ML20202C593
| ML20202C593 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/25/1984 |
| From: | Eisenhut D NRC |
| To: | Ippolito T NRC |
| Shared Package | |
| ML20202C125 | List: |
| References | |
| FOIA-85-59 TAC-55222, NUDOCS 8607110320 | |
| Download: ML20202C593 (41) | |
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NOTE T0: Tom Ippolito
SUBJECT:
C'0MANCHE PEAK - TELECON WITH H. MYERS/J. SIMPSON
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I On May 4,1984 I received a phone call from H. Myers and J. Simpson. b' Their call related to Comanche Peak. Several question or concerns were passed on to me that I'd like for you to follow up on and get me a written report within two weeks. Part of their concern related to their belief that the NRC doesn't follow up on such concerns. -
The principal matters raised included:
- 1. The allegation regarding main steam line using acrane
, the forcing
. Did it in placewas occur; of theit , d acceptable; was it properly ' reported; did the NRC issue -
Id an evaluation. IM i
- 2. Concern as to whether there was an adequate technical bases for the d_erated value for the polar crane. Is the new derated value coincidently the maximum load expected? *
\, 3. Regarding . concern about welding, does the NRC believe he was, or was not, requested to perform a weld,ing that is outside the approved procedure. What is our technical view for such wo k? -
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~l81984 MEMORANDUM FOR: Darrell G. Eisenhut, Director Division of Licensing ac Office of Nuclear Reactor Regulation
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FROM: Thomas A. Ippolito, Project Director Comanche Peak Division of Licensing
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION - RESPONSE TO ALLEGATIONS
REFERENCE:
Note to, T. A. Ippolito from D. G. Eisenhut, dated May 25, 1984 ,
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2 By the above referenced note, you requested responses to three (3) concerns identified to you by H. Myers and J. Simpson on tlie Comanche Peak Steam Electric Station (CPSES). The principal matters raised deal with allegations that were related to us through the Atomic Safety and Licensing Board hearing.
Enclosed are the staff responses to these allegations. If I can be of further assistance, please let me know.
Sincerely,
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a Project Director Comanche Peak Division of Licensing e
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'Alleo*ation 1. One of the main steam lines in Unit 1 was moved usino the polar crane, thereby placing the section of pipe line in an unsafe stressed condition.
Response
The above alleged improper construction practice was expressed by
. Min an affidavit dated February 3,1983, prepared for Citizens l i
Association for Sound Energy (CASE) and in an interview conducted 'on April 14, {*
1983, by members of the ilRC Office of Investigations Field Office, Region IV.
An inspection of this and other allegations was conducted May 10 - July 1 and !
September 9-22, 1983 and documented in Inspection Report 50-445/83-27, dated '
September 29, 1983 (See Enclosure 1 ~.llegation #2).
Although Brown & Root personnel named by/ M as being involved with the movement of the Steam Line contradicted tne a t tegation, the (IRC inspector conducted an independent review of the onsite documented records regarding this matter, n i
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The reactor building polar crane was utilized in a vertical lift to assist [
repositioning a section of permanent piping mentioned byM The' ;. J licensee has maintained a documented engineering record of the specific line "-
movemert. The flRC inspector noted that the movement of the line was necessary in order that a large section of temporarily installed flushing pipe could be a removed, and to relocate the permanent section of the main steam line-that had " sagged" due to the weight of.the temporary pipe. The record folder.contains meeting notes (memorandum) which reflect discussi6ns with Westinghouse (t1SSS a' Supplier) and the cognizant A/E representatives prior to the work activity, in addition to establishing engineering' limitations and acceptability. The line was moved on January 16, 1982 under the supervision of the field mechanical engineering group, and was witnessed by an engineering representative who observed the installation and use of the dynamometer (to register crane liftirig loads) thrcuchout the_operatiorE ine litt connections ano appited forces Wre recorded and retained in the file. The lifting points were consistent with the hanger locations to simulate the permanent support system. The'as-bu.ilt conficqration O.g h was analyzed for strm and the ac_cy tability of the line confirmed. In addition, the recent completion of the " Reactor Hot Functional Test" did not reveal any undue stress' conditions. The allegation could not be substantiated. t!o viola.tions or deviations were identified in this area of the inspection. ,
Allegation 2. The Containment Polar Crane was derated. Wny was it derated to a point where it was still able to move the reactor vessel head?
Resoonse Containment Polar Crane derating is an accepted, anticipated practice during the transition f rom the cons truction phase to. the operation phase. As stated in the Applicant's Final Safety Analysis Report (FSAR), Section 9.1.4.3.1, "The Containment Polar Crane is used during the plant construction phase for lifts up to 475 tons (for handling the reactor vessel and steam generators) prior to its intended normal service. The use of the crane during the construction phase does not imply any nuclear safety related condition. During ref ueling or mair.tenance operations , the Containment Polar Crane handles,a maximum noncritical load of 175 tons. The heaviest load expected to be lifted is the reactor vessel head assemblyM'.
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Originally, the Polar Crane was rated at 499 tons and du' ring the preconstructicn phase of Comanche Peak appropriate testing of the Crane was completed. Prior to preoperational testing, the polar crane was derated to 175 tons, consistent with the load requirements for plant operation. The containment polar crane was adequately tested in its derated configuration for handling th'e maximum critical load (Reactor Vessel head assembly). Static and dynamic tests with..
a load the equal to derating 125% of thetomaximum modifications the maincritical hoist. load were performed subsequent ~to The Safety Evaluation for Containment Polar Crane Testing (See Enclosure 2) will appear in a future supplement to the Safety Evaluation Report for Comanche Peak Steam Electric Station. ,
Alleoation 3.
)was required to perform welding activities in violation of 'the approved procedures.
Response
ThisallegationisstibunAr Board (ASLB) hearing. litigation in.the Atomic Safety and Licensing 3 the scope of this general allegation. cited specific concerns that fall into j specific concerns and performed inspections in these areas.ihe staff expanded These inspections the scoy raised questions by the staff.
applicant's response to staff inquiries. Resolution of these matters will depend on the
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jn Reply Ref,er To:
Dockets: 50-445/83-27 Texas Utilities Generating Company ' ~
ATTN: R. J. Gary, Executive Vice
. President & General Manager 2001 Bryan Tower Dallas, Texas 75201 Gentlemen:
Tnis efers to -he inspection conducted by Mr. R. C. Stewart of this office during the periods May 1,0-July 1, and September 9-22, 1983, of activities ac .hori::ed by NRC Construction Permit CPPR-126 for the Comanche Peak, Unit 1.
Areas examined during the inspection included inspection of alleged improper construction practices expressed by Robert L. Messerly and an individual who recues .ed confidentiality. Withi.n these areas, the inspection consisted
- of selective examination of procedures and represehtative records, interviews -
with personnel, and observations by the inspector. These findings'are
. documented in the enclosed inspection report.,
., Within the . scope of the inspection, no violations or deviations were
, , identified. ,- ,
"' In accordance with 10 CFR 2.790(a), a. copy of this letter and the enclosure '
' vill be placed in the NRC Public Document- Room unless you notify this office, by telephone, within 10' days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the
,date of this letter. Such application must be consistent with the requirement $..
- of 2.790(b)(1). * ,
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Should you have any ouestions concerning this inspection, we will be pleased o discuss them with you. .
Sincerely, s-v- ongt..si siened by
- p. C. M A7Vi""
G. L. Madsen, Chief Reactor Project Branch 1
Enclosure:
Appendix - NRC inspection Report 50-445/83-27 .
cc w/ enclosure: .
H. C. Schmidt', Project Manager .- .
Texas Utilities Generating Company - 3 2001 Bryan. Tower .,
. Dallas, Texa,s 75201 -
R. S. Clements, Vice President-Nuclear
-(same address as above)
Texas Utilities Generating Company ATTN: H. C. Schmidt, Project Manager 2001 Bryan Tower '
Dallas, Texas 75201 Texas Utilities Generating Company ATTN: B. R. Clements, Vice President, Nuclear 2001 Bryan Tower, Suite.1735
' Dallas, Texas 75201 bec to DMB (IE01) bec distrib. by RIV:
D. Kelley, SRI-Ops RPB1 RPB2 R. Taylor, SRI-Cons T.PB Section Chief (RPS-A)
J. Collins, RA J. Gagliardo, DRRP&EP C. Wisner', PA0 T. F. Westerman, ES M. Rethschild, ELD M. Resner, CIA MIS SYSTEM .
RIV File Q TEXAS STATE DEPT. OF HEALTH '
Juanita Ellis -
David Preister ,
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.c APPENDIX
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U. S. NUCLEAR REGULATORY COMMISSION
, REGION IV NRC Insoection Report: 50-445/83-27 Docket: 50-445 Construction Perrnit: CPPR-126 Licensee: Texas Utilities Generating Company (TUGCO) 2001 Bryan Tower Dallas, Texas 75201 ~
Facility Na.me: Comanche Peak, Unit 1 Inspec-ion At: Comanche Peak, Unit 1, Glen Rose, Texas Inspection Conducted: '
10-Jul
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1, and September 9-22, 1983
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Inspector: -
A. n ,9 m FT. C. Stewa@nliadtor Inspet%or
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Reactor Projec.t Section A .
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' Approved:
hh M D. M. Hunnicutt, Chief
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Insoection Summary ;
Inscection Conducted May 10-July 1. and Seotember 9-22. 1923
- (Recor 50-445/E3-27)
Areas Insoectec: Special, unannounced inspecti.on of alleged improper construc- i:
tion practices expressed by Robert L. Messerly in an afficavit dated February 3, 1983, prepared for Citizens Association for Sound Energy (CASE) and in an ' Q interview conducted on April 14, 1983, by members of the NRC Office of pl J
Investigations Field Office, Region IV. - Ihe inspection involved 120 inspector- I hours ensite by one NRC inspector.
Additional information was received from an individ alu , who requested confidentiality, that a former B&R millwright had drilled holes through rebar {
4 witnout the reovired eng.ineering approvals. This supplemental inspection involved 10 inspector-hours onsite by one NRC inspector.
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Results: Of the seven fl.lecations recardino improper construction practices l i
expressed by Mr. Messerly, five were found to'be unsubstantiated. One h allegation regarding improper documentation was found to be substantiated, !!
however, the error was properly co'rrected by the licensee and appbar,s to lack *
- technical merit; and one allegation regarding~the posting of NRC Form 3, t ;
could neither be refuted nor substantiated, however, .it too appears to lack '
technical merit. No violations or deviations were identified. N
' e Results of Succlemental Insoection
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The allegation that unauthorized cutting of rebar during installation of "tr.olley tracks" in the fuel handling building is considered to be. a unsubstantiated. No violations or deviations were identified.
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s De t' ail s A. cersons Contacted .
Texas Utilities Services Incorocrated (TUSI) Emaicvees
- s. G. Scott,_ Quality Engineering Supervisor G. Tanley,. General Superintendent C. R. Hooton, Lead Civil Engineer ,
R. M. Kissinger, Project Civil Engineer C. Fleming, Field Engineer-Brown & Root (B&R) Emolovees W. Wright, Project Welding Engineer S. Hauser Field Engineering Superintendent ,
C. Osborn, Tool Crib Foreman The NRC inspector also contacted other licensee and'centractor employees during the course of the inspection. - -
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- Note: Prior to this inspection, separate and independent investigative interviews were conducted by members of the Office ef. Investigation 20, 1983). Field Of fice, Region IV (see attached Report A4-83-005, ' dated May .
.,B. Alleced Imorocer Construction Practices L. Messerly's
.The NRC inspector, through an interpretative review of Mr. R.
affidavit, dated February 3,1953, and his statements curing his interview, determined that there were seven specifically alleged -
April 14, 1983, matters that receired a detailed inspection effort to assess their tec merit and/or their pctantial . impact cn safety-related systems, component, and structures.
