ML20211J848

Partially Withheld Technical Interview Transcript.Related Info Encl

ML20211J848
Person / Time
Site:	Comanche Peak
Issue date:	02/08/1985
From:	NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
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FOIA-85-59 NUDOCS 8606270070
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_m _E__D _I _N G S PROCE D 3 MR. CUDANS: Fcr the. record, this is an interview ~1 c:Tl ww%n!fx w m._4;na] for the purpose of providing feedback O the%n 4 a. regarcing technical review team assessment on certain 1 6 concerns raised about the Comanche Peak facility. The ' Ws %%n:an;y pD' .;%sp "mf,w q, 0" cent ,,, & n n%ru?.[J location or the interview is at the e S at the interview are Mr. Jim Malonson, Mr. Herb Livermore, .a and a Court Reporter. As k.ly[{}kih$N[A@hbJohnZudans, 9 i 10 ; a reed, this interview is being transcribed. Do you have 11 l a goed picture of what the tiRC's doing for this whole i i 12 effort.? Co you knew what the technical review tear is? i 13 l'! 5%.nh #~M'Af* J Ya= I? s. .p'Q,4fN$, M?h4 - 9 -~. - I 14 ! Q Okav. Than, I don' t have to go through it. 15 Just for the record, I want to make'sure that we under-16. stand that you are scill employed at Ccnanche Peak; this b 17 transcript is to be =aintained in strict confidence to I h protecc ycu and we will do that to the best of cur ability. 14 A Okay. a i 20 0 I would '1.<e to turn ever this meecing ncw tc e 2[- Jim Malcnson so he can cover -- 1 I .1 Hold it. 2; C Yes. Ce.Cuad. A Hait. Eef cre we got into this, cne condinicn t in that I'd li.he a cery of this t r.a n s c r ip t. t, k__

- y- .-]'. Q We're going to go over this at the'.end cf'the ~ meeting. .i A Ch! I thought it was at the beginning en the 4 - ast one. Can we go off the record for a minute. .a Q Okay. 6 i (Off the record.) l S MR. ZUDANS: Jim Malonson will cover the items 9 of concern that you have brought-to-us and I guess I can I 10.i ' turn it over now'to Jim. i 11' MR. ' MAI.ONSON : I'd like tc go off the record'for a 13 moment.

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j l (Off the record.) g4 I i i .g-4 MR. MAI.ONSON : pfg[fj}yourelatedscceconcerns i 16 about the paper work, drawings, hanc.er c.ackac.es, travelers, for.wcrk being performed in the pipe support fabric 2tien ' ~ )g. -3 -i ts. 3 shop; ccamonly referred to as the iron fab shcp, anf : g9 think fcr purposes cf discussion here, we'll alwa;s refer i .,9 '"l to it as the iron fab shop. You vere concerned th : the ~ l s i craft didn't have encugh knowledge of the recuirements 2 3 ~ t ,t for the job to do the work to sketches and memes and v, informal roquasta rc do work. We will track that c :..;r V t first because there are many of your ccncerns to ha ,,. - l ~' ' 'covored in thic discuacion. Can we cc off the re : tu

4. '.I ~ 'for a minute. (Off the' record.) 1 MR. MALOMSON: We'll continue the discussion in .4 4 regards to the lack of paper work to-enable the craft i a .o t know what they were supposed to be doing in accordance 6 with procedures and specifications or drawing requirements. j o -I M NN5 N$Ifg,} That pretty well... j S' ~ Q-We had notebcok information that identified 9 a history of some werk. And frcm that notebook information, i i 10 . I selected fortv-three of the entries to track down the i tj I paper work associated with getting-these jobs done. There may haze been more than the forty-three I picked in ther,e, 13 .O 't but the fortv-three were reoresentative of the concerns r-- 14. that:ycu gave us. I reviewed all of the fabrication 15-and inscection crecedures that are used in the iron shep 16 ~ 6h< 7 i that wculd be the procedures for craf class supports; ncn-nuclear supports, which would be classified pipe

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15 - succorts; miscellaneous steel; electrical suppcrts; and I ~~ 19 ; = the precedures for the receipt stcrage and issue cf I i 20 material. l 'I i 5 A Sounds like you got into it a little bit. 1 _ _1 1 0 Mcdification of vendor supplied catalccue ~>> items: color ecdinc of piping materials; inspectier of ' l I l storage and maintenanca of permanent plant equipment: y, i i t r i

5. t .I welding and related processes; reporting of base metal 0 defects; control of material traceability for site r 3 f fabricated structural miscellaneous steel. That's just 4 a sample of twenty-four procedures that are applicable to ~ work performed in the area. 6 A Well, wait a minute. Let me tell you something 1, right now since we're on the record. You have to under- .I S i stand that the last time I read my actual fabrication i procedures -- you know, sit down and read them to where 10 I knew exactly what I was building by, it's been over 11 three years, easy. Anytime that we have any training that's 19 required, like there's an addition into the procedure ~ 13 (]} or something, instead of really being read the whole I4 section it enccmpassed, if it's an and, if, or but change 15 in the line, that's read to us like line so and so, 16 they changed this, and that's it. II Q Okay. IS { A So, some of what I may have told you may have I9 not been by up to date procedures, but by procedures I f I 20 was trained about two years ago or so -- you know -- three. s j 21 Q Okay. To track down your concern in regards t f to not having the paper work, I reviewed the material 22 i 23 ! requisitions that were prepared in the pipe shop to 24 determine whether or not the required dccumentation in f (../ l the form of drawings, hanger packages, or travelers were 25 j i

6. I I available to the work at the time the work was performed, i and I foun'd that it was standard practice in the shop for ~ 3 f some period of time to fabricate material without the i 4 presence of either the control drawing, the hanger package i 5 or the traveler. I would like to clarify one point, if t 6 I may. The fabrication of plate material and cutting off angle iron and so forth, is strictly a dimensional ' l I 8 thing. It doesn't necessarily require that you have the l i 9 drawing in hand. The requirements for the dimensions as i 10 specified on the material requisition and then, the 1 11 traceability requirements and the material are also spe-l io cified on the material requisition. Now, in the review oftheproceduresfor$hhbsupports, I found that the j 13 (?) ~- I4 procedure allowed the fabrication of parts of supports 15 in the iron fab shop without a drawing or a package, as l 16 long as the traceability was established on the material s Cf a class 17 identification log. And I found,that for l supports, Class 1, 2 and 3 supports, there was no problem I IS i 19 '[ l with the documentation being available in the shop. l i 20 A On the material traceability? I j 21 Q Yes. t 22 A Okay. l Q Now, to find out what was going on in the 23 l i 21 shop, I performed an unannounced audit of the shop, using ~ 25 prepared check lists for each job that I came to to find i t .. ~.. -... ~.

7. out whnre the pcpar work was -- Was there a traveler? i Was there a drawing? Was there a hanger package? If it '3 ! 'was a component modification, was the modification record 4 available in the traveler package? And in the two days i 5 I did the audit, I didn't find any jobs that were working 6 without the required paper work. Now, for the miscellaneous i e 7 steel procedure that you raised a concern about, which is t 8 your prime area of work, I found that the procedure 9 requires that you perform the work in accordance with 10 control drawings. The net result of the assessment of that II concern was that we are asking Brown and Root and Tudco j 12 to take corrective action in the. shop to assure that the

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packages -- the traveler packages,- hanger packages, and 13 I4 drawings are available to the job when the work is being i 15 done. 16 A Can I say something? 17 Q Yes. You may. l i i l[ IS j A Okay. When you were in the shop auditing, I 19 you were there approximately, like you said, two weeks. I. ! i 20 You inspected -- Well, I was on two jobs with you.

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21 I bent some plates for you; and one, you inspected a job l ~ O i 22 j that was in process. My foreman stopped me while I was L l I 2.1 I in the office checking a log for something, and he come [ l over and asked me and then took my paper work and took 24 i j 25 you out to inspect some work that was in progress; and you I wn-. .7

8. ' j couldn't hear it because you were sitting on the other end of the office, but during the time you were there, 3 he questioned me right out: Is this job in line? Okay? i ^ 4 Q Yeah. . i A During the time you were there, everything t 6 fell in line. If it was questionable, they sent it back. 7 Q They didn't know i was going to be there. + 8 A No. But once you appeared -- once you appeared, 9 you know, it was just like: Back up. Let's wait a minute. 10 Q Well, I don't want to develop a long discussion ~ { 11 on this. 12 A Okay. l r i 13 Q However, there were two of us that went into ^ .).s I4 I that shop, and for the very reason that if I was looking 15 at one job, the other gentleman could be seeing if a job 16 was being pulled. 17 A Yeah. j IS Q He was looking at other jobs while I was looking 19 at one. -j i i 20 A I see. But I just wanted to make you aware i 6 j 21 that when you come in, it made a drastic change in the i Afterwards, it l way we received paper work immediately. 22 23 5 chanced back. I don't know how it's went since, you know. I 24 Q All right. There was another concern of yours 25 that was coupled with the lack of knowledge of the paper l

9. 1 work. You stated that the paper work is illegal because i 3 ~ I couldn't find any instances of it-was post-documented. ~ 1 i that. That may have happened working to a sketch or a i f memo today to get the job going and then the paper work 4 . I following it up at some later time. I did not find, in 6-that area, any problem with the traceability requirements 7 for the material. Where the material requisition started 8 the job, it did define whether there was a heat number j l' 9 requirement for traceability or a unique number or a 10 f coding number or something like that on the material II requisition. So, I d'idn't find any problems with the l' sign-off of the heat number on the material requisitions. 1 i 13 (}) A Okay. N Q The paper work is illegal because it is post-15 documented; we've just covered. That may have happened. 16 And that may be a rare event that will continue. I don't II know. I think in your previous interview with us, you j IS ' agreed that there would be instances where a job was in I l9 process down in the -- i i 20 A Oh, a hot job. d j 21 Q Yes. t 22 A One that, you know, you've got something + 23 l that's got to get down there. 24 Q And paper work would follow. The job would e '\\i.' 2a_ start and the paper work would follow, i

10. 3-l A A hot job -- something they would call you on the phone and say, "We're coming up there after it." I '2 l 3 [ can go along with that occasionally, you know, if... 4 ! Q Well, on that single concern,without knowledge 5 of the paper work, we're asking Brown and Root and Tudco, i 6 we'll call it, to take corrective action to assure that l 7 that's restored to procedure requirement. You had a con-8 cern in regard to your supervisor telling.you to improperly 8. ? 9 color code material. I reviewed all of the procedures i t 10 l for marking and color coding that applied to what's going i 11 on in the shop, and there is no procedure that directs 12 you to color code material up there. I' 13 A Was there one three years ago? 14 Q That's possible. There was a situation that 15 you discussed in regard to the color coding, saying: 16 Marking with red paint. We observed that situation in 17 the shop; however, there is no procedural requirement for j it. And in discussion with quality control supervisors j IS 4 l and quality engineers who were at the area where that 19 i I red paint marking material was located, they stated that's i 20 21 a requirement from an old NCR procedure that required i i. 22 temporary steel when it was removed, if it was no longer 23 i traceable, to be coded with red paint and put back in the yard in the storage area, or material that was rejected 23 dE# by NCR disposition. But they had discontinued that practice 25 4 i

11. .~l !'clongtimeago. i 2 l A When we discontinued it, we didn't have no 1 3 other way of segregating it in our yard -- in our storage yard out there. 4 5 O But it is piled in one place. 6 A Oh, it's gone now. 7 Q And we find that we've asked the Utility to do 8 something about that. And I'll pick that up in a later 9 concern. We asked the Utility to do-something about the 10 pile of material. Now, does that satisfy your concern 11 about not marking the material with red paint? Because I 12 that's what you discussed with us in the original inter-13 view. ( l 14 A Yes. And I've got to add that ever since i 15 y'all come up there and did look at our yard, they did 16 start pulling material. And when I.last left the job I 17 site, they had the main lay-down yard pretty clean. We still had a bunch of base plates with questionable trace-I IS I 19 ability, but otherwise, the rest of it was pretty well i 20 cleaned up. Q Now, in my investigation of that item, I 21 stated that in your interview with us, you had stated 22 that you could identify the material either by Nissen. 23 marking or by the heat number stamped on the piece. 24 \\' A Right. 3-a /.

