ML20195G686
| ML20195G686 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/03/1985 |
| From: | Haughney C NRC |
| To: | Beach B NRC |
| Shared Package | |
| ML20195G683 | List: |
| References | |
| FOIA-85-699 NUDOCS 8811300005 | |
| Download: ML20195G686 (176) | |
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APPENDIX B SP_ECIAL UNIT _1 '[
CABLE TRAY SUPPORT "AS-BU_ILT" PROGRAM INSPECTION U.S.14UCLEAR REGULATORY COMISSION REGION IV 1
NRC Inspection Report: 50-445/85-19 Construction Permit: CPPR-126 .
c Docket: 50-445 Category: A2
, bplicant: Texas Utilities Electric Company (TVEC)
Skyway Tower 400 North Olive Street <
Lock Box 81 Dallas, Texas 75201 >
- Facility Name
- Comanche Peak Steam Electric, Station (CPSES), Unit 1 ;
Inspection At: Glen Rose Texas f Inspection Conducted: November 18 - December 18, 1985 !
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l j Inspectors:
R. E. Lipinski, NRR Date i l
7 J. R. Dale, RIV Consultant Date l i i
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i E. A. Solla, NRR Consultant Date f i
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C Langowski, NRR Consultant Date l
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Reviewed By: ~
I. Barnes, Group Leader, Region IV CPSES Group Date Approved: -
I. F. Westerman, Chief, Region IV CPSES Group Date ;
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Jnsp_ection Summary
_ Inspection Conducted November 18 - December 18, 1985 (Report 5.0-445/85-19)
Areas Inspected: Special, unannounced inspection of the Unit 1 cable tray support as-built inspection program and the related QA audit program for this f activity. A management meeting was held at the conclusion of this inspection period. The inspection involved 224 inspector-hours onsite by six HRC personnel. 7
_Results: Within the two areas inspected, three violations (failure of walkdown teams and QC inspectors to correctly determine and verify, respectively, as-built cable tray support attributes, paragraph 3.a-3.h; failure to perform periodic audits of the as-built cable tray support program, paragraph 6; use f of weld angles in cable tray supports which were below the permissible minimum ;
values, paragraph 5) were identified.
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l DETAILS
- 1. _ Persons Contacted
('*)(**)R. A. Muldoon, Ebasco
(*)R. B. Bronson, Ebasco (a)R. C. Iotti, Ebasco
(*)(**)R. M. Kissinger, Texas titilities Generating Company (TUGCo)
(*)R. Stever, B&R
(*)(**)C. R. Hooton, TUGCo
(*)(**)R. E. Camp, TUGCo
(*)(**)W. F. Rockwell, Ebasco C. A. Briggs, TUGCa
(**)H. A. Harrison, TUGCo (aa)P. Halstead, TUGCo
(**)T. Brandt, TUGCo *
(**)J. S. Marshall, TUGCo
(**)J. Vorderbrueggen, Impe11 H. A. Levin, TERA The NRC inspectors also interviewed other applicant employees during this inspection period.
(*) Denotes those present during November 22, 1985, exit meeting.
(**) Denotes those present during December 5, 1985, exit meeting.
- 2. . Cable Tray Support As-Buf._1t Inspect _ ion Program The inspection was performed to verify the adequacy of the Unit 1 as-built inspection program for cable tray supports. The bases used for this inspection'were: (a) TUGCo Nuclear Engineering (TNE)
Procedure THE-AB-CS-1, Revision 1, dated September 30, 1985, "As-Built Procedure, Cable Tray Hanger Design Adequacy Verification;" and (b) the as-built red ifned drawings which were prepared by TUGCo walkdown teams (composed of a walkdown engineer and a QC inspector) in accordance with Procedure THE-AB-CS-1, Revision 1.
From a total of 789 cable tray supports that had been through the walk-down program, a total of 66 steports were selected by the NRC ir,spection team using a random number generator. These supports were then broken e
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. o down by building and type. An engineered sanple of 32 supports was selected. This sample included the following cable tray supports:
Reactor Building Fuel Building CTH-1-42 CTH-1-1695' CTH-1-239 CTH-1-1716 CTH-1-4738 CTH-1-1742 CTH-1-5488 CTH-1-1845 CTH-1-5517 CTH-1-1853 CTH-1-5538 CTH-1-1963 CTH-1-5757 CTH-1-5352 CTH-1-5817 CTH-1-7047 CTH-1-5873 Control Room CTH-1-5942 C1H-1-7199 CTH-1-5976 CTH-1-6041 Safe uards Building CTH-1-6497 CT 207 CTH-1-6517 CTH-1-607 CTH-1-6559 CTH-1-636 CTH-1-6631 CTH-1-707 CTH-1-12075 CTH-1-13026 As a result of this inspection, deficiencies were identified in major attributes associated with the Unit I cable tray supports red-lined as-built drawings.
- 3. Summary of _ Deficiencies (TNE-AB-_CS-1)
A summary of the findings from this inspection which appear to be in violation of 10 CFR 50, Appendix B, Criterion X and TNE AB-CS-1, Revision 1, are as follows:
- a. Tray size (1) g edure Requiremeny THE AB-CS-1, Revision 1, Section 4.2.2.B.7 requires verification of the following:
"7. Cable Trays
- a. Width
- b. Depth
- c. Location within Support" e
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! CTH-1-5817 is recorded as a 4" x 12" tray. It was found to be i a 4" x 24" tray by NRC.
- b. Tray Span (1) Pro _cedure Requirement l 4 TNE-A8-CS-1, Revision 1, Section 4.3.2. requires verification !
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of the following, ,
"6. Indicate span from support to support . . ." l i
i (2) Findings
- CTH 1-5817 conduit span was in error by l' 6",
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- CTH-1-239 spans were in error by 8" and 10". l
- c. Tray Clamps (1) Procedure Reouirement THE-AB-CS-1, Revision 1, Section 4.2.2.B.6 requires verificat'6n of the following: ;
"a. Clamp Type (Attachment D) l
- 1. Bolted i
- a. Flat washer or bevel washer {
- 2. Welded
(2) Fin _ dings
- CTH-1-12075 cable tray clamp was recorded as a Type J "Heavy Outy Clamp" h" 5iate welded to c.hannel. Actual clamp 'vas a Type C bolted clamp.
- CTH 1-1845 cable tray clamp G-2 was recorded as a bevel washer only, actual clay contained a bevel and a flat washer.
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- d. Member Size
. (1) Procedure Requirement THE-A8-CS-1, Ravision 1, Section 4.2.2.8 requires verification of the following:
"2. Hanger Configuration
- a. Member shape and nominal size per AISC (see Table 13 Or AISC manual of steel construction 7th edition)."
1 (2) Findings CTH-1-5787 angle shape under tray was identified as 5/16" in thickness. Actual thickness was 7/16".
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- e. Weld _ Qualitative Measurement (1) Procedure Requirement
- TNE-AB-CS-1, Revision 1. Srction 4.2.2.8. requires verification of the following-
) "3. Member Connection Details (Connection to support member)
. in accordance with Reference 1-G."
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- Reference 1-G, QI-QP-11.10-9 Cable Tray Han er As-Built,
! (Inspection / Verification), Revision 2, Sect on 3.3.5
! requires verification of the following:
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' "3.L 5 Welding Inspection 3.3.~5.1 General
< Welding shall be inspected for quantitative and I qualitative attributes as listed below without i paint removed.
i Quantitative l a. Type of Weld (fillet, flare b.evel, l
groove,etc.)
- b. Configuration (two sides all around,
+ etc.)
l c. Weld Length
, d. Weld size" i
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- In Supplementary Safety Evale tion Report (SSER) 17, Section 3.8.3 which addresses FSAR Amendment 55, the applicant has been given approval to use Nuclear Construction Issue Group (NCIG) document NCIG-01, Revision 2 "Visual Weld Acceptance Criteria for Structural Welding to Nuclear Power Plants" (WAC). . WAC specifies the following acceptance criteria for fillet welds:
"3.5.2.2 Acceptance Criteria: a fillet weld shall be permitted to be less than the size specified by 1/16
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for % the length of the weld."
(2) Findings
- CTH-1-5942 fillet weld #1 was found to be 1/16" undersized from that recorded for greater than 1/4 of its length.
- CTH-1-1845 fillet weld detail B was found to be 1/16" undersized from the recorded for greater 1/4 of its length, i e CTH-1-5517 fillet weld #1 was found to be 1/16" undersized
-from that recorded for greater than 1/4 of its length. ,
- CTH-1-5488 fillet weld was round to be undersized 1/16" from that recorded for greater than 1/4 of its length. ,
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- CTH-1-4738 fillet weld was found to be undersized 1/16" ll
- from that recorded for greater than.1/4'Gf its length.
- CTH-1-12075 measurement of the top nd ttom of member weld lengths was recorded in reve .
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- CTH-1-1853 measurement of the top qbt er weld lengths was recorded in reve e{. ;
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- f. Dimensional Measurements (1) Procedure Requirements
- THE-AB-CS-1, Revision 1, Section 4.2.2. requires
- verification of the following
"A.2 Elevation (of lowest horizontal member)
B.2. Hanger Cc.itiguration
- b. Dimension,~ Including addition of required i dimensions.
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- f. Expansionanchorboltprojectionand/or embedment (Table 12).
8.4 Support Anchorage
- e. Be't distance from heel of angle or channel, etc. (Gage 'G' dimension)"
(2) Findings
- CTH-1-5942 dimension to edge of column was in error 1".
- CTH-1-1845 dimension between attachments was in error l' 3/4".
- CTH-1-1963 elevation was in error by 3" (Elevation A-A).
- CTH-1-42 gage dimension kas in error 1".
- CTH-1-239 gage measurement was in error 5/16".
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- CTH-1-1845 bolt projection measurement was in error 3/4"
- CTh-1-7047 bolt projection .fr ;;U,( #1, #2, and #3 was in error greater than %".
& CTH-1-5976 bolt projection measurement was in error 1/2"
- g. Bolt _ Size (1) _ Procedure Requirement
- 'THE-AB-CS-1, Revision 1. Section 4.2.2.B requires verification of the following:
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, "3,b Bolts 1-Size" 1
(2) Findings CTH-1-6631 hex nut was standard when a heavy hex nut was specified,
- h. Member _ Orientation (1) Procedure Requirements
- THE-AB-CS-1, Revision 1, Section 4.2.h.B requires verification of the following:
"2. Hanger Configuration"
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(2) Findings
- CTH-1-1845 angle to wall was rotated 90 degrees / rom
- frawing detail.
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- 4. Other Findings Related to TNE-AB-CS-1
- a. Measurements Criteria were not provided with respect to the required acurac j of
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measurements in obtaining THE-A8-CS-1 red-line data. Variations in bolt projection and gage measurements were identified which appear F to be attributable, in part, to the many different methods used to !
make the measurements. The applicant has indicated that TNE-AB-CS-1 will be revised to provide clear guidance with respect to '
measurer.ents. This in considered an open ites (445/8519-0-01). .
The NRC inspectors compared NRC mehsured dimensions and the red-line l ter:oeded dimensions to the tolerances given in tables attached to THE-AB-CS-1. Measurements which violated these tolerances are identified in paragraph 3 above,
- b. Inaccessibility The NRC inspectors identified that there were attributes which appeared accessible, althougn they had been identified as !
inaccessible.
The applicant stated that the training provided to the walkd v personnel instructed that measurements be taken only if they were fully accessible at the support. Further, the training provided gave instruction that all attributes of a particular component be fully accessible before it is inspected.
The applicant has indicated that the term inaccessible will be clarified by revision to TNE-AB-CS-1, i
This considered an open item (445/8519-0-02).
violation of the American Weldir. (AWS) 01.1 Society Code. The quantita- '
tive weld attributes, such as toel, were inspected by the applicant only t for the first 100 supports in accordance with THE-AB-CS-1. It was there- t fore not a requirement of the Unit 1 as-built cable tray program to verify weld bevel beyond the first 100 supports inspected. - -
The FSt,R, Table 17A-1 states that cable tray hangers will be construc'ed in accordance with American Institute of Steel Construction (AISC) Coce.
The AISC Code, Seventh Edition, Page 4-131, states that "The AISC Specification and the American Welding Society exempt from tests and qualification most of the common welding joints applicable to steel structures. When the joints . . . as designated as prequalified . . ."
Gibbs and Hill, Inc., Specification 2323-55-168, Section 6.4, dated May 7, 1975, states, "Welding construction shall conform to AISC Specifi-cation for Design, Fabrication and Erection of Structural Steel for Buildings and AWS D1.1."
1he AWS D1.1-75 Code, Section 2.9.2.4 states with respect to wald groove angle, "The groove angle is minimum. It may be detailed to exceed the dimension shown by no more then 10 degrees."
The weld bevel for hanger drawing CTH-125538, full penetration weld #2, was found to be 30' by the NRC inspector. In addition, the weld bevel for hanger CTH-1-5517,sI" plate full penetration weld, was measured to be 36*-38*. The prequalified weld bevel specified by the hanger drawings (CTH-1-5538 and CTH-1-5517) was 45*.
The failure to control weld bevel angles appears to be in violation of the AWS D1.1 Code and 10 CFR 50, Appendix B, Criterion IX.
- 6. Audit of As-Built Cable Tray _ Support Inspection Program The NRC inspectors could find no objective evidence that the cable tray support as-built inspection prugram had been audited or scheduled to be audited.
The failure to ' establish planned periodic audits of the cable tray support as-built inspection program is considered to be in violation of 10 CFR 50, Appendix B, Criterion XVIII,
- 7. Applicant Corrective Actions The applicant promptly initiated the following corrective actions:
- TUGCo Engineering was requested to document and evaluate each finding to determine corrective action on November 22, 1985.
- Stop Work was issued to field activities associated with Unit 1 as-built / inspection program on November 26, 1985.
- A Ccrrective Action Request was issued on November 26, 1985.
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- A TUGCo investigation was initiated to determine the cause. Personnel actions have resulted from the investigation underway. ,
- Inspection of the as-built program Unit 2 was initiated to determine ;
if similar problems existed in Unit 2.
- The evaluation of actions necessary to resume the as-built program j j is in progress. ,
- 8. Exit Meeting An exit meeting was held on November 22, 1985, to discuss the findings ,
i from this inspection. A return exit meeting was held on December 5, 1985, i to discuss the final findings. I
- 9. Managemen_t Meeting l
l A management meeting was held with TUGC6 corporate managers to discuss i
- the findings from this inspection on December 18, 1985. Potential ,
escalated enforcement action was discussed. ,
Those present included:
TUGCo W. G. Council, Executive Vice President l J. W. Beck, Vice President, Licensing, Quality Assurance and Fuels P
I NRC R. D. Martin, Regional Administrator, Region IV
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V. S. Noonan, Director, Comanche Peak Project ;
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In Reply Refer To: ;
Docket: 50-445/85-19 ,
Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive, L.8. 81 Dallas, Texas 75201 This refers to the special inspection conducted by Mr. T. F. Westerman, members of the Region IV Comanche Peak Group, and NRR personnel during the period of November 18 through December 18, 1985, of activities authorized by NRC Construction Permit CPPR-126 for the Comanche Peak Steam Electric Station, Unit 1, and to discussions with Mr. R. E. Camp and other members of your staff on November 22, 1985, and December 5, 1985.
> The purpose of the special inspection was to evaluate the Comanche, Peak Steam d
Electric Station, Unit 1 as-built cable tray in:pection program. As detailed in Enclosures 1 and 2, the inspection identified multiple instances involving the failure to properly inspect and document as-built cable tray attributes.
In addition, violations were identified relative to both the failure of the d QA programs to establish audits of the Unit 1 as-built cable tray inspection program and the use of incorrect weld bevel angles. The violations and related NRC concerns were discussed with you in the management meeting held on December 18, 1985.
The violations have been separated into civil penalty and non-civil penalty categories. With respect to those items assessed a civil penalty, we have evaluated their significance and believe that they collectively indicate a i
significant weakness in your QA/QC program with respect to the oversight of inspection activities.
The violations assessed a civil penalty have been categorized in the aggregate as a Severity Level III problem in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions,10 CfR Part 2, Appendix C (1985). The base civil penalty for a Severity Level III is j
$50,000. The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstances. In this instance, the base civil penalty is
! reduced by 50% because of the prompt and extensive corrective action taken by Texas Utilities Generating Company.
r Therefore, to emphasize the need for increased management attention i'n the l
control and oversight of inspection activities, I have been authorized, after i consultation with the Director, Office of Inspection and Enforcement, to issue i
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RA RIV:CPGTT C: CPG y AD:DRS& ES I IBarnes;ap TVesterman son 0Powersk R0Hartin EJohp/86 1/6 I/11/86 / /86 l l/g3/86 I/l)/86 1
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i Texas Utilities Generating Company l the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-Five Thousand Dollars ($25,000) for the violations
't described in the enclosed Notice.
You are required to respond to the enclosed Notice of Violation. You should
- follow the instructions specified in the Notice when preparing your response.
In your reply you should give particular attention to both those actions designed to increase the ef fectiveness of your QA/AC program with respect to current project controlled inspection activities and your determination that similar conditions do not exist in other project controlled inspection 1ctivities. Your response to the Notice and the results of future inspections will be considered in determining whether further enforcement action is i appropriate.
The response directed by this letter and the enclosure is not subject to t.he clearance procedures of the Office of Management and Budget as required by the Paperwo*k Reduction Act of 1980, PL 96-511. ,
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, Robert D. Martin redi onal Administrator
Enclosures:
- 1. Appendix A - Notice of Violatlon and Proposed Imposition of Cieil Penalty
- 2. Appendix 8 - NRC Inspection Report 50-445/85-19 cc w/ enclosures:
Texas Utilities Generating Company ATTN: J. W. Beck, Vice President Quality Assurance, Licensing, and Nuclear Fuels -
Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 t
Texas Utilities Generating Company DISTRIBUTION bec w/ enc 1:
POR SECY CA JMTaylor, IE RVollmer, IE JAxelrad IE JLieberman, ELD Enforcement Officers RI, RII, RIII, RV LCobb, IE FIngram, PA JCrooks, AE00 8 Hayes, 01 SConnelly, CIA '
DNussbaumer, OSP IE:ES File IE:EA File BSummers, IE (1tr hd)
DCS RIV Distribution:
Regional Administrator, RMartin Division Director Branch Chief OPowers Inspector (2 copies)
CWisner (1tr hd)
R0oda RIV Files 6
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- 1. Allegation Category: QA/QC 4, Training and Qualification
- 2. Allegation Number: AQ-23, AQ-24, AQ-26, AQ-27, AQ-28 and AQ-108
- 3. Characterization: It is alleged that quality control inspectors are not qualified due to inadequate training, that there was widespread cheating on certification exams, and that training records are incorrect. There are also allegations that a small group of quality control (QC) inspectors in the design change verification group (DCVG) and a group of QC inspectors inspecting 2500 class 5 hangers were inadequately trained.
4 Assessment of Safety Significance: The NRC Technical Review Team (TRT) reviewed 5 Brown & Root (B&R) procedures and 21 Texas Utilities Generat-ing Company (TUGCO) procedures to determine if they complied with ANSI N45.2.6-1978, Regulatory Guide 1.58 Revision 1, and SNT-TC-1A-1980. The TRT also reviewed the training and certification files for 102 QC person-nel (13 Level ! QC inspectors, 76 Level !! QC inspectors, 8 Level !!! QC ins:ectors, and 5 QC clerks). In addition, the TRT interviewed eight Level II OC inscectors, the training coordinator for ASME QC inscectors, anc.see training ecordinator for tne non-ASW QC inspectors. Of the 102 OC personnel whose training records were examined, 79 were ASME-certified.
In aedition, 37 of the 79 A$wE inspectors had non-ASME certifications for Hilti bolts. The TRT revie ed tests fc,r Level II visual weld (VT) inspec'-
tors and Level I and Level II mechanical fabrication (MIFI) inspectors.
The ASME personnel training and certification program was established by B&R procedure CP-QAP-2,1, a general corsennel training and certification procedure, and the more specific B&R procedures Ql-QAP-2.1-5, "Training and Certification of Mechanical Inspection Persennel," and QI-QAP-2.1-1, "Noncestructive Examination Personnel Certification." These orecedures nere detailed and ret or exceeded the requirements of ANSI N45.2.6, Regulatory Guide 1.59, and $NT-TC-1A-1990. The requirements for each * -
spection discipline and level were well defined, with inspector education level and experience specified for each level of inspection. The proce-cures contained outlines for certification and recertification, and in-cluced detaile e-- % es for certification training. On-the-job train-ing (0)T) was alt. ..: 'ree for each inspection cisciplice.
There were two areas in the OC testing program which were poorly defined in the B&R procedures. The first area was that the type of test monitoring (i.e., proctor) for certification testing was not specifically defined.
Second, there was no specific program for periodically establishing new tests, except when procedures were changed. .
One other area of concern to the TRT was P&R's and the Texas Utilities Electric Company's (TVEC's) interpretation of the applicable ANS! standard, ANSI N45.2.6, paragraph 3.5, "Education and Experience Recommendations,"
delin(4tes the education and experience recem.?endation for each le al of '
inspeetpr The standard also states that other factors which may demon-stratecahabilityinagivenjobarepreviousperforranceorsatisfactory completion of capability testing. Paragraph g of the "Value/!mpact of Action" in Regulatory Guide 1.58 states: "Regulatory position 6 of the regulatory guide states that a comitment to ccmply with the regulatory guide will n'enn that the education and experience recomendations of the e
t standard will be followed." B&R and TUEC procedures quote the ANSI guide-lines as their standard of inspector certification; however, in practice, they did not follow the guidelines. Their system followed the exception by using "other factors" as the normal method for qualification.
The non-ASME personnel training and certification program was governed '
by TUGC0 procedures CP-QP-2.1, "Training of Inspection Personnel,"
CP-QP-2.3, "Documentation within QA/QC Personnel Qualification File," ,
and TUGC0 quality instructions QI-QP-2.1-1 through QI-QP-2.1-19.
Although, TUEC had committed to ANSI N45.2.6 and Regulatory Guide 1.58, the TRT has the following concerns ab:ut the lack of specificity of its procedures and quality instructions.
(1) There were no requirements for verification of education and work experience.
(2) Personnel capabilities were not specifically defined by' levels (I,
!!. !!!). r (3) The specific inspection disciplines were addressed in separate quality instructions and were administered by a cognizant quality engineer in that discipline. There was no one individual who -
controlled tne training programs. As a result, the overall quality training program lacked cohesion.
(4) Recertification could be accomplished by a simple "yes" from an ,
inspector's supervisor.
(5) There were no guidelines for using waivers for OJT, even though i waivers were frequently used, p L
(6) The certification testing program had many problems, including:
(a) No requirement for additional training between a failed test and a retest.
(b) No time limitat.icn en how soon an individual could retake a failed exam.
(c) No assurance that the same test would not be given consecutively.
(d) Two different scoring methods were used to average the results i when two tests were taken, (e) No guidelines on how or when a question could be disqualified i on a test. '
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( No program for establishing new tests, except when procecares ,
Ichanged.
I (g) No specific details on how tests should be monitored.
(h) No limits on how many times an individual could be tested for l t
4 specific certification.
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Many of the above concerns are also addressed in Safety Evaluation Report Supplement 7. Electrical and Instrumentation Category 7, allegation AQE-8.
In reviewing testimony and training and certification files, the TRT !
identified the following specific problems which demonstrated an overall weakness in the QA training and certification program.
, (1) Of all the B&R and TUEC training ano certification records reviewed, 20 percent contained no verification of education and/or past employ-ment and work experience. In addition, there were several instances where verification took place after the individual was certified; as t
, long as 2 years later, in one case. There was one instance where an individual listed work experience on his resume that was false.
After receiving correct information from the individual's former employer, B&R noted the fact, but took no further action concerning the person.
$ (2) There were ten instances where the results of a B&R Level I certifi-cation test were recorded on the Level !! certification. The time ;
oetween the Level I test and the issuance of the Level !! certifica- ;
tion varied from 1 month to 6 months. Normal practice was to test incividuals at each level of certification. The TRT was unable to determine why these ten individuals were not tested in the normal .
way.
(3) There were six instances where, after failing a certification test, !
l applicants were permitted to take the identical test; in some cases 1 as soon as the next day. This occurred with both B&R and TUEC !
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(4) There was one instance where a S&R certification was issued, but was ,
3 J not signed or dated. The explanation given was that this individual l would not be used for inspections. ;
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l (5) There were two instances where white-out was used on certification d
exadnations, contrary to CP-QP-2.3, para;raph 3.3.1(h). ;
(6) Ouring one certification examination, two people observed a TUEC QC-inspector applicant leaving the testing area, going to his desk,
' reading something, then returning to the testing area. Even though i I his certification was subsequently voided, tests were supposed to be i
- monitored and this one was not. This incident raised questions about how closely the monitoring policy was being followed. There was no apparent corrective action taken,by TUEC in this. case.
In reviewing B&R and TUEC records, the TRT found seven cases where the cualification of inspectors appeared to be questionable: '
(1) he individual, a millwright prior to his transfer to QC, had no back-grodndinQCinspectionornondestructiveexamination. He was issued l a Level.!! certification for liquid penetrant (Lp) inspection work 4 i months after his transfer to QC, and a level Il certification fe l
I magnetic particle inspection work 7 months after his transfer. ;
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(2) Another individual was a carpenter prior to his transfer to QC inspec-tion and had no inspection background. Two months after his transfer to QC, he was issued Level !! certifications for VT, MIF! and mechan-ical equipment inspector. After 3 months, he was issued a Level !!
certification for LP.
(3) A third individual was a laborer with no inspection background prior to entering QC. Four months after transfer to QC inspection, he was issued Level !! certifications for LP and VT.
(4) A person who had been an iron worker prior to his transfer to QC had no experience in inspection. Less than 1 month after his transfer to QC inspection, he was issued Level !! certification for VT and MIFI.
(5) Another person was a ficorhand on a drilling rig prior to entering QC and had no inspection background. Six months later he was issued a t.evel !! certification for VT, and 7 months af ter he entered QC inspection he was issued a Level !! certification for LP, (c). In another instance,'a carpenter's helper with no background in inspection was transferred to QC. Seven months after the transfer, he was issued a Level !! certification for VT; 8 months after the transfer to QC, he was issued Level !! certification for magnetic .
particle and LP.
(7) An ANI liaison person with no background in inspection was also t,ransferred to QC. One month after his transfer, he was issued a Level !! certification for VT, and 2 months after his transfer he was issued a Level !! certification for MIFI, In an earlier review, B&R had found that a laborer was hired into QC in-spection with no work experience in QC inspection. Two months after his hire date, he was certified as a level ! inspector for Hilti bolts. A tre-orandum was sent to the QA manager requesting a waiver of the 1 year experience requirement on the grounds that the individual had received suf ficient OJT and had passed a test. The waiver was granted by the Qa manager. B&R subsequently discovered that this inspector's work was tot. ally unacceptable and all of his inspection work had to be reinspected.
Tne requirem,its in QI-QAP-2,1-5 were intended to prevent an individual from taking t t same examination consecutively and specified that a person who failed th- e consecutive examinations for the same certification was not eligible t a qualification and certification in that inspection ac-tivity. The B, , practice of not retaining f ailed examinations *nde it difficult to determine if an individull had failed three examinations or if he was retaking the same examination.
With Nspect to the allegation that specifically questions the qualifica-tions sf the QC inspector in the DCVG, the TRT reviewed the qualifications of all fike QC inspectors in that group. The TRT concluded that all inspec-tors were qualified, with the possible exception of an individual whose certification was limited to document-review verification on),v.
In reviewing the allegation concerning the inspection of 2500 class 5 suc-ports. the TRT reviewed the gnlifications for 19 inspectors involved in 4
- - - - - - , , , - , , - , - - - - - . . - - - - ~ ~ ~ ~ . - , -- ~-m- w
,' e that activity. Only one inspector, was found to have questionable qualifications.
In the TRT's review of craft personnel who transferred into QC inspection, five individuals were found to have questionable qualifications.
With the exception of the one case where TUEC identified an individual who had cheated on a certification test, the TRT could not find any docu-mentation that there was widespread cheating on certification examinations.
- 5. Conclusion and Staff Positions: Based on its review of the allegation concerning qualifications of inspectors assigned to the DCVG, the TRT concludes that these inspectors were qualified for the task to which they were assigned. The allegation was not substantiated.
The TRT reviewed the allegation that specifically questioned the qualifi-cations of inspection personnel inspecting seme 2500 class 5 supports. The TRT reviewed the qualifications for 19 inspectors involved with this activi-ty and concluded that only 1 inspector had questionable qualifications.
Tne staff position is that, altnough a small percentage of the inspectors were not cualified, the quality of some of the . hardware may be suspect; therefore, the allegation has substance. ,
With respect to the allegation concerning widespread cheating on QC certification tests, the TRT could find no evidence during interviews or documentation reviews to substantiate this allegation, with the exception of the one case documented by TUEC.
Based on a TRT review of allegations concerning inspector qualifications, certification, and training in general, the TRT concludes that the train-ing and certification program as written for the ASME inspection personnel is adequate with the exceptions already noted. However, in actual practice, this program is not followed scrupulously.
In the non-ASME training and certification program, the TRT found a lack of progra e ntic controls to ensure that the program achieves and maintains reovirements as set forth in 10 CFR part 50, Appencis B. problem areas were: (1) in the docueentation for qualification, including verification of education and experience; (2) in the training and certification program; (3) in the racertification program; and (4) in the certification testing program. The TRT concludes that these deficiencies in procedural require-r.ents and guidclines in the training and certification programs have potential safety significance. .
The TRT does not infer frem the above that all TUEC a'nd B&R inspectors are unqualified. However, identified inspection deficiencies (as enumerated in the TRT's Electrical and Civil and Structural SSERs) or lack of inspec- .
tion tTereof, indicate a root problem with inspection qualification that isdifepglytraceabletoTUEC'sandB&R'slackofprogrammaticcontrols and use of minimum requirements for the inspection certification program.
In a meeting with the allegers on December 10, 1984, the TRT presented the results of the assesseent of the allegations and the TRT's conclusions. A brief discussion ensued. There were no major items of disagreement.
5
- 6. Actions Reovired:
- 7. Potential Violations: Criterion V of 10 CFR 50, Appendix 8, requires that "Activities affecting quality shall be prescribed...and accomplished in accordance with... procedures...."
The following are examples of the applicant's failure to adhere to proce-dural requirements:
- a. B&R procedure CP-QAP-2.1, paragraph 3,1,2, states that the QA administrative assistant shall initiate requests for verification of an applicant's previous education and employment experience from those institutions or employers whose activities would substantiate the applicant's qualifications. A documented telephone verification may be used, provided that written requests for verification have been initiated.
Contrary to the above, of 102 training and certification records re-viewed for tSME and non-ASME QC inspection. 20 percent did not con-
. tain verification of education or employment experience,
- b. B&R procedure QI-QAP-2.1-5, paragraph 3.2.3, states that "Reexaminations acministered to the same individual for the same activity or certifi-cation shall be prepared and administered by the site mechanical Level !!! or his designee in a manner which precludes the individual from taking the same examination consecutively."
Contrary to above, there were six instances identified in the review of ASME and non-ASME QC files where an incividual was given the same examination consecutively,
- c. TUGC0 procedure CP-QP-2.3, parsgraph 3.3.1(h), states that white-out or liquid paper shall not be used on an examination.
Contrary to the above, there were two instance 3 identified in the review of ASME and non-ASME QC files where whiteeut was used on an examination.
d, B&R procedure QI-QAP-2.1-5, paragraph 2.1, states that personnel training, qualification, and certification requirements shall be implemented at CPSES to meet the intent of AN5! N45.2.6-1974.
Contrary to the above, seven ASME and non-ASME QC inspectdrs whose cualifications did not meet the sintent of ANS: N45.2.6 were identi-fied in the review of ASME and non-ASME QC files.
- 8. Attachtents: Nene.
Referfice Documents:
- 1. E$Rprocedures: CP-QAP-2,1, CP-CAP-2.3, QI-CAP-2.1-1, and QI-QAP-2.1-5, 6
~ - - - -
i
.
- l
- 3. AN5! N45.2.6-1978.
4 Regulatory Guide 1.58, Revision 1.
- 5. Recommended practice $NT-TC-1A, "Personnel Qualification and Certification in Nondestructive Testing," dated 1980. -
- 6. QA Personnel Certification and Training Files.
- 7. CPSES F5AR 17.1.2.
- 8. RIV Inspection Reports 82-11 and 80-15.
- 9. A-5 Interview August 1, 198A, pp. 34-41.
- 10. A-1 Interview August 1, 1984, pp. 63-65.
11.' A-3 Intervie. April 26, 1984, pp. 100-105.
- 12. A11eger Interviews, December 10, 1984, pp. 73 85. *
- 9. This statement prepared by:
, a son, IRT Cate Technical Reviewer Reviewed by:
H (tvermore Date Group leader Approvec by:
. y Noonan Date Project Director
\
S
6
. i J t i
i h
- 1. Allegation Category: QA/QC 4, Training and Qualification
~
- 2. A11eastion Number: AQ-73 [
( L
- 3. Characterization:
. 's alleged that document control clerks received j poor training regarci..g how to process travelers and other types of ;
documentation. ;
- 4. Assessment of Safety Sicnificance: The NRC Technical Review Team (TRT)
! found that document control clerts were responsible for: (1) receiving {
j contaciled documents and assuring that the correct document number, revi- l l sion number, number of copies, and all design changes had been incorpersted :
and entered into the design change log book; (2) assuring that all packsges i J requiring travelers had the correct traveler number and date; (3) assuring I that issued dccument packages were complete; and (4) entering the informa-tion into the checkout log used by the document control center (DCC) ;
satellites to assure that complete document packages were returned to the i files. <
l t
! The TRT reviewed Brown & Root (E&R) procedure OCP-3, "CP555 Document Con- i i trol Program" (all revistens), and training records for ten document con-a trol clerks. These records were taken randemly for personnel using time r l sheets dating from July 1981, to the time of the TRT review. A formal i i training and testing program was outlined in DCP-3, Rev.16. for the first
! time; therefore, July 1981, was chosen by the TRT to assure that the period i prior to DCP-3, Rev. 16, was reviewed. The TRT also interviewed five OCC -
clerks who were employed prior to August 1983. The TRT found no recced of !
any formal orientation or training of the 15 do:utent control clerks prior i to the issuance of DCP-3, Rev.16 ( August 5,1933); however, the 5 OCC :
i clerks interviewed stated that they had receivec so-e irformal on-the-job {
- training Following the issuance of Rev.16 to CCP-3, however, records indi- i
! cated that all document control clerks received foreal orientation and !
training and were tested regarding t,he requirements of DCP-3 and its later [
revisions. [
- 5. Cenclusion and $taff Posittens: Based on a revie of B&R procecure OCP 3 f and a saeple of training records for DCC personnel, the TRT concludes !
J tnat this allegat. ion is substantiated. The IRT founc no evidence of any (
l type of formal training program for document control clerks prior to !
I DCP-3, Rev. 16 (August 1983). I
! fi J
A letter summarizing the TRT findings regarding these concerns has
- been j sent to the 411eger. No exit interview will be conducted. f,
- 6. Actions ReQuiredt
} 7. Potential Violations: Criterion !! ef 10 CFR 50, Ap;endix B, states: "The . !
I CA Program shall poilde fce todactrina.1:n and trainini, f personnel per-f formi Ag getivities af fecting Quality, as necessary to assure snat suitaole i
profictency is achieved and maintained."
\
j Contrary to the above, no training or orientation for cocutent control clerks was provided nor required prior to the issuance of DCP-3, Rev.16, in August 1983, 1
- 1 I
- 4. Attachment s: None.
l neference e.eu.enti:
Brown & Root procedure DCP-3, all revisions.
l 1.
- 2. Training records for ten document control clerks.
i
- 3. Interviews with five OCC clerks. l 4 A-2 Interview, pp. 88-90 f
i
- 9. This statement prepared by: _
li V. Watson, TRT Date Technical Reviewer i Reviewee by: i hercert Livermore Cate [
Group Leacer
- l l
Approved by:
Vincent Noonan Cate l e
project Director i
t l
I i
l t
t 6
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f i
t I
I P
l' s
a
- 1. Alle;ation Category: CA/QC 2, Documentation Control
- 2. Allegation Number: AQ-102 ,
- 3. Character 1 ration: There is a concern that a supervisor's action in a docu-rent control center (OCC) satellite resulted in procedural violations which were not reported to Texas Utilities Electric Company (TVEC) cuality assurance (CA) representatives for the determination of reportability to the NRC as reRuired by 10 CFR 50.55(e)
- 4 Assessment of Safety Significance: This concern is related to a supervisor who reportedly advised personnel that because information was entered into the computer they .ere not responsible for continuing to update the manual satellite log book, that they were not responsible for reporting errors detected in the computerited design change legs, and that personnel were never inforeed that the OCC cathode ray tube group (CRT) was to be notified when a document was recuented through the DCC satellite. ,
!n assessing the corcern, the NRC Technical Review Team (TRT) reviewed the TUEC prececures for controlling documentation within the OCC and its satel-lites, for the impletentation of these precedures, and for reporting vio-1ations per 10 CFR 50.55(e) . The TRT also revie ed the findings of the .
NRC Construction Appraisal Team (CAT) audit, NRC Regio 3 IV inspection reports and TUEC audits of the OCC, and conducted interviews with the OCC/
satellite and design change tracking group personnel.
Between February and May 1983, both CAT and Region IV inspections identi-fied recurring documentation deficiencies. Typical deficiencies included drawings out-of-date by up to several subsequent issues and crawings which had incc clete title and revision blocks. On May 31, 1993, a Notice of Violation (50-445/83-16 and 50-446/S3-12) was issued to TUEC for inaceauste docuteetation control at Cemanche Feak Steam Electric Station (CPSES)
(Criterion VI of 10 CFR 50 Appendia B). Substantial corrective action was recuired to correct the identified deficiencies. part of the corrective action taken by TUEC was the estabitsh-ent in August 1953, of the DCC satellites to issue and control design coeurents.
In August 1933, Brown & Root (S&R) establisned a monitering team to audit the OCC satellites on a continuing basis. A charter for the team was delineated in procedure OCP-3. The TRT's review of the monitoring team's audit findings from August 1983 to July 1984, indicated that the recurring problem of drawing accountability was still an area of concern, but had been diminishing since of the monitoring team began reporting results to the assistant project manager in April 1984 The performance data pub-Itshed by the monitoring team in early Apet) 1954 for Unit 1 sstellites (306 and 307) she ed defect rates of 30 percent and 10 percent respectively.
'The topic.of,10 CFR 50.55(e) reporting was previously weatiered ir the D. Eisenhut Wtter to D. M. Spence, dated January S,1955 on page 22, items C
& D. The TRT subsequently learned that the procedure referred to in the letter was not the appropriate precedure for 10 CFR 50.55(e) reportability in the area
' document control. Accordingly, this assess?ent 5.cersedes items C & D in w"er.
4
By mid-May to early June, the defect rates dropped to 5 percent and 1 per-cent. July's deficiency rate for both satellites averaged 1 percent.
Based on the monitoring team's audit findings, the TRT determined that document deficiencies existed in the OCC satellites from August 1983 to May 1984 4 Based on interviews with the OCC and design tracting group personnel, the TRT determined that the portion of the concern regarding the, satellite supervisor's actions, which resulted in procedural violations, was substan-tiated. According to these employees, the supervisor did instruct employees '
not to challenge the computer, not to call the design change tracting group when discrepancies were identified in the computerized design change legs, not to notify DCC CRT of drawings the satellite obtained usin 4
bank, and not to maintain certain manual design change legs. g TRT The the phon 1 earned that this sweerviser's employment was terminated in February 1984 As noted above, the defect rate of 30 percent for satellite 306 was reduced to 5 percent by May and 1 percent by July. It is the TRT's view that the
. hign defect rate for satellite 306 was attributaele in part'to the satel- ,
l lite swce visce's actiens. (Cetails of the TUEC audit re: orts and the menitcring team awcit fincings are accressec in CA/CC Category 2, allega-tions ACE-9, AC-17, 13, 42, ane 53.) The TRT revie=ec the ncnconformance re: ort (NCR) log becks for 1933 anc 1994 These NCRs were generated in .
l accordaace with CP-CP-16.0. Of the NCRs listed in the 1933 log book, 19 i s:ecifically dealt with document control prececural violations. The TRT
- fewa c no evicence that an NCR was generatec basec on a satellite super-visor's actions.
Io assess the p0rtien of this allegation conce**ir; "reportability," the TRT revie.ed site CA procedures cealing with geaeral norconformance report-ing and significant constew: tion ceficiercy re:ceting, i.e., 10 CFR 50.55(e).
' The TET n:ted that E&R d es not have a trocedure(s) specifically ad-i cressing significant deficiency recceting, as they consider 10 CFR 50.55(e) f to be an NRC/ utility relatienship rather than a centractor/ utility rela-
! tionshic. Accordingly, the procedure g:verning 10 CFR 50.55(e) reporting is accressed only in TUEC procedure Co-Op-16.1, tev. 5, "Significant Con-i struction Ceficiencies." In reviewing this prececure, the it' 'nued that
- it lacks s;ecificity regarding =nat is a sigaificant trearcc.- . , scr-l tien of the CA program. In paragraph 2.3, technical failures (for e,arole, ;
design, construction, and performance deficiencies) are defined and identi-I fied as to reportability. However, paragraph 2.3 cefines a CA program reportable deficiency as: "A significant breakce.n in any portion of the t Ovality Assurance Program conducted in accordance with the requirements of ,
Appendia B." ,
t The TRT reviewed both B&R and TUEC NCR procedures to cetermine if non- '
d conforming conditions were to be evaluated for 10 CFR 50.55(e) report-ability, E&R's nonconformance procedure (CP-cap 16.1, revisions 20 and 21) .
s'ates tFat ner.ccr.formance conditions are to be evalwated with respect to
! CP*0P-lE.9, but no specifics are given. TUEC's nonconformance procecure CP-CP-16.0 (Revs 13 and 14) did not address the review of NCRs as potential candidates for 10 CFR 50.55(e) reporting or reference procedure CP-QP-16.1, j "Significant Construction Deficiencies." CP-Qp-16.1 coes delineate in 1 caragraph 3.5 that NCRs were to te reviewed to recognice and identify sis- '
j nificant ceficiencies, as defined in paragraph 2.3, and as quoted ab0ve; l
hewever, this procedgre, whien is used to revie. NCRs, lacks specificity.
4 w
I 1 s 1
o
)
l i As noted previously, the TRT's review of NCR log books for 1983 and 1984 did not reveal any NCRs based on actions of the satellite supervisor which I' resulted in procedural violations. However, it is the opinion of the TRT i that the issue is not that TUEC was unaware of DCC procedural violations, but that the definition of a reportable deficiency in the QA program is tco vague. None of the 19 NCRs documenting procedural violations a:Deared to have been reported to the NRC using 10 CFR 50.55(e) reporting.
4 i
- (The subject of untimely reporting of significant def tetencies to the NRC
! is acdressed in QA/QC Category 7 allegation AQ-113.)
! 5. Conclusion and Staff positions: The concern that the DCC satellite super-Tilor took actions which resulted in procedural violations was substan-i t1ated. The concern that TUEC OCC procedural violations were not reported j to TUEC for potential reportability under 10 CFR 50.55(e) was not sub-stantiated. In the course of assessing this allegation, the TRT deter-
! mined that the TUEC definition of reportable deficiencies is too vague.