The seven areas of NEC ccacern which Mr. Messerly alleged tc have cccurred are summarized as follows:
- 1. That S&R employees crilled undocumented and unauthorized holes that cut through reinforcing steel and that such Mr.
drilling and Messerly provided cutting a
was ,
ccpy done at the directicn of supervisors.
of'a persor.al diary which, he alleged, refiected undecumentdd and '
unauthorized crilling.
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- 2. That ene of the mair steam 'ict: .7 Of ne adClicr. pi;J lin:- ' n a n uh0 0 7 ' :tru'.
crane, thereb} plaC %? #
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That tubular hanger / support steel anchor bolt holes were enlarged
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with a burning torch which he said was' unauthorized.
- 5. That (Richmond) anchor bolts were not perpendicular to concrete surface and, therefore, unacceptable.
- 6. That stainless steel pipe attachments were welded on piping without-an inerting purge.
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- 7. That NRC Form 3, " Notice to Employees" was not posted on three main bulletin boards.
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C. Insoection Findinos Allecation 1 .
- 1. Discussion .
Mr. Messerly stated that dur.ing his' assignment as foreman over the first crew responsible for drilling through concrete and reinforcing *
' steel (rebar) during . installation of cable tray ar.d pip'e ' hanger supports , he was ordered by his supervisors to loa'n out drill bits e and/or drill undocumented and unauthorized. holes through rebar. ,
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To 'further support his allegation, Mr. Messerly named B&R employees responsible for the alleged improprieties and those who could substantiate his allegations. 1/ ,
In'additio'n, Mr. Messerly provided the'NRC staff a copy of his i personal daily diary in which he . logged drilling of holes for electric cable trays / hanger supports and rebar cutting details. He -
stated that this diary also identified holes he drilled, in or through, rebar and concrete without having documentation and autnor-iration.
- 2. Chronolooical Findinos 1978-1982 In order to determine the magnitude of implication and the resulting findings of Mr. Messerly's allegations.
1 2/ See attscnec " Assistance to Inspec-ion Report," Report A4-83-005, data:
May 20, 1953 .
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. . 5 T.he NRC inspector reconstructed,;through the use of record archives and'
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interviews with site personnel, the onsite construction activities and QA/QC program being implemented in the specific area of concern curing the period 1S78-1979.
- 3. Rebar Cuttino Cacabilities .
The NRC inspector found from B&R purchases that during 1975 through 1982, the type of ons,ite equipment (drills) capable of cutting through rebar and available to craft personnel were restricted almost exclusively to the (water cool'ed) type diamond core drill bits (rebar eater) and associated drill motors, purchased'from Drillco Equipmer.-
Company, Inc., (Drillco) Miami, Florida. The Drillco water cooled d'iamond core drill bits purchased are hollow, tubul a r' in shape, varying in sizes frca 1/2" to 16" in diameter and from 2" to 14" in l e n'gth.
The drilling end has a series of carbide rectangular shaped teeth , impregnated with industrial diamond dust. When worn, or dull, the bits can be reconditioned and reused.
The NRC inspector found ,that the initial core drilling requirements (1975 to 1978) were under the control of the concrete department. -
Drilling was restricted to investigative' type core drilling (identif-ing concrete honeycomb, voids or cold joints) in the base mats (NRC
, Inspection Report 445/446/76-04 dated Apri1~20, 1976).
In late 1977, record archives contain copies of'the original " Core
~ Drilling Procedure," MCP-13, dated September 27, 1977, and issued for implementation April 21,.1978. The procedure was develo' ped for core drilling through walls and slabs for the purpose of installing pipe sleeves, conduits, instrumentation sleeves, etc.
Penetrations which were shown on' drawings or included in design documents prior to .
! concrete placement and inadvertently omitted, or penetrations which, were added by the architect engineer (A/E) but for which the installa-l tion information was not available to.the field prior to concrete placement were covered by this procedure. The procedure was applicable for all core drilling required in the plant. Core drilling was assigned to the mi11 wright department.
The procedure and its cont' rolling document, " Core Drill Request Form," requires delineation of exact location, size and rebar location, and contains review and approval signoffs. This procedure continues to be the principal core drilling' procedure (Revision 3, dated December 2,,1981). However, curren't policy (as determined by :the cognizant project civil engineer and reflected in documented records)
' is the assignment of core drilling of 2-1/2" diameter and larger to the mi11 wright department and 1/2" to 2" diameter core drilling to the steel fabrication department drilling crew. The NRC. inspector also noted that " Core Drilling Request Forms" do not imoly rebar cutting;.in fact, rebar cutting has, for the most part, been avoided where possible as stated ~ by. the project civil e,ngineer during discus-sionswitheng(neeringpersonnel.ThisfactwasobservedbyLtheNRC
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n inspector.during hi,s review of randomly selected."Co're Drilling f Request Forms" (1978 through 1982). -
Construction records indicate that electrical cable tray, conduit j
hangers, and pipe hanger support installations were initially started 1 in late 1978. This coincides with the formation of the steel fabrica- I tion department pi,pe hanger crew (s), special drilling crew (headed up by Mr. Messerly , and the requisition of the water cooled diamon'd core drills and motors by the steel fabrication department (of which kr. Messerly was a member) on.S.,eptember 6, 1978. A record search indicated a besign Change / Design Deviation Authorization 2470, dated [
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September 5, 1978, authorizing rebar cutting for Cable-Tray suppor- !
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- No. 597. This was an initial rebar cut made on September 9, 1978, and 3 identified by Mr. Messerly in his personal handwritten diary (see paragraph 6)..
The primary anchor and fasteners utilited it CPSES for the attachment of cable tray supports, conduit supports, pipe hanger supports, etc. ,
to concrete surfaces are the "Hilti" drilled-in concrete expansion .,
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anchor and " Richmond" screw anchor. The Richmond screw anchor is positioned prior to concrete placement, whereas the Hilt'i requires
- concrete drilling and placement at 'the time of component ' installation !N (a licensee representative stated, that based on purchase orders, 1:
oyer ene million Hilti bolts 1/2" to 1-1/4" in diameter, have been "
installed to date). Drilled-in expansion bolts are bolts having expansion wedges so arranged that, when placed in a drilled hole and the nut tightened, the wedges are expanded and the bolt is securely 3 anchored.
- The mest predominant means of drilling holes into concrete for !
expansion bolts. is the use of Hilti power drills, using Hilti. carbide :
masonry bits of the same nominal site as the bolt. This form of .
drilling does not ~have the capability to drill through rebar.
In limited access areas where the Hilti power drills cannot be usec, '
a flexible Drillco crive drill with drill press / vacuum base and Drillco water cooled carbide / diamond bits are used. This form of drilling has the capabili to the steel f abrication ,ty of drilling through rebar and was restrictec department special drilling crew (headed :y Mr. Messerly from September 1978 through October 1979).
For these.two methods of drilling,,no authorization is required for Hilti bolt installations (other than an approved hanger support installation " traveler" with its accompanying location drawings). A design change authorization is only required if relocatien 'is. beycr.c the drawing tolerance limits, or if rebar is encountered and reovires cutting. Constructi'on quality programs of this nature rely heavily on each incivicuals personnal integrity to achere to crescribec proccoure recuirements.
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. 7 ,i A ,research of purcha'se orders for 1978 through 1979 conducted by tne NRC inspector, indicated that only seven (Drillco) power drives that facilitate water cool .ng capability were purchased during that time frame. Two were issued to the millwright department and five were ,'
jssued to the steel fabrication department (under the control of Mr. Messerly . Mr. Messerly requisitioned (f rom the S&R warehouse) h three drill machines, with water cooling splash guards, and one flex E shaft unit on September 6, 1978. An additional flex shaft unit was
- requisitioned by Mr. Mess'erly on October 6, 1978.
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In discussing the method of dr~illing with the Drillco water cooled I diamond bits with cognizant site personnel, the NRC inspector was h
, informed that when drilling with the diamond core bi.ts, water coolino E is mancatorv. The water provides two primary functions: it removes 5 dri,lling debris (concrete / steel) as drilling progresses, otherwise the drill bit would bind; secondly and most important, without water l-cooling, the drill bit will readily " burn up," particularly when attempting to cut through rebar steel.
j In addition, a drilling i foreman stated that, drilling e,quipment is heavy and bulky and f drilling set-up time (mounting to walls or ceiling) generally takes
- half an hour to one hour. .W hen drilling, the water cooling creates a
- concrete / water mist deluge requiring crew members (normally two) to f
, wear rain type outer protective clothing. 5
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- 4. Diamond Core Drill sit Control . 0 y
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" In verifying the purchase and control of the diamond core drill ' bits, d the' NRC inspector reviewed 21 B&R purchase orders awarded to Drillco y dating from January 13, 1978 through February 13, 1980. [s The NRC inspecter found that 'of the total 21 purchase orders, .10 l requisitions were initiated by the steel fabrication department .
h-general superintendent, representing 293 core drill bit purchases, /
and 11' purchase orders were intiated by millwright superviscry .
, personnel representing 122 core drill bit purchases. [
i In reviewing the accompanying warehouse recuisitions contained in !
each of the purchase order files, the NRC inspector noted that in the i case of the steel fabrication department orders, all recuisitions bore the signature's of Mr. Messerly or his department personnel. ,
Correspondingly all equipment ordered by the millwrights was issued to and signed for by a cognizant millwright toreman. j The NRC inspector conducted an inspection at each of the respective department tool crib areas (mi rights ano steel fabrication). The millwrights maintain a tool r' area enclosed b,v heavy cauce wire screen and a locked counter access. The tool crib attencant maintained 'a clip board type log specificaliy for the ccntrol of Dril.ico diamond core bits. The.lo.g icentifiec the-individual, along with checko'ut and return dates ~. Entries in tnis' log cate back to October 16, _978.
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.3 The steel fabrication department maintains a small separate building W' where the hanger installation crew controls the drilling equ'ipment and bits. The NRC inspector observed that the Drillco diamond core bits were separately stored in a large wooden cabinet with an acccmpany- (
ing combination lock. t discussed with the cognizant The method foreman.of control over drills and bits was '[
The foreman stated that he had I been in charge of diamond core bits and the fabrication department dril. ling. crew since April of 1982. He stated that he did not'cuf any r,ebar without an approved " request for rebar cutting" form, which he j further demonstrated by utiliz,ing.an inprocess form dated June 14, 1983, No. 135. The NRC inspector determined that this was in acco-cancs with the prescribed procedure, CC-P-47, " Request for Rebar Cutting,"
dated June 17, 1981.
In interviewing former supervisors, foremen, and members of diamond core drilling crews 1/, all interviewees stated that the present method of controlling diamond bits has been in effect since the initial purchese of Drillco bits; i.e. , only cognizant supervisors, <
foremen, or drill crew members have access to the diamond . bits (these a interviewed included five former members of Mr. Messerly's drill ;~
crew). ~ '
- 5. i: 4 Procedure Reviews and Procedure Imolementation i.
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' During .the inspection, the NRC inspector reviewed S&R procedures and
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procedural implementation applicable to concrete core drilling and y drilling requirement; for Hilti bolt installations. j 1
Included in the review were the original versions of issued procedures $
from archive files that were applicable during 1978 and 1979. t 5
- Applicable procedures reviewed included the following: -
i, B&R Procedure 35-1195-CEI-20 "Installa-ion of 'Hilti' Orilled-In e!