12. i, j O So, that identification of material for traceability purposes, we couldn't' find a problem with A in that area. 4 A Well, maybe you didn't understand what I was t . I trying to relate to you about. What my main concern was when we were talking -- there was a bunch.of flat bar 6 I that was brought in as bulk plate -- brought on the job S site as a big sheet of plate; we cut it'down to flat bar 9 back for electrical with no heat number transferred by QC. l 10 l We just ripped the sheets down to flat bar. - They went 11 and got painted and went to electrical. When they brought 12 electrical back to us, they brought all their' flat bar, 13 ~ [g all their base plates, all their material started coming 14 back and intermixing with 15 Q Can we address that in a later concern? 16 A Okay. 17 0 But do you have any concerns with color coding, j IS as we discussed it? I f 19 A No. Now, we don't have nothing but Q material ii 20 in our yard. 3 j 21 Q Now, there's a concern that during consolidation l 22 of all fabrication shops, material from the electrical 23 shop was mixed with safety material in the iron fab shop, 24 and I found by procedure that the procedure for the fabri- '\\- 25 cation of electrical supports states that Q material shall I ~ _.. k

13. I I l'beusedand.itshallbeobtainedfromthe--I'llgive -you the exact words. May I quote from procedure? In the 3 fabrication procedure for electrical supports, it states: 4 Material used for hanger fabrication shall be in accordance l - I with the detailed drawing, XXX -- it doesn't make any 6 difference -- structural steel members are to be those 7 obtained from the electrical fab shop or designated O 1 0 storage areas. So, what I was attempting to relate to you 9 is is that there's no conflict in where the material.is 10 stored for use in the electrical fab shop, as long as they 11 get the right material -- Q material. I 12 A As long as it's segregated from our structural 13 work. i I4 Q No. It can be from any place. This is the 15 point I'm trying to make. Just because it's for use as 16 electrical material -- electrical support material, doesn't ' 17 mean that it can't be taken from the iron fab shop because j IS l it says, "It shall be Q material from some designated i f 19 i 0 -storage area," but it doesn't say where the area is. i i i 20 A Well, let me ask you a question here. What 5 j 21 I'm trying to get it is on the non-ASME side, we're l 22 required to metal stamp it, and on the ASME side, I under-l 23 stand they can accept a Nissen marker on it as traceabiltiy 24 -- writing a number on it -- I understand they can. d 25 0 13ut we' re not discussing that area. We're

1.1 discussing -- .~ We're getting back 00 A. Well, wait a minute. 3 i the metal. We're talking about the bul': ' me tal. We're 4 talking about electrical metal in our vard. When ycu -5 1 bring flat bar over with a heat number, say for e::arple: 6 T45353, we receive bulk flat bar en that heat n=ler; I we receive Q plate on that heat number. Okay?' A let of S that Q plate was brought in and wrote down as more flat bar, with no traceabiltiy from whether it was T45353 or 9 i M T45656. Do v.cu see what I'm saying? NobcdY verified 11 the cut down. It went to electrical. That was fine. l') Eut now it ccmes back, and throw it in our iron and if .Q you don't mark it as electrical, where did it ccme frem? l 13 v I4 l Who knew if it was cut from plate to flat bar and then I 15 processed cut for a hanger or sc=ething? 16 MR. ZUDANS: Is that material all Q material? My i -s understanding of this discussion is that as long as it's II 1 15 l all Q material, you can use that material in the fa:ricati:n. A si.tdr.;ui:JMJ Q G R Q_j .M -,, I was unaer na train ng t.a: ycu 19 l i 21) had to maintain traceability of heat n=ler jus: richt T .w 21 down the line. If you cut off a big plate, you wcu'_J j i i .' 2 l have had to shew whare it ccce f rc:- a plate to a.3:r-g 4 21 ! of flat bar. That was m. i 21 MR. ti' 0:lSO :: Onlf i.f it's usea -- I 'e,e*'

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15. [ .1 Q -- whero traceability is required. A Okay. Such as ASME hangers, Class 1, 2 and 3? 3. O If it's used for that, yes. If it's used-i 4 l where traceability is required, then the material has . I a to be traceable. 6 A That was my concern. See, they were bringing I i 7 flat bar that electrical didn't require us to document the 8 cut down. Do you see what I'm saying? i 9 Q Yeah. I 10 : A We didn't have to do it for electrical. We i 11 just ripped that plate up and shipped it over there. But 12 when they brought it back'to our yard, they threw it in 13 our rack. "We have our Q steel there that we know where 14 it come from. They broke the tags and they transferred 15 the heat numbers, you know, and QC -- 16 Q When you say, "our rack," do you mean out in 17 the storage rack? l IS + A Yeah. The regular structural storage rack I i d 13 before they brought the other iron over, i i 20 I Q Yeah. But the point at issue here is that I ? 21 when it's going to be used, if it's not traceable material i 22 -- heat number traceable, it won't be used. Nobody will i 23 l accept it. The inspectors won't accept it and the craft 24 won't accept it. l. A It goes out on electrical supports every day v 25 ; I i i L

16. I I right now. 2 [ Q The electrial support don't require'that. ~ 3 A Okay. But whenever I told you about there was f a problem with the stock getting mixed, they brought their 4 5 flat bar and intermixed it in our rack;.so that if I i 6 went out and grabbed that piece of half-inch flat bar, 7 if I didn't go back and look in the log under flat bar 8 to specify that it was come in as flat bar, it was l 9 questionable. It may have come in as a sheet of plate 10 i and there it is a piece of flat bar to be used. Are you 11 following me? l 12 O I don't understand why you would say that 13 nobody would know that it was cut down from plate because i 14 it'll show the cut mark. You don't grind the edges smooth. 15 A No. But if you sent it to the paint yard i 16 and it gets san'dblasted and painted, what does it come i 17 back lcoking like? l 16 O Is it coming back to you on a job that requires 19 traceability by heat number? i i 20 A It sure was, up until the time you got out l 3 there and started checking the yard for material and j 8 21 i 22 they started cleaning the place up. That's what I was 23 i trying to tell you. 24 Q That's not the way you related it to us. You 25 related it to us as: The material from the electrical fab

17. I .i shop is mixed -- Q material from the electrical fab shop s,- I is mixed with Q mat.erial in the iron fab shop. And the 3 results of the investigation show that the procedure allows them to use Q material no matter where they get it from. ~ A Well, see, according to what I've been told l 6 electrical procedure, it was Q material, they didn't have i I to have it verified down. From what I've been trained is 8 the electrical could go out and get the flat bar; that 9 they couldn't show an MR to where somebody cut a sheet 10 of plate down to a stack of flat bar; sent it to paint l 11 yard; it got sandblasted and painted, and got sent back j 12 down to the bulk stock, you know, four hundred foot of 13 flat bar sitting right here, come out'of a plate. I4 Q Is it filed in the Q material storage area? 15 A Well, it was up until the time you come out 16 there and checked their yard and they started cleaning it g II Because that was part of what I was yelling at up. Ib j' management about. I couldn't show traceability back l from a piece of flat bar that was sitting here painted and I9 ' t a - 20 - looked like bulk stock to where it come from. It come j 21 back as a sheet of plate on -- j: 22 Q But if it's being used in the electrical support I 23 ! shop, it only requires either a unique number,or if it's 21. going to be used inside containment, akoingcodenumber. ..w 25 A Well, wait a minute. The electrical shop is

13. In cur-shop. 0 But : they' re working two dif ferent procedures'. + I 3-A Yeah. But they got the material mi:<ed with curs. 1 -I - Up,until -- whenever I talked to you, this is what I was'- 5 .trying to relate'to you: They brought.their material tha: 4 F 6~ didn' t have traceabilitv on the cut down that was sent 4 I t up1 there, blasted and painted, brought.back as five hundred ' ~ ~ 8 foot of bulk flat bar stock; stuck it-in our backs and g' 9 said,."Use it boys. It's traceable. It come in on a p. 10 i sheet of plate." 11; Q Well, if it's traceable, there's no problen, o f- '}O 4 u..j ; e.., w;Ylu $.32 ~ y

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4 -13 A It's traceable to a sheet of plate. But it' ! L-t '.-).U.: 14 ain't traceable from when it got cut dcwn. I I 15 Q Let's go off the record. 16 I (Off the record.) 3 l-I [y:jk. w: c...: Okay. Up until-here about -- I den't w $l $9 l.I - IS .1-know. I'd say about a year ago, maybe eight =cnths, I 14 i I'l' 20 whenever electrical recuested flat bar, bulk stock, frce s. j 21-us, if we didn't have it in yard si:<, the main material ? 22 i -yard, did not have it in stock, we would take a shea of i 2.1 plate in the shop -- Do you remamber :Ir. Mahan? Reu :tahar ' 21 ' l- 'Ile-was the primary man that done this -- he would cet up 2.3 and track tor.ch this plate into flat bar. IIe ' d c tamp 1 u.

to _ _.- - =.... I number on it; bundle'it uo; and shin. it to the nain: v. a r d. 1 They would paint it and it would go.to electrical. OC- ~ 3' would'never et invcived. They never seen it. Do ecu 4 know what I'm'saying? Q Uh-huh. 6 A When it ccme back to electrical, it's cainted, ~ QC' stock for:their work, supposedly. You know, it's got S traceability' maintained. But whenever you went back and 9 looked in the books.and tried to locate the material ~and i, i 10 ! see what it was, it come in as a 96"X 120" sheet or something 11 like that.and there was no transfer down the line. You l' couldn't go back and say, "Well, this flat bar come cut ~ e bE 13 -of this sheet of plate and it was CC verified." Ycu knew, x,t f 14 it.being stamped prior to cutting. It just wasn't done. M2. LIVERMORE: It was stamped. It j ust wasn' t 16 j verified? I _' -f' 4,a:.:;2;in?aff Well, it was. The only reason tha: it 3d

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IS :~it's cuestionable.is I have before and I know cther fittars { t i 19 that's went'out thera and drawn scme stock, went t: use -i an it and check it, and it'd be wrong. You'd pull a year ~ g i a hundred foot of flat bar or two hundrad foot of f'_at bar i 3i ? -- ;.that was no good. That's when we'd use it on our ju-c ir:n, you knew, temporary T.iscellaneous work to get rid cf it, i but you couldn't even track it back to the right th.c.:no c s i s_- O.p[atd.

_ _ _ __ __ _2 0. -. .g~ MR. MALO:ISOU: Do ycu agree, though, that where traceability is recuired that QC would not buy off that 3 material for use? 4 M%flNO$, 1:ct~ knowingly. Some of the CC, if a r _ ~. .N they don' t know it exactly - - if you don' t show them: 6- 'Lcok, you can't locate it as flat bar, you knew, then they buy it. If you can show it as a three inch plate, t. t 8 they'd buy it. But the ones that have got involved with 9 the situation that I have brought in frcnt of my gcid hat i 10 -and my general foreman of the lack of traceability, -that's II what c.ct it sec. rec.ated. That, plus vcu went un. thare. I' _lecking at the yard.. ~ -13 Are vou satisfied now that that material has Q t 14 been segregated the way it should be? A The last time I lcoked, it was Yeah. U r l Q All right. And you think it was the results s l I _' i of the TRT's investigation of the area that got this IS i i separation of the material? l I.. } () A That brcuch-a bic cart of it about. 4 .e-1 1 Q Okay. Can we safely state hat-you bal_a'te -y) there's no prcblem with traceability fer the material in 'l

• 1

+> useage? .t' 2. LIVERMO22: In segregation cr traccabil:.: ' -' + i 2I MR. 21ALONSO:1: Traceability. r 4 - V. .l <1 ol e% g sh.. <2 6 g ' (Nat r0 Sp0nd ing. ) ( -pt

• • t I

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m m MP.. MALO !SO::: If we have heat number tracsar: ty, -j of it doesn't make any difference whether it came in ggyg.,y 3 as a plate, as a flat bar, or anything else as lcng as 5 it's traceable. He know, for instance, by the heat number ~g. that it's some type of steel, if you will, frca some source 1 that meets some specification requirement. As lcng as the 6 heat' number is.'there or it's traceable, then it dcesn't ~ 8 make any difference whether it came in as flat har c: 9 . plate. iI 10 A I guess not. Even though if it come in as ! plate and ycu're using it as flat bar, you know -- 11 l '-- MR. ZUDANS: Well, the material properties ars still 13 th ,s L.. r~i... e e %g;$,;[:, M y d kl Yeah. But how do you know that p ". a t e 14 1 15 was that flat bar? I mean, just theoretically, you knew. t

• AS:iE GC when -- See, it was brought to their attenti:n 16 'I 3

I. and ASME OC kind of looked hard en it. They wouldn': le I none cf the bass plates that we used like that. j IS accept i 19 You knct, this was just informal, in the shop. ~ Ii-Uell, you' re telling us actuall! that i 20 l MR. MAEcNSON: 3 the procedure works and they are observing the precafure. 21 22 When vcu relate to us that when the ASME QC Iccked

:. t --

1 1:han the AS:!E CC -- whanever it was br uch t: 2.i A 21 their at:antien -- See, the bace platas they br ugh: c car 23 had the same : r o b l.e m : lach of traceability f ro.- he,:- : a \\ s.-

big-sheet to a little base plate; a 12 X 12 cr.a 14 :. 14 ~ I base plate. They were cut in bulk s:cck, sent to pain: F yard and painted and shipped back. Well, when ASME GC 4 ? caught onto that, they says, " Hey, y'all can't use the .I a ': base plates." The last I heard, they were informed on-6 the~ flat.bar. I don't know, you know, how much. 7 Q. Yeah. I think-we'll' try to stop this discussion j i 8 on it because what you're saying to us,. effectively,'is j 9 is that'the material is traceable; although, when it was 10 sent to you, it was electrical shop Q material mingled-1 11 .with iron fab shop Q material. The material-is. traceable. 12 MR. LIVEFr. ORE : Ey virtue of the heat. number. 13 MR. MALONSON: '.eah. 'g. .w a,g4d$s asa c If the heat nu.ber's right. g-k _ y-iT$25'[ 14 l ,~ 15 MR. ZUDANS: Well, what we'll have to assume is f 16 ! one point, [m$$)Nd is that thev're'either doing it right .m g i 17 cr not. Okay? And that is, that the heat number, they f' IS ; have that right. t I Ep'@,ftW, c.[- If it was right. 3 1 10 i 1 ,1 II 20 i MR. ZUDANS: I understand that, but there's scm2 L 21 peint at which you have to have a little confidenca in i t

i.,.

