery chargers Failure to follow procedures for cable pulling Failure to follow procedures for reporting and repair of damaged electrical cable Failure to follow welding procedures Failure to follow electrical inspection procedures Failure to establish quality assurance program for Class 5 pipe support systems l
Failure to follow inspection procedure for returning l
inspection stamps Failure to follow inspection procedure to initial and date operations traveler Failure to report a significant construction deficiency (50.55(e))
Failure to follow construction procedures required by drawings In Spring of 1982 the CPSES Quarterly Report on QA Department and QA Program Activities for the First Quarter of 1982 (CASE Exhibit 620) reported:
(1)
The constant revision of the QA procedures and instructions prevented the QA/QC program from being adequately implemented and followed by management, QA/QC, and Construction personnel alike.
(2)
Internal, external, and vendor audits for the 1st Quarter of 1982 reveal deficiencies which have been recurring since the inception of the QA/QC program at Comanche Peak.
(3)
Trend evaluations performed on deficiency control documents reveal that recent trends in both construction and engineering type problems are mere extrapolations of past deficiency trends, indicating that corrective actions taken on previous deficiencies did not prevent recurrence.
On December 3, 1982, the second SALP report was issued which again noted deficiencies or violations in:
plant operations and preoperational testing, noting that tests were scheduled "6ut of sequence with con struction status, coupled with the lack of timely test procedure generation, are examples of lack of experience" (p. 4) failure to follow Quality Assurance Procedures for f
inspection of coatings (81-15) failure to perform inspections of installation acti-vities related to Unit 1 Containment Polar Crane (82-11) failure to properly indoctrinate and train personnel performing activities affecting quality (82-11) inadequate control of procurement document and __
k
purchased materials (82-03)
In October 1982 the Comanche Peak station received a Design and Construction Self-Initiated Evaluation, using methodology prepared by the Institute for Nuclear Power Operations (INPO).
That evaluation, transmitted to the Board on March 8, 1983, also contained numerous warnings about the failure of the OA/QC program.
O Construction procedures were observed as not being followed.
Construction personnel were observed bypassing steps of weld procedures.
This observation was performed on balance of plant work activities and not safety-related items. (p. 123)
Procedures do not appear sufficient to control construction activities.
It was noted that welding had been initiated on large bore piping attachments with water flowing through the pipe, contrary to welding procedures.
No construction procedure was found which would preclude this situation. (p.
127)
Uncontrolled drawings were observed being used.
Sketches had been made to assist in the modifications of vendor supplied items. (p. 129)
The Startup Support Group checks their records to determine the status of systems for which work packages are being released.
Hangers, however, are being treated differently and are being issued directly to the field without this review.
They are only aware of attachments when they noticed work being performed or a question arose.
Another instance of welding being performed on a turned over system was brought to my attention. (p. 133)
Several sketches had been made using the details in CP-CPM 9.13.
These uncontrolled sketches are used to provide the physical information required to correctly modify the transition kits.
Using uncontrolled sketches does not assure control of the processes used to fabricate these snubber assemblies. (p. 133)
Paper tags with no protective covering on them are used for calibration stickers and the duration between calibrations may allow for the dates on the calibration stickers to become unreadable and cause a tool to be used out of calibration. (p. 148)
The majority of activities evaluated under the performance objective was generally satisfactory.
However, the procedure for indoctrination and training of CPP engineers _ ____ _
is inadequate as it does not require or document formalized training in site procedures. (p. 198)
Comanche Peak Project engineers are indoctrinated by required reading of listed documents.
Any additional training is the responsibility of the CPP discipline engineers and is not documented.
The adequacy of the training of the engineers in the application of site procedures is questionable. (p. 199)
Current TUGCO-TUSI policy documents and procedures pertaining to training were reviewed.
There were no procedures available requiring and documenting the training of CPP engineers in site engineering procedures other than d
(p. 200) l Discussed Pipe Hanger Design with TSG supervisor.
There is no formal training to procedures / instructions / guidelines.
Supervisors require personnel to read documents. (p. 200)
S ampling of DCA's/ CMC 's indicate that " engineering / design error" is the reason for processing of the design change documents.
Such an approrach, of using general terms in identifying the error, prevents identification and trending of the root cause of the errors. (p. 226)
Three findings, included below, contain explanations by TUEC management which are illustrative of its dangerous management attitude.
Finding:
The TUSI engineering procedures / instructions define safety-related activities to be performed.
- However, Quality Assurance review and concurrence with these procedures / instructions is not required by the Comanche Peak Quality Assurance Plan.
Response: We agree with the finding.
Our experience leads us to believe that this is the best approach for the following reason: Quality is designed and built into a plant - not "QA-d" into it.
In our system, each functional group is responsible for developing a working knowledge of the requirements and commitments that apply to their activity.
Each group is responsible for developing and establishing procedures that not only address requirements and commit-ments, but also serve as management tool to accomplish activities uniformly.
TUGCO QA verifies through timely audits that the above described system results in a quality awareness and places responsibility on the people who are doing the work.
This verification by TUGCO QA is accomplished by assuring that procedures /instructicns are adequate and _ _ _ _ _ _ _ _
effective.
TUGCO QA also assures that they contain proper controls and that they are consistently implemented.
Finding:
When reviewing CP-EP-6.0, Preparation of Engineering Procedures and Instructions, it appeared that TUCGO QA does not review site engineering procedures / instructions.
Response: In various discussions with the Site QA Manager and the QA/QC Supervisor, the following was noted:
TUGC0 audits include review of engineering procedures, as well as technical audits.
Iloweve r,
8 in accordance with TUGCO corporate policy, QA review of site engineering procedures / instructions is not required. (emphasis added)
Finding:
The procedure for DCA/ CMC's does not require formal inter-disciplinary review at the site.
There is the possibility that two or more disciplines could issue design change requests for the same problem area; i.e.,
the procedure does not require interdiscipline review of DCA's/ CMC's.
Response: We agree with the finding.
However, our experience has indicated that the after-the-fact design review performed at New York provides adequate assurance that no problem of safety significance will remain unresolved.
(pp. 220-222)
In late 1982 a special NRC Construction Appraisal Team (CAT) also identified significant deficiencies in the QA/QC program.
In its report, released April 11, 1983 (Staff Exhibit 206), the team identified the following construction program weaknesses:
1.
Results of the inspection indicated a breakdown in fabrication, installation, and inspection in the heating, ventilation, and air conditioning (HVAC) systems.
2.
A number of examples were identified of failure to meet criteria for separation of safety-related cables from mechanical structures and piping, and separation of redundant trains of safety systems....
3.
The licensee's quality assurance program did not ensure that certain hanger, support, electrical and mechanical equipment was installed to the latest design documents, and commensurately that an appropriate inspection was _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
conducted to the latest design documents.
4.
Findings also indicate a number of instances where nonconforming conditions were identified; however, various methods (e.g., punchlists, inspection reports, verbal, and other informal methods) were used to address and resolve these nonconformances.
These methods do not comply with requirements to identify nonconforming conditions and provide corrective actions to prevent recurrence.
5.
The licensee's Quality Assurance audit program should have been more effective in detecting and obtaining correction of deficiencies in safety-related work; such as those in the HVAC system, mechanical equipment, and electrical components.
In summary, the identified weaknesses require increased dedication by management at all levels to assure completed installations meet design requirements and that inspection documentation reflects that the completed installations have been adequately inspected to the latest design document.
On September 13, 1984 the Technical Review Team issued its first of three reports into the " allegations of improper construction practices at the facility." (p. 1)
This report covered the areas of electrical / instrumentation, civil / structural and test programs.
This report provided the utility with a confirmation of allegations that:
- 1) electrical quality control inspectors were not aware of certain inspection attributes for witnessing the installation of " nuclear heat shrinkable cable insulation sleeves 2) inspection reports didn't contain the " witnessing" attribute for splice installation 3) lack of cable splice qualification requirements and circuit operability 4) drawings and "as-built" cable terminations are in disagreement 5) improperly closed NCRs on vendor-installed GE motor control centers 6) violations of minimum separation requirements for safety-related cable within flexible conduits 7) violation of minimum separation requirements between l
safety and non-safety cables 8) no requirement NRC review of separation criteria has been performed 9) violation of separation criteria inside control panels 10) inconsistent support installation for non-safety related conduits with seismic requirements 11) lack of verification documentation for electrical OC inspections 12) totally compromised testing and certification programs for QC inspectors 13) omission and unauthorized cutting of rebar from reactor cavity 14) unauthorized cutting of rebar from the fuel handling building 15) questionable concrete strength tests 16) questionable " air-gaps" between concrete structures 17) inadequate control room design (seismic) 18) inadequate, incomplete, and unreliable heat functional test procedures 19) unreliable CILRT results 20) use of unqualified craft personnel to perform start-up tests.
On November 29, 1984 the TRT issued its second of three reports into their investigation of allegations in the mechanical and miscellaneous areas.
They foun'd that:
1)
No fillet weld inspection criteria existed for certain types of skewed welds.
although the small sample of welds inspected by the TRT are acceptable, due to deficiencies in inspection records and the apparent lack of inspection criteria, the TRT is not certain whether other type skewed welds were inspected properly.
This is a generic issue involving many NF supports in various safety-related systems." (p. 2) 2)
No evidence existed that anchor bolts were properly installed, and not cut.
"The TRT concludes that such unauthorized bolt-cutting and lack of installation inspection records is a violation of Criticism XVII in Appendix B of 10 C.F.R. 50 and General Design Criterion 1 of 10 C.F.R."
(p. 2) 3)
Piping systems (Main Steam, Aux. Steam and Feedwater) are routed from the Electrical Control Building (seismic Cat I) to the Turbine Building (non-seismic Cat I) without any isolation.
3 4)
Uncontrolled repairs (plug welds) of holes in pipe supports, cable tray supports and base plates (confirmed in cable tray supports, Unit 2).
"Although the effects of unauthorized, undocumented and uninspected plug welds in some locations... will be inconsequential, their effect in critical locations in critically located supports or base plates could affect their structural integrity and intended function." (p. 4) 5)
"... inadequate requirements and construction practices for the support of the main steam line during flushing, and for temporary supports for piping and equipment in general.
In particular, evaluations to assure the adequacy of temporary supports during flushing and installation were not required.
The deficiencies in the analyses, specifications and construction practice identified above constitute a violation of Criterion V of Appendix B to 10 C.F.R. 50."