Bolts," dated May 31, 1978; ij, B&R Procedure 35-1195-CEI-20, " Installation of 'Hilti' Drillec-in Bolts," Revision 8, dated January 26, 1983; }
TUSI Procedure QI-QP-11.3-2, " Cable Tray and, Conduit Hanger !I Inspection," dated June 3, 1978- tj
- .i B&R Procedure 35-1195-MCP-13, " Core Drilling," dated September 27, "
, 1977;
- BER Procecure 35-1195-MCP-13, " Core Drillinc," Revisicn 1. da 20 April 21,-1978; TUSI Procecure CP ,QP-11.2, " Surveillance and Inspection of j ConcreT,e Anchor Soit Installation," cated Detemoer 12, 1979; t
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9 B&R Procedure 35-1195-CCP-47, " Request for Rebar Cutting," dated June 17, 1981; -
TUSI Procedure QI-QP-11.2-1, " Concrete Anchor Bolt Installation,"
dated December 13, 1979; and G&H Specification 2323-55-30, " Structural Embedmer.ts."
The principal construction procedure applicable for Hilti bolt installation was B&R Procedure 35-1195-CEI-20, originally issued May 31,1978. Section 3.2.1 s'tates, " Expansion bolt holes shall not be drilled into concrete reinforcing steel unless approved by the G.ibbs & Hill, resident engineer or his representative." This require-ment has been retained in all subsequent (eight) revisions to the p ro,cedure. The statement is currently found in Section 3.1.2.1 of Revision 8, dated January 26, 1983. .
In discussing the method of " engineering approval" established,in the period 1978-1979 with the cognizant project. civil engineer, the NRC ,
inspector was informed that an " Interference Task Force" was established' .
in. September of 1978, composed of three TUSI project civil engineers -
who coordinated any design changes or rebar cutting with the cognizant onsite, A/E Civil Design Engineer. Where interference between the expansion' bolt and reinforement was encountered, the bolt location was generally adjusted within the tolerances al.loked by the design drawings, otherwise a design change / design deviation authorization
- (DC/DDA), design change authorization (DCA), or a component modif-ica' tion change (CMC) was initiated and issued. The various forms of design change documents have subsequently been reduced to the DCA and CMC forms of design change approval. Where. Interference with reinforc-I ing steel cannot be avoided and the cutting of rebar is requir.ed.. the approval authorization is initiated by the A/E site project civ.il . .
engineer who evaluates all requests for cutting rebar. The criteria for such evaluation is based on design parameters determined by the A/E, Final design approval for any rebar cutting remains the responsi-bility of the A/E's New York office. j The.A/E site project civil. engineer maintains a CMC DCA issuing log, for rebar cutting. The earliest entry noted by the NRC inspector is CMC 0188, dated October 3, 1978. The information ,on the DCA or CMC;,
i.e., number of reber cut, size and location is transferred to a separate set of building structural, drawings especially established for showing "as-built" rebar' cutting entitled "rebar drawings-cutting criteria." In interviews with the cognizant.A/E site project civil engineer assigned during 1978-1979.1/, the NRC invest 1gators were informed that although requests to cut rebar came from a number of different B&R craft personnel, he, almost always, gave the approving CMC to Mr.'Messerly, since his crew did the rebar cutting. He further stated that he had no know. ledge of rebar cutting without
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- engineering approval. The NRC inspector subsequent 1.v conducted a detailed review and documentation verification of the above proce-dures. .
3
- 6. .hesserly's Diary (Loo) i, During the interview on April 14, 1983. Mr. Messerly provided the NRC
, investigators with a copy of his personal diary log entitled, " Start o.f New Crew and New Operation Rebar Cutting Detail." The diary consists of 24 handwritten pages. of columniation entries on standard
+
8-1/2" x 11" paper dating f rom September 7,1978, through October 17 - !
1979. Five columns delineating print numbers (cable tray / hanger i
, ' support numbers); building location; rebar cut; day and date; and l position (floor.. wall, flex, DC/DDA, DCA, or CMC number) were recorded j by Mr. Me s s e r 1.y. In addition, various notes regarding work activities are intersperseo thoughout the 24 pages.
During a detafled review of the diary, the NRC inspector observed that (barring errors due to legibility) Mr..Messeriy recorded drilling !
a total of 2976 holes associated with 415 hanger / supports. Of the 2976 holes drilled, 280 rebars were cut. This means th'at.rebar recuiring cutting was encountered in less than 10% of the holes P drilled. All rebar cuts, as noted by Mr. M.esserly, were identified by,either a DC/DDA, DCA, or a CMC. A total of 84 such authorizations '
were identified. f i
i Twenty one of these rebar cuts wera related to nonsafety related buildings; therefore, the NRC inspector did not review these carticular authorizations. In addition, of the 2976 holes :
orilled, 247 were identified by Mr. Messerly as being in the turbine building. .
Of the remaining 63 documents authorizing rebar cutting, the NRC inspector made a random selection of 22 authorizaticas for a comparative verification against Mr. Messerly's tiary. The NRC inspector verified 132 rebar cuts identified in the 22 authoriza-tions. In all cases, the location, si:e, and number of rebar were identified on the DCA or CMC. In addition, all 132 cut recars were traced to, and identified on, the specific building structural drawings, "rebar drawings cutting critef i a," with the corresponding authorizing document number.
There was no rebar cutting, as identified by Mr. Messerly in his diary, that does not have a corresponding authori:stien numoer.
1* was also observed by the NRC inspector, that a hancwri ten note in.the diary (assumed to be written by fir. Messerly states "Orcered to criil by (name withneld) - floor S~.W.I.' Adjacent to the date July 23, 1979, and Har.ger/Sucport Numoer SW-2-035-00'-J03R.
Uncer the rebar cutting column Mr. Messerly n'otec, "Ncne ?".
Mr. Mes se r1'y also noted.that eight holes were cr"il'.ec. Durine O
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an investigatica of' this particular support (SW-2-035-004-J33R) in' the service water intake , structure (S.W. I. ), ~the NRC inspector found that the support was delete'd on July 30, 1950. !
.The original bolt holes were subsequently grouted and concrete j surfaces painted. It is assumed that, by indicating a. question mark after his notation, Mr. Messerly was-not a witness to the [!
actual drilling of the specific holes drilled by his crew
, members, and since seven persons formerly associated with 1 drilling operations have stated 1/ that they have no knowledge /
of unauthorized retar cutting." The NRC inspector did not pursue il this matter further.
- I i
t I't was also observed by the NRC inspector that, during a I verification review of the 32 DCA's and CMC's identified bv the Hr.' Messerly.'s diary, CMC 3307 identified 48 rebar cuts in' the i service water tunnel alone. This was also mentioned by. l hr. Messerly during his interview. All 48 rebar cuts were traced
.i to the design change authorization documents. L Although Mr. Messerly's diary consistently identified the -
percentage of rsbar cut, the .establishec~ G&H design criteria y considers any reduction .in individual b,ars a 100% loss of the
- a bar.
The NRC inspector found no unauthorized rebar c'utting identified' f by Mr. Messerly in his handwritten diary. . -
- 7. Concuision - Alleoation 1 .
q
.I Nr. Messerly 3 allegation that B&R employees drilled undocumented and j unauthorized holes that cut through r.einforcing steel could no't.be , .
3 substantiated for the following reasons:
- a. Mr. Messerly's statements lack sufficient specificity as to who he " loaned" the water cooled diamond drill bits to cut rebar, or who specifically ordered him to cut rebar when and where.
Former supervisors deny ordering Mr. Messerly to " loan" out drills or cut unauthorized rebar, nor did any of the five former, crew members support this contention.
- b. In the. event an unauthorized p'erson did use a' water cooled diamond bit, it is highly unlikely that cutting of rebar woule be accomplished without' the accompanying water cooling drive eouicment, or if a drill bit was "loanec" for drilline concrets only, it is conceivable that drilling would be -successful
. without water cooling,-but not necessarilly resulting in defective wo r kma ns hip. -
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- c. Although Mr. Messerly implied that his personal ~ diary contained identification of unauthorized and undocument rebar cutting, unless shrouded by omission or misinformation, the NRC inspector could not identify a rebar cut that was not authorized by {
DC/DDA, OCA, or CMC.
d h
- d. Although the method of diamond bit accountability / control !
exhibits a weakness, the need for relying on individual pers'enal i integrity would not be diminished. The inspection findings did not, nor do not, suggest indiscriminate cutting of rebar was ,
done. Documented records' exhibit a purposeful avoidance of rebar interference. Furthermore, the Messerif diary demon-strates that less than 10% of the recorded total holes drilled by his crew encounted rebar that recuired cutting.
There inspection,were no viola'tions or deviations identified in this area of the
'Aliecation 2
?
- 1. -Discussion - -
l Mr. Messerly stated in his affidavit of February 3,1983, and in his interview on April 14, 1983, that he had wi'inessed the use of the -
- dhit I reactor containment building polar crane by a pip,efitter supervisor in relocating a main steam line in a manner that put undue tension on the pipe. In addition, Mr. Messerly provided the names of persons involved with the movement of the steam line 1/.
- 2. Conclusion - Allecation 2 Although B&R personnel named by Mr. Messerly contradicted his ' allegation
- 1/, the NRC inspector conducted an independent review of'the onsite documented records regarding this matter.
It was observed by the NRC inspector that the specific 32-inch steam
'- line mentioned by Mr. Messerly is , Loop 1, Line number MS-1-RS-001-1302-2, and the reactor building polar crane was utili:ed in a vertical lift to assist repositioning a'section of this permanent piping. The licensee has maintained a documented engineering record of the specific line movement. The NRC inspector noted t' hat the movement of the line was necessary in order that a large section of temporary piping (attached to the steam generator feedwater no::le and previously used for water flushing) be removed and to relocate the perman'ent section of the main steam line that had " sagged" cue to the weight of the temporarly installed flushing pipe. The record foider contains meeting notes (memorancum) which reflect discussicns -ith westingneuse (NSS Supplier) and the cogni: ant A/E representatives pricr to the work activity, in addition to establishing engineering limitations andaccep'.aqility. The -line was moved on January 15. 1982 under the
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. 13 supervision of the field mechanical engineering group, and was wi'inessed by an engineering representative:who observed the installation; and use of the dynamometer (to register crane lifting loads) thrcughout the operation. The lift connections and applied forces were recorded and retained in the file. The, lifting points were consistent with the hanger locations to simulate the permanent support. system. The as-built configuration was analyzed for stress and the acceptability of the line confirmed. In addition, the recent completion of the
" Reactor Hot Functional Test" did not reveal any undue stress conditions.
This allegation cannot be substantiated.
No violations or deviations were identified in this area of the inspection.
A11eca' tion 3
- 1. Dis'cussion .
During Mr. Messerly's interview on April 14, 1983, Mr. Messerly (in referencing his personal diary) stated that.he initially started drilling rebar based on,the instructions of three part memos, DC/DDAS, and subsequently the CMC. Although Mr. Messerly did not allege that
- the CMC was an improper document, he did' imply that the DC/DDA and D the three part memo were not the right. documentation.
. . 2.* Conclusion - Allecation 3 .
- During the NRC inspector's review of Mr. Messerly's personal dia'ry (pa'ragraph 6), it was observed by the inspector that the first four holes (rebar cuts) he drilled on September 7 and 8, 1978, for cable tray hangers 596, 642, and 643, Mr. Messerly made the notation "RFIC". In. researching the archive files, the NRC inspector f,cund the original Request for Information or Clarification (RFIC) documeots,.
Request Nos. EH-14 and EH-15, dated August 29, 1978. Although.the instructions authorizing rebar cutting contained in the RFIC were
~ correct and authorized by the cognizant A/E design engineer, the RFIC document was not the " approved" method of authori:ing a design change. The NRC inspector noted that this documentation error was corrected by CMC No. 00766 issued on October 16, 1978 The original document, the RFIC contained a note to this effect. On September 9, 1978, Mr. Messerly's diary contains a reference to DC/DDA No. 2489 for two rebar cuts for hanger No. 597. In researching this particula'r DC/DDA, the inspector found that DC/DDA No. 2489 was not related to hanger No. 597. The NRC inspector 'found that DC/DDA No. 2470 correctly identified the rebar cutting authorization. The location and number
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of rebar cut was also traced to CMC No. 01146, dated September 20, 1978, and to the as-built builcing structrual drawings, "Recar Drawings Cutting Criteria." This allegatioh by Mr. Messerly was substantiated; hewever, the original cocumentation error .as icentifiec a short. time after its occurrence and immediately corrected anc did _
not-impact on plant s a f e~ ty.