I 22 what they're doing cut there; right? With regard to at 2.1 least knowing the heat number. And I wculdn't at all be I ', surn.rised if there are cases where ther. didn't ha're the i s J 1 25 traceability and still uced the material. That n.1 y P - tha , t...

~ I Case, tGo. But the fact iC that wO Can't f f C !" dC ) I'm hearing, we really halen't beer able to find that. a"1--.e _c

1. 4.e 4-

_- a_.n. _e Obviously, we haven't be.'t ~- w 4 One'is that we're here; right? You kncw, and everybcdy's 5 acting real good. Q.;;t;'h, h.g[, Well, 6 that helps. ,, ~x.. n.y i 7 MR. ZUDANS: Well, that's the c.oint. That's why O we're there, I c.uess; c. art of the reascn. i, .. ~...,,,y 9 .?Q t.C, ', #. d. s O k.a v.. Well, onward. e, 10 l F.R. MALCNSON: All right. I'd like to ask another I l 11 c_ u a.c ".. c.1 "w"...,.". T s "u ' *w e d 'w ^ vo u t'- n., e # # = ". _4 ". e _' ", ' 1".. _ w 12 ' ~ v_ c 'a ' '- n " c. ' _' 4.. - t'. o- _4 - t'.. ' "w t.". e....'. ". $_ _ _2 _' _' _# _c t nceb_'o a' n c . c o l i I 1, t.ud I *icu'd- _1 _4 . c, w _# ". ' ~~ ~- *. c.. "u c ". ., i t h.o. c, r v-e 4 " _- o wo. 's.c. T- ,E -) i 14 i discussicn' to have you either agree with that or disagree l i la. l with it. _--1 e.v : ?.'.if Well, we're pretty cicse in agreement. 16 ! n l 17 - If the heat number is right, it works And I don't kncw " e "< e _ _2 _# 4 e d- =-_s-

s. 2_.4 _2_4 2. A.

7 t h. o u r b..". _4 '.. 1. ' u d '^ [s 1_ 1w c e - e vv a 19 s t3,, a, _, s,. 4 4- +J-, _7 re.. c, = _. - - L v, 4 r *. '. C,... r +. 8 'C L s 2ar 3 6.. .J w m. _w o - - ~.. .L .si-j y w. _-vad. eg. _3) s_;n, e r. _ 3, u;.. .; e e i, 21 C Well, you're telling us alsc that this hacpened I 2.' roughly, three years ago? .m., , i,. ~,., u,,.,.,. e. 1,. 3 w e-,.....;. - a.1 1 -..e 1- '_ 1 _w _t .g wa 21 about a year ago that to cut tha bulk s:cck _;ke t !' i t. (' ' - 23 - Sinco I've been in the ; hop 'til then. i i MeMI ,e, ,,,.ee-.'.e NW.ligy%, y, ' ^ ,,y -Q, ~ -dw ' - m, g+ ,-9y., O. $ Y. 4, A,, g,, - 7 yo wee,_ ,,i, ,e,.- e s -e.. ..a,,s ra s... s vl . O -.c e.1.. f. .. ~ -. e E. i. e,

o 24. i 'I Q Okay. I'd like to go on to the next -- No. 2 I've got to.back-track a minute. The procedure for 3 ! electrical supports allows them to take material either i 4 I from the electrical fab storage area or from some other i l 5 designated Q storage area, so it doesn't make any difference. 6 where the material ~is stored as long as it's selected as I Q material from a Q storage area, and they are doing that 8 now. 9 A Yes, sir. Right now, they are doing that. 10 l Okay. I can go with that. 11 Q You were also concerned that the electrical i 12 people were using undocumented material. I believe that 13 that relates to the material that we discussed in the f5 -:J 'I4 previous concern, about the mixture of material. I stated 15 in my investigation that, during the audit, we checked 16 work in process. And I reviewed the procedure for the I l-17 fabrication of electrical supports and I find that since l 15 electrical supports require either a heat number, a unique l 19 number or a coding code number, that it would be very i j i 20 difficult, under the procedures and the inspection process l 5 j. 21 'for electrical supports, for them to use any undocumented c 22 material. l 23 ; A It would. l 24 Q I didn't find any events or any cases of it , f _.,.

W 25 happening while I was in the shop, nor did I find any l

i l

3 p_:.O .' I ' packages.thae I would suspect it was happening. A Well, that goes back to the material because, 3 like I sa d, I was under the impressicn that Q material, i 4 ' you maintain traceability throughout. If i.t comes in twenty. foot long, if it's less than twenty foot,.if you've i .o i Ii 6 got, you know, a sheet -- a big sheet,-if1 you're using-7 a flat bar with the same nurier and you can't find it 8 or vou use a -- I e 9 .Q' You mean you can't find it in the' log of cater-10 ials? You can't find it logged as flat bar? ~ 11 A Mo, sir. Not as flat bar. 12 O I don't think.that's sic.nificant to tracsabili t 13 A Well, I don't know. I thcught our prccedures ) i .n o e -required us to_have a trans:eer.verirlec. 14 ~15 MR. ZUDAMS: Ecwe'/er, if you find traceability in 16 a sheet, then you can relate that back to the bar right? A If the nurlers are richt. 'M Yeah. t. 17 A ' n-o j 15 MR '. ZUDAMS: Yeah. I think that's what you're scying: 1 f~ 19 l aren'.t ycu? i '20 MR. MALcNSON: For the record, I'm going to clarify i 1 i q s,' I 21 that. The fabrication shcp maintains a heat card file b l iscue y; l

cr materials requisitionac as bulk material and the i

t cf the fabricated :aterial -- Ue're stating that inctaad 23 of purchasing flat bar stock with traceability reqmr2-I

\\

2 *, ' mentn, the chop cut down semo heat number traceable p l.a te ~ t - - - ~ ...~.. I. i J 1-

m _e_ I material into bar stock, and perhapc, did not take^an a. entry in the heat card ~. file that they had bar stock on I hand. Dces that, sound right? Le:'s go off the record '4 : l' for a minute. (Off the record.) 1 6 MR. MALONSON: You were concerned that ASME CC - l l in the fab shop did.not check threads. We are referring i S I to. Brown and Root threads' fabricated in the iron shop. i-9- } 'This would be for bolting, studs, threaded rod. i i 10 n"uk ug W ,@2!,w..ie. d?<r U-bolts. .a 11 l. Off the record.- i I!R. LIVER: ORE: 12 i iii 13 (Off the record.-) r s- -j V 14 MR. MALONSON: You were concerned that the ASME QC 15 did not check threads on any job unless it was a step -- 16 an operation'on a traveler, rectirine CC sign-o:: as I 1_, i, g evidence of inspection. I reviewed the procedure for I i, 15 found fabrica:icn and the procedure for inspecticn and I 19 j I. that neither cne of the documents requires the inspecticn i 20 ! I of_ threads. Operation travelers are net required, ner i 2 21 used rcr tabrication in inspecticn of threaded red used t 1-7 I had a discucsi:n in ASME related safety class compenents. 2.1 in regards to thic requirement with a quality engina2r l and I fcund that there's perhaps a lack of definitien for .21 ';v t. ..) -. ~ ~ *.

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z_------- c- . _. ~ _/ the fabrication of threads;.definiticn of direction On how to fabricate a thread and what it should be, anc.the .r inspection requirements; and I'n asking the Ut.ility ::. take corrective action en this bv. refisine. the orccedures. l I witnessed threads being made and where there was an i operation traveler, the inspection is being per:cr ec. 6 I I In discussion with the quality engineer as to whv_ thev_ .i 8 were not inspecting threads, he told me that they rely on' fit-up and < tightening at installation for the 9 10, proper threads. And I checked the installation rect fs in the form of the hanger packages and thair inspecti:n 11 8 l '- check list covers the requirement for prcper'tightsning i 1 4 13 onLthe threaded devices. J-O), i /he_ v.:a can we go of f the record a minute? 14 15 I need some clarification here. 16 (Off the record.) 1 1. MR. MALONSON: Okay. Can we go en to the ne::: IS concern? to s... .n. '$2 W.. Me & ti Keep going. i i ^^ - t 5

a There's another concern that you raised a'cu c

1 0 j undocumenteddk,3t repairs were made on base metal, il 2: :. to en t h.: P2 : 3 clarify that, we're diccucaing terch bicw-cut w (ci_r. . :ne I of cut plate. Whera the plata has been cet s anc i ~g ni sedio,W to e:: tin !'.m 2 :",. o t candtna and tha ecca,; caunen tha te re:- ,_ r I ~ - - ~ ~.. - ~, _

m 28. 4 1 it creates a melt gouge in the edge of the plate. You-i e 2 ! were concerned because these repairs are being.made and J 3j not documented, and therefore, the repairs don't conform. 4-4 to a procedural requirement for traceability of the filler i 5 ' material and the application of procedure and so forth, i 6

JC Right.

7 Q I checked the procedures that relate to the i 8 reporting of base metal defects, and I found that where l l 1 9 there's reporting of the type of defect that your concern In4YD 10 is in regard to, that tssy should be unsatisfactory irs i 11 written for. In discussion with the people in the fabri-l 12 cation shop, and witnessing cutting operations in process, -i ? ~ 13 the fab shop personnel and foremen related that it's i t 14 standard practice that when that occurs -- when the gouging 15 of the base metal occurs in the cutting operation, it's 16. standard shop practice to discard the piece and replace - 17 it with another piece. In questioning welders in the fab j' 18 shop, they stated that they do not do any weld repairs 19 I to base metal. It's conceivable, but since the fab shop 20 does a multi-assortment of types of work, they might be t i 21 doing work for a piece for a truck on the site or something i 22 like that; that that could happen sometime. With the 23 procedure in place, I couldn't find that it was standard i 21 l practice for that to happen. Now, in your previous dis-I 23 cussion with us in the technical interview, you stated l u.- I =dw. e s sa e 3e-e+ e ge, we w ++ - pwmg .,m - s o. e + e ese twwS w ep ee.a we4m-4see M4 *eh =m*+, as-, me,e e m = e e-ae ^w he- = esp'apush-

Ja u.. O .._.._9.., m I _ that' if.;e u ried to find it cut in the shcp, that the t ,). Ewelders culd run away frcr us. I:cw, no welders ran away ~ from me and the welders that I spoke'to about it, were, 3 ~ ! knowledgeable in the procedural requirements and knowledge-able in the categories of work goingzon in there, and none-6 of them would admit to having made any repairs in base ~ metal. My-personal assessment of the situation for the 8 i type of work going on, it would be very uneconcmical to I couldn't 9 make repairs in the gouges of small plate. i 10 l find any evidence of that going on in the shop. There e are procedures in place thrcughout the site for reporting 11 and repairing base metal defects. OC' inspectors in the i,~> h. fab shcp were aware of the procedures for reporting base metal defects and obtaining the repairs of base metal 14 15 defects. 16 MZ. LIVERMORE: What you're saying in essence is if this was going on, we couldn' t. find any e:<amples? II that f. ME. MALONSOM: Right. U I,, N._6,.What can I say? I told vou if vou wan: l() l _r'E cc i, t .,,) to ask hem people, you'd ga: what you gc: because it's a 3; qualification out there that if you do illegally pass scme- 2 thing, ycu're out of work. They'll fire a welder in a I A heartbea: for that. 23 M2. "UDANS: As well ha should, but -- e' 'l The we t.iera all c:< pressed conce rn .,e Mr.. MALOM00ti: i

• * = =.