(p. 5) 6)
"... a design change in the RPVRI support ring (i.e.
locating the ring outside rather than inside the insulation) resulted in a limited clearance between the RPVRI and the shield wall.
The TRT review of the 50.55(e) report revealed that TUEC failed to (1) address the fundamental issue of design change impact on annulus cooling flow, and (2) determine whether Unit 2 was similarly affected." (p. 6) 7)
Polar Crane bracket and seismic connections exceeded design requirements.
Finally, several weeks ago the Technical Review Team released a 25-page sumiary of its findings which, according to the January 8 repo) t., indicates:
A.
TUEC failed to periodically assess the overall effectiveness of the site QA program in that there have been no regular reviews of program adequacy by senior management.
Further, TUEC did not assess the effectiveness of its QC inspection program.
B.
During the peak site construction period of 1981-2, TUEC employed only four auditors, all of whom had questionable qualifications in technical disciplines.
Although charged with overview of all site construction and associated vendors, these Dallas based auditors provided only limited QA surveillance of construction activities.
C.
Repetitive NCRs were issued that identified the need to retrain construction personnel in the requirements and contents of QA procedures.
One corrective action i
request (CAR) dealing with inadequate construction training and records remained open for one year.
The identical problem was identified in a subsequent CAR, which still had not been closed at the time of the TRT's onsite review.
D.
The TRT found many examples of incomplete and inadequate workmanship and ineffective QC inspection in TUEC's evaluation of the as-built program.
(See Section 4 for a detailed discussion.)
E.
Some craft workers newly assigned as QC inspectors were in a position to inspect their own work and records.
Site management did not view this lack of separation between production and inspection roles as a potential conflict-of-interest.
F.
There were potential weaknesses in the TUEC 10 CFR 50.55(e) deficiency-reporting system.
Applicable procedures did not identify what types of deficiencies constituted significant breakdowns in the QA program, nor how they should be evaluated for reportability to the NRC.
Evaluation guidelines for reporting hardware deficiencies lacked clarity and definitive instructions and the threshold for reporting deficiencies was too high.
G.
The TUEC exit interview system for departing employees appeared to be neither well structured nor effective, as evidenced by the lack of employee confidence, limited implementation, failure to document explanations and rationale, and failure to complete corrective actions and to determine root causes.
H.
The B&R corrective action system was generally ineffective and was bypassed by the B&R QA Manager.
I.
The TUEC corrective action system was poorly structured and ineffective. _ _ _ _ _ _ _ _ - _ _ _ _ _
Additionally, in 1978 the Management Analysis Corporation (MAC) conducted an audit of the Quality Assurance program of Texas Utilities Generating Company to determine the adequacy of the program as related to the NRC's requirements and the effectiveness of implementation to meet program requirements.
The scope of the audit included commitments made in the PSAR, the corporate QA manual, the project procedures manual, and the Brown & Root QA manual and procedures related to the Comanche Peak site.
Their findings, including a finding that as late as 1978 the QA program did not conform to Appendix B requirements, are included in their entirety as further evidence that the terms of the construction permit were not complied with. (Exhibit B-1) 0
.1 5 -
ADMISSIONS BY SPOKESPERSONS FOR TUEC (OR AS CONTAINED IN DEFICIENCY REPORTS, NCRs, OR OTHER TUEC-GENERATED DOCUMENTS)
December 18-19, 1985, Meeting between NRC and TUGCO regarding breakdown in the Unit 1 cable tray as-built program and status of CPRT program plan activities:
The NRC inspection of the Comanche Peak Unit 1 cable tray as-built program was discussed first.
The purpose of this inspection was to I
verify the accuracy of the as-built data developed by EBASCO which would be used in their reanalysis of the cable tray supports.
T. Westerman (NRC) presented a summary of the findings identified in the November 18-23, 1985 inspection.
Out of 32 cable tray supports inspected, the independent NRC inspection team found 19 supports which had discrepancies.
W. Counsil (TUGCO) then presented a summary of the actions, and the consequential findings, taken by Texas Utilities after being informed by V. Noonan (NRC) on December 3, 1985 of the NRC inspection results.
The first action was a stop-work order; the second was to develop a sampling program.
This sampling program was to confirm the NRC findings and to insure that this problem was confined to Unit 1.
TUGCO's preliminary findings identified that there are deviations from the as-built program on Unit 1 and that the problem is confined to Unit 1.
W. Counsil said that the results from an investigation he ordered indicated that a supervisor had reinterpreted work procedures to eliminate double-checking of inspection results and that the supervisor had placed production quotas on inspection teams.
January 13, 1985, Summary of Meeting Held on December 18-19, 1985 re Discussion of Comanche Peak Unit 1 cable tray as-built program anu status of CPRT program plan activities.
Similar problems have been discovered by the staff in other areas of the plant.
Additionally, the record produced through discovery and investigation confirms that a major breakdown in compliance with federal and/or corporate procedures occurred during the life of construction.
See, generally, record of recent 50.55(e) reports, significant design adequacy review reports, nonconformance reports, and all other identifications of deficiencies.
)
FINDINGS AND CONCLUSIONS OF STAFF INVESTIGATIONS OF ALLEGATIONS BY FORMER WORKERS AT UNIT 1 AS DETAILED IN THE SSERS; AND THE EG&G FINDINGS Five Supplemental Safety Evaluation Reports have been issued since January 1985 which detail the findings and conclusions of the NRC's Technical Review Team into allegations provided to the TRT by allegers.
SSER #7, which deals with electrical and instrumentation issues, SSER #8, which addresses miscellaneous quality and hardware issues, SSER #9, which deals with protective coatings allegations, SSER 410, which addresses mechanical and piping concerns, and SSER #11 on QA/QC allegations.
The significance of the TRT's findings is demonstrated by the conclusions of the QA/QC Group regarding the implementation of the QA/QC program approved by the original FSAR.
The summary, pages P-27 to P-35 of SSER #11, are attached in their entirety.
The undeniable conclusion of the TRT's findings is that the QA/QC program at Comanche Peak failed over the life of construction. (Exhibi t B-2)
In September 1985 the EG&G issued its supplementary report into the alleged climate of intimidation.
The supplement, while only reviewing a selection of the harassment and intmidation incidents pursued during the licensing case and none of the incidents of harassment of craft personnel, engineering personnel, or auditors, still reached the conclusion that some incidents of harassment had occurred.
The report concluded:
In summary, a number of managerial practices exist which, while not intimidating, may not have been conducive to good job performance.
The job skills of inspectors may 19
have been negatively impacted by poor communication with their supervisors, inadequacy in their job training, and infrequent feedback on performance.
Some evidence exists that inspectors were asked to perform tasks without adequately understanding what was expected or why the work was performed.
Difficulties in dealing with crafts were apparently accepted rather than managed, with little attention devoted to fostering more cooperative working relationships.
A lack of clarity prevailed regarding appropriate employee interfaces with the NRC.
The general lack of supervisory j
attention to the human dimension may have generated mistrust, suspicion, and some lack of credibility with employees.
10
SUMMARY
OF PRELIMINARY DECISIONS OF THE ATOMIC SAFETY AND LICENSING BOARD On December 28, 1983, the ASLB issued a Memorandum and Order (Quality Assurance for Design) which contained the Board's initial conclusions on the question of the design adequacy of Comanche Peak.
The Board stated:
The record before us casts doubt on the l
design quality of the Comanche Peak Steam l
Electric Station (Comanche Peak), both because the Texas Utilities Generating Company, et al.
(applicant) has not demonstrated the existence of a system that promptly corrects design deficiencies and because our record is devoid of a satisfactory explanation for several design questions raised by the Citizens Association for Sound Energy (CASE).
We suggest that there is a need for an independent design review and we require applicant to file a plan that may help to resolve our doubts.
On October 2, 1985, the Board stated in a Memorandum and Order (Applicants' Motion for Modification) that nothing subsequently presented to them in the record since December 1983 has detracted from the conclusion reached above.
20
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NUREG-0797 Supplement No.11 7
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' E,7_5 SidGty Evaluation Report an reimed..to the operation of c
C6nianche Peak Steam Electric Station, Units 1 and 2 DockgBo(5). 50-445 and 50-446
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U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation May 1985 AA Af%
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._ m 4 QA/QC CONCLUSIONS specific areas in Section 2 and in the tables in Attachment 1 a
reflect the findings of Appendices 0 and P.
The conclusions Section 4.9 presents the QA/QC Group's conclusion regarding the QA/QC issues reviewed by the TRT at Com Peak.
4.1 Desion Process Wk The assessment of design process generally focused on a review of control o changes to design documents, principally vendor designs, incorporation of fie t
changes in the design, and design interaction with plant organizations
~
the QA/QC point of view, the TRT finds that the design process for C From Peak is based on procedures consistent with NRC requirements and that thes omanche procedures were implemented.
Actual design process performance, however, dis-e played some deficiencies.
Design changes (DCAs and CMCs) were permitted to accumulate against basic design documents with no program requirement for the timely incorporation into the drawings.
delays previously experienced. quicken the incorporation of changes and to The TRT found examples of ineffective interaction among the engineering 4
struction, and quality control groups that was evident because of incomplete or
, con-inadequate work instructions for the craft personnel, design acceptanc tionable construction practices, inadequate design analyses of field cha e of ques-and incomplete seismic analyses.
- nges, poor in judgment, lacking in analysis and in technical depth.NCR dispositions by e Because a basic premise in designing a piping system includes the fact that support designs will reflect the assumptions made in the analysis of that pip-ing, the failure of the design process to require Gibbs & Hill to revi signs and modifications of pipe supports prior to fabrication and installation ew de-is of concern.
documentation (see SSERs 8 and 10).There were instances of failure to co of changes to the FSAR (see SSER 10). There was also failure to notify the NRC Within the scope of TRT QA/QC Group's assessment of the design process interactions among the engineering, construction and QC groups, the deficiencies presented, appear to be the only deficient are
, and program TUEC.
in future SER supplements dealing with the NRC's review of findings fro CYGHA Independent Assessment Program.
m the
- 4. 2 Document Control The TRT assessment of the document control function for the period following July 1984 indicates that the preparation, issuance and changes to documents that specify quality requirements or prescribe activities affecting quality a adequately controlled.
and in the field where prescribed activities were being performed, were re to be complete and current.
Further, a sample of safety related quality Comanche Peak SSER 11 P-27 l's
]
~
7F Th<
records stored in the permanent plant records vault (PPRV) was reviewed and no found to be acceptable.