Ne violations or ceviations were icentified in tnis area of the inspection,
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Allecation 4 *
- 1. Discussioh During Mr. *55 serly's interview on April if,1983, and as stated in his February 3,1943 af fidavit, Mr. Messerly indicated that anchor bolt holes in tubuivr steel hanger supports were enlarg'ed with a burning t, orch in order to compensate for the angularity of the :.
previously installed (Richmond) anchor bolts, rather than r'edrill the h'ol e s .
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- 2. Conclusion - Allecation 4 The result's of the interviews of eight B&R employees, whose names were provided ,by tir. Messerly and alleged to have knowledge concern-ing the improper use of cutting torches on hanger material, is contained in the attached " Assistance to Inspection Report." 1/ Two individuals stated that they recall an instance during a redesign modification of a hanger where it was discovered that holes had been enlarged by a burning torch, therefore, that portion of the hanger was scrapped. - -
During the onsite followup inspection.concerning this~ matter, the NRC 2 inspector discussed the use of cutting" torches with the licensee's wriding engineers and f acrication department engineers. The NRC inspector was informed that the use of cutting torches is not prohibited, provided it is done in accordance with prescribed S&R procedures and/or ASME,Section III, subsection 4211 (thermal cutting). In the-
- case of tubular hanger installations, the preferred method of correction for hole misalignment .is to drill offset hole (s). This has been done on many occasions via the design change CMC document. The cognizant project engineer, responsible for approving and issuing CMC's'for hanger modifications, stated that he knew of no CMC that involved authorization of hole enlargement or hole relocation on tebular hanger supports utiliting thermal cutting; however, thermal cutting has been permitted as necessary on other types of carbon steel suoports, base plates, etc.
The NRC inspector conducted a walk-through of the containment builcing to examine accessible installed tubular hangers, specifically in the plant areas mentioned by Mr. Messerly curing his i'hterview. The inspector examined approximately 60 hangers at the 905' and 860' elevations,in the containment build'ing. Although limited in visual accessibility to each 1" or 1-1/4" drilled hole in each section of the tubular hangers , the NRC inspector did not find any hole ihat - a's enlarged by a cutting torch.
In addition, tne NRC inspector-discussed the subject cf tnermal cutting with the- cognizant OC supervising inspector wno was invcl.ed with inspec.tions of tubular hanger installatien during 1980-1952 .
TheQCsuper'v{sorstateo, that neitner ne nor any -inspector disccverec o
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15 an installed tubular hanger hole. having been enlarced bv a cuttinc
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torch. , pI Sased on the lack of specificity by Mr. Messerly, the lack of . j :i corroborative testimony by Messerly's w'itnesses, interviews by the '
NRC inspector with cognizant site personnel, and the (limited) examinations of installed hangers, this allegation could not be substantiated.
There were no violations or deviations identified in this area of the inspection. ~
A11ecation 5
- 1. Discussion D'uring the interview on April 14, 1983, Mr. Messerly stated that Richm6nd Insert anchor bolts installed between elevations 905' and 860' in the reactor containment building have not been installed perpendicular to the concrete surfaces and,'therefore, are unaccept-able. In addition, Mr. *Messeri,y stated, ". . . whatever. angle it is, .
t we'would drill it at that a'ngle so that it would come through the (
tube (i.e. , tubular steel) and when it comes out the other side of the tube, it comes out as close to center as we could get it."
Mr. Messerly also stated, "Ju'st go out there and pull any . ..
studded rod out of there, pull three of them and two of. them is { sic]
crooked." .
. 2. Conclusion - Alleoation 5 During the NRC inspector'r onsite follow up of this matter, the '
inspector found that the L&R Procedure CP-CPM 9.10, " Fabrication of'
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ASME-Related Component Supports," (or,iginal issue 12/28/78) is the primary construction installation procedure to be implemented and followed by the hanger installation crews. .The " General Fabricati:n '
and Installation Recuirements," Section 3.3.1.2 " Installation i Tolerances," states in part,
" Field Fit Tolerances '
"The tolerances discussed above shall be maintained for support fabrication activities. However, if during the installation, the support won't fit, the members may be " field fit" provicec the piping and elevation tolerances shown below have been maintained. All other tolerances regarding axial location, a l i gnme r.t . and base plate attachments must be adherec to unless otherwise notec on the drawing."
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t In addition, Section 3.3.2, states in part,
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". . . Surfaces of bolted parts in cuatact with th'e bolt or nut shall have a slope of no more than.1:20 with respect-to a plane 5 normal to the . bolt axis. Where the surface of a high strength i*
bolted part has a slope or more than 1:20, a beveled washer ,
shall be used to compensate for the lack of parallelism."
r- .
During discussions with the cognizant design engineers concerning the i s'pecific installation requirements _ relative to the limiting perpen- f.
dicular angle of the anchor b67ts (Richmond Inserts), the NRC (
- inspector was informed that the limiting perpendicular angle cf '
anchor bolts (Richmond Insert's) to the concrete surface is,' aside a from the requirements of Section 3.3.2, is handled on a case-by-case ~
basis. No enl,argement of the existing predrilled holes in the a
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tubular steel is permitted without prior approval; however. . numerous i CMC's have been issued wherein offset holes have been authorized. l The approval is generally accompanied by th'e requirement that the i large square bolt washer be welded in place using a 1/4" fillet on 2 sides. The cognizant engine'er further stated that the requirement ]
abdve only applies to sa'fety-related supports (ASME III*, Subsection NF, Classes 1, 2, and 3 component supports). Enlargement of the 3 predrilled holes in the , tubular steel .f,or nonsafety supports is ]
permitted without prior eng,ineering approval. -
1 Since Mr. Messerly specifically referred to the 860' and' 905' elevations in the reactor containment building in his testimony, it a was assumed by the NRC inspector that his specific concern was in
- 1 reference to the permitted angular.ity of the safety related Richmond Insert anchor bolts. Mr. Messerly was apparently of the' opinion that a the anchor bolt should be precisely perpendicular to the concrete surface, which appears to be a misunderstanding on his part of the .
installation specification. Furthermore, Hr. Messerly's testimony '
reflected his awareness and knowledge of the procedural requiremer.ts, therefore, it must be assumed that Mr. Messerly did not ignore procedural requirements and did not indiscriminately enlarge pre-i drilled tubular steel holes in safety-related supports. Further, that any offset or enlargement done by Mr. Messerly had prior engineer-ing approval as required. As noted in Allegation 4, paragraph 2, the NRC inspector conducted a limited visual examination of approximately 60 hanger' supports at the 905' and 860' elevations'in the containment building. During the examination, the NRC inspector found no hole enlargement.s or anchor bolt angles '(parallelism of bolt nut surface to washer surface) that appeared to violate'the above instaliation specifications. It is concluded by the NRC inspector thc*. this specific allegation appears to be more of a casign concern by Mr. Messerly, .than an improper installation c:nstruction practice having been implemented by him.
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17 The need for the Ricncond Insert anchor boIt to be precisely perpendicular.to the concrete surface .is not required according to the documented criteria established by the licensee, therefore, this 7
concern alleged by Mr. Messerly is not substantiated.
Tnere were no violations or deviations identified in this area of the inspection.
Allecation 6 hi
- 1. Discussion -
- During Mr. Messerly's interview on April 14, 1983, Mr. Messerly !
stated, "There was a welding foreman out there that done [ sic) a lot of welding illegally without occumentation, such as lugs on pipes without purges." In addition, Mr. Messerly identified three individuals who would have knowledge of attachments (lugs) being '
welded on pipe without an inerting purge 1/, with specific reference to the.832' elevation in the reactor centainment building. *
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- 2. Conclusion - Aliecation'6 .
0
- As noted in attachment 1/, two individuals identified by Mr. Messerly 7, .
}
.'- were interviewed concerning their alleged knowledge of lugs imprcperly I welded on to' stainless steel, pipe without purging tne pipe wnen h reouired.
, activiti es . Both interviewees denied any knowledge of improper welding-
- During this inspection, the NRC inspector conducted an onsite follow up, review of this matter.
e The licensee's pipe welding procedures had been establ.ished pri.or t,o {I the initial piping installation early in the construction ph se. The procecures and implementation activi-ies had been inspected and documented on numerous occasions throughout that phase of construction by the NRC senior resident inspector and independently by NRC regional staff personnel.
Therefore, during this inspection, the NRC inspector limited the review to pipe welding purge reouirement established by the licensee.
The NRC inspector observed that the primary weldidg procedures
- associated with safety related piping are B&R CPM-6.9, Appencix 0,
" Welding and Related Processes," and B&R Inspectio'n Procedure.
QI-QAP-11.1-26, "ASME Pipe Fabrication and In'stallation Inspection."
Paragraph 3.5 of this procedure, states, in part,
" Purging shall be caintained for welding of attachments tc 3tainless steel oiping having a wall thickness of 1/4 incn or less for field welcs only. This may be waived on a case-cy-case
~ basis.by the PWE and Engineer'ing. Thi s wa i,,v e r s ha l l b e coc ume n t e'c on the' applicable WDC."
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In discussing this matter with the cognizant project' welding engineers, the NRC inspector was informed that when a welding purge is reo.uired for attachment welds, the requirement would be noted on the weld da'ta card (WDC) and a " Hold Point" established for verification by a QC inspector. However, in instances'where the purge is waived, an interof fi.ce mem.o waiving the purge is attached to the WDC. The interoffice memo is controlled by a chronological numbering system and Yiled within the permanent record files. It was f urther pointed
, out by th'e B&R welding engineers that the ~ majority of stainless steel p'iping at the 832' elevation have pipe wall thickness in excess of the limiting 1/4" wall, therefore, an inerting purge would not be recuired for weld of attachment lugs.
Based on the fact that prior NRC inspections have not identified a concern in this area,,that Mr. Messerly's allegation lacks speci-ficity (i.e. , ' safety related piping, pipe line numbers, size, location, etc.), that the majority of stainless steel piping at the 832'
~ elevation excpeds 1/4" wall thickness, and that persons named by Mr. Messerly did not support the allegation, this allegation was not substantiated.
.There were no violations or deviations identified in this area-of the inspection. .
., 3 Allecation 7
- 1. Discussion
' ~
IbwasobservedbytheNRCinspectorinMr.Messerly'saffidavitof February 3,1983, and during his interview on April 14,~1983, he stated he did not remember seeing the posting of a copy of NRC Form 3, " Notice to Employees," on three main ensite bulletin boards. -
- 2. Conclusion - Allecation 7 The Code of Federal Regulations, Part 50 (10 CFR 50), was revised by 47 FR 30452 to add 10 CFR 50.7, " Employee Protection." The change was published ~ July 14, 1982, and hac an ef fective date of October 12, 1982. An important element of the cnange is that of a require-ment to post NRC Form 3 at locations where the form can be readily viewed by employees on their way to or frcm their place cf work.
During a prior review of.this matter by the NRC senior resident.
inspector (SRI) (see NRC Inspection 'eport 50-445/S3-03; '
50-a46/e3-01, oated Marcn 28, 1983), the NRC Form 3 was observec Cy One SRI to be pos ed in early January 1953. Mcwe . e r , the precise date (between October through January) of the posting ~ of NRC y
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il Form 3 could not be established. S&R personnel records indicate l th~at Mr. Messerly was terminated on December 6,1982. j 1-The allegation cannot be refuted nor substantiated. Furthermore, i
. the matter lacks any technical merit relative to an impact on the i safety of the plant. .