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3D. .I that they would be caught doing something like that. 2 They wouldn't want to face the consecuences of being caught I doing something like that. Twwg gi. r6WJ.A5@y!'.; One of the welders you talked to in 4 r. O.. r ~ particular, told us, she said, " Yeah. I talked to him and i a 6 l he asked me abcut that. What do you think I'd tell him? l l 1 / No way." What could she say? You know, I mean that 8 MR. ZUDAMS: That's right. And that's scmething i 9 that's difficult to find under any conditions. 10 ! MR. MALONSON: Cces my investigation satisf-i v_our t 11 ! concern? We lcoked at it and we looked for it and we I I to - coulc,n,t tinc any evicence or it. i t a j 13 l 4gy*jd..OsJ You looked for it. i f..... 1,.. [ p. g y _ 14 Q And ycu weren't able to identify any specific I 15 examples for me. You know, you couldn't point to that 16 piece en this hanger package as having been repaired along i -i 3 le t.ne sice. 15 A Nc: readily. No. Mot at the time we talked. 19 I O I'd like to state that it's not practical to t 2i 20 l .ake that tv_ r. e c f rec. air in the shoo. -- in the iron shcn. I s 21 Co you have an'; other concerns en that item,fdTy;.[, k. 22 A No. That just kind of hit me funny. 21 Q well, I'm concerned that ycu say it "it ,.u ! funny. Is the funni a hidden concern er is the fun,- 21 L... i l '> I semothing that just happens to be momentarily funny'

T.a'.

9 A

Just mcmentarily.. funny, ycu know. -.y. Q Okay. ~ MR. LIVERMORE: Can we go off'the record a second. ...'t (Off.the record.)- a.' 6-MR. MALONSON: In following up this concern, I alsc 6. i I - spoke to the manager of weld-engineering who stated that t 'S -- who affirmed the-standard practice to discard the 9 pieces because of the uneconomical nature of repairing 10 ll that type of defect in the iron fab shop. Do you have I II I any other concarns with that? 12 ?;%dj.9zyjdi., l gg, i t e:N-*:n - w y-_ . r.cg Q Ycu also had a concern that there was threaded 13 %_t I4 red cut in the iron fab shcp without'CC checking the [ 15 transfer of heat numbers before cutting. I witnessed 16 the cutting cf threaded red, and the traceability for 1 II the heat number was being maintained en the paper werk 'IS traveling with the job -- en the operation traveler. It's not practical to try to establish the transfer of haat I" i 3 i 20 number when they're threading a length of red befcre i 8 'l 21 pieces are cut from it. I found that the heat number ,j 1 22 ! traceability for tha fabrication' operation was in acccrd- - 2; ance with the procedure. I believe I understeed what 21 you were telling me and I stood over the operation while I s' i 23 j-it was in precean. I. don' t know hau you would tr.mai. r i

32. ' heat numbers before thezindi'tidual pieces are cut because 2 they're marked.cn the~ ends. .i A They'were tagged. 4 Q Or tagged. Yes. And I believe that'the 5 traceability for that material was being maintained. 6 A Okay. I can go along with'that. I. questioned l 7 it before and'before, we just had QC to stand by while 8 .I was working -- See, certain jobs we require them to f 9 actually verify you doing it; where others didn't. They i 10' -l would stand there and watch us cut forty little chunks I -11 of rod, then stand them up and stencil them, you knew, t 12 just actually stand there and physically watch to go along i i 13 uith -- but the other side wasn't, you know. .. j ' MR. ZUCANS: Sure. 14 15 MR. MALONSON: I'd like to go off the record for.a 16 l minute. I, l{ (Off.the record.) { IS {ffA MR. MALONSOM: You had a concern with. cret gcuging 19 j _of stainless steel baing done as close to the cut line i 20 as possible to minimico grinding. One precedura used .3 I A3 .i in the fab shoe. sc.ecifies az c.occ.ine en stainless steel y _r_ i i provided the edges are ground after cutting to remcta the 2.5 I l heat affected none en the steel. 1 l kj[fdfphpfg'[ Appro::imately, one-eighth of an inch. M, I MC;' -

• i

~.* n 4 L

33. . - ~. I' Q An eighth of an inch. r-w ~ A Right. 2 Yes. Now, that eighth of an inch has to be ! provided~for in the layout before the piece is cut. 4 And t 5 I talked with the shop foreman and he stated to me that 6 it's standard' practice for him to check the one-eighth 7 layout -- the oversized layout before the pieces are cut. '8 Now, he did tell me,that he 'oesn't check a hundred percent d 9 of them,.but he said that he'd feel confident in stating 10 that he checked ninety percent of them. I also had some 11 discussion on the condition of the material as it was 10 released from the shop, after the, edges were ground back l ~ l 13 (}} and he said, "The inspectors look at it and I look at it,." t I4 and you know, it's standard practice to try to minimize 15 any grinding. If they're not providing for the one-eighth 16 3 oversize on layout and they're grinding the edges back 17 anyway, they may be getting something that's not to print, I8 and I felt confident with the supervisor telling me that l 19 they do check layouts. 1 i A Okay. f i .20 j. 21 Q You've seen this occur or I gather that you've i 22 seen it occur or you wouldn't be talking about it. I i l 2I couldn't find anything on it and I saw some cutting opera-i 24 tions going on. I witnessed cutting operations going on, s s' ,5 and it doesn't occur to me that it's standard practice. ... -.. _. = -...-. --........~..

34. I And I felt confident with the explanation that was given 2 to me by the craft and the supervisor. .i I A Well, on the record officially, I don't know i i 4 Il which supervisor told you that and stated that the felt 1 5 l confident that one-eighth was in there ninety percent of I 6 the time. He flat lied to you and I will say that on the l l 7 Bible. I know it is standard practice and it's been I. I 8 standard practice. That's it. You know. As long as l 9 l you can get a slick look on it whenever you get through 10 i with it, if you can buff off in thirty seconds and get 11 a slick look, that's it. 12 Q But if they can get a clean metal look, that's l 13 all they need. i ~ 14 l A Well, I didn't know. They were telling us 15 ' that they had to leave the one-eighth that we had to grind 16 back -- do something the way the air gouging affected t 17 l the metal. I don't'know. 5, IS Q Yeah. It's the heat that affects it. 19 A Okay. ii 20 MR. ZUDANS: If you leave the heat affected zone, l ? j 21 you have a problem. 22 MR. MALONSOM: That's right. They grind in the heat ( l [ 2:1 i af fected -- 1:e says that they're getting a good, slick l look on the surface, and if they're getting a good, clean 21 v;> 25 look on the surface after grinding --

- ~ ~ _ g MR. ZUDANS: Does that mean you've remcVed the 3 ~ heat affected zone? Ikk hfh They told'us it has to be an eighth. 4 i We've been hitting it ---If you can get it within a. thirty-i 'i l second with'a gauger and hit it with a buffer and take 6 i it look shiny... t-MR. ZUDANS: I'm just asking a technical question. 8 The heat affected-zone does not get removed by just buffing. i .I MR. MALONSON: Yeah. But they grind it. 10 ! MR. ZUDANS: Yeah. But they have to grind encugh ~ 1 II to reccve the heat affected zone, l' MR. MALONSON: Yes. (2); MR. ZUDANS: And that's'the whole reason for it, 14 but the heat affected zone has a -- 15 gg,'MALONSON: It's crystali::ed caterial. 16 MR. ZUDANS: It's crystalized and it's hardened and 3 I I~ now when you weld it, it will just crack right there. {' IS ! MR. b,IALONSON : Crack up. I IiI MR. "UDANS: Right. And that's why they wan: to 4: i 20 remove that. Right? l $7h[h.,lh,q That's what we were told it was fer -- I l 2I 22 the reasen we had to grind off, you know, at least leave ll l an eighth to grind off -- in our procedure trainire. 21 But in standard operating practice, we just dcn't de it. L You don't do it. If you leave an eighth to grind c~f, 23 I

-00. .. ' I your foreman will be dead.cn ycur ass fcr spending thirty e-minutes on the grinfer or forty-five minutes e::tra' cn the 3 crinder. \\ 4 MR. ZUDANS: Chay. Well, I think what we've heard 1 5 is.that you couldn't find that. 6 MR. MALOITSON: That's right. 7 MR. ZUDANS: And you talked to the people and again, 1, 8 this might be another case like what we discussed before, y. 9 when we go looking, we're not going to be able to find 10 these kinds of things. We're not working there on a day-11-to-day routine. t }o MR. MALONSC::: But that will show up.in installatic: 1 r i' 13 where-the plate is welded to its -- it's joined to its

/O TCJ 14 main device.

'15 ; MR. ZUDANS: Yes. Ycu get a good heat affected zone 16 welded to.another piece of material, and the first time .g 17 v.ou c.et anv. movement, the thing will break right.there. i. 15 i MR. MALONSC::: Ett ycu're saying that with minimum ) 1 19 grinding, you're ge :ing a visually good surface when ycu l t i. 20 send it out? Nc discolcra icn er --- [jhgMhh Nc. Ycu take a buffer if you have to 21 22 and shine it off. Stainless shines up real geod. All I 11 vou a.ct to do ic take a bpffing wheel on a grinder and cc i 21 around it and you can chine out -- l 23 MR. LIVER.".CE: : What he's saying, Jim, is that you'11 ' -q. %y 4We D 6W *-'

27. I + never know it. You can cut it as close as you can, whip 4 it with a grinder, and you can never tell the difference. / -1 s If y u can shine it up, that's all 3 jhhNN. N... 4 MR. MALCNSON: And if it's been bicwn out and it's 5 l removed,that'sallyoucareabout? i l -- 6 MR. ZUDA'iS : No. t I MR.'LIVERMORE: That's not what he's saying. 8 MR. ZUDAliS: No, sir. 9 MR. MALONSON: No? MR. ZUDANS: No, sir. The heat affected zone is 10 ! t .,and t through the metal, all the way through the thickness, 11 I I l that's'the real problem with having that theory. If you t 13 burn that thing off, you'll affect the whole penetration v - 14 lofthatmetal. 15 MR. FM.CNSON: Oh, yes. I understand. 16 MR.,ZUDA:IS: And if you buff that off, it doesn't 17 mean you took out the heat affected zone. You still have I 15 it in the material. e i I I You just take the surface appearance. t .i 20 You maka it icok cood. 1 21 MR. LIVIT0! ORE: Cosmetically, with the buffer, he's I l 22, making it lock like they did the job right, although 21 he didn't. 28 "hk"$NfjNNf.5'pj It's been standard practice on any m m B GtainlOGG CtJel. 2 ") I

33.

t I

~I want to ' go of f ' tihe record. .MR. MALOISON: ~ (Off the record.)- 4 - ' I was unable to find .MR. MALC:: SON: I receat that 5 any examples of this occurring and I.was confident with.the -6 foreman's explanation that he-checks layouts before cutting i 7 'and the condition of the~ finished item is checked before S it's-released to installation. Do you have any other 9 concerns with that? hh [hh No. We've done discussed them. ~ ~ ~ 11 g - Okay. In your technical interview with the T.:.T go you asksd us te icok at two items, specifically. One item i 13 dealt with beam clips which you stated ycu believed they .s ' J/ l 14-l had cracks on.the outer radius, rorming cracks. I fcund l I 15 j that the. beam clips are used in the patch panel platfo-- 16 in.the reactor building. The beam clips were welded in 3 I 17 'l place in the platform and the outer radius was hidden. We tcok a sample of the material frcm the same heat number 13 i f0.\\.m 0 l and we,fdEh,d it in the shcp by the same prccess tha: was .19 r i 20 used te form the original clips and we didn' t find any i t' ?. - 21 crackin. I locked at it and saw some minute, if ycu will, i-22 discontinuities in the outer radius -- in the outer formed l ', radius. They were not cracks. We showed it to an inspac: r i 21 ! who has responsibility on the line where the beam clips i 6 li { were preduced and he agrood that it wasn't cracked. No i

