ML20206U635
| ML20206U635 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/19/1984 |
| From: | Hofmayer C NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML19284C882 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8607110044 | |
| Download: ML20206U635 (8) | |
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s SEER WR11EUP DOCUMEfiT C0fiTROL/ ROUTE SHEET
- I Allegation Numbers
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Subject of Aliegation (imdur))ML.fi) Mw [] ffj6dA TRT Group D J n l l& lf?h dzt u )
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Author:
C. /-h/mdWr y / J. DWifr.5
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This sheet will be initialed by each reviewer.
It stays with all revisions to the SSER writeup and serves as a routing a'nd review record.
It will be filed in the g
work package when the writeup is published.
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Group Leader Mb1Kqhyjp M %S W/'7,.
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Revision Number Final 1
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Author Tech. Editor Group Leader J. Gagliardo T. Ippolito Administrative Writeup integrated into SSER Potential Violations to Region IV Workpackage File Complete Workpackage Returned to Group Leader r
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CARDE85-59 PDR i
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4 sser aqc-13/14/15, ac-18/40/CP5 1
Revision 1 - 10/22/84 SSER 1.
Allegation Category:
Civil and Structural 15, Rebar Improperly Drilled 2.
Allegation Number: AQC-13, QC-14, AQC-15, AC-18 and AC-40 3.
Characterization:
It is alleged that undocumented and unauthorized holes were drilled through rein, forcing steel (rebar). The issue
% -.' includes all'egations relating to:-
the loan of reba'r drills without proper documentation (AQC-13),
the unauthorized cutting of rebar in'non-specific locations a
(AQC-14,AC-18,AC-40),and the unauthorized cutting of rebar used in the irista11ation of a
the trolley process aisle rails in the Fuel Handling Building (AQC-15).
4.
Assessment of Safety Sigaificance: The implied safety significance of these allegations is that, if th'ey are true, the structure integrity of the buildings may be indeterminate.
AQC-13 concerns the loan of rebar drills allegedly used for the unauthor-ized cutting of rebar.
During the NRC investigation of this matter, the NRC Office of Investigation (01) interviewed nine t'ndividua'is alleged to have knowledge of unauthorized cutting of rebar. These individuals pro-vided sworn statements denying any knowledge of this activity. These statements are a part of 01 Report A4-83-005 (May 20, 1983), which con-cludes that "there was no testimony received indicating that holes were drilled or rebar was cut without proper documentation, and no evidence was found to c'ntradict the testimony of these individuals." One instance of o
possible, unauthorized cutting of rebar is discussed in'a supp,lement to the OI report'(September 7, 1983).
This instance is discussed below in rela-tion to allegation AQC-15.
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- g Because the alleger did tiot specifically identify who made unauthorized cuts of rebar, or where this cutting took place, the TRT attempted to quantify the amount of rebar that allegedly was cut without authorization.
l In discussions with the TRT,'the alleger estimated that approximately five percent of the diamond core drill bits ordered by him were use'd tii an.
unauthorized manner.' He further estimated that one dril'1 coul'd be used to cut up to five r'ebars, depending upon the extent of cutting req' ired.
u Although'he could not be specific as to how many drills he ordered, the alleger thought that the number would be in the thousands.
The NRC Region IV Investigation of thi's issue indicated that 415 diamon'd core, drill bits were purch'asei during the period in question (IE Report 83-27). Using the actual num'ber of drill bits purchased, together with the information pro-vided by the alleger,. the TRT estimated that there could be approximately 100 alleged unauthorized rebar cuts.
Considering the large amount of reinforcing steel used in the plant, and the fact that the structures consist primarily of heavily reinforced concrete walls and slabs, the TRT determined that, if such unauthorized rebar cutting occurred, the amount involved would have an inconsequential effect on the safety of the structures.
Allegations AQC-14, AC-18 a'nd AC-40 also raise questions regarding the unauthorized cutting of rebar, but do not identify specific locations.
During the course of the NRC Region IV investigation of this matter, the a? leger provided a log book which, it was reported, would identify the unauthorized and undocumented rebar cutting. However, the Region IV inspector could not. identify one rebar cut listed in the log that I
was not authorized.