I
' There were no violations or deviations identified in this area of the !
inspection. I t
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SUPPLEMENTAL INSPECTION September 9 - 22, 1983
- 1. Discussion As noted in th,e attached assistance to NRC inspection report, yr
~~ " Supplemental," dated September 7, 1983 2/, during the course of an unrela'ted investigation, information was received that a former B&R millwright had drilled holes through'?shar without the required
. engineering authorization.
Curing the period September 9 - 22, 1983, the NRC inspector conducted'an onsits follow up on,this matter.
From the information provided by the interviewees, the NRC inspector identified'the spegific " Trolley Tracks" 2/, as the drum and spent filter handling equipment, liner transfer trolley process aisle rails, located -
- on the 810'-6" floor level, in room 252, of the fuel handling building.
- The system is currently in the preoperational testing phase; however, E this system is not a safety-related system.- In reviewing the construction documentation rscords regarding the installation of the rail
- assemb-iies, the NRC inspector found that the rail base plates,, rail
. clips, drilled Hilti anchor bolts, and rails were installed per drawing,,
" Anchoring Details for Radwaste Solidification System," Figure 39, Sheet 5 of 5, and by direction of Design , Change Authorization (DCA) 7041, Revisions 4, 8, and 9, dated October 22, 1980, October 28, 1982, and November 11, 1982, respectively. It was observed by the NRC inspector that Drawing Figure 39, Sheet 5 of 5, contained the following pertinent notes, "2:
Expansion bolts and base plate may be moved in east-west direction to avoid interference with rebar running in north-south direction. " and, "3: For rebar running in east west direction, holes may be drilled through the uppermost #18 bar @ only one rail location and expansion bolts shall be installed through the hole (it is assumed that bar interference shall occur at any one rail only)."
2/
See attached assistance to inspection report " Supplemental," dated September 7, 1983, Report No. A4-83-005. -
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. . 21 In addition, Revision 8, of DCA 7041 directed the addition of extending the len'gth of the rails froi the original 24'-3" long to 27'-6" (3'-3" section added to east end); also, Revision 9 permitted the modification of Hilti bolts (shortening) to avoid cutting any additional rebar.
The NRC inspector met with the superintendent of the millwright department and interviewed millwright craft personnel that were directly involved in installation of the rail assemblies. During the interviews, the NRC inspector found that the rail assemblies were installed during two different time periods. Although actual dates were not established, it appears that the initial 24'-3" rail sections were installed in late 1982 and the 3'-3" extension sections were installed early in 1983. The individual interviewed on September 1, 1983 2/, stated that he was not
' ware of the 3'-3" extension of the rails; therefore, his reference to a
his work activities involved only the installation of the initial 24'-3" rail sections.
In addition, it has been established that, aside from the core drilling foreman, five millwrights and one millwright foreman were directly involved in the installation *of,the base plates and rail assemblies. -
(Three of the millwrights and the. millwright foreman were individuals ,
also interviewed.) -
. . - 2. Insoection Findinos
- As a result of the onsite followup inspection,, records review, and intervie'ws wit,h personnel, the inspection findings are as follows:
- a. As stated by the millwright interviewed on. September 1, 1983 2/, and acknowledged by other millwrights, only the east west, #18 rebar, running parallel with the east-west rail, was drilled through'to ,
accommodate the 1/2" Hilti bolts which secure the rail base plates to the 810'-6" floor. This rebar cutting was authorized pe'r Note 3, Drawing Figure 39, Sheet 5 of 5, DCA 7041.
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- b. The alleger stated that the 3'-3" extension rails were installed in accordance with the DCA 7041, and that-rebar.was drilled through for the south rail Hilti bolts by the steel fabrication department drilling crew and that no unauthorized rebar was cut during installation of the 3'-3" rail extension.
- c. '
The millwright foreman stated that during installation of the 24'-3"
' rail base, plates, the steel fabrication department drilling crev v foreman arrived with the "rebar eater"Jdrilling equipment by h'imself, therefore, he assigned one of the millwrights to assist the drilling crew foreman in drilfi3g 'Lhe holes in which rebar required-being cut. He further stated that only rebar that was authoriled to
'be cut per the DCA was cut. -
- d. During the inspection, two of the millwrights interviewed stated that north-south rebar was encountered during drilling Hilti bolt holes for base plates for the north rail and that since cutting of the particulas rebar was not permitted by the DCA, the Hilti bolt was modified (shortened) as authorized by Revision 9 of DCA 7041.
The' NRC inspector had a 'TUGC0 licensee representative locate and -
verify the moaification of the specific Hilti bolt. The bolt was located at the west end .of the north r.a,il and further supports the millwright's contention that no unauthorized rebar was cut.
- e. In discussing the use of the core drilling equipment wit'h the craft supervisory personnel, the NRC inspector was informed that there is no hard set policy as to who can or who cannot use the core drilling *
' equipment as long as the equipment is used properly and the drilling being done is authorized and directed by craft foreman or supervisory personnel. As with the millwright interviewed September 1, 1983 2/, wherein he stated that when the core drilling foreman did not show up, he (the millwright) completed drilling the remaining (approximately 10) 1/2" diameter holes for the south rail base plate Hilti bolts.
f.
The' NRC inspector found no evidence to support the allegation that unauthorized c'utting of rebar was done during installation of the
" Trolley Tracks" for the drum and spent filter handling equipment.
{
- 3. Res ul ts '
i The allegation t. hat unauthorized cutting' of rebar was done during
' i.nstallation of the drum and spent filter han.dling equipment process aisle rails is considered to be unsubstantiated.
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e N U C LE A R R E G U L
- T O R Y C O N'J.'. ! S S IO N ., , ?
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OrrtCE Or INVE STIC A11oNS Fit LD OFFICE. RE GtON !\
. 61) R Y A N PL A Z t- D RIV E . S ult E SCTC P;.
A R LING 7 0r texts n:11
! .' . 8 '
ASSISTANCE TO INSPECTION REPORT f g k May 20, 1953 h BJECT: COMANCHE PEAK Pg ALLEGED IM? ROPER CONSTRUCTION PRACTICES g
, PORT NUMBER: A4-E3-005 . h.
On February 3,1953,/ provided an affidavit to the Citizens
- Association for Sound Energy ( 'SE), an intervenor that included three alle- Q gations regarding improper construction. practices b Brown & Root personnel at
~
t' the Comanche Peak Steam Electric Station. alleged the followine:
- a. That Brown & Root employees drilled undocumented unauthorized hcies throuch retar, and such cutting of rebar was done at the direction of supervisors!
- b. That the main steam line pipe in Unit I was moved using the polar crane, thereby plac~ing the pipe under unsafe tension. .
- c. That a Brown & Root employee used a cutting torch on hanger material in violation. of procedure. -
1 it was contacted by the reporting investicator, and a 5 On April 6, 19E3,.
- meetinc was arranged with for the foll'owing' day. M contacted "q reporting investigator on April 7, 1953, and recuested t.he meetino be changed to April 8, 1953.
On April 8, s1983, NRC 01F0 Director R.K. HERR and the reoortjng investigator j me t a restaurant in Fort Worth, iexas. was accompanied :
by a CASE representative, and A husband. ~j f wasneo to ricord the meeting; however, OlFO:RIV was not previously informed of her intended presence nor of her desire to record the interview. 1 01F0 did not have a recorder, and in accordance with'Ol's policy, the I meeting was resch'eduled. On April 10, 1953, arrangements were made to use a room a.t the U. 5. Attorney's office, Fort Worth, Texas , and for a court recorter to transcribe the interview of FN On Acrii,14, 19E3,t as interviewed at the U.S. Attorney's office with Wg oresent. testimony was taken under oath, Attachment (1),
ano W aos her own personal recording of the interview. In his testi-many,'[ expanded in detail on his original aliegations. 6 named Brown & Root employees responsible fo,r the alsleged improprieties'and inose who could substantiate his' allegations. M aiso identified numerous employees by title, and agreed to later provide the corresconding names. yhen he was able to refresh his memorv with his personal recercs locatjd at his resicence. 4 6 also provid'ed the NRC with a copv of a ice. T T ' Q e clained that he maintained this log te document the cut-ing ci retar at Coranche Feat. (Note: =cest;/did not allege that all the entries in the log cocumented unauthorized cuts through rebar, but rather that some of the entries in the luo nav have been for holes orilied .nrcuch rebar that m2y r.ct hav.e had t.h ap'Drepr; ate accompanying authorizations.) During this intarview,q')made a fourth alieoation regarding instsnces o:
UfW( 3Q { { d_.1,NSh ( 3 PO)
--mmanon
i'-E3'-005 . -
Page-Tse *
, i Erown & Root welders failing to purge stainless stee'l pipes during welding.
5.
On at his April 21, 1983, a copy of the recorded testimony was mailed to%
residence. On April 27,1983, Mwas contacted by HERR, ano acknowledged receipt of the transcript, but p6stponed givi'ng the names of the
' Brown & Root employees he had identified by title in the transcript. M stited he had not as yet had an opportunity to read his entire testimony. On April 29, '1983,6 was again con,tacted by HERR, but he again postponed providing the names, explaining he was very busy. On May 1, 1983, the reporting investigator telephoned Mat his residence, and /M_
provided twelve, additional names of Brown & Root employees at Cc:5anche .
Peak he alleced had knowledoe of unauth'6rized cuts through rebar.
- 6. On May 3,1983, intervips' were initiated s at the Comanche Peak site addressing i the for, or four allegations.
having knowledg .g'eIne of allegationsidentified 38employment Review of individualsrecords allegedly res determined that eighteen individuals were n'o longer employed at Ccmanche ?eak.
7.
Between May 3, 1983 and May 10, 1983, 19 Brown & Root employees and 1 Dravo ,
Concructors Inc. employee (formerly employed by Gibbs & Hill) nimed by Ie sere interviewed, and signed, sworn statements were taken from 13 of, them. One..Erown and Root employee interviewed left on vacation before a signed, sworn statement was obtained from him, and his testimony was reccrded in the form of a Resu.lts of ]nterview. One Piping Design Serivces Inc. .
engineer was identified by the reporting investigator as responsible for !
the movement of-the main steam line.
executed a signed, sworn statement. . This engineer was interviewed, and S. Nine individuals alleged to have knowledge of improper, unauthorized ' cutting of rebar were in.terviewed and.provided sworn statements. These individuals denie'd having knowledge of rebar that was cut without proper authorization. A IC-h incividual responsible for issuing the Ccmponent Modification Cards (CMC),
authorizing cuts threugh rebar, was interviewed and provided a sienet, swcrn statement cenying,hnowiedge of any procedural violations. Testim 3ny iden-ified
' instances where rcbar was accidentally cut, but this testimony also established
.nat in these instances, CMC's were ob .ainad af ter the cu s were reportec to the enigneers. There was no testimony received indicating that holes were drilled or rebar was cut without proper documentation, and no evidence was found to contradict the testimony of these individuals.
- 9. Three. Erown & Ecot imployees alleged te have knowledge concerning the-use cf
-he polar crane to mcve a portion of the main steam line in Unit I were irter-view.ed and provided signed, swcrn statements. A Piping Design Services in:.
engir.eer responsibie for relocating the steam line, proviced .estim:ny ci nis ev31ca.icn and direction cf the relocation of *.he iine. The tes:im:r.v taken from tnese four witnesses indicated that the relocation of the miin s' tea 'ine was dcne under the djrecticn of engineers, and was accompiishec 1 remove stress on the line ands te return.it to its designeo iccation. R testi.T ny was recievec to indicate that the line was "colc thrung" or installed unter stress.
A4'52-025
. Page Tnree" .