Included in the documentation packages were completed te records for piping, piping supports (hangers), assembled and/or installed con-rea ponents, fabrication and inspection / testing data, including walkdown inspection an check lists and the applicable N-5 data reports.
In process and final inspec-mon tion and acceptances for completed record packages appeared to have been per-
' formed to the latest revision of drawings and specifications.
Th@
no l
However, the history of recurring document control deficiencies prior to the l
July 1984 raises concerns about certain aspects of the quality of construction.
}
For example, the TRT observed deficiencies in coating inspection reports which 6!.R
/
included:
inadequate description or location of areas or items coated; improp-met er changes and corrections; lack of signatures or acceptance for inprocess anc the:
final inspections; and missing dates and times.
These deficiencies were sig-to 9 nificant enough to render the inspection reports unacceptable as quality botE records and inadequate to provide documentation of material traceability.
One the specific traceability and records problem was that paint mixing slips were not pers retained as permanent records, but were discarded after the inspector in the rule coating applications area transcribed the information onto his own report.
Thus, the original record of the mixing inspection, including inspection accep-The tance, was lost.
In procedural control, the TRT mechanical and piping group inag observed that uncontrolled and unauthorized procedures were used to perform cold-springing (realign piping) during its installation.
The guid
~
j#fth respect to draw:ng control prior to 1984, the TRT found deficiencies that pote 4
included:
distributic n of incomplete or obsolete drawing packages to the craf t orde and QC personnel; inaiequate drawing control; high CCC satellite error rates, 1
/
and procedural non-cc.npliance..Tne TRT QA/QC Group concludes that although
- 4. 4 many of the document control inadequacies have been corrected, the implicatic,s of past inadequacies on construction and inspection nave potential generic sig-The p N.nificance which has not yet been fully analyzed by TUEC.,
p race
- as - -
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recue
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or cc 4.3 Training and Qualifications The TRT QA/QC Group found a pattern of inadequacies ~ith the training, certifi-(1) cation and qualification program at CPSES, because of the many deficiencies identified.
These problems can be directly traceable to TUEC's and B&R's " min-imal requirement" training, certification, and qualification program; the fick (2) of or failure to follow procedures and guidelines; and a lack of programmatic controls to assure that the program achieved and maintained requirements as set (3) forth by 10 CFR Part 50, Appendix B.
The TRT Electrical and Instrumentation, Protective Coatings, and Civil and Structural Groups also assessed allegations and concerns about electrical in-(5) ;
These inspectors were l
spectors, coatings inspectors, and concrete inspectors.
all trained, certifici, and qualified under the same program (non-ASPE) as the (6) r y
inspection personnel reviewed by the QA/QC Group.
Each TRT group found exam-o no verification of education or work ples of the same kinds of deficiencies:
experience; an identical certification test taken af ter the examinee f ailed tre
( 7) E for 0JT; no time limit first one; no guidelines provided for the use of waiver and inspectors with ques-rne r3 on how many times an examination could be retaken; p roper tionable qualifications.
Ccmanct Comanche Peak SSER 11 P-28
~
-,,,7 There were also many problems with the certification testing program f k
non-ASME inspectors.
test, there were different scoring methods to grade the origina or the j
j and there were no details on how the administration o s and the an a
ed, monitored.
no prior background or experience in inspection.The TRT als pection had the coatings area when painters were made " instant" QC paint iThis was espec n.
nspectors.
met the requirements of ANSI N45.2.6 and Regulatory h
p-minimally h
these guidelines were not always followed.
, but in practice to follow the requirements set forth in ANSI N45 2 6 and ReAlthough TUEC and B&R both chose to follow the " exception to the rule" and used "othegulatory Guide 1 the normal method of qualification.
e r factors" as personnel (both ASME and non-ASME) were qualified under the "excep t
rule" factor.
on to the The TRT QA/QC Group also found that some QA auditors lacked experie p.
inadequately trained, or had questionable qualifications.
nce, were The TRT QA/QC Group concludes that deficiencies in procedural requirem guidelines in TUEC's training, certification, and qualification programs ha ents and t
potential quality significance.
Further evaluation by TUEC is required in ve ft order to determine the impact of the deficiencies on the safety of the proj 4.4
_ Construction and Testing ns g-The tables in Attachment practice which were considered to be deficient.to Appendix P indicate those items of construction or contributing factor and had a plant wide impact. recurring prac mary i-(1)
Craf t personnel failed to follow design documents or installation procedures.
n-k (2)
Unauthorized work was performed in absence of procedures.
et (3)
Housekeeping procedures were not followed.
(4)
Use and return of equipment, tools, and materials were not per requiremen (5)
There was loss, damage, and interchange of valve parts.
Y2 (6)
There was improper transfer of heat numbers onto scrap metal which was used in a pipe support.
(
th2 i.
(7)
Equipment repairs and rework were performed without proper documentation.
It Th2 fact that the TRT found these recurring practices indicates a lack of proper first-level supervision.
Comanche Peak SSER 11 P-29
I In conclusion, these types of improper workmansnip by craf t personnel, coupled I
with lack of proper supervision of craf t personnel during construction, have potential for significant quality and safety impact on critical plant systems and structures.
For several entries on the tables in Attachment 1 to Appendix P, there were allegations or concerns involving construction practice that were neither sub-stantiated nor refuted.
These were not included in the above conclusion, but are unresolved QA/QC issues.
The T There were only two entries on the tables in Attachment I which involved the ports area of testing.
Both of these entries indicated that the deficient practice forms was not frequent enough as to imply a generic problem.
One concern involved tive
)
several hot functional test objectives that were not met.
The other deficient practice was that TUEC's method for calculating leak rate was not consistent In co with TUEC's FSAR commitment.
scme and T 4.5 Nonconformances and Corrective Actions appli.
The TRT QA/QC Group identified deficiencies during its overall review of the 4.6 (
nonconformance system.
Most of the deficiencies related to implementation of
~
the NCR system in specific areas; for example, coatings NCRs that were dispo-fhe tt sitioned "use-as-is" lacked sufficient engineering justification (Protective siders Coatings Category SA), and some instances were noted in the Mechanical and inspec Piping area in which NCR corrective action was not considered to be satisfacto-impact ry.
There was also an instance of the use of pieces of nonconfortring pipe wnite are ei on NCR hold.
Improper disposition of the NCR allowed the installation of the entrie pipe (Mechanical and Piping Categories 13 and 20).
- items, quent The TRT also noted a generic deficiency in the corrective action system.
Some above of the specific deficiencies noted are:
cient made s a.
The B&R corre.:tive action system was generally bypassed, as shown in the inspec following examples:
tion /t (1) There were no definitive instructions to describe the types of prob-As desi lems that required corrective action.
Minimal procedural instruc-the tat tions resulted in corrective action decisions frequently being left design to the judgment of the QA Manager.
potent-erly re (2) Since June 1983, B&R had issued no corrective action requests (CARS),
inaccur and was substituting memos and letters of concern for this function.
in the This shortcut had become a regular method of operation and appeared Group c to bypass the CAR system.
in moni signifi b.
The TUEC corrective action system was poorly structured and ineffective in that:
- 4. 7 Au (1) Controlling procedures were brief and general.
In the evaluat (2) There was no translation of FSAR requirements on trending and no de-view th tails on how trend analyses were to be accomplished.
tified (3) Quarterly reports were not issued in a timely manner.
Comanche Peak SSER 11 P-30 Comanch.
^
x
(4) The method of categorizing irs and NCRs by building did not assure meaningful trend analysis.
(5) A 1984 CAR report identified three items that appeared to require action; however, none had been taken.
(6) CAR 029 was used as a vehicle for a specific disposition rather than for generic action, as intended by the CAR system.
The TRT QA/QC Group also noted that approximately 40 dif ferent forms and re-ports (other than NCRs) were used for recording deficiencies.
Many of these forms and reports did not appear to provide information entry into the Correc-l tive Action System to prevent problem recurrence.
i t
In conclusion, the QA/QC Group found deficiencies in NCR implementation; and in some cases NCR corrective action was unsatisfactory.
The QA/QC Group found 8&R and TUGCO's corrective action systems poorly structured, inef fective, and poorly applied.
- 4. 6 QC Inspection The tables in Attachment 1 indicate those items of QC inspection that were con-sidered to be deficient.
Of particular concern were those items for which QC inspection was indicated as being primarily responsible and having a generic impact level of 4 (frequent occurrences tnat have plant wide impact).
i-There are eight such items in the tables.
le Of lesser concern were the 27 additional entries that indicated QC inspection as a contributing factor for lesel 4 items, or as either a primary or contributing factor for level 3 items (fre-quent occurrences, but apparently confined to a particular area or ittm).
The above 35 items indicated to the TRT that QC inspection was particularly defi-cient in the areas of coatings and mechanical hardware, and that QC in:ipectors made significant errors in a number of additional specific items.
Further, QC inspection problems are generally accompanied by and associated with construc-tion / testing problems (see Section 4.4).
As described in more detail in the individual assessments listed for entries on the tables in Attachment 1, QC inspectors in many instances failed to follow design documents and the quality procedures for inspection.
Of concern is the potential for critical installations to be inadequately constructed and improp-erly represented on documents in the plant permanent records vault as well as inaccurate accounting of safety-related systems and structures for input used
),
in the stress analyses by the engineering group.
In conclusion, the QA/QC Group considers the site QC inspection program to be less than fully ef fective in monitoring, detecting, and reporting deficiencies that have or could have a significant safety impact on the plant.
in 4.7 Audits and Reporting In the T'tT's overall assessment of TUEC's audit program, emphasis was placed on evaluating the administration of the audit program, management's action to re-view the status and adequacy of tne QA program, and followup on findings iden-tified by internal (TUEC) and external audit teams (NRC and consultants).
Comanche Peak SSER 11 P-31
I I
TUEC's audit program consisted of internal and external audits of design struction, engineering, and procurement activities.
, con-2 bility for external audits of vendors.
TUEC assumed the responsi-C b
Region IV found that TUEC's audit procedures did not comply with NRC require-1 ments, and that the program was not implemented in accordance with procedures.
I t
4 The lack of an established audit program was also substantiated by Region IV S
For example, Region IV Report No. 50-445/84-32 lish and implement a comprehensive system of plar.ned and periodic auditscite t!
compliances identified were:
Non-at annual audits were not adequately addressed by audit implementation procedures; planning and staffing to perform 1983 audits were inadequate; the Westinghouse site organization performing Nuclear Steam U
Supply System (NSSS) engineering services was not audited by TUEC from 1977
- F through 1981; and audits of vendors that manufacture or fabricate parts 84 3
ance with annual or other applicable requirements dating compo-f dS Assessments by the Miscellaneous and Mechanical and Piping Groups concurred IS' l
ANSI N45.2.12 requirements.with the QA/QC Group that the audit frequency o Wit
{
th' 1981 and 1982, the height of construction, the audit staf f fot Lgb auditors.