The TRT also reviewed the log and came to the
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same conclusion.
l In discussing this matter with the TRT, the alleger confirmed that there was'documentatton supporting "ninety nine and three quarter percent"oftherebarcutsidentifiedinthelog.AspartofReport
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83-27, the NRC Region IV investigator traced 32 authorizations, approximately half of the documents notea in the log for the rebar 1
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He found that in all cases rebar. cuts were properly identified on a design change authorization (DCA) or on a component
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modification card (CMC).
In addition, the 'rebar cuts were traced to and iden'tified on specific building st'ructural' drawings, with the corre'sponding authorizing document number. The TRT reviewed ten CMCs and' confirmed the findings of the Region IV investigation.
In reviewing authorizations in the log, the TRT.noted th'at certain
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CMCs involved a number of rebar cuts in one area, and selected these s.
7 for review In one case, seven dif ferent CMCs (3307, 3664, 3665, 3666, 3667', 3668 and 3669)' seemed to pertain to one area and ' accounted for 68 rebar cuts.
Npon reviewing the documentation, the TRT found that these cuts were made in 'a tunnel area in the'Fuei Building.' (Thealleger
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identified this a's a location where a large number of rebar was cut.)
However, the 68 cuts were arranged such that only S bars actually had been In another case, the log indicated 25' rebar cuts pertaining to CMC cut.
In this case, the TRT3Netermined that all'the cuts werN made on 00979.
one ret'nforcing b'ar in a support beam.' Finally, the log indicated eight 9',$
7 rebar cuts pertaining to CMC 3022..Once again, thes'e eight cu,ts were to e
one bar in a support beam. All cuts were made in accordance with the D,
rebar cutting c'riteria provided by Gibbs'& Hill.
These examp1'es also illustrate the point that a la'rge number of rebarl cuts recorded are not.,
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necessarily synonymous with an identica1 ' number of rebar actually being
'In all cases, one bar was cut a number of ' times, but adjace'nt b'ars cut.
were not.
Thus, the cuts were a.rranged to minimize the overall effect on the strength of the structure.
The TRT estimates that approximately 335 rebar cuts are indicated in the alleger's log.
Discussions with the alleger revealed that he believes he cut approximately five percent more r'ebar'than was authorized, a' number that corresponds to approximately 17' unauthorized rebar cuts.
As noted earlier, such a numbe'r would have little effect on the safety of the structures.
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6 As noted above, allegation AQC-15 identifies a specific instance. of In this case,"a former the poss1ble unauthorized cutting of rebar.
Brown &, Root employee s'tated he possibly drilled holes through rebar l
in a concrete floor without a component modification card (CMC) or a I'
design change authorization (OCA).
He explained that in January 1983 i.
he drilled approximately 10 holes about 9 inches deep Ehile installing t
22 metal plates with a core drill.- He said the metal plates were used to secure -the trolley' process aisle rails located on.the 810-foot, i
6-inch floor level in Room 252 of the Fuel Handling Building.
i A.
The TRT inspected the trolley process aisle rails and its anchoring system and observed no violations of project dra' wings or specifications.
The TRT' reviewed the reinforcement drawings'(2323-S-0800 and 2323-5-0 The for the Fuel Handling Building' to determine' the location of rebar.
drawing showed thre layers of reinforcement in the upper part of the mat, h
which consisted of a No.18 bar running in the east-west direction, in t e first and third layers, and a No. 11 bar r0nning in'the north-south direc-tion, in the second layer.
The review of the reinforcement drawings (2323-5-0800 and 2323-5-0820 reinforcement a'nd the revealed that the layout of the east-west trolley process aisle rails was such that the east-west reigforcement*
would interfere with the drilling of holes at only one location.
However, if 9-inch h' oles were drilled, both layers of the No.18 Design Change Authorization (DCA) No.
reinforcing bar would be cut.
l 7401 was written for authorization to cut the' uppermost No.18 bar at l
only one rail, but it did not reference the authorization to cut the The DCA (No. 7041) also stated that the bar.
lowermost No. 18 expansion b'olts and base plates could be moved in the east-wes't r-direction to avoid interference with the No. Il reinforcement running The information described in DCA No.
in the north-south direction.