- 10. Eight Brown & Root employees alleged to have knowledce concerning Two witnesses the improper use of cutting torches on hanger material were interviewed.
stated they remembered an instance during the redesign of a hanger in which a piece of ~ tube steel was discovered to have had the bolt The testimony holes of the two enlarged witnesses using t a torch, which was a procedural violation. i indicated that this hanger was scrapped because of the procedural violation, The other six had no knowledge of improper I and was replaced with new material.
l use of cutting torches or hangers. ,
I 11.
Two Erown & Root employees were interviewed concerning their alleged knowledge 0 f
of lugs . improperly welded onto stainless steel pipe without '
Eny instances where weiding Was done on stainless steel pipe which required purging by procedure unless a " purge deletion" was received from .
All of the employees mentioned by in his affidavit who were s.till i
- 12. l employed or available for ir,terview den.Ted the allegations made .
by No evidence was uncovered during,these inquiries which indicated deception on The w.itnesses ranged f rcm pipe fitter. helpers .to the part of the wi.tnesses.
Erown & Root superintendents. A Piping Design Services Inc. engineer and the Dravo Constructors. Inc. project manager also provided testimony which contra-
~
._ dicted.the allec.ations. .
No further inquiries
. 13 . .
The signed, sworn statements are maintained in 01F0:RIV.
are an*.icipated unless staff inspections identify additional pertinent 4 information that would tend to substantiate the allegations or discredit the p
r P inte rviewees . .
y[ Attachments:
y Testimony of - dated 4-14-83 .
f, (1) e (2) List of Interviewees f
h (3) 1.ist of terminated ecoloyees identified in Attachment (1)
REPORTED BY: . h.c - [ ,
H'. 'brtoks Grif fin,1/ rest 1cator 01 Field.0ffice, Reg $on. IV' p
APPROVED BY:
.[/[h .9 Ricnarc K. herr, Director 01 Field Offica, Region !Y I cc: W. '.:a rd , 01:DF0 - w/ at .achments W . Collins, ElY - w/ attachments .
E. Johnson, RIV - w/cs attachments s
e
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NUCLEAR REGULATORY COMMISSION
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j O F 8 8 C1,68 ' NVI511Ct-ilDr45 8 st.* w of f 801 RE G'C'r. av s )I*. ' 7 " * =(l. ,. ~ * .
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......- A R. ; tN G T ON Ti A A5 7C*.
ASSISTANCE TO INSPECT 107. F.EPORT '
" SUPPLEMENTAL"
. September 7,1953 SU5JEti:
COMANCHE PEAK STEAM ELECTRIC STATION: '
ALLEGED ISPROPER CONSTRUCTION FRACTICES .'
REPDF.T- HUMEER: A4-E3-005 s-
- 1. Duri nt '
the course of an unrelated investigation, information was re:eived, free
- an'indivicuaT wnc recuested confidentiality, that a former Srown 1 Root, Inc.,
riilwrigh.
had drilled holes throuch rebar without the re:;uired er.cineerine.
a .nor..:ation.-
2.
Dr. September ,1,19E2, this raillwright was interviewed and provided information wherein he stated hejiossibly drilled holes through.rebar in.a concrete floor without a Com:cr.er.1 Modification Card (CMC) er a Design Change Authcrization (DCA). H6 explained that he drilled about 10 holes in January 1552 while instaliinc* 22 metal plates usino a core drill. He said these cetal plates
,,ere used to secure the trolley tracks located ir. the Fusi'Etndlino Evildino as par: c' the 1:aste Monitor System. ~
cere drii'. b;rrowec from the Core Drilling He statecCrev.. that he and his crew used a The piib.rigr. saic that -
- :ne trciley ins hcies mace witr. the cere crill were located cr. tr.E soetn. es t cerner of tracks. He explained tha the biveprints ht use: a Anori2ec .
the cutting of orje r,iece of rebar or. tach hele, anc' he adcec that it is his belief the holes were orilled properly.
~
- 3. TneResuitsofinterview: with the f ormer Brewr. & Root mili.<right is main
.in 01 Field Office, Region ]V.
Ana:h.er.- (i .' - F.esuits cf Ir.terview witt r,.f ilwrigh.1, dateo Ee ..er.5e* 1,19E2.
REPOR7EO EY:
y h,.r- , -
'D rot t'.s c r i;; 1 r. , g . e s *,; c a ,O r 01 Field Difice ~
Region iY
- % ed f- ATFROVED BY:
i.'. cna r e i.. c.e rr
- g . .n. .c .e..<. . .
.,...tre:tcr kecicn l'i cc:
. . J. ka rc , 01 : DFC..- '
.. attachment) [ 1,\ ds o d J+~~l39 )P F. C. Eati, 01:0F0 W. i. Coliir s , T.iv tw
\((w/ attachment)
/a tta chr.ent )
T. F. iesterman,.i. V (w/c atta:r. ment)
.s ATTACHMENT 2
. _ _ _ . _ . . - _ . _ __ ...m_. .. . _ - _ _ . . . . _ . ___m 4
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- t INSPECTO.k'S REPORT -
N/
Office cf In:;>ection and Enforcemint
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, ENCLOSURE 2 SAFETY EVALUATION REPORT .
93 COMANCHE PEAK STEAM ELECTRIC STATION CONTAINMENT POLAR CRANE TES' TING -
In a Letter dated November 21, 1983, the applicant for Comanche Peak provided information to show compliance with the guidance kC of NUREG-0554, " Single Failure P r o o f _. C.r an e s f o r Nuclear Power Plants" relative to the preoperational testing of the contain-cent polar crane. For single failure proof cranes, compliance with the testing guidelines of NUREG-0554 also satisfies the testing guidetines of ,NUREG-0612, " Cont ro L of Heavy Loads at Nuclear Power Plants." Our evaluation of the Comanche Peak polar crane tests relative to the testing guidelines of NUREG-0554 a and NUREG-0612 is provided below. The overrlL acceptability of ~
the heavy load handling facilities at Comanche Peak as described i.n ' applicant submittats dated August 7, 1981, October 8, 1981, March 1, 1982 and June 8, 1983 is being reviewed separately, under Multiplant Item C-10, " Control'of Heavy Loads." The revie,w of the containment polar crane against the other NUREG-0554 criteria for single failure proof cranes will be performed.
under Multiptant Item C- 15 , " Control of Heavy Loads, Phase II."
The applicant's November 21, 1983 Letter provides the= testing history of the cont,ainment polar crane. Originalty, the polar crane was rated at 499 tons and during the preconstruction phase
\
[. .
of Comanche Peak underwent static and dynami'c tests at 100 percent of rated Load. The load was raised and Lowered, rotated 360 degrees and moved across the width of the containment. .
Prior to preoperational testing, the polar crane was derated to 175 tons consistent with the load requirements for plant opera-4 tion. ,
The main hoist was disassembled and repaired, and the gear train in the main hoist was modified for the , lower rating. Sub-sequently the polar crane was statically tested at 125 percent 1
of the maximum critical load (McL) as. required by ANSI B30.2-1976 for cranes that have undergone significant modifications. Ho,w- g ever, in telephone. conversations with the staff,.the applicant
] requested an exemption for the full'rar.ge of dynamic testing
- r.equired by ANSI B30.2-1976 as referenced in NUREG-0612. Full
! dynamic testing would involve raising and lowering the test load, rotating the bridge through 360 degrees and moving the trolley , .
.across the full Length of the bridge while supporting the test i -
Load. The applicant expressed the concern that safety-related equipment in containment could be damaged by falling lead ingots l that had been strapped together t'o form the test load. After 4
discussions with the staff, the applicant performed a dimited-l range dynamic test as described in the November 21, 1983 submittal.
l The dynamic test consisted of raising and lowering the test load
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(125 perc ent of MCL) with the main hoo'k at variou's speeds. The ,
1 bridge was rotated a minimum of 10 feet and the trolley was moved l a minimum of five feet at stow speed. The applicant stated that the'se tests resulted in moving the trolley and bridge gearing "'
- ~ ~ -
- through at least one revolution. -
Based on the above, we conclude that the polar crane tests meet the intent of the NUREG-0554 a nd NUR EG-0612 t e s t i ng guidelines and a'r e , therefore, acceptable. The preconstruction testing at 499 tons ade'quately tested the* structural integrity of the bridge-
. e and trolley members for crane operation. The later testing at 125 per cent' of MCL adequately tests the main hoist gearing, as modified for the derated capacity, and adequately tests the bridge and trolley gearing for plant operational use. The acceptability of the containment polar crane relative to the other criteria of NUREG-0554 for single faiture proof cranes witL be evalusted under Muttiplant Item C-15, " Control of Heavy Loads -
Phase II."
\.
8
. b
- C July S. 1981
- i
_ Ca b g- -
Al ?.
Intimidation 30 1 31
(( ,'y AM Miscellaneous 23 6 29 Cr'.
4-k AD g [ Design of Pipe / Pipe Supports I g 19 0 19
~
C AV Vendor /Ceneric
-w I'
18 0 18
%,-p i' Al fest Program L *815 13 4 .
17 AA linfeperulent Assessment Program , y 0 y Total 403 57 460 G
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CDNTR0ttED COPY QA/QC (General) P. 15 -
j C0f1ANCitE PEAK NUCLEAR PO%TR PI ANI 1 AttICATI5NGM7CFTWE5TICATTDRNRY
{
TA5E CROSS REF./OR COMPLET1074 SOURCE ALLEGER-DATE REC [lvfD
- 80. IRACKING CATEGORY l-7 SCliEDULE SOURCE AttEGATION CR CohCERM ACll0N/SIATUS ANCN CONFID BN/04TE SYSifM NO. LEAD OPEN COMPLETE DOCUMENT PAGE AQ-85 Abuse of forms ICR's, IR's Open t
, .rmt MAR's ttut should t,e 1 GAP #4 hCE*s ARI AQ-86 QC Ew3 i neers supervisor Open . K makes it dif ficult for QC 1 GAP witness ! #6 to do followup inspections ART to ICR's AQ-87 Craft (not QC) 5 d:Can Open X *
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, that QC refuses to sign ARI j off I
!. AQ-88 Illegal aliens were used Open I 1 GAP witness I #8
? to da Q work without paper-work ARI AQ-89 150 drawings no longer Open I
., I,elng sent to Gites & Hill 1 GAP witness 0 #1 bet are being corrected on ART site by B&R '
AQ-90 Iterative design process X has broten down, engineers 1 GAP witness 0, A, C are not performing any ARI #2, #3 analysis on design (hanges AQ-91 Imprcper inadequate train- X
, ing of testers (no super- 1 GAP witness H #12 ART
! vision of tester in the i
field) 9
^^
CONIROLtED COPY QA/QC (General) P. 16 COMANCllE PEAK NUCLEAR POWER PLAN 1 AllICATT5HT If4D75TTEVE5TTCIT!51[3IM4ARY TASK CROSS REF./0R COMPLEi!0N SOURCE ALLEGER-DATE RECEIVED NO. TRACKING CATEGORY l-7 SCitEDULE AttEGATION CR CONCERN ACTION / STATUS ANON CONEID SOURCE 5 EN/DATE SYST[M NO. LEAD OPEN COMPLE TE DOCtNENT PAGE AQ-92 Packages arriving to SIE's open x with DCA's issued against 1 CAP #15 drawings. (Aux. Relay ARI -
Room)
AQ-93 Print changes with no Open x DCA's in package arriving 1 GAP witness H #17 at SIE ART AQ-94 No procedure to ensure Open x that SIE has proper 1 .