. TUEC's NCR procedure lacks references and does not address correlation
) of NCRs to reportability under 10 CFR 50.55(e). The significant deficiency j :recedure lacks 5:ecificity as to what is a significant breakdo=n in any i oortion of tre QA pregram or the trechanism for revie of NCRs for potential
) res:rtability. This concern has generic implications in that significant
- cwality program deficiencies coulc go unreporte
- to the NRC. ,
4
) The source of this c:ncern was not an 411eger; therefore, no exit inter-J view was conducted.
l 6. Actions Reaviced:
1 7. potenti'l Violatiens: Apperdin B, Criterion V cf 10 CFR Part 50 recuires that activities affecting quality shall be prescribed by docutentec proce-cures and accomplished in accordance with these procecures.
l Contrary to the above, nonconformance procedures do not reference or cor-relate the NCRs as potential 10 CFR 50.55(e) re:ortaele items. Proce-
. c'.re CP-CP-16.1, "Significant Construction Deficiencies," lacks specificity I in cefining a significant breakdewn in the QA prog am anc dces not identify cetails on NCR reviews for reportability, f B. M eh ents: None..
Reference Documents:
- 1. Procedure OCP-3, "CP5ES Occu-ent Control Program." Revisi n 16, dated August 5, 1983. i
- 2. Procedure CP-CP-16.0, "Nonconformances," Revision 14, dated July 2, 1984 -
- 3. botedure CP-EP-16.3, "Control of Reportable Ceficiencies," Revision 3, dated June 15, 1954.
- 4. Operating lastructions DCC Satellites, datec Oct:ber 24, 1933.
3
- 5. Operating / Administrative Guidelines for DCC Satellites (Craft), issue date: June 26, 1984
- 6. Interoffice Memo 35-1195, H. A. Hutchinson Jr. to R. Scott, "Schedule -
Transition from Control Numbered Drawing Distribution to Satellite Controlled Distribution," dated June 16, 1983.
- 7. Of fice Memorandum, J. O. Hicks to R. G. Tolson "Comanche Peak Steam Electric Station CAT Inspection - Document Control Ref. letter TUQ-1620," dated May t, 1983.
- 8. Pe-crandum, TUG-1620, R. G. Tolson to Distribution, "Construction Appraisal Team Inspection," April 18, 1983.
- 9. Results of Investigation into A11egattens Rega_rding 0ccutent Control .
at Cceanche Peat by L4w Offices of Bishop, Liberman, Cook, Purcell anc Reynolds, cated July 19, 1984. ,
- 10. Precec.re CF-00-16.*. Revision 5. "Significant Construction Ceficiencies."
- 11. TUGC0 N:nconformance Report Log E oks for 1932 (NCR 82-00001 through 32-02387), 1953 (83-00001 through $3-03312), and 1984 (84-0C001 thr: ugh 54-01969).
- 12. Ince encent Assessment Program for Comanche Peak Steam Electric Station Final Report, precared by Cygna Erergy Services, Volume 1 Section 3 and 4 dated Nove-ber 5, 1983,
- 13. TUGC0 Ceficiency Revie Report tog - ORR C01 through ORR 063, dated April 15, 1932 through August 31, 1934 14 NRC Office of Investigation Report 4 84-025 "Alleged Incrotrieties anc Potential Wrong Doing in the B&R Occueent Control Cemter."
- 15. Drocecure CP-CAD-16.1, Revisions 20 and 21, "Control of Nonconformin; Itats.
- 9. This stateTent prepared by:
1 TRT Cate Technical Reviewer -
t Reviewed by:
H, Livermort, D't' '
Group Leader
- i1 Approved by:
y, gnenan, Cate Project Director 4
s . o L
l 1. A11eastion Cateacry: QA/QC 2. Document Control I
I
- 2. A11eastion Number: AQ-19
- 3. Character 1:ation: It is alleged that "control copy" stamps were in use by see paper flow group (PFG) and cuality control (QC) departments for a period of time. It is alleged that two stamps were issued to the QC department by document control center (OCC) management and used to make QC drawing packages "legitimate." The use of these stamps by any organiza-tion other than the OCC/ satellites is in violation of Texas Utilities Elec-tric Company (TUIC) procedures.
4, Assessment of $afety_ Significance: The NRC Technical Review Team (TRT)
{T) reviewec TUEC DCC and V G procedures and docueents pertaining to this allegation. (2) reviewed a sampling of PFG packages to determine if docu-eentation was current, (3) reviewed OCC/ satellite use of "control copy" stamps, and (4) intervie.ed TUEC representatives and an Authorized Nwelear Insoector ( AN!) relative to the allegation.
Tre TR* fownc snat CCC enragement illsec only one "control cop >" stamp to tne' CC decartment as a result of the issuance of a special inspection services (515) report by the ANI of the Hartford Steam Boiler Inspection and Insurance Company. The 515 report noted that the ma.iority of CC hang *er oackages contained drawings which cbviewsly had been reproduced 'from the original, controlled copies with the c:ntrol numcer marked over in red.
The AN! believed there would be no evidence tmat these drawings were in fact controlled if the drawing was not stampec .ith a red "control copy" sta p. As a result, Bro n & Root (BM) procedere OCP-3 was revised (Revi-sion 15) to specifically eandate the use of red "control copy" stamps for the c pies reprocueed. Prior to this tire, the color of the control copy sta-o was not designated. The sta?p used by tne QC department was "netched" to distinguish it from tho*e usec by the CCC.
The issuance of the $!$ report and the swesecuent stamping of hanger draw-ings by B&R owality engineering ectwrred because of tre manner in which tne welding engineering organi2ation had organilec hanger packages fcr craft personnel. The fabricatorf prepared generic crawings (typicals) that reflected the design of the majority of hanprs. Drawing size was 8h i 11 inches. Upon receipt of the red stamped control copy from DCC, welding engineering sade copiel for affected hanger sackages. The control stamp number, 098, was marked in red. Approsimately 17,000 hanger packages were constructed in this manner. In reviewing the hanger packpges, the AN! noted that the hanger drawings were not stampec in the standard DCC method,andthereforeissuedthe515.bc$wbsecuenttothis,ascorrective action, a procedural change to DCP-3 curred: the EM welding engineering organization would no longer make document distribution, and a specifically identifiable starp was issued to it.e B&R 00 to erocerly stamp any uncon- -
trolled hanger dra.in; within tne hangea packages. CC verified the latest revist:n of any drawing which did not have a rec control %-ber and sta%ed itwithIhe"notchec"controlstap,enteringthe095controlnu-ter.
When B&R QC no longer needed the control copy stamp in question, it was returned to the OCC and defaced so it could not be used again.
The TRT found no evidence in CCC procedures or ; sidelines, prior to Revi-sien 15 of DCP-3, which delineated the use of sne "control copy" sta ps,
. O or stated that the control copy was to be stamped in red. In addition, no evidence was found that written guidalines were issued or that special procedural changes were made to control t,he use of these stamps by B&R QC.
The TRT considers the lack of guidelines or procedures for QC's use of these centrol stamps to be a potential violation. The TRT interviewed TUEC and 84R representatives and found no evidence that "control copy" stamps were issued to any other organization.
The TRT noted that if a control stamp cam.e into the possession of an organ-1:ation outside of OCC, it would not be significant to construction and inscection activities. The document packages used by craft personnel are verified ey the DCC satellite for accuracy and completeness, and the documents are updated with current revisions upon the issuance and return of the document, packages to the OCC satellite, Since only the OCC has access to non sta? ped documents, the possession of a control stamp would serve no purpose in construction and inspection organizations.
Tre TRT telieves that future, unauthorized ute of a control steep would te cifficult arc im;ractical tecause the control stamos of concern are usec cn!,y Oy tre CCC sat,ellites, anc OCC satellites are the only recipients of non-stampec crawings. .In aceition, other contro11ec documents are red-statted in DCC prior to issuarce. Only DCC can enke standard size drawings, anc tre persennel in OCC and its satellites are accountable for the docu-ments in their possession.
- 5. Cerciusion and Staff p: sitters: Essed on the ateve reviews, the TRT found evicence to swestantiate the allegation t. hat c:ntrol sta?ps had been used by organi:ations other than DCC; hcwever, since July of 1?44, DCC stamps have teen adetwately controlled. The TRT learred that a "control copy" sta?p was issued to the QC cepartment in confor*ance with the AN! request that cceweents transmitted to them be "red-stat;ed." Hcwever, methocs for the issuance and control of such stamps were not described in TUIC's c:cueent control procedures. Issuance of the statps to QC had no significant, safety tec11 cation in t,he erection, f abrication, or ccnstruct,icn of safety-related systems, c0 cenents, and structures, and the TET found no evicence that there was a bss of haeger Crawing coetrol as a result of the CC depart, ment's sta-;in; of tne hanger crawings of ecncern.
Although this allegation has gce.e-ic implicat, ions for Unit 2, it is the TRT's position that the multiple levels of checks and verifications asse-ciated with docu?ent packages issued to the craft personnel by the OCC and its satellites wow 14 have detected and corrected potent,tal problems, in a meeting with the alleger on Decfmter 10, 1954, the TRT idesentee the reswits of the assessment of the allegation anc the TRT's .onclusion.
There were no major items of disagreement, and no new concerns or allega-tiens were identified. '
- 6. Actica equired:
- 7. potential Violations: Appendia B,Section V, of 10 CFR 50 requires that Tettvities affecting quality shall be prescribed by dccument procedures and acccFolished in aCCordance with these procecures.
2
_ .- - . - . _ - . . _ . _ - . . __ - __- __ --_ _ - _ _ _ ~ - - -
1 . O I
Contrary to the above, there was no procedure or instruction describing l and controlling the use of the specialized documentation control stamp i tssued to B&R QC for the period from June 1983 to August 1984 L
- 8. Attach. tent: None.
Reference Occuments: ,
- 1. Procedure Nwmber DCP 3 "CP5ES Document Control Program,".all revisions !
I throwgh 18.
i
- 2. TUGC0 letter, Dirs tor, Division of Licensing, NRC, "Comanche Peak ,
5 team Electric Station Units 1 and 2 Allegations Transmitted by ;
t.etter en April 24, 1984," TXX-4180, dated May 25, 1984. '
t
- 3. Hartford 5!$ Record 8355 "Unsatisfactory Section 1 of Brown and Roos l CA Manwal," dated June 7, 1983.
4 E :wn & Rest iette $l$ *355. catec J ee 5, 1983. '
- 5. Allegation s,atetents: A 1, datec March 2, 1984, page 4 i A-49, datec May 1, 1984, page 4 T
- 6. Alleger's interviens: A-1, dated Apri' 16, 1984, pages 12-24 :
A-2, datec April 5, 1984, pages 37,53.
- 7. A-1, close-out interview, dated Cecember 10. 1984 '
i
- 9. This sta',e ent prepared by: _ !
V. Wenczel, Cate ;
Technical Reviewer [
Reviewoo by: , ,
- k. Liver cre. Cate !
Grouc Leacer [
l A:provec by: l V. N:caan, Cate :
Project Director i s ;
k
.. g
- I} .
I 3
i t
0
- 1. Allegation Category: QA/QC 2, Document Control
- 2. Allegation Number: AQ-17, AQ-18, AQ-42, AQ-58, AQ-101, AQ-104, AQ-107 and AQE-9
- 3. Characterization: It is alleged that there was a lack of control of design document packages (AO-17, AQ-18, AQ-58); that craf tsmen and QC inspectors were provided with obsolete or partial (uncwntrolled) design doc, snt pack-ages during construction (ACE-9, AQ-42); that individual documenw were issued against travelers per telephone request (AQ-107); that a document control center (OCC) supervisor authorized the release of partial document, packages to the field (AQ-104); and that the DCC cathode ray tube (CRT) group was not notified when d:cw ents were obtained by t,he "phone bank" and the distribution rowting control lists printouts were not updated (AQ-101).
4 Assess ent of Safety 51cnificance: The issues and concerns identified by the allegers were for the control of design documents relating to safety-related hard are constructed and installed at Cemanche Peak Steam Electric Station (Cp5ES). The TRT c:nfined its assessment of these allegations to safety-related Farc=are cesign cecu ent control for the pericd from August 1951 through June 1984. (The TRT's assessment of the decweent centrol
- system during July, August, and September 1984, is contained in QA/QC Category 2, allegatiens AQ-16, 57, 59, 60, and 61.) 1 Tre NRC Technical Review Team (TRT) compared Br =n and Root (!&R) procedure CCP-3, Rev. 18. "Cp5ES Occurent Centrol Program " to the re:wirements of ANSI N 45.2 and found it to be acceptatie.
The IRT accressed allegations ACE-9. AQ-17, A0-13. AQ-42, and AQ-58, by reviewing Texas Utilities Electric Company (TVEC) audit reports, monitoring ciscrepancy reports (MCRs), anc TUEC menitoring team executive sum. mary re: orts. These TUEC reports were issued frem August 1981 thr:wgh Jwly 1984, and identified the follo ing deficiencies for civil, structural, ;
electrical, mechanical, arc piping safety-relatec systems.
- a. Dra ings in tre field were not of t*e later. . .-
- o. Design change authorizations (OCAs) are ce+porent modification caros (CMCs) were not of the latest revision,
- c. Design docu-entation was missing,
- d. Satellites were not, always wpdated with the latest cesign g e c oent re m ien.
- e. Dramirgs hanging in an open rack were available to craf t and CC '
personeel with no checkout centec1.
f Design change IC; books were net maintained.
- g. Superseded copies and current copies of design decements were 1 filed together.
1
l
- h. Satellite distribution lists were not updated and current. l
- 1. Discrepancies were found between drawings in the satellites and those in the DCC. l
- j. Drawings were missing fecm the satellite files. !
It was determined by the TRT that t.he above deficiencies were of a recur- ,
ring nature. Therefore, it appears that any corrective actions taken by TUEC based wron these deficiencies were ineffective. j In order to evaluate the consequences of the recurring documentation deft-ciencies, the TRT reviewes a sample of completed safety-related doeweenta- t tion packages stored in the TUEC permanent plant records vault (PPRV).
Completed records covered the period of OeceSher 1977 to June 1984 In- !
c1wdec in the packages were documentation for piping, piping supports, !
assettled anc/or installed cceponents, f abricatica and inscettion/ testing cata in:19cing walkdown inspection check lists and applicable N-$ data recoats. It was noted t*a*. cPecklists, incrocess irstections, final in- '
s:eniens anc 4::eptan:es for c alete: .ori, p.):Lages mere performed to r the latest revision of the cesign drawings. While reviewing hanger records, :
t,re TRT foun d, in the saeple sele:tec, that the design analysis had been, !
perforced in at:ordan:e with final as tutit revisiens of the a:p11 cable t crawiegs. The TRT did not analyze the adecuacy of design. (For detatis [
cen:erning the adequa:y of the procedures governing the design processel, i see CA/CC Category 1, allegation AQ-90.) [
The allegation ( AQ-101, A0-107) that craf t arc 0' persennel retwested individwal docwi *3ts using traveler nu ':ers was assessed by interviewing DCC perscene) and reviewing OCP-3 for traveler docut.ent requiretents. The personnel interviewed referres the TRT to the CCC organizat.icn chart which included a "phone bank." The phene tank was established .n approximately Septeteer 1982, to enpedite the isswarce of infortation copy doc uents.
From a shore recuest OCC would generate a copy of the re:vestes do:w-ent.
h:*ever, the doeweent was not to ee isswec wetti DCC re:eivec a completad c:atrol distribution renwest form contairing t*e re:wirec accrovat si;aa-twees in 4::oreance with QCP-3, Revisions 13 tuowgs 15.
- The review of CCP-3, Paragraph 3.4, Revision 13, incicated that cc:veents cotid be released for inclusion into a traveler proviced they were iden-tified with the stamp, "The docurent shall be used only in conjunction with Operatten Traveler s ." The organization accountaile for controlling the package was responsible for assuring that'the current document revision nwster was referenged in the pt:Lage.
Further /eview of the CCP-3, Revisions 13 throw;n 19, revealed t, hat uncon-trolled distridwtion of design de:waenu was s'le ec provides they were ,
not, wied fwr orodwetun acti.ities and e e 4 waiateiv eartes d!n'erta-tien Cely." "For Of fice and Eagi9eerirg Me Cr' ." Or, -hem re: wire:.
"This Dece ent. Affe:ted by Cesign Changes."
The DCC personnel int,erviewed confireed that c:curents requestec by the satellites from the phone tank were not always recorted to the DCC CRT group, whiCn was respons10le for w dating the tonte:11ec distribution C
o j lists. This resulted in the satellites and/or others not rect'ving subse-quent revisions of the decy ent. Such actions constitute a prvcedural violation to DCP-3, 10 CFR Part 50, and AN51 N45.2. Since the types of ,
d:cuments obtedned fru the phone tank were not used for construction or engineering analysis, the violation was generic, but not safety significant, N.ever, the TRT 1 earned that, the OCC supervisor took action in March 1954, to enforce the reewire ents of DCP-2, upon discovering that the CRT group was not consister.tly iriformed when satellites obtained dotweents fro's the i chens tank. This e s ace:?plished by requiring each reawester to deliver a c:mpleted "C9ntrolled Distribution Request" to the CRT prior to receivir.g the retwested docwten's, The action assured that, the CRT group a s notiftad j when t*e satellites received a d:cy ent,, The distribution Nwti g control list, was then updated accordingly, The TVEC monito-ing team executive !
sumary reports confireed that the corrective action prevented recurrences.
The TRT assessed the allegation (AQ-104) that a DCC supervisor aw',heri:ed t*e release of incivicsal cecw ents by interviewing sate 111lte clerks who
.cre casite at tre ti e tr*.s inricent sue;osedly c: curred. The Et* 3atei- !
I*te :le'As if;teh i**** state: t9ey ra* never been inst,rweted ba, XC s ;er=
vifien or manage *ent t0 releau partial Cra ing packages to Craf t and QC
- e*50nnel. Ra'.her, ttey =t'e reewirec to follcw proce gres prohibiting the itswance of inciv Lal Oesign c0cu-ents. 4 .
- 5. C:eciwsien a*: $ta'f ::siticas: The review of TU!C audit repor.s, MORs, am: eenitorirg team eit:wtive re,:crt,s substantiated the allegatHns ( AQ-17,
~
A; 18 AC-42, A0-53 A02-9) to t*e ta',ent tomat trere were den.tr ces in the c: .rol of celian d:U.?en' packages and t*at Asolete andh. partial g
c U ents were avaiia:1e to craft are QC pers:P ce which coule ha t been wsec in t*e tetricat, ion, installat cm, and irs;e:t,'On of safety-related ,
harc.are fr0m a gsst 1951 thr0wgh Jwre 1934 i
k a/er, 1 9 review of the a
c: ;1eted sefety i't ": wality re.ords in tr o PPRV indicated t*>t draw-ings used for 1: m .;.:n a*: fa '::ation were performed to the latost revis10M.
Tre inte vie. =ite 0*: cersonmel s osta%iste: t*e allega*,1an: A -101, A; 1C7) t,*as t,re ;r:ee tant releasec cesign :: m ent,s to the m.ellites witeca rotifyteg tre CRT grewc to w;cate sne cistriewtier. list. As a ;
resvit, sete c uign cc:w-tr*,5 were not updated .ith the lat n c: cure nt, revisiens. ;
i The allegation (AO-104; that a DCC supervisor authori:ed the release of individual decutents ceg1d met te swestantiates. Satel'.ite clerks inte - ;
vie ed stated they hac eever teen instructec by CCC sw;ervision er rarage- -
eens to issue irece:1ete era =ing pack' ages, In a meetin; with an alleger en N:ve'ter 27, 1954, the TRT pre +1nted the [
ruwler cf t,n* usess ent f e allegat,tcn 10-17 are the TRT's c'r:1wsien.
f there ,sete no spep fic items of cisagreement, and no acettiona' concerns ;
or alligattens were icent,1fiec. An appointeens was mace to discuss allega-tion AQ-lS and a portion of allegation AQ-17 with the Cogni! ant alleger. l He.ever, the alleger cid PP keep the emocinttent. Allegation' AQ-9. AQ-42, AQ-58, A0-101, AQ-104, and A0 W , *re issues and cencerns not identif tec .
ty allegers. Therefore, no c.le '. ' interviews were come.cted fer these .
c ncerns and issues.
l 3 ;
O
- 6. Actions Required:
- 7. Potential Violations: 10 CFR 50, Appendix B, Criterion 16, states in part:
In the case of significant conditions adverse to quality, the measures shall assume that the cause of the condition is detertained and corrective action taken to preclude repetition.
Contrary to the above the document control center and satellites were cited repeatedly in inspection reports and monitoring deficiency reports for issuing documents that were not current, but effective corrective actions to preclude repetition were not taken until 1984. For example, audit TCP-23, conducted September 21-25, 1991, identified 19 documents that were missing or not current; similar findings were made in subsequent internal and external audits. Effective corre:tive acti6n does not appear to have been taken until mid-1984, as evidenced by findings in the TUEC monitoring team sum.??ary reports beginning with the June 2,1984, repor,t.
$. Atta . tents: Nene.
Reference Occuments:
- 1. Work Packages:
- a. R:-1-BR-046
- b. AF-1-55-007
- c. AF-1-5B-006 4 d. AF-l'55-006
- e. FST-1-1207-01-A-01
- 2. TUG 0 Audit Reports:
- a. TCP-23
- b. TCP-40
- c. TCP-68
- d. TCP-84
- e. TCP-99
- 3. Surveillance Reports:
I
- a.82-019
- b.82-020 '
- c.82-021
- f.83-016
,,.,83-017 .
ii. 83 012 i'. i j.$'3-020 3-027 4
- 4. TUEC Monitoring Team Executive Summary Reports 1 through 12.
- 5. Procedure OCP-3, Revision 0 through 18, "CPSES Occument Control Pro-gram," snd "Operating Instructions for DCC Satellites," dated '
October 24, 1983.
- 6. Hanger Numbers (see QA/QC Category 1, AQ-22).
- 7. Source Documents:
- a. GAP 2.206 Petition, March 19, 1984, Item 8 and A-2 Statement.
- b. A-2 letter, item 4, and A-5 letter item 3.
- c. Q4-84-014.
- d. A-15 testimony, page 46. ,
- e. Region IV Report, "New Issues," 0. Norman to R. Bangart.
- f. TXX-4187.
- g. Region IV Inspection Report 50-445/81-04; 50-446/81-04.
S. Internal memo establi,shing TUEC OCC Monitoring Team rehortability
. te senior management, cateo March 30, 1954
- 9. A-5 closecut interview, November 27, 1984, pages 105 to 115. ,
- 10. ANSI N45.2, "Qualty Assurance Program Requirements for Nuclear
- Facilities."
- 11. TUEC Procedures:
- a. CP-QP-19.0, Rev. 2, "Audits." ,
- b. 0QI-CS-4.6, Rev. 7. "Conduct of Internal, Prime, and Subcontractor Audits."
- c. CP-QP-15.7. 2ev. 2, "Tracking of Audit Reports / Corrective Action Reports."
- 9. This statenert prepared by: ,,, ,
V. wenczil, io vate Technical Reviewer Reviewed by:
H 3 Livermore, Date Group Leader Approt d by:
g V. Noonan, Date Project Director i
. 5
Y '
. GSGRk&
- 1. Allegation Category: QA/QC 2, Document Control
- 2. Allegation Numbers: AQ-4, AQ-16, AQ-57, AQ-59, AQ-60 and AQ-71
- 3. Chara:terization: It is alleged that the document control center (OCC) satellites were inadequately staffed, that documentation of design changes and drawings has been inadequate and unreliable, that design changes were not revised or maintained current by DCC in the satellites (a field exten-sion of tne OCC), and that an accurate listing of design changes generated against drawings and specifications was not maintained.
- 4. Assessment of Safety Significance: These allegations were assessed against the document Control system in effect in July, August, and September 1984 (The NRC Technical Review Team [TRT) assessment of allegations concerning the document control system from August 1981 to July 1984 is contained in QA/QC Category 2, allegations AQE-9, AQ-17, -18, -42, and -58.)
The TRT revie ed 46 engineering drawings and specifications and their attendant design changes, as indicated by design change authorizations (OCAs) anc c eponent modification cards (CMCs). Tne TRT made this review to determine if documents within the control of the DCC and the Unit 1 satellite were current and accurate with regard to the following: (1) that drawings and spwcifications contained the most current revision; (2) that all open design changes were identified, using the manual logs or the com-outer data base; and (3) that design changes reflected the most current revision in the logs or on the computer. The review also was made to verify the accuracy of the log and the computer revision levels by compar-ing them with the hard copies of the documents in the CCC files.
The TRT identified numerous errors associated with design documents con-trolled by the OCC/ satellite. Errors identified typically were as follows:
(1) design changes which had been incorpor ated were still shown as open; (2) design change revisions were not current, i.e., log (incorrect) vs hard copy (correct); (3) voided drawings were still shown on the comDuter; (4) design change references to drawing sheet numcers were incorrect or missing in the log vs the hard cooy; and, (5) no references were made in the design change log to the affected document.
The TRT then evaluated the implied significance of the above errors by examining controlled document packages issued by the DCC/ satellites to craft and inspection personnel. These controlled document packages ere examined by DCC/ satellite personnel for accuracy and completenes: before being issued. Because the craft and inspection personnel had to account for each controlled document when retdening it to the OCC/ sat <.ilite at the end of each shift, they also checked the accuracy and completeness of each document package when it was issued to them.
The TRT's examination of issued document packages focused on all ca:Lages issued byl satellite 307 (mechanical / instrumentation counter) f rom the beginning of the shif t (7:00 an) on July 26, 1984, until 12:30 p.m. This sample represented more than 90 percent of the packages issued by the mechanical / instrumentation counter, and more than 60 percent of all packages issued by sateilite 307 on that day.
--w
o 1
During this examination, each design document and any changes to it were noted when these documents were issued to craft and inspection personnel.
The current revision of each design document was then verified by checking the aperture cards in the OCC. The current revision and the design docu-ment applicability of each design change were verified against the hard copy of each design change in the DCC files. The TRT examined a total of 179 document packages (this number does not include duplicate packages also examined) and 597 design changes associated with these document packages.
4 Errors similar to those identified above concerning documents within the control of the OCC and the satellite were identified; however, not a single error was found in the controlled document packages issued to the crafts and inspection personnel. The TRT attributed this absence of error to the numerous checks and verifications of each document that were made by both DCC and craft persennel immeciately prior to its issuance.
The process described above is consistent with the requirements of DCP-3, Rev. IS, "CPSES Occument Control Program," and is followed for controlling quality dccuments onsite, except for pipe support (hanger) drawings ano subsequent changes. The hanger task force functioned as a pseudo-DCC-satellite for hanger documents, but was not staffed by DCC personnel. The -
procedural control of hanger documer.ts was governed by DCP-3 and other construction procedures such as CP-CPM-9.10, "Fabrication of ASME-Related Cosponent Support." Based on procedure reviews, document processing, and interviews of personnel, the TRT determined that the document control exercised by the hanger ta'sk force was not as rigid as that of the OCC and the satellites, but document accountability (complete and current documents in hanger packages) was equally effective.
In the TRT review of 90 documents that were in the hands of craft personnel, all were found to be complete and current; however, the same type of prob-lems identified in the OCC and the satellites were found in the TRT review of hanger document control.
In assessing the allegation of inadequate staffing in the satellites (AQ-4), the TRT found there were no numerical requirements for staffing levels in the OCC or its satellites in the procedures. However, from interviews with document control personnel, it was learned that levels were adjusted, based on construction activity. The TRT's review of in place procedures, controls, and DCC/ satellite responsibilities described above indicated that staffing has been adequate.
- 5. Based on the review of design' documents, Conc 1_usions and Staf f Position:
the TRT concludes that some errors do exist in the manual legs, the com-puter data base, and the files in the OCC and the satellites. However, numero,u.s cross-checks and references are made by document control person- ,
nel before any document is issued to ensure that the current revisions with c*crepet design changes are issued. The TRT examined a large, repre-sentative sample of controlled documents issued to the craft personnel and found no instance in which design changes or design documents were in-correct or not current. Although inaccurate document packages may find their way to the craft personnel, multiple levels of checks and verifica-tions should minimize the occurrence of such errors and provide for early detection when they do occur. .
2
_ _ _ . _ , . - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ m _ _ _ _ _ _ . _ _ _ _ _ _ _
The TRT was neither able to substantiate nor disprove the allegation of inadequate staffing and resources during an earlier time period (AQ-4);
however, present scaffing levels are adequate to support craft personnel needs.
In a meeting with the alleger en November 27, 1984, the TRT presenteu the results of the assessment of allegations AQ-16 and AQ-4 with the TRT's conclusions. A brief discussion ensued. No new concerns or allegations were identified. An appointment was made to discuss AQ-71 and a portion of AQ-16 with the cogni: ant alleger; however, the alleger did not keep the appointment. AQ-57, AQ-59, and AQ-60 were not raised by allegers, therefore, no formal closecut interviews for these concerns and issues wers conducted.
t
- 6. Actions Required: '
- 7. Potential Violations: Criterion V of 10 CFR Part 50, Appendix B, requires that activities affectirig quality be prescribed by procedures and instruc-tions, ?.nd that these activities be accomplished in accordance with estab-lished crocedures and instructions. The following occurrences are contrary to.this recuirement,
- a. OCP-3, "CPSES Document Control Program" (Rev 18), Paragraph 3.2.2.1,.
states, in part, that: "This group shall monitor all controlled docu-ment files to ensure that all applicable design documents are current and that design change logs, manuals, and computers show the current approved and issued design change information."
Contrary to the above, FW-1-99-004-C62K, Rev. 1, sheet 2 of 2 was voided, but the computer continued to list the drawing as current and active. (Computer data were corrected when this error was noted by the TRT.)
- b. OCP-3 (Rev. IS), paragraph 3.2.2.5, states, in part, that: "If, for any reason, a superseded document is retained, the face of the docu-ment must be stamped or marked 'V010.' When no longer recuired, superseded documents should be destroyed."
Contrary to the above, the following conditions were found in satellite 307 on July 31, 1984:
(1) 1-002-5-09 document package listed 18 design changes outstanding; however, 20 changes were in the package, including one super-seded and one vaidtd package that were not appropriately marked.
I (2) Two voided design changes were listed and included as current in design packages (CMC 62535, Rev. O, against M1-2607 and OCA 13170, Rev. O, against MS-084) but these were not appro- ,
priately marked.
(3h I A superseded drawing, RH-1-SB-006, Rev. 13, was found in the files on July 31, 1984, but was not appropriately marked,
- c. CCP-3 (Rev. 18), paragraph 3.1.2.4, states, in part, that "Controlled documents affected by design change documentation shall be stamped as follows: 'THIS DOCUMENT AFFECTED BY DESIGN CHANGE.'"
3 4
, , _ _ _ _ _ _ _ - - . _ _ _ _ _ _ _ . _ . - - - - - - - _ . - , , _ _ - ~. . . . - , , , . - - - . - - - , - - - - .
o Contrary to the above, drawing numbers 2323-MI-2301-10, -2304-01, and -2304-05 were in the 307 satellite files on July 31, 1984, and DO-2-099-709-553R was in the hands of hanger craft personnel and '
were not stamped "This document affected by design changes," even '
though each document was affected by changes.
- 8. Attachments: None.
Reference Documents:
- 1. Procedure OCP-3, "CPSES Document Control Program," all revisions.
- 2. TUGC0 Nuclear Engineering Manual, specifically TNE-AO-4, "Control of Engineering Documents," Revision 4.
- 3. AQ-16: A-2 March 7, 1984, letter, item No. 3; and A-5 item No. 1.
4 AQ-57: 04-34-014 March 8,1984, :nd A-15 testimony, pp,. 23-25.
- 5. . AQ-59: 04-54-012 March 3, 1954, a,c A-15 testimony, op. 46, 47, 53, 54
- 6. AQ-60: Q4-34-014 March 8, 1984, and A-15 testimony, pp. 60-61.
- 7. AQ-71: A-2 statement and interview, pp. 54-74
- 9. This statement prepared by:
V. Wenczel, Cate TRT Technical Reviewer Reviewed by:
H. Li ve rmo re Date Group Leader i
Approved by:
V. Noonan Date Project Director ,
t I
. , O a
- 1. Allegation Category: QA/0C 2, Occumentation Control
- 2. Allegation Number: AQ-102
- 3. Characterization: There is a concern that a supervisor's action in a docu-ment control center (DCC) satellite resulted in procedural violations which were not reported to Texas Utilities Electric Company (TVEC) quality assurance (QA) representatives for the determination of reportability to the NRC as required by 10 CFR 50.55(e)."
- 4. Assessment of Safety Significance: This concern is related to a supervisor who reportedly advised personnel that because information was entered into the computer they were not responsible for continuing to update the manual satellite log book, that they were not responsible for reporting errors detected in the computerized design change logs, and that personnel were never informed that the OCC cathode ray tube group (CRT) was to be notified when a docunent was requested through the OCC satellite. ,
In assessing the concern, the NRC Technical Review Team (TRT) reviewed the TUEC procecures for controlling documentation within the DCC and its satel-lites, for the implementation of these procedures, and for reporting vio-
, lations per 10 CFR 50.55(e) . The TRT also reviewed the findings of the -
NRC Construction Appraisal Team (CAT) audit, NRC Region IV inspection reports and TUEC audits of the DCC, and conducted interviews with the DCC/
satellite and design change tracking group personnel.
Between February and May 1983, both CAT and Region IV inspections identi-fied recurring documentation deficiencies. Typical deficiencies included drawings out-of-date by up to several subsequent issues and drawings which had incomplete title and revision blocks. On May 31, 1983, a Notice of Violation (50-445/83-18 and 50-446/83-12) was issued to TUEC for inadequate documentation control at Comanche Peak Steam Electric Station (CpSES)
(Criterion VI of 10 CFR 50 Appendix B). Substantial corrective action was reovired to correct the identified deficiencies. part of the corrective action taken by TUEC was the establishment in August 1983, of the OCC satellites to issue and control design documents.
In August 1983, Brown & Root (B&R) established a monitoring team to audit the OCC satellites on a continuing basis. A charter for the team was delineated in procedure OCP-3. The TRT's review of the monitoring team's audit findings from August 1983 to July 1984, indicated that the recurring problem of drawing accountability was still an area of concern, but had been diminishing since of the monitoring team began reporting results to the assistant project manager in April 1954 The performance data pub-lished by the monitoring team in early April 1984 for Unit I satellites (306 and 307) showed defect rates of 30 percent and 10 percent respectively.
- The topic of 10 CFR 50.55(e) reporting was previously mentioned ir the D. Eisenhut letter to 0. M. Spence, dated January 8,1985 on page 22, itens C
& 0. The TRT subsequently learned that the procedure referred to in the letter was not the appropriate procedure for 10 CFR 50.55(e) reportability in the area of document control. Accordingly, this assessment supersedes items C & 0 in the letter.
i
_-- - - - - - - - - --,e
.' l
. . o By mid-May to early June, the defect rates dropped to 5 percent and 1 per-cent. July's deficiency rate for both satellites averaged 1 percent.
Based on the monitoring team's audit findings, the TRT determined that document deficiencies existed in the DCC satellites from August 1983 to May 1984.
Based on interviews with the DCC and design tracking group personnel, the TRT determined that the portion of the concern regarding the satellite supervisor's actions, which resulted in procedural violations, was substan-tiated. According to these employees, the supervisor did instruct employees not to challenge the computer, not to call the design change tracking group when discrepancies were identified in the computerized design change logs, not to notify DCC CRT of drawings the satellite obtained using the phone bank, and not to maintain certain manual design change logs. The TRT learned that this supervisor's employment was terminated in February 1984 As noted above, the defect rate of 30 percent for satellite 306 was reduced to 5 percent by May and 1 percent by July. It is the TRT's view that the high defect rate for satellite 306 was attributable in part to the satel-lite superviser's actions. (Cetails of the TUEC audit reports and the mcnitoring team audit fincings are accressed in QA/QC Category 2, allega-tiens AQE-9, AQ-17, 18, 42, anc 58.) The TRT reviewee the nonconformance re; ort (NCR) log books for 1983 and 1984 These NCRs were generated in -
accordance with CP-QP-16.0. Of the NCRs listed in the 1983 log book, 19 specifically dealt with document control procedural violations. The IRT found no evidence that an NCR was generated based on a satellite super-visor's actions.
To assess the portion of this allegation concerning "reportability," the TRT reviewed site QA procedures dealing with general nonconformance report-ing and significant construction deficiency re;crting, i.e., 10 CFR 50.55(e).
The TRT noted that B&R does not have a Tarecedure(s) specifically ad-dressing significant deficiency reporting, as they consider 10 CFR 50.55(e) to be an NRC/ utility relationship rather than a contractor / utility rela-tionship. Accordingly, the procedure governing 10 CFR 50.55(e) reporting is addressed only in TUEC procedure CP-0P-16.1, Rev 5, "Sigm *,: ant Con-struction Deficiencies." In reviewing this procedure, the Tti ' w d that it lacks, specificity regarding what is a significant breakc:e . , ;, o r -
tion of the QA program. In paragraph 2.3, technical failures (for eeamole, design, construction, and performance deficiencies) are defined and identi-fied as to reportability. However, paragraph 2.3 defines a QA program reportable deficiency as: "A significant breakdown in any portion of the Quality Assurance Program conducted in accordance with the requ'irements of Appendix B."
The TRT reviewed both B&R and TUEC NCR procedures to determine if non-conforming conditions were to be evaluated for 10 CFR 50.55(e) report-abilit.y B&R's nonconformance procedure (CP-QAP-16.1, revisions 20 and 21) ,
states that nonconformance conditions are to be evaluated with respect to CP-QP-36.1 but no specifics are given. TUEC's nonconformance procedure CP-QP-16.0 (Revs 13 and 14) did not address the review of NCRs as potential candidates for 10 CFR 60.55(e) reporting or reference procedure CP-QP-16.1, "Significant Constr.; tion Deficiencies." CP-QP-16.1 does delineate in paragraph 3.5 that NCRs were to be reviewed to recognize and identify sig-nificant deficiencies, as defined in paragraph 2.3, and as quoted above; however, this procedure, whicn is used to review NCRs, lacks specificity, 2
o As noted previously, the TRT's review of NCR log books for 1983 and 1984 did not reveal any NCRs based on actions of the satellite supervicor which .
resulted in procedural violations. However, it is the opinion of the TRT that the issue is not that TUEC was unaware of DCC procedural violations, but that the definition of a reportable deficiency in the QA program is too vague. None of the 19 NCRs documenting procedural violations appeared to have been reported to the NRC using 10 CFR 50.55(e) reporting.
(The subject of untimely reporting of significant deficiencies to the NRC is addressed in QA/QC Category 7, allegation AQ-113.)
- 5. Conclusion and Staff Positions: The concern that the OCC satellite super-visor took actions which resulted in procedural violations was substan-tiated. The concern that TUEC OCC procedural violations were not reported to TUEC for potential reportability under 10 CFR 50.55(e) was not sub-stantiated. In the course of assessing this allegation, the TRT deter-mined that the TUEC definition of reportable deficiencies is too vague.
TUEC's NCR procedure lacks references and does not address correlation of NCRs to reportability under 10 CFR 50.55(e). The signiff' cant deficiency crocedure lacks specificity as to what is a significant breakdewn in any portion of the CA program or the mechanism for review of NCRs for potential reportability. This concern has generic implications in that significant quality program deficiencies could go unreported to the NRC. -
The sou ce of this concern was not an alleger; therefore, no exit inter-view was conducted. ,
- 6. Actions Recuired:
- 7. potential Violations: Appendix B, Criterion V of 10 CFR Part 50 requires that activities affecting quality shall be prescribed by documented proce- !
dures anc accomplished in accordance with these procedures.
Contrary to the above, nonconformance procedures do not reference or cor-relate the NCRs as potential 10 CFR 50.55(e) reper:able items. Proce-dure CP-Op-16.1, "Significant Construction Deficiencies," lacks specificity in defining a significant breakdown in the QA program and does not identify details on NCR reviews for reportability.
- 8. Attachments: None.
Reference Documents:
- 1. Procedure OCP-3, "CPSES Docueent Control Program," Revisio'n 16, dated August 5, 1983.
- 2. Procedure CP-QP-16.0, "Nonconformances," Revision 14, dated July 2, 1984 .
- 3. Procedure CP-EP-16.3, "Control of Reportable Deficiencies," Revision 3, dated June 15, 1984.
- 4. Operating Instructions DCC Satellites, dated October 24, 1933. l 3
y---.---,_-___- _ , ,--- -,-, --,--,r. -
.-+--.---rw- - - - - - . m_ ,,--.-,,7---m _e,. _,_w. ,_.,e ,. - ,__ _,_ , ,
- 5. Operating / Administrative Guidelines for DCC Satellites (Craft), issue i date: June 26, 1984.
- 6. Ir'.eroffice Memo 35-1195, H. A. Hutchinson Jr. to R. Scott, "Schedule - l Transition from Control Numbered Drawing Distribution to Satellite Controlled Distribution," dated June 16, 1983.
- 7. Office Memorandum, J. D. Hicks to R. G. Tolson "Comanche Peak Steam Electric Station CAT Inspection - Document Control, Ref. letter TUQ-1620," dated May 2, 1983.
- 8. Memorandum, TUG-1620, R. G. Tolson to Distribution, "Construction Appraisal Team Inspection," April 18, 1983.
- 9. Results of Investigation into Allegations Regarding Document Control at Comanche Peak by Law Offices of Bishop, Liberman, Cook, Purcell and Reynolds, dated July 19, 1984. ,
4^. Procecure CP-CD-16.1.' Revision 5, "Significant Construction deficiencies."
- 11. TUGC0 Nonconformance Report Log Books for 1982 (NCR 82-00001 through-82-02387), 1983 (83-00001 through 83-03312), and 1984 (84-00001 through 84-01969).
- 12. Independent Assessment Program for Comanche Peak Steam Electric Station Final Report, prepared by Cygna Energy Services, Volume 1 Section 3 and 4, dated November 5, 1983.
- 13. TUGC0 Deficiency Review Report Log - ORR 001 through ORR 063, dated April 15, 1982 through August 31. 1984.
14 NRC Office of Investigation Report 4-84-025, "Alleged Inproprieties and Potential Wrong Ooing in the B&R Document Control Center."
- 15. Procedure CP-CAD-16.1, Sevisions 20 and 21, "Control of Nonconforming Items.
- 9. This statement prepared by:
V. Wenczel, TRT Date Technical Reviewer .
t Reviewed by:
.. H. Livermore, Date .
Group Leader l
Approved by:
V. Noonan, Cate Project Director 4
0
- 1. Allegation Category: QA/QC 2, Document Control
- 2. Allegation Number: AQ-19
- 3. Characterization: It is alleged that "control copy" stamps were in use by the paper f'ow group (PFG) and quality control (QC) departments for a period of time. It is alleged that two stamps were issued te, the QC department by document control center (DCC) management and used to make QC drawing packages "legitimate." The use of these stamps by any organiza-tion other than the OCC/ satellites is in violation of Texas Utilities Elec-tric Company (TVEC) procedures.