39. then-did a-liquid. penetrant examination of the outer surface and we:found no cracks. Althcugh'those visible 3' discontinuities were-still in the piece, they were net 4 cracks. I 3 A Okay. 6 0 You agree with that? I A Yeah. I was there. I was the one that bent. S them for you. Like I told you before, I wasn't.sure about it. It was unclear to me whether they were -- what they 10 were. I i 11 ~ Q In our discussions when vcu looked at the'piecs I I2 you said, " Yeah. That locks like the piece before -- '13 looked like the other pieces." A./ K_ I4 ~ l A Yeah. Pretty close. 1 MR. LIVERMORE: What were the discontinuities? l 15 16 MR. MALOMSOM: Nothing. II MR. LIVERMORE: You saw something. What was it? IS ! MR. MALONSOM: Surfaca roughness. Do ycu have I9 other concerns with those? any I I guess if them are all right, .i 20_ dygg,f ni.,,7 Mc. .j 21 the rest of them we've been doing are ckay. I 22 MR. MALOMSOM: Okay. You asked us to check -- 2I MR. LIVERMORE: Let me go back. Let me ask ye'1: I 21 l Do you agree that those things you saw were surface rotv;h-l noca or -- I

40. py((fg{$,f.dE.mhI'm not no -- You know,'I wcrk -- I I'll tell you what, they appear to to to be what loc..ed ~ 1 like the surface was cracking back. Ncw,-I don't kncw. I'm not no expert. MR. LIVEPJiORE: I mean, we brought this.up on the-i 6 record and I.want to get it clear on the record actually I what was it. It wasn't cracks, yet you say you saw seme-S . thing there. You say it.was surface roughness, I want l 9 I; to make sure that you understood that, tco. ifa"etif 3.e%-p.?/N '. _. Yeah. D 10 I1 j MR. LIVEF31CRE :

Okay, i,

MR. MAI.ONSON: Well, once again, the licuid penetran: 13 e:: amination -- r~. L* {..f kII No. It didn't bleed back through -- y 15 t MR. LIVElt! ORE : It didn't bleed out? t 16 I j } f,(([ No. It didn't bleed back through on it. g m _4 pf. m

j; to lack a l'

MR. MALONSON: You asked us also, i ,1 } 15 a treble hcok fabricated on a thirty fcot stainless s:sel io . chain. b. l .,9 1 y;wv Yea 1.

o.. q. 3..._ m,

f i 21 C They came back and dccumented it the day after l 22 '. they masa Lt. 21 .T W.311, they document 2d test of it aftar it w. t.1 28 being built. 2 ~i 0 t Ldahad through tha -- or the TRT looke.' th ecun I

41. i !theFSARbecauseyouidentifieditasalowfuellimit I t r- ., o (,, i switch. 3 A That's what the drawing that the fitter had 4 said something about it was an emergency -- 5 Q Low fuel limit switch. 6 g. Okay. 7 Q I looked through the FSAR because we arbitrarily l 8 decided that this would have something to do with the l 9 diesel fuel. We couldn't find any devices like that in l 10 the FSAR. We discussed it with the @oengineering 11-people and they couldn't identify it for us. Now, there 12 were some limit switches identified in the FSAR. Inci-13 dentally, the FSAR is the final safety analysis report. 14 And the limit switches that we looked at were all electrical ' 15 devices that had no mechanical association with -- I 16 went to the warehouse -- material control room and spoke l t 17 to the material control supervisor and asked him.if he j IS could identify the issue of any stainless steel chain, 19 and he couldn't -- while he acknowledge that they had i i 'O stainless steel chain on site, he couldn't account for the ~ 3 j 21 issue of any of them. I also discussed it with the shop I 22 foreman and stated it was an odd item for the shop to be 23 fabricating and stainless steel chain would, you know, 21 trigger your memory, and he couldn't remember having made ?' U 25 it. I questioned the millwrights in regards to devices

42. I that'they had for handling fuel in the fuel storage area, l not diesel' fuel storage area, in the fuel pool in the 2 3 transfer areas -- fuel handling devices, and they couldn't 4 identify it. So, I couldn't go any further.with it, so 5 'I couldn't identify the device. Now, in this report, I 6 haven't asked the Utility to do anything further about it. 7 Since you stated in the interview that it was documented, O I felt-that since it was documented, that there would be 9 no safety concerns. Is.there anything else you wanted 10 I to tell us about it? Or you can tell us about it? 11 A All I know is that it was a stainless steel 12 treble hook with -- I didn't build it. The guy next to 13 me built it, and like I said, it was cut out of -- they i 14 brought in a stainless plate and ripped off some pieces 15-and hot-formed it. But whenever he was doing all of this, 16 he built.it like, you know, you'd build a boat anchor. 17 And then, they come back and brought him a control' drawing l 18 back and says, " Hey, look, this is what you're building. l 19 You've got to draw welding rods on this," because they Ii 20 had those, you know, them little connectors to put on 3 i j 21 the chain..You know, and I just thought it may be important 22 because it was stainless steel and it was some kind of fuel 23 limit switch -- emergency fuel limit switch, and I thought i 24 it seemed kind of important to be just sitting there jd,, t 25 rolling it out of a piece of red hot stainless, you know. k

43. 1 I don't know. Because '.te normally don't hot-form stainless up there. That's why I told you about it. ~ 3 MR. ZUDA'IS : Yeah.. I guess what we find in this 4 one is that we attempted to find the material that ycu say t was fabricated there and they can't find, so vl;Js@'~,1;cW?u- )- y N & 6 p0 It's down there somewhere. It's on a l p <c boat somewhere. l S "2.- ZULANS: If you can find it in the future,.let i i 9 them know because they're still icoking for it. But you t i 10 ; say it was documented. It's nowhere in the files? i p{= ' ~; :g.> . m 3g .-: / t : Well, the guy built it.

• de built it on l  !

an MR. [ ~ I 'g Q,jii8 tio one could identifv it. I w+g+1. A:;:q _ 13 (r- .I N i MR. ZUD. mis : And we didn't look throuch the files l a. too much? f MR. MALOSSOM: At no place was boat anchors listed. 16 I T{',/(pif'!W %.. It was built by the fabricator that I I as Ih wo-ks na::t to me and, you know, like I said,-it was an M cddhall scmething that would catch your attention. And when ha got the drawing back was after he had dcne startad I 20 j 21 forming it, you know, and ovarything. And I happened to i 22 look at the drawing with it because he was shewing it 2I "I.,ok at all of this," you knew. We wora talking about i t. ll It just caemed kind of strango te me. 7 .n nn. h.u.oncon : Was thin a f ermal drawinc:, (7qp,?

s.. .f,hh[dj h h Yeah. 'I MR. LIVER:' ORE : ' Wait a second. I think the b0 00 3 .line is this: That Jim searched as'much as he could -- 4 everythinc.. We went to our cperaticas people. We went 5-to everybody we could think of to find out the identifica-i 6 8 tion of this thing so we would have someplace to start-- I to get a number or something like that. to trace the paper. t 8 We could not find anything that fit, even like this. Thers I i 9 was just nothing. Everything else was electrical. There 10 -wasn't anything resembling a chain with an anchor on it 11 that fit this description. And we went through all cf 1, cur cperations pdoc.le that knew all of the systems, the l 13 tanks, the limit switches and everything. So, we-care it ...y i v,_ I4 cur best shot en this and we couldn't come up with a thing. -15 Let me just end at this point. I want to go off the reccrd 16 fer a second. j 17 -(Off the record.) ) IS l I couldn't find the devira /j,/*/~,y@) MR. MAL 0t:SO!!: to I ! that ycu're concarned about. And as part of the action i 20 i under this report, we will ge back and ask the Utility t: l f, 21 2 E investigato and try to determine the identification Of ths i

device.

And if we find it and find what it's usea a is, I we' ll ma::e a da termination f rca there. It's my unda: 3tc.nding i ,_I i .i that there is enly one of theco devicea fabricated. s -- .D . _ - ~... ._ w-

43. .k$yp[@W,.w[fifS;p ~ n g That I kncw of. 'i3 t i Q Okay. .I've co'tered all of the items of concer.- '~ 3 that were brought to us'.bv %?.M any; e '4 MR. ZUDANS: -In looking through the list that I ' l got off of there, and just jotting notes where we discussef I each~of the items, this one here: Safety /Non-safety 6 i I material mixed; does that go with the mixing of --- l l 8 MR. MALONSON: Segregated. I MR. ZUDANS: Segregation issue. Okay.. I just 9 wanted to-make sure that was the same. 10 II MR. IGLONSON: I would like to go over for you what iI we're asking the Utility to do in regards to the cencerns to 3 I. We're asking them to take correctiis 13 ycu've brought to us.

j. action to assure.that the scrap and salvage pile in the 14 iron fab shop lay-dcwa yard is identified and segregated 15 16 and restricted to prevent access to an inadvertent use a

1 I' cf the material. New, that pertains to the material that J I. - IS l ycu were talkinc. abcut, celer coding with the red caint. i j I9 In regards to the pecple werking withcut the required paper work and the post-decumentation of jobs, we're achin: ! i 20 jj 21 them to conduct a documented training session for those 1 : persons who prepara and precess material requisiticn.: to l' 22 2J assure that information is entored where and as rac u r+. i and the intended use deceription en the material reculai.:icn '.l a n.! ena!> Leo the deturmi.na tion o f the quality requira:r.ent ; '~ 23 a,

-d. 3 establishes traceabilit3 identification to the iter in s or on which the fabricated parts are used. So, that says 3 the material recuisition has to sn.ecif.y er.actly what shcul; 4 . be-there. f -.,. XOh...e', .g.. b?lAI tP ~. Take it all back down. / i twkqw,o a: 6 Q And we fcund foremen in the iron fabrication 7 shcp who weren't familiar with the procedures applicable S to the work they were doing, and we're asking them to con-9 duct a documented training session for those foremen. 10 We're asking them to take action on the procedures for the i 11 fabrication of threaded red to specify meaningful infcrma-a.c .i.._e =~...'.c 12 I t _i c. n _4.. *'"~ p-^c_d_u-os ... _ = w^_. 4 -- _d-. v. r 13 of the threaded items in the f'ab shcp. We found in the .i %) 14 i checkin~v cut of the material lav-dcwn yard that there was I i 15 i some unidentified material in the electrical shop lay-dcwn 0 v.ard and we're asking them to take action to assure tha: 16 : l 4 i i i 17 I those materials are identified or removed and to maintain e } 15. the prcpar segregaticn of materials cut there. We'ra l 19 ! asking them to do seme site surverlances in acccrdance f i i 20 with the procedure to acsura that tha ma:arial segragati:n 21 is maintained. We are asking them to take acticn tc assura d - a th'a t the iron fab shce. activities are c.revided with the I 23 required documentation: hanger packages, travelers, and/cr 2: -I drawinga; at tha time when and the loca:ica whera tc.a 1 s - 23 l activity in performed. We're aaking than to recc ie y geco^e e - 9

'i t indeterminate material mingled with 0 and ncn-Q D teri31 I in the electrical shop lay-down. yard. And we have cited 3 them for some violations of their proceduras; precedures 4 pertaining to the receipt storage and issue of items that's 1 for the preparation of material requisitions. The same i 3-6 procedure for the return of unused material. We cited them for being in violation of site survellances for the ~ segregation of material. We cited them for being in j S lviolationofprecedurefornothavingthedocumentsavail-9 10 I able -- the hanger package drawings and travelers -- when 11 ! the work -is perfcrmed; and for contrcl drawings. And 1 12 we're also asking them to take acticn to stop the fabri-P 6 h. cation by sketches and memes for supper:3, including 13 %P 34 i electrical supports. And I believe that concludes the i l a. explanation or -- i r 16 MR. LIVERMORE: One additien. Ycu didn't mentien 1 i I _d the treble hock. MR. MALONSO:1: We did that back in the -- Okai'.

}.