CAP witness H #18 bcumentation
- i AQ-95 Possible misuse of NCR's Open X to cover more than one 1 GAP witness A, D #24
- traveler" ,
ART AQ-% Use of open ended Field Open X Job Order " blank check" 1 GAP witness J #29
- 40 or 04 makes work ARI appear to have been pre approved AQ-97 Permanent documentation Open I is teing pulled out of the 1 GAP witness C #32 vault and new NCR's written ART on old problems because the documentation did not match the log book '
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CD. AtLEGATION OR CONCERN TRACKING CAIEGORY l-7 SCHEDULE ACil0N/ STATUS ANON CONFID BM/DATE SOURCE SYSTEM NO. LEAD OPE N COMPLETE DoctMENT PACE AQ-103 In mid-May 1984, design Open X changes not incorporated 1 Current O! Investigation le the drawing were de- ART D. Norman to R. Bangart leted from the open design ctange logs printed out on i the computer. These changes !
were critical to ongoing inspections and construc-tion and work may have t,een performed w/o all the nec- i i
essary information. -
AQ-104 A DCC supervisor authorized Open X the release of individual 1 Current O! Investigations documents "for reference ARI D. Norman to R. Bangart only," and soon most of .
the document requests were made in this manner.
A week later this authori-zation was suspended.
AQ-105 Ihe F5E-159 cable tray Open X hanger drawings were 1 Current 01 Investigations switcted f rom civil con- ARI D. Norman to R. Bangart trol to DCC. These draw- .
ings were not accompanied '
by logs showing wt.at docu-mentation was against each drawing. For a period of
- time there was no sign out logs for F5E-159 drawings.
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change documents into start- ART tions D. Norman to up work authoritations (54As), R. Bangart
{' and NCRs ha e been written because 114 changes had not
~ been reviewed and distributed as controlled abcaments. !
- . AQ-107 Until $ bout March 19S4, Open a craft and QC telephoned 1
- Current 01 Investiga-ARI
- requests for individual tions D. Norman to d,cuments using a tra.eler R. Bangart !
nust.er which ef fectively i circum.ented tie require- *
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i seats of DCP-3. hten the instructions for the satellite's release of documentation for travelers were changed to require craft to bring the hard ,
copies of tre travelers * [
to its satellities to obtain the documents, the requests were reduced dramatically.
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l 1 - Prior to OL -
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4 - Zero Power Testing
- 5 - tow Power Testing 6 - Power Ascension Testing '
7 - Full Power i
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At t E CATIUiOJ.570 FI NVETJI" T10NGihAR Y l i
TAst CROSS REF,/OR COMPLEIION SOURCE TRACKING ALLEGER-DME TECEIVED NO. AttfGATION CR CONCFRN CAIEGORY l-1 SCilEDULE SOURCE
, - ACIION/SIAltl5 ANON CONFID BF/DAIE SYSTEM NO. 1EAD
- OPEN COMPLETE DOCt5 TENT PAGE E. / AQW-67 Doctmentation errors on Open ,
K welds for the steam 1 CAP witness H #2.
ART geenrators j
AW- 63 Supports on tanks to RI\ O 1 i
1 CAP witness C, I #3.
f.eatenchangershasunder-\, pen i
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It[Y 10 COMPLEi!0N CATEGORY:
1 - Prior to 0L * '
i 2 - Fuel Loading -
3 - Initia1' Criticality 4 - Zero Power Testing 5 - Low Power Testing e
6 - Power Ascension Testing 7- Full Power j
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\ Att ECATTDfrAE75FTRW5TICATICNNRY l
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' SOURCE ALLEGER-DATE RECEIVED NO. TRACKING CATECORY 1-7 SCHEDULE AtLECATION OR CONCERN ACTICN/ STATUS ANGN CONTID SOURCE BN/DATE SYSTEM HQ. LEAD OPEN COMPLETE DOCUMENT PACE AC-44 Cracks in concrete pad Initkaldispo- RIV-84-A-0029 beneath the reactor vessel siti'on 01 Report i A-46 2/28/84 ART Q4-84-016 Q4-84-016 P. 1 l
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N0_ AtlEGAll0N OR CONCERN CATECORY l-7** SCHEDULE ALLEGER-DATE RECEIVED i
ACil0N/51Allis ANON CONFID BN/DATE SYSTEM NO. LEAD OPEN COMPLETE SOURCE DOCUMENT PACE AQO-43 Coatings Inspector Certifi- IR 84-08 x cations and Iraining may be contains report 1 5/2/84 Anon. phone call inadequate of IE inspector AR1 received by HQ Opera-visit to coatings tions Center Duty inspector training Officer after RIV work-session ing hours. Tape record-
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4 ELECIRICAL AQE - 2 AE - 5 7
Key to Completion Category:
1 1 - Prior to OL I
2 - Fuel Loading l i '
3 - Initial Criticality .
4 - Zero Power Testing 5 - Low Power Testing
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! 6 - Power Ascension Testing 1
4 7 - Full Power a
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- AltECATTURFAfG75FINVE5TICATIURr5MhARY TASK CROSS REE./OR COMPLETION NO. SOURCE IRACKING ALLEGER-DATE RECE!vED AltfGAi!ON OR CONCERN CATEGORY l-7 SCHEDULE AC110N/SIATUS ANON CONFID BN/DAIE SYSTEM NG.
SOURCE LEAD OPEN COMPLETE DOCUMENI PAGE AE-18 Cables are being " butt- Open spliced" in violation of X 1
CAP #6 procedures ART AE-19 Overloaded cable trays Open X t GAP witness A H #5 ART AE-20 Violation of cable tray Open 1 separation requirements 1 GAP witness H #1 (incongistent procedures ART regarding cable tray '
separation) '
AQE-21 Duel numerical designation Open X system in electrical / mechan-
- 1 GAP witness H #13 ical. area has resulted in ART massive confusion regarding ,
as-built. (System numbers assigned for both components and not accurately reflected in each systems package)
AE-22 Unauthorized " cable Open pulling" to substitute X 1
GAP witness H #16 d>-
cable that came up short ART (control room) e i
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V CONIROLLED COPY Electrical P. 5
,t COMANCliE PEAK NUCLEAR POWER PLANI I
At t E CATTURFAND75R~IRVE5TitATMIPf4AR Y TASK CROSS REF./OR COMPlE110N ALLEGER-DATE RECEIVED
- SOURCE TRACKING NO. AllEGAll0N OR CONCERN CATEGORY l-7 SCHEDULE SOURCE Aci!ON/SIAIUS ANON CONFID BN/DATE SYSTEM NO. LEAD OPEN COMPLETE DOCUMENT PAGE AQE-23 Extensive revisions in the X electrical post-construction 1 GAP witness I #25 verification inspections ART AE-24 A cable tray held by a tem- X 1 CAP witness anonymous porary hanger fell several levels and ripped out instru- ART #33 mentation wires going to the control room n
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July 5, l'381 PIPE & PIPE SUPPORIS (NON W/D) s AQP - O
' AP - jir k EL Key to Completion Category:
1 - Prior to OL 2 - f uel Loading '
4 3 - Initial fritica'lity 4 - Zero Power Testing 5 - tow Power festing 6 - Power Ascension Testing 7 - Full Power
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' SOURCE 1 RACKING CAIIGORY l-7 NO. AllEGAll0N OR CONCERN SCHE DULE SOURCE ACTION /51Alus ANON CONfID BN/DATE SYSTEM NO. IEAD OPE N COMPLETE Doctt1ENI PAGE
'3 AP- 18 On pipe support MS-1-004- Initial
' 4* *.' ., X 1 IR 84-05 007-C72k an excessive gap dispostion IR RIV/ARI Hartin/Oberg of 1" or more was noted 84-05 i during the fit up of the bottom kicker and out
' , irigger. This gap was i
welded in violation of fit up limitations.
i AP-19 The web of the structural Initial dispos-4 X 1
- 1R 84-05 support member (M-17) was tion IR 84-05
- RIV/ ART Martin /0 berg cut out in the wrong location
. Instead of reporting the problem and repairing accord-ing to procedure, it was '
filled in by unauthorized welding.
s . " AP-20 Pipe support MS-1-003-009- Initial dispos- X P' C72k. lhe stanchions of tion IR 84-05 1 1R 84-05 this item were welded on RIV/ARI Martin /Oberg the inside with "hellarc" .
and back welded because of excessive cutof f at " lower point" This was filled in by welding, grinding, and polishing.
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CONIROLLED COPY Pipe & Pipe Suppuits. P. 5 COMANCHE PEAK NUCLEAR POWER PLANT AttECATTDfl5 KHD7DlFIRETICATTUH5 EllAMARY 1ASK CROSS REF./0R COMPLEll0N SOURCE TRACKING ALLEGER-DAIE RECEIVED NO. ALLEGAll0N OR CONCERN CATEGORY l-7 SCHEDULE SOURCE-ACTION /SIATUS ANON CONF!D BN/DATE SYSTEM NO. LEA 0 OPEN COMPLETE DOCUMENT PAGE
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fA .# v AP-21 Pipe Support H5-1-003-010- Initial X C12k The bottom saddle cut dispostion 1 IR 84-05 in four pieces. The left IR 84-05 RIV/ARI Hartin/0 berg hand back piece did not fit due to curvature of the pipe. The piece was heated, and a 20 ton hy-draulic jack and hammering were used to bend the metal Into place.
- p, --j E AP-22 Pipe support MS-1-002-005- Initial X C72K. lhere was an dispostion 1 IR 84-05 excessive gap in the steel IR 84-05
- RIV/ARI Martin /Oberg of the support box. The gap was between shim plates but the shim plates were enclosed without the problem being re-ported or corrected.
f2gAQP-23 Inspector for approx. 2500 Open Itr to pipe supports were not IUECo being 1 IR 80-15 para 6 p adespiately trained or prepared by RIV ARI OL Hearings i
supervised in June 1984 Iranscripts at 4132 and 4180 i
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, NO. Alt [ Call 0N da f,0NCFkN SCHEDULE ALLEGER-DATE RECEIVED ACl[0N/SIATUS ANON CONfl0 BN/DATE
, All-14 SYSTEM NO.
@D OPEN COMPLETE SOURCE DOCUMENT PAGE Cable tray hangers have Open X 1 CAP #4
( not been installed where
,': gf designed therefore, stress ARI 1
analysis is inaCCurale and do not have pioper material traceability.
' All-15 Use of non-Q material in Open X Q components 1 GAP Witness J #28
/
- Fire sprinkler system ARI
- f. I 'b ' system done by Grinnel !
- pipe hanger , ,4 ,
AQll-16 llanger packages are being Open X 1
taken out of the vault and , 1 GAP witness H, I #31 ART
" screened" (old material
- s. is put in manilla folders
,,s so that it is not looked 4- at instead of packages reflecting all document-ation (25-50 per day)
,- Screen.ing being performed , '
by llanger Task Force and DCC clerks 4
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, A8-12 S/G laterial support Initial Olspos-
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DOCUMENT PAGE Al-31 Harassment and intimidation Open K for accurately doing job, 1 GAP witness 11 #2 and contacting the NRC 01 i
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) MISCELLANEOUS i
l Key to Completion Cateocry:
j 1 - Prior to OL
/ .
2 - fuel Loading '
3 - Initial friticality 4 - Jero Power Testing
- t l 5 - Low Power Testing 6 - Power Ascension Testing i 1 - full Power e i
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' OPEN COMPLETE SOURCE DOCUMENT PAGE AM-24 Damage to stainless steel Initial dispo-rods in upper internals RIV 84-A-0029 I A-46 2/28/84 sition in O! Rpt. RIV
- components of reactor Q4 84-016 and Q4-84-016 P. 1 vessel (Thermal couple IR 84-08 IR 84-08 i
columns) 4 AM-25 Polar Crane problems with Initial dispo- RIV 84-A-0029 electrical cables and sition in 01 Rpt. 1 A-46 2/28/84 crane rotation RIV QA-84-016 p.1 Q4-84-016 AM-26 Prenotification of site Open X
,1 visit of ASLB (3/20/84) Anonymous letter GAP ART witness 0 #1 AM-27 Prenotification of all Open i X
NRC audit inspections -
1 GAP witness J, I, H. K #5 i ART j' AM-28 Past Design Practice Open K 1
Concern - Construction Former Contractor Employee, l
9"' ART 5/29/84 Allegation Data Form Received by J. Blake - R!l AM-29 Possible inadequate Open Ril Alternate Analysis X Ril 0081 1 Former contractor transferred to ART Procedures used in Region IV employee 3/27/84 Design Applic. Allegation made to W. Liu of Region II.