4 Assessment of Safety Significance: The NRC Technical Review Team (TRT)
'(T)reviewedTUECOCCandPTGproceduresanddocumentspertainingtothis allegation (2) reviewed a sampling of PFG packages to determine if docu-mentation was current, (3) reviewed OCC/ satellite use of "control copy" stamps, .nd (4) interviewed TUEC representatives and an Authorized Nuclear Inspector (ANI) relative to the allegation. '
TRT founc :nat CCC management issued only one "centrol cop >" stamp to The,CC the cecartment as a result of the issuance of a special inspection services (SIS) report by the ANI of the Hartford Steam Boiler Inspection .
and Insurance Company. The 515 report noted that the majority of QC hanger cackages contained drawings which obviously had been reproduced from the original, controlled copies with the control number marked over in rec.
The ANI believed there would be no evidence that these drawings were in fact controlled if the drawing was not stamped with a red "control copy" stamp. As a result, Brown & Root (B&R) procedure 00C-3 was revised (Revi-sien 15) to specifically mandate the use of red "control copy" stamps for the c: pies reproduced. Prior to this time, the color cf the control copy stamp was not designated. The stamp used by the CC department was "notched" to distinguish it from those used by the CCC.
The issuance of the SIS report and the subsequent stamping of hanger draw-ings by B&R quality engineering occ.urred because of the manner in which the welding engineering organization had organized hanger packages for craft personnel. The fabricators prepared generic crawings (typicals) that reflected the design of the majority of hangers. Drawing size was 813 x 11 inches. Upon receipt of the red-stamped control copy from DCC, welding engineerint made copies for affected hanger packages. The control stamp number, 098, was marked in red. Approximately 17,000 hanger packages were constructed in this manner. In reviewing the hanger packa,ges, the ANI noted that the hanger drawings were not stamped in the standard DCC method, and therefore issued the SIS. Subsequent to this, as corrective action, a procedural change to DCP-3 occurred: the 24R welding engineering organization would no longer make document distribution, and a specifically identifiable stamp us issued to the B&R C'C to procerly stamp any uncon-trolled hanger dra in; within the hangee onclaget. CC verified the latest
- revisten of any drawing which did not have a red control number and stamped it with the "notched" control stamp, entering the 098 control number.
When B&R QC no longer needed the control copy stamp in question, it was returned to the OCC and defaced so it could not be used again.
The TRT found no evidence in OCC procedures or guidelines, prior Aevi-sion 15 of OCP-3, which delineated the use of tne "control copy" stamps,
or stated that the control copy was to be stamped in red. In addition, no evidence was found that written guidelines were issued or that special procedural changes were made to control the use of these stamps by BAR QC.
The TRT considers the lack of guidelines or procedures for QC's use of these control stamps to be a potential violation. The TRT interviewed TUEC and B&R representatives and found no evidence that "control copy" stamps were issued to any other organization. ,
The TRT noted that if a control stamp came into the possession of an organ-ization outside of DCC, it would not be significant to construction and inspection activities. The document packages used by craft personnel are verified by the OCC satellite for accuracy and completeness, and the ,
documents are updated with current revisions upon the issuance and return :
of the document packages to the OCC satellite. Since only the OCC has access to non-stamped documents, the possession of a control stamp would serve no purpose in construction and inspection organizations.
The TRT believes that future, unauthorized use of a control > stamp would be difficult and impractical because the control stamos of concern are usec cn!,y oy the OCC satellites, ano DCC satellites are the only recipients of non-stamped drawings. ,In accition, other controlled documents are red-stamped in DCC prior to issuance. Only DCC can make standard size drawings, and the personnel in DCC and its satellites are accountable for the docu-ments in their possession.
- 5. Conclusion and Staff positions: Based on the a ove reviews, the TRT found evicence to substantiate the allegation that control stamps had been used by organizations other than DCC; hewever, since July of 1984, OCC stamps have been adaquately controlled. The TRT learned that a "control copy" stamp was issued to the QC department in conformance with the ANI request that doct.ments transmitted to them be "red-stamped." However, methods for the issuance and Control of such stamps were not described in TUEC's document control procedures. Issuance of the stamps to QC had no significant safety implication in the erection, fabrication, or construction of safety-related systems, components, and structures, and the TRT found no evidence that there was a loss of hanger drawias coat *ol as a result of the CC department's stam:ing of the hanger drawings of cencern.
Although this allegation has generic implications for Unit 2, it is the TRT's position that the multiple levels of checks and verifications asso-ciated with document packages issued to the craft personnel by the OCC and its satellites would have detected and corrected potential problems.
In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of the allegation and the TRT's conclusion.
There were no major items of disagreement, and no new cencerns or allega-tions were identified.
- 6. _ctions A Required:
- 7. Potential Violations: Appendix B, : tion V, of 10 CFR 50 requires that activities affecting quality shall be prescribed by document procedures and accomplished in accordance with these procedures.
2
Contrary to the above, there was no procedure or instruction describing and controlling the use of the specialized documentation control stamp '
issued to B&R QC for the period from June 1983 to August 1984.
- 8.
Attachment:
None.
Reference Documents:
- 2. TUGC0 letter, Director. Division of Licensing, NRC, "Comanche Peak Steam Electric Station Units 1 and 2 Allegations Transmitted by Letter on April 24, 1984," TXX-4180, dated May 25, 1984
- 3. Hartford SIS Record #355 "Unsatisfactory Section 7 of Brown and Root GA Manual," dated June 7, 1983.
4 9 o n & Root letter $15 d355. catec June S, 1933.
- 5. Allegation statements: A-1, dated March 2, 1984, page 4 A-49, dated May 1, 1984, page 4 -
- 6. A11eger's interviews: A-1, dated April 16, 1984, pages 12-?d.
A-2, dated April 5, 1984, pages 87,53.
- 7. A-1, close-out interview, dated December 10, 1984
- 9. This statement prepared by: --
], gag, Techr.ical Reviewer Reviewed by: --
- h. Livermore, Date Group Leacer Approved by: ==
Noonan, 0"I' Project Director G. .
O e
- 1. Allegation Ca ggory:
o QA/QC 2, Document Control
- 2. Allegation Number: AQ-17, AQ-18, AQ-42, AQ-58, AQ-101, AQ-104, A0-107 and AGE-9
- 3. Characterization: It is alleged that there was a lack of control of design document packages ( AQ-17, AQ-18, AQ-58); that craf tsmen and QC inspectors were provided with obsolete or partial (uncontrolled) design document pack-ages during construction (AQE-9, AQ-42); that individual documents were issued agtinst travelers per telephone request (AQ-107); that a document control center (OCC) supervisor authorized the release of partial document packages to the field (AQ-104); and that the DCC cathode ray tube (CRT) group was sot notified when documents were obtained by the "phone bank" and the distribution routing control lists printouts were not updated (AQ-101).
4 Assessment of Safety Significance: The issues and concerns identified by tne allegers were for sne control of design documents relating to safety-related hardware constructed and installed at Cemanche Peak Steam Electric Station (CPSES). ihe TRT confined its assessment of these allegations to safety-related hardware cesign document control for the period from Augast 1981 through June 1924 (The TRT's assessment of the document control system during July, August, and September 1984, is contained in QA/QC
- Category 2, allegations AQ-16, 57, 59, 60, and 61.)
The NRC Technical Review Team (TRT) compared Brown and Root (B&R) procedure OCP-3, Rev. 18 "CpSES Occument Control Program," to the requirements of ANSI N 45.2 and found it to be acceptable.
The IRT adcressed allegations AQE-9, AQ-17, AQ-13, AQ-42, and AQ-58, by reviewing Texas Utilities Electric Company (TVEC) audit reports, monitoring discrepancy reports (PORs), and TUEC monitoring team executive summary reports. These TUEC reports were issued frem August 1981 through July 1934, and identified the following deficiencies for civil, structural, electrical, mechanical, and piping safety-related systems.
- a. Drawings in the field were not of the laten . .-
- b. Design change authorizations (OCAs) anc component modification cards (CMCs) were not of the latest revision.
c, Design documentation was missing.
- d. Satellites were not always updated with the latest design document revision.
e.
Drawings hanging in an open rack were available to craft and QC
- personnel with no checkout control.
- f. Design change log books were not maintained.
- g. Superseded copies and current copies of design documents were filed together.
1 l
o l{
Q
- h. Satellite distribution lists were not updated and current.
- 1. Discrepancies were found between drawings in the satellites and those in the DCC.
J. Drawings were missing from the satellite files.
It was determined by the TRT that the above deficiencies were of a recur-ring nature. Therefore, it appears that any corrective actions taken by TUEC based upon these deficiencies were ineffective.
In order to evaluate the consequences of the recurring documentation def1-ciencies, the TRT reviewed a sample of completed safety-related documenta-tion packages stored in the TUEC permanent plant records vault (PPRV).
Completed records covered the period of December 1977 to June 1984. In-cluded in the packages were documentation for piping, piping supports, assembled and/or installed components, fabrication and inspection / testing data including walkdown inspection check lists and applicable N-5 data recorts. It was noted trat checklists, incrocess inspections, final in-scoctions and accectances for completec wors packages were performed to the latest rivision of the design drawings. While reviewing hanger records, the TRT found, in the sample selected, that the design analysis had been .
performed in accordance with final as-built revisions of the applicable drawings. The TRT did not analyze the adequacy of design. (For details concerning the adequacy of the procedures governing the design processes, see CA/0C Category 1, allegation A0-90.)
The allegation (AQ-101, AQ-107) that craft and CC personnel requested individual documents using traveler numbers was assessed by interviewing CCC personnel and reviewing DCP-3 for traveler document requirements. The personnel interviewed referred the TRT to the OCC organization ct. art which included a "phone bank." The phone bank was established in approximately September 1982, to expedite the issuance of information copy documents.
From a phone recuest, DCC would generate a copy of the requested document However, the document was not to oe issued until DCC received a completed control distribution request form containing the recuired approval signa-tures in accordance with OCP-3, Revisions 13 througn 18.
The review of DCP-3, Paragraph 3.4, Revision 13, indicated that documents could be released for inclusion into a traveler provided they were iden-tified with the stano, "The document shall be used only in conjunction with Operation Traveler # .
The organization accountable for controlling the package was responsible for assuring that 4"e current document revision number was referenced in the package.
Further review of the OCP-3, Revisions 13 throu;h 13, revealed that uncon-trolled distribution of design documents wi. allo ed provided they were ,
not used fur productiun activities and wen 4;tr.rciately marked "Informa-tien Only," "For Office and Eagineering us, Cet ." or, when required.
"This Document Affected by Design Changes."
The OCC personnel interviewed confireed that docu ents requested by the satellites from the phone bank were not always reoorted to the DCC CRT group, which was responsible for updating tne centro 11ec distribution 6
w
i lists. This resulted in the satellites and/or others not receiving subse-quent revisions of the document. Such actions conscitute a procedural violation to DCP-3, 10 CFR Part 50, and ANSI N45.2. Since the types of documents obtained from the phone bank were not used for construc'. ion or engineering analysis, the violation was generic, but not safety significant.
However, the TRT learned that, the DCC supervisor took action in March 1934, to enforce the requiraments of DCP-3, upon discovering that t.he CRT group was not consistently informed when satellites obtained documents from the phone bank. This was accomplished by requirin a completed "Controlled Ofstribution Request" to gthe each requester to deliver 1 CRT prior to receiving the requested documents. The action assured that the CRT group was notified i
j when the satellites received a document. The distribution routing control list was then updated accordingly. The TUEC monitoring team executive su-mary reports confirmed that the corrective action prevented recurrences.
The TRT assessed the allegation (AO-104) that a DCC supervisor authori:ed tne release of individual documents by interviewing satellit'e clerks who were ensite at the time snis incicent supoosedly occurred. The B&R satei-1 lit.a clerks interviewec statec tney nad never been instructed by DCC su;er-vision or manage ent to release partial drawing packages to craf t and OC personnel. Rather, they were required to follow procedures prohibiting the j l issuance of individual design documents, j
- 5. Conclusion and Staff positions: The review of TUEC audit reports, MDRs, I anc monitoring team executive reports substantiated the allegations (AO-17, AQ-18, A0-42, A0-53, ACE-9) to the extent that tnere were deficiences in '
the control of design d0cu ent packages and that obsolete and/or partial documents were available to craf t and OC personnel which could have been ,
used in the fabrication, installation, and inscection of safety-related '
hard are from August 1931 through June 1934 He.ever, the review of the completed safety- @ ned :uality records in the PPRV indicated that draw-ings used for inspection and fabrication were performed to the latest revision. ,
. I The interview with DCC oersonnel substantiated tre allegations ( AO-101, :
i A0-107) tnat tne pnene bank released design documents to the satellites witneut not* fying tne CRT group to upoate the distrioution list. As a
- result, some design documents were not updated with the latest document revisions. -
The allegation (AO-104) that a DCC supervisor authorized the release of individual documents could not be substantiated. $atellite cle'rks inter-
' viewed Stated they had never been instructed by OCC supervision or manage-ment to issue incomplete drawing packages.
In a meeting with an alleger en November 27, 1954, the TRT presented the
- resulfs of the asstessment for allegaticn AQ-17 and the TRT's conclusion.
There=were no specific items of disagreement, and no additional concerns or allegations were identified. An appointment was made to discuss 411ega- !
tion AQ-18 and a portion of allegation AQ-17 with the cognizant alleger, ,
However, the 411eger did not keep the appointment. Allegations AQ-9, A0-42, 4
AQ-58, A0-101, AQ-104, and A0-107 were issues and concerns not identified i
by allegers. Therefore, no closecut interviews were conducted for these i
- concerns and issues.
3 1 1
- 6. Actions Required:
- 7. Potential Violations: 10 CFR 50, Appendix B, Criterion 16, states in part:
In the case of significant conditions adverse to quality, the measures shall assume that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above the docu ent control center and satellites were Cited repeatedly in inspection reports and monitoring deficiency reports for issuing documents that were not current, but effective corrective actions to preclude repetition were not taken until 1984. For example, audit TCP-23, conducted September 21-25, 1991, identified 19 documents that were missing or not current; similar findings were made in subsequent internal and external audits. Effective corrective actidn does not appear to have been taken until mid-1984, as evidenceo by findings in the TUEC monitoring team sum. mary reports beginning with the June 2, 1984, report.
- 5. A::ac- ents: Ncne.
Reference Occu ents:
- 1. Work Packages:
- a. RC-1-BR-046
- b. AF-1-55-007
- c. AF-1-5B-006
- d. AF-1-5B-006
- e. FST-1-1207-01-A-01
- 2. TU3:0 Audit Reports:
- a. TCp-23
- b. TCP-40
- c. TCp-69
- d. *CP-34
- e. TCP-99
- 3. Surveillance Reports:
- a.82-019
- b.82-020
- c.82-021 .
- d.82-023
- e.83-015 -
- l. . 83 012 i*, S3-020 J.83-027
4 TUEC Monitoring Team Executive Summary Reports 1 through 12.
- 5. Procedure DCP-3, Revision 0 through 18, "CPSES Document Control Pro-gram," and "Operating Instructiens for DCC Satellites," dated '
October 24, 1983.
- 6. Hanger Numbers (see QA/0C Category 1, AQ-22).
- 7. Source Documents:
- a. CAP 2.206 Petition, March 19, 1984, Item 8 and A-2 Statement. ,
- b. A-2 letter, item 4, and A-5 letter item 3.
- c. Q4-84-014 L
- d. A-15 testimony, page 46. '
- e. Region IV Report, "New Issues," 0. Norman to R. Bangart. E
- f. TXX-4187.
- g. Region IV Inspection Report 50-445/81-04; 50-446/81-04.
- 3. Internal memo estaelishing TUEC CCC Monitoring Team reportability -
l . to senice management, datec March 30, 1954.
~
- 9. A-5 closecut interview, November 27, 1984, pages 105 to 115. !
i 1 10. ANS! N45.2, "Qualty Assurance Program Requirements for Nuclear Facilities." -
i
- 11. TUEC Procedures: ,
- a. CP-OP-19.0, Rev. 2, "Audits."
- b. CQI-CS-4.6, Rev. 7. "Conduct of Internal Prime, and ,
Subcontractor Audits." -
- c. CP-QP-15.7, Rev. 2 "Tracking of Audit Reports / Corrective !
Action Reports."
- 9. This statement prepared by.
V, nenczel, IAT Cate F J Technical Reviener :
I !
1 Reviewed by:
H. Livermore, 6 ate Group Leader 1
l Approved by: '
i V. Noonan, Date l Project Director [
I l i
5 i
Y '
gg} ,
N0Ya L. tMe
- 1. Allegation Category: QA/QC 2, Occument Control
- 2. Allegation Numbers: AQ-4, AQ-16, AQ-57, AQ-59, AQ-60 and AQ-71
- 3. Characterization: It is alleged that the document control center (DCC) satellites were inadequately staffed, that documentation of design changes and drawings has been inadequate and unreliable, that design changes were not revised or maintained current by DCC in the satellites (a field exten-sion of the OCC), and that an accurate listing of design changes generated against drawings and specifications was not maintained.
4 Assessment of Safety Significance: These allegations were assessed against the document control system in effect in July, August, and September 1984
~
(The NRC Technical Review Team [TRT) assessment of allegations concerning the document control system from August 1981 to July 1984 is contained in OA/QC Category 2, allegations AQE-9, AQ-17, -18, -42, and -58.)
The TRT reviewed 46 engineering drawings and specifications and their attendant design changes. as indicated by design change authori:ations (CCAs) anc component modification cards (CVCs). Tne TRT made this review to determine if documents within the control of the OCC and the Unit 1 .
satellite =ere current and accurate with regard to the following: (1) that drawings and specifications contained the most current revision; (2) that all open design changes were identified, using the manual logs or the com-puter data base; and (3) that design changes reflected the most current revision in the logs or on the computer. The review also was made to verify the accuracy of the log and the computer revision levels by compar-ing them with the hard copies of the documents in the OCC files.
The TRT identified numerous errors associated with design documents con-trolled by the OCC/ satellite. Errors identified typically were as follows:
(1) design changes which had been incorporated were still shown as open; (2) design change revisions were not current, i.e., log (incorrect) vs hard copy (correct); (3) voided drawings were still shown on the computer; (4) design change references to drawing sheet nu-ters were incorrect or missing in the log vs the hard copy; and, (5) no references were made in the design change log to the affected document.
The TRT then evaluated the implied significance of the above errors by '
examining controlled document packages issued by the OCC/ satellites to craft and inspection personnel. These controlled document packages were l examined by DCC/ satellite personnel for accuracy and completene'ss before being issued. Because the craft and inspection personnel had to account for each controlled document when returning it to the DCC/ satellite at the '
end of each shift, they also checked the accuracy and completenest of each document package when it was issued to them.
5 ..
The TRT's enamination of issued document packages focused on all pa:ka;es issued by satellite 307 (mechanical / instrumentation counter) from the beginning of the shift (7:00 am) on July 26, 1984, until 12:30 p.m. This sample represented more than 90 percent of the packages issued by the rechanical/instry entation counter, and more than 60 percent of all r packages issued by satellite 307 on that day.
l i
i
During this examination, each design document and any changes to it were noted when these documents were issued to craft and inspection personnel.
The current revision of each design document was then verified by checking the aperture cards in the OCC. The current revision and the design docu-ment applicability of each design cha, ige were verified against the hard copy of each design change in the OCC files. The TRT examined a total of 179 document packages (this number does not include duplicate packages also examined) and 597 design changes associated with these document packages.
Errors similar to those identified above concerning documents within the control of the OCC and the satellite were identified; however, not a single error was found in the controlled document packages issued to the crafts and inspection personnel. The TRT attributed this absence of error to the numerous checks and verifications of each document that were made by both DCC and craft personnel immediately prior to its issuance, t
The process described above is consistent with the requirements of DCP-3, Rev. 18. "CPSES Occu ent Control Program " and is fo11cwed for controlling quality dccuments onsite, except for pipe support (hanger) drawings and subsequent changes. The hanger task force functioned as a pseudo-DCC-satellite for hanger documents, but was not staffed by DCC personnel. Thr procedural control of hanger documents was governed by DCP-3 and other construction procedures such as CP-CPM-9.10. "Fabrication of ASME-Related Component Support." Based on crocedure reviews, document processing, and interviews of personnel, the TRT determined that the document control exercised by the hanger task force was not as rigid as that of the OCC and the satellites, but document accountability (complete and current documents in hanger packages) was equally effective.
In the TRT review of 90 documents that were in the hands of craft personnel, all were found to be complete and current; however, the same type of prcb-lems identified in the OCC and the satellites were found in the TRT review of hanger document control.
In assessing the allegation of inadequate staffing in the satellites (AO-4), the TRT found there were no numarical recuirements for staffing levels in the OCC or its satellites in the procedures. However, from interviews with document control personnel, it was learned that levels were adjusted, based on construction activity. The TRT's review of in place procedures, controls, and DCC/ satellite responsibilities described above indicated that staffing has been adequate. *
- 5. Co_nclusions and Staff Position: Based on the review of design documents, the TRT concludes that some errors do exist in the manual logs, the com-puter data base, and the files in the OCC and the satellites. However, numero,u.s cross-checks and references are made by document control person- ,
nel before any docutent is issued to ensure that the current revisions with c*orrect design changes are issuad. The TRT examined a large, repre-Sentative sample of controlled documents issued to the craft personnel and found no instance in which design changes or design documents were in-correct or not current. Although inaccurate document packages may f.nd their way to the craft personnel, multiple levels of checks and verifica-tions should minimize the occurrence of such errors and provide for early detection when they do occur. ,
2
The TRT was neither able to substantiate nor disprove the allegation of inadequate staffing and resources during an earlier time period (AQ-4);
however, present staf fing levels are adequate to support craft personnel needs.
In a meeting with the alleger on November 27, 1984, the TRT presented the results of the assessment of allegations AQ-16 and AQ-4 with the TRT's conclusions. A brief discussion ensued. No new concerns or allegations were identified. An appointment was made to discuss AQ-71 and a portion of AQ-16 with the cogni: ant alleger; however, the alleger did not keep the appointment. AQ-57, AQ-59, and AQ-60 were not raised by allegers, therefore, no formal closecut interviews for these concerns and issues were conducted.
- 6. Actions Required:
- 7. Potential Violations: Criterion V of 10 CFR Part 50, Appendix B, requires that activities affecting Quality be prescribed by procedures ahd instruca tions, and that these activities be accomplished in accordance with estab-lished procedure: and instructions. The folicwing occurrences are contrary to.thi5 requirement
- a. OCP-3, "CPSES Deca ent Control program" (Rev 18), Paragraph 3.2.2.1.,
states, in part, that: "This group shall monitor all controlled docu-ment files to ensurt that all applicable design documents are current and that design chan3e legs, manuals, and computers show the current approved and issued casign change information."
Contrary to the above, Pd-1-99-004-C62K, Rev. 1, sheet 2 of 2 was voided, but the computer continued to list the drawing as current and active. (Computer data were corrected when this error was noted by the TF.T.)
- b. OCP-3 (Rev.18), paragraph 3.2.2.5, states, in part, that: "If, for any reason, a superseded document is retained, the face of the docu-eent must be stamped or marked 'VOIO.' When no longer required, superseded documents should be destroyed."
Contrary to the above, the following conditions were found in satellite 307 on July 31, 1984:
(1) 1-002-5-09 docu ent package listed 18 design changes outstanding; however, 20 changes were in the package, including one super-seded and one voided package that were not appropriately marked.
(2) Two voided design changes were listed and included as current in design packages (CriC 62535, Rev. O, against M1-2607 and DCA 13170, Rev. O, against MS-034) but these were not appro- .
priately marked.
(3) A superseded drawing, RH-1-SB-006, Rev. 13, was found in the files on July 31, 1984, but was not appropriately marked.
- c. OCP-3 (Rev.18), paragrach 3.1.2.4, states, in part, that "Controlled docuvents affected by design change documentation shall be stamped as follows: 'THIS DOCUMENT AFFECTED BY DESIGN CHANGE.'"
3
O ,
Contrary to the above, drawing aumbers 2323-MI-2301-10, -2304-01, and -2304-05 were in the 307 satellite files on July 31, 1984, and DO-2-099-709-553R was in the hands of hanger craft personnel and were not stamped "This document affected by design changes," even though each document was affected by changes.
- 8. Attachments: None.
- i Reference Documents: '
i I 1. Procedure OCP-3, "CPSES Document Control Program," all revisions.
~
- 2. TUGC0 Nuclear Engineering Manual, specifically TNE-AD-4, "Control of Engineering Documents," Revision 4
- 3. AQ-16: A-2 March 7, 1984, letter, item No. 3; and A-5 item No. 1.
l 4 A0-57: 04-34-014 March 8, 1934, and A-15 testimony, pp'. 23-25.
- 5. . AQ-59: 04-54-014 March 5, 19!4 anc A-15 :estimony, op. 46, 47, 53, 54.
- 6. AQ 60: 04-34-014 March 8, 1984, and A-15 testimony, pp. 60-61.
- 7. AQ-71: A-2 statement and interview, pp. 54-74.
- 9. This state.ent prepared by:
V. Wenczel, Date TRT Technical Reviewer l Reviewed by:
H. Livertore Date Group Leader
! V. Noonan OAte
! Project Director i
4 l
, - - - - - - , - - - - - . - - - - , , - - - - ,, , ,-y,, --
y __,__ n,_ __,,___
- 1. Allegation Category: QA/QC 5A, Repairs, Rework, and Maintenance
- 2. Allegation Numbers: AW-37 and AQ-52
- 3. Characterization: It was alleged that a 4- or 6-inch stainless steel check valve was disassembled for a weld repair without a written procedure for the disassembly and reassembly (AW-37) and site personnel interchanged parts of diaphragm valves during disassembly and reassembly operations 2) 4 Assessment of Safety Significance AW-37: In its assessment of this allegation, the NRC Technical Review Teaci (TRT) found that Brown & Root (B&R) procedure CP-CPM-6.9, Rev 0, "Gene-ral Piping and Inspectier Procedure," Section 3.6.17, contained the detail requirements for the control of the disassembly and reassembly of valves curing the installation process. The control was implemented by use of an operation traveler which directed craf t personnel to disassemble and reas-semble the valve in accordance with the manufacturer's instruction. The TRT examined a typical operation traveler, W 79-106-5600, dated March 19, 1979, for the installation of valve tag numbers 3616A&B in the boron re-cycle piping system at the 831-foot elevation in the Auxiliary Building.
The TRT found that the manufacturer's instruction was attached to the tra-veler in compliance with the procedure. The TRT also noted that the disas-se?bly and reassembly operations required a quality control (QC) inspec-tion and evidence of that inspection by the ir,6l*ctor's signature and date on the traveler. The QC inspection was required by B&R procedure QI-QAP-11.1-26, "ASME Pipe Fabrication and Installation Instruction."
The TRT was unable to identify the valve referred to in the allegation; however, by reviewing the applicable procedure and a typical operation travel,e,r for valve installation, the TRT found evidence of compliance with .
procedural controls for performance of valve disassembly and reassembly in accordance with manufacturer's instructions.
05/07/85 1 CCMANCHE PEAK AW-37 & A0 52 w
RIV inspection report (IR) 79-22 provided the details of the RIV investigation of the subject of allegation AW-37, including interviews with the alleger and a witness to the event alleged. The report concluded: the witness stated that the valve in question was a 6" check valve and that proper repair and resolu-tion of the initial discrepancy was complete and documented. Furthermore, there is no evidence that would suggest that a procedure discrepancy (lack of a procedure for valve disassembly / assembly) Cited by the alleger would have a potential detrimental impact on the health and safety of the public.
Although the valve alleged may have been disassembled and reassembled without a procedure (at the time of the repair), the RIV inspection found that an accep-table repair was accomplished. Also, the alleger acknowledged that defects in safety-related components did not go uncorrected. Region IV found that there was no evidence to suggest that the procedure discrepancy cited by the alleger would have a potential detrimental impact or, the health and safety of the public.
The TRT concludes that disassembly and reassembly of this type of valve (s.ing check) is a simple process by the craft personnel and that since valves are subjected to testing and/or inspection during system pressure (hydro) testing, the N-5 walkdown, flushing, startup procedures, and preoperational testing, the Region IV finding is valid.
AQ-52 To assess the allegation that site personnel interchanged parts of dia-phragm type valves during the installation process, the TRT reviewed B&R procedures applicable to the control of materials and equipment, piping installation and inspection, and the disassembly of valves. Included in this review were CP-CPM-6.9, Rev. 0, "General Piping and Inspection,"
CP-CPM-6.9E, "Pipe Fabrication and Installation," ACP-3, "Receipt 5torage and Issue " CP-CPM 8.1, "Receipt Storage and Issuance of Items," MCP-10, "Storaje and Storage Maintenance of Mechanical Eouipment." CP-CPM-9.18. .
"valvt Disassembly / Reassembly," and QI-QAP 11.1-26, "Piping Fabrication
, and Installation Inspection."
. 05/07/85 2 CCKANCHE PEAK AW-37 & AQ-52
r r
From this review the TRT fourd that the valve disassembly and reassembly, and the control of the recsved valve parts, were required by CP-CPM-6.9 as ;
follows: "All parts removed from the valve shall be stored in a heavy !
duty plastic bag, or in the casa of a large valve, a woodin or cardboard box. The mechanical superintendent (MS) shall mark the box / bag with the !
valve number." The TRT noted that while this procedure intended to require ;
that parts be reassembled to the same valve body from which they were origi-
! nally removed, there was no explicit instruction to prevent the reassembly l
of parts into a different valve body. [
) l t
The TRT found that the process for the installation of a valve was further j controlled by a construction operation traveler for valve disassembly and !
reassembly. The traveler scecifically identified the valve by the tag nua.cer and serial number and stated the assigned location at which the valve was to be installed. The traveler also included instructions for . ;
the disassembly and reassembly of the valve and control of the removed ;
parts in accordance with CP-CPM-6.90. ,
t The TRT examined a typical traveler (MV-79-107-5600 dated March 19,1979) [
for the disassembly and reassembly (for installation) of a 3-inch manually I o;erated (handwheel) diaphram valve, Tag No. 8616B, Serial 75-4105-12-3, !
which was installed in the boron recycle piping systet (Ref. drawing [
BRP-BR-X-AB-018, Rev 2) in the Unit 1 Auxiliary Building at the 831-foot [
elevation. The manufacturer's instruction for disassembly and reassembly :
and the rechanical supervisor's request to disassemble and reassemble. [
were included with the traveler. The required QC inspection signatures and date were on the traveler. The TRT found that the activity prescribed ,
by the traveler was in compliance with the applicable construction instal-lation and inspection procedures. Since procedure CP-CPM-6.9E' requires identification of the parts traceable to the valve number from which the f parts were removed, and the operation traveler identifies that valve number, l compli,ance with the operations prescribed by the traveler requires that ,
parts.be *eassemoled to the same valve body from which the parts were removed.
05/07/85 3 COMANCHE PEAK AW-37 & A0-5
i The TRT reviewed drawings 2323-MI-0241 and 0242 (demineralized and reactor !
water make-up flow diagrams) to determine the locations of the type of valves referred to by the a11eger. They were 3-inch butt weld, hand-operated diaphragm valves installed in systems such as the spent fuel [
cooling, boren recycle, and chemical and volume antrol systems. l The TRT found that installation of these butt-welded valves required dis-assembly and removal of internals to protect temperature-sensitive parts. !
Interviews with engineering and QC personnel, as well as review of docu-mented deficiencies, verified that during installation the valve parts were stored in uncontrolled areas, which resulted in lost, damaged, and sometimes interchanged parts. Interviews with site personnel also indi-cated that although the generic traveler used for original installation of these valves contained a requirement to package and identify loose parts (traceable to the valve) in accordance with CP-CFM-6.9, it was not adequate to prevent lost or interchanged parts because these conditions continued.
Subsequent revisions of this generic traveler added a requirement to record the heat numbers of the valve body and bonnet prior to disassembly to pro-vide further assurance that the part (Bonnet) would be reassembled to the valve b:dy from which it was removed.
A TRT walkd:wn field inspection identified similar 3-inch ITT-Grinnell (ITT-G) diaphragm valves rated at different pressures. The TRT determined that if the valve bonnets on these valve bodies were interchanged, a po-tertial problem of safety significance would exist. Conversations with ITT-G and TUEC engineering personnel identified a concern that if a valve bonnet rated below 275 psig was assembled with a valve body installed in a system with pressure greater than 275 psig, galling could occur in valve stem components. However, both ITT-G and TUEC personnel indic6ted that valves parts of identical design temperature end pressure could be inter-changed with no effect on valve function. The TRT learned that this type of ing,erchange occurred on valves of the same gressure rating and was doc- ,
umented on $1 permanent equipment transfers (PET) which involved valves reassembled between July 1981 and October 1984. The TRT assessed this interchange of parts as a noncompliance with CP-CPM-6.9, the operation traveler, and/or CP-CPM-9.13.
05/07/85 4 CCMANCHE PEAK AW-37 & A0-52
o The TRT obtained the receipt and inspection reports which documented the natching body and bonnet heat .sumbers of 136 valves arriving onsite in May 1976. The TRT conducted a field inspection of 32 of these valves to en-sure traceability of the heat num.bers from receipt to installation. Three valves (Tag Numbers 1-70148, 2-8475, and 1-8683) were found with a mismatch between body and bonnet heat numbers from these identified by receipt in-spectien. FurtS
- review by the TRT found that the mismatch was documented on PET numbers H 3, 183, and 219. A review of the pressure and temperature ratings of tM interchanged valve components indicated that they were equivalent, The TRT feund no examples of a mismatch between valves of differing pressure ratings, although the potential for this existed e.se to the sit) Mctice of mass disassembly of valves using potentially inef-fective or peerly implemented procedures. ,
The TRT interviewed QC inspectors who knew of recent incidents involving lost, misplaced or interchanged valve bonnets. The QC inspectors stated that when ti.ese valves were disassembled for system flush under the direc-tion of startup test enginears, one bonnet was lost and a mismatch between valve body and bonnet occurred. Although these incidents were documented in nonconformance reports, see e.g., NCR M-11645 (May 8,1984), the prob-lems associated with maintaining control of vahe parts during installation, -
system flush, and startup indicated to the TRT that in spite of the issuance of the revised traveler and CP-CPM-9,18 in June 1933, loss, damage, and interchange of valve parts continued to occur. Tne TRT did not find any evidence that B&R addressed the problem on a pregra .?atic basis, e.g., by use of a formal corrective action request (CAR).
- 5. Conclusion and_ Staff position: Af ter reviewing cirawings, procedures, and a typical construction operation traveler, the TRT was unab'* substan-tiate allegation AW-37, a finding in accord with thai expressed by RIV in IR79-22. The TRT further agrees with the RIV conclusion that there is no evidence to succest that. the crocedural discrepancy would have a cetri-eental impart on the ne61th and safety of the pu:,lic.
05/07/85 5 CC".ANCHE PEAK AW-37 & AQ-50
r r
The TRT concludes that allegation concerning interchanged valve parts (AQ-52) was substantiated. The TRT also concludes that this condition har.
potential quality significance cat to the generic implications. The gene- [
ric implications are based on occumented evidence that the interchange of valve parts did occur and effective programmatic corrective action was not implemented to identify the probl6m and ts prevent the loss, damage and interchange of valve parts.
The TRT attempted to contact the alleger to discuss the findings and con-clusions of this assessment, but the alleger declined furtNr contact with
- the TRT.
A. Actions Reevired, ,
l l 7. Potential Violation: 10 CFR Part 50, Appendik B, Criterion XVI corrective I
action requires J
Measures shall be estr311shed to assure that conditions adverse l
to quality, such as f ailures, malfunctio' ;, deficiencies, devia-l tiens, defective material and equpiment, and nonconform?nces are !
t
- promptly identified and corrected. In the case of significant [
conditions adverse to quality, the esasures shall assure that j the cuase of the (ordition is determined and corrective action taken to creclude recetition.
r Contrary to the above, % asures were not taken te issure that the cause of !
the lost / misplaced or int;rchanged valve componer,ts was determined and !
- corrective at. tion was not taken te identify all affected equipment V to j preclude repetit'ea. as evidenced by nonconformance reports (e.g., MJ013 ;
dated November ; '2e ; M3090 dated December 8,1984) issued o'ver a three- !
tear peried. This .c,ntitive condition is also documented in permanent i eovicqent transfers covering a perted from 1981 (e.g., PET 139) :hrough , f 1934 (PEil546). l i
r l
l t
05/07/$5 6 CCMANCHE PEAK AW 37 & AQ-50 l
[
i
L L
o Reference Occuments:
- 2. ACP-3 (replaced by CP-CPM-8.1 Rev. 1), "Receipt, Storage and Issuance Items."
- 3. MCP-10, Rev. 7, "Storage and Storage Maintenance of Mechanical and Electrical Equipment."
4 CP-CPM-L 9E, Rev. O. "Pipe Fabrication and Installation."
- 5. 01-0AD-11.1.39A. Rev 0 (issued June 8, 1983) "Valve 01sasserely/
. Reassembly."
- 6. CP-CPM-9.18, Rev 0 (issued June 8,1983) "Valve Disassembly /Reasse251y."
- 7. Flow diagrams X2323-MI-0241 and 0242 of the comineralized and reactor makeup water.
- 8. Valve tag numbers XSF-083 and XSF-089 per 50-C-105636; 8616A ano 36163 per SD-C-100551,
- 9. Perma = . . : t-- transfer forms 139, 183 and 219.
- 10. Operation travelers HW 80-673-4700, FW 80-673A-4700, and MW 79-107-5600.
- 11. ITT-Grinnell Corp., "3" Nuclear Diaghragm Valve H.W.O.," drawings SD-C-105686, Rev. 8 and 50-C-100551, Rev. H.
- 12. 40-52: A-7 testi ony, March 7, 1954, pp. 12-14.
05/07/85 7 COMANCHE PEAK AW-37 & AQ-50
- 13. Drawing MI-0225 (Valve Tag Nos. 1-8440, 1-8481A, and 1-84818).
- 14. Drawing MI-0263 (Valve Tag Nos 1-8949A thru 0). l I
- 15. RIV IR 50-445/79-22; 50-446/79-21. !
e
- 16. QI-QAP-11.1-26, "ASME Pipe Fabrication and Installation Inspection." ,
F
- 17. CP-CPM-6 9, Rev. O, "General Piping and Inspection Procedure" and Rev. 1. "General Piping Procedure."
L This statement prepared by-9.
J. H. Malonsen, TRT < Date :
. Technical Review Team I Reviewed by:
H. Lisermore, Group Leader Date I Approved by:
V. Noonan, Date Project Director 05/07/85 S COMANCHE PEAK AW-37 & A0-52
i i
- 1. Alle;ation Cate3ery:
r QA/QC 6B, Onsite Fabrication
- 2. A11ecation Number: AQ-77, AQ-79, and AQ-138.
- 3. Characterization: It is alleged that the onsite structural f abrication I and hanger shop (iron fabrication shop) made t'omponent parts, such as eye- !
4 bolts (!-bolts), as replacements for parts that were lost after receipt ;
inspe: tion (AQ-77); that safety related parts were mde in the iron fabri-cation shop in response to telephone requests, without any fabrication in- i 1 structioqs or the required quality control (QC) inspections (AQ-79); and l that (1) craft personnel in the iron fabrication shop were asked by their '
supervisors to perform work without any knowledge of the pap'erwork, (2) the f
, oaperwork was illegal because it was post-dated, (3) nonsafety-related l material was mixed with safety-related material, (4) a supervisor directed ,
personnel n:t to mark indeterminate material as scrap. (5) during consolte dation of the electrical and iron f abric. Lion shops, safety-related mate- l
> rials were mi..ed from both areas, (6) electrical fabrication personnel used l undocumented material, (7) ASME QC personnel in the iron fabrication shop did not check Brown & Root (B&R) f abricated threads, (8) undocumented weld [
i repairs were made on base metals, (9) thrc:d:d r:d was cut in the ir:n fab- '
i rication shop without a QC check to verify the heat numbers befo e cutting, (10) are gouging (cutting) on stainless steel was done too close to the cut
! line to minimize grinding time (11) beam clips may have been cracked during I the fabrication process, and (12) a device (stainless steel hook and chain) was fabricated without regard to procedure (AQ-136).
- 4. Assessment of Safety Stanificance:
AQ-77 The NRC Technical Review Team (TRT) review of this allegation found that the prh esses used for B&R shop fabrication and OC inspection of component parts were addressed by site construnion procedure CP-CPM-9.10. "Fabri-l cation of ASME-Related Components and Component Supports." QC inspection was controlled by procedure 01-QAP-11.1-28, "Fabrication, Installation
- Inspections of Safety Class Component Supports." The TRf ir.terviewed l
i i
C5/07/85 1 AQ-77, 79 & 138 !!
0 fabrication shop personnel and observed fabrication work inprocess. When vendor-supplied item replacements and modifications were fabricated onsite, d
specific instructions were provided by engineering on a canstruction opera-tion traveler and vendor concurrence was obtained, either by signoff by the site vendor representative or by correspondence. Component support modification was controlled by procedure CP-CPM-9.13, "Modification of l Vendor-Supplied Catalog Items." The TRT examined the following quality l
controlled work packages from the iron fabrication shop and found that the work was performed and inspected in compliance with the applicable procedure. ,
Sway Strut / Eye Red H-CS-2-SB-083-002-2 ,
i Hanger CS-2-327-406-556R I - -
Rear Bracket VD-2-013-437-536R j $*ay Strut C5-2-58-079-005-2 .
Hanger MS-2-RB-040-004-2 Vortex Breaker Cage N34-6511-8902 4
This list of work pac h ges included both safety-related and nonsafety-related assemblies. $ince safety-and nonsafety- elated work was conducted cercurrently in the iron fabrication shop, close examination of the opera-tion travelers and the hanger packages was required to distinguish between them. The TRT also reviewed the processes used in cutting, grinding, fitting, and assembling components onsite. This review revealed that current shnp practices were in compliance with the applicable procecures and that material acceptability and traceability were documented as required by those procedures.
The TRT discussed the B&R fabrication of I-Bolts with the superNisor and foremen in the iron fabrication shop. They stated that the shop fabricated the I-Bolts as replacements for vendor-supplied items that were missing or lost after receipt on site. The I-Bolts were used for rigging and hoisting .
vendo, components. These I-Bolts were not part of the QC package, that is, they were not subject to the same rigorous standards as permanent (safety-related) hanger and strut components. Further, TRT interviews with field C5/07/55 2 AQ-77. 79 & 133 !!
o
. r l
i installation personnel indicated that the I-Bolts were load tested and in-spected prior to use to assure that appurtenances of safety-related compo-t i nents were not overstressed during hoisting and rigging activities. The TRT found no examples of undocumented fabrication of I-Bolts which were used for permanent plant installation. ,
i :
- A0-79 To assess the allegation that safety-related parts were made in the iron l fabrication shop without fabrication instructions or the required QC inspections, the TRT interviewed the shop supervisor and shop craft person- *
, t nel, reviewed the applicable procedures, and observed shop fabrication work in process. The TRT found that shop fabrication work was controlled !
I by procecure CP-CPM-9.10. "Fabrication of ASME-Related Component Supports.,"
- and CP-CPM-9.13. "Modification of Vender-Supplied Catalog Items." The QC g
inspections applicable to this activity were required by QI-QAP-11.1-28, 4
"Fabrication Installation Inspections of Safety Class Component Supports." [
I The TRT noted that procedure CP-CPM-9.10, Rev. I'., Section 2.1.4 stated: !
1 Parts for a support, e.g. t456;,14t65, strateral members. I etc., may be fabricated without a drawing or hanger package I provided they are described on the MIL (Material Identifica-tion Log) and verified by QC as required by 2.1.1. However, .
- when the parts are being assembled into a support, the .