IS 19 We will-ask them to fcllcw up to lind the treble hec %, 2 i. 20 if possible. 21 j MR. L I V E :C '.O R E : One thing I might mention is these i, i 22 things than you've just mentioned: thesa violations, 2; citings and requests of the cccr.an.c; these are tanta: */e r l .2 -- preliminary, tentative things. T a.h [ = F-- T l 4.l ab.M IJ" W'-g ? ^ l ~

~ 43. ~ I anyway, er. cept my wife. She's going to be killing me 2 with curiosity, but other than her, you know... MR. LIVE?liORE : That's what I'm trying to tell you J'. 4. that we say these are what we're going to recuest the 1 - 1 company to do. These things are just tentative. 3 i {}.f; @ ygg,g Them things that you brought up -you're i 6 going to talk to them about, they'll relieve a lot of my t d S worries why I.come to you. l MR. MALONSON: Well, when I say that concludes 9 -, 10 l the discussien, it only concludes the discussion on what i i I 11 the TRO has.dene to follow up cn your concerns. I have 12 some-questions for you. The first questien will be: Cc i 1 13-you' understand that we have given the attentien, or do ^y ,,, '.J you feel we have given the attention to the concerns that 14 15 you feel should have been given to then? t e g"' *. t[ f h,. **f,.--, 16 j;pilutM' Sure. s~ I-17 O And do you feel that the answers given uc them s [ IS in regards to the concerns are adacuata? Do they satisfy -14 [ you in sc=e regard? r i ii 20 A Yeah. They make me feel a let better, like i 21 I said. There are a feu of them in there that we talked l: to be 1 about, like the gouging and stuff that ';cu'd have 22 2.; a' fly en the wall to coe. 21 i Q M,311, I don't want te get inco a diccucuten of i 25 that becanno we' ve diccussed it at some length befor. asM l

49. e - e I A Other than what we've talked about, no. It seems like y'all have icoked into what I come to you about. 3 Q Do_you have anything other than what we've dis-L 4 ' cussed that you want to bring up at this time? _ i 3 8-A Not other than one fact. Since you've left 6' the shcp area before I was injured, but after you had i 7 left from.being in that area, we did resume back te working.;. S off of memos and three parts, attached to our MRs, but ? 9 other than that, you know, that went back into form just 10 as soon as y'all got out of the neighborhood good. I I'R. ZUDA::S : Chay. It appears that we've pretty 11 12 much covered all of y:ur concerns. The documentation I i 13 will be in two forms. The paper that v.eu're c.oinc. to cet ..g,,. 14 i will be in two forms. There will be_an SER which he was 15. reading frem, basicall_{, Pere, and it's probably gcing to 16 be published scmetime in January 1985. Uculd you like a 17 copy cf that? Yes. Without my name in it, you-know, .?.,Md5$.5. U..7.,,W } IS s .a 19 i if it gats published. .. t-20 G. ZUDA:iS: That's right. That will.he_ par: cf I i t the public, but because we're talking to you perscnally, f j 21 t 22 wc'll send you a cery of that. It will address specifically 1, your cencarns enly. You can get the rest of the 5EI'., if 2.1 i .3 vou want to, frcm the public document rccm. The c: hor ,y j. .3 quectien, of cource, is and you've already mentio:.,! that

-v. you want the transcript, and we'll be sending you that I 2 one certified mail, as we did-before se that your confi-3 dentiality is maintained. And the other cuestien as we 4 always have to ask is: Have you given this statement to I 5 I us freely and voluntarily? Ycur statements? t dfI_ Yeah. 7 MR. ZUDAMS: Okay. I think that based on what all f S we've heard, that ends this interview and we appreciate 9 having you here. I 10 MR. LIVERMORE: One thing we did leave off here is 'P j 11 l we didn't ask him if he' knew cf anybody else who had any 12 similar concerns. He asked ycu if you had anymore ccncerns, 13 which you said, "Nc"; you were satisfied. We should aisc

4. : -

14 '. ask you:. Do you knew of anybcdy else in your area of i 15 work out there that might have similar concerns? I

1. U@effb-Yeah.

But I don't know if tco canv 16 p. : b,..-yA_ _m 3, s ' I. 17 of them will talk to y'all, ycu know. That's it. } 15 l MR. CUDASS: If you find someone that is particularly 19 ! distraught and wants to talk, tell them who we are and i. s i i. .O hou ve've -- well, don't tell them -- Ycu really shculdn'c 1 F { l do anythinc., I c.uess. a &g,4. ~ A c,?lr~p);gs%;,n N #i l i f,' a p er .'.m. 5) o y... ( N .' J MR. LIVCP210EZ : Juct call us if you fael you kncu i l s j someone out there that has scma concerns and they're 12.2-i ..i traught about anything, call us. Call Mr. Malencen. de e p+.h -_m

r. ~ .=.

m..

1

hfkff5h,.,..y...Nh, (j Well, you knew why I called y'all in

, w.a l ~- .? r-1~ - the first place; don't you? We can cc off the reccrd. 3 i MR. ZUDA.iS : Yeah. I t'hink that 's it. That Ekes 4 . it. care or. o i 6 (Whereucon this inter /iew 1 concluded.... 9:00 c.. .) 4 8 9-1 10 ; i 11 to D >~, 14 15 16 le I 15 I o0 3 e S q 1 e .1 '.1 l i ).!e l ' s. ..I t - - - - = = - ~ - - ~ - - ~ ~ ~ ~ - - _ _. _.... ~ - _. _ -. t

x p . / 52. oeo e I C T.". T.r ? m....e. er T. T..r. C r.r D T "..G 3 This is to certify that the attached proceedings before the Uuclear Regulatory Cc=ission t 4 In the Matter of: COMANCHE PEAK, TECHNTCIT, 7""r ?"T T ' I[' '[';If, cIR'Mdgf@.{ljpj;,}.g'g>fl@S-n ^ ^'ald}r} h. T. 5_' Date of Proceedings: ~ pjjg,f PlaceofProceedings:{r t-6 were held as herein ac.cears, and that this is the origina*_ l i transcript for the file' of the Cc=ission. ~j ~ i; 8 l. 9 i Chervi Lynn Walters, CSR 10 ' ' Cerrified Shorrhand Reporter 3, l} ./ to b' A4Y .':,v ) /.E. i.L's V 5 CTrtif# W SE.drrhahd Re crear' ~ 1 13 f y. x. 14 i e 15 16 .i 1_, = b f l9 l '5.i 20 ., g a 1-) 4 )*.) ( 1 i .( .,..)

.~ g o, n.d'1 0~* Q '1*1 A0-138 CP9 2 Draft p 0-29-84 SSER Format /CP2 SSER 1. Allecation Grouo: QA/QC, Category 5B SQ-T1 RQu79; 2. Allecation Number: A AQ-138, j?, _CJ1aracteristics: It is alleged that' the onsite fabrication shop fabricated component parts such as eyebolts (I-bolts) that had been lost af ter receipt inspections P-Q 'l 7)

• t

~ Wm D is-=-- M m safety-related parts were made in the f abrication shop without the use of any fabrication "instructionsortherequiredqualitycontrolinspections(AO Mam9&gANSM: (1) fabricators (craft personnel) in the iron fabrication (fab) shop were asked to perform work without any knowledge of the paperwa , (2) the paperwork was illegal because it was post-dateh, (3) nonsafety-related material was mixed with safety-related 'd materiali (4) the -supervisor had directed the alleger to improperly cc'or code mater , (5) during consolidation of the elect cal and iron fab d3hd >::j materials were mixed %6)t.hvL safety p-4h electrical sho C g T ..,s,. a i fab personnel used undocumented material, (7) ASME QC,in the fab shop did not check fabricated threa , (8) undocumented weld repairs were made en base mata , (9) threaded rod was cut in he fab shop without QC checking the transfer of heat numbers before cuttin, and (10) arc gouging (cutting) on stainless steel was done too close to the cut line to minimize grinding timchQ - lSh,

a g aw() 4. Assessment of Safety Significance: The implied significance}is that incorrect material may have been installed in the plant rendering system operation and quality indeterminate. . AQ-77_ _ The TRT review of tnis allegation indicates that the processes utilized for fabricating some vendor parts were addressed by site construction procedures, and that the required inspections were identified by quality control procedures and instructions. When vendor-supplied items were fabricated onsite, specific instructions were provided by engineering on a construction operation traveler and vendor concurrence was obtained,- eitherbysign]offbythesitevendorrepresentativeorbycorrespondence. t t l l

N h. TRT monitoring of current activities at the structural fabrication end hanger department shop included the following quality controlled work packages: Sway Strut / Eye Rod H-CS-2-SB-083-002-2 Hanger CS-2-327-406-S56R Rear Bracket VD-2-013-437-536R Sway Strut CS-2-SB-079-005-2 Hanger MS-2-RB-040-004-2 Vortex Breaker Cage MW84-6811-8902 This list of work packages included both safety-related and nonsafety-related assemblies. This work,was conducted concurrently at the fabrication shop and often close examination of the paper [ work was required to distinguish between safety and nonsafety-related work. The TRT reviewed the processes utilized in cutting, grinding, fitting, and assembling components onsite. This review revealed that shop practices were in compliance with approved procedures. However, since not all work in the fabrication shop was safety-related, some work would have less rigorous controls applied. In those cases, the work could be confused as not being in compliance with quality procedures. The TRT found, however, that safety and nonsafety-related materials were adequately segregated in the fabrication shop.

'~ The TRT staff interviewed site personnel who had knowledge of-fabrication shop practices at the approximate time of this allegation. These personnel acknowledged that requests for shop fabrication of replacement parts (e.g., I-bolts) were received in the past by telephone. and were informally documented on a three-part memo, which was not a violation of site procedures. The fabrication shop had recently instituted a formal four-part form to be used for requesting hangers or parts. When a new hanger installation replacement was required, the material traceability was-maintained using the material identification log (MIL). The MILS reviewed by the TRT on the shop work packages listed showed this control process to be effective. The TRT conducted further discussions with the fabrication shop supervisor and foreman regarding the fabrication of I-bolts. The fabrication shop had always fabricated lost or missing I-bolts for hoisting and rigging of vendor components. As such, these I-bolts were not part of the quality-controlled package; that is, they were not subject to the same rigorous standards as permanent hanger and strut components. i Further TRT interviews with field personnel indicated that the I-bolts received load testing and inspection prior to use, and were later removed, scrapped, and replaced with certified hanger or strut components. This was done to assure that appurtenances of safety-related components were not,overstressed during hoisting and rigging activities.

r- - I* i AQf 79 Review TehTRTQerviewed the fabrication , The NRC Tuhoic.i supervisors in the hanger and millwright shops and toured the shops to observe the work being performed. The TRT found that shop personnel were performing work in accordance with procedures CP-CPM-9.9, CP-CPM-9.10, and CP-CPM-9.13. The TRT noted that procedure CP-CPM 9.10 " Fabrication of ASME-Related Components Supports" Section 2.1.4 stated: " Parts for a suoport, e.g. base plates, structural members, etc., may be. fabricated without a drawina or Hanger Package provided they are described on the MIL and verified by DC as required by 2.1.1. However, when the parts are being assembled into a support, 1

. 4 the Hanger Package shall be intact unless the MIL must be removed to fabricate another part." Although the allegation specified no particular parts, the TRT reviewed work packages for a hanger (MS-2-RB-040-004-2), sway strut (CS-2-SB-079-005-2), and vortex breaker cage (MX84-6811-8902). The TRT identified the processes used in cutting material for hangers as mechani-cal sawing, grinding, and thermal cutting methods. The TRT determined that traceability documentation was properly transferred to each piece cut and that the evidence of QC inspector's verification was recorded on the appropriate document. The TRT found that current shop practices are also in compliance with the procedures reviewed. The TRT interviewed representatives from Texas Utilities Electric Company (TVEC) concerning the allegation, but could identify no specific examples of work performed by telephoned instructions. TUEC personnel acknowledged thatcraftpersonnelmayhavereceivedtelephonedrequeststosupplya part, but only in accordance with a previously issued drawing to which the shop had access. When such a request was made, the shop work order would follow at a later time. TUEC personnel also stated that if a hanger installation required a replacement part, they maintained the material traceability by using a:, mete ia'ridenti'icM.ivo list MIL Q he TRT reviewed the MILS on the shop work packages and determined that their statements were correct. e i I 1

O -l 4 la o ( W..:., e, d I e.T ~ To assess allegation 41)/ fab personnel were asked to perform work without O any knowledge of the paperwork)', the TRT performed an unannounced audit of in-process fabrication activity in the pipe support fab shop (commonly Tk 7 .. u e " s tl /, identified as the " iron shop").s Tfie ava ability of traveler packages q and included documentation we a accorr d to determine t the information IP provided was in accordance with procedures and the*. craft personnel wpuld HAD THf AfW)l/2f2 thibb4RTitA (EWr14'NI4l6.. know wha re re ID PEAf06h THE AJJMNE])1AJ/(. a n a 7 d%L dight traveler packages== ndited at the location where the fab activitywasine! process. The travelers audited covered fabrication of N /,,n:u, ASME Code class supports, nonsafety supports, miscellaneous steel.. - / A electrical supports, and modification of vendor-supplied items (e.g., snubber-spring hanger). The TRT found that the audited hanger packages and operation travelers contained the documentation (e.g. drawings and Q ll, '%tWm;wk p.) required by the applicable procedure and i,Ca l i were current for the status of the work in-process. During discussions with the shop foreman and the assigned QC inspectors, the TRT found that the shop foremen assigned to nonsafety supports, miscellaneous steel, and electrical supports could not identify;and were not familiar withjthe fabrication procedures applicable to the activities under their responsi-U. bilities (e.g. B&R CP-CPM 9.9, B&R CCP-21, and B&R ECP-19). The TRT does not view this as a weakness in the foremen's knowledge and abilities; however, it indicate the need for procedure indoctrination and addi-tional training, fvP MC[#MM6h j 1 l a l