S 9
- r.i, s Ja w-77, 1984 l
l IESIING PROGRAH t
NUMBERS AT-14 -- AI-17 l
Key to Completion Category 1
.I 1 - Prior to OL 2 - Fuel Loading
- 3-Initialfriticality 4 - Jero Power Testing
- 5 - Low Power Testing l
6 - Power Ascension Testing 7 - Full Power i i
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CONIR0ttED COPY lest law Program P. 5 COMAhCllE PEAK NUCLEAR POWER PL ANI I
At t [CAI[0NFAf4D7647ld[$IlhAI]6R7FORMARY *
! IASK CROSS REF./0R COMPLEll0N SOURCE
& AttEGATION OR CONCERN ACIl0N/$iATUS ANON CONFID BN/DATE TRACKING CAIEGORY l-7** SCHEDULE ALLEGER-DATE RECElvfD AT-14 SYSTEM NO.
M OPEN COMPLETE SOURCE DOCUMENT PAGE Test Program for pre- Open X operation and startup 2 GAP witness H #8 is flawed ART l Al-15 Functional testing is not Open X proper, only doing con- 2 GAP witness H #9 Linuity (acceptance) testing ART t
(CR latest safety injection pumps)
AI-16 System turnover is uncon- X teolled activity. ,_
,2
- Gap witness H #10
^- ART AT-11 Example of problems from ,
Open X Hfi Test Deficiency Report
- 2 Gap witness H #19
,- (IDR) #853, IDR 555 ART 4
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d 2 MR. GRIFFIN: Which letter are you refer i
.- 3 to? Is this a letter you wrote cr you received?
4 .
6: No, sir. Eitner the Attorney
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5 General wrote it or tne Anti-Nukes. !
6 (At this point in the proceedings M h i
7 paused to check his files for the letter and handed it to g g
8 Mr. Griffin.) 6 9 MR. GRIFFIN: Okay. I believe I have seen this ,
0 10 before. This was a request for information by the State of o i
11 Texas on certain issues and problems at Comanche Peak.
12 Who sent you this letter?
13 M: M Do you know her?
14 MR. GRIFFIN: Yes. !
i i
- ,/ 15 m I am sure everybody knows her.
1 i
16 MR. GRIFFIN: She is the intervenor for CASE at 17 Comanche Peak. I
. l 18 N Weave welcing I woula say was One .
19 rule rather than the exception. Most of the welding '
20 inspectors I don't think knew weave welding from anything 21 eg. Where they got a lot of tnese inspectors and also 22 the welders, they send them to school for two weeks. You
(
l 23 know, tney would be making moonshine or cutting cedar l
24 fence posts out in Glen Rose and two weeks later they 25 would be an inspector or a welder.
TAYLOE ASSOCIATES 1625 i STRIET, N.W. . $UITI 1004 tu WASHINGTON D.C. 20006 h.$a ah ;I i I (202) 293 3950 i L . I I ' ~ 8 ,f t " -
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N . 2 So at tne end of two and a half years you have 3 got a big hole in tne system somewhere and you can't even 4 start up because they threw a critical valve away.
5 . MR. GRIFFIN: To go back to something we have 6 discussed previously for a second, you were talxing about 7 the lack of experience of some of the welding inspectors.
8 You were mentioning weave welding. Did that conclude what 9 you had to say on weave welcing?
10 M: First off, I saw very few, if any, 11 inspectors carrying any kind of welding mask around with 12 them to watch what the welders were doing, and it is kind 13 of hard to tell wnat a welder is doing unless you have got 14 a mask to watch him. I had one and I used to watch them
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15 all the time and you would see them get down tnere they 16 are supposed to be welding stringer beads and tney would I;
be going oack anc forth lixe that -- (Indicating).
18 The only time tne inspectors were down there !
19 was for the fi_t-up and maybe the first pass, the root 20 pass. When they would finally finish their cover pass they 21 would look for pits and what-not, you know, and put some 22 liquid penetrant on and that would be it.
23 MR. GRIFFIN: What systems were they doing this 24 welding on?
25 N Everything that was not X-rayeo.
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TAYLOE ASSOCIATES I b' 1625 i STRUT. N.W. - Suf71 1004 WASHINGTON. D.C. 20006 (202) 293 3950 l I !
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T 1 MR. GRIFFIN: But what systems were they 2 working on at this time?
3 m: Nuclear piping systems, the whole 4 nine' yards, you know, the boron system ---
5 -
(At this point in the proceedings M 6 again looks through his files and pulls out a document.)
3 7 All the boron lines, the sampling system 8 lines, the waste gas collecting system, the chemical
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9 volume and control system, the containment spray system. ;
10 They built most of that thing off tne plant over in the l i
11 backyard somewhere in bits and pieces and then drug it in. l l
12 The residual heat removal system, some of that, the boron 13 recycle system.
14 There was one instance, you can call it a 15 vertical pipe enase, and there was probably 20 different 16 lines there that were in some stage of construction. All 17 .of them were uncapped, wnicn they are not supposed to de i
18 unless they are actually pnysically working it. They are i
l 19 supposed to keep a cap over tne end of tne pipe. There was 20 grinding going on and these grindings were going into the j
21 line. They were pouring concrete and tney had a lear in i 22 the form and tnere was concrete in the lines. There was t3 trash all over the place and sitting right in the middle
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24 of tne whole thing was this big fat welding inspector !
I 25 eating a banana or a candy bar or something like that,
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! , TAYLOE ASSOCIATES b 1625 i STRIET. N.W. - SUITI 1004 l
WASHINGTON. D.C. 20006 3 (202) 293 3950 i
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I htt_-uctoi her te t: c c:3 vcidti E:urcntatien fren ti.c henger 7ach:cer when they ce=e 1.ck fron A'C reviev .E place then in large nanille c:4velopes cnd cark t$.e=' "Eist:rica.1".
Once this hac been d:ne, the pech ce: cnd envelopes cre returne2 to the vanit. I believe
. this is being done so that to anyone reviewing the hanger packages, it vill not appocr that the hangers have been reworked as nany times as they have been. Wen ed why this was being done, told ne that I
the person I talked to p. aid they did not pc.rticularly want__guyQnMng at the old docunentation.
24 Y cently, both assistant project nanagers, sent about 10 or 11 nev QC Inspectors to help review. .
told to train the= for review. refused to do ..
, so.
I thi
- this.was done for tvc reasons: 1) since these QC Inspectors are new they are core likely to sign 'off on docunentation without **4rg-questions and without b.oving if procedures are being violated; and 2) 3&E gets nore noacy for verk done by QC Inspectors than it does for verk done by Docu=ent Centro 11ers, so I believe, as do the Docunent Controllers,.
) that they are troining their replact=ents.
i There are aise sone other incidents which have happened recently the.t concern me. Cn Lyril 3, and'I carried hanser p h ;es to the pe n nent' records vault. W ile ve vere talking with a vault supervisor, came by and stopped. He showed us an HT film pack 26e for IEC CC-2-AB-3 on weld lio. 9-1. The .
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- robic= vas that there is y veld ro. 9-1 on this I
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Q Um-huh.
3 A And it's just more or less that it wouldn't apoear 4 that that much effort had gone into that one carticular 5 You've got thousands of hangers out there. This is hanger.
of that plant, is 6 one thing that has escalated the cost 7
the number of revisions.
8 Q And rework?
8 A That's right. And it would just appear that there 10 wasn't as much rework as there was.
11 Q Okay, also in your affidavit here, you mention l
-l OA4 in which you and @ were taking hanger o
g 12 a recent incident .
C-W 13 packages to the records vault, and you were talking to
./ 14 some other people --
15 A Yes.
16 Q -- and they showed you a package or ISO that 17 contained no weld?
18 A Well, he had a film package, you know 'for this 19 . weld; and he started laughing and said, you know, the funny !
20 part about this: thereis no weld 9-1 on this IS_Q." ,
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21 And h ays, "Well, where does it belong, then?"
22 And he says, "How can we find out? How do m ;
l 23 k3cw2."
24 Q Okay, we've got the ISO number here.
25 A Yuh, you sure do.
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. 2 A The film package is what you want on that, and 3 then check it with the ISO.
4 Q Okay.
5 MR. IPPOLITO: That's all part of the package, 6 though?
7 THE WITNESS: No. He had that in his hand by l 8- itself. I don't know if he put it with the package; I don't 9 know.
10 BY MR. GRIFFIN:
11 Q For the record, that's ISO 16-2-AB-3, and it 12 refers to Weld No. 9-1.
13 A And then he said -- they asked me how would we 14 check this out to see that it was a good film; he says, 15 "well, I can pull it out like this, and they can say, well, 16 that looks like a pretty good weight; looks like it's pretty 17 good plastic."
18 (Laughter)
Oct !JkA% 0 19 Q. Okay, and then you give an example in here of k Q~ ll ] 20 -- a classic example -- of people not knowing -- you talk 21 about flange?
22 A Yes.
23 Q And you've given that as an example of how work is 24 being duplicated, and people do not know -- okay; that will 25 help our inspectors out. They can be on the look-out for that .
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INVESTIGATION b / y, DALLAS FIELD OFFICE k de l
REPORT OF INQUIRY J August 2,1982 l
SUBJECT:
ALLEGED IMPROPER WELD PRACTICES AT CPSES (Q4-82-0005 )
c
- 1. On June 9,1982,
, contacted HRC Region IV to report alleged weld ,
problems at CPSES. l l
- 2. On June 10,1982, M was interviewed by the reporting investigator. &
stated $was employed at CPSES as a welder from late 1977 to early 1980.
He stated he has 13 years' experience as a welder and believes that some of the weld practices he observed at CPSES will result in the plant being unsafe.
6 allegations pertained to observations he mrde while working at -
various locations at the site, although he was unable to provide any specific locations.
- 3. M made several allegations relating to the qualifications of personnel.
He stated he did not think welders (not further identified) were adeouatelv, trained and that he did not believe weld QC inspectors (not further identifiedl had sufficient welding background to qualify them to do weld inspections durino the period from late 1977 to early 1980. also stated he believes that the poorest qualitt of weld rods are beino utna at rpsrs With
'r regard to specific allegations of procedural violations, M stated that in some instances he is aware of occasions when reauf red welds are nnt accomplished r,n piping when they are at inaccessible locations (he could provide no specific date or locations). He. also stated that some weld pro-l cedures mquire that a heliarc weld be made prior to capping with stick welds.
He stated it was frequently the practice to accomplish the entim weld usino stick welds. stated that he is aware of a general location (inside turbine building, ground level, and one level below) whem a 52-inch steam line, containing " chrome molly pipe" was welded using carbon steel weld rods. M stated he and another individual had also done some repair work in this area without the required heatup being accomplished. Lastly, W sumised that if radiography of these welds was done, someone must have falsified the identification of radiographs.
- 4. Investigator's note: It is noted thathwas very difficult to communicate i
with and to understand during this telephonic interview. It was the impression of this investigator that he may have been intoxicated. M indicated he ^
could be available for a personal interview at his home.
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FOIASWENTITY K emmmxymm.__ -mmmm.x - khoe
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- 1 Q4-82-0005 2 August 2,1982
- 5. It is requested these allegations be evaluated by the technical staff to determine whether inspection effort is warranted. Investigative support will be provided upon request.
' s D. D. Liiskill, Investigator cc: J. Collins,RIV J. Gagliardo, RIV 9
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NOT DISCLOSE DO IDENTITY SOURCE OF
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CONT AINS EN TIAL
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