4 hanger package shall be intact unless the MIL must be l l
removed to fabricate another part. I
, t The TRT found that the parts referred to in the allegation were additional
! parts or replacements for parts which (for some unspecified reason) were not
! usable when the support was in the process of being installed. Shop fabri- ;
l cation required selecting the correct material and cutting the inatorial l l to the requested dimension. Although the shr.,p fabrication may have been j accomplished without documented instructions and the shop QC inspection may not have been performed, the acceptability for use and the material trace- [
l I ability were documented by QC inspection at installation on the hanger inspection report (pe" Ql-QAP-11.1-28, Atta:hment 2). The TRT assessment i of allegation AQ-138 also addresses the lack of required documentation l
i i i I I
05/07/S5 3 A0-77. 79 & 133 II
. - - - . . _ , - . - - - . ~ . . _ - - - - _ - - _ . - . _ - _ - . , _ _ - - - - ,._-___.__ __ - -
l I o
I (instructions) at the time that work is performed in the iron fabrication shop; therefore, this allegation is substantiated. ,
Although this allegation specified no particular parts, the TRT reviewed work packages for a hanger (MS-2-RB-040-004-2), a sway strut (CS-2-SB-079-005-2), and a vortex breaker cage (MX84-5811-8902). The TRT identified the processes used in cutting material for hangers as mechanical sawing, grinding, and thermal cutting. The TRT found that traceability documentation was properly transferred to each piece cut and that QC inspector verification was recorded on the appropriate document. The TRT found that current shop practices were in compliance with the procedures reviewed.
The T;T intervie ed representatives from TUEC concerning the allegation, but could identify no specific examples of work perfortred as the result of telephoned instructions. TUEC personnel acknowledged that the iron fabri-cation shop may have received telephone requests to fabricate a part, but j only in accordance with a previously issued drawing to which the shop had
)
access. When such a request was trade, the shop work order was subsequently l t
, sent. TUEC personnel also stated that if a hanger installation required a i s
l
-eplacement part, the material traceability was maintained by use of the MIL in accordance with procedure. The TRT reviewed the MILS on the shop work packages and determined that TUEC's statements were correct. ;
F 1
A0-138 (
l !
- 1. To assess the allegation that iron fabrication shop personnel were asked to perform work without any knowledge of the paperwork (e.g.,
{
drawings, travelers, and hanger packages) the TRT performed an un- [
announced audit of inprocess fabrication activity in the iron fabrica- l tion shop. The TRT assessed the availability of hanger packages and l ttavelers and the documentation included to determine if the informa- . !
tion provided was in accordance with procedures ano if craft personnel I had the required information (documentation) to perform the assigned task.
i !
05/07/85 4 AQ-77, 79 & 135 !*.
1 L
a 0
The TRT audited eight hanger packages and travelers at the location where the fabrication shop activity was in process at the time of the audit. The documentation audited covered fabrication of ASME Code class supports, nonnucleL.-safety supports, miscellaneous steel, electrical supports, and modification of vendor-supplied items (e.g.,
snubber-spring hanger). The TRT reviewed procedures for fabrication /
installation, inspection, material traceability, and receipt and storage, all of which are applicable to activities performed in the iron fabrication shop. The TRT found that the audited hanger packages and operation travelers contained the documentation (e.g., drawings j and MILS) required by the applicable procedure and were current for the status of the work inprocess. ,
- The TRT notec that procecure CP-CPM-9.10, Section 2.1.4, allows shop
,r fabrication of parts for a support without a drawing or hanger -
package provided the parts are described on the MIL and verified by CC.
The TRT did not find any examples of shop fabrication of safety-related material in process without the recuired doc u entation being available at the location where the work was performed.
During discussions with the iron fabrication shop foremen and the assigned QC inspectors, the TRT found that the shop foremen assigned to snop fabrication of non-nuclear safety seismic category !! pipe supports (procedure CP-CPM-9.9), miscellaneous steel (procedure CCP-21), and electrical supports (procedure ECP-19) could not iden-tify and were not familiar with the shop fabrication procedures which controlled the work performed under their supervisory responsibilities.
Although the TRT did not find any examples of unacceptable quality workmanship, the TRT found that the foremen's lack of knowledge of tt.ese procedures indicates need for procedure indoctrination and .
mdditional train;.ig for the foremen.
The TRT reviewed the documentation furnishec by the alleger which identified materia' ceevisitions (MRs) as specific examples of the 05/07/55 5 AQ-77. 79 & 135 II
O l I
allegation that iron fabrication shop personnel were asked to perform work without any knowledge of the paper work (e.g. controlled drawing,
- hangerpackage,ortraveler). The TRT interviewed the shop general foreman and the MR coordinator, reviewed the applicable procedures and the shop MR file. The TRT found telephone requests, memos, and <
sketches attached to the MRs. In further discussion with the foreman and coordinator, the TRT found that the shop fabrication work was performed in accordance w th the MR instead of: (1) the hanger d
package as required by procedure CP-CPM-9.9, Section 3.1, which i l states, "fabrication shall be accomplished in accordance with the j hanger package"; and (2) controlled drawings as required by procedure CCP-21, Section 3 1.3, which states, "all work shall be accompitshed -
in accerdance with centre!1ed drawings." Procedure ECP-19. "Exposed l
- Conduit / Junction Ben and Hanger Fabrication and Installation," does t
] not contain a requirement for the availability of the hanger package, ;
er traveler at the location where fabrication is performed; however, l
)
tne TRT also found that parts were fabricated as directed by the MR without the availability of the hanger package or traveler in the iron fabrication shep. The TRT found that +.he CC inspection and material T.raceability were recorded on the WR, i,
The TRT found that MRs issued in the iron fabrication shop were not l prcperly prepared in accordance with procedure Cp-CPM-8.1, "Receipt, l Storage, and Issue of items " Section 3.4 The MRs did not cortain the infor ation required by the block titles, e.g., material type was !
entered in the code class column, the code class was not identified, [
and the vague information entered for intended use was taken from the requestor's memo or sketch rather than specific information given on [
the appitcable drawing, hanger package, or traveler. Cons,idering i these conditions, the TRT agreed that iron fabrication shop personnel ;
performed their work without the required paperwork (documentation f r,ecuired by orocedures). .
- 2. The alleger did not identify any specific items for the allegation l that the paperwork was illegal because it was postdated. This alle- }
gation is addressed in the previous paragraph as it relates to work 05/07 H f A0-77. 79 & 135 II
O 4 performed without knowledge of the papenverk. In the TRT interview with the alleger, the alleger stated that he had refused to do work in accordance with a note paper sketch, and a day later, a traveler was written to Jocument the fabrication process, thus the allegation.
- The TRT found that although sketches were used, the material issue, ;
fabrication activity, material traceability, and QC inspection were documented on an ar.cortpanying MR. The MR traveled with the fabricated items to the installation location, where subsequent QC inspections documented the acceptability of the item in the hanger package or en the operation traveler, i
- 3. To assess the allegation that nonsafety material was mixed with safety material ir the 1*en fabrication shop, the TRT, accompanied by
- a representative from the B&R material control group, examined the 4 eulk material and vender-supplied supports storage areas to learn the standard onsite procedures and methods for segregating safety and r.onsafety materials. The eaterials were identifiable and segregated as required. Based on the satisfactory compliance with methods and procedures in those areas, the TRT, accompanied by fabrication shop personnel, also examined the iron fabrication shop material storage (laydown) areas, where the IRT found d&signatsd areas for the storage of safety-related bulk materials. A sampling of the material revealed heat number markings, as required. The TRT found a pile of scrap eaterial, which although it was separated fecm other traterial, was not identified as scrap material, nor was the area in which it was found identified as a scrap / salvage area. The TRT also found that unidentified bulk materials were mingled with safety and nonsafety material in the laydown yard adjacent to the former electrical hanger shop. This condition was in noncompliance with procedure 'CP-CPM-8.1, Sections 3.3 and 3.5 which states
.. 3.3 Within each of the storage areas (type A through E as .
- delineated in Appendix 1) safety-related items should be physically separated from nonsafety-related items and identified. Where segregation is not practical, due to si:e, configuration, or specific storage requirements, 05/07/S5 7 AQ-77, 79 & 135 II
o l
t etc., positive identification shall be maintained which l clearly identifies the material.
3.5 Items which have been withdrawn from the warehouse and are net needed shall be transmitted to the warehouse by the "Material Return to Warehouse" form (Attachment 3). [
I In further assessment of this allegation, the TRT noted that proce-dure QI-QP-11.14-1, "Inspection of Site Fabrication and Installation of Structural / Miscellaneous Steel " Section 3.1, requires that "The QC inspector shall perform random surveillance over storage and '
control of materials in the Structural /Miscellareous Steel shop area to assure orooer storage and control of materials in ac'cordance with Reference 1-C and as folle=s: safety-related material for items i
requiring traceability through installation shall be segregated from, other materials and shall be identified by heat number at all times." l The TRT found no evidence that the required random surveillances were .
performed, a condition in noncompliance with the procedure quoted. !
i 4 It was alleged that a supervisor directed craft personnel not to mark t indeterminate (non-traceable) material as scrap. The TRT did not find any procedural requirement for identification marung or color ;
coding of scrap. The TRT revte.ed record documentation and found !
that the material identified b'y the alleger as indeterminate was in 74.. .is: 'e by heat nunber.
- 5. It was alleged that during consolidation of the electrical and the j tron fabrication shops, safer.y-related ("Q") materials from both ;
areas were mixed. In its assessment, the TRT observed that the !
storage area (laydown yard) was a common area for the storage of I material for the fabrication of both electrical and component ,
wpports. The TRT found that BAR orocedure ECP-19. Section 1.1., -
i states, in part: "Structural steel members are to be those obtained I r
from the electrical feb shop or (from) designated "Q" storage areas." [
The TRT noted that according to the procedure, there was no conflict i in regard to the location where "Q" materials were stored or obtained.
05/07/85 S AQ-77, 79 & 135 II
t
. 8
- 6. To assess the allegation concerning the use of undocumented material in the electrical fabrication shop, the TRT reviewed electrical support traveler packages and observed the shop fabrication work in process. The TRT also considered the assessment of this allegation during the verification of documentation for the assessment of other allegations reported in this assessment (e.g. material traceability and work performed without knowledge of the paperwork). The TRT found compliance with traceability requirements for heat number, unique number, and coating code number. The TRT also found that the ,
QC inspection process for verification and documentation assures the :
use of and documentation for traceable material. Although the alleger did not identify a specific instance of undecumented material use, the TRT fogad that the crocedures, as impletented, would prevent the use of undocumented materials.
- 7. It is alleged that the AWE QC inspector in the iron fabrication shop did not check threads on any job unless it was a prescribed operation '
on a traveler requiring CC inspection. To assess this allegation, I the TRT reviewed fabbrication procedure CP- FM-9.10 and the QC inspec- i tion procedure QI-CAP-11.1.-23 and the TRT found that neither document j reautres the QC inspection of threads fabricated in the iron fabrica=
tion shop. The TRT % nd that operation travelers were neither !
required nor t ed for the fabrication and inspection of threaded rod f used in ASME-related safety class components supports, In its review l cf the fabrication procedure, the TRT founc that the procedure cid not j provide a general reference to design drawings or the identification l of the design specification or specify a national standard that would enable the acceptable fabrication of threads in conformanc,e with l design specification to assure quality (e.g., size, pitch, length, l and class of fit).
1.no TRT interviewed a B&R ovality engineer assigned to ASME-related -
construction activities who explained that B&R reited on inspe: tion i during installation as the means to assure the quality and accept-f ability of the B&R fabricated threads as defined in QI-QAP-11.1-28.
The TRT also reviemed a typical hanger inspection report and verified L
l 05/07 'SE 9 A0-77. 79 & 13S II
i
. E
- that the thread inspection requirement was defined. The TRT found ;
d that the threads fabricated in the iron fabrication shop were l inspected in compliance with the requirements of the applicable ;
procedures at installation.
4 !
- 8. It was alleged that undocumented weld repairs were made on base metal i l
- (plate) which had been damaged by flame cutting during the fabrication process. To assess the allegation, the TRT reviewed TUEC procedure !
QI-QP-16.0-5, "Reporting of Base Metal Defects," and B&R procedure I CP-CPM 6.90, "Welding and Related Processes," which controlled the ,
t
. alleged activity. The TRT interviewed the shop general foreman, ;
foremen, QC inspectors, and welders, all of whom stated'that it was i standard shcp practice to discard a damaged piece and cut a new piece j
' as a replacement, The personnel demonstrated a knowledge of the j procedural requirements for reporting base metal defects. During . ;
discussms, welders den.onstrated an awareness of the procedural constraints on repair welding and the requirements for authorization of, and documentation for, repairs made by a weldirg process. The ,
l TRT could not find any occurrences of the alleged practice during its (
~
audit and shop walkdowns. The TRT found that procedures were imple- l 1 mented and that the alleged repairs, if they occurred, were not ;
standard or common shop practice. )
}
! i i t i 9. It was alleged that QC inspection verification of heat number was not l i
done before threaded rod was cut into pieces. In its assessment of ;
j this allegation, the TRT found that B&R procedure CP-CPM-9.10, Sec- (
) tion 2.1.2, required that the transfer of traceability marking be l Verified by QC prior to cutting, except where marking was not possible j such as on rods threaded the complete length of the piece. Standard f j practice in the iron fabrication shop was to obtain a length of bulk l l rod, record the heat number on the M!t. or other required documentation. I
- tAread the rod, cut the required number of pieces, and mark the heat - i resmber on the ends of the cut pieces. The marked cut pieces, and any f j remaining length of the threaded bulk rod, were then QC inspected. By l comparing the number marked on the cut pieces to the number recorded l on the MIL and on the remaining bulk rod, the QC inspector verified !
l t I
05/07/S5 10 AQ-77, 79 & 138 II l
[
l l
f the accuracy of the number transferred. The TRT witnessed the thread- !
ing of rod for drawing item 15 of hanger 51-2-031-430-532A and found l that the activity was done in compliance with procedures CP-CPM-9.10 and QI-QP-11.1-28, which were applicible to the fabrication and )
i inspection of A5ME-related component supports. The TRT found that traceability was maintained. I 1
t
- 10. It was alleged that are gouging (cutting) on stainless steel was done as close as possible to the cut line to minimize grinding. B&R proce-dure CP-CPM-9.10, Section 3.3.5, states that, "Stainless steel base !
plates may be thermally cut by are gouging. After the thermal cutting process,1/3 inch of material shall be removed from the thermally cut 3
ecges by geinding." To assets the allegation, the TRT intervie=ed the ;
iron fabrication snep foremar and CC inspector who were responsible
$ fortheironshopfabricationendinspectionofA5ME-relatedcomponent ;
cuports. Tb: fore-an stated that it was standare shop practice to lay out stainless steel materials to e 1/8-inch minimum oversize cut i j dimension of when the prescribed method of cutting was by are gouging. j The foreman also stated that it was stand 4*d shop practice for him to [
i check lay out dimensions prior to the cutting of materials by the (
l craft personnel. Although he was unable check 100 percent of the l l
l layouts, the foreman stated that he does check more than 90 percent. l The assigned QC inspecter stated that the cut edges were checked f visually for acceptability concurrently with dimensional inspection I l price to release from the shop. The foreman then stated that he f I performed a check of the traveler package and a visual check of the condition of the fabri ated item to assure its acceptability before [
l it was released for field installaation. No are gouging was in j i process during the TRT's observations of shop activities.' Arc gouging and removal of the heat affected zone adjacent to the cut is standard industry practice. The TRT could find no examples that this practice n s vioiasee.
l j . ,
i I
- 11. During the TRT's interview with the alleger, the TRT was requested to {
I look specifically at two jobs: beam :. lips that may have been cracked, j i
i !
1
! 05/07/55 11 AQ-77, 79 & 133 I:
I l 1
O l
and a triple hook on a 30 foot-long stainless steel chain which was hot formed and documented after it was built.
In its assessment of the beam clips, the TRT found that the allegation <
referred to beam clips bent to prescribed angles for welded installa-tion in the patch panel platform in the reactor building (RB), Unit 1.
The clips were identified in the bill of material included in DCA
(
17551 (Revision 6 to drawing 2323-51-0525) as piece 20, SA36 plate (structural steel), 3/8 x 3 1/2 x 8 inches.
L The TRT was unable to verify the alleged condition of the clips i because they were welded in place with the outside radi,us on the side hideen from view. To assess the octential for the alleged condition,.
the TRT requested that the iron fabricat. ion shop form a 90' bend on a like piece of the same heat number material from which the original , ;
clips were fabricated. The sample piece was cut as a longitudinal
[
section (with the grain) and cold formed to a 90' angle. The outer i radius was then wire brushed. Visual inspection (without magnifica- I tion) by the TRT detected minute surface indications which the TRT j assessed as nonrelevant indications (dtfects). The sample was then !
checked by the craftsperson who cut and formed it, and inspected by l
the QC inspector responsible in the area of the shop where the l original c1tps were produced. Both agreed that the sample piece was ,
j acce: table. The piece .as then subjected to a nondestructivo examina- ,
j tion by liquid dye penetrant (PT), visible color contrast eethed, and ,
i was found to have no indications. The method of forming was in ,
accordance with the industry standard practice and site procedures, j r
12, In its assessment of the 30-foot chain, the TRT reviewed the Final i Safety Analysis Report (FSAR) and interviewed TUEC project engineers :
to determine the identification and application of the device described (
tv.the alleger. The TRT interviewed the iron fab shop general fore- . ,
rsn and learned that, although the stainless steel chain was an odd or unusual item, he could not remember its fabrication. The TRT also ,
interviewed representatives from the material control group, the mill- f i
. L 05/07/55 12 AQ-77. 79 & 138 II i
.-__-__--_-__-_-----I
wright department, and a TUEC instrumentation engineer but could not find an example of the alleged device.
- 5. Conclusion and Staff positions: Based on its assessment of these allega-tiens the TRT conclusions are as follows:
AC-77 Onsite fabrication practices for the fabrication of replacement parts such as eye bolts, (I-Bolts) were properly controlled by construction inspection procedures and instructions. The TRT review did not identify instances where the iron fabrication shop made safety-related component parts without the a: ore;riate croceduces or without CC inspection and was unable to sub-stadtiate the allegatior. b e*=# m , v T i ss that tnu s;.,,...v.
PM *-
J-. . '; ., . . , - ' " : : ;; ^ ; ;; ^ ; > . i . g , a s . . s s . ,
AQ-79 Based on a review of applicabit documents, shop inspections, and interviews with TUEC personnel, the TRT concludes that the allegation that the iron fabrication shop made safety-related parts in resconse to telephoned instruc-tions rather than to written instructions cannot be traced to a specific event and, therefore, cannot be substantiated. (Also see allegation AQ-138.)
Sc e nonsafety-related parts may have been fabricated based on telephoned instructions; however, t.he TRT found nothing te tadicate that safety-related parts were fabricated in non-compliance with applicable procedures. Current
! iron fabrication shop practices also provide adecuate assurance that mate-3 rial traceability was maintained in compliance with the applicable proce-l dures. A cw w . me j , , > , . ' ' : '*"a he * * " " - ' ' '"; * ' ; ' ' ' ; . .. u o r
- gr . . _ .
d
) In a meeting with the alleger en Decet.ber 10. 1954, the TRT presented its .
l findin)s and conclusions for AQ-77 and AQ-79. The alleger cisagreed with the TRT's findings and conclusion for the allegation AQ-77. The original j allegation was that safety-related eye Delts were fabricated without any j instructions or documentation. No specific examples .ere found, althougn 05/07/85 13 AQ-77. 79 & 135 II
i the TRT did conclude that the fabrication shop was manufacturing parts t
without drawings and instructions. The alleger stated that, if allowed to l visit the site specific examples could be identified. The TRT believes that the alleger may be confused with the use of non-safety threaded rod j installed in the plant. The TRT position is that a specific example is net needed at this tin.e since our assessment did find procedural problems
! with the f abrication shop ( AQ-138). The TRT will follow up this item with I the alleger during our further evaluation. Any noteworthy additional l information will be added to a future $$ER. ,
1 >
1 .
I A0-138 l l lm assestim; the twelve ccmcerms enccmpassed by allegation AQ-138, the TRT l reVie.ed crocedures and coceemtation, audited f abricatien work in process, j witnessed the f abrication and pf examination of a comparison sample.
l witnessed the fabrication of threaded rods, and conducted a walkdown i verification of the material laydc.n storage areas. The assessment alic i included interviews with B&R shop foreten and craft personnel, QC inspec-
, tors, quality engineers, material control persennel, and a TUEC instrumen-tatien engineer.
l
!, The TRT substantiated tne a.a;stien (1) tha' tron f abrication shop person- ,
j nel were asked to perform work without knowledge of the paperwork. The I j TRT's assessment found that the fo11 ewing concerns were not substantiated:
l (3) safety and nonsafety materials were mixed (4) identification marking ;
on scrap material, (5) electrical shop safety related material was mixed i with iron fabrication shop material. (7) ASME QC did not check threads in
]
the iron fab shop, (9) ASME QC did not verify heat number on threaded rod
(
before cutting, and (11) beam clips were cracked in the f abrication process, f l
1 The TRT's assessment was unable to substantiate the allegations that:
- f j (2) cacerwork was illegal because it was post dated, (6) the electrical -
}
shop esed undocumented material (S) undocumented weld repairs were made l
on base retal, (10) are gouging on stainless steel was too close to the l
cut line to minimize grinding time, and (12) a stainless steel hook and l chain was fabricated without a procedure. [
l 05/07/S5 14 a0-77, 79 & 13S !!
1 l l .
, l t
1 i i
[
The TRT found procedural noncompliances, however, the documentation
~
examined by the TRT in the tron fabrication shop indicated that the
' required QC inspections were performed and material traceability was main-
~
tained and documented. The TRT therefore concludes that the procedural violations have quality significance and generic implications. [
1 In a meeting with the 411eger on November 14, 1984, the TRT presented its assessment of AQ-138 and its conclusion. The alleger had no major dis- L
, agreements with the TRT's assessments and conclusion. No new concerns or [
! allegations were identified. !
k
- 6. Actions Recuired . I
! f
- 7. Oct'ea.ti al Vi ol a ti on s : NRC Regulation 10 CFR part 50, Appendia B, Cri- f' terion y requires:
l; ,
l Activities affecting quality shall be crescribed by documented r i instructions, procedures, or drawings, of a type appropriate ;
i to the ciilumstances and shall be accomplished in accordance t j with the instructions, procedures, or drawings. Instructions, !
- procedures, or drawings shall include appeceriate quantitative i i or qualitative acceptance criteria for detemining that .
- im:ortant activities have been satisfactorily accomplished, j l
j 1. Contrary to the above, B&R site fabrication / installation procedures l
) do not provice the fabrication reevirements to assure that B&R j i f acetcated tnreacs conform to the cesign specification arc /or an t
I i
applicable standard. .
Section 3.4, requires that all items shall be issued by means of a l l
l material requisitics (MR) and further defines the typical information !
t i to be entered thereon. ;
I Contrary to the above and to Criterion V of 10 CFR Part 50, Appendix S, j y
! the TRT found that numerous MRs prepared in the fabrication shep do i s -
- not c eply with the procedure, i.e., code class is not identified and j intended use descriptions are vague.
i
- 05/07/85 15 AQ-77, 79 & 135 II ,
i.________,_____
- 3. B&R procedure CP-CPM-8.1, Section 3.5 states in part: "Items which have been withdrawn from the warehouse and are not needed . . . shall be transmitted to the warehouse by the Material Return to Varehouse Fo rs. "
Contrary to the above, the TRT found during an audit in August 1984, that material returned from the field was mingled with controlled !
(safety and nonst'ety) material in the laydown yard adjacent to the
{
foreer electrie,a1 support shop. The material was neither identified ;
nor acccmotnied by the required form. Also, this condition is in j noncompliance with CP-CPM-8.1 Section 3.3, which states in part,
"... safety related items should be segregated from nonsafety related items an identified...."
4 TUEC instruction QI-QP-11.14-1, Inspection of $ite Fabrication and Installation of Structural and Miscellaneous Steels, Section 3.1, requires that, "the QC Inspector shall perform random surveillance over storage and control of materials in the structural / miscellaneous steel shop area to assure proper storage anc control of material...."
Centrary to the ateve, there was no evidence that surveillance of storage areas was performad by QC.
- 5. B&R procecure CP-cpm-9.9 NN$ Seismic Categcry II Supports, Section 3.1, states in part, "Fabrication / Installation shall be accomplished in accordance with the Hanger Package. The Hanger Package will consist of the BRH drawing and Weld Filler Material Log (WFML) for each hanger listed on the BRH."
B&R procedure CCP-21, Fabricatien of Miscellaneous Steel, Section 3.1.3, requires "All work shall be acs:molished in accordance with controlled crawincs." .
Co.ntrary to the above, iron fab shop work was performed to sketches and memos without the availability of the hanger package, traveler, and/or controlled dr; wing at the location where the activity was 05/07/55 16 AQ-77. 79 & 138 II
I
$ i
!- l i
performed. This action is a noncompliance to the above cited proce- I i
! dures. In addition, parts for electrical supports were also fabri- l cated to memos and sketches, and procedure ECP-19 does not define a !
requirement that fabrication work shall be performed per the traveler / l hanger package, f i
t 8. Attacheents: None. ;
I I i i
{ Reference Occuments: :
- 1. CP-QAP-11.1, "Fabrication and Installation Inspection of Components, Compenent Supports and Piping." >
! 2. CP-CCM-9.10. Rev. 11. "e atricatica of ASME Related Ccmpenents
- Supperts."
l 3. CP-CFM-9.9, Rev 8. "NNS-Seismic Category !! Support." -
4, CP-CPM-9.13, Rev.10. "Medification of Vender-Supplied Catalog Items."
- 5. TUGC0 letter TXX-4120, datec May 25, 1984 7
- 6. AQ-138: TRT interview with alleger A-59, September 13, 1984
] 7. FSAR Figure 9.5-52, sheets 1 and 2.
- 8. B&R ECP-19. "Exposed Cenduit/ Junction Box aac Hanger Fabrication and l1
- Installation."
j 9. B&R CCP-21, "Fabricat, ion of Miscellaneous Steel."
2
- 10. B&R CI-CPM-8.1, "Color Coding of Piping Materials."
- 11. B&R CP-CPM-6.9C. "Material Icentification."
- 12. B&R CP-QAP-14.1, "Inspectice of Storage anc wa intenance of Permanent Plant Equipment."
- 13. B&R CP-QAP-8.1, "Receiving Inspection."
- 14. B&R Ql-QAP-11.1-28, "Fabrication and Installation Inspection of Safety Class Component Supports."
- 15. B&R CP-CPM-6.90 "Welding and Related Precesses."
- 16. B&R MCP-10. "Storage and Storage Maintenance of Mechanical and 5lectrical Equipment." -
- 17. BE.R CP-CPM-8.1, "Receipt Storage and Issue of Items."
- 18. TUEC QI-CP-11.10-1, "Inspection of Seismic Electrical Support and Restraint Systems."
C5/07/35 17 AQ-77. 79 & 135 II
- 19. TUEC QI-QP-11.16-1, "Installation Inspections of NN5 Seismic Category !! Supports for Class V Piping."
- 20. TUEC QI-QP-11.14-1, "Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel."
- 21. TUEC QI-QP-16.0-5, "Reporting of Base Metal Detectors." l
- 22. TUEC QI-QP-11.4-4, "Control of Material Traceability for Site !
Fabricated Structural / Miscellaneous Steel." t
- 23. Design Change Authorization 17551. [
- 24. Hanger Packages, CP-82-086-8903, CP-82-008-8903, and ;
CP-84-224-02 8902. ;
i
- 25. AQ-77 and AQ-79: A-3 statement and interview. ;
- 26. TRT eeeting with A-59 November 14, 1984 ,
6
- 27. TRT meet.ing with A-3 Cecember 10. 1934 pp. 115-13S.
- 9. This statement prepared by: _
J. Malonson, TRT Date l Technical Reviewer ,
Reviewed by- i H. Livermore, Date I Group t.eader -
f Approved by:
V. Noonan, Date i Pro. ject. Director i i
I l
i l
l l
05/07/55 IS AQ-77. 79 & 133 II
s' i
l j 1. Allegation Category: QA/QC 5.C Housekeeping
- 2. Allegation Number: AQ-54, AQ-65
- 3. Characterization: It is alleged that: (1) cleaning procedures for and cleanliness of components and areas were not maintained during construc-tion of the plant (AQ-54) and (2) a worker assigned the task of cleaning was instructed to detettine the three areas that QC inspectors were going to check, clean those areas, and forget the rest (AQ-65).
j 4 Assessment of Safety Stanificance: Cleanliness standards at Comanche Peak j are described in the Final. Safety Analysis Report (FSAR), Ta'ble 1.(A)N, j "Discussion of Regulatory Guides." These standards are based on Regulatory j Guices (RGs) 1.37 and 1.39, which in turn cite ANSI standards N45.2.1 and N45.2.3 as acceptable methods of implementing cleanliness controls.
)
4 AQ-65 i
The NRC Technical Review Team (TRT) interviewed Brown & Root (B&R) QC in-
! spectors and inspection supervisors, who explaired that the B&R QC inspec-
] tors performing plant surveillance were scheduled to rotate throughout I various areas of the plant on a weekly basis, thus minimizing the possi-bility that craft personnel would know the identity of the OC inspector assigned to their area in advance. The TRT reviewed cleanliness control procedures and records for the adequacy of the implementation of the AN51 requirements and the performance of the QC inspections required by those procedures. The TRT did not find any evidence to support the allegation of improper guidance by a supervisor. Although the reported conversation between the worker and the supervisor may have occurred (as stated in the transcript of RIV interview with the alleger 84-006) the TRT found in its assessment of allegation AQ 54, below, that housekeeping and cleanliness procecures were ieplemented. .
05/04/S5 1 20-54/AO-65
l 0
A0-54 To determine if cleanliness controls were implemented and maintained during construction activity, the TRT reviewed 15 of the B&R and Texas Utilities Electric Company (TUEC) procedures through which the above AN5! requirements are implemented. The TRT reviewed all plant surveillance reports for January and February 1979, to assess the implementation of cleanliness controls during earlier phases of construction. The TRT noted that, according to the documentation reviewed, 411 of the deficiencies reported had coen corrected. The TRT also examined 125 plant surveillance inspec-tien reports (irs) for 1981 and 1982,16 of which cited unsatisfactory conditions, each of which was corrected. In addition, the TRT reviewed 50 plant surveillance IRS for January through June 1984, amorg which were 3 re; orts that noted unsatisf actory conditiens which were later corrected.
E&R procedure CP-CPM 10.2, "Cleaning and Insulating Stainless Steel Pipe and Equipment," prescribed the methods of cleaning, final rinse, and swipe tests used to verify acceptability of cleanliness. The swipe tests, per-formed in accordance with B&R CP-CPM 6.9H," Cleanliness Control," consisted of wiping it.e cleared area with a specified abscrbent material which was subsequently analy:ed to determine the amount (if any) of specified con-taminants remaining on or in the previously cleaned area. The TRT discus-sed procedure implementation with TUEC QC laboratory inspection personnel and found that the TUEC lab inspectors took swipe samples on a random basis, af ter written not,1fication that a specific compc nent or section of pipe had been cleaned and was ready for inspection. In addition to inspecting easily accessible areas, these lab inspectors also sampled hard-to-reach areas, where cleaning may have been inadequate. Like the BAR inspectors, the TUEC laboratory inspectors were rotated threughout the plant, so that craft personnel did not know in advance which inspector wouir be assigned ',o their area. The swipe saeples were analyzed in the TVEC QC laboratory and the ru ults were transmitted to the field. The OC verification of accep- .
table. swipe tests was one of the inspection criteria which has to be satis-fied just prior to insulation installation. All swipe test lab ratory reports were stored in the permanent plant records vault, 05/06/S5 2 AC-54/AO-65
l The TRT reviewed 100 swipe test reports from 1979, and 100 swipe test reports from 1984. For 1979, 31 test reports indicated that chloride or fluoride contamination exceeded specifications; the 1984 reports contained 2 items that exceeded specifications. In all cases, the items involved were cleaned and retested with acceptable results. The TRT observed flush plans (FP2-11-01 and FP2 31-01) in use. The TRT also reviewed startup and turn-over surveillance reports 0$R-82-017, 0$R-83-058, 0$R-83-052, and 0$R-83-044 ,
for completeness and close-out of defteient items and found that these items were properly closed. The TRT reviewed eight completed flush plans to verify the cleaning of various primary coolant system components and ,
found that the components were properly flushed.
Tre TRT reviewed a draft of flush procedure FP-55 03, dated August 6, 1904, that =as in the initial stages of preparation. The purpose of this proce-cure was to verify cleanliress of the Unit I reactor coolant loops, in- .
cluding the reactor vessel (RV), by means of handwiping, visual inspection, .
and swipe testing. Tnc'se tests used to determine surface chloride and fluoride centamination were performed by TUEC systems test engineers and Westingheuse representatives. The TRT noted, he ever, that FP-55-CB re-quired only two swipe tests of the RV (one on the side and one on the bottom). Although the procedure was still a draft, the TRT expressed its concern in regard to the adequacy of performing only two swipe tests to verify the cleanliness of an item the size of the reteter vessel, i
Tne TRT inspected imple entation of c'.vanliness centrols by .. . ~'r; inspections of the safeguards building and the diesel generator building i fon Unit 2 and the containment building for Unit 1. The inspection was e.ade to verify the implementation of housekeeping and cleanline,ss con-trols. The following conditions were found.
- 1. HOUSEKEEPING
- a. 'ork
. areas .cre clean and orderly.
- b. Temporary excess materials were identified and stored in a ,
neat manner.
05/06/55 3 AQ-54/AQ-65
l o
s.
- c. Areas of activity were adequately lighted, ventilated, protected, and accessible as appropriate for the work being performed and consistent with the quality requirements.
- 2. CONTAMINATION OF STAINLESS STEEL
- a. Slings hand 113y stainless steel were made from nylon or stainless steel or had adequate protection, such as being covered with rubber or wood, to prevent contact with carbon steel slings,
- b. Toc 1s (for example, wire brushes, files, flapper wheels, and drills) used on stainless steel materials were designated by a fluorescent orange color code.
- 3. KATERIAL/ EQUIPMENT ST00t3E: .
- a. Material and equipment were checked for evidence of damage or deterioration.
- b. Pipe spools, both carbon and stainless steel, were protected by the use of plastic or retal caps and/or wood covers and plugs appropriate to the e.aterial type (carbon or stainless). The pipes were stored off the ground in racks or on dunnage.
1
- c. Weld rods were field-stored in pluggec-in ovens.
l l
l d. Motors were stored with ventilation holes covered with fine screening to ensure that motor internals were free from debris l
I and rodent infestation. .
l
- e. Space heaters on motors and motor-operated valves were functioning. ,
05/04/85 4 A0-54/AO-65
l .
L i-4 INSTALLED ITEMS:
) ,
i 1
) Cables and Cable Trays, 4
- a. Cables were covered with fire-resistant materials any time 3
welding, grirding, or torch cutting was being performed in an ,
j area that could damage cab've. !
1
- b. Items such as nut.s. bolts, structural steel, pipe fittings,
) etc., had not been stored or left in cable trays.
f c. Metal gratings were installed over cable trays to prevent trash l f*em falling or aceutulating in the trays. f ig
{-
i
- d. Flea conduit to equipment was not brokin, damaged, or used to , j i support any weight.
I j e. Trays containing cables were not used as walkways.
- f. Trays were not used as work platforms, escept when standard work j l
platforms were not feasible. The following precedures applied: j r
l
) (1) A 1/2-inch (or thicker) piece of plywood entending across f the top of the cable tray from siderail to siderail, which f was stabilized 50 it could not be accidently dislodged, was f
) used an a temporary work platform.' f
' i I
b
] (2) Alternatively, a three-fold fire blanket covered with an [
l approved electrical rubber blanket was used when workers l 1eaned over or into a cable tray, but not for supporting f t
their l'ull body weight when standing, kneeling, etc. l 1
f l
, t
! "This was not used when accitional sidera11s were added to entend the depth l I of the cable tray. l i I i l i
}, (JS/06/85 5 AQ-54/AQ-65
. j
~
. I
i e
,, }
i I
- g. Cable trays were not used as structural supports, or used l l to suspend lifting devices. f;
< i
! h. Hoses and cables were not laid across the trays.
i
- 1. Doors and covers to electrical equipment vara in place when !
I no work was being performed on the item. i Mechanical: ;
?
I
- a. In the safeguards building, Unit 2 (rooms 67, 72, and 74),
j the TRT sbserved that not all snubbers w3re wrapped with I protective covering when welding was being done in' close proximity to them, this was a violation of B&R procedure f CP CPM-14.1, which required protection of nstalled equip- l ment during welding. This condition was immediately cor- !
I rected when the TRT reported it tc TUEC quality assurance
{' t t
j management, and an inspection was trformed by TUEC to j l correct similar conditions in other areas as well.
i
- b. Open ends of coeponents were covered unless work was being ;
performed on them.
i !
- c. Installed pice, especially pipe connected to valvas and (
7 .
- equipment, was properly supported by permar.ent or !
temporary supports. !
l 1 !
j d. No rigging was off supports (unless authcrired by j engineering in writing on a traveler, etc.). , l I
l i
- Instrumentation
- f i .. . l Aretective coverings were installed and maintainee whenever work f j was done around indicators, gauges, tubing, etc. l
! I l
1 i i l 05/04/85 6 AQ-54/AC-65 l l
- i
l o
- 5. Conclusion and Staff Positions:
AQ-54 j Based on its review of records of QC surveillances for January and February 1979, and inspection reports for 1981 and 1982 the TRT finds ,some merit in the allegation relating to inadequate cleanliness controls during the early stages of construction. The TRT concludes that the cleanliness con-trols implemented since 1981 indicate that management recognized the clean-liness prcblem and frplemented procedures to correct it,
&_6_1 Tnt TRT was vrable to substantiate tne allegatten that, a worker was terro-perly instrweted by his supervisor in regard to cleanliness inspectiens. .
On Octeber 29, 1984 the 411cger's parent informed the TRT that the alleger declined any further contact with the NRC; consecuently, the results of this assessment were not presented to the alleger.
- 6. Actiens Recuired:
i 1 7. potential violattens: 10 CFR 50. Accendt 8, Criterien V, states in part snat activities af fecting quality shall be acccaelished in actordance with cocueentec procedures."
B&R procedure CP-CFM-14.1, Section 2.8.1.1 states that protective cover-ings should be installed to protect items where welding or torch cutti'i l col 1d cause damage. ,
i 1
i ,
Cintrary to the above, during September of 1984, the TRT observed welding l in pegcess adjacent to snubbers that were not protected as required. The ,
activi,ty occurred in the Unit 2 safeguards butiding, rooms 67, 72, and 74.
}
C5/06/25 7 AQ-54/AQ 65 1
\;
- 8. Attachments: None.
Reference Docu+ents:
- 1. Flush plans FP-55-01, GP Ta-02, FP-55-03, FP-55-04, FP-55-05A, FP 55-058, FP-55-05C, FP-55 06, FP 55-08, FP-2-11-01, and FPal-31-01,
- 2. Startup/turnovsr surveillane.e reports 0;R-83-058, 0$R 82-017, 05R 83-052, ai.e 05R-83-044,
- 3. Plant surve111ence insoection report PS! 0001-PSI 0020.
. 4 cia t suave.11s :e ree:*ts. 0500:01-0500030.D5003Cd-P500375, are 75 Cn350-P5 00iDC.
- 5. Swipe test laboratory re> orts J-1 through J-99, dates March 26, 1979 threwgh Nove-ter 15, 1979.
- 6. Snipe test laboratory reports J-600 through J-699, dated Fourvary 28, 1954 through April 27, 19!4
- 7. Ett CP-CPM-6.9, "General Piping Precedure."
- 8. B&R C1-CPS-6.9E-2, ""+4 tainie; System Cle. diness Cwring 'neld Repairs."
- 9. E&R CP-CPM 6.9K (Append 1 H), "Cleanliness Cor. trol."
- 10. E&R CP-CPM-9.2, "Centrol of C.51mical Substances." .
- 11. B&R CI*CP/4-6.12 "Installation, Rework and Modification of Reflective insulatien." .
- 12. B&R CP-CPM-10.2, "Cleaning e,1 Ir.sulating Stainless Steel Pipe and Equipment."
05/C6/s5 K A0-54/AO-65
- 13. B&R CP-QP-39.5, "Surveillance of Plant Conditions."
- 14. TUGC0 MEI-8, "NSSS Cleanliness During Coolant Loop Installation."
- 15. TUGC0 CP-SAP-24, "System Cleanliness Requirements and Control."
- 16. TUGC0 XCP-ME-4, "System Cleanliness Verification."
- 17. B&R MCP-10. "Storage and Storage Maintenance of Mechanical and Eiectrical Equipment." .
- 18. TUGC0 01-0P-11.1-65, "Determination of Contamination of, Flourides and Chlorices on Stainless Stee!."
- 19. TUGC0 Ql-QAP-11.1-40, "Insulation Insta110:f on in,pectier.." .
- 20. TUGC0 QI-QAP-11.1-65, "Determination of bufface Contamination of Chlorides and Flourides on Stainless Steel.
- 21. B&R CP-CPM-14.1, "Guidelines for the Protecticn of Permanent plant Equipment."
- 22. A0-54: A-7 testimony, March 7,1984, pages 19, 24, 25, 29, and 39.
P
- 23. A0-65: A-7 testimony, March 7, 1934, page 13.
- 24. GAP 2.206 Petition March 19, 1984,
- 25. NRC letter to TUEC, dated November 29,1984 (Com.;nche Peak' Review).
- 9. This statement prepared by:
J. Malonson, TRT Date
-- Technical Reviewer -
, H. Livermore, Date Geo;p 1.eader Approved by:
V. Noonan., Date j Project Director
- 05/06/85 9 A0-54/AC-65
E ;.
- 1 l
- 1. Allegation Category: QA/QC 5.0, Nonconformance Reports
- 2. Allegation Number: AQ-30, -31, -32, -34, -35, -36, -37, -80, -85, -86, -87,
-95, -96, -97, -106, -109, -114 -116, -120 and -124
- 3. Characterization: It is alleged that nonconformance reports (NCRs) were initiated, processed, controlled, and dispositioned improperly. (Similar allegations, related to specific NCRs for electrical work and protective coatings, were reported in Electrical and Instrumentation Category 6 and Protective Coatings Category Sb.)
- 4. Assessment of Safety Significance: In assessing these allegations, the NRC Technical Review Team (TRT) reviewed applicable procedures, NCRs, component modification cards (CMCs), design change authorizations (DCAs), inspection reports (irs), and N-5 data reports. In addition, interviews were held with both Texas Utilities Electric Co. (TVEC) aod Brown & Root (B&R) per-sonnel in engineering, QA, QC, accounting, scheduling, and document control.
The results of the TRT findings for specific allegations are, discussed below.
A0-30 and A0-31 alleged that interoffice memos (IMs) were used to voic NCRs his make other unauthorized changes; no specific examples were identified.
Texas Utilities Generating Company (TUGCO) procedure CP-QP-16.0, "Non-conformances," and B&R procedure CP-QAP-16.1, "Control of Nonconforming Items," allowed NCR to be voided under specified conditions. In assessing these allegations, the TRT interviewed TUEC and 9&R QC, engineering, QA, and document control personnel. The TRT also reviewed 154 NCRs, of which 64 had been voided. Three NCRs (82-0005, 82-0CC6, and M-12354) had been dispositioned by IMs, and one (M-83-02847) had been voided by an IM.