~' .h n RegardinggallegationsMI) =d ( fabricators are asked to perform work without knowledge of the required paperworky and the paperwork is illegal if it is post docume the TRT reviewed procedures for fabrication / j AE:7#7 installation, inspection, material traceability and chl issue and p storage,which are applicable to fab activity in the iron shop. The TRT J notes ~the significance of Section 2.1.4 of procedure CP-CPM-9.10 " Fabrication of ASME Related Component Supports," which states: " Parts for a support, e.g. base plates, structural m' ember, etc., may be fabri-cated without a drawing or Hanger Package provided they are described on the MIL W N N i M and verified by QC as required by 2.1.1. However, when the parts are being assembled into a support, the Hanger Package shall be intact unless the MIL must be removed to fabricate another part." The TRT then selected for review 43 of the alleger's annotated items that were identified as material requisition (M R numbers (3th:) design change authorizations (DCAs), and shop work orders j (SW0s). In the review of the documents the TRT found that fabrication activity in the iron shop was performed by use of an MR as a result of a memo request or sketch, instead of the hanger package or traveler as required by procedure CP-CPM-9.9, Section 3.1, which states " Fabrication / installation shall be accomplished in accordance with the hanger package..." The TRT also found that the same condition existed for fabrication per procedure CCP-21, Section 3.1.3, which states "All work shall be accomplished in accordance with controlled drawings." Although the-f9+ coecd:s -that the hanger number is identified on the MR for electrical l n

_) j supports, fabrication was accomplished without the availability of the hanger package in the fab shop where the work was performed. The TRT found that MRs were not properly prepared per procedure CP-CPM-8.1, Section 3.4, " Issuance of Items." MRs issued in the iron shop did not contain the information required by the block titles, e.g., material type was entered in the code class column, 4.he code class was not identified, and the vague information entered for #1 tended use was taken fr,om the 4 requestor's memo or sketch rather than p uc.e.a identificatica given on the applicable drawing, hanger package, or traveler. Considering the condition cited in this assessment, the TRT agrees with the allegation that the iron shop fabricators performed work without knowledge of the ~ proper paperwork. The alleg cuments did not identif specific items for the allegation 4 9 e paperwork is illegal A it is postdated.% This allegation is addressed in the previous paragraph as it relates to work performed without knowledge of the paperwork. In the TRT tem....cci interview with the alleger, the alleger had refuse M o do work per a note paper sketch, h and a day later, a traveler was written to document the fab process, thus the allegation. The TRT found no safety significance to this allegation. To assess the allegation that nonsafety material was mixed with safety material in the iron fab shop, the TRT, accompanied by a representative from the Brown and Root (B&R) material control group, walked down the bulk material (steelyard) and vendor supplied supports storage area to obtain i j knowledge of procedure and methods applied to the segregation of safety i

. fQ. and nonsafety materials. The TRT observed that the material was identi-fiable and segregated as required. The TRT, accompanied by fab shop personnel walked down the iron shop material storage (laydown) areas. The TRT found designated areas for the storage (segregation) of ASME bulk material. A visual sampling of the material identified heat number marking as required. The TRT found that the pile of obviously scrap material, although separated, was not identified as scrap nor was the area identified as a scrap / salvage area. The TRT also found that there were unidentified bulk materials mingled with safety and nonsafety material in the laydown yard adjacent to what had formerly been the electrical hanger shop. This is in noncompliance with procedure CP-CPM 8.1, Sections 3.3 and 3.5 which requires: -3.3 Within each of the storage areas (type A through E as delineated in Appendix 1) safety-related items should be physically separated from non-safety-related items, and identified. Where segregation is not practical, due to size, configuration, or specific storage requirements, etc., positive identification shall be maintained which clearly identifies the material. 3.5 Items which have been withdrawn from the warehouse and are not needed shall be transmitted to the warehouse by the " Material Return to Warehouse" form (Attachment 3). }

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(f In further assessment of this allegation, the TRT noted that procedure I-QP-11114-1, Section 3.1, requires "The QC inspector shall perform random surveillance over storage and control of materials in the Structural / Miscellaneous Steel shop area to assure proper storage and control of materials'in accordance with Reference 1-C and as follows: safety-related material for items requiring traceability through installation shall be segregated from other materials and shall be identified by heat number at all times." The TRT found that there was no documented evidence that the required random surveillances were performed :nd :::c::e5 % c b c' ef d^ =e: 1 ideh j es a noncompliance to the previously identified procedure. In its assessment of the allegation that the supervisor directed the alleger to improperly color code materi the TRT reviewed procedures applicable to activities performed in the fab shop. The TRT was unable to find any procedure requirement for color coding to be applied by fab i personnel at that location. In the TRT interview with the alleger, where the phrase " color code" is used, the alleger also referred to " Nissen markers" (permanent ink markers used to mark metallic materials). The TRT found the alleger's statements confusing and disconnected. Within these statements, the alleger admittedly could determine the material identification (for traceability) either by Nissen marking or by the stamped heat number. The TRT assesses no safety significance to this allegation. w e m ,.m. w,m ,m, r-r-- ,m - r -a,-- v n --e

(1. w c 8 The TRT assessment of the allegation that safety aMpmdety materials were ' mixed was of no concern since the storage area (laydown yard) is now a common area encompassing the fabrication of both electrical and component supports. B&R procedure ECP-19, Section 1.1., states " Material used for hanger fabrication shall be in accordance with detail drawing SI-910/S2-910. Structural steel members are to be those obtained from the electrical fab shop or designated "Q" (safety related) storage areas." The TRT noted that there is no conflict in regard to the storage location, for the alleger identified "Q" material, and that allowed by the procedure. To ass ~ess the second part of the allegation, undocumented material the TRT j considered this allegation.during a shop audit of traveler packages for work in process and during its verification of documentation which was used in the assessments of other allegations reported in this SSER. The TRT found compliance to requirements for heat No., unique No., and coating code No. traceability. The TRT also found that the QC inspection process for verification and documentation assures the use of documented (traceable) material. The alle a specific item. The p r % ger did not identif TRT4 4 c M W ra that impIemented procedures 4 prevent the inadvertent use g of undocumented materials and found no safety significance to this allegation. e It was alleged that the ASME QC (in the iron fab shop) did not check threads on any job unless it was a step (operation) on a traveler requiring QC sign off (evidence of inspection). To assess this 1 's m =-

O ' ll 8-allegation, the TRT reviewed the fabrication procedure CP-CPM-9.10 and the QC inspection procedure QI-QAP-11.1.-28 and found that neither document requires the QC inspection of threads fabricated in the iron shop. The N TRT found that operation travelers aee not required nor used for the fabrication and inspection of threaded rod used in ASME-related safety class components (supports). In the review of the fabrication procedure, the TRT noted that the procedure did not provide identification of the design specification, or a national standard that would enable the acceptable fabrication of threads in conformance with design requirements to assure quality (e.g., size, pitch, length, and class of fit). The TRT interviewed the B&R quality engineer responsible for the applicable QC inspection procedure for the fab / installation of ASME-related supports. He explained that B&R5 rely-on acceptable fit up inspection at installation as the means to assure the quality and acceptability of the B&R fabricated threads. The TRT reviewed a typical hanger inspection report to v.erify that the inspection requirement is defined. The TRT found that the inspection of threads fabricated in the iron shop HlfP/GAW was in compliance with the requirements of the applicable procedures and A assesses no safety significance to the allegation. I l

It was alleged that undocumented weld repairs were made on base metal (plate) which was damaged by flame cutting during the fabrication process. To assess the allegation, the TRT reviewed TUEC procedure QI-QP-16.0-5, w n Reporting of Base Metal Defects,"and B&R procedure CP-CPM 6.9, Welding and Related Processes, for familiarity with the requirements that control the alleged activity. The TRT interviewed the shop general foreman, foremen, W QC inspectors, and welders who stated that it W standardK shop practice to discard a damaged piece and cut a new piece as a replacement. The shop personnel demonstrated a knowledge of the procedural requirements for reporting base metal defects. During discussions, welders demonstrated an awareness of the procedural constraints on repair welding, and the requirements for authorization of, and documentation for, repairs made by a welding process. 'The TRT could not find any occurrences of the alleged Lan 3 event during its audit,and shop walkdowns. The TRT - M E that vy ~ 'b procedures lementes, that the alleged repairs aee not a repetitive v N or common shop practice, and f4m13-that there was no safety significance to the allegation. WM It[ alleged that threaded rod is cut (in the iron fab shop) without QC checking the heat number transfer before cutting,but checking after cuts were made. In its assessment of this allegation, the TRT found that B&R procedure CP-CPM-9.1, Section 2.1.2, requires that the transfer of k traceability marking as. verified by QC prior to cutting except where marking is not possible such as on all threaded rods (threaded the complete length of the piece). It is standard practice in the fab shop to obtain a length of bulk rod, record the heat number on the MIL or other 4ee-

f ls required documentation, thread the rod, cut the required number of pieces, and mark the heat number on the ends of the cut pieces. The marked cut pieces, and any remaining length of the threaded bulk rod, were then presented to the QC inspector. By N M the number etched on the cut pieces to the number recorded on the MIL and on the remaining bulk rod, the QC inspector verified the accuracy of the number transferred. The TRT witnessed the threading of rod, for drawing Item 15 of hanger SI-2-031-430-S32A, and found that the activity was in compliance with procedures CP-CPM-9.10 and 01-QP11.1-28, which are applicable to Re fabrication and inspection. The allegation implies that the QC inspection was out of sequence with the procedures.,Since it was demonstrated that traceability was maintained the TRT o safety significance to the allegation. L<.>e2) It was alleged that arc gouging (cutting) on the stainless steel -45 done as clo % 1 se Ito the cut line) as possible to cut de 6% (minimize) es grinding. 7 The 79T found that B&R procedure CP-CPM-9.10, Section 3.3.5, that: " Stainless steel base plates may be thermally cut by arc gouging. After the thermal cutting process,1/8 inch of material shall be removed from the thermally cut edges by grinding." To assess the allegation, the TRT W interviewed the shop foreman and QC inspector who we responsible for the fab and inspection of ASME-related supports. The shop foreman stated that W it +9 standard shop practice to layout stainless steel materials to an oversize cut dimension of 1/8 inch minimum when the prescribed method of Lv % > h cutting by arc gouging. The foreman also stated that is standard shop practice for him to check layout dimensions prior to cutting of materials i

by the craft. Although not able to check 100 percent of layouts, he stated with confidence that he does check more than 90 percent. The M assigned QC inspector stated that the cut edges see checked visually for acceptability concurrently with dimensional inspection prior to release 1 from the shop. The shop foreman then stated that he performs a check of I the traveler package and a visual check of the fabricated item condition to assure acceptability of the job before it is released field install-ation. There was no arc gouging activity in-process for the TRT to verify. Arc gouging and removal of the heat affected zone adjacent to the cut is a standard practice in the industry. The TRT could find no W b M examples.....a_.., The alleger reque.sted that the TRT look specifically at two jobs: f, f d n i y (1h h am clips that may have been cracked, and /d 4 s' i spf" r (g.) ktriple hook on a thirty foot long stainless steel which was hot 4 formed and documented after it was built. In its assessment of i4es @ the TRT found that the allegation referred to beam clips formed (bent to prescribed angles) for welded installation in the patch panel platform in the reactor building (RB), Unit 1. The clips tified in the bill of material included in DCA 17551, Revision 6, l to crawing 2323-SI-0525 as piece 20, SA36 plate (structural steel) 3/8" x 3 1/2" x 8".