From 1982 to 1984, the audit staff has increased from 4 to 12.
fin i
Also, on occasions, individuals participating on the audit teams were not QA
!.e auditors.
As such, a potential existed to compromise thei,- independence.
'"9 TRT reviewed the technical background, experience, anc training of auditors The sgol well as the quality of audit reports.
II*~
, 3s l
. qualifications to be questionable, which rendered the audit results for 198 sun through 1983 potentially ineffective.
pres
- d t The T9T and Region IV reviewed the scope of the QA program audited during 198
M Of approximately 650 safety-related procedures, 165 (25% overall) were audited (OII In looking at quality procedures, TUEC audited 24% of TUGCO's implementing pro cedures and 39% of B&R procedures for a composite 32% audit rate.
9"3" audits on a sampling basis are acceptable, there was no evidence that allAlthough (Cont safety-related areas were audited.
d"d 5 the QA program in order to determine effectiveness.The audits did not encompass all asp The r progr With respect to audit corrective action followup, it was learned that TUEC QA eftec had not been verifying that corrective action on previous audit findings was resob
{
@ pr, accomplished.
For example, audit TCP-111, initiated to verify corrective ac-tions on previous audit findings, was started prior to the TRT's review.
I TUEC Ouring emphasized that TCP-111 be considered a " Punch List of Completion Tasks" to verify that corrective action had been implemented and not an attempt to re.
the at write or change previous audit findings.
effect Another specific example of inef fec-
- d*PI tive followup action was found that pertained to a deficiency identified in for 10 audit TCP-23, performed in September 1981.
Audit TCP-68, conducted in March 305 wh 1983, attempted to verify corrective action of TCP-23's audit finding, but logs that would document the corrective action had been destroyed.
d"d dC' was written at that time and the response was accepted, but the corrective ac.A new deficiency tion implementation is still unverified.
Based c reporti ficant In correlating nonconformance reporting to the audit finding / corrective action during reporting tracking system, the TRT noted that during 1983, 18 NCRs identified tivenes-Comanche Peak SSER 11 P-32 Comancn.
B _-
the need to retrain construction personnel in the content and requirements of QA procedures.
The TRT found that TUEC corrective action request CAR-024, which dealt with inadequate construction training and records, was open for 12 months.
training of construction personnel.Af ter. CAR-024 was closed, five other CARS identi The TUEC construction, startup/ turnover 1984, which had not been closed at the time of the TRT inspectio audit findings.ther supports the TRT finding of inadequate followup and corrective action of This fur-and adequacy of their QA program.The TRT found that TUEC management h TUEC representatives stated that there have been no regular assess-84-32).
ments or reviews of the adequacy of the total QA program by upper management as required in Criterion II of 10 CFR 50, Appendix B, and as committed in the FSAR.
With respect to follow up corrective action for previous findings cited against the audit program by NRC and TUEC consultant audit / inspection teams found TUEC's corrective action followup to be not fully effective.
, the TRT Lobbin Report (a TUEC consultant), dated February 1982, identified four major The Fred findings:
i.e., commer(cial nuclear plant design and construction QA expe ing for the audit and surveillance functions is inadequate; (3) the number and staff-scope of design and construction audits conducted by TUGC0 QA to date has been limited; and (4) QA management has not defined clearly the objectives for the surveillance program resulting in a program which, in the author's opinion "is presently ineffective."
quately addressed by TUEC.To date, findings (2), (3) and (4) have not been ade-(Region IV Report No. 50-445/84-32.)
Following the Lobbin Report, the NRC performed a CAT inspection (IR 446/83-12, dated April 11, 1983) 445/83-18; and included a review of the TUGC0 audit pro-gram at the corporate offices.
The inspection included a review of 18 audits (conducted between 1978 and early 1983), auditor qualifications, audit plannin The report concluded that weaknesses existed in the established Q program which included the scheduling and frequenc effective monitoring of the construction program, y of audits, the lack of resolution of certain audit findings.
and the lack of effective QA program should have been more effectivb.The inspection also indicated that the During the TRT's evaluation of allegations and concerns, it was observed that effective corrective action was not instituted to prevent recurrence.th examples were:
Typical for 10 CFR 50.55(e) items, (2) QA breakdown in document control for and accepting documentation for work they previously performed s
Y Based on its findings and observations, the TRT concludes that the QA audit and reporting program has had and continues to exhibit deficiencies.
ficant period of time, recurring deficiencies include:
Over a signi-inadequate staffing during peak periods; failure by management to review the QA program for ef fec-tiveness; procedural and implementation inadequacies; questionable qualifica-Comanche Peak SSER 11 P-33
tions and capabilities; incomplete assessment of the QA program on an annual basis; inadequate corrective action to prevent recurrence of identified defi-ciencies and insufficient management direction and understanding.
In summa-tion, the QA/QC Group finds the past audit and reporting system less than ade-quate, and theraudit and reporting program at the time of the TRT review was questionable.
4.8 Inadequate Procedures Criterion V to 10 CFR 50, Appendix B requires that QA/QC procedures be written to prescribe activities affecting quality.
The TRT found that procedures in some areas did not comply with this guideline.
For example, material control procedures did not adequately address requirements for physical inventory control material traceability, material handling, and segregation of paints.
TUEC re-quirements for authorized nuclear inspector involvement in the TUEC inspection process were unclear.
Quality control personnel inspected without written procedures or formal accept / reject criteria.
Some inspection procedures lacked comprehensive inspection and reinspection criteria for inspectors.
Require-ments for reinspection of repair work were not clear.
p The TRT found that construction procedures provided inadequate instructions to craft and QC personnel for installation of temporary supports, steam generator CI bolting, jam nuts, thread engagement, Richmond anchor bolt inserts, repair of te misdrilled holes / plug welding, mixing of paints, and protection of unpainted ci j
threads and surfaces.
Procedures do not specify design standards for fabricat.
au ed threads, interchangeability of valve parts, and reactor vessel cleanliness co requirements.
There were inadequate welding procedures for welding of thin-a n<
I wall stainless steel pipe for preventing hoop shrinkage.
Procedures did not 9"
provide clear precautionary directions regarding prohibited construction meth-SY!
I ods, such as unauthorized welding to rebar, and restricted use of various tools.
Requirements to paint the threads of component support bolting contradict Cor requirements of another procedure to maintain threads free of extraneous d98
,qterials.
C P
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In summary, the TRT QA/QC Group concludes that construction and inspection pro-j cedures in some areas were inadequate, contradictory, uncontrolled, or nonexis-tent.
s I
/*
, T9 Overall Assessment and Conclusions w n y n, N..,
Appendix P consolidates all quality issues identified by all TRT Groups in re-i lation to eight quality attributes.
As noted in the introduction, the scope of
'q the TRT review and inspection was limited to the QA/QC concerns raised by the allegations.
Appendix P focuses on problem areas that need further identifica-tion.
This identification of problem areas will facilitate the preparation of a corrective action plan, which should provide reasonable assurance that the facility has been properly constructed.
1 Based on its assessment of the total TRT effort, the QA/QC Group finds that QA/QC problems at Comanche Peak appear to be the result of the following condi-J tions that existed prior to 1984:
i i
a.
TUEC senior management was not actively involved in site QA/QC activities.
Comanche Peak SSER 11 P-34 Coma
^
s
E b.
The training and qualification of QA/QC, craf t, and other personnel were not administered and monitored effectively.
Design engineering activities were not effcctive in providing craft c.
and QC personnel with adequate procedures, instructions, and other design documents.
d.
The control of documents, and subsequently of records, was replete with recurrent deficiencies.
Some craft personnel appeared to be insensitive to QA/QC concerns at e.
times, possibly because of lack of training, tight schedules, and excessive schedule emphasis by construction management.
f.
Quality management was lax in its responsibilities to direct and n
oversee an effective site Quality Program.
- d Some QC personnel exhibited repeated lapses in effectively executing g.
their responsibilities for inspection activities.
The pattern of failures by QA and QC personnel to detect and document deficien-
.cies suggests an ineffective 8&R and TUGC0 inspection system.
This pat-tern, coupled with (a) the past problems in the document control system, (b) defi-ciencies in the QC qualification program, (c) ineffectiveness of the quality audit and surveillance systems, (d) a rudimentary and ineffective trending and t-corrective action system, (e) QC problems as shown in QA/QC Category 8, AQ-50; and (f) instances of improper workmanship of hardware as found by all of the TRT groups, challenges the adequacy of the QC inspection program at CPSES on a system wice basis.
,l s.
Corrective action will require hich-level management attention and a new man-agement emphasis on the importance of qual'ty as a vital element of an adequate construction program.
o-s-
/
J of a
- a-af di-Comanche Peak SSER 11 P-35
9 5 TUEC ACTIONS As the TRT QA/QC Group has noted previously, i' results are based on a biased sample in the sense that the sample was initi' y developed from allegations, i
additional items brought to the TRT's attention, and items found by the TRT.
e Nevertheless the TRT believes the results are meaningft.-
TUEC shall evaluate the TRT QA/QC findings and consider the implications of these findings on thiE--
Quality of construction at Comanche Peak.
IU R shall then submit to the NRC~a program plan and schedule f or completing a detailed anc thorough assessment of the QA issues presented in the enclosure to this supple: ment.
The programmatic plan and the plans for its implementation will be reviawed and evaluated by the NRC staff.
I The TRT considers the findings to be generic to both Units 1 and 2, and the program plan and schedule should address both units.
This program plan should:
(1) address the root cause of each finding and its generic implications on safety-related systems, programs, or areas, (2) address the collective signifi-cance of these deficiencies, (3) address the total impact of one discipline-related finding in other disciplines, and (4) propose an action plan that will correct all problems identified and ensure such problems do not occur in the future.
The plan should also assure that the foregoing tratters are addressed so as to provide reasonable assurance that no safety-significant deficiencies remain undetected and unresolved.
TUEC's examination of the potential quality impli-cations of the TRT findings shall include, but not be limited to the areas or activities selected by the TRT.
The program plan must describe the depth and breadth of TUEC's approach in sufficient detail to permit an independent evalu-ation of the plant.