(NCRs can also be voided by writing "VOIO" in tne disposition block and adding the appropriate justification.) j All NCRs that had been dispositioned or voided by IM had the IM attached to the NCR as supplementary information for the disposition or voiding of the NCR. This practice was consistent with procedure CP-QP-16.0, which required that "any pertinent supporting documentation shall be attached to the NCR and referenced in the reason and justification statements."
Voided NCRs required, and had the approval of, the quality engineering (QE) supervisor. Therefore, these allegations were not substantiated.
AQ-32 alleged that corrective actions were not being implemented: speci-fically, that 35 NCRs identified in corrective action request (CAR) S-41 had not been cleared as of September 10, 1930. .
The TRT reviewed CARS S-41 through S-57. CAR S-41, related to hanger NCRs, referenced 36 NCRs. All 36 NCRS had been closed, with closing dates rang-
- ing from May 14, 1980, to February 19, 1981
- 19 of the 36 referenced NCR$
had been closed by September 10, 1980. .
l Other CARS reviewed by the TRT indicated that the required corrective
- actions had been completed. For example, CAR S-48, relating to are 1
1 I
l strikes, resulted in 419 welders being given reindoctrination for the prevention of are strikes, plus additional equipment prot 4ction measures.
Welder attendance was verified by signed attendance sheets. Allegation AQ-32 was not substantiated. (See allegation AQ-116, below, which discusses implementation of the corrective action system.)
AQ-34 alleged that NCRs were disapproved and destroyed, but no specific examples were identified.
The disapproval (voiding) of NCRs by use of IMs is addressed in the assess-ment of allegations AQ-30 and AQ-31, above. The destruction of NCRs was previously reviewed by the NRC in September and November of 1980. The re-suits of that review, published in Region IV Inspection Report 50-445/80-22, indicated that up to tha* time some NCRs were voided and those NCR numbers were then reassigned, which was considered to be a poor practice. The re-port also indicated that new procedures, issued in August 1980, required voided NCRs to be forwarded to the records vault and prohibited the reissuance of their NCR numbers. ,
The TRT initially reviewed 131 NCRs (dated between 1980 and 1984), of which the' NCR log indicated that 41 had been voided.. The voided NCRs were available in the rec::rds vault, except for six originated by TUEC, which were not available. Additional interviews with the TUEC open records vault coordiha-ter indicated that, at times, an NCR number was assigned, then subsequently was not used because the individual obtaining the number decided that an NCR was not required. The open records vault coordinator stated that the six missing NCRs had never been written. This approach is consistent with procedure CP-QP-16.0, which stated: "NCRs may be voided at any time if it is determined that nonconforming conditions do not exist, the nonconformance was previously reported on another NCR, or other similar conditions exist."
Additional research by the permanent plant records vault personnel disclosed that, of the six missing NCRs, one duplicated the subject of a preceding NCR, and two others duplicated the subjects of precedir.g inspection reports.
The three other NCRs (E-81-00024, E-80-00143, and E-80-00228) could not be located. The three missing NCRs occurred in approximately the last cuarter of 1980, shortly after issuance of the revised NCR procedure.
The TRT reviewed 23 additional NCRs which were voided in the last quarter of 1983; all were available in the vault.
A TRT review of NCR procedures verified that 84R procedure CP-QAP-16.1 re-quired voided NCRs to be transmitted to the records vault. TUGC0 procedure CP-QP-16.0 stated that, "The original voided NCR will be forwarded to the (PFG) NCR Coordinator," but gave the NCR coordinator no additional instruc-tions for handling voided NCRs. The TRT found that the NCR log books listed all NCRs, including those that were later voided, and that the numbers of voided NCRs were not reissued. These changes to the procedures, in addition to the NCR coordinator's understanding of the NCR process,
- appear to have adequately corrected the handling of voided NCRs. although TUGCO. procedure CP-QP-16.0, Rev. 14, should have contained explicit instructions to the NCR coordinator for handling voided NCRs.
The TRT concluded that allegation AQ-34 was substantiated in that there were instances of poor practice in handling voided NCRs prior to the end of 1980; however, the practice has been corrected.
2
AQ-35, AQ-37 and AQ-80 alleged that a B&R QC manager issued oral and written instructions stating that IRr were to be used to document deficien-cies in lieu of NCRs, and that deficiencies were reported on irs rather than on NCRs. No specific examples were identified. The reasons given were that: (1) irs could be "dispositioned by anyone," and (2) items re-ported on !!1s might not be reinspected. Also it was alleged that inspec-tors were under "pressure" not to write NCRs.
As identified in B&R procedure CP-QAP-16.1, "Control of Nonconforming items," the intended use of an IR was to document conditions that did not conform to drawing requirements and that could be repaired using existing procedures. If a drawing change would resolve the condition, a DCA or CMC was issued. If engineering disposition was required or the deficient item required a hold tag or if the "UNSAT" IR was not resolved within 2 weeks, an NCR was issued. According to the B&R representatives interviewed, irs were never intended to replace NCRs, but were initiatory documents completed by inspectors that led to an NCR, if required; however, non-inspection personnel would continue to document deficiencies on NCRs. ,
Tne TRT reviewed 63 irs for various items that initially had been deter-mined to be unsatisfactory. The irs did not appear to have been written against items that should have been written as NCRs. (However, during re-view of 22 TUEC irs associated with the post-construction verification -
program, QA/QC Category 8, Allegation AQ-135, the TRT did find that apoarently identical conditions were described on NCRs in some cases and on irs in others.) In those cases where the IR required engineering disposition, the appropriate documents were prepared. For example, the following irs resulted in the preparation of the listed CMCs or DCAs:
IR I-1-0043092 resulted in CMC-66621 IR ME-1-0043113 resulted in CMC-99152 IR I-1-0043118 resulted in CMC-66646 IR ME-1-0043054 resulted in OCA-16947 IR ME-1-0043055 resulted in OCA-16947 The 63 closed irs had been reinspected af ter repair and we-e sicaed of f by qualified QC inspectors as satisfactory. The signature of a .. V ita: QC inspector was required to close an unsatisf actory IR, as defineo in pro-cedure Cp-QAP-16.1, not the signature of "anyone" as alleged. The TRT noted no misuse of this requirement. The procedure also requires that a quarterly report of unsatisfactory irs be sent to the QE supervisor for assessment and trend analysis in accordance with the corrective action system. The TRT found that these quarterly reports were preparad as required.
The TRT located a B&R memo that was apparently intended to apply specifi-c:lly to QC inspectors, which stated, in effect, that only items that could .r.ot be resolved with an IR, DCA, or CMC were to be written as NCRs. .
These remos were consistent with the above procedures; however, some inspectors may have interpreted this memo as instructions to write irs, rather than NCRs.
TRT interviews with QC inspectors and management personnel revealed no evidence of pressure not to report nonconforming conditions, only the need 3
to report deficiencies on the appropriate form in accordance with pro-cedures. The TRT reviewed the QA/QC oitentation film, "Introduction to Quality Assurance and Quality Control" used in the training of all CPSES QC inspectors. The film made many references to the organizational inde-pendence of QA/QC from construction. Additionally, the training emphasized the establishment of good working relationships with craft personnel to avoid personality conflicts.
Allegations AQ-35, AQ-37, and AQ-80, related to misuse of the B&R IR system, were not substantiated.
AQ-36 alleged that DCAs were being used to "cover-up a condition for which an NCR should be written," since the DCA does not receive QA/QC review, as dees the NCR. No specific examples were identified.
TUGC0 procedure CP-EP-4.6, "Field Design Change' Control," Revision 10, stated that changes must be approved by the "original designer's designated site representative." In April 1983, the Gibbs and Hill (G&H) site represen-tative approval function was supplemented by a G&H site design review team, as cescribed in CP-EP-4.6 and CP-EP-4.7, "Control of Engineering / Design Review of Field Design Changes." TRT interviews with the TUEC engineering manager indicated that DCAs and CMCs were used by TUEC to change design documents (drawings, etc.). Orawings were originally prepared by Gibbs &-
Hill (G&H), the architect-engineer for Comanche Peak Stream Electric Sta-tion (CPSES). The original drawings were signed by a professional engineer and were not signed by QA/QC personnel. The TRT determined that the appli-cable procedure did not require approval of drawings or DCAs by QA/QC personnel.
Procedure CP-QP-16.0, Rev. 14, defined a nonconformance as "a deficiency in characteristic, documentation, or procedures, which renders the quality of an item unacceptable or indeterminate." Because this definition is so all-encompassing, it may have been difficult to determine when a noncon-formance which required an NCR existed, or when a CMC or DCA was adequate.
[A similar concern related to irs and NCRs is described in QA/QC Category 8, AllegationA0-135.] Certainly, all CMCs or DCAs were not prepared as a result of an NCR. Also "tracking NCRs" were f requently written, in which the NCR was n_o_t used to describe a nonconforming condition, as defined above, but was used to record removal of a part from equipment on a perma-nent equipment transfer (PET). The purpose of the NCR, in this case, was to ensure eventual replacement of the removed parts. This usage does not appear to be consistent with the definition of nonconformance.
Procedure CP-QP-16.0, Revision 14, was not entirely clear en no'nconformance reporting. Specifically, paragraph 2.1 stated, "It is the responsibility of all site employees to report items of nonconformtnce to their supervisors or to the TUGC0 Site QA Supervisor," and paragraph 3.1.2 required using the NCR form for that reporting. However, paragraph 3.2.1 states that -
non-Q&/QC personnel should transmit the NCR to the Paper Flow Group (PFG)
NCR Coordinator, who in turn would transmit the NCR to the "appropriate" QE, who was neither the individual's supervisor nor the Site QA Supervisor, as required by paragraph 2.1.
4
Additionally, the NCR form nad no form number or revision date, indicating that the form may not have been adequately controlled. The TRT identified two versions of the TUEC NCR form, one having a space for ANI review. This version apparently was not used. The TRT also noted that the form currently in use has no space to identify the cause of the nonconformance and the steps taken to prevent its recurrence, and that there is no provision for quality assurance review, as described in allegation AQ-116.
OCAs and CMCs may be prepared as a result of NCRs and inspection reports, as described in the assessment of AQ-35, AQ-37, and AQ-80, above, and the possibility for overlap exists. Following the previously noted procedural guidelines, the 90 CMCs and 82 OCAs reviewed by the TRT did not appear to
- have been written for items that should have been the subject of NCRs.
While the TRT noticed some weakness in the procedures, allegation AQ-36 was not substantiated.
AQ-85 alleged that the use of test deficiency reports (TORS), irs, and maintenance action requests (MARS) was being abused in that ,these forms wtre used for conditions that warranted NCRs. Specific examples were not i de,n t i f i ed .
TUGC0 procedure CP-SAP-16 "Test Deficiency and Nonconformance Reporting,"
defines the use of TORS and NCRs. Specifically, TORS were used to describe deficiencies in operating characteristics, test documentation, startup procedure compliance, or any other deficiency identified by startup person-nel. NCRs were used to describe deficiencias in physical characteristics, vendor documentation, or construction documentation.
The TRT reviewed 42 TORS which were originated from July 1983 to May 1984 All TORS described items in the categories apprcpriate for TORS.
The TRT reviewed a listf eg cf MARS issued in March 1980, and March 1981, since there was a relatively larger quantity of MARS compared to TORS. The ,
MARS described normal maintenance werk and did not cover material that should have required an NCR.
The use of IR$ versus NCRs has been described in allegations AQ '5, AQ-37 and AQ-30, above. Procedure CP-SAP-16 also required that the Startup Quality Specialist and lead Startup Engineer identify trends adverse te quality and initiate corrective action.
The TRT found no examples of abuse of the MAR, TOR, or IR system; there-fore, allegation AQ-85 was not substantiated. .
AQ-86 alleged that QC supervisors made it difficult for QC personnel to do followup inspections of NCRs. Specific examples were not identified.
B&R pnocedure CP-QAP-16.1, required that: "The applicable QC Superintendent / -
QCE shall ensure that the work activities required by the NCR disposition are verified and/or witnessed by qualified inspection personnel. The in-spector shall document the completion of the NCR disposition by:
l
- a. Assuring documentation is available to verify that the disposition has been satisfactorily implemented. This 5
o documentation shall be attached to or referenced on the NCR; and
- b. Signing the verification block on the NCR. The stgnature provides objective evidence that the hold tag has been removed.
QE will coordinate obtaining ANI concurrence. Should any dis-crepancies arise, they will be referred to the QCG [ Quality Control Group] and/or QEG (Quality Engineering Group) super-visors for resolution. Following ANI concurrence, the QE will review the NCR and applicable supporting documentation for legibility, clarity, and specificity and then sign for ' Closure' of the NCR.
TUGC0 procedure CP-QP-16.0 contained similar language.
The TRT noted that there was no requirement stating that ths original inspector was required to follow up the NCR disposition implementation.
Such followup would have advantages, as would the forwarding of a com-pitted NCR to the originators, but this was not a requirement.
In assessing this allegation, the TRT reviewed 154 NCRs. Required rein-spection had been completed and signed off by a QC inspector on inspection documents attached to, or referenced in, the NCRs. The TRT also compared inspector signatures on a representative sampling of these NCRs with signa-tures maintained in a card file, and could not identify any discrepancies.
Quality engineering had also signed the NCRs separately for closure.
The TRT found no examples of QC difficulty in performing followup inspec-tions for closing NCRs; therefore, allegation AQ-86 was not substantiated.
AQ-87 and AQ-124 alleged that craf t personnel rather than QC personnel have been signing off NCRs that QC refused to sign, and that some NCRs were dispositioned "inaccurately."
The TRT reviewed 154 NCRs, as noted in AQ-34 above, and found no evidence of incorrect or falsified signatures. Falsification of signatures is very difficult to substantiate unless specific individuals voluntarily dis-close that specific signatures are not theirs, or the signature handwrit-ing is widely different from their usual handwriting. The TRT identified no cases of this kind for NCRs. ,
The TRT determined that the QA staff, or the QE who s.1gned an NCR for closure, reviewed previous signatures. The hignatures of the QE, engineer, and addressee on the NCR typically are very familiar to the QA staff or QE. One QE stated that there had been instances in which he had refused to sign an NCR because of an unfamiliar signeture; however, in each in- .
stanct the question was resolved, and he then signed the NCR for closure.
I Part of this allegation referred to NCRs for flanges on 12-inch piping shown in isometric drawing VA-2-AB. There are two isometric drawings in i that series: BRP-VA-2-AB-001, and BRP-VA-AB-002. Both of these drawings show only 3/4-inch piping without flanges.
6
Another part of this allegation referred to NCR M-13932, in that the NCR was incorrectly dispositioned by voiding. This NCR specified that the only requirement violated was B&R procedure CP-QAP-11.1, Revision 4, para-graph 2.3.2. The TRT noted tnat the only paragraph 2.3.2 contained in that precedure was in Attachment 1, which did not relate at all to the subject of NCR M-13932. After a review of the NCR, the TRT determined that the NCR was properly voided by the QC supervisor.
The TRT review did identify specific cases of improper dispositioning of NCRs. One such case is described in Electrical Category 1, Allegation AQE-36. Another, in which the description of the nonconforming condition was changed by two successive revisions that changed the meaning of the NCR, is described in QA/QC Category 6, Allegation AQ-55. A third case is discribed in Mechanical and Piping Category 33 Allegation AH-3, and a fourth is described in Protection Coatings 5b, Allegation AQO-7.
Inproper dispositioning of NCRs by B&R was also investigated by the Authorized Inspection Agency, Hartford Steam and Boiler, in Citizens Associated for Sound Energy (CASE) Exhibit No.1050, dated Dctober 21, 1983, with responses thereto by B&R, which was considered in this assess-ment by the TRT. ,
Allegation AQ-87 was not substantiated. The TRT concludes that there wer6 instances of improper NCR dispositioning, and therefore allegation AQ-124 was substantiated.
A0-95 alleged that NCRs were misused in that an NCR was written to apply to mere than one traveler. Specific examples were not identified.
The TRT found that there were a number of NCRs that were used as "generic" NCRs, i.e., each NCR applied to a common type of problem identified in a nutber of locations. For example, NCR M-83-01162, "Stairway Framing,"
listed 17 affected travelers. Each traveler applied to a specific stair-way and each individual traveler had QC sign-of f for repair of that stair-way. All travelers were attached to the NCR for closure. Procedure CP-0D-16.0 had no requirement that prohibited the use of multiple travelers in NCRs. The TRT found no examples of generic NCR misuse, and consequently, allegation AQ-95 was not suostantiated.
AQ-96 alleged that the use of open-ended field job orders (FJos) made work appear to have been pre-approved. Specific exsmples were not identified.
The TRT reviewed the FJO files. The FJO was an accounting mechanism only; it was not a construction document and craft personnel could not do work to an FJ0. Approximately 330 FJ0s were written for repair work to vendor equipment. Of these, two were open: No. 49, for Allis Chalmers, and No. 261, for ITT Grinnell. The two were open because of continuing re-pair work required for equipment supplied by those companies. FJ0s were ,
used {s financial documents to backcharge the vandors for repair to vendor equipment rather than returning the equipment to the vendor.
Allegation AQ-96 was not substantiated.
7
9 F
AQ-97 and AQ-116 alleged that permanent documentation was pulled out of the
,ecords vault and NCRs were written because the documentation did not match the "log book" (AQ-97), and that B&R procedural changes have resulted in the violation of procedures for document review of ASME documentation and manipulation of safety-related documentation (AQ-116). Specific examples were not identified.
The TRT reviewed 32 B&R NCRs that had been written against items after acceptance of the isometric N-5 data report. The 32 NCRs noted the lack of ANI sign-off on flange travelers related to the N-5 data reports. The 32 NCRs were dated between January and April of 1984. Eighteen of the NCRs resulted in "cosmetic repair" that did not require any change in the N-5 data report; 14 of the NCRs resulted in repair that caused an amendment of the N-5 data report, with QA sign-off and ANI concurrence. B&R estab-lished an N-5 data report documentation checklist, which required checking for the latest flange traveler.
Review of the B&R NCR log indicated that 50 NCRs, related to incorrect docu-mentation, were issued during August 1954 The TRT attributed part of this increase to an increase in the amount of cocumentation being transmitted to the records vault. The issuance of that many NCRs would seem to war-rant the preparation of a CAR; however no CAR was written. -
The TRT noted other instances in which specific nonconformances were cor-rected, but programmatic corrective action was not taken. The TRT noted from the CAR 1.,9 tnet no CARS were issued between June 11, 1980, and January 14, 1982, but that four separate CARS (22, 27, 32, and 43) were issued relating to hold point violations. This lack of issuance of any CARS for 19 months, plus repetitive issuance of four CARS for the same subject, indicated to the TRT that this portion of the QA program (as dis-tinguished from QE and QC) was not effective. Indeed, the NCR form did not identify any review of NCRs by an element of the QA organization. The QA review identified in TUGO procedure CP-QP-16.0, paragraph 3.2.6, was in reality a QE review, and the only reference to QA review in B&R proce-dure Cp-QAP-16.1 was to a managerial review.
Allegation AQ-97 was substantiated; however, the alleged occurrences were conducted according to procedure. The TRT notec a weakness in the CAR system.
The TRT found that hanger packages may continue to be modified (by NCR) to add revised drawings that require adjustment rather than structural modification, e.g., snubber loading or adjustment of spring cams. The TRT did not consider this to be an abuse of procedures. (The lack of or untimely documentation review by the ANI is addressed in QA/QC Category 2, AQ-134.)
The TRT reviewed B&R procedure CP-QAP-12.1, "ASME Sect :n ::1 lr.sta11ation i
Verification and N-5 Certification," which was revise: and reissued as Revision 11 on June 11, 1984 The TRT noted that at least 14 other quality assurance procedures were revised and reissued on June 11, 1984, apparently as part of an overall procedure updating.
5
t i
0 A TRT interview with the N-5 lead QA/QC engineer indicated that the intent in issuing Revision 11 of Cp-QAp-12.1 was (a) to incorporate detailed instructions for preparing N-5 data reports, which had been contained previously in a separate, informal document; and (b) to require documenta-tion for recently completed activities to be sent directly to the N-5 group, who assembled the complete N-5 report package and transmitted it to the ANI for review and approval. The previous revision of the procadure required that the documents be sent from the field to the records vault, which required the AN!s to wait until the documents were processed and indexed by vault personnel before obtaining a copy to add to the N-5 report package, and then proceeding with their review. This change may appear to be a violation of earlier procedures; however, the revised pro-cedure made no change in the review required for the report package nor i in the use of the N-5 documentation checklist. The change involved the j sequence for transmitting documents to the vault. The N-5 QA/QC lead engineer indicated it was a more satisfactory process. Allegation AQ-116 i
was not substantiated.
A0-106 alleged that NCRs were written against startup work 4.uthorizations UWAs),whichareauthorizationsforworkrelatedtostartupactivities (rather than construction), to correct encontro11ed design change documents that were released for use with the SWAs. The implication was that un-authorized design changes were being made by SWAs. Specific examples were not identified.
1 The TRT conducted a computer search of the entire SWA file to locate the SWAs that had resulted in NCRs. Three were found (NCRs 83-0083, 84-0111, and 84-0066). These three NCRs were not related to the use of uncontrolled design change documents. The TRT found no evicence that NCRs were written 4
against SWAs to correct uncontrolled design charges; therefore, allegation AQ-106 was not substantiated.
AQ-109 alleged that the dismissal of a QC inspector had a negative (chill-ing) effect on the preparation of NCRs.
This allegation was previously investigated by NC cersonnel in Region IV.
That investigation concludes (Reference 25):
! In summary, a total of 76 past and present QC inspectors were inter-viewed. None of the 76 inspectors indicated they had ever failed to i report a deficiency or document a nonconforming condition. Only one assented that there were attempts to intimidate him. No one indi-cated that knowledge of (the discussed QC inspector's) termination
! had caused them to improperly perform inspections, but three inspec-tors did state that as a result of (the inspector's) termination, they j
were more careful in their inspections and in' writing NCRs.
The T&T. interviewed t-o of the three indhiduals onsite that knew the ,
i dismissed inspector, as well as other QC inspecters. None of those inter-l viewed indicated any reluctance to write NCRs because of fear of dismissal.
- Therefore, the TRT concurs with the report conclusion, and this allegation was not substantiated.
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AQ-114 alleged generally that, instead of writing NCRs, B&R inspecters kept personal logs of "problems" they discovered, then obtained their disposition and that "kneping such logs is in accordance with Construc-tion Procedures in the section on precedures for nonconformance reports."
Specific examples were not identified.
The TRT reviewed both TUGC0 and B&R NCR procedures are found no reference to inspeciars keeping personal logs of problems. Lead B&R QC inspectors did maintain a log of unsatisfactory irs, according to B&R procedure CP-QAp-16.1, "Control o' Nonconforming Items," which provides that each OC group be preassigned a block of IR numbers, which they used as unsatis-factory irs were written.
Interviews conducted by the TRT with two QC inspectors and three QC super-visors disclosed that, during the first few years of the CPSES project. QC inspectors kept logs of all the jobs they inspected. Such logs supposedly are no longer maintained; some inspectors do maintain an informal log of jobs worked in case supervision questions the amount of work they have cetoleted.
The' TRT discovered a personal QC log book with the following entries:
Date Entry -
12-13-81 "Night shift personnel (paint) have been verbally directed by to violate paint QI and inspect via 3 part memo - (who's on first?) -
pregram violation."
03-02-82 "Ouplicate hanger numte s on supports to phantem steel - how to inspect, how to as-built, how to code certify."
05-20-82 "Talk to on scread room:
- 1. Bolt _ torquing
~
- 2. Coping by 05-24
- 3. As-Builttrain[ing]
4 100*, reinspection" 07-03-32 "Overtime for As-Built denied by and for budget considerations. 35 problem backlog."
Inspectors tnay keep informal logs if they desire; however such logs should not be used in place of the formal nonconformance or deficiency reporting system. It appeared that some of the above itens should have been the sub-ject of irs or NCRs. but the TRT could not locate irs or NCR$ related to the e erles. The TRT was unable to locate additicral legs of this natv4
- however, if the use of such logs was common, it cculc imply a breakccan in this area of the QA/QC program. Based on the log book found, the TRT considers the allegation was substantiated.
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AQ-120 alleged that "during the time Reactor Building Unit I was starting to be turned over, there were a number of NCRs written, the disposition of which was questionable." Specific examples were not identified.
The TRT interviewed engineering and scheduling personnel to identify the turnover process. Turnover is accomolished as a specific subsystem or area is completed, not by turnover of the Reactor Building as a complete unit. The first system at the site to be turned over by B&R was system 85-01, Turbine Building Unit I and 2 Cathodic protection, on September 19, 1978.
The TRT reviewed the B&R NCR log for the period around September 1978.
. There was no apparent reduction in the time required to disposition NCRs immediately before September 1978. Some NCRs issued in the first half of September required over a year to disposition, which also does not indicate a rush to complete disposition of NCRs. The NCRs issued during the period of August to October 1978 related to a wide variety of systems (not just system 85-01). TRT review of a number of these NCRs indica)ed they were dispositioned satisfactorily.
InsDection of the B5R Open NCR Status Report of July 18, 1984, indicated that, of typical open NCRs listed, approximately 83 percent were to be closed by hardware work of some kind, and approximately 17 percent were -
to be closed by revision of paperwork.
Of 423 areas and 331 subsystems listed for the Unit 1 Reactor Building, 317 areas and 323 subsystems had been accepted by TV C as of July 20, 1984.
Turnover of the Unit 1 Reactor Building is still in process; consequently, the implication of a ish to complete its turnover is not supported by the actual schecule.
- tion AQ-120 was, therefore, not substantiated.
- 5. Conclusion and Staff Pesitions: Allegations AQ-30, AQ-31, AQ-32, AQ-36, AQ-85, AQ-36, AQ-87, AQ-95, AQ-96, AQ-106, AQ-109, AQ-116, and AQ-120 were not substantiated and have no generic implication. Although allegations AQ-35, AQ-37, and AQ-80 were not substantiated, the TRT review did identify some concerns. The generic significance of these concerns is discussed in QA/QC Category 8, allegation AQ-135. Allegation AQ-34 was substantiated; ho.,ever, tne occurrences have been corrected, and the allegation has no generic implication. Allegation AQ-97 was substantiated; however, the occurrences were conducted according to procedure, and have no generic implications, Allegation AQ-114 was partially substantiated, and allega-tion AQ-124 was substantiated, and both allegations may have generic implications of a partial QA/QC breakdown. .
The initial NCR process was deficient in some areas; however, a number of audits have resulted in revisions to correct those deficiencies. Current procedures are generally adequate, with some weaknesses noted as indicated in AQ.34, AQ-30, AQ-97, AQ-114, and AQ-104. .
In a r$eeting with the allegers en December 10, 1984, the TRT presented the results of its assessment of allegations AQ-31 and AQ-80, including the TRT conclusions. A brief discussion followed. There were no major disagreements or concerns, and no new allegations were identified.
Additionally, the results of allegations AQ-95, AQ-114, AQ-116, and AQ-120 11
were transmitted by letter to the allegers. Other allegations in this category were obtained from sources other than allegers, and a closecut meeting was not required.
- 6. Actions Recuired: i
- 7. Potential Violations
- a. 10 CFR 50, Appendix B, Criterion XV, states: "Measures shall be estab- i 11shed to control materials, parts, or components which do r.ot conform to requirements in order to prevent their inadvertent u:& or instal-lation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and noti- ,
fication to affected organizations. Nonconforming items shall be re-viewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."
Contrary to the above, measures established for the identification .
and cocumentation of nonconforming conditions were circumvented by i the use of a personal log, and by revising the description of the I nonconforming concitions in NCRs (e.g. , NCR M33-00795) to limit the investigation required. Further: ,
(1) Measures were established for control of ASME NCRs in procedure CP-CAP-16.1 that require voided NCRs to be transmitted to the records vault.
Contrary to the above, the measures established for control of non-ASME NCRs in procedure CP-QP-16.0 Rev. 14, did not contain specific instructions for transmitting voided NCRs to the records vault. -
(2) Procedure CP-QP-16.0, Rev. 14, established for the verification and documentation of nonconforming conditions, defines a non-conformance as:
"A deficiency in cnaracteristic, c:cu enta. . ; :cecure wnien rencers the quality of an item unacceptasie ce indeterminate." ,
Contrary to the above, "tracking NCRs" were used to record removal of parts f rom equipment on a permanent equipment transfer to ensure replacement of the part, a usage of NCRs that 15 not included in the above definition of nonconformance.
(3) Procedure CP-QP-16.0, Rev. 14, Paragraph 2.1 states: "It is the resoonsibility of all site employees to report items of noncon- ,
- fo*eance to their supervisors or to the TUGC0 Site OA Supervisor," -
. and Paragraph 3.1.2 requires using the NCR form for the reporting.
Contrary to the above, Paragraph 3.2.1 in Procedure CP-QP-16.0 states that non-QA/QC personnel should transmit the NCR to the PFG NCR Coordinator, who transmits the NCR to the "appropriate" QE, who is neither of the supervisors required by Paragraph 2.1.
12
- l 1
- b. 10 CFR 50, Appendix B, Criterion XVI states: "Measures shall be !
established to .P,ure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and ]
corrected."
Contrary to the above, corrective action was not taken promptly for deficiencies in N-5 data report preparation and review, as would seem to be warranted by the issuance of 50 NCRs during August 1984, related to that subject, nor was corrective action taken after the repetitive issuance of CARS, 22, 27, 32, and 43 for hold point violations. There was also s time period of 1 year and 7 months (June 11, 1980 to January 14,1982) in which no corrective actions were issued.
- 8. Attachments: None.
Reference Documents:
- 1. Procedures: (a) TUGC0 CP-QP-16.0, Revs. 2, 12, and 14,."Nonconfor-mances"; (b) B&R CP-0AP-16.1: Rev. 21, "Control of Nonconforming Items"; (c) TUGCO, CP-QP-17.0, "Corrective Action"; (d) TUGC0 CP-QP-18.0, Rev. 19, "Inspection Report"; (e) TUGC0 CP-EP-4.6, "Field Design Change Control," Revision 10; (f) TUGC0 CP-SAP-16, -
"Test Deficiency and Nonconformance Reporting," Revision 8; (g) TUGC0 CP-EP-4.7, "Control of Engineering /0esign Review of Field Design Changes"; (h) TUGC0 CP-EP-16.4, "Protective Coatings Exemption Log";
(1) B&R CP-QAP-11.1, "Fabrication and Installation Inspection of Com-ponents, Component Supports, and Piping"; (j) B&R CP-QAP-12.1, "ASME Section III Installation, Verification, and N-5 Certification."
- 2. B&R NCR Log.
- 3. TUGC0 letter TXX-4180, dated May 25, 1984.
4 NRC Inspection Reports 80-22, 83-34.
- 5. N-5 Data Reports: VA-1-34A, SF-1-38A, 00-1-45A, CH-1-05A, CH-1-27A, CC-1-58A, and related flange travelers.
- 6. CMCs: 5301 through 5343, 57051 through 50775, and 86551 through 86575.
- 7. OCAs: 10763 through 10775, 11620 through 11645, and 16301 through 16342, 4
M-2234 M-2239 M-2316 M-2318 M-2248 M-2263 M-2322 M-2324 M-2265 M-2277 M-2325 M-2326 M-2281 M-2283 M-2334 M-2338 -
M-2289 M-2292 M-2341 M-2346 M-2294 M-2296 M-2347 M-2352 M-2297 M-2298 M-2354 M-2359
.. M-2300 M-2303 M-2361 M-2362 .
. M-2308 M-2312 M-2365 M-2366 M-2840 M-14222 M-12163 M-2846 M-2658 M-12354 M-13788 M-2627 M-2577 M-12305 M-12306 M-2523 13
M-12382 M-2831 E-1905 M-11652N through M-11681N M-1135N and M-11687N
- 10. TUGC0 NCRs (Non-ASME):
E-81-01573 E-81-01536 E-81-01483 82-0001 E-81-014565 E-81-01393 E-81-01286 82-0002 E-81-00061 I-84-00378 I-84-00341 02-0003 1-84-00284 E-84-01688 M-84-01602 82 0004 I-84-014425 C-84-01374 E-84-013395 82-0005 E-81-00027 E-81-00024 E-81-00144 81-0001 E-81-00178 E-81-00195 E-80-00086 i'l-0002 E-80-00143 E-80-001625 E-80-00228 81-0003 M-82-02395 M-82-02399 M-82-02385 81-0004 M-82-02360 E-82-02347 M-82-022755 81-0005 E-82-022035 E-82-02153 M-82-021385 E-83-03152 M-82-02113 E-82-02078 M-82-01131 E-83-03128 M-8201055 M-82-00953 M-82-00910 E-83-03075 M-82-00807 E-83-02730 E-83-03036 E-83-03003 M-83-02736 E-83-02651 E-83-03005 M-83-02738 E-83-02652 E-83-03008 M-83-02725 E-83-02653 E-83-02902 E-83-02732 E-83-02654
- 1-83-02853 E-83-02703 E-83-02628 M-83-02847 E-83-2692 E-83-02620 E-83-02830
- 11. TUGC0 Memorandum TUQ-1559, "Documenting Nonconforming Conditions."
- 12. B&R Memo to all Foremen, dated Feburary 23, 1983.
- 13. 63 Unsatisfactory Inspection Reports
- 14. 42 Test Deficiency Reports
- 15. TUGC0 Turnover Status Report for week ending July 20, 1984
- 16. A-47 Affidavit, p. 15 and 16, July 16,1984 (AQ-114)
- 17. A-5 letter, dated March 7, 1984 (AQ-31).
- 18. GAP letter, dated March 19,1934 ( AQ-30) (AQ-80) AQ-85) ( AQ-86)
( AQ-87) ( AQ-95) ( AQ-96) ( AQ-97).
- 19. Region IV Report 4-83-001, p. 20, dated August 24, 1983.
- 20. A-5 Interview, p. 28 through 31, May 18,1984 ( AQ-120).
- 21. A-1 Statement #2 (AQ-116).
- 22. A-1 Interview, August 1,1984, pp. 71-79 ( AQ-116).
- 23. Region IV Report 4-84-006, dated March 7, 1984 (AQ-37 and AQ-35). .
- 24. Region IV Report 4-83-013, dated November 3, 1983 (AQ-109).
- 25. Special Review Team Report of July 13,1984(AQ-124).
- 26. Transcript of TRT A-1 and A-5 interviews, dated December 10, 1984, ,
beginning on pages 139, 148, 154, and 161, 9
l 14
o
- 9. This statement was prepared by: I, b JL3 -85~
T. Curry,#TRT Date '
Technical Reviewer
- Reviewed by:
H. Livermore Date Group Leader Approved by:
V. Noonan Date Project Director G
)
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o 6
- 1. Allegation Category: QA/QC SE, Materials
- 2. Allegation Number: AQ-5
- 3. Characterizati,on: It is alleged that lack of traceability for safety-related materials and components has occurred.
4 Assessment of Safety significance: The NRC Technical Review Team (TRT) reviewed the Brown & Root (B&R) Quality Assurance Manual, Section 8.0, dated May 17, 1978. Paragraph 8.2 of the manual requires that if material with material traceability identification is cut into more than one piece, the identification (or heat numbers) shall be transferred to the other pieces before cutting. A QC inspector shall then verify that heat numbers have been transferred. Section S.C of this B&R manual, in the revision dated August 14, 1931, continued to require verification of heat numbers by a QC inspector prior to subdividing material. Quality instruction ,
QI-QAP-11.1.28, Revision 25, required QC verification of material heat numbers prior to subdividing and also required that this heat number re-main distinguishable until the fabrication and installation of component supports were accepted by QC inspectors.
The TRT also reviewed an ASME Boiler and Pressure Vessel Code survey con-ducted at CPSES on October 12-14, 1981. Because of the many deficiencies identified by the survey team in the B&R QA program ASME delayed B&R's recertification until appropriate corrective action was taken. Some of the deficiencies identified by the ASME survey team were:
- 1. Control of material salvaged from vender-supplied components was inadequate.
- 2. B&R's survey and qualification of vendors was inadequate.
- 3. B&9 divided mate is' ard transferred the material identification .
rncorrectiy.
o
- 4. B&R did not verify the transfer of material identification.
ASME conducted another survey after B&R took the necessary corrective action.
The following were among the corrective actions taken:
- 1. B&R's appointment of a new quality assurance manager on November 6, 1981. -
- 2. TUEC obtained fabrication records from two vendors, ITT Grinnell and Nuclear power Services Incorporated (NpSI). The records contained certified matsrial test reports (CMTRs) and other fabri' cation data that
. provideo the recessary material control information. TUEC incorporated this data into the record packages for those cases in which B&R had used salvaged material to fabricate ccmponent supports, p
- 3. B&R received procurement documentation and issued interoffice memoranda which documented material reclassification.
4 TUEC proturement documents specified that material be purchased with CMTRs. Therefore, purchase orders were issued with standard paragraphs requiring material traceability. This allowed B&R to review procure- !
ment documents and verify that the material was acceptable for
. reclassification. l
.1
- 5. TUEC reviewed approximately 17,600 data packages, reinspected material !
where necessary, and scrapped material unacceptable for reclassification. !
- 6. In February 1982, B&R initiated a program to review all hanger packages to confirm acceptability of material. The review identified that
! A,$,ME Class 2 and 3 material had been installed in 45 Class I component , ,
wpports, as documented on NCRs P.-3033, Rev. 1 and M-3256, key. 1.
As a result of this review and subsequent reinspection, some material t was identified as unacceptable and was scrapped.
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.= y The ASME conducted another survey in January 1982 and recommended acceptance of the QA program.
t Based on a review of records and interviews with craft, inspection, and engineering personnel, the TRT determined that since the identification 1 and correction of the deficiencies reporttd by the ASME survey team, t the QA program for material control has been maintained, i
, I
- 5. Cenclusion and Staff Positions: Based on its review, the TRT concludes that the allegation that TUEC failed to maintain material traceability for safety-related material for numerous hardware components prior to October 1981, was substantiated. TUEC did have procedures for material traceability. as recuired by 10 CFR 50, A:pendix B, Criterien VIII; how-2 evte, IUEC did not follow these procedures, resulting in a partial break- !
down in the QA program. Although corrective actions were taken and were I documented (NCRs M-3033 and M-3258) in accordance with TUEC QA procedure
- CP-CAP-8.5 TUEC failed to report this partial breakdown to the NRC per j
' 10 CFR 50.55(e) requirements. l A meeting was held with the alleger on December 10, 1984, and the TRT's i findings and conclusions were presented. No nea concerns or allegations were identified. j
- 6. Actions Required ,
- 7. Potential Violations l Title 10, Code of Federal Regulations, Part 50.55(e) states: "If the per- ;
i mit is for construction of a nuclear power plant, the holder of* the permit !
I j shall r.3tify the Commission of each deficiency found in design and con- t f struction, which, were it to have remained uncorrected could have affected f adversely the safety of enerations of tlie nuclear power plant at any time ,
j throug50uttheexpectedlifetimeoftheplant,andwhichrepresents: (1) A j significant breakdown in any portion of the quality assurance program con- l i ducted in accordance with the requirements of Appendia b to this part." ;
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o O t Contrary to above, TUEC failed to report the breakdown in that portion of the QA program relating to the verification and transfer of material ident*fication as identified by ASME survey of October 1981.
t Attachments: None.
8.
t Reference Documents:
- 1. Procedure CP-0AP-8,5, Rev. 4, dated June 11, 1984. ;
- 3. A-5 letter, dated March 7, 1984.
4 Interoffice Memorandum (IM) 26, 407, $15367-B; IM 26, 589 SIS 369, l
SIS 369-9, IM 26, 729. ,
5.. A-5 meeting December 10. 1984, p. 99.
- 6. Procedure 01-QAP-11.1-28 i
- 7. Procedure CP-QP-16.1, Rev. 4, dated September 11, 1981. *
- 8. Results of AMSE B&PV Code Survey, dated November 23, 1981.
- 10. This statement prepared by:
V. Watson, TRT Oate Technical Reviewer Redewed by:
H Livermore, Date 1
- ' a Leader Approved by: !
.. .sonan, Dat'e ,
Project Director l
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I t
I
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- 1. Allegation Category: QA/QC 6, QC Inspection
- 2. Allegation Number: AQ-55 and AQ-78
- 3. Characterization: It is alleged that fuel transfer canal liner documen-tation was falsified, that required weld radiography was not completed, and that hold points on inspection travelers for the fuel building were signed off improperly.
- 4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) learned that the liner consists of a series of 3/16-inch-thick stainless steel plates welded together and attached to the inside of a concrete structure within the fuel building. Transfer tubes at either end of the canal connect to similar fuel pools inside the Unit I and 2 containment buildings, which are also referred to as reactor cavities. The method of construction required that all vertical liner plates first be preassem-bled; concrete was then poured around the outside of the plates. The plates also had studs welded to the back and ecedded in the concrete to hold the plates in position.
The plates were first joined to a backup bar on the back side with a 1/4-inch spacer temporarily attached between the plates to maintain a weld gap. A channel was then welded over the backup bar to form the leak chase cavity, and concrete was poured around the outside of the liner. Follow-ing concrete backfill, the back side became inaccessible. The final (wa-ter side) seam was machine welded after removal of the 1/4ainch spacer.
Plates that did not maintain a minimum gap of 3/16-inch required grinding out to 3/16 inch or hand welding. The final seam weld was made as much as 3 years af ter the initial back side welds. After completion of welding, the seam welds were intended to be examined by dye penetrant testing, vacuum box testing, and visual examination before the traveler was signed and dited. .
The Final Safety Analysis Report (FSAR) for Comanche Peak includes a "Q" Itst (Table 17A-1), which identifies safety-related structures, systems, and components. This list also identifies the items for which a quality 05/16/85 1 AQ 55 A C A0 73
I o
assurance program in accordance with 10 CFR Part 50, Appendix B, is re-quired. The stainless steel pool liner is not specifically identified in that list as a "Q" (safety-related) item; however, Gibbs & Hill Specifica-tion 2323-55-18, Revision 3, dated April 6, 1979, paragraph 11.0, for the fuel pool liner, states that:
1 The contractor shall establish and implement a Quality Assurance Program which rigidly conforms to the applicable rules and standards as imposed by the Nuclear Regulatory Commission, 10 CFR 50, Appendix B, ANSI N45.2-1971, ANSI N45.2.9 (Oraf t 11, Rev. 0 - January 17, 1973), ANSI N45.2.10 (draft dated 1973),
ANSI N45.2.11 (Oraft 2, Rev. 2 - May 1973), ANSI N45.2.12 (Draft 3 Rev. 0 - May 2, 1973), ANSI N45.2.13 - NRC Extract (Oraft dated May 31, 1973) and this specification. The program shall include ;
pertinent aspects of procurement, fabrication, site erection, -
inspection, testing, handling, shipping, storing and cleaning. ;
The allegations refer to a period early in 1983, when the QC inspection responsibility for the liner plate welds was being transferred from ASME, ;
Brown & Root (B&R), to non-ASME, Texas Utilities Electric Company (TVEC),
since the liner welds were not ASME-Code welds. In preparation for that l transfer, B&R apparently noticed travelers that had missing QC signatures for hold points but that had been completed. l l
Part of the allegation was :m. . ;M 0; inspector was coerced into sign-l ing 112 liner travelers that supposedly were inspected by another inspec-
, tor; that is, the other inspector had signed the inspection hold point .
some 5 years presiously, filling out a chit documenting completion of the , ,
hold point, but not signing the traveler. The inspector who made the allegation signed the travelers, referencing the original chits as sub-stantiation that the inspections had been completed, but maintained that l the ch.its available did not contain adequate information to substantiate .
l signing the hold point. Therefore, according to the 411eger, such sign-off constituted falsification of the travelers.