The OCA approval 7041 was substantiated by Gibbs & Hill calculations.
was based on the understanding that only the uppermost No. 18 If the 10 holes were actually drilled 9 reinforcement would be cut.
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. g inches deep, then the allegation that reinforcement wa's cut without proper authorization may t,c valid, II w.'d fV The OCA notes that the holes were drilled to accommodate I/2 ~ inch Hilti bolts, which require a minimum embedment of 5-1/2 inches (as noted in Fig. 39, Sh. 5 of 5, attach'ed to DCA-7041).
Since th'ere K.
was no need to drill the holes deeper than 5-1/2 inches, the alleger may not be correct in stating that the holes were drilled 9 inches deep.
s.
The TRT interviewed the individual concerned about the loan of rebar drills without proper documentat' ion and unauthorized cutting of rebar at non-specific locations.
This individual did'not agree with certain TRTfindingsandp'rovidedtheTRTwithLoreinformationregardinghis concerns. At this time the TRT is further investigating his concerns; any adjustments to the existing conc 1 sion resulting fr'om this additional investigation will be reported in a upplement to this SSER.
TheTRTconcludesthat[ legations 5.
Conclusion and Staff Positions:
AQC-13, AQC-14, AC-18 and AC-40 should be closed for the following reasons:
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The allegations were not specific as to who made unauthorized cuts a.
of rebar or where the cuts took place.
b.
The number of unauthorized rebar cuts alleged,'if true, would have an inconsequential effect on the safety of the structures.
However, the results of these evaluations will be further assessed as a part of the programmatic review concerning procedures addressed under QA/QC Category 6 "QC Inspection." Therefore, the final acceptability of these evaluations will be predicate,d'on the sa'tisfactory results of the programmatic review of this subject.
Any adjustments to the existing conclusion of this evaluation resulting from the programmatic review will l
be reported in a supplement to this SSER.
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.s 6-d of Allegation AQC-1,5 will remain open until the information re d" is Texas Utilities Electric Company (TUEC) in " Actions Require provided.
i See Item II.e in the enclosure to the D. Eisen Actions Required:
to M. D. Spence (TUEC) 6.
l letter of September 18, 1984 I
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Attachments: None.
9.
Re_f_erence Documents:
IR 83-27, 9/28/83.
1.
IR 83-03, 3/28/83.
2.
01 Report A4-83-005, 5/20/83.
3.
Testimony of Alleger, 4/14/83.
b Cutting l
Alleger's Log, " Start of New Crew and New Operation 4.
5.
Detail."
Telephone Interview with Alleger, 3/7/84.
OI Report A4-83-005, Supplemental, 9/7/83.
6.
7.
OI Report Q4-84-001, 1/9/84.
8.
. Affidavit of Alleger, 2/3/83.
9.
- 10..TRT Interview with Alleger, 8/2/84.
11.
CMC-00979.
12.
CMC-2889.
6 13.
CMC-3022, 14.
CMC-3307.
15.
CMC-3664-3669.
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- 16. GTT-2863, 10/16/78.
- 17. GTN-29823, 9/5/78.
- 18. GTT-2874, 10/17/78.
19.
GTN-29641, 8/25/78.
20.
Fuel Building Rebar Cutting Dwg FSC-1000, Sht 1.
21.
DCA-7041, Rev. 9, 11/10/82.
- 22. G&H' Calc. Book Number SFB-107C Set 1, Set 10-24.
23.
Reinforcement Dwgs. 2323-5-0800.
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Reinforcement Dwgs. 2323-5-0801.
25.
Reinforcement Dwgs. 2323-S-0820.
- 26. QI-QP-11.2-1.
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10.
This statement prepared by:
V C. Hofmayer, TRT Date Technical Reviewer J. Devers, TRT Date Technical Reviewer Reviewed by:
L. Shao, Date Group Leader Approved by:
V. Noonan, Date Project Director i'm::.- rJ+:=':.1.
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