This evaluation must conclude that the plan is comprehen-sive and self sufficient and will provide reasonable assurance that the quality of the construction can be demonstrated.
The actions shall also consider the use of management personnel with a fresh perspective to evaluate the TRT's findings and implement co*rective actions.
TUEC shall consider the use of an independent consultant to provide oversight to the program.
TUEC shall also investigate the role of the erincipal contrac-tor personnel (Brown & Root and Ebasco) in regard to Quality Assu nce/ Quality Control concerns.
Although the TRT QA/QC Group realizes that TUEL is ultimately responsible for the plant, the contractor (constructor) was directly respon-sible for construction and quality control.
TUEC shall also consider the prudence of continuing to rely on contractor management personnel involved in ongoing work and recovery efforts when they are the same people directly responsible for the problems identified hereir.
Comanche Peak SSER 11 P-36
l
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APPENDIX A
- j TEXAS UTILITIES GENERATING CCMPANY l
AUDIT REPORT I
1 I
I I
I I
I I
I MANAGEMENT ANALYSIS COMPANY
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5 R
R lE
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APPENDIX A E
TEXAS UTILITIES GENERATING CCMPANY E
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E I
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1 I
1
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~
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I APPENDIX A TEXAS UTILITIES GENERATING COMPANY AUDIT REPORT l
I l
9 P
k G
I AUDIT REPORT O
Suesect:
Au4te or rexas ut411:4es Generat4ns Comoany. Certas offices and Comanche Peak Steam ETectric Station Construction Site Date of Audit:
May 1-12,,19fa Audit Scope:
A management audit was conducted of the Quality Assurance Program of Texas Utilities Generating Cocoany during tne weeks of May 1 and May 3,.1978. The purpose of tne audi
)'
was ta determine the adequacy of the Quality Assurance Program as related to NucTear Regulatory Commission require-ments and the effectiveness of implementation to met program requirements and authorf ty delegations. Activities were audited at bot.Y the TUGCC offices in Callas and at the Comanche Peak constraction site. Activities of the Architec:/
Engineer and Constructor were audited only at the construction site. The scope of the audit included comittents ?. ace in the PSAR, the Corporate QuaTity Assurance Manuai, tne Comanc.ne Peak Quatity Assurance PTan, tne Project Procedures Manual and tne Brown & Root Quaiity Assurance Manuals and Precedures related ts the Comanene Peak site.
Auditors:
Calias office, May T-3,,1973 J. P. Jackson, MAC Audit Team Leader J. 't. Norris,, MAC Auditor Comanene Peak Construction Site. May ? i 5, May 3-12,. i973 J. P. Jackson,. MAC Audit Teant Leader J. M. Norris, MAC Auditor J. A. Hendron,. MAC Auditor (May 3-12 cnly)
Personnel NME CCMPANT TIRE Contacted or Interviewed:
D. N. C9a n n MCO QA Manager, '4 -2 R. G. Toisen TJGCC Mgr, Site Sur/eillance, ' * -2 C
R. '/. Fiecc TUGC3/G M Civ. Inspec. Supv., '-l J. 't. Hanins.
TUGCO/G E Prod. Assurance (CA), *-1
m TUGCQ AUDIT REPORT I..
O aersaaa i "A*e cc"a^"'
7t 's Contacted or Interviewed:
J
- 3. George TUSI Prof. General Mgr., *-1-2 J. T. Marrit TUSI Resident Manager, *-1 E. G. Gibson -
TUSI Project Engineer, *-1-2 E
J. Murray TUSI Engineering Supv., *-1 J. J. Moornead G&H Resident Engineer, *-1-2
- 3. C. Scott B&R Site CA Manager, *-1 i
J. P. Clarke 3&R Site QC Manager, *-1 4
R. Mann S&R QA Records Coordina or,
- 1 ff. C'. <frkTand B&R Prof. Generai Mgr, *-1 (I. 7. Dougias 3&R Project Manager, *-i
- 7. C. Frankum B&R Asst. Project Mgr., *-1 4,
P. Foscolo B&R Prof. Chief Engineer,
-T L Hancock 3&R Mat'I Procurenant, Con-structica Branen, *-1 A. Boren TUGCG Vendor Comoliance
- A. Vega TUGC3 car Central Staff Functi:n,
'-I-C. Beggs TUGCG Systems Comoi f ance,
-T -2 R. Gary TUGCG V.F., Operations, *-1 L. Ffker TUSI V.F., Design & Procuremen:. -:
F. Brittain TUGCD/TUSL President,1 Interview I Pre-audit meeting Z Fost audit meeting Audit Method:
The audit as conducted nrougn a series of interviews *i:n responsible managemen and sucervision and examination of Quaif'y Assurance manuals, arecedures, records and acrt operations both at tne Dailas headquar*ers of Texas "tili-f es Generating Comcany and Texas Utilities Services, Incer:cra:e and at the 2manche Peak construction site.
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Summary:
The auci: isclosed that recent enanges in autnort:y : ele-gations nad teen generally *1T accepted and :nat morale
TUGC0 AUDI REPCRT 3-1
.,y {
Suninary (Cont!d): and teant spirit were good. Powver, the changes had no:
L yet beert fornalized in revisions to the PSAR and the Comanche Peak Quality Assurance Plan.
The audit also disciosed that present practices in the control of design changes and of certain nonconformances do not provide.he
[
requisite level of review by the original designer.
In other instances it was evident that design changes were being used in lieu. of nonconfor.ance reports.
Exceo: for the areas. noted. nerein and below, there was generally good adherence :s existing procedures.
Findings:
T.
The current activities of TUGC0 Quality Assurance ser-sonnet are not consistent with the authority delegations ta Brown & Root and to Gibbs & Hill as defined in :ne PSAR and Coranche Peak QuaTity Assurance Plan.
Similariy, the-Quality Assurance Pian and Procedures are not consistent wit:t current and pTanned revisions in authorf ry delegations to ne Ar:nitect/ Engineer and :ne Construc:ce,. and is. not c molete in addressing all eignteen criteria of ICCFR50 A :endix 3.
The lack of a well identified plan of reorgani:ation and responsibitiry causes, uncer ainty in car ~ying Out sore activities.
There needs to be a slan f0r revising :ne Quality Assar-ance Program; sucn a plan snould include One estaciisn en:
of an arenitecture of procedures to show hcw c:ner TUS*/
TUGC3 and contractor.anuais inter-r= Tate witn :ne ;uali y Assurance Manual.
The TUGC0 QA Manager snould es.ablis t a scnedule and assign rescorsibilities for completion of the necessary procedur=s.
The schedule should be sucole-mented *it t a management effort Oc nonitor acherence to
- ne n' art and acnievement of One senedule.
h 2.
The Ourmnt site CC :CA system of after tne fact coerci-na*.ica af design cnanges with :ne original designer p
h6_
TUGC0 AUDIT REPORT
.4-Findings:
provides a. significant risk of design error and does (Cont'd) not meet the requirements of ICCFR50 Appendix S, nor of ANSI N45.2.IT, " Quality Assurance Requirements for the Design of Nuclear Pcwer Plants".
A systent for expediting and documenting Gibbs & Hill home office approvals should be estaolished using teleonone, teleccoier or telex as a means of speeding q
CCCT3uniCati ort.
,T.
The Comanene Peak Quality Assurance Plan does no: :rovice for a Quality Assurance review of procurement dec. rents i
and changes thereto prior to purchase order placemept.
except for site originated precurements.
Sucn a review is identiffed in 10CFR50 Appendix 3, Criterion :V and is a requirement of ANSI N45.2.I3.
It snould :e recuire:
ort all safety related procurements.
1
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4 The curnne conninatiert of Chapter IT of :ne PSAR. ne TUGC3 Corporate Quality Assurance. Manual, one C:mancne
[
Peak Quality Assurance Plan, Pmfect Procedures and Browrt & Root Manuals and Procedures pmvides a ::m::ex array of procedures wnich is difficui: Oc main at, l
current and consistent.
5.
The current systent of providing ins:ection instruc:::ns or cneckTists := inspectors is too gene.-ic, plact rg an undue burderr en the inspec cr in attemoting to etem *e apolicable drawings and. s:ecifications and appli:a: e revisions thereto. A review of records. of concrete cours incidates nat configuration reflecting one as-
= cured condition is not clearly defined. Applica::e C :CAs are not noted in ins:ecticn documentati:n.
{.
C nfiguration neecs to be clearly identified to ins:ec:crs on a current basis, including; all 3::iica::e
TUGC0 AUDIT REPORT 5
Findings:
DC DCAs. and. completed. documentation must reflect the (ContW status of the applicable changes.
6.
Special, processing markings for later in-service inspections.are carelessly applied.
The circle and f
arrow used. for such marxing is sometimes incomolete and not recognizable for its intended purpose.
In One instance only a. portion of the circle resemoling ne
)
ietter "C" was. discernible.
FaiTure to properly I
mart nese Tocators now wiTT cause delay and ::ossible en cr wnent in-service inspections are made in hignTy frn dfated areas.
7.
Gispositiert of nonconforning items does not always acnieve the requisite review by appropriately qualified design: personnel. A procedure, Timited to. defects in concrete,. was recen Ty issued.wnich bypasses. One esta:-
Ifshed: nonconfornance centrer systent and,. :nus, vicia:es reguTatory requirements in this regard.
In c:ner instances, the DC CCA, pregrant has been used to ::y:: ass One nonconfornance recor:ing system. The noncenformance contrai systent snould te the means for maintaining in-s::ec cr integrity, icentifying ::rcblem areas anc ::revf:e f
a driving force for heir : rrection.
f c?. The records stcrage facility does not curren:Ty nave any means of internaT fire are: action during hours it is l
unmanned, eithougtr it is understood scme method is l
alanned. Quality Assurance records, suctr as ;3erscnnel cualiffcations,. are not maintained in the Rec:rcs Center, but are maintained in fireproof file cabinets in a trai'er
- ncer
- ne cogni:ance of 3rown i Root training ::orcina:Or.
9.
Accroximately t,*!nty-four percent of Central Staff au ':s nave not been c::nducted as scheduied. Comeining Central 5taf" audits,. site audits and site surveillance activities
i I
TUGC0 AUDIT REPORT I Findings:
by TUGC0 and by Brown i Root into a single, cohesive (Cont'd 7
program would. provide improved visibility to the overall
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audit and surveilTance effort and permit evaluation and ajustment to the audit schedule to attainable and yet effective frequencies.