05/06/85 2 AQ 55 AND AQ 78
The TRT reviewed all inspection travelers for liners in the fuel building, plus selected travelers for the refueling cavity pool in the Unit 2 con-tainment building. The TRT located 47 inspection travelers related to the Unit 2 refueling cavity liner, which were signed by two different in-spectors and for which hold point No. I had been signed-off out of se-quence (i.e., after later hold points had been signed off). 'A footnote ,
was placed at the bottom of each traveler, stating: "Late entry per CP-QCI-2.11-11, Para. 5, see Note. ReferNDE[nondestructiveexamination]
chit attached documentation." The footnotes were signed by the inspectors and dated in early March 1983.
The TRT found the "chits" referred to in the traveler footnote attachec to the travelers. Most of the chits were dated in late 1978. The Cp-QCI-2.11-11, Para. 5, "Note" referred to states: "The QC Inspector shall use information on the NDE Report chits to update Attachment 4-A
[i.e., the inspection traveler] daily and subsequently forward the NDE request chits to the QA vault daily as a status indicator."
The TRT noted that there appeared to be confusi:n in implementation of procedures related to stainless steel liner ins:ection, as indicated by the following:
- a. TRT review of CP-QCI-2.11-11. "Welding Inspection and Fit-up of Stainless Steel Liners." showed that the ccrrect number for this pro-cedure was CP-QCI-2.11-1, although pages in the procedure useo either number. However, the TRT found that procedure CP-QCI-2.11-1 had been deleted from the QC manual on January 10, 1979, by B&R interof fice memo IM-16606. This procedure was replaced by procedure .
QI-QAP-10.1-4.
The TRT found two procedures numbered QI-QAP-10.1-4: QI-QAP-10.1-4, Meauest for Recualification of Welders by ANI," Revision 0, dated .
August 24, 1978; and QI-QAP-10.1-4, "Welding Inspection and Fitup of i Stainless Steel Liners," Revision 0, dated January 5, 1979. The sec-ond procedure was replaced by QI-QAP-11.1-4, "Welding Inspection of I Stainless Steel Liners," Revision 0, dated Cecember 26, 1979. This 05/04/85 3 AQ 55 AND AQ 78 i
_ . _ _ _ . _ _ , . . _ , . . _ . , _ . . _ . . _ . . . . . _ . . _ . . _ . . _ _ _ . . . _ . _ _ , . , . _ . . _ _ _ _ . . . ,,.__.-__m... ,_ . _ _ . . . _._._. _ _ ,
e procedure was deleted from the QC manual on January 15, 1982, and was then reinstated without change on January 26, 3982.
The TRT also noted that, beginning with CP-QCI-2.11-1 and continuing through QI-QAP-11.1-4, paragraph 3.1.1, these procedures required fit-up and cleanliness verification of the inside seam welds af ter con-crete placement as a QC hold point. Similar requirements were noted in B&R procedure 35-1195-CCP-38, Revision 3, and in QI-QP-11.14-6, Revision 1. This appears to conflict with testimony prefiled by TUEC, which states that there was no procedural requirement for QC to reverify cleanliness (Reference 23).
F
- b. Texas Utilities Gener'ating Company (TUGCO) procedure QI-QP-11.14-6 references B&R procedure 35-1195-CCP-38 for instructions on issuance and distribution of the inspection traveler and chit. However, CCP-38 does not contain such instructions; indeed, even the intent of the TUGC0 procedure is not clear, since the traveler and chit do not receive "issuance" and "distribution" in the usual sense,
- c. The use of the chit was introduced in B&R specification CCP-38 in Revision 1, dated October 21, 1977, paragraph 3.4.2, which stated:
"The form shown in Figure 3 [i.e., the chit] shall be used in the above noted hold points as notification to QC to perform inspection."
4 The QC inspector signed the chit after the inspection, providing craft personnel with a record of completing the hold point and allow-ing them to proceed. The chit was apparently intended to be used as a construction document, not as a QC record to document completed inspections. Procedure CP-QCI-2.11-1, which referenced use of the chit, was deleted on January 10, 1979. The superseding procedures, QI-QAP-10.1-4 and Q1-QAP-11.1-4, contained no reference to the chit, but stated in paragraph 3.1.1:
. The QC Inspector shall inspect the following items duri9g fit-up and welding of liner material upor, receipt of the Stainless $ teel Liner Inspection traveler. (A list of items to be inspected i
followed.)
05/04/85 4 AQ 55 AND AQ 78
. O The chit was replat.ed in CCP-38 on August 14, 1978 by the inspection traveler in Interim Change Notice (ICN) No. 2 for Revision 2, and was reintroduced in CCP-38 by ICh' No. I for Revision 3, dated July 26, 1979, and in QI-QP-11.14-6, Revision 1, dated September 8, 1982,!.:h of which indicated that the travelar was to be used to notify QC to perform inspections and that the chit was to be used to record in-spection results for hold points not !ncluded on the inspection -
l traveler (e.g., examination of plates af ter removal of temporary attachments,etc). Apparently, the continued use of chits after l
January 10, 1979, as a primary means to request and document inspec-tions was not in accordance with the above precedures. ,
i
- d. There were frecuent changes in the inspection traveler form attached l to specification CCP-38. Initially, the form was issued as part of CCp-38 on August 14, 1978, and showed five weld inspection hold .
j points. The use of five hold points was inadequate for plate-to-plate = elds, in that two fitup and cleanliness inspections of the !
l same gap were appropriate, but the use of five hold points allowed '
for only one sign-off. The form was modified to include eight hold E points, one of which was an additional gap fitup and cleanliness l inspection, and was reissued on April 18, 1979. The form was also reissued with minor revisions on May 23, 1979, July 26, 1979 June 22, 1982 (decreased to seven hold points), and September 7, 1982 (increased to eight hold points).
The TRT found that welding of stainless steel liners for the refueling cavity in the Unit 2 containment building was also the subject of noncon-formance report (NCR) MS3-00795, issued on March 17, 1983, whic,h stated the following nonconforming conditions:
- a. "A random review of stainless sten 1 liner travelers for Reactor
.. !! cavity liner welds has found recuired fit-ups/ cleanliness .
. inspections of inside (water side) welds cannot be verified as being performed."
- b. "Quality of nelds indeterminate."
05/04/85 5 A0 55 AND A0 78
- c. "See attached sheet for welds randomly reviewed."
- d. "Five hold tags applied."
This NCR was dispositioned and closed on March 23, 1983. However, the NCR was reopened and issued as Revision 1 on March 29, 1983, for the stated purpose of changing the nonconforming condition, i.e., the words "random" and "randomly" were deleted. In the opinion of the TRT, deletion of those words limited the scope of the NCR to the welds listed on the NCR, which was not the meaning of the original NCR. It appeared to the TRT that this revision was issued to avoid the investigation that the original NCR would have required. No explanation was provided on the NCR for revising the descriptien of thJ nonconforming condition, and there was no indication on the NCR of the inspector's concorrence with the changed description. (The TRT has reviewed TUEC's testimony filed before *.he Atomic Safety and ,
Licensing Board on November 27, 1984, regarding this subject, and does not accept TUEC's explanation that the revision was simply a matter of wordchanges.) -
The TRT learned that Revision 2 of the NCR wat issued on August 13, 1984, for the stated purpose of deleting weld No. 1225 from the NCR. This was an additional change in the description of the nonconforming condition, and also was made without explanation and with the signature of someone other than the original inspectors. This NCR was dispositioned as follows:
Subject welds are seam welds utilized to provide leak tightness of the liner. Acceptability of welds shall be based on vacuum
. box and hydrostatic tests.
9 The TRT also reviewed NRC RIV Inspection Report 79-15, dated June 21, 1979, related to welding of the pool liners, in such the inspector concluded: .
The resident inspector...has become reasonably sure that there were dif ficulties encountered by the welders with water, moisture, and in some instances with concrete on t weld surfaces, and that 05/04/85 6 A0 55 AND A0 78
O in some instances, the welds may not be completely sound inter-nally. These welds, however, serve no strength purpose and need only be smooth and leak free, factors which are established by l visual inspection, dye penetrant, and by vacuum box tests of the joint after it is complete. The allegation, while probably true, l
has no safety significance.
Review of the stainless steel liner by the TRT mechanical and piping group is documented in Mechanical and Piping, Category 43. As indicated in that assessment, the liner is not safety-related, and the liner welds are considered to be acceptable, i 1
1 The TRT then reviewed that part of the allegation regarding 'the improper j j sign-off of inspection travelers, including review of material supplied by the intervenors (References 14 and 16). The TRT found certain recurring irregularities in the inspection travelers which were grouped into six categories. The categories itsted in References 14 and 16 were not spect-fically addressed by the TRT, because the TRT reviewed the travelers independently in forming their conclusions. In some instances, the items identified in References 14 and 16 are similar to items noted by the TRT; in other instances, the items did not appear to the TRT to be significant.
The following examples are typical, b n not inclusive, of the irregulart-ties noted for liners in the fuel building (unless otherwise noted):
- a. Travelers for Weld Nos. 595, 591, 588, and 589, Owg. WFB00831, were signed by a QC inspector on 12-4-81. However, the "5AT" preceeding the signaS re does not match the inspector's signa-ture on penetrant testing inspection forms attached to the trav-elers. It appeared to the TRT that someere entered "$AT" and the date on the travelers, then obtained the QC inspector's sig-nature. This inspector confirned during an interview that this had occurred, and the TRT discovered a number of travelers in .
. which "SAT" was written for Hold Point No. 5 with no inspector's signature (e.g., weld Nos. 6, 15, 19, 34, 36, and 61 for tJnit 2).
Also, Step 5 of the traveler for Veld No. 580, Dwg. WFB00831, had a signature and date of 8-5-81; then the date was chnged to 05/04/85 7 A0 55 AND AQ 72
. O "7-2-80" and was initialed and dated "7-2-80." The traveler for Weld Nos. 567, 568, 572, and 583 were similarly modified.
The same type of corrections were a m i on some NDE examination records (!ee travelers for weld numbers 60, 70, 104, 114, 126, 129, 144, and 580 for the fuel building). It ,ippea's r to the TAT that cates were also pre-entered on some NDE examination records; howe <rvr, the practice of pre-entert'q the scheduled date was apparuntly discontinued because of the aut.ber of corrections required.
- b. The traveler for Weld No. 564, Dwg. WFB00831, was signed as coe- [
plete on "7-29 81." However, in reviewins th traveler before i transmittal to the B&R QA files, the 1.9spector apparently noted that vacuum t.ox testing hd, not been completed. The vacuum box
- P testing was performed on "8-26-81," then the signoff date for weld completion was chang'd to "8-26-81," and the traveler was receipt-stampedbyB&RCAfilesas"8-27-80(sic]." The TRT noted similar occurrences on tNyelers for Wald Nos. 584 through 586, 558 through 563, and for 555 and 592. .
t
- c. The procedure numbers for the vacuum box and leak tests were ,
changed during construction of the liners; however, the numbers on the inspection forms were not changed. Since the form was not ,
changed, the insoector was required to write in the correct pro- l cedure numbers, as shown on travelers for Weld Nos. 568 through j 571, and for 573 and 575, dated July 2,1980 and August 10, 1981, and signed by another inspector. However, travelers for Wald .
Nos. 536A through 544A and 546A through 549A, with the same !
inspector's signature, were dated in November and Ouember of f 1981, and did not have the procedure numbers corrected. The L
.. p.v:edure nuebers were corrected and a ted separately in Decem- .
= ber 1981 and Janu.ry 1982, a few days n' ore the travelers were I received and date-stamped by the B&R QA files. I I
05/04/85 . $ AQ $5 A C A0 78 l
.o
- d. Inspection travelers, 58, 60, 114, 115, 126, 129, and 144 had the signoff dates changed without explanation, including, in some instances, changes to first party inspector dates on the NDE sheet,
- e. In comparing weld rod issue dates with inspection signoff dates for 23 travelers, the TRT located one traveler (No. 62 for Unit 1) in which weld rods were issued on October 3,1978, but the fit-up and cleanliness inspection hold point was signed off on December 14, 1978,
- f. The TRT also noted that inspection travelers typic' ally had the welding informAtion completed en the left side of the form to
- identify the ww1 der, wele filler material log, procedure, and the hold point against which weld red had been issued However*,
some travelers for welds that had welding performed and inspec-tion hold points signed of f did not have information as to weld-er, weld filler material log, procedure, or hold point (e.g.,
welds 410 through 540 for Unit 2). It is difficult to determine what the requirements were for completing the left side of the traveler form, since the procedures that reference the form identify requirements for QC inspectors to sign off hold points, but do not indicate how the left side of the form is to be used, or if it is required to be used.
4
- g. In testimony filed on November 27, 1984, p. 21,041, TUEC stated that for the inspector to correctly sign hold point 1 as a late entry, there must be verification that both inspectio,ns (inside and oute ;de) have been completed for a plate-to-plate weld; i.e. ,
two chits, or one chit plus one personal inspection. This is demonstrated by Unit 2 traveler No. 261, for which hold point 1
.. was signed en "3-3-83." and whi:5 has two chits attached, ene ,
. dated "9-28-75 " the other cate "10-19-51." However, Unit 2 traveler Nos. 248, 250, 263, 331, 334, 335, 338, 341, and 346, which were also signed on hold point 1 on 3-3-83 as a late entry, have only one chit attached, which substantiated the initial 05/04/85 9 A0 55 AND A0 ?!
- a (outside) inspection. The inside weld was completed in 1981 and/or 1982, as indicated by weld filler material logs; therefore, a second cleanliness inspection before welding could not have been accomplished by the inspector on March 3, 1983. Addt-tionally, these travelers have an NCR (M83-00795, dated March 17, 1983) attached which states that the documentation required to support complation of inspection for the inside weld is not available. Final sign-off of the traveler was completed after the hCR was dispositioned. Based on the above, the TRT concludes that these travelers were signed off improperly, i.e., without substantiation or personal inspection of the inside weld. The TRT does not consider this improper sign-off to bertalsification, as stated by the alleger, because of an aoparent absence of an intent to deceive. The note entered by the inspectors on the travelers indicated they were signing hold point I with some ,
reservation, and NCR M33-00795 further identified the lack of adequate documentation.
A total of 5,022 inspection travelers related to the liners were issued as of September 14, 1934 Of these, 1,209 were for Unit 1; 2,612 were for the fuel building; and 1,201 were for Unit 2.
Three lift gates in the fuel building fuel transfer canal had gate supports which were welded to the liner. B&R specification CCp-38 required radio-graphy for these Welds (Nes.1759 through 1772; 1803 through 180S; and 1823 through 1826). The TRT located the radiograph records. These records showed acceptance of all the above welds. Therefore, the TRT concluded that the required radiography inspection was completed. (This subject is assessed Mechanical and Piping, Category 41, allegation AQW-79.)
The fuel building fuel pool was filled and the liner was satisfactorily leak tasted on March 22. 1983 by Test No. XSF-055. .
- 5. Conclusion and Staff positions- The allegation that required radiography was not completed is not substantiated, since the TRT found records showing the results of radiography of those welds for which radiography was required.
05/04/85 10 A0 55 AND A0 7S
i i
The primary subject of this allegation was the falsification or improper sign-off of records i.e., inspection travelers. The TRT could not con-clude that the irregularities noted constituted falsification, per se.
Apparently, these irregularities occurred because of poor practices and inadequate inspection forms. Some travelers also appeared to have been signed of f improperly.
TUEC representatives indicated that it was common practice for the mill-weight department to write "SAT" and, in some instances, the scheduled date for inspection of the completed weld on the traveler, with the intention of obtaining the inspector's signature when the weld was com-pleted and inspected. Wel. ding priorities apparently were then rescheduled ard the pre-entered dates were corrected when the traveler was signed.
The TRT cencludes that there are record anomalies apparent in the liner +
plate travelers which are not adequately explained on the face of the travelers (e.g. , dates changed), which violate procedures (e.g., f ailure to transfer sign-off from chits to travelers daily), and which employ in-adequate procedures (i.e., confusion over the .ne of the five-line i
traveler).
It appears to the TRT that the QC documentation relating to the liner plate welds did not meet the standards expected of an effective QA/QC program, or the standards required by Gibbs & Hill specification 2323-55-18, and 10 CFR 50 A;;endix E.
The TRT discussed the results of the assessment of allegation AQ-78 in a meeting with the alleger on December 10, 1984, as documented in the meeting transcript, beginning on page 166. A letter containing these results was also transmitted to the alleger. A meeting with the alleger of AQ-55 was held on March 5, 1985, to discuss the results of this assessment. No new issue),or concerns were identified. ,
- 6. Action's Recuired:
l l
05/02/95 11 AQ 55 AND AQ 78
{
o
- 7. Potential Violations: 10 CFR 50, Appendix B, Criterion V states: "Activ-ities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings," and TUEC Procedure CP-0CI-2.11-1, Para. 5, Note, states, in part: "The QC Inspector shall use information on the NDE Report chits to update Attachment 4-A (ie., the inspection traveler) daily and subsequent-ly forward the NDE request chits to the QA vault daily as a status indicator."
Contrary to the above Procedure CP-QCI-2.11-1 was referenced as a working document on travelers 4 years and 2 months after it had been deleted from the CA Marual and sign off of hold points on inspection travelers was not upoated daily in accordance with Procedure CP-QCl-2.11-1, Para. 5 Note, when the procedure was in effect. .
10 CFR 50, Appendix B, Criterion X states: "If mandatory inspection hold points, which require witnessing or inspecting by the applicant's desig-nated reper 'atative and beyond which work shall not proceed without the consent of its designated representative are recuired, the specific hold points shall be indicated in appropriate documents."
Contrary to the above, the five-line inspection traveler was not an appro-priate document in that certain ia-process inspections were not made be-fore werk was allowed te proceed.
- 8. Attachments: None.
Reference Documents:
- 1. Logbook pages for radiography of Weld Nos. 1759 through 1772, 1803 through 1808, and 1823 through 1826.
- 2. 11gneff sheet for Test ASF-055, dated March 22, 1983.
- 3. Fuel Building Spent Fuel pool Liner Details, 23235-0831 through
-0834.
05/04/S5 12 A0 55 AND A0 78
i
. , l 2
- 4. Fuel Pool Liner - Fuel Building Weld Map, WFB-00831. ,
- 5. B&R Specification 35-1195-CCP-38, "Stainless Steel Liner Erection."
t
- 6. B&R Procedure CP-QCI-2,11-1, "Welding Inspection and Fit-up of Stain- ;
less Steel Liners," with IM-16606, dated January 10, 1979. f
- 7. Office Memorandum TUQ-2340, "Stainless Steel Liner Travelers :
Unit II," dated September 11, 1984. .
S. Interview with alleger A-3, pp. 60 through 89. ;
- 9. Bostrem-Bergen drawing 2401. !
i.
- 10. Testimony of alleger A-4, March 7, 1984, pp. 18, 19, 20. -
i 11. Testimony of alleger A-3, August 1, 1984, pp. 59,516 through 59,536.
i l 12. G&H Specification 2323-55-18, "Stainless Steel Liners," Rev. 3, l April 6, 1979. !
i
- 13. Deposition of C. Thomas Brandt, August 16, 1984 (Tr. 45,239-355).
i
- 14. "CASE's Evidence of a Quality Control Breakcown," dated September 27 -
1984 (
i
- 15. Prefiled Testimony of C. Thomas Brandt, Octcber 3, 1984 (Tr. 45,356-480). !
i
! 16. "CASE's Further Evidence of a Quality Control Breakdown in the Con- {
struction, Installation and Inspection of the Stainless Steel Liner i Plate," dated November 15, 1984 l l
- 17. h stimony of C. Thomas Brandt, Tr. 15,629-697 (9/12/84); 15,978-16,214 l J
(9/13/84); 16,728-777 (9/18/84); 17,264-363 (9/19/84); 20,569-774 l (11/26/84); 20,778-21,091 (11/27/84). ;
i i
i 05/04/S5 ,
13 A0 55 AND A0 78 i ,
1 0
,--------,,------.---.n,-n, , , , . - - - . - , . , , . , - - - , . . , . - , ,-.,,,c., . . _ , , _ _ , - - - , . , _ , , - . _ , , _ ,w._,____,.,,_ , , , ., _ . - - - - , , -
i i
- 18. Deposition of alleger A-3, August 1, 1984 (Tr. 59,516-536, 59,640-676) and August 2, 1984 (Tr. 59,773-825). ,
. i
- 19. Deposition of A11eger A-1, July 31, 1984 (Tr. 54,596-617). l
- 20. Deposition of Dwight Woodyard, July 24, 1984 (Tr. 56,561-566). ,
- 21. Deposition of Ted Blixt, July 25, 1984 (Tr. 57,015-036) i
- 22. Deposition of Robert $1ever, July 25, 1984 (Tr. 58,024-056).
- 23. Profiled Testimony of C. Thomas Brandt, October 16,198'4 (Tr. 45,373).
l 2 4 .' Transcript of TRT Interview, December 10, 1984 (beginning on page 166). -
1 :
- 25. NRC letter, D. Eisenhut, NRC, to M. O. Spence, TUEC, dated January 8, 1985. !
l c
i 26. Liner inspection travelers as noted in text, i
- 9. This statement prepared by:
T. Curry TRT Date Technical Reviewer Reviewed by: '
- H. Livermore, Date Group Leader t <
j Approved by: .
V. Noonan, Date !
Project Director !
i ;
i
. i e
h i I l !
i !
l
),
05/04/85 14 A0 55 AND A0 75 l
l . , . , _ . _ _ _ . - . _ _ . . _ . _ ~ _ , _ _ _ ._ _ _ _ _ , _ _ _ _ _ , _ .. _ , _ _ . _ _ ,__._,___,._. _ _ _ . _. _ _ .
3$4Ah%%
w/ thbW#ods A, -d8
- 1. Allegation Category: QA/QC 7. QA Implementation
- 2. Allegation Number: AQ-121
- 3. Characterization: There is a concern that the program controls for areas not constructed according to ASME Code requirements are considerably less structured than in those areas constructed according the ASME Code. It is further stated that some installed structures did not meet design draw-ing requirements; there are also concerns that the lead QC group leader (the QC lead) was inappropriately approving cha,nges to travelers for non-ASME structures.
4 A_ssessment of Safety Sienificance: The NRC Technical Reviek Team (TRT) reviewed applicable procedures, instructions, specifications, codes, and standards to determine whether appropriate program controls were established for non-ASME structural steel construction. These documents were also reviewed for their conformance to Texas Utilities Electric Company (TVEC) commitments and NRC requirements for structural steel fabrication, erection, installation, inspection, and material traceability. In general, non-ASME program controls were established in the specifications, procedures, and instructions, except in the following instances.
First, no written procedures were established for the inspection of embedded anchor holts, even though there was a statement on the operation traveler that "nuts on anchor bolts shall ee snug tight." (Operation trav-elers are checklists normally used for routine inspections by the QC in-spectors.)
Second, the baseplate hole size cor'esponding to the anchor bolt size was not specified in the inspection procedures. Based on information from TUEC representatives, approximately 10 percent of all steel construction used embedgpd anchor bolts. To ensure cuality, the CC inspectors nortally ,
would. detect these deficiencies during inspections based on information in operation travelers or on design drawings.
05/04/85 1 A0-321
Third, structural assembly verification cards (SAVCs) were used in the QC inspection for material traceability. There were no written ti. ructions l concerning the 3AVCs, nor were they addressed in a principal QC inspection i instruction, QI-QP-11.14-1, Rev. 18. f Fourth, TUGC0 procedure CCP-22, Rev. 3, "Table of Contents," identifies paragraph 4.6 as "Insper. tion-Category I," and the scope of work statement in paragraph 1.2.1 indicates that the inspection of Category I items was covered by this procedure. Although paragraph 4.6 in the procedure was ,
titled "Attacheents to Building Structure," there were no specific sec- ;
tiens in the procedure that related to the inspection of Category I !
structures.
In regarcs to insta11ec structures, the TRT interviewed four QC inspectors [
and one QC supervisor whose primary functions were to inspect steel struc- ,
tures that had been installed and which were not subject to ASME Code re-quirements. During the interview, the TRT learned that prior to April 1963, all of the concerned individual's work was performed in piping sys- ,
tems which were subject to ASME Code requirements. The work which gave !
rise to the concern was the work the concerned individual had done as a QC inspector in structural steel construction that was not subject to ASME !
Code requirements. After a lengthy discussion with the individual about program controls of the Code applications between non-ASME work and ASME work, the TRT formed the opinion that the individual made an inappropriate I
comparison of ASME Code work to the requirements of non-ASME Code work. !
All other QC inspectors in'.erviewed said that proper controls existed for f non-A$ME steel constructions. In fact, they believed that the plant was [
being built in a proper manner in this area. , !
In assessing the issues of design drawing requirements and the QC lead l changj,qg travelers. the IRT held discussions with the TVEC representatives .
l about design changes mace to design drawings tnrough the use of design [
change , authorizations or component modification cards and about the QC lead !
modifying travelers to determine whether appropriato controls were esta-blished for the non-ASME work. The TRT found that TUEC did have procedures }
to control these activities (References 2, 3, 4, 5, 6, 7 and 8).
05/04/25 2 AQ-121 r
I t
- , ~ . _ , _ _ _ _ _
The TRT also performed field inspections of two steel structures (in the auxiliary building) that had been inspected previously by the non-ASME QC group to determine whether ttie program controls were fully implemented in accordance with established procedures and instructions. Based on compart-son of procedures, inspection criteria, and inspection results, the TRT determined that the controls had been implemented, except in one area, where i minor discrepancies (missing washers) were identified in an anchor bolt 3
installation.
! 5. Conclusion and Staff Positions: Af ter reviewing documents, interviewing
< QC personnel and TUEC representatives, and conducting field inspections, the TRT finds that program controls for the non-ASME work were established and i.mplemented. The TRT fcund no physical evidence of lack' of program controls for non-ASME =cek in the areas of structural steel construction, except for a minor discrepancy in ancher-bolt installation. That part of, I
the concern associated with a minor discrepancy in the installation of l
anchor bolts was substantiated.
The A0-121 concarns and issues came from an NRC special review team report.
On March 25, 1984, a close-cut interview was conducted with the individual expressing these concerns and issues. No new concerns or issues were identified.
- 6. Actions Required:
- 7. potential Violations:
- a. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall te prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings.
kntrary to the above, activities affecting quality were not being accomplished in accordance with this requirement in that no written procedures had been established for the inspection of embedded anchor bolts and baseplate hole sizes for bolts. Consa:uences 05/04/55 3 AQ-121
of this were noted when TRT's audit of two steel structures revealed that washers were missing on three anchor bolts, and holes in the
]
corresponding baseplate appeared to be oversized by more than the :
maximum 1/8 inch allowed. ,
i i
- b. 10 CFR 50, Appendix B, Criterion VI, requires that measures shall be ;
established to control the issuance of documents, such as instruc- )
tions, procedures, and drawings, which prescribe all activities '
affecting quality. These measures shall assure that documents, in- (
cluding changes, are reviewed for adequacy and approved for release l by authorized personnel. 7 i
Contrary to the above activities af fecting quality were not being accomplished in accordance with established document control in [
that construction procedure CCP-22. Rev. 3, in the table of contents, ,
l called for "Inspection Category 1," to be in paragraph 4.6 and the [
scope of work in paragrach 1.2.1 addressed inspection of Category I !
l items, but the inspection of Category I items could not be identified i in the text of the procedure. This procedure had been reviewed by i TUGC0 CA and approved by the construction project manager. [
t
- 8. Attachments: None, t
! t i
Refereece Documents: l l r l 1. Cesign change authorization No. 1213 Rev. 7. (Structural steel inspect. ion pertaining to missing washers on etbedded anchor bolt). ;
- 2. Procedure CCP-22, Rev. 3 "Structural Steel Erection." - f i
r
- 3. Instruction Ql-QP-11.2-1, Rev. 16, "Installation of Hilti Orilled-in Anchor Bolts." , i j 4. Instruction QI-QP-11.14-1, Rev. 18 "Inspection of Site Fabrication j j and Installation of Structural and Miscellareous Steel."
l '
a
) I i
! 05/04/85 4 A0-121 ;
l . (
O k
a
- 5. :nstruction QI-QP-11.14-5, Rev. 10. "Inspection of Platforms and stairways Installed in Seismic Category I Structures."
- 6. Gibbs & Hill, Inc. specift:ation 2323-55-168, "Structural Steel ,
(Category !)."
- 7. Procedure CP-CPM 6.3, Rev. 11, "Preparation Approval, and Control of :
Operation Travelers."
- 8. TUGC0 Nuclear Engineering drawing update activities, April 1984. '
- 9. Procedure TNE-DC-7, Rev. 5, "Preparation and Review of Design Drawings "
i
- l 10: NRC Special Revie. Team Report, dated July 13, 1984, page 64.
- 9. Tht: statement prepared by:
j V. Wenczel. TRT Date j Technical Reviewers !
.c r
Reviewed by: !
I H. Livermore Date i j Group Leader [
l Approved by:
V. Noonan Date !
Project Director !
i b
i i
i i
i 1 e t
1 1
4 l ;
a 1
i 05/0t/65 5 A0-121 i .
i 1 t i
I
- 1. Allegation Category: QA/QC 7, QA Implementation
- 2. Allegation Number: AQ-6 and AQ-126
- 3. Characterization: It is alleged that quality assurance / quality control (QA/QC) lacked independence from production (AQ-6), and that former craft l persons and inspectors were assigned the responsibility of performing a record l vertf tcation of packages containing their own inspection or work between December 1983 and February 1984 (AQ-126).
4 Assessment of Safety Sionificance: In assessing the allegation that QA/QC lacked independence from construction, the NRC Technical Review Team (TRT) first reviewed Texas Utilities Electric Company (TVEC) organization charts for the relationship betwe'en the construction, startup, and operations groups. The authority and duties of all group positions were described ,
in the Final Safety Analysis peport (FSAR) and implementing procedures.
,, The TRT learned from November 1983 organization charts and interviews that the construction activity wat changed from management on a plant-wide basis to a building management organization (BMO), which subdivided plant con- f q struction responsibilities into four buildings: the reactor building; electrical control and turbine building; auxiliary building; and safeguards I
] and diesel generator building. Construction resoonsibilities included (
) planning and scheduling, documentation processing, engineering, and craft.
CA/QC personnel were assigned to provide quality services to each building, and reported directly to the project QA manager. The building manager and the QA manager were at the same reporting level to Comanchs Peak Steam ;
Electric Station (CPSES) senior management. l The TRT verified that QA/QC personnel working with building organizations f did indeed report direct to QA management and not BM0 management. At the time af the TRT's evaluation. it was determined that QA/QC organization ,
was independent from the influence of construction production and was in !
compliance with 10 CFR Part 50, Appendix B, requirements for QA/QC organt-2ational independence. The change of management on a plant wide basis to 05/04/85 1 A0-126
5 l
the BM0 did not affect quality personnel, who continued to report to the same management as before; nor were their job assignments affected by the change.
The TRT then reviewed the audiovisual orientations given to all new CPSES j employees. Brown & Root (B&R) provides an orientation program for con-struction employees and TUEC provides an orientation program for all QA/QC
, empicyees. Part of the B&R program consists of a slide presentation called j "Quality Is Your Job," which was created in October 1983. The TRT was told j by the instructor that the presentation was prepared at the direction of l the vice president for Nuclear Operatier s as the result of an NRC commit-l ment. The presentation was given retroactively to all construction personnel and included an explanation of the multiple levels of inspection l
j re pired by the worker, foreman, QC, QA, and the NRC. All site workers i were expected to cooperate with inspectors and it was explained that i "bullying or harassment" of QC inspectors would not be tolerated. When l TUEC's orientation first began, all new employees were shown the TUEC i QA/QC film "Introduction to Quality Assurance and Quality Control," but I for the last 5 years it has been shown solely to the site QA/QC inspectors.
The TRT reviewed two of the six sections in the TUEC presentation, both 3
of which made many references to the organizational independence of QA/QC I from construction, as required by the regulatiens. There was a good I presentation on the "Nature of QA/QC Inspectors," which placed special l emphasis on the establishment of good working relationships with craft personnel and avoiding personal disagree ents and conflicts with construc-f i tien personnel.
l In assessing the allegation of former craft personnel and inspectors
- performing verifications of their own records, TRT reviewed four B&R and two TUEC procedures on personnel training and one procedure on 'verifica-tion activities of QA records. These procedures did not provide any l preventive measures or precautions that record reviewers avoid the poten- .
l tial conflict of interest alleged. The training requirements for record reviewers prior to spring of 1984 included attendance at the QA/QC orientation class, review of the applicable procedures, and a general reading list, which included 10 CFR part 50, Appendix B, and ANSI N45.2.
05/04/55 2 AQ-126
l Criterion X of 10 CFR Part 50, Appendix B, states that inspections shall
. be performed by individuals other than those who performed the activity being inspected. This criterion also would apply to record verification.
B&R management could not provide any documentation in the training given to record reviewers that stated they should not review their own work, nor were record reviewers required to sign statements disqualifying them-selves when they were assigned work with such a potential for conflict of interest. Subsequent to spring of 1984, the new position of verification inspector was created and qualified per B&W CP-QAP-12.1 and TUGC0 CP-QP-2.2A.
I In interviews with B&R management, the TRT learned that the record review group was made up of former craft personnel and QC inspectors who were transferred tr.o this group when construction work was slow.' This fact l was' confirmed by the B&R organization chart (dated April 15, 1984) of the l "N-5/ Hydro" group, B&R QA management acknowledged that it was a violation, j of 10 CFR Part 50, Appendix B, Criterion X for craf t personnel to inspect their own work, but stated that there were no specific requirements which j prevented inspectors from verifying the contents of records which contained the results of their own inspections. B&R acknowledged that there were I instances in the past where this situation had occurred, but they could j identify no specific instance of this practice. The TRT interviewed the Authorized Nuclear Inspectors (ANIS) who stated that when they found in-l scectors verifying their own work at Unit 1 they returned the packages to B&R for reverification by another person. The TRT attempted to identify instances of this type of potential conflict of interest, but was unable to do so. The TRT reviewed all 66 field weld data card packages trans-mitted by the N-5 group to the permanent plant records vault from November 1, 1983, to March 31, 1994 The TRT could identify no specific instance where the document reviewer was the same person as the QC inspe,ctor, welder, or weld filler metal issuer.
The TR,1 also selected 92 pipe hanger record packages, one from each N-5 .
group,* transmitted to the permanent plant records vault from December 1, 1993, to February 29, 1984 Each package contair.ed one to six weld data cards (the average was three). The TRT could find no instance where the 05/04/85 3 AQ-126
O I
document reviewer was the same individual as the craft pe an or the QC inspector.
- 5. Conclusion and Staff Positions: The TRT concludes that the allegation that QC lacked organization independence from construction could not be substantiated by the reviews and interviews conducted.
i l
Based on interviews with AN!s and with B&R management, who were directly [
! responsible for creating the record review group, the TRT substantiated
, the allegation of the potential for inspectors reviewing records of their own work, although specific examples were not found. The situation was
- created by B&R QA management's interpretation that 10 CFR Pa,rt 50, Appen-
! cii 8, Criterion X was net violated. The TRT cuestions the effectiveness I of a OA program when inspectors are placed in compromising positions in ;
1 which falsification of records could occur.
- 1 i i
i On Deceeter 10, 1984, the results and conclusions of the TRT's assessment of these allegations were presented to the allegers. No new allegations ;
! or concerns were presented at this meeting.
I
- 6. Actions Recuired:
4 :
6
- 7. Potential Violations: Criterion X of 10 CFR 50. Appendix B, reautres l i
that "inspection shall be performed bw individuals other than those who j i' performed the activity being inspect' 2." i l
l Contrary to this requirement, B&R assigned QC inspectors to verify record
. packages containing the results of their own insptctions or work and, l t
therefore, did not provide the required independence of the inspection ;
function. This occurred when craft personnei were assigned to the N-5 f
record verification ef fort (from approximately November 1983 to March 1954).. .
i -
i S. Attachments: None. ,
I i .
! 05/04/S5 4 AC-126 l l
l i
Reference Documents:
- 1. TUGC0 procedures: CP-QP-2.1, Rev. 16.
CP-QP-2.2A, Rev. O.
CP-QA-2.2, Rev. 2. !
CP-QA-2.3, Rev. 4 CP-QP-3.0, Rev. 15. ,
t
- 2. Brown & Root procedures: CP-QAP-2.1, Rev. 11. l CP-QAP-2.1.5, Rev. 6. j CP-QAP-12.1, Rev. 11. ;
CP-QAP-18.1, Rev. 3.
!, 3. . AC-6: A-5 letter,' March 7, 1984; A-1 interview, August 1, 1994, pages 61 through 66; ;
A-3 interview, pages 93 through 100; l A-1 and A-3, statement, undated '
- AQ-126
- A-1 testimony, August 1, 1934, pp. 61 through 66. i l
4 Close-out interview with A-1, A-3, and A-5 Cecember 10, 1984, p. 173. >
i
- 5. 10 CFR 50, Appendix B "QA Criteria for Nuclear Power Plants and Fuel !
Reprocessing Plants."
t
' 1 I
! 9. This statement prepared by: '
J V. Wenczel, TRT Date
! Technical Reviewer [
j Reviewed by: !
H. Livermore, Date !
Group Leader
[
Approved by: (
V. Noonan. Date '
t 4 Project Director E l
i !
i I
- 05/04/85 5 AQ-126 j i i
_ _ _ _ _ __ - J
- 1. Allegation Category: QA/QC 7, QA Implementation
- 2. Allegation Number: AQ-132
- 3. Characterization: It is alleged that Texas Utilities Electric Company (TUEC) QA audits and auditors are not independent of the area being audited and that the audit reports are changed to reflect what management wants them to state.
4 Assessment of Safety Significance: In assessing this allegation, the NRC Technical Review Team (TRT) compared the TUEC cuality assurance (QA) manual, Section 19. "Audits," against the Final Safety Analysis Report (FSAR) com-mitments in Chapter 17 for establishing an audit program for Comanche Peak Steam Electric Station (CPSES). The TRT also reviewed 6 implementing pro-cedures (Reference 1), which werti established to ensure the independence of the TUEC auditors from direct responsibilities in the area being audsted, and 23 TUEC QA audits of CPSES construction activities (Reference 2).
The TRT was able to identify audit TCP-f>6 as the original basis for the allegation. The alleger had referred to a "God Squad" which investigated an audit. The term "Ged Squad" was used to identify a TUEC special review team that was directed to investigate audit TCP-66.
The TRT reviewed the report of the TUEC special review team. The indi-vicuals on the TUEC special review team were frem TUEC engineering and administrative services; :E n were not QA auditors. This special review team was requested by the vice president of nuclear operations to act as an independent third party to investigate rumors of a coverup in QA activities. They were directed to review the TCP-66 audit file and inter-view the personnel involved. The TRT reviewed the special review team's report,"ReportonAllegationsofCover-upandIntimidatienbyTUGC0[ Texas Utt11Mes Generating Co'epany) Dallas Quality Assurance." which evaluated -
the etnduct of ICP-66 and its final published audit report. !ccluded in this report were methods of review, the history of TCP-66, and the results of the review. Based on TUEC's special review team assessment, the report concluded that there was "no evidence to support either an allegation of coverup or intimidation" for changes made to TCP-66 by QA management.
05/06/85 1 AQ-132
4 .
, t
. t
- The TRT reviewed the audit file for audit TCP-66, which was performed by l two TUEC QA auditors from February 7 through March 22, 1983. The audit file contained the final audit report (May 3, 1983), the initial audit !
report (April,1983), which was prepared by the acting team leader, with f
comments by the QA supervisor, and a copy of the acting team leader's dissenting opinion memo (April 29,1983). In the dissenting opinion, the l team leader stated that major revisions made by the QA supervisor resulted !
in a different representation of the findings than that identified by the l audit team.
d l
The TRT reviewed the initial audit report, which contained errors and '
t j redundant and subjective comments. The TCP-66 subject, "Radioactive Waste !
Managetent Systems," was audited using the incorrect requirerents, which (
contributed to the confusien of the audit team and led to the pectly written j
- initial audit report. Although the TCP-66 audit team members were qualt .
fied to existing TUEC procedures (Reference 1), a review of their past j experience (Reference 3) showed that one had only minimal technical experi-
) ence in the activities being audited. Under these circumstances, the TRT !
) fcund that the revisions made by the QA supervisor were justifiable and I appropriate. Rewriting of audit reports by management in cases of disagree-j ment is permitted according to the guidelines defined in TUEC memo QTQ-435, ;
dated September 9, 1983.
The audit TCP-66 team members were unavailable for TRT interview during j the time the TRT was on-site, because both had voluntarily terminated their l 1 employment with TUEC 4 months after the audit. TRT cembers participated :
l in an interview with one of these auditors on November 28, 1984 This
] interview did not alter the TRT's conclusion concerning the revisions to the audit made by the QA supervisor.
]
t i As noted above, the TRT reviewed 23 audits of CPSES construction activities, i j The TR,T,noted that at the time of peak site construction there were only , ,
I l four @ auditors. A further TRT review of personnel records revealed that i
- only one of the four had a bachelor's degree in a technical field. ;
I ;
I i 05/06/85 2 AQ-132 L t
d
~
The job functions of audit team members, other than QA auditors, were reviewed by the TRT to determine their independence from the activities they audited. The results were inconclusive because the extent of participa-tion of the various members, particularly the contributions made by tech-
- nical advisors or observers, was not well-defined; specifically, no pro-cedures defined participation guidelines, nor were guidelines or explana-tions provided in audit files. For example, TUEC audit teams frequently included quality engineering site surveillance personnel. A TUEC QA super-1 visor admitted that site surveillance personnel could be on TUEC QA audits 1 of areas where they had previously performed surveillance.
I j The TRT reviewed TUEC organization charts which indicated that the QA func-
. tien was independent of construction activities. Hewever, TRT interviews I
with TUEC QA management and reviews of audit reports produced no evidence j) of independent managetent audits of the TUEC QA function. Such audits ,
) assessed the site QA program including QA organizational independence from l construction. TUEC QA management has recognized the need to meet require-I ments for independent audits by membership in the Joint Utility Management j Assessment (JUMA), a group established to assess the QA programs of member
]
nuclear pcwer plant owners. TUEC's first JUPA review is scheduled for the
- spring of 1985.
)
- 5. Conclusion and Staff Positions: The TRT substantiated the allegation to j the extent that a QA supervisor had rewritten TUEC audit recert TCP-66.
However, after an in-depth review ot' the report, the TRT concludes that
! the basis for the rewrite was appropriate.
l The TRT finds a weak. ness in the qualifications of the TUEC audit personnel in that they had only minimal technical education and experience. ,
Based on interviews with TUEC QA management and reviews of CA audit, reporp the TRT concludes that no independent management audits of TUEC's ,
j QA prog *am at CPSES were conducted.
I 05/06/S5 3 AQ-132
4 .
o In a meeting with the alleger on December 10, 1984, the TRT presented the I results of the ast.nssment of the allegation and the TRT's conclusion, j No new concerns or allegations were identified.
- 6. Actions Required:
I
- 7. Potential Violations:
Criterion 11 of 10 CFR 50, Appendix 5 stetes: "The applicant shall regularly review the status and adequacy of the quality assurance program."
Contrary to the above, TUEC management has not conducted any regular re-views or audits of the TUEC QA program.
- 8. Attachments; None.
Reference Deeuments:
- 1. Procedures: DQP-CS-4, Rev. 10; CP-QP-19.0, Rev.2; CP-QP-15.7, Rev. 2; DQ1-C5-4.6, Rev. 7; CQP-C5'1, Rev. 1 and Rev. 2; and CP-QP-3.0, Rev. 15,
- 2. TUGC0 QA aucits TCP-1, 2, 3, 4, 6, 17, 23, 24, 34, 39, 40 41, 43, 46, 56, 66, 67, 68, 74, 81, 97, 101, and 111 (inprocess).
- 3. Training records for selected individuals.
4 AQ-132: A-5 interview, August 2, 1984.
- 5. TV,G,CO office mererandsm OTO-435 dated 5eoterber 9. 1983. ,
- 6. A-5 closeout interview, Cecember 10, 1984, pp 173-176 05/06/85 4 A0-132
0
- 7. In camera deposition, Docket No. 50-445/50-446 Exhibit 39-1, dated July 10, 1984.
- 8. TUEC QA Manual and procedure CP-QP-19.0, Rev. 2 "Audits."
- 9. FSAR Chapter 17
- 10. Manuscript of interview with TCP-66 auditor, November 28, 1984.
This statement prepared by:
V. L. Wenczel TRT 3/23/85 Technical Reviewer t
Revie=ec b>: '
~~~
H. Liverecre, Oate Group Leader * ,
Acproved by:
V. Noonan, Date Project Director l
05/06/S5 5 AQ-132
- 1. Allegation Catecory: QA/QC 8 As-Built
- 2. Allegation Nutber: AQ-50
- 3. Characterization: It is alleged that the "As-Built" inspection program i ITsed by Texas Utilities Electric Company (TVEC) to address Inspection and Enforcement Bulletin (IEB) 79-14 for pipe supports was too narrow in scope, i.e., restricted to a limited number of systems and types of attributes only; and that as a result, dimensional discrepancies might exist between 6 the field condition and final "as-built" drawings and those discrepancies would be overlooked. .
r
- 4. Assessment of Safety 5tenificance:
- s. :E9 ~9-14 proces-Tne primary purpose of IEB 79-14 was to ensure that sne as-built pipe anc su::ert configurasien was used by TUEC in its final seismic stress analysis of critical piping systems. IEB 79-14 also identified the critical systems
.nith must be censidered in the seismic stress analysis. "The(Inspection anc Enforcetent) staf f has determined. .here cesign specifications and drawings are used to obtain input infermation fo seismic analysis of safety related piping systems, that it is essertial for these documents to reflect as-built c:rfigurations." (Raf. IEE 79-14, Rev. 1). ints entails verifying support type, location, direction, clearances, and argularity. l TUEC engineering precedure CP-EI-4.5-1 defires *e pregeam for develeping l ard using the information needed to cceply with IEB 791*. This program r
.as to be imple*ented in adcition to the moreal CA/CC process, althcugh t*e p imary responsibility for assuring overall mareware co-p11ance with r estac14sned peccecures arc drawings cerained a C2 4C furetion.
TLEC precedure CP-El-4.5-1 listed pertinent cocu ents cescribtng the ;
as-built configuration of the piping and support systems, such as Brown &
Root (EAR) piping isometrics. B&R hanger drawings, and B&R hanger location :
drawings. It defined field checks which must be .?ade to verify pipe support location, direction, support type, and clearances. It also p*ovided instructions for int,egrating this as-built information' into the final seismic stress analysis of the piping systems. This program was .
i9itiated in April 1981. ;
since the subject matter of IEB 79-14 was lie tee in score, the pr:; r
- t. TUIC to acJi eis 1EE 70-14 appeared to tu a'.'e;* . .% =a s a CC 1rst e:- -
tor. }o be too narro. in scope. TbEC's pre;rn, a ac: ess !EE 71-1 o revie ed by the NRC Technical Review Team (TR!) .as of sufficient secte to meet the intent of the NRC bulletin.
The TRT iate viewed the alleger by telec'eae cc Agust 21 are 23, 1934 anc in persen :n A gust 25. 1934 Tne a11eger, a ferter CC inspect:r. as
Q on one of the Unit 1 as-built teams and had seven areas of concern with the IEB 79-14 program. Each area of con:ern is Itsted below, with the TRT assessment following each concern:
(1) Alleger's concern: Hanger location was acco.?plished by craftsmen and field engineers, without QC involvement.
TRT finding: The use of engineering drawings by craft personnel and field engineers to determine the field location of pipe supports is standard construction practice. QC inspects the location during installation inspe: tion; the location then is rechecked in the
!EB 79-14 program.
(2) A11eger's cencern: No hanger dimensional checks were made during ,
the verification inspection. .
TRT fiading: Besides the attributes listed in TUEC procedure CP-E!-4.5-1. as certiene: atove ether detailed dimensional checks e , :t :a t of the s:::e o' IES 79-14 B&R oro:ecure.QI-QAP-11.1-25 r
'Ssis t*e :etaila: cre:S cf attatoutes =nien shoulc be part of tne installation inspe: tion ey QC 'er pice supports. If, as alleged, ma*y ciscre:ancies were nctec early in the as-built program, the
, CC installation ins:ection ge:vp should have been notified and then
- should have taken ap;r:priate corrective and preventive a: tion. [
(3a) Alleger's cencern: Tne writing of een:enfer ance reports (NCRs) was dis::uraged.
- TRT finding
- This allegattom was assessed in AQ-37 and AQ-80 of QA/QC Cate;:ry 50, anc was not s.:stantiated. *
( 30) A11eger's con:een: Ceficie*: des se:h as 10:se belts or bad welds were not reported.
IR' f'r-irg* Icentifyiry t*tse t);es of ce#iciencies was not the .
90'f 31 pu'Cose cf the IEE 79*}a prograt; PC= eve', these types 0 # i Ce#'Oie*:ies, when cete:te0 SnCalC have betn re;Crted to the ins *a'*
i lation QC ins;ector, amen the QC inspector was notifieo of any ,
ceficiencies, NCR$ should have been processed by the QC inspector as appropriate. No spe:ific cetails were pr:vided by the alleger; hc ever, an independent inspection by the TRT, using QC installation inspection criteria, is dis:vssed in secticn 4.9 of this assessment (AQ-50).
1 (4) Alieger's concern: Orientation cf nuterous sway struts, as insta11ec, esceeded the angular tolerance.
- 5*
. f'edirj. ?6d; h ilv;at': e 4,*ra',e: t#:4wte *.*tre meet vaat .5 . !
gn;.larity toleran:e. a:::i . e t' s.e, strws; and am.:cers orio* ts a;ril 11, 1954 Post it;ortant was the overall installation and inspection tolerance on angularity of plus or minus 5 degrees, with the exce: tion that cesc *vight su: ports east be within plus or minus 2 cegrees. HCnever the IEB 79-14 program required all angles over 22 degrees to be Peasured aa: reported. Of five su:ccris in the 2
l i !
ICB 79-14 program that the TRT field reviewed, there were no instances of sway strut or snubber angularity exceeding the allowable installa-tien tolerance. Also, the TRT reviewed documentation for 37 hanger reverification packages for the IEB 79-14 program and found none indicating any support exceeding the allowable installation tolerance for angularity.
(S) A11eger's concern: None of the personnel involved in the IEB 79 14 program had hanger inspection experience. ,
TRT finding: The alleger had a misconception of the purpose of the IEB 79-14 program. With the exception of the alleger, the as-built
. crew consisted cf degreed civil engineers. The primary task in the IEB 79-14 program was checking for support type as well as measurement of lecation, direction, clearances, and angularity. The IEB 79-14 inspection work did not resemble QC installation inspection and was not a part of that progra9.
(6) Allege *'s ::n:e*9: T%e e was ec en;1reering review cf the inspection cata.
TRT finding: TRT investigators found that, of the cocuments looked at by the TRT, the engineering review for the IEB 79-la program was .
pr: :t, c: :etent, and ell-de:veented.
(7) A11eger's cencern: Boundaries of the ins": tion were not defined.
TRT finding: Texas Utilities Generating C :ary (TUGCO) engineering pro:e:ure CP-E!-4.5-1, "General program for As-cuilt Piping verifica-tion," provided sufficient definition of the inspection package and instru:tiens for what attributes were to te che:ked within the IES 79-14 program.
Ea:$ of TUEC's as-built reverification tea-s consisted of a party chief, an instrument can, a red man, and a CC insee: tor. Tne alleger maintaine:
a legbeek bet een January ard May 1983, .* ten listed tee identificatien nw-ters of the as-built reverification receres (a!RRS). ABRR5 we e use:
in the IEE 79-14 program to reverify the as-evilt condition of mecifte:
pipe hangers. The alleger identified 97 AERRs as unsatisfactory, 93 of which descrioed hangers with excessive sway strut angularity. The alleger's legtook identified "stress prcblem nutters" for 37 of the 97 unsettsfactory ABRRs. This information alle ed the TRT to identify the corresponding hanger numbers easily.
In assessing the situatien regarding unsatisf act.:ry AERRs, the TRT revie ec tne cispcsition of Ji out of the 97 ABRRs identified by the alleger. In ea:A case, tPe s Ntter ce s.ay strut, angularity was rote: as more than
. dwse i t, A . 6 =vr e ac:utented to r ate e s:ted&d tP6 $* eg*te 1 M t. .
F; w r
're IR,T als: c a;1etely field inspe:tec 5 Of these 37 pile swpports.
of the t' angers were chosen by the TRT f rom the list of 93 AERRs indi:ated by the alleger as having excessive sway st, rut angularity. One aeditional sucport was selected by the TRT from the balance of su: ports listed by the alleger as hawir; deficiencies other than excessive angularity.
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i One of the purposes of the IEB 79-14 program was to identify those sway struts or snubbers whose as-built angularity deviated from specified angu- l 1arity by more than 22 degrass in order for engineering to review total displacement of the sucport during hot loads. Angular deviations greater than 2 degrees were identified on AERRs for reverification. Review by ;
engineering consisted pritarily of adding the angular displacement due to !
thermal growth of the pipe to the as-built angularity. This was ne:essary I to determine whether the movement exceeded 25 degrees during het or cold system conditions. The main reason for this part of the review was to pro-vide confidence that a misaligned snubber or sway strut would not bind urcer hot or cold conditions.
The TRT selected 5 AERRs from the grou: of 31 described above and per-for-ed a complete field reinspection of W corresponding individual pipe supports. These five supports were ASME !!t, NF, Class 2 and 3. Four of these ABRRs had documented snubber or sway .trut angularity that deviated m:ri than 2 degrees from the angularity specified by CP-EI-4.5-1. In none of these cases did the deviation ex:eed : 5 degrees offset, which was the ali:wable limit for sev:te* cr stru' misalign ent in a system's celd or n:t settirg. B&R prece:w e e Cl-CAO-II.1-23A, Revision 4, Earagraph 5.74. .
"!ns:ection Criteria for $nw::ers," $$4tes that "to prevent binding within tee clamp and/or bra:Let, s%::er shall not te installed with an offset of rore than 5 degrees." The TRT eessured this angularity and in ea:h -
case confirred the angularity docu ented on the ABRR, The TRT reviewed 4: lica 1e CC ins:e:tien pre:ecares in effect at the tire of the ABRR ,
field work and learred that strut and snubber ar;ularity which did net ceviate ecre than : 5 ce;*ees was a:ceptable. (;eferen:e BAR proceduce O!-CAP-11.1-23 Section 6.3.1.1.d Revisions 16 inrou;b 23, issue: between Ce:e-ter 15, 1932 anc Oct:ter 24,1933.) The five inspe:ted su:perts did ,
not violate this QC ins ection criterion for aegalarity. All other hard- t
.are attributes were inspe:ted by the TRT and tre documentation was revie.e: by the TRT for these 5 su:corts. These att ':.tss .ere those
+enti:ned on the CC che:kli:t in B&R procedure Q!-CAP 11.1 25, as well as in a0011:able codes or stamdards not covered by the procedure. Cre suca
- t as founc ey sne TAT to have t : nar: are ceficiencies, while anetter m . *ac eme ciscrepaa:y. Tne reut ti ef tM s 'iele insee:tien are l
.. ate: in Se: tic- 4.E cf this assessment (1;-50).
B. A: itieral Piee $weeert inspection t Since the scope of IEB 79-14 was limited to only these attributes needed I pr! arily for input to the seismic stress analysis, the TRT conducted a -
field review of CC-accepted, as-built hardware in Unit 1. This inspec- i tion sample was used as a measure of the effectiveness of the eite CA/CC !
program for work cerformec prior to the initiation of the TRT effert.
l Effectiveness of the site CA/CC program tneant ensuring that hard.are in the .
field was reflecte: ac: pately on the as-built cra ings are that ciscree-aa:ies.=ere detected. re::*te:. aa: ::rre:ted Le* apolicable e:wi e ent: .
The T(T selected 42 pipe s'pports (ASME !!!, NF, Classes 1, 2, anc 3) for cetplete field inspection in 10 plant systems throughout 4 safety related l buildings (safeguards, fuel handling, availiary, and containment) in Unit 1.
All of the 42 supports had teen previously acce:ted by site OC, are their ;
ins;e: tion packages had been placed in the QA receres vavit. For the *:st l i
4 I
i a
o part, these finished systems were in areas that had been cleaned, locked, and ready for fuel load. Thirty-saven pipe supports were selected by the TRT, and 5 additional supports were chosen from those considered in the i IES 79 14 assessment discussed above. Twenty of the 37 supports were selected by the TRT frem the safeguards building rather than other build-ings because of a general trend noted by TRT managee.ent that the safeguards building had been a problem area in the past.
All TRT-inspected pipe systerts were from safety-related piping systems such as safety injection ($I). component cooling (CC), containment spray (CT), residual heat removal (RH), auxiliary feed ater ( AF), main steam (MS), chee.ical volume and control (CS), and reactor coolant (RC).
Ouring its inspection of the 42 component supports, the TRT found a number of hard are discrepancies (see Tables 1, 2, and Figure 1) which warrant
- fr ther consideration of the ef fectiveness of the site QA/QC inspection pregram in dete
- ting, reporting, and correcting deficiencies on hard= ace as installed. $;ecift: details of ceficien:ies fosnd ey the TRT QAiQC Gr:s: an: 40emti'ie: recein are liste in Sectfen 4 o# the NEC letter frcm D. G. EisenP. or JaNary i, liii, to M. 2. 5:ence ed Tetas Ut'11 ties Generating C: ;any. (See Atta: Ment 3),
4 Cver three c.arters of the suppoets in the sampling grove received 10C*.
visual ins:e:tien by the TET of welcs with the paint rem:ved. The balance of the 42 scr? orts were irs;ected with the paint left on tre welds for j eany reas as, cne being be:4vse paint removal in :ertain locati,ns of the sy; ports movic have been cif ficult cse to their inaccessibility.
The TRT findin;s ef weld dis entinuities were 56:aitted to TUG 00 opera' tie-s anc the QA *aaagees. Ten rejectable wel:s ictatified by the TRT
{ nee:ec repair or re= ora; ard one cet:enent sus; ort was coepletely removst aa: *as since teen retvilt by TUEC. The deft:1ea:ies ir:luded unceasi:e welds. = eld undercuts, escessive grinding resulting in red'.,: tion of the tage material, and coOr weld aCDearanCe. One su;ctet had melds Cerfor?ed f with no Q ins 0ector sigratyre or initials on t*e 00rres;o* ding ble:ks of j the weld :sta
- arc fo' tPat su cop
- inspe:tio* Ca;kage.
l i In t.: cases, tre TRT feur: that t*e manufacture *'s eccel n.*:e n on sne*A l arrester co'a;onents were not the same as t.he MC el n4"be's shone On the as*DWilt drawings for the same asseetlies, i C. potentially Gereric Pipe $geport Ceficiencies In the CowPse Cf instecting the 42 pipe suDports, t*e TRT fo6PC potentially Ceneri Ceficiencies that included insufficient bolt thread ePjage'ent, 40sence of proDer locking devices for threa:ed f asteners and Icac pins.
ard es:essise f ree gao at the s: Fees:al bea ing ' ate #sce in saubrees ae:'
s.a t%t s . As s,re.i a sly notec, tre 40 ;ie, a.;;:-ti c'::Trasse: A D'E .
S e: i qa lI:, N' Class 1, 2, and 3 Ccce jsris:t:tions a-c were 1 crate: m i t t i r.
the centairment, fuel, switliary, an: safeguares buildings of Unit 1. In addition to the deficiencies noted in the 42 pipe supperts, the TRT feund so e ceficiencies while going from one area of Uait. I to another durieg ins:e* tion.
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Table 1 Pipe Supports in Unit 1 Supports Inspected by TRT As-Built group '42 Class 1 supports inspected 4 Class 2 supports inspected. 14 Class 3 supports inspected 24 Hangers with problems **26 Total problems identified 46 Procedure adequacy problams $
Hardware-related problem: 16 As-built drawing related problems 8 Ceeponent identification prcblems 2 Weld related problems 10 QC record problems 1 Material identification problems 4 Welds inspected withou'. paint by TRT 305 Welds ins;ected with paint ey TRT 39 ,
Tetal welds ins:ectec ey TRT 394
! heics neecing =e c repair '10
(*. of '= elds ins ected) 2.5%
Supports involving weld repair 6 (4 of su; ports inspected) 14% ,
l l
No. of Supports Eld 2 $1stem Inspected Containment Safety injection (51) 1 Contain? tnt Reactor Coolant (RC) 6 Centaintent Residual Heat Re.? oval (RHR) 2 Fuel Handling Component Cooling (CC) 11 Safe;uards Residusl Heat Retoval (RNR) 1 Safeguards Containrent Spray (CT) 8 Safecua es Dominera11ted Watea (CD) 1 Safeguares au xiliary Feec.ater ( AF) i Aue111ary Cnemical Voluee & Cont *c1 (CS) 1 Safeguards Main 5 team (M5) 2 Safeguards Chilled Water (CH) 1
'All142 pipe supports inspected by the TRT had been previously accepted by site CC. .
- 5pecific details of geficiencies found by the TRT are listed in Section 4 of the NRC letter from D. G. Eisenhus on January B 1955, to M. D. Spence of Temas Uti1tt1*n Geeuratin; Company.
(See Attacorent .L) ,
. . - _ _ . - - _ . ~ . ~ . . - - _ - - . . _ -
- _ . - ~ . - - -. - - - - _-. - - . - _ _ _ . . -
i J
iable 2 Pipe Supports in Unit la
~ No. of Problem Ca'. p --r h oger No. Problems Type a
- 1. No lockfrq device for threaded fasteners RC-1-901-702-C825 2 h rdware problem j (see F!gure 1) CS-1-085-003-A42K i
- 2. Min.*edjedistance(onbaseplate) violated CC-X-039-006-F43k I b rdware problem
- 3. Base plate hole-location dimensions aut of tolesance CC-X-039-007-F43R 4 As-built probles CC-1-126-010-F33R CC-1-126-011-F33R CC-1-126-012-F33R
- 4. Spherical bearing / washer gap e cessive CC-1-126-015-F43R 4 h rdware prob.
RC-1-352-015-041K i
- l RC-1-052-020-C41K MS-1-416-001-533R
! t
{ 5. Spherical tearing contamination (see Figure 1) SI-1-090-006-C41K 2 hrthsare prob.
4 1 MS-I-416-002-533R '
) 6. Soubber adapter plate-insufficient thread engagement Ms-1-416-002-5332 3 Proced. prob.
i (See Figure 1) 51-1-090-006-C41K CT-1-013-012-532K '
a
- 7. Insufficient thread engagement, threaded rod RC 301-702-C825 1 h rdware prob.
(sight holes, see Figure 1)
- 8. Snubber / Strut load pin locking Cevice broken or AF-1-001-014-533R 1 k rdware prob.
missing (see Figure 1) ,
i
- 9. Load side of pipe ci g halves not parallet AF-1-001-001-533R 2 Proced. prob. t (see Figure 1) AF-1-001-014-533R 1
- 10. Pipe clearances.ts/suptet oest of tc!erance CC-1-126-013-F33R 2 h rdware prob.
AF-1-001-702-533E!
- 11. Pipe clamp locknut loose (see Figp*- 1) AF-1-035-011-533R 1 Mardware prob.
i i
- 12. Seribber/Sesay strut af saligne nt CC-1-126-014-F#.3R 2 hrahsere problem AC-1-052-020-C41E l
i
- All 42 pipe ' se ts inspected by TRT had been previously accepted by site QC.
l
Table 2 (Continued) -
No. of Problem Category Hanger No. Problems Type
- 13. Snubber cold set dimension does not match drawing CS-1-085-003-A42K 1 As-Built prob.
- 14. Snubber
- orientation does not match drawing CT-1-005-004-522K 2 As-Built prob.
CT-1-013-010-522K
- 15. Component type /model no. installed does no match SI-1-090-006-C41K 2 Compon. ID prob.
drawing RC-1-052-020-C41K
- 16. No identification for support materials, parts, and CT-1-013-014-532R 4 Matl. identific.
components CC-1-126-012-F33R prob.
CC-X-039-005-F43R AF-1-035-011-533R
- 17. BRP column line dimension does not match BRHL Support not affected 1 As-Built prob.
dimension ^
- 18. Weld porosity excessive AF-1-001-0G1-533R 1 Weld-related prob.
m
- 19. Weld undercut excessive AF-1-001-702-533R 1 Weld-related prob.
- 20. Weld length undersized AF-1-001-0G1-533R 1 Weld-related prob.
- 21. Weld leg or effective throat undersized AF-1-001-001-533R - 3 Weld-related prob.
RH-1-006-012-C42R CC-X-039-007-F43R
- 22. Weld called out on drawing does not exist in field CC-1-126-013-F33R 1 Weld-related prob.
- 23. Welds added in field are not reflected on drawing AF-1-001-7,02-533R 1 Weld-related prob.
numerous welds -
. 24. Excessive grinding resulting in min. thickness AF-1-037-002-S33R 2 Weld-related prob.
violations (weld clean-up) CT-1-013-014-532R
_1_
46 Total problems identified by TRT
O I
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9 l
Figure 1 Hardware Examples 9
9 Figure 1. Fardware Exampfes I
Lood Bolt, One Nut Only, "'
- No Lock Nut , _ _
h h s
\ oodL Pin j
~i[#'. Spring j With Cotter
' Pin Locking
~ c~
,- ~'
Con ::
Threod :: Device 1,::~ Sight -
y +e s s.2] L,i t
Sway Strut C
.s b
Snubber Thr ee-Bolt Adopter Plote 4_ ,-J) P'pe Cicmp Topped Hole k )
Extension Kit gn, Not Topped Pipe I Cicmp H
. One Nut only, No Lock Nut j
tE Spherical "Decrbg ;;)
(@ q{ \$' Muununu w
Snubber Extension Kit
f The six potentially deficient conditions that required further evaluation for generic implications were as follows:
(1) Strut and snubber load pin spherical bearing clearance with washers was excessive. B&R procedure QI-QAP-11.1-28, Sec. 3.7.3.1, Rev. 25 definec bearing gap as the space between ttie outside surface of the bearing race and the inside surface of the clevis bracket and may not be more than one thickness of the vendor-supplied spacer washer to prevent bearings from dislodging from their seats. Bearing dislodge-ment could cause 59ubber or strut misaligneent and change its moment range, or angle of loading, thus degrading the snubber's or strut's loading r.apacity.
(2) Strut and snubber load ein locking devices (cotter pins or snap-lock rings) were missing. QI-QAP-11.1-28 does not address load pin lock-ing devices. This appears to be an inadequate procedure.
(3) Dice clame halves on the lead side were not parallel.
(Ref C*-CA -11.1-23. Sec. 3.7.3.1. Rev. 25.) -
( 4 )- Tnreac engagement of colts into tapped noles of snubber adapter plate was less than full. (Ref. ASME Sec. I!!, NF 4711.)
(5) "Hilti Kwik" bolts (ccacrete expansion anchors) as installed did not meet mininum effective etcedment criteria. (Ref Q!-QP-11.2-1, Sec.
3.5.1, Rev. 16.)
($) Locking devices for threaced fasteners were missing or of 3 non-approved type. (Ref. ASME Sec. III, NF4725.)
In order to further evaluate the potentially gereric occurrence of these ty:es of deficiencies, the TRT undertook additio9al inspections (see Table 3). A large number of supports within a designated area were in-soected fer these soecific deficiencies. The:e areas were different from
- h0se previcusly selected f 0r TRI insDection cf ci e su0po'ts. 50me of tae accessiele riot succorts in Roco 77N. at the il3-fcot. 6-inch eleva-t'ca :f tre Urit I safeguards building were fes:ectec by the TRT for c6-ficiencies icentifiec as items (1), (2). (3), arc (4) aeove. Room 77N was chosen because it was a typical room containing an ample number of pioe 56pports.
Ninety-two sway struts and snubbers in Room 77N were checked by the TRT in Room 77N for spherical bearing clearance and for missing locking devices on lead pins. The TRT inscected 40 of tne same 92 sway struts and snuebers in the same room in the safeguards building for pipe clamp halves that were not parallel. In addition, 19 snubbers cut of the same 92 supports were tsaM ned da t *.e aoove- entiee:' -n- 4r ada:te* ris*.e belt s on snubber t.dv V.P ! f . ' ; o Li's . tat ed attec %s:
. .sa- . t
- r + 1:: enga;etent. .
To ass *ess the frecuency of o:currence of item (5), the TRT inspected "Hilti" bolts on electrical support baseplates located in the cable spread room 133, at the 807-foot elevation of the Unit 1 Auiiliary Building. These 24 "Hilti Kwik" bolts (concrete exoansion ancnces) were chosen because of an obviously large am unt of exoosed threads thr.: were visible. The
iu e g
, j Table 3 Summary of Frequently Occurring Hardware Deficiencies i
Area: Room 77N, El 810'-6" Unit 1, Safeguards Bldg No. of Supports No. of Supports Deficiency Inspected Deficient % Deficient Item 1. Excessive 92 5 5.4%
Spherical Bearing Clearance Item 2. Lead Pin Locking 92 14 15.2%
Device Missing Item 3. Pipe Clamp Halves 40 9 22.5%
Not Parallel Iten 4 Snuteer Adaeter 19 *13 to be Fiate 3o1:5 Witn ceterminea Less than Full Thread Engagement item 5. Hilti Kwik Bolt 24 (Bolts 3 (Bolts 12. 5%* * "
Does Not Meet inspected) deficient)
Minimum Embedmant**
Item 6. Locking Devices For (See Text)
Threaded Fasteners
- Bolts had less than full thread engsgement.
- Area: Cable Scread Room 133, El 807'-0", Unit 1, Auxiliary Bldg.
- The sample of 24 Hilti Kwik bolts was chosen by the TRT because the bolts had an obvicusly large amount cf exposed threads that were visible.
4 e
4 9
e 1 -
1
procedures for installation of the "Hilti Kwik" bolts on baseplates of electrical conduit supports and cable tray supports were the same as those procedures governing installation of expansion anchors on baseplates for pipe supports, i
The inspection criteria for items (1), (2), and (3) were based on B&R pro-cedure QI-QAP-11.1-28. The inspection criteria used by the TRT for item (4) regarding thread engagement of bolts on snubber adapter plates were based on full thread engagement. Those bolts lacking full engagement through the adapter plate were cited, even though procedure QI-QAP-11.1-20, Attachment 29, allowed less than full engagement. For example, Attach-ment 29 showed a minimum thread engagement of 3/16 inch for snubber sizes 1/4 to 1/2 inch; for snubber si:es 1 inch through 3 inches, the minimum thread engagement is 5/16 inch. In all cases, the thickness of flanges and lengths of tapped threads in respective adapter kit flanges were ignored in Attachment 29. B&R procedure QI-QAp-11.1-28A, "Installation Inspections of ASME Class 1, 2, and 3 Snubbers," Attacheent 10, also showed the same minimu bolting engagement allowances. The TRT concern is that ,
the Droc60ure wal inconsistent with A$ME Section III. Subsection NE A711; anc the concition for tareaa engagement snoul:: have been certified as acceptacle by the manufacturer. It appears that the QC Engineer approved an inadequate procedui2 for ieplementation in the field.
Subsection NF-4711 relates to thread engagement in nuts, requiring that "the threads of all bolts or studs shall be engaged for the full length of thread in the nut." The same reasoning would also imply that there be a full length of a threaded hole in plates, sha es, or bars where the required threaded hole length is the same as tne bolt diameter. No evi-dence has been proviced to the TRT that partial thread engagem.ent at the snuober adapter plate connection has been given consideration in the design [
procedures for linear-type supports, nor does it appear that sufficient design margins have been introduced to allow for 12:2 than fdl-threaded connection. The TRT did not check "as-built" analyses to cetermine whether any such variations from full thread engagement had in fact been considered in tne "as-coilt" stress calculations. What is in question is whether any is':;1at' ens had beer made to e evide the cases 'c the cri t eria ir Attaen-
., e tioned above, fcr each si:e snu::ber being used in the plant.
Th; inspec*. ion criteria for item (5) regarding "Hilti" installations was based on B&R construction procedure CEl-20, "Installation of Hilti Drilled-In-Bolts," and TUEC quality procedure QI-QP-11.2-1, "Concrete Anchor Bolt Installations." "Hilti Kwik" bolts were checked for minimum embedment.
Two f actors were considered in figuring the "ef fective" embedment for each concrete expansion anchor:
(1) B&R preced.re CEI- 3 for "Hilti Kwil" bolt installation (Ref. Rev. 3, Cara 3.1.4.;) alis ed minimum etbecment as sho n on the desig- draw- -
ing or as specified by the "Hilti" catalo;, minus one nut thickness to account for slippage due to torquing.
(2) The 2-inch topping slab on the floor of the cable-spreading room can-not be included as structural embedeent for the concrete expansion anchor ("Hilti Kwik" bolt). Embedment length is the length of the 12
f bolt extending below the surface of the 4,000 psi (28-day strength) structural concrete, as defined in B&R instruction CEI-20, Rev. 9, paragraph 2.4.5.
Item (6), absence of proper and sufficient locking devices for threaded fasteners is discussed in Section 4.7 of this assessment f\Q-50). Also s6 ) Category 1 of Table 2 in this assessment for two examples of supports without proper locking devices on threaded fasteners.
D. Class IE Electrical Cable Tray and Conduit Supports The TRT expanded the inspection of component supports ard ha'.gers to in- ,
clude a number of Class 1E electrical cable tray and conduit supports.
Five hangers and supports in this category received 100% inspection by the TRT. Two other supports were inspected for. weld size and bolt torque verification only. The electrical supports inspected by the TRT for Unit I were in the cable-spreading room, auxiliary building, and conteirment building.
I 4
~
ne TRT inspected elect ical condui; supports anc caole tray hangers to tne requirements of precedures 01-QP-11.10-1, "Inspection of Seismic Elec-trical Support and Restraint Systems"; QI-QP-11.21-1, "Requirements of Visual Weld Inspection"; and other applicable instructions for conduit .
support and cable tray hanger inspections. All electrical supports included in TRT inspections had been previously inspected and accepted by QC, Table 4 summarizes the results of these QA/QC group inspections.
Five of the seven electrical hangers and supports inspected by the TRT ex-hibited a variety of discrepancies. Although no unsatisf actory open itets remained in the inspection records of B&R, a high percentage of inspectable characteristics failed on TRT inspection. The principal types of unaccept-able conditions concerned welding. Most of the inspected hanger and support welds were undersized. Some welds were made in the wrong location on a supoort, while one hanger had a substantial number of welds which were not shewn on the installation hanger drawing nor inecep: rated on the as-built crawing.
Other defects were founc in the installation, such as anchor bolts exces-sively skewed; minimum bolt-hcle edge-distance violations; unmarked "Hilti" bolts; undersized nuts; missing washers; and frame clip (stif fener plate) sizes different from the dimensions given on the drawing. The TRT inspec- :
tiens of electrical cable tray hangers and conduit supports were performed t in the presence of B&R OC inspectors, who witnessed and cuncurred with these TRT inspection findings.
E. ;aspection of Instrument Tubing Supports The TE! inspected Class 1 nuclear safetv-relats: 'N trumer.t t. tin 3 sup:3rts .
as part of the overall TRT QA/QC as-built inspe:.i:n effort. Three Class 1 supports were selected which were located in the Unit 1 Containment Building.
These supports were on instrument tubing emanating from ASME Class 1 reac-ter coolant lines.
12 ;
l
o Table 4 Summary of Electrical Conduit and Raceway Support Inspection - Unit 1 Support welds inspected 59 Supports inspected 5*
Supports with problems 3*** (60%)
Types of problems Hardware-related, other than welding 6 Unauthorized configuration change 1 Weld-related types of problems (categories) 2 W' elds requiring rework 41 Welds made in field but not recorded on drawing 80**
Beam stiffeners added but r.ot recorded on drawing 40 Buildinc/ Area Supports ,
able 50 ead R:em CTH1$646
. C 130-21-250-3 t C 120-21-194-3 ,
Auxiliary Building CTH 6742 Centainment Building CTH 5824
- All electrical supports inspected by the TRT had been previously inspected !
anc ac:epted by CC.
- Full visual inspection was not performed by the TRT on these extra welds.
- Specific cetails of deficiencies founo by the TRT are listed in Section 4 of the NRC letter from D. G. Eisenhut on January 8, 1935, to M. D. Spence of Texas Utilities Generating Company. (See Attachment 3).
l I !
t I e I 14
9 Hardware attributes such as location, support type, configuration, dimen-sions, and welding were checked for compliance with applicable standards, drawings, procedures, and other pertinent documents. In addition, the TRT reviewed record documentation for the supports which consisted of drawings and their applicable change addenda, construction operation travelers, weld filler material logs, and inspection reports. The results of the TRT hardware inscection of instrument tubing supports revealed no discrepancies. !
l One tubing support exhibited a small dent that was not considered significant.
- F. Other Conditions Observed :
The following conditions w .'e observed during the foregoing reviews.
Material Traceability The TRT examined 33 component support packages to determine whether mate-4 rial traceability existed from marked and identified material through the various recorcs to the Certifiec Material Test Report (CMTR) or a Certifi-cate of Cor'o maace (C of C). The TRT found that th cu;h various legs and
, recorcs an auci trail coulo oe estaclisneo satisfact:rtly to tne material sou'rce and certification, as long as the material was ceperly identified, i .e. , the material neat lot or control number was stamped or etched on the part. The TRT found four supports not identifiable because the identifi , '
cation number was either not stamced or etched 01 the installed material or was not entered in the material identification log (Ref. 10 CFR 50 App. B, ;
Criterion VIII and B&R procecure QI-QAP-11.1-28, Rev. 19, Sect. 3.1.2). t Locking Devices 1
- The TRT also investigated the omission of lockirg features for NF support l 2 threaded fasteners. ASME Section !!!, Subsecticn NF, Subarticle NF-4725 states in part that "all threaded fasteners shall be provided with locking devices to prevent loosening during service." ;
, N ncompliance with this requirement was rec 0gni:ed by TUEC and B&R CC who ;
issuec a "Re:uest for Information and Clarificatter" (4:IC) to TUGCC !
engineering in April 1984, recuesting direction f or resolutien Of tnis '
issue. On May 24, 1984, TUGC0 engineering advised by memorandun '
(CPpA 38997) that He paint which was applied to Unit 1 component supports, I including fasteners, when set or hardened, would act on bolt and nut threads to prevent the nut from loosening. TUGC0 engineering had performed a series ,
of torque tests to substantiate their position. Samples coated with a !
multi-process epoxy formula were chosen by TUGC0 on the basis of sizes and ;
included in the test. .
I 4
SSER 10, Piping and Mechanical (p. N-150 and N-151) also discusses require-4 ments for threaded fastener locking features. Hoever, tne sub.iect (SRT 9) :
perta'.ns to Poe whio restrauts which are net ithin ASME Se:t'sn III Coce .
I ju*is(iction and, therefore. are not governed by Subsectico NF criteria.
TUEC had a potentially inadequate quality assurance specification No. 2323- i AS-31(Q), which did not cover inspection of painted threnced fasteners.
l t Further 2323-AS-31(Q) was invoked for thread lock purposes only with .
issuance of DCA 18,853, Rev. 2, received by Occument Control on August 14
- 'i J
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1984. The paint was applied to ASME code-controlled, NF hardware per specification 2323-AS-30 (non-Q) which required no inspection. This issue appears to be generic for Unit 1.
There was a difference in locking devices on threaded fasteners for similar ASME pipe support hardware made by two separate vendors. In some cases, Nuclear Power Service Incorporated (NPSI) specified only one nut and no locking device; but ITT-Grinnell required two nuts in those same applica-tions. If the design of NPSI models should be found to need the locknuts or their equivalent, there could be hundreds of pipe supports installed without adequate locking devices.
The TRT has several concerns regarding the utility and reliability of coat-ing used as a locking device for threaded fasteners:
(1) The TRT could not locate any NCRs, ASME/ANI notification, or docu-mentation to NRC describing absence of approved locking devices for component supports installed and inspected in 1983 and, earlier.
( !), If an NCR woulc have been written, the apolicable procecure (Ref.
, TUGC0 CP-QP-16.0, "Nonconformances") required that the NCR receive an enginee'ing disposition. The TRT has the following specific concerns about TUGCO's engineering justification for use of paint on NF fastener threads in lieu of approved locking devices:
(a) Paint-coated threads were tested in the weld shop under normal environment and ambient temperature. Useful life or holding capability under anticipated service conditions, including design-basis temperatures and radiation aging, was not adcressed.
(b) The type of coating which was torque tested was not identified in TUGCO's cocumentation of the "Multi-process Epoxy Formula Torque Test," attachment to TUGC0 CPpA 39209, office memorandum.
The unanswered questien is whether the coating tested was CZ 11/P 305 (Carbo-:ine 11, prime, and phenoline 305, top-coat) or C193/P305 (carcoifre 193, epexy orimer, and phenoline 3CS, ::o coat); and whether torcue test conclusions for one coating would ce tne see for tne otner coating formula. Botn coatings were used on threaded f asteners in Unit 1.
(3) There was no avidence that an effective plan had been initiated to provide for routine maintenance activities in order to ensure that all painted f astener threads on NF supports maintain suf fi.cient thread-lock reliability for the life of the plant, or until the paint lock method is replaced by a different procedure.
(4) Deposit of paint on threaded f asterers for safety-class corroonent i sopport s tr,a y te in contracietier, with inspection attributas provide-
- in Attachment 2 of Q!-04-11.1-21, i.e., all threads are to be free i of extraneous material.
I
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Excessive Radial Weld Shrinkage During inspection of pipe supports under the TRT hardware inspection pro-gram, radial weld shrinkage was noted on nearby stainless steel piping welds. One very obvious weld in particular exhibited considerable weld shrinkage. The exhibited radial weld shrinkage was excessive and poten-tially resulted from improper fit-up of the weld joint.
The examined weld was in a 12-inch diameter SI line located in a Unit 1 pipe tunnel designated as Room 850. The line number was 12"-SI-1-031-151R-2 and the weld number was FW 98 as detailed on piping isometric BRp SI-1-YD-03-1.
This line was an ASME code Class II line and was NA-stamped at the time of the TRT inspection. The TRT measured shrinkage at this weld joint in ex-cess of 3/16 inch, which is a violation of inspection criteria delineated in Section 3.6.8.4 of B&R quality inspection procedure for pipe installa-tion QI-QAp-11.1-26, Rev. 16, issued June 11, 1984. A review of the weld documentation indicated that weld FW 98 was visual test (VT) accepted on June 25, 1979, as noted on Weld Data Card (WDC) 13265. The TRT was able to establish snat in 1979 neither the piping inspection ;-oc' dure.
e C:-CAs-11.1-26, nor Gioos & Hil' 5:ecification 2323-MS-100 containeo inspection criteria for measuring weld shrinkage. At that time, the Gibbs & Hill specification stated only that "welding parameters shall be controlled to avoid excessive heat input resulting in necking down of butt-welds" (Ref. Sec. 4.27.8). On May 20, 1982, Design Change Authorization (OCA) 13,335 was approved for adding the amre specific inspection criteria, cuantifying the acceptance range of radial weld shrinkage, to MS-100 Sec. 4.27.8, which became part of Rev. 7 of that scecification. Revision 7 of MS-100 was issued on December 2, 1983. A c:rprehensive documentation review by the TRT showed that the veld package was acceptable. It was determined that original weld Pd 9A at this same location was cut out due to rejection of radiographic test number 5478 and was rewelded as FW 93.
This may have also contributed to the radial weld shrinkage. However, weld shrinkage at Joint FW 9B was outside of the acceotability tolerance as cuantified in Rev. 7 of MS-100.
- 5. Conclusion anc Staff Position:
A. _I_EB 79-14 Program The allegation that TUEC's IEB 79-14 inspection pregram for pipe supports was "too narrow in scope" was not substantiated. The IEB 79-14 program was not intended to take the place of the more detailed QC inspection for installation. The primary task in the IEB 79-14 program was verifying for support type and direction as well as measurement of location, c16arances, and angularity. This field verification was to ensure that the as-built pipe and support configuration was accurately represented in the final stress analysis of critical piping systems.
Tot ablegation that TUEC's IEE 79-14 program "igno ec cimensionai discrep-ancies that might exist" between tne field condition and final "as-built" drawings was not substantiated. As stated in Section 4.A of this assess-ment (AQ-50), 93 of the 97 ABRRs mentioned by the alleger involved only sway strut and snubber angularity. For the sammle of 5 ABRRs selected by
~
the TRT from the alleger's list for field review, none exceeded the 5-degree limit for angularity.
On February 7, 19a5, the TRT contacted the alleger by telephone and dis-cussed the results and cerclusions of the TRT assessment of the alleger's previous allegations. The alleger did not identify any further concerns or allegations.
B. Additional Pipe Suoport Inspection Based on the TRT inspection of 42 NF component supports and selected attri-butes on 92 other pipe supports as outlined in Section 4 of this assessment (AQ-50), the TRT concludes that the ASME cede requirements and quality acceptance stan(ards a; well as site QC procedures were not consistently followed in some 4 the systems and components inspected.
The TRT observed that the characteristics of the discrepancies identified were both specific to individual succorts and potentially generic. Fre-ovency ano repeatability o.f deficiercies were most notable dith respect to ,(1) escessive free gap at tne sonerical cearings of snuocers and sway strats; (2) strut and snubber f asteners not properly secured; and (3) in-sufficient thread engagement of bolts in shock arrester adapter plates. .
The TRT notes that items (1), (2), (3), and (5) of the potentially generic issues listed in Table 3 are deficiencies that do not meet established in-spection criteria. The TRT considers that the inspected level of occurrence of items (1), (2), (3), (5), and (6) is excessive. The cumulative effect of these deficiencies not being detected, reported, or corrected appears to indicate a potential site QA/QC breakdown in the QC field inspection area and with regard to adequacy of some of tne quality inspection procedures.