I b
6 P
>9 I
e O
f55E
/
'O APPENDIX 3 3
TEus UnLITIES GENERATING CCMPANY CBSERVAT:CNS AND RECOMMENDATICNS h
/
(V
TUGC0 AUDIT CBSERVATICNS AND RECOMMENDATICNS O
t.
a m N m TICN A.
General TUGC0 Quality Assurance has undergone considerable reorganization in the past year. The general thrust of tnis effort has been the assumotion of greater direct involvement in :ne management and supervision of the Comanche Peak Quality Assurance Program.
It is to be noted that imeer an; shifts in resconsibility were being made at :ne time of MAC's review.
4 As a part of tnis assessnent,. FAC evaluatec the reactions of key managers, supervisors and inspec:crs to the overaTT cnanges :na have taken ciace to date.
It was. generally observed that those intereiewed :nougn that witn few exceptions the changes were for the better.
There appeared to be a team effort on the part of OA and Construction *f tn excellent TUS executive management and project management support of ne GA pregram.
There nas nar noticeable prooiem di.n organi:ationat :re;udice brougnt about y :ne organizational internixing of TUSI,. Brown L Roo: or Gibbs i Hill wor <
forces and sucervision.
B.
Oreanization During ne course of tre audit FAC discussec :ne value of a revised organizational stracture with the TUGCC luality assurance anager anc u
the Manager, Site Surseillance.
It is reconsnended :na: TJGCC adco: an organi:a::enal realignment Of activities, as set for n in Exnibit T, uneracy Cualf y Engineering anc Inspection recort to :ne Site QA Sucervisor as tao le::arate sub-organizational entities wi:n resconsibtiities as cefined in Exnibi; T.
Such an organi:atien iii tetter succlement.ne exining Constructicn organization and will :erni cetter organt:ation for nandling :ay
-:ay site problems as aeil is i: olementing mccanencations of :nis re:: ort.
This is particularly so in :ne area of ins::ection planning.
J hdhdL aJhm
TUGC0 CBSERVAT!CNS & RECCMPENCATIONS I C.
Quality Surveillance Cennittee AIT mimatas of meetings of the QSC since its inception were reviewed.
It is noted that the QSC was established as a mechanism for provicing
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to;r TUGCG management with a periodic update on such matters as " schedules and miTestones" or " audits and corrective actions".
It was noted that recent meetings dealt witn tracking on :ne status of r
(
action items as set for:n in :ne Outstanding Sureviliance Recort :: ems de or tne Quaif ty Assurance Items of Concern Recort.
In sucn instances i:
appeared. the Quality Surveillance Consnittee was taking on :ne role of a task. force or prooiem solving group.
The proclem that exists if :ne OSC assumes. suct a role is that probTems would tend to await ne :nree xntn meeting cycle before ne necessary management atten: ion is effected.
It is. reconnended that TUGC3 re-evaluate the charter of the QSC and serious g
cons.ideration given as. to its value ta :ne project recognizing :na::
T.
AT.1 action to resolve problems snould be nandled on a day-:c-daf cas::
througn the functioning organi:ation, and Z.
The crimary cojective of maintaining manageren: awareness of Oua: I:/
Assurance status mignt be accomolished more efficiently, effective f and on a more timely casts nrougn a montnly Cuality a ssurance progress report distributed Oc the PJGCO/TJSI executives.
D~.
Qualificatiert of personnel MAC reviewed the qualifications of all TUGCO/TUSI and licos & riiii Quality Assurance eersonnel and many of ne Brown i Roc: cersonnel.
was observed that most of the TUGC0/~USE Quali / Assurance personnel nave ga.ined neir Quality Assurance exoerience nrough Cor.ancne Deak activi:'es only. Althougn the project nas provided valaaole exoerience, it is ec-onnended t1at any fu:ure assignments in Cuality Assurance be fillec 4t:n quality engineers nired from ou: side :ne comoany witn cread nuclear ex-perience, preferably in constraction.
Sucn experience added to One existing staff will serve TUGCO/TUSI well in accomplishing tne imoor:an:
O TUGC0 CBSERVAU CNS & RECOMPENDATICNS
-3 I'
piping, electrical and startup activities anead.
MAC had occasion througneut the audit to assess one qualifications and g
E experienca of 20-30 inspectors throughout the construction site.
Piese observations are worth mentioning:
1.
The insoectors are generally young and inexperienced with many having
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as little as six mon:ns experience in inspection.
2.
There was an covious need for more seasoned inspectors 03 work with the novice ins;:ectors on a day-to-day basis.
I 3.
Too much responsibiTf ty is placed on the inspectors with res::ect s preparation of inspection planning, resolution of site proolems and
, detemination of the design configuration base. for per#cr ance of inspections.
I II.
CUALITY ASSURMCE PROGRAM The Quality Assurance Prograrr is defitted in three casic documents:
The Corporate Cuality Assurance Manual Chapter 17 of the PSAR The Comanche Peak Quality Assurance Plan These documents ar* not irt total agreement wi2 one ano:ner.
Since 19ere is no other nuclear plant cur ~.n:ly clanned and since tne autnority cele-gations identified in ne Corporate Manuai are not in consonance 41:n practices on Conancne Peak,. TUGCC snould consider discontinuance of :ne l
Corporate Manual unless. :nere are other projects to unicn it is 03 ::e appifed.
If a. Cor:: orate Manual is required at a ia:er date, a new one g
could be prepared based on Comanene Peak ex::erience and ne recuirements of any new projec s 03 whicn it would be aoplied.
I The Comrnene Peak Cuaifty assurance Plan addresses cnly :ne following criteria of :ne eign:een icentified in ICCFR50 Ap::endix 3.
6 TUGC045ERVATICNS i RECCMMENCATICNS l
l O
ors >at: tioa Design Control Procurement Administratton Inspection Nonconfor.ance Control Document Control Records Audits 4
With the expanded resconsioflities of the TUGC3 Quality Assurance Cecar.-
ment, the pian needs :s be exoanded to address all eighteen criteria to reflect the creation and "unc:f ons of the Precurement Capartment and :s be consistent with :ne authority deiegations and functions setti resting I
with Gibbs & Hi1T and *im Brower & Root.
There needs to be a pian for procedurai fdentiffcation and development and a schedule and assigned responsibilities for thefr comoletion, inciacinq a complete architecture of Quality Assurance procedures project prececures.
and interfacing prececufes of the Arenf tect/ Engineer and Construct:r.
~h e effort. should be := minimi:e One nu=cer of procedures required and to eliminate ducifcating or overlapping procedures tnreugn consolidation of detafT and joint approvais of the organi:2:fons involved.
It is rec:rmenced that tne Quality Assurance Manager use his organi:ation as ne driving force to achieve required procedurai : overage on senedule.
It was noted :nat TUGC3 is planning on cotaining f s Own Code manual.
The stated reason for :nf s. was the fear :na: Brown & Root would not actrieve Code acceptance. The auditors feet that the Brown i Root manual would :e acceptable ts the Code Sur/ey Team and :na: its weid practt:er as exemc11-ffed in the Weid. Shop are very acceptable. The auditors are of ne opinion that oe:aining a Code Stamp wili be difficult wnere all the nort of fmolementing :ne program is perfomed oy others.
III.
DESIGN CCNTROL The present system of excediting field enanges by referring design enanges to the originai design organization for approval after the fact does not
TUGC0 CBSERVATICNS & RECOMMENCATICNS p.
=
O e ta. 4atcae or toCraso A aeadix a ace of ANSt N4s.z.ii. n4cn recu4re P
that field changes be subject to design controls connensurate witn. nase exercised on the original design. TUGC0 audits have already disclosed that the Architect / Engineer has not been reviewing field originated enanges on a concurrent basis, thus the design engineer's cernents may be received after the specific construe.icn work is complete resulting in possible loss of design integrity, uncue pressure on the designer to justify ana:
has been done, loss of designer ensconsibiii y or possible extensive repairs.
It is recommencec :nat a system for ex: editing review and approval by the originar designer ce estaotisned en all safety related enanges using te!eonene telecocier or teiex as necessary Oc c ordinate and document change approvais.
IV.
PROCUREMENT CCCL'ME.C CCNTRCL Except for site precurements, ne Comanche Peak Quality Assurance Plan
, does not provide for a review of precurement documents and their cnanges prior to placing a curenase order. 'his fs. : ntrarf to requirements :f 10CFR50 Appendix 3 Criterion :7 and ANS: N45.I.i2, "Cuality Assurance Requf mments for Contrei of Procurement.....*.
there is a review of =rc-curement documents cy Ouality Assurance during esfgn Review, but is nas ascartained that :nis. nas a review of One drawings and scecifications and not the purchase order or : ntract.
Procurement document review cy Cuality Assurance snould assure that ali necessary requirements for access. to the sucolier's facilities are :revi:ec and that necessary con:rcis and documentatictr have teen 5:ecified are that the appropriata ::nfiguration has :een f.efined.
The review shou!1 also assure that recuiments imcosed are accrocriate to ne procuremen:
and that there are no excessive requirements for quality program deveico-ment or for the delivery of unnecessary cocrantation.
5xe of :ne cr -
curement packages reviewc acceared c nave :otn :lanket requirements ':-
Quality Assurance programs and excessive recuiremen:s 'or decrentati:n.
G IEEE
TUGC0 OBSERVAT'sCNS 1 RECCWENCAT!CNS I' V.
INSTRUCTIONS A.
Insoection Plannine The current systent of providing inspection instructions or checklists :=
the inspectors is too generic in nature.
In the case of concrete ins ection planning the inspector fills out a simple pour card with an attacned Concrete Placement Checklist, a Reinforcing Steel, Electrical, Meenanical and Entedded Item Placement' Checklist and a Stainless Steel Liner Checklist, k
the combination of anica:
I.
Provides no infor.ation wi:n res:ect Oc unique, emecments or penetrations to be incorporated in ne cour.
t 2.
Piaces an undue burdert on the inspec:cr in attempting. to de:e-mine appif cabie drawings, scecifications, a:piicasle revisions and applicable DC CCA's.
Nctr of this incut should te provided my ciericai succor: uncer the direction and sucsecuent a;oroval of
(
a-quality engineer.
Inspectors estima:ed :na: 45-7C% of :neir time is s:ent en decu-mentaticri ratner nan :nysical ins:ectun activity. Welt :nougn:
out pianning : uid do mucn := alleviate :nis situation.
Traceability It was observed :na: Comanche Peak has estaciisnec a crogram of unnecessary material traceability wnien based en :ne estimate, ::nsames h
at Teast a three-man Tevet of effer and 4rna:s as nign as a sir an levet of effort if one ::nsiders 2TT :ne su:ccrt func-ions. r%ui ec ::
{
implement the program.