The TRT notes that the frequency of less than full thread engagement of snubber adaoter plate bolts, item (4), is allowed by B&R procedures QI-QAP-11.1-28, Attachment 29, and QI-CAP-11.1-23A, Attachment 10. This coes not acpear consistent witn tne intent of ASME Section III, NF 4711 weict is designed to ensure sufficient tnread engagement. The TRT was not able to find correspondence by site QA/QC or engineering which: raised tne question of possioie coce violation, requesteo venoor concurrence with less than full thread engagement, or raised questions of how minimally-threaded fasteners were properly accounted for in the final as-built stress analyses.
The significance of each noted deficiency varies. Item (1), excessive spherical bearing clearance, may result in dislodgement of the bearing from its race and detrimentally affect the function of the support. The TRT noted that in each case the ercessive clearance was not enough to allow total dislodgement of the bearing.
Item 42), load pin locking cesice miasing. :culo result in the distecgerer,.
of the lead pin. In effect, the support would lose its functiona' operabil-ity. This deficiency is considered potentially safety significant.
Regarding item (3), pipe clamp halves not parallel, it is not apoarent to the TRT tnat tr.are is a necessity for requiring the load-side clamp halves 16
to be parallel without any tolerance. The TRT recognizes that at some point a non-parallel condition would be unacceptable, and maintains that an installation tolerance should have been instituted in project proce-dures; however, the non parallel conditions found did not appear excessive. l Item (4), snubber adapter plate bolts not fully engaged, may have signifi-cant safety impact. It is not apparent to the TRT that the snubber design allows for less than full thread engagement. Therefore the load capacity of the snubber may be reduced by this condition.
Item (5), "Hilti Kwik" Bolts installed with less than minimum embedment, is safety significant in that the amount of embedment directly affects load capacity.
Item (6), absence of proper and suf ficient locking devices for threaded fasteners on NF supports, is a violation of ASME Code requirements and may have safety significant safety implications, a items . (1) th -o u g *. ( 6 ) acove, are significant in regardsto cuality in '
as Tuce as tne ceficiencies were 03vious even On cursory inspection, ar.d sit'e OC should nave detected and recorded the deficiencies.
In cerclusion, the TRT staf f position is that items (1), (2), (3), and (5) of the potentially generic issues sampled by the TRT occur at levels that are excessive. The TRT believes the item (3) occurrence level is related to an insoection criterion that may be too stringent (i.e., with no con-struction or inspection tolerance). Items (4) and (6) nay be safety sig-nificant; and cepending on acceptability of sue;orting analyses and docu-mentation to be provided by TUEC, these two itets may also have an excessive level of occurrence in Unit 1.
Based on inspection findings in Class IE electrical supports, listed in Table 4, and the high rate of rejectable characteristics perhaps unique to electrical succorts, the TRT concluded that B&R *nscection of these elec-trical caole tray and concuit supports was unsat's'actory anc tnat objec-tive evidence o' comoliance with sp'ecdfied engiree*4ng and construct'oa cri teria wa s not provided.
The TRI found nothing deficient within the Class I instrument tubing sup- :
port sample inspected. The documentation review indicated that the record software completely and accurately represented the hardware found in the field; and that the in process and final inspections were comprehensive and provided sufficient evidence of acceptance, in accordance with appli-cable quality procedures.
- In the majority of cases, material identificatien on pipe supports was crecerly esta:ilisned frc9 the carts or reco c5 dastected by the TRT.
De#ickv'.iv, founc c 'ege in;tarcs. ar e . trr " se .ra:eef al and omit sier -
ef ma*ertal neat nw.icer from tne matenal ice.t' 4caticn log.
The TRT's findings with regard to TUGCO's omission of locking devices for NF supcort threaded fasteners were that CA/QC failed to report the viola-tion of the recuirements of ASME III, NF, subarticle 4725, by a formal nonconformance report (NOR). Further. TUEC failed to reoort the ASME code li
o violation to the NRC and was, therefore, in noncompliance with the require-ments of 10 CFR 50.55(e).
SSER 10, Piping and Mechanical (p. N-150 and N-151) also discusses require-ments for threaded fastener locking features, However, the subject (SRT-9) pertains to pipe whip restraints which are not within ASME Section III Code jurisdiction and, therefore, are not governed oy Subsection NF criteria.
The QC inspection criteria for the weld joint involving radial weld shrink-age was not violated at the time of the visual test inspection. The TAT actr.swledges that the ASME code of record (prior to 1981) does not specif-ically address acceptance criteria for weld shrinkage. The TRT requested that TUEC address the situation, especially for thin walled stainless steel pipe, that weld joints do exist in NA-stamped systems that exhibit exces-sive weld shrinkage when measured against their current procedure and that the safety significance of this situation be assessed. ,
Unsatisfactory QA/QC oerformance was most visible in the inadequacy of d soections in the f' eld, a oreolem comoounced by ocor workmanship; neglect of s:me recuire. tents of tne ASME coce, incustry stancards, ard station prececures; and in one . instance, disregard of the reporting requirements of 10 CFR 50.55(e). .
During the TRT's assessment of allegatters in the areas of design and doc-ument control (QA/QC Categories 1 and 2), it was determined that a number of conditions may have existed during the early stages of construction that could have resulteo in problems significant to quality. Whether actual problems did occur could only be determined from this as-built assessment. While the as-built assessment does not specifically associate the identified prooiems with design or document control deficiencies, many of the problems identified could have been the result of incorrect or obsolete documents being used for construction and/or inspection.
The as-built verification effort conducted by the TRT for pipe suosorts, electrical cable tray hangers, and electrical concuit supports p ovices seme examples of faulty construction by craft pe-scenel, installed narc-wsre that oces not maten as-built drawings, implemea.*.ation of inadecuate cuality procecures, ano less snan effective QA/QC inspections. Oespite the seall size of the TRT's sample, and considering the significant amount of findings plant wide, there could be a large number of deficiencies not represented correctly in the final stress analysis.
- 6. Actions Required:
- 7. Potential Violations:
10 CFR Part 50. Appendix B, Criterion II "Quality Assurance Program."
- reasires hviders of csostruction permits for nv: lear pc.ee cla .ts to document by written policies, procedures, or instructions, a quality assurance program which complies with the requirements of Append'x B !
for all activities affecting the quality of safety-related structures, systems, and components. The program shall take into account the need for special controls, processes, tools, and skills to attain the requirec
O quality, and the need for verification of quality by inspection. Manage-ment of other organizations participating in the quality assurance program shall regularly review the status and adequacy of that part of the quality assurance program which they are executing.
A. Component Support Welds:
10 CFR part 50 Appendix B, Criterion IX "Control of Special processes,"
requires that measures shall be established to assure that special pro-cesses including welding, heat treating, and nondsstructive testing, are accomplished by qualified personnel using Qualified procedures in accord-ance with applicsble codes, standards, specifications, criteria, and other special requirements.
TUGC0 instruction 01-QP-11.21-1, Rev. 8, sets forth the criteria and re-quirements to be used when performing visual inspection of welds under the guidelines of AWS 01.1. structural welding standard, and ASME Section III, subsection NF, as applicable for pipe supports and electrical supports.
This inst uctica recuires trat all welds are free frem caacks. slag er slag inciv51cns. tnat tnerougn fusion exists cet een wela me!ai anc case metal, and that uncercut shall be limitea to 1/32 inch for structural tube, shape, and plate, to specific allowances. The weld size shown on the draw-irg shall be the minimum required weld size; except that fillet welds in
- any single continuous weld shall be permitted to be 1/16 inch undersize, provided that the portion of undersi:ed weld does not exceed 10 percent of the total weld length. Welds which do not meet si:e requirements shall be corrected. The requirements of Rev. 3, stated a:cve, are similar to re-quirements in earlier revisions of this procedure.
Brown & Root Instruction QI-QAD-11.1-28, Rev. 25. states in part that in-spection personnel shall routinely observe general workmanship practices during the performance of their inspection activi t '+s '
sll areas of plant construction, and that fcbrication and installation snail ce performed in accordance with the drawing detail and permissible tolerances. Section 3.5.5 of tnis procedure lists reavicements for weld and case eetal inspection, 9 1 1 si:e. uncercut, and otner defects or indications, consistent with the
. nee.ts :f TUGC0 Instruction QI-QP-11.21-1 s9:wn above. The require-v.ts of Rev. 25, stated aeove, are similar to snose in earlier revisions of this procedure.
Contrary to the above, the Technical Review Team (TRT) found a number of unacceptable welds during an inspection of 42 cc :enent supports. Although the proper instructions, standards, codes, and procedures were available to site QA/QC, with well-defined acceptance criteria for component support welds, rejectable weld quality had been accepted by QC inspectors' final weld inspections. Some welds were not made in ac:ordance with drawing requirements or not CC verified.
~
- 1. QI-QAE-11.1-05 Rev. 05. Para 3.5.5.1 pecvices w+1d and base metal inspection requirements.
Contrary to the above:
21
(a) Support No: AF-1-001-001-533R had porosity, insufficient weld leg, incomplete welds, and insufficient fill. This support was re-moved, scrapped, and completely rebuilt subsequent to and as a result of TRT inspection of the welds.
(b) Support No. AF-1-001-702-533R. This support had two more welds than required. The extraneous welding was not documented on the as-built drawing. One of the required welds, however, was under-cut (1/16 inch - 3/32 inch deep, for a length of 2 inches) beyond limits of acceptance. Further, the required clearance between the shim underneath and on top of the pipe was zero because the required gap was obstructed by duct tape or some such substance.
(See QI-QAP-11.1-28, Rev. 25, para. 3.3.4.) !
(c) The support drawing (CC-1-126-013-F33R) required a h-inch fillet weld to cennect item 5 to item 6. This weld was omitted in the field. Further, this drawing required 1/16-inch top-of pipe to hanger clearance, but no clearance was found. -
t
, (:1 Su: port No. CC-X-039-007-F439. A 5.16-inch all-arouno filiet welo had an approximately 1/16-inch undersiz2 weld leg for the length across the top flat of the tube steel.
(e) Support No. RH-1-006-012-C42R. An all-around 1/4-inch fillet weld connecting item 5 to item 7 was undersized by 1/32 inch to 1/16 inch across the top.
(f) Support No. AF-1-037-002-533R. This support exhibited a 1/16-inch to 3/32-inch reduction in plate thickness and weld size due to excessive grinding of the welc at the case plate. Base material thickness of the support plate was reduced beyond the limits of acceptance in three locations.
(g) Suoport number CC-1-126-013-F33R had some welds performed with no OC inspector initials or signature on the corresponding blocks of the weld data card for the supcoat inseection package.
(h) Support ho. CT-1-013-014-532R exnibitec excessive overgrinding of welds which resulted in notching of the sway strut rear brackets. This condition was repaired subsequent to and as a result of the TRT inspection.
- 2. TUGC0 instruction QI-QP-11.21-1, Rev. 8, para. 3.3.1 to 3.3.1.3 pro-vide requirements for visual inspection for electrical ca$1e tray hangers and conduit supports.
Contrary to the above:
Sa) Tr.ree of four welds on cencuit .uppert 0120-21-194-3 (cable spread room) were undersized. The required weld size was 1/4 inch at all weld joints, while the measured weld size was 7/32 inch to 5/32 inch for the full length of three out of the four welds.
22
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(b) Similarly, cable tray hanger CTH 5824 (' Containment Building) had 12 undersize welds. The all-around welds on the six horizontal l be;;ms should be 1/4 inch in size, accordfng to details La and La on Drawing FSE-00159, sheet 5824, 1 of The measured size of these welds was 3/16 inch to 5/32 inch e , each connection. Also, support IN-SP-7b exhibited undersize welds measuring 7/32 inch to 5/32 inch instead of the required 1/4 inch.
(c) The TRT found that cable tray hanger CTH 5824 (Containment Build-ing) h?d been fabricated to include 40 more stiffeners and 80 more welds than required or shown on drawing FSE-00159, sheet 5824, 2 of 2, Detail L . Inspection Report ME-1-0006155 verified final QC inspection and acceptance on January 3, 1984.
(d) Cable tray hanger CTH-6742 (Auxiliary Building), Clip, MK-12, should be 6 inch x 6 inch x 3/4 inch angle stock in accordance with FSE-00159, sheet 6742. The actual flange thf ckness of HK-12 was 3/9 inch.
(e) During inspection of Hanger CTH-6742, the TRT found that two structural welds were made in the wrong location. The 3/16-inch shop welds which join MX-10 and MK-11 were made horizontally
- instead of vertically, as shown on drawing FSE-00159, sheet 6742.
B. Other Ceroonent Suoport Hardware Attributes:
10 CFR 50 Appendix B, Criterion V "Instructions, Procedures, and Drawings" requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures or drawings.
TUGC0 Instruction QI-QP-11.10-1, Rev. 20 "Inspection of Seismic Electrical Succort and Restraint Systems" provides the OC inseector with the criteria and attributes that shall be used when inspecting seismically installed field-f abricated electrical succort systems; including attachment inspec-i tion of H'Iti bolt embedment and spacing, bolt bearing requirements, and
". colt locations per G&H Drawing 2323-5-910. The requirements of Rev. 29, stated abo n , are similar to those in earlier revisions to this procedure.
Brown & Root instruction QI-QAP-11.1-28. Rev. 25, "Fabrication and Instal-lation Inspection of Safety Class Component Supports" provides requirements and guidelines for material dimensional control, including installation tolerances for base plate attachments (21/4 inch), baseplate hole locations (21/4 inch or as shown on the design drawing), minimum edge distance for bolt holes is 1.5 times the bolt diameter from center of the bolt hole to the edge of the plate); pipe clearances; full thread engagement on fast-
, enersT* anchor bolt torque verification; snubbe spherical bearing installa-
- l tion and cleanliness criteria; pipe clamp parallelism; upset threads / sight l hole verification; use of cotter pins; tightening of fasteners; snubber '
cold set dimensions; sw,iy strut angularity requirements (not to exceed i 5 degrees). The requirements of Rev. 25, stated above, are similar to ;
those in earlier revisions of this procedure.
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ASME Section III, NF-4725, states in part that all threaded fasteners, except high-strength bolts, shall be provided with locking devices.
ASTM Material Specification A-325 (Part 4-1974) paragraph 1.5 provides that heavy her structural bolts and heavy hex nuts shall be furnished un-less other dimensional requirements are stipulated.
Contrary to the above, the TRT found various conditions in nonconformance with applicable ir.structions, drawings, procedures, and ASME code rules.
- 1. 01-0AP-11.1-28, Rev. 25, para. 3.3.1.1 provides installation tolerances for base plate attachment and hole location. Minimum edge distance recuired from center of bolt hole to edge of baseplate is 11: times the bolt diameter.
Contrary to the above, the minimum edge distance has been violated by h inch at the installation of NF component support, CC-X-039-006-F43R, located in the comconent cooling system, Room 249A, fuel handling M !cing. '
2.' Cl-CAP-11.1-28. Rev. 25, para. 3.3.4.1 provices design tolerances for 3
pipe clearance.
Contrary to the above. pipe support, CC-1-126-013-F33R, exhibited no
- clearante en too or bot;om, while the han;er drawing called out 0 incP.es on the bott a and 1/16 inch on too. A similar problem existsd for pipe support, AF-1-001-702-533;.
- 3. 01-0P-11.10-1, Rev. 29, Para. 3.5.1 provides instructions and referen-ces for inspection of attachments for race-ay and conduit su:;crts.
9entrary to the above:
(a) CTH-6742 (Auxiliary Building) anchor bolt teroue was not verified
' (paragraon 3.5 of the proceoure). H 1 '. t i colts aere net earied in accordance with recuirements of CI-04P-11.1-25, atta:- ert I act was the leng n of tnese toits veri'ia:*.e (cara; ach 3.2).
(b) CTH-5824 (Containment Building) base plate bolt holes had violated minimum edge distance--edge distance cannot be less than 1 7/8 inch
- for 1 -inch diameter bolts (per CMC 11061, Rev. 3). Actual dis-t tance was 1 5/8 inch to 1 3/8 inch from the nearest plate edge.
l This condition af fected five of the eig'it Hilti anchor bolt holes j in the base plates for this hanger.
(c) One Hilti bolt was skewed to more than 15 degrees. Maximum allowable skew was 6 degrees without corrective bevel wasteas. ,
(d) T r.e wilti bolt tor.;w on nanger CTH-C'4 ( Avi'iary 8.11oin;)
was not doc cented as being verified by QC.
j 4. QI-0AP-11.1-28, Rev. 25, para. 3.7.3.2 gives requirements for s.ay strut thread sight hole verification.
l N
i l
o Contrary to the above, on support, RC-1-901-702-C825, sight holes were present in the strut body to verify threaded rod engagement. The rod was not visible through the sight hole.
- 5. QI-QAp-11.1-28, Rev. 25, para. 3.3 provided instructions for material dimensional control.
Contrary to the above, the horizontal member of support, CC-1-126-010-F33R was 3 inches lower at its centerline relative to the upper bolt-hole centerline than shown on the vender-certified drawing. The as-built .
drawing had not been revised to reflect the actual installed condition '
in the plant. This support was located in the component cooling sys-tem, Room 247A, in the Fuel Handling Building. Other supports with similar ho10-location violations found in the inspections were:
CC-X-039-007-F43R, CC-1-126-011-F33R, and CC-1-126-012-F33R.
- 6. QI-0Ap-11.1-28, Rev. 25, para. 3.7.3.1, requires installation criteria and cleanliness verification for spherical bearings.
t Contrary to the acove:
(a) An excessive free gap existed between spherical bearing and ,
washers on the sway strut assembly of support, CC-1-126-015-F43R.
Other supports with similar bearing gap anomalies found in the TRT's insovetions were: RC-1-052-016-C41K, RC-1-052-020-C41K.
and MS-1-416-001-533R. The frequency of this type of procedure '
violation in the TRT's limited inspection suggests that this problem is generic for Unit 1. I (b) The TRT found paint contamination in the bearings of both snubber assemblies on component support, SI-1-090-006-041K, that severely obstructed the bearing cavities and limited their movement.
This Class I component support is located in the Containment Building of the Unit I safety injection system. A similar condition existed on supoort. MS-1-416-002-533R.
- 7. 01-0Ap-11.1-25, Rev. 25, para. 3.7.3.1 and attacement 2 provice in-spection criteria for sway struts.
Contrary to the above:
(a) Clamp halves for pipe supports, AF-1-001-001-533R and AF-1-001-014-533R, were not parallel.
(b) Sway strut No. AF-1-001-014-533R had a broken cotter pin.
(c) A pipe clamp locknut for pipe support. AF-1-035-011-533R, was !
found loose (less than finger-tight). * '
(d) pipe support, CC-)-126-014-F43R, exhibited angularity that exceeded the maximum misalignment allowance of 5 degrees. A similar pro- '
blem existed with pipe support, RC-1-052-020-C41R.
25
(e) Pipe support, CS-1-085-003-A42K, vestated by approximately 1 inch from the cold set dimension shown on the design drawing.
(f) Snubber, CT-1-005-004-$22K, was installed end-to-end 180 degrees opposite frem the orientation shown on the drawing. The TRT acknowledges that TUEC procedure, QI-QAP-11.1-28, allows instal-lation 180 degrees (end-to-end) from the configuration shown on the drawing, but questions whether the "as-built" drawing should have been revised to show the "as-installed" orientation. A similar problem existed with pipe support, CT-1-013-010-522K, where dimensional discrepancies existed on the support drawing
, that detailed the orientation of the snubber.
- 8. ASTM Haterial Specification A-325 provides criteria for application of Heavy Hex and standard nuts. Heavy Hex nuts are to be used unless a deviation (such as standard nuts) is specified on the design documents.
Contrary to the above, B&R Drawing FSE-000159, Sheet 5824, 2 of 2.
recuiceo tne use of ASTM A-3:5 belts for cable tray hanger CTH-5524.
, Tsere was inconsistency in tne apo11 cation of nsts for SA-325 bo'its in that both standard and heavy hex nuts were used for cable tray hanger CTH-5324 No stipulation was found which would permit tne use of stancard (non-heavy) hex nuts.
- C. Material and Supoort identification:
10 CFR 50, Appendix B, Criterion VIII "Identification and Control of Materials, Parts, and Components" requires that identification of the item is maintained by heat number, part number. serial nur,ber, or other appropriate means, either on the item or on re::rds traceable to the item.
TUGC0 Instruction CP-EI-4.5-1, Rev. 10, "General Program for As-built Piping Verification" requires verification in the field to ascertain that actual hanger mark nuebers agree with the mark numbers shown on the crawing and that the hanger tyce agrees w th tnat shown on the support i
crawing. The recuirements of Rev. 1". stated 4::ve, are similar to Fest in earlier revisions of this procecure.
Brown & Root instruction QI-QAP-11.1-28. Rev. 25, states that at installa-tion inspection, the QC inspector shall verify tne hanger number, material type, grade and heat number (Section 3.1.2), anc that vendor-supplied NPT-stam. ped component supports shall bear marking (i.e., name plate) traceable to the design drawing. The requirements of Rev. 25. stated above, are similar to those in earlier revisions of this procedure.
Contrary to the above, the TRT found in six instances (from the inspection cf 42 suceerts) that re:ulatory, orocedu-a1. ant 'estru: tion *):uirements
- 44 bt49 Ecitted dwrtr; CO ft941 inspe:ta;
- Specific misnomer cf support assemblies and absence of part markings were as follows:
l 1
e
- 1. Model numbers of installed snubbers for pipe support, SI-1-090-006-C41K, did not match the model number on the design drawing. A similar problem existed with pipe support, RC-1-052-020-C41R.
- 2. A replacement part (sway strut eyerod) for pipe support, CT-1-013-014-532R, had no apparent material identification either on the hardware or in the documentation package for the support. The Material Identification Log (MIL) did not list any identification traceable to the origin of the replacement part. A similar problem i existed with pipe supports, CC-1-126-012-F33R, CC-X-039-005-F43R, and AF-1-035-011-533R.
D. Snubber Adapter-? late Belt Thread Engagement:
10 CFR 50, Appendix B, Criterion III "Design Control" states in part that !
the design control measures shall provide for verifying or checking the i adequacy of design, such as by the performance of design reviews, by the ;
use of alternate calculation methods or by the performance,of a suitable :
testing orogram.
TL'G;0 engineering instruction Cp-EI-4.5-1 (cara. 3.6.1) requires that support cesign shall be verified to as-ouilt analysis support leads by the responsible engineering organt:ation. -
P own & Root instruction 01-0Ap-11.1-28. Rev. 25 (para. 3.8.3.2) states that in those cases where the bolts which attach the forward bracket or transition kit to the snubber do not protrude completely through the ;
tapped hole in the snutber flange, the minimum thread engagement is given 1 i
on attachment 29 of the same instruction. Earlier revisions of l 01-CAP-11.1-28A show similar thread engage ent allowances in Attachment 10, identical to thread engagement allowances given in 01-QAP-11.1-28. Rev. 25, Attach.ent 29.
ASME Section III. NF-4711 states that all bolts, studs, or the threaded f
red snail have full tnreac engagement in tne nut.
Centrary to tne above, snutber (shock arrester) acapter-plate bolt threads were insufficiently engageo in all four tnreace: noies of component support, ;
MS-1-416-002-533R. The worst condition was 0.095 inches short, or lacking full thread engagement by 25 percent. Similar lack of full thread engage-ment deficiencies was found on NF supports, SI-1-090-006-C41K and CT-1-013-012-532K.
1 The inspection criteria used by the TRT regarding thread engagement of t bolts on snubber adapter plates were based on full thread engagement. '
Those bolts lacking full engagement through the adapter plate were cited, even though procedure 01-CAP-11.1-28. Attachment 29. allowed less than full +ngagenent. For aaamcle Attachment 20 s ao ed a minimum inreae -
engastment of 3/16 inch for snutter si:es R4-1.'2 inches; for snwb:6-si:es 1 inch through 3 inches, the minimum thread engagement is 5/16 inch.
In all cases, the thickness of flanges and lengths of tapped threads in respective adapter kit flanges were ignored in Attachment 29. B&R proce- 1 dure O!-CAP-11.1-28A, "Installation Inspections of ASME Class 1, 2. and 3 .
Snubbers," Attacheent 10, also showed the same minimum bolting engagement
]' , ,
a k
. .. l I
allowances. The TRT concern is that the procedure was inconsister.t with ASME Section III, NF-4711; and the condition for thread engagement should have been certified as acceptable by the manufacturer. It appears that the QC Engineer approved an inadequate procedure for implementation in the field.
Subsection NF-4711 relates to thread engagement in nuts, requiring that "the tnreads of all bolts or studs shall be engaged for the full length
. of thread in the nut." The same reasoning would also imply that there be a full length of a threaded hole in plates, shapes, or bars where the re-quired threaded hole length is the same as the bolt diameter. No evidence has been provided to the TRT that partial thread engagement at the snubber adapter plate connection has been given consideration in the design pro-cedures for linear-type supports, nor does it appear that sufficient design margins have been introduced to allow for less than full-threaded connec-tion. The TRT did not check "as-built" analyses to determine whether any such variations from full thread engagement had in fact been considered 4n the "as-built" stress calculations. What is in question is whether any ca'c.lat'ces 9ad been made'to crovide the bases for the criteria in Att;cnment 29 mentione; aoove, f or each sice snuocer ceing usec in tre piant.
E. Lecking Devices en Threaded Fasteners:
10 CFR 50, Appendix B, Criterion XVI reovires that measures shall be establisned to assure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, defective material and equipment, and conconformances are pro ptly identified and corrected.
ASME Section III, NF-4725, reevices that all threaded fasteners, except high-strength bolts, shall be provided with locking devices to' prevent loosening during service. Code interpretation No. !!!-1-83-49R provides that the users should satisfy themselves that any other locking device than those described in NF-4725 (elastic stop nuts. lock nuts, jam nuts, anc drilled and wired nuts) is ca:able of acting as a 1:ckin; device under 4
all le*vice conditions, d
Erc n & Root instruction Ql-CAF-11.1-25. Rev. 25, Sect. 3.7.1 and Attach-meet 2, Operation 7, inspection attribute "h", reovires that all exposed threads be free of extraneous material. This requirement was first invoked by issuance of Rev. 24 of this instruction, Attachment 2, referencing sec-tion 3.7.1 of the rain body of the text in this instruction.
Contrary to the above, the TRT found examples in Unit I where deficiencies existed so that TUEC was in potential violation of the codes, procedures, guidelines, and commitments concerning locking devices for threaded fastentes ' r ASVE Section !! Nr succerts. Di*e suceort. RC-1-901 702 CS:5.
t i d u *a n d bul t A t a be am a t t a e r.n.+r t s 1 ;' di: ett e.bitit an ap; roved '
' :. c e dag civice. (The telt meterial tyre -a > S A-!.'J. grade A.) Add i t i o".-
ally, pipe support, CS-1-025-003-A42A, had no approved locking device on the "special clamp" bolts, even though the design drawing for this clamp showed each bolt with a nut and a locknut. In another instance, noncompli-acce with the above reevirements was recogniced by TUEC and B&R QC who issued a "Request for Inforeation and Clarification" (RFIC) to TUGC0
.' i
O 9
] .
Engineering in April 1984, requesting direction for res.lution of this issue. In spite of the requirements pursuant to 10 CFR 60.55(e)(1), TUEC did not report to the NRC the omission of thread-locking devices in the Unit 1 NF supports in nuclear safety systems.
SSER 10, Piping and Mechanical (p. N-150 and N-151) also discusses require-ments for threaded fastener locking features. However, the subject (SRT-9)
- pertains to pipe whip restraints which are not within ASME Section III Code
- jurisdiction and, therefore, are not governed by Subsection NF criteria.
I On May 24, 1984 TUGC0 engineering advised by memorandum (CPPA 38997) that I
the paint which was applied to Unit I component. supports, including fast-j eners, when set or hardened, would act on bolt and nut threads to prevent the nut from loosening. TUGC0 engineering had performed a series of torque tests to substantiate their position. Samples coated with a multi-process s epoxy formula were chosen by TUGC0 on the basis of site and included in the test.
I TUEC had a octentf ally inai:ecuate ovality assurance soecification he. 2323-AS-31. nicn cio not cover inspection of painted threaced fasten-ers. The paint was apolied to ASME code-controlled, NF hardware per spec-ification 2323-AS-30 (non-0) which required no inspection. This issue
- l appears to be generic for Unit 1.
There was a difference in locking devices on threaded fasteners for similar i pipe support hardware made by two separate venders. In some cases, Nuclear power Service Incorporated (NPSI) specified only one nut and no locking j device; but ITT-Grinnell required two nuts in those same applications.
1 If the design of NPSI models should be found to need the locknuts or their equivalent, there could be hundreds of NF pipe supports installed without adequate locking devices.
S The TRT has several concerns regarding the utility and reliability of coat-ing used as a locking device for threaded fasteners used on NF supports:
(a) Tne TRT could not locate any NCRs. ASME/AN! notific& tion, o* dccumenta-l tion to NRC describing aosence of approved locking devices #or NF com-ponent supports installeo ano inspecteo in 1953 ano earlier.
l 1 (b) If an NCR would have been written, the applicable procedure (Ref.
TUGC0 CP-QP-16.0, "Nonconformances") required that the NCR receive i an engineering disposittor:. The TRT has the following spe i cerns about TUGCO's engineering justification for useaint of p,cific in con-lieu of approved locking. devices:
i j (1) Paint-coated threads were tested in the weld shop under noreal l environment and ambient temoerature. Useful life or holdica '
l cacaM 1ity under anticipated service conditions, 1.cludin; ce-
- sign-casts temperatures arc radiation aging, was not aedressee.
i I (2) The type of coating which was torque tested was not identified in TUGCO's documentation of the "Multi-process Epoxy Formula -
Toroue Test," attachment to TUCGO CPPA 39209, office memoran-l dum. The unanswered question is whether the coating tested was i 29 i
i
,i -
CZ 11/P 305 (Carbo-zine 11, prime, and phenoline 305, top-coat) or C193/P305 (carboline 193, epoxy primer, and phenoline 305, top coat); and whether torque test conclusions for one coating would be the same for the other coating formula. Both coatings -
were used on threaded fasteners in Unit 1.
(c) There was no evidence that an effective plan had been initiated to pro-vide for routine maintenance activities in order to ensure that all ,
painted fastener threads on NF supports maintain sufficient thread- !
lock reliability for the Itfe of the plant, or until the paint lock i method is replaced by a different procedure, i
- 3. At t a c h.me nt s : Nene.
Reference Documents:
- 1. Comanche peak Steam Electric Station, Final Safety Analysis Report.
t
- 2. C:de of Federal Regulat ons. Title 10. Part 50 (10 CFR 50). Aenendix B i
"Coality Assuran:e Crite-ia for huc' ear oc er Plants ano Fuel Repro:essing plants." .
3, 10 CFR Part 50.55(e), "Conditions of Construction Permits: Reporting :
Criteria for Significant Deficiencies."
4 American Society of Mechanical Engineers (ASME), So11er and Pressure Vessel Coce,Section III. Division 1, 1974 Edition.
5 U.S. Nuclear Regulatory Commission, Inspection and Enforcement Bulletin l No. (IEB) 79-14 [
- 6. IEB 79-02, "Pipe Support and Baseplate Designs '.3' ; C:a:*ete Expansion Anchor Golts." ,
I
- 7. American welcing Society. Structural Welding Coce (Steel), AWS 01.1-79. [
..~; N :r.1to:ts arc En;ineers Anenor arc Faste er Design Manual."
I
- 9. Gibos & Hill specification: 2323-MS-100, Rev. 7. dated December 2, 1983, l and earlier revisions, j
- 10. Gibbs & Hill specification: 2323-MS-46 "Nuclear-$afety Class Hangers &
Succorts." *
- 11. TUGC0 engineering procedure: CP-E!-4.5-1 "General Program for As-Built l Piping Verification."
- C&R q M11tv pro:edure. 01-01: 11.;-;! "Fao t:ati n. Insta'lation and
! Inspection of Safety Cla s C:mponent Swoports," key. 25, July 11.1954, and previous revisions, f
ous revisions.
i
{
20 l
l
o
- 14. B&R quality procedure: QI-QAP-11.1-37 "Instruction for QA/QC Review, Approval and Utilization of Construction Operation Travelers."
- 15. B&R quality procedure: CP-QAP-12.1, Rev. 11, June 11, 1984, and previous revisions.
- 16. B&R quality procedure: CP-QAP-16.1 "Control of Nonconforming Items."
- 17. B&R construction procedure: 35-1195-CEI-20 "Installation of 'HILTI' Orilled-In Bolts," Rev. 10, September 14, 1984, and previous revisions.
- 18. TUGC0 quality procedure: CP-QP-11.2 "Surveillance and Inspection of-Concrete Anchor Bolt Installations " Rev. 8. July 13, 1984, and previous revisions.
- 19. TUGC0 quality procedure: 01-0P-11.2-1 "Concrete Anchor Bolt Instal-1ations," Rev. 16. July 20, 1984, and previous revisions. .
2C. TUGC0 :uality =coceaure: 01-CD-11.2-2 "A:n-coned Cone ete Ancher
.-o:es." an: *iste ical revistens.
- 21. TUGC0 quali'y procedure: 01-0P-11.2-3, "Torquing of Concrete Anch:r Botts," and historical revisions.
- 22. TUGC0 quality procedure: 01-CP-11.2-4 "Inspection of 'HILTI' Super Kwik Bolts," and historical revisions.
- 23. B&R procedure 01-0AP-11.1-23A, "Installation Inspections of ASME Class 1, 2 and 3 $nubbers," Rev. 4 24 E&R Quality Assurance . Manual.
l 25. TUGC0 instruction CP-0P-11.10-11, "Inspection of Seismic Electrical Suonnet and Restraint Systems."
l
- 26. TUGC0 instructice CD-CD-11.10. "Inseection of Ele:tri:a' Raceway Su:-
l :ert Systems."
\
( 27. TUGC0 instruction QI-QP-11.21-1, "Requirements of Visual Weld Inspection."
- 28. TUGC0 instruction QI-QP-11.10-2, "Cable Tray Hanger Inspectionr,"
Rev. 28.
- 29. TUGC0 quality procedure CP-QP-18.0, "Inspections Peport."
- 30. Gibbs ,&, Hill drawinp 2323-5-910. "Seismic Suceer: ef Class I-E Cenduit." ,
- . Gibes t H114 crawing 2322-5-902, "Ele
- trical 5sp orts Stancard De:atis."
- 32. Gibbs & Hill Specification ECP-10 for electrical conduit supports.
- 33. Region IV Inspection Recort 83-24, c.12 (Tracking System *RIV-83 A-0026),
August 24,1983 (source of AQ-50 allegation).
3;
O
- 34. Region IV Report of Inquiry, Q4-83-009, April 8,1983 (source of AQ-50 allegation).
- 35. Telephone interviews by TRT with A11eger A-6 on August 21 and 23, 1984.
- 36. Interview by TRT in person with A11eger A-6 on August 24, 25, and 26,1984
- 37. Telephone interview by TRT with A11eger A-6 on February 7, 1985.
- 38. Design Change Authorization (OCA) 13,335, on May 20, 1982 (part of B&R NCR M-3220, on February 17. 1982).
- 39. TUGC0 Engineering Office Memo, CPPA 38997, May 24, 1984.
- 40. TUGC0 procedure QI-QP-11.10-1, "Inspection of Seismic Electrical Support and Restraint Systems." ,
TUGC0 Cffite iemo. CPPA 39209.
41.
- 42. TUGC0 p ocecure. CP-0:-16.0. "honconformances."
- 43. TUGC0 Quality Assurance specification No. 2323-AS-30.
44 TUGCC Quality Assurance specification, No. 2323-AS-31.
- 9. This statement prepared by:
M. Eli, TRT Date Technical Reviewer Reviewed by:
H. Livermore. Date 0 9uo Leader 1
l ACproved Di: ,
V hoonan, uate Project Director S
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DO NOT DISct.0SE
- PROPOSED :. . .. ::
ed! PAnft - EWC2CTMf M f: - DOL CASE 01 : ALLEGATION:-
. :~;>:. : ,. .
- : : .;: :: o: e: : . : :: : :: :-
- : :,: , : . :: (: c: : : O. :: : :: ::
- : : g: :::: c: ;: 3: 3: g: .: CASE : :: CASE ::
8tM - romslataiti - ConaOSION . .a - * : * : >- : :*: e: o: CONCLUSION - NO - CONCLUSION : _ _ __ NO :- NOTES epry -
V - no Int. - - -
-- ({5 Review Sheet ,
e< pry .
~"
- N F inoing - -
- leduc tinn o* Force (ROF)
- % rt Incident: : Int. -
m- -
~
- 4-54 A-033:: I Pic N Nits elah N ailton . Y - no Int - - -- - - - - -
~ ~ ~
~
- D efusat oI Inspect Coatings '
- inson : Y : no Int. - - - - - -
- Q 4-82-Oll: No Int. :4-82-A-049:- tent to IIH Panel ich
~
- N : : : :: : : : T
--zi,Q4 84-038: No Elements::4-84-A-091:: Cl Toond b Elements for H&I Case
- :For HLI Case:: ::
X;ma : h :4-85-A-009:R effee Cup Incident-QA Auditor A :9 Q4-84-002:s ew xhison :: 4-81-01) : he Int.
V - me Int. - -- - - - - -
- 4-83-A-0 9: D ntimidation of Coworkers M) : fr / : Pos Int. : ?: ?: ? :: : : : . : ::gQ4-81 621: ho :4-83-A-066:: Intimidation of Elec. Craft r - - - -- - -
Conclusions:
'.04F ) ,
~
, . Symbols) erby : Y - me Int. - - - - - - - -
- r- Q4-84-011: No Int. --
Derby Denied Inticidation
- Y . No Int. - - - - - - - - -
- MD . No Int. ::4-84-A-64) :' Alleged leproprieties in the
- : . . . . . . . . . . . .. . ggg goc, S bu - -
F _ p
- ? -- _ - _ -
- g: . g-aw_ fc rreedom - tao;ited :4-aa-a
-- wm-- QC Ipp . , ' - ia}. test,
- # : : ?: ?: ? .. : : : : : .: Q4-84 -047: hot Issued ::A-84-A-096:: Alleged Falsification of Test -
9 84-047 - :4-84-A-106.: Results
'ONF) V : he Int. . : : :: : : : : : No U nding :: :: Elec. Crafi Int. by B&R Sure.
- : : . . .. . . . . . : 6. Q4-84-001:. OF HLI
- Y : he Int. : : -
- c 4-64-006 : No :- :: Alleg. Intia. of QC Pe.S h 1
- i - -
Conclusions:
M
- 24 Interviews w/ Case Witness r - - -
- : :?Q4-84-027: b Int. : -- Alleq. De?.cris. By TUGCO-%R Y : he Int. : : : :: : : : : -
- g.,,Q4 T 646 . No Int. :: :: Alleg. Harassment of B&R QC Insp
. . try QC l LIIIty 38'est- . # : : ?: ?: ? :- : : : : : . - 85-A-123:: TUGC0 Investigated: Two [9ASCO l hwe Case) - - - - - - . . . -
- .: AS T. . .
.5 Removed M5+a :
~
- : ?: ?: ? :: : : : -
W Case) : :
- ::4 A-107:: TUG M R 1eeents) Resolved
- : : : : : :: : . ggy,g,,.s Concern Alleg. Over
- Tones of Int. (Sent to TRT)
't .
.g.
i I
c_-. A 2-- _
o i
.- =
~- DO NOT DISCt.0SE
- P90P0$fD ::
HLI PAmit :ENF0eCINENI:-
- : DOL CASE 01
- ::AttfGATION:--
--: m :. :g: : : : .":
....o.
. . y .. . .
. . x . .a . .. .::
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~
"." m ! .- ' 3 . Y ~.n " u '. E ". $ .~ Cast !
a
- "CONSIDiR[D-CONCLUSION $3$% %!%$5$I . U$0$ hti CONCLUSION CASE ::
CONCLUSION :- - NO (CONF)
NOIES .' '
(upw) : :
- 4-84-A-120:: Pressure not to write NCRs
- 1: ?: 7 :. : : : : >
- - (Closed SSIR 11)
(b_,) gag,}
. . ~ . .
- 4-84-A-122::
- Iere. Due to Lost Welder Quals
{
(COhF) : - - - -
- 4-84-A-133:: Weld Quotas Demanded j
.: :: (Closed SSER 10) <
(CONF) : : :
- 4 A-140i: Manger Design Intimidation
- :: : " (Crosed 55fR 10)
(CONF) : : : : :
- - :4-84-A-141:: QC Iold to Boy Off on Hilti Bolts
- :: : : . : + ::
- (closed 55ER 10)
(CONF) : : : : :
-- - ::4-84-A-147:: QC Told to Sign Off on Hilti i
- - Bolts and Hangers (Closed SSER 10)
(CONF) , : : :
- 4-84-A-154:: forced to Close NCR
\tchison
- (Closed '5ER 7)
- : : 1: :- : :: 4-84-A-155:: Pressure Not To Write NRC P. r
- * .: Y: IF: IF: IF:NIF: 5th Circuit:.
- - - : . 85-A-157:: (Closed 55EA. 7)
- Y : Int 7 : : E.
- Court NIF -- - ::4-84-A-144:: Civil Penalty - Order Pending V: IF:MIF:hlF: : Secretary :C4-83-016 : Int.
- - 1:
leumeyer - - - - -
- is ic h Y Int. -
-X*
- Ruled NIF -
- 4 A'C?0:: Firing of Dur. ham (DOL MIF) ~~
Y -- Y: -
- 4 A-069 :
fr - - he Int. _ : - -
- Y- : -
- NIF
- f_4-84-039 - Int. '
Ir.tley Y
- no Int.~ -
- : f,Q4-84-037: No Int. :4-84-A-050Atiner Plate Traveler -
- Y
- No Int. -- V:NIF: ? :NIF: - NIF :4-84-A-090::]QC Inspector "Black Balling"
- - : ?.?: ? :: Y: Tor.: : :e QFA4-014 ~No Int.
- 4-84-A-018 f _ i anny 'malter
- * * ~ -
- : (7-12-85) 54 4-84-014 : No lat. ::4-84-A-0Wi7
- . :Conci? lated : :
- - : 7: :7: ? :: Y :NIF: APP: : : :: / :: l regory -
Y
- Mo int. -?-7-F-V- IF; APP: -
Discrimination. Retransfer. and
- ___ /
n RIF (DOL Inv 9/20/84)
Appealed to AtJ (00t Inv 9/26/84) 44 4-89-A~o4L a
. . . . . . . . . _ - . - _- .= - -
.-._. . . .. . ~ _ _ _ . .... ._ . . -
4
- 1
+-
DO NOT DISCLOSE
- : Pe0P05L3 :: :: :: ::
MLI PANEL :EuFDACfMENT:- 00t CASE :- 01 :: ALLEGATION:-
- : : : ~ : > :: 4: : : : .- : :: ::
- : : : 4: J:: o: p: : : : :: : :: :
- : : m:
. : .:: c : c : :
u
- 0: ::
CASE CASE ::
- : : ~ :: %* :-: " :: gu: :Conclusion " :: ::
ACCU 55ES : CON 510ERED : CONCLUSION : *a :
g : = : = :: c : ; : ',:% No : ConctuSION :- no "
NOTES
- U G4-84-013. he Int. :4-84-A-028: Alles. Intie. of Pipe Fitters sch Mill -
V - me Int. - - -
'Tfeen : N : -
- : :: :. : : : : g-Q4-85-903: No Elearnts::4-85-A-012:: latioidat:en of Iron Wer6er OF I&N : ::
alsen -
N -
- f7 : K : ():-
- C 4-84-050 - Int. :- " Alles. Int.
6 L a
9 O *
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