ATT ancnor bolts anc 3 series :acwelds are fully traceable tc nea: numcers sucn :na: :nr ugn an eta: orate and extensive system af.a:cing aII installations, :ne ca: ability exis:s of identifyinc eacn emedded anchor bolt, 3 series cacwelds and 3:ner standard emceds :s s neat number.
Tnere exists no suca NRC or g
I industry recuiremen: ' v nis egree of :raceaciti y,
- is in:e.
esting to note :na: e:ar aces not require rsceacility en Comanene :ea(
(and snouldn't), "AC < cws of no a:ner project :na: imposes this recui e-
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E
TUGC0 CBSERVATICNS 1 RECCm ENDATIONS. t' ment and could not identify a Comanche Peak specification or procedure requiring it. Accordingly, it is recocinended that this practice ce g
dropped imediately. Such a move would enhance inspector morale as a
those involved are aware that the practice serves no useful purpose.
C.
Procedure Simolification Newly established procedural systems are such that Constm ction and
-Quality Assurance issue procedures on s.fmflar subject matter jointly, for example,. the recen:Ty issued procedure on shop travelers was i
{
fointly precared my Construction and Quality Assurance.
It is recom-mended that important procedures such as, those related Oc concrete ce
{
revised and fssued as. a single procedure approved by Construction and Quality Assurance.
Similarly, those procedures related :s picing and I
eTectrical should be revised and foin:Ty issued as a single Comanene Peak procedure.
D.
Procedures Indecencent of Houston-The present system of obtaining 3rowrt i Root. Houston office a::rovai on construction ;:rocedures snould be modf fied.
Guidelines should te worked out with te Houst:n office wnerecy mey approve Only 00 'evei procedures, per nitting tne site full flexibility in revising ce:ai'ed site procedures.
pernaos the Brown & Root. Houston office could m a,
approval authority on : nose ::p level docurents that establish 3rown L Root policy, controi :ne necessary tyce of for.s. etc. However, detailed operating crocedures, should be :nanged with site approval :ni f.
PerMaps the Houston office would agree :s a retroactive review procecure.
E.
Configuration ControT A review of records for completed concrete pours indicates :na tre configuration reflecting the as-poured c:ndition is not properly defined.
It was noted :na: :ne inscec::rs record the :: articular :ra*1rg nurt)er and revision Ie::er, newever, all acclicable :C CCAs are no:
.Q noted anywnere in re-ins;:ection supporting documentation.
F
'UGC0 CBSERVATICNS & RECCMMENCATICNS.
Q F.
Preolanning of Construction Work In discussions. wittr constructiert management personnel it was indicated that a new scheme of constmetion planning is being developed. This new scheme provides for a d'etailed material takeoff en all Gibbs & Hili drawings which provides detailed instructions to the crafts as to tne t
civil, mechanicai and electrical items to be included in each segment of work. This formalized accroach of taking material takeoffs in :ne
[
office and providing :nis infor-nation to the field forces on an accroved materiai takeoff if st *f1T da mucn to imoreve the quality of :ne wort.
i P
[
Since the materiar takeoff is a for nal process accomolisned by c nstruc: ten engineers welt in advance of the worx:, it provides a significant measure of preplanning,. incTuding the processing of necessary design enanges :s accomplish the work.
Such art effort will do much to minimize field errors with respect to. Teft out emcedments or inability to complete work as 3.
r resuit of design errors.
It is recomended, however that tnis eff r. te formalized inta a Comanche peak site ::rocedure.
As such, it wiiT ::e
~
recognized as part of the systent and wflI de mucn to assure that Gib s. f.
HiTT drawings. are femardec t2 :ne site on a timeTy basis to accceolisa
- nis preplanning eff:rt.
VI.
CCCUMENT CCNTRCL While there appeared to be scre prooiems 4f tn cringing the Aut: matt:
Records Management System en line, One manual system sacking it uo appeared to be functioning satisfactorily. The aucitors found no deficiencies in document control.
VII.
CCNTROL GF PURCuASED MATERIAL. ECU!?"ENT 20 SERVICES The QuaTity Assurance pian is not up to date in regard to R:GCO's respons.ibfif ties for precurement, source evaluation and source sur-vei1Tance. TUGCQ has developed a progrant for rating succlier ::erfor t-ance and shows evidence of acticns een reatings are unsatisfactory.
The 11st of suppliers requiring evaluation and source surveillance is not kept up to date my :ne Architect / Engineer. The list in use is over
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TUGC0 GBSERVATIONS & RECC.T ENCATICNS
.g_
four months old, but is maintained manually by One TUGC0 Supervisor of Supplier Compliance.
There does not appear to b'e any method. of assuring that the Tatest con-figuration is supplied to the personnet perfor ning source inspection prior to shipment of procured items.
The source inspector appears to be at the mercy of :ne sucolier in determining wnat enanges have been identified and incorocrated. Thus,. it is concaivable tna tems wili be shipped ta the site- :na: ca not meet One desired configuration even g
though requirements of :ne curenasing document nave been met. Suca receipts can cause delays. and unwarranted costs in meeting the proper configuration.
I It is reconinended nat a practice be established of identifying and confirming requirec configuration prior to procurement and prior to shipment of purenased materials anc cocconents.
I
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VIII.
IDENTIFICATICN 30 CONTROL GF V~ERIALS. PARTS AND CCMPONENTS No deficiency noted. MateriaT reviewd in :ne warenouse, in open storage and in the *eid snoc appeared to be adecuately identified.
3 IX SPECIAL DROCESSES l
A.
Radfooraony Iridium ig2 is being used as the radiation source for all radiograony at the site.
This isotope nas its cotimum cacability at aoout 1.5 inen thickness of steet and is not recocrnended oy ne Code below.75 incnes.
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It is permitted for lesser nicknesses unen :ne use of otner radiation sources is not practical and wnen resolution of :ne outline and 4T noie size of tne penetrameter can be demonstrated. The energy levels of iridium isotopes are nigner than optimum for materials.375 inenes or thinner, resui:ing in a 'la: image and Tack of contrast.
Because ecosure time relates to distance. One isotooe is normally placed against :ne cice opposite ene film.
4i:n r.iCG inc*r source size, nis causes blurring of the image.
Lact o' :entrast and. a blurred image makes it unlikeij
TUGC0 OBSERVATIONS & RECOMMENCATIONS..
that hairline cracks will be seerr and difficult to accurately define larga indications.
The use of f ridius 192 meets the minimunt requirements of theCbde, but by not providing optimunr identification of observed anomolids it does three undesirable things.
First it causes unnecessary removal and repair of indications that can be seen but not properly identified; secondly, it masks narrow cracks, tight lack of weld pene-tration and non-fusion wnich can be detrimental to service life; thirdly,
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it does not provfde art adequate base line for in-service inspections perfonned after the plant has gone ints operatfort.
FaiTure to have cTear i
identification of the original indications at that point cart cause deia ys, the cost of which greatly exceeds the cost of p'reviding better identiff-cation and necessary repair of defects found irt the construction phase.
Recomunendation - It is reconsnanded that TUGC0 require x-ray for shop w and consider its use where practical for constraction weids.
X-ray machines frt the range of thirty pounds of weight are avafiabie and are nearly as. portable as the isotope. Because of its smalier focai spot size and variable voltage,. x-ray cart ;fve superior radiography.
The 7
feedbacic of informatiort to. welders can improve the quaTity of welds and minimize the potential for defects. The abf Tity to discriminate betweert indications having roundness or sharpness at the ends can eliminate repair.
The ability to positively identify in the constructiert phase those indi-cations which have a potential for growth and failure can pernit economical repair without radiation hazards that are inherent if found later irr the operating phase.
B.
Weiding No. causes for concern and no procedural noncompliances were found frr review of the weld shop. There seemed to be a generai opinfort that after radiography repairs are being required that are acceptable within the Code.
A review of a small quantity of rejected film indicates this generaTization may be valid.
It was disclosed during tne audit that radiographs may be reviewed by as many as five individuals.
,.D Sucri ex-cessive review leads to supercritical evaluation of filnr and ta excessive repair.
As. previously stated, better radiography permits better
e TUGC0 CBSERVATICNS & RECCMMENCATICNS B
identification of conditions. acceptable witnin the Code.
Unnecessary repairs increase cost and reduce pipe reliability.
Reconinendations - Have radiographs wnica have been rejected for defects reviewed by TUGC0 Level III radiographer.
If a reasonable statistical l
sample shows that excessive repair of welds has been required, establisa the policy that Code accectable indica:icns snali remain untoucned, ut g
shall be recorded en *ne moor s.
i As art economy, consider reducing ne num::er of persons performing sequential review of radiograpns.
C.
NDE (7ualifications.
The site NDE Level III si.ua: fort is. unclear. Only Levei II certificati:n by-Brewrr.& Root was availacle for the NCE Su:ervisor;. however, it is understood that TUGC3 nas issued.1 Te: er identifying nint as Level I~I.
Recocinendatierr - Clarify :ne autacrity and ms:ansicility of the N E f
sucervisor in administering tests and evalua:ing and cer:1fying ::er-sonnel.
This is sery im::or an: as reTated :s ::ce norx, since ne
{
Level III will be worxing under :ne autnori y of the ncicer of :ne cce stamp.
X.
INSPECTION There were no deficiencies. noted mlative :s ins:ectien; nowever, i:
was noted. that a large num::er of insoection personnel are receiving their first. nuclear construc fon ex::erience on :ne ::rancne Peak si:e.
As a. consequence, it is recessary :o imer:ve ne puaif ty of in:::ecticn planning and to incr=ase ne Tevei of su::ervision and cuality engineerf rg Inspection alanning snould identify :ne mcuired configuratien suoport.
including applicacie JC :CAs, ne features ::
- e eeriefec, :ne inscec:1:n method and acceptance :rt:er a in Or er to minimize :ossi: 1+ c:nfusion d
h and error, f55E
im TUGC0 CBSER.VATlCNS i RECOMMENDATIONS 12 XI.
TEST CONTROL A review was made of the TUGCQ startup administrative procedures, with l
the following observation:.
1.
The procedures appear to be written around the old organization; that is, in several instances :ney refer to :ne Brown & Roo CA/CC input required in :ne precaration of "startup work requests".
1 2.
It was noted *.na an unique systern is being established to nandie nonconfomances during the startup anase.
It is recommended :nat wherever possible existing schemes utiif:ed in construction se used during the startup process. This is important since most personnel involved in dispos.f tioning such 1: ems as nonconfomances and design changes, will be the same persons involved in construe:fon.
XII.
CONTROL OF WEASURING $ TEST ECUIPMENT It was observed that out of 24. instruments sampied which are utili:ec in civil, structurai, mecnanical and, electrical woric, accroximately 50 percent had not been wi:ndrawrr frorn the caI1: ration laboratory since 1:s Tast caTibration date. This is particularTy significant nen it is recognized that tne present system is such that if a calf oration ca:e becomes due, the instrument is recalibrated wnetner or not 1 nas :een issued for use.
It is reconnended tat consideration be given :s s' :!j changing the calibration date rather nan going inrougn a calibra i n cycle if the tool has not been used.
It was noted that many construction toois are calibrated.
- is important to note- :nat calibration of construction : cots is not necessary wit!r respect to 10CFR50 Appendix 3.
Althougn calibration and mz intenance is extremely important on construe:f on : ols, i: 7.a y be that frequencies.ay be relaxed.
XIII.
INSPECTION, TEST AND CpEPAT!NG S~ATUS No deficiencies were noted in :nis area.
Material and equipment observed in receiving inspection, in the warenause and outside storage
~
TUGC0 OBSERVATIONS & RECOMMENDATIONS 1 area appeared to be adequately identified.
No tests were observed.
XIV.
HANDLING STORAGE AND SHIPPING Exterior storage practices'should be reviewed.
The protective coverings of many 1 cms are damaged; some reported on monthly surveillance recorts have not been corrected.
Large temporary structures, such as those over the emergency diesel engines, require wind bracing to prevent furtner damage. Because of soil enemistry, rain and humidity, the cur ent crac-b tice of allowing large stainless steel piping to remain unc:vered snould be revfewed. Sensitized stainless.is extremely sensitive to enlorice, fluoride and suTpnide contamination mien witn water as a couclan: can cause intergranular corrosion and premature failure.
XV.
CONTROL OF NONCONFORMANCES There appears to be an effort to reduce the nurcer of documented non-conformances.
It was notad that CC 00As were being utiT f:ed for none:nfor.ance ecer 2.
Altncugtr *4is was ceserved err a small percentage of CC 00As issued curtrg the mont.4 of April, it is receranded that :nis practice be s:c::ed immediately. ~he TUGC0 system is correc:Ty establisned wnerecy non-1
)
conformances are written after the fact and CC CAs are reserved 'Or design changes before *ne fact.
It is impor ant :na: :nis practi:e :e l
enforced since DC CCAs prepared after :ne fact necessitate :na: worcers be directed vertally to violate :ne drawing since :ne deviation at !! :e handled after the fac: 41:n DC CDAs. ~his is a poor Cuality Assurance practice.
Procedure CPQT-AB, Dev. O, dated 5-5-78 was issued for :ne purpose :f providing expedient discosition of concrete discrepancies.
Die peccedure infers that discre:ancies of 72*F versus 70*F or 6.2 air content ve-sus 6.0% maximum is cer#ectly sc:eptable wnen i-is signed Off by :ne 'ie:d engineer.
Sucn a sys en snortcuts :ne esta:lisned nonconforming ma:eriti control system as defined iq 3rown & Root and TUGC0 procedures and snculd
TUGCC CBSERVATICNS 1 RECCWENCATICNS
- 1 1._
s Q
be discontinued.
If tolerances are unrealistic such that tne 729 is acceptable., then the design specificatien snould be changed Oc so indicate.
It is reconsnended that good inspection planning ce provided inspec: Ors, identifying the characteristics ta be inscected, One :nethod of ins;:ection and acceptance criteria and tnat ins:ectors identify noncenfomances to 1
suen criteria.
Th,is *ili.aintain :ne integrity of ins:ectors and previces l
identification of precien areas anc :revices a means for tneir cor ection.
0 It is reasonable to assume nat are a project as. Targe as Comanche Pese, there will be severai :ncusand noncenformance recer:s. The numcer :ces not reflect adversely arr One quality of construction, but the failure tc identify nonconfomances :ces refTect adverseiy Orr the integrity of inspectors and leaves unknown :ne cuality of Me piant.
XVI.
CORREC IVE AC~~CN There were no deficiencies noted. reiative :s c:rnctive action en nard-ware. The Supolfer Comcif ance Suoereisor has established a metnoc of tracking vendor perfor ance and snows positive esults. frect ac icns :acen te correct su:: plier quality reciems. 4 review Of reports of site sur-vetilance conducted :y UGCC snowed cornetive action res:enses were being promotiy received.
A review of $:cr:s of sur<eiiiance actions by Brown & Root snewed generaTTy acequa:e es;2cnse and resolu:icn cor ective action except for a periac of 'Our t:ntns anen sureefitance personnel were assigned :s c ner tasc.
Irr general,. corrective action at:cear: :c. :e icecuate and tirnely on <encar and site related preolens, Out some deficiencies identified in audits Of major contract:rs stiti :ersist. Some of :ne enanges in authority ceis-gation to major c:ntract:rs at:: ears :c be action takert to correct inace:La:e or untimely res::ense :y : nose organintions; newever, ::ner sc:icns :acen, such as handling of ei: :nanges and nonc:nfor.ances,1::cear c :e incse of circumventing :ne :re::em ra:ner : nan :Orrecting it.
f5EE
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. =.
TUGC3 CBSERVATIONS i RECC.?ENCAT!CNS
.;5 XVII.
RECOR E Except for lack of internal fire protection, tne quality records area is considered to be satisfactory. Scme Quality Assurance recorcs, suen as personnei quaitfications, are not s:cred in :ne records center but are maintained separately by the Brown & Rcot training coordinator.
There is not currently a catalog or Tisting of required records althcugn it is being precared.
A r= view of a selection of Ouality Assurance records snowed ne dccuments in eem :o nave been ro:erly c:moleted l
a and in the correct creer.
Recc.nnendatien he ins:aiiation of an inert gas fire extinguisning systent or the identtficaticrt of geogrionicaTTy sacarate duplicate rec:rcs should be ex edited. T'JGC3 should review the fire protection capacilities of storage facffities in :ne training supervisor's trailer and : nsider a dupiicate-set of sucn records to be maintained in the records center.
XVIII.
AUDITS There are-several audit and sureeifiance rograms in effect.
Auctis :y the Quality Assurance Je: art ent Can:ra! 5:1?' ar= ;erf:rmed :n si te activities, major c:ntrac:ces and sucof fers.
Sita surveillance actions are per#0rned under :ne directicn of ne T;GCC OA Site Su:ervisor.
Sim::ar survefilance activities ar* carried Out ancer ne directico Of :ne 3r wn &
Root Site Quality Assurance Manager. Whtie caitec surseiliance ac:::rs, the surveillance programs are for aiij slanned and scneduled, uti!i:e checklists to guide ce activity and Ncord esuits. and issue re: orts of deficiencies and require correcti:n.
Exce:c for for al and decrente:
pre-audit and post-auci:,eetings, al! Oe elements Of an audit r: gram are irt place.
It was recor:ed tna ce reason f r :alling :ne actiet:y l
"surve11Tance" was s avoid outsice auditors fincing :ne :rogram def':ien; l
l because it did not include me documented re-and act:-audi t meett ags,
yet the auditors 'cund Sa sucn eetings were ::nduc: 3d, but en an infor al basis.
Recorr,endation - Die suc::crs :cns t er me resen: Orogram :: :e an effective tool wnica ::uid :e further improved.
TUGCC should :ensider e j g
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6
1
,. TUGC3 CBSER'/ATICNS i RECCMMENCAT:CNS 15
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comoining the audit and surveillance activities into a single, cohesive effort. Such art integrated effort could cover required areas more efficiently, without duplication and at a frecuency that can be main-tained. Such an audit program should be described in written procedures-and include a descriptien of ectn the fonnai audit and the continuous audit pian (surveilTance) and the method of cenducting pre-and post-audit meetings should be described :: creclude later criticisms by outside organi:ations. The resulting aucit program should be a superior tool for
),
management assessment Of 3regram imoiementation and effectiveness.
9 IEiiiiE
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spys pues quam pges name same smug guip SITE SUPERylson I
4 QUALITY PROCltoRES
[NGINEERING INSPE0110t(
AUDIIS IHAINING DCSIGN REVily QUALIIY VERIFICATION SITE PROCEDURES i
PROC, DOC'I, RLV.
HONCONIORMNCE SURVEILLANCE /
INSPECIl0N Pt AN'G.
IDENI, & CONI't.,
AUDils INSP. HElll0DS INDOCIRINATION QUALITY SIDS.
TRAINING NONCONf0R4\\NCE QUALITY HECORDS DISPOSill0N CORHECityE AC110N EXillDil I
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/
UNITED STATES OF AMERICA f
g NUCLEAR REGULATORY COMMISSION i
FEB uo w
Before the Commission In the Matter of
)
c,
)
TEXAS UTILITIES GENERATING
)
COMPANY, et al.
)
Docket Nos. 50-445-OL
)
and 50-446-OL (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Request for_ Imposition of Fine, for Suspension of Construction Activ(ties, and for a Hearing on Application to Renew Construction Permit have been sent to the names listed below this 31st day of January 1986, by:
Express mail where indicated by *: Hand-delivery where indicated by **;
and First Class Mail unless otherwise indicated.
Administrative Judge Peter B.
Bloch U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Herbert Grossman Alternate Chairman ASLB Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074 Dr. Walter H. Jordan Carib Terrace Motel 522 North Ocean Blvd.
Pompano Beach, FL 33062
\\
Ellen Ginsberg, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels
, & Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201 Nicholas Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds
)
1200 17th Street, N.W.
Washington, D.C.
20036 Stuart Treby, Esquire Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S.
Polk Dallas, Texas 75224 Mr. W.G. Counsil Executive Vice President Texas Utilities Generating Co.
Skyway Tower, 25th Floor 400 N. Olive Street Dallas, Texas 75201 l
T l
e Mr. Roy P. Lessy, Jr.
Morgan, Lewis & Bockius 1800 M Street,,N.W.
Washington, 20036 Mr. Thomas G ignan, Jr.
Ropes & Gray 225 Franklin Street t
Boston, Massachusetts 02110 d
Alan S. Rosenthal, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. W. Reed Johnson Administrative Judge Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas S. Moore, Esq.
Administrative Judge Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Lando Zech, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555 James Asselstine, Commissioner U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.