) o The TRT was unable to verify the alleged condition of the clips because ~ they are welded in place with the outside (suspect) radius on the hidden side. To assess the potential for the alleged condition, the TRT requested that the fab shop form a 90' bend on a like piece of the same heat number material from which the original clips were fabricated. The sample piece was cut as a longitudinal section (with the grain) and cold formed to a 90* angle. The outer radius was then wire brushed. Visual inspection (without magnification) by the TRT detected minute surface a imperfections which the TRT assessed as not er i od u t relevant g indication (defect). The sample was then checked by the craftsman who cut and formed the sample, and inspected by the QC inspector with assigned responsibility in that area of the shop where the original clips were produced. Both agreed M that the piece was acceptable. The piece was then subjected to a nondestructive examination by liquid penetrant (PT),visiblecolorcontrastmethod/andfoundtohaveno indications. The TRT found that the forming of clips was in accordance with allowables specified in the American Institute for Steel Construction l (AISC) handbook and that the alleged condition is not a concern of safety significance. In its assessment of ik2) the TRT researched the FSAR and interviewed TUEC project engineers to determine the identification and application of the device described by the alleger. The device could not be identified. W The TRT determined that there eve low fuel limit switches installed in the diesel generator fuel oil storage and transfer system) kowever, the TRT w verified that the switches ese an integral electrical unit supplied by a ii

I vendor and do not require any associated site fabrication for installa-tion. The TRT interviewed the fab shop general foreman, and although the stainless steel chain was an odd or unusual item,-he could not remember 49te fabrication. The TRT also interviewed representatives from the material control group and the millwright department and could not find an example of the alleged device. No further action was taken by the TRT. J 9 r t I i 1 i i

k 5. Conclusion and Staff Positions: TheTRTconcludes:hyonsite g { fabrication practices were properly controlled by construction and A G-7 7 C g,y inspection procedures and by instructions. The TRT review did not identify 3 instances where the fabrication shop manufactured safety-related replacements without the appropriate procedures or without QC supervision. Therefore, the TRT finds that this allegation has neither safety significance nor generic implications. AQ -79 gtidib: Based on a review of applicable documents, shop '.nspections, and interviews with TUEC personnel, the TRT concludes that the allegation that the fabrication shop cut new parts to telephoned g instructions rather than to written instructi.ons cannot be traced to a T specific event and, therefore, cannot be substantiated. Some nonsafety-sh related parts may have been fabricated based on telephoned instructions; however, shop practices for the fabrication of safety-related parts were in compliance with procedures. Current fabrication shop practices also provide adequate assurance that material traceability was maintained in compliance with the applicable procedures. Accordingly, this allegation has neither safety significance nor generic implications. Q3i.w p Aq-r38 i e m a-m e s - a-^ ' # Ab-

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Q-3( C M tafLJo A h By review of procedures and documentation, an audit of fab work in process, witnessing the fabrication and PT examination of a comparison sample, witnessing the fabrication of d threaded rods,3walkdown verification of material laydown storage areas, the TRT assessed the stated allegations. The assessment also included interviews with B&R shop foremen and craft personnel, QC inspectors, a_ quality engineers, material control personnel, project engineers and>TUEC d instrumentation engineer. h 9 The TRT found that the allegations, working without knowledge of the paperwork and QC did not check threads, were substantiated. The allegations that safety and nonsafety materials were mixed, electrical he shop safety materials were mixed with iron shop materials,Aheat number transfer on threaded rod,[ cracked beam clips, and improper color codQ-were not substantiated. The TRT was unable to substantiate the allega- ,,.. o a tions that ee paper work was postdated, undocumented weld r ir on base p qo metal, arc gouging oT stainless steel, the Atriple hook on a s el chain, and use of undocumented material used by electrical shop. Procedural noncompliances were found by the TR owever, the TRT notes that the items were of a localized nature and therefore concludes that there is no safety significance nor generic implications to the allega-tions. l In a meeting with the alleger on November 14, 1984, the TRT presented the results of the assessment of the allegationsand the TRT's conclusion. A brief discussion ensued. There were no major items of disag-eement and no new concerns or allegations were identified.

/ 6. Actions Required: TUEC shall initiate imm(3(hte corrective action to ~ assure that the scrap and salvage pile in the ' Iron hab Thop\\ aydown'Kard t \\ \\ is identified and sufficiently segregated and restricted to prevent access to and inadvertent use of the material. TUEC shall conduct a documented training session for those persons who prepare and process material requisitions to assure that information is entered where and as required and the intended use description enables determination of the quality requirements and establishes traceability identification to the item in or on which the fabricated parts are used. l l I ( i I l

i i TUEC shall conduct a documented indoctrination and training session for those' foremen responsible for gon hgop brication activities controll'ed by ocedures CP-CPM 9.9, CCP-21 and ECP-19. TUEC shall review, evaluate, and revise the applicable procedures to identify the specification or specification requirements which assures that the threaded item characteristics comply with design specification requirements. A typical example of industry standard identification of threads is given as 1-8"X6"L UNC CL2A which provides a typical specifi-j cation and design requirement for a threaded item 1-inch diameter, 8 threads per inch, 6 inches long to a national standard class of fit (thread interference with the mating device). TUEC shall take appropriate action to assure that the return of unused or unneeded materials complies with procedures. The action may be in the form of an audit or documented surveillance. Although the noncompliance is identified as a singular event, the TRT noted that the site is effectively undergoing cleanup (consolidation of fab shops) and there is potential for repetition of the noncompliance. TUEC shall initiate @ corrective action by performing and docu-i menting the site surveillances required by Q -QP-11.14-1. TUEC shall initiate % corrective action to assure that the kron Kab4hopactivitiesareprovidedwiththerequireddocumentation: hanger a 1 e e o s --+ s e-e y

I m, ,c. ,- -- T. x'" -1 packages, travelers anc drawings at the time qwand tp. location where .the activity is performed. TUEC shall initiate't{r,eb action to assure the removal of (or identify ~ cun Ldv and segrecate) the indeterminate material which is mingled with G add x e n livn-@ materia in the former lectrical(hop ydown rd. TUEC shall perform an investigation to identify and report the usace s% application for a treble hook on a thirty fcot stainless steel chain fabricated in the iron fab shcp identif.ied as an ' emergency low fuel limi-switch.' 3.5WNfhN,n, x. i-r.dUV W sA.w.@.; e +;.% :<?..&..y#W Y

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4 1 i 8. Attachments: None. 9. Reference Documents: CP-QAP-11.1, " Fabrication and Installation Inspection of Components, 1. Component Supports and Piping." CP-CPM-9.10, Rev.11, " Fabrication of ASME Related Components 2. Supports." CP-C P 9.13;3Re W L uiT; d ion v F M "7 eve W N 3. a _r aea** a = wa r v i.e.,. _f* W in., .n _.. W-t

u. o m. _ r, __ _11_..

m oc. ne..weu o v. m. n b3.CPkPM-9.9,Rev.8,"NNS-SeismicCategoryIISupports." E 9,CP-CPM-9.13, Rev. 10, " Modification of Vendor-Supplied Catalog Items." b G, AlicMim. 03 cmu..ncd tTUGC0 letter TXX-4180 tdMW dated May 25, 1984, i n n s. (-, b 4 RT TecHal %terview with alleger A-59, September 13, 1984, M e!!cgcr feraichcMc;. M v..cc.;:t4n raenede - MaeSar " and 5, !QGb g,FSARFigure9.5-52, sheets 1and2. q, 4 B&R ECP-19, " Exposed Conduit / Junction Box and Hanger Fabrication and Installation." @ C CPD S.lG, "Foui.uu?..ca O MS"I :1c h +h.p c r.5-t S u pf' W " M-O u I

fh27 .J 7, @ B&R CCP-21, " Fabrication of Miscellaneous Steel." / O. t B&R CI-CPM-8.1, " Color Coding of Piping Materials." B.dMr.,sv.0, w mf h W a h r Sp A d-0 esA l l. 2. B&R CP-CPM-6.9C, " Material Identification." / 1,-t;b. B&R CP-QAP-14.1, " Inspection of Storage and Maintenance of Permanent Plant Equipment." /3@ B&R CP-QAP-8.1, " Receiving Inspection." / W -tik B&R QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports." H -ii&R CP-QAFdL1, "Fabricetice-Wet +14atinn inep^rtio cf -Ecf;b C h:: C=per.c..d,- Compenent s"nnnrts, anchtm:L

15. B&R CP-CPM 6.9D Welding and Related Processes.

16. B&R MCP-10. " Storage and Storage Maintenance of Mechanical and Electrical Equipment."

17. B&R CP-CPM-8.1, " Receipt Storage and Issue of Items."

18. TUEC QI-QP-11.10-1, " Inspection of Seismic Electrical Support and Restraint Systems."

19. TUEC QI-QP-11.16-1, " Installation Inspections, of NNS Seismic Category II Supports for Class V Piping."

20. TUEC QI-QP-11.14-1, " Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel."

21. TUEC QI-QP-16.0-5, " Reporting of Base Metal Detectors."

22. TUEC QI-QP-11.4-4, " Control of Material Traceability for Site Fabricated Structural / Miscellaneous Steel."

23. Design Change Authorization 17551

'i

4

24. Hanger Packages, CP-82-086-8903 CP-82-008-8903 and j

j CP-84-224-02-8902.

10. This statement prepared by:

J. Malonson, M Q M M, C* R Reviewed by: H. Livermore, g ate Approved by: V.Noonan,[ Date n-,, a m-n : AD3 To REf3 ' 2E x nuEUA A-3 srATEHENiMD MifRHEhl$hGR[) M e w N *t! &&=) mBs;uTwR. 7wt W Thi R wa N 5 % 64

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COMANCHE PEAK SSER FINAL REVISION CONTROL SHEET ' Allegation Nunbers: Md-7 7 Subject of Allegation: Y4/7, egg,,) op [ogy lfgoyhy L TRT Group: h g [g g* ~,,, Author: h/sec This is the FINAL revision to the attached document. Please sign the last page, place a photocopy of it in your file and return the signed Original with the complete allegation packag to V. Nooaan in an envelope marked " FINAL SSER." ~;, -~w&,7~~*:T~" :-!=~QKF3 N_ MM<y A ss sh ~gd, ds a Esss!~..kJ.h warn- /. I h' J h l 1 (

9 SSER Allegation AQ-77 Revision 1 10/29/84 SSER 1. Allegation Group: QA/QC Category No. 5B 2. Allegation Number: AQ-77 3. Characteristics: It is alleged that the onsite fabrication shop fabricated component parts such as eyebolts (I-bolts) that had been lost after receipt inspections. 4. Assessment of Safety Significance: The implied safety significance of this allegation is that lack of quality control in the fabrication shop could result in unknows or substandard material being used in a safety-related system. i - The TRT review of this allegation indicates that the processes utilized for fabricating some vendor parts were addressed by site construction procedures, and that the required inspections were identified by quality control procedures and instructions. When vendor-supplied items were fabricated onsite, specific instructions were provided by engineering on a construction operation traveler and vendor concurrence wa's obtained, either by sign off by the site vendor representative or by correspondence. i I L

• ' TRT monitoring of current activities at the structural fabrication and hanger department shop included the following quality-controlled work packages:

Sway Strut / Eye Rod H-CS-2-SB-083-002-2 Hanger CS-2-327-406-S56R Rear Bracket VD-2-013-437-S36R Sway Strut - CS-2-SB-079-005-2 Hanger MS-2-RB-040-004-2 Vortex Breaker Cage MW84-6811-8902 This list of work packages included both safety-related and nonsafety-related assemblies. This work was conducted concurrently at the fabrication shop and often close examination of the paper work was required to distinguish between safety and nonsafety-related work. The TRT reviewed' the processes utilized in cutting, grinding, fitting, and assembling components onsite. This review revealed that shop practices were in compliance with approved procedures. However, since not all work in the fabrication shop was safety-related, some work would have less rigorous controls applied. In those cases, the work could be confused as l not being in compliance with quality procedures. The TRT found, however that safety and nonsafety-related materials were adequately segregated in the fabrication shop.

i e

-1

.. The TRT staff interviewed site personnel who had knowledge of fabrication shop practices at the approximate time of this allegation. These personnel acknowledged that requests for shop fabrication of replacement parts (e.g., I-bolts) were received in the past by telephone and were informally documented on a three-part memo, which was not a violation of site procedures. The fabrication shop had recently instituted a formal four-part form to be used for requesting hangers or parts. When a new hanger installation replacement was required, the material traceability was maintained using the material identification log (MIL). The MILS reviewed by the TRT on the shop work packages listed showed this control process to be effective. The TRT conducted further discussions with the fabrication shop supervisor and foreman regarding the fabrication of I-bolts. The fabrication shop had always fabricated lost or missing I-bolts for hoisting and rigging of vendor components. As such, these I-bolts were not part of the quality-controlled package; that is, they were not subject to the same rigorous standards as permanent hanger and strut components. Further TRT interviews with field personnel indicated that the I-bolts received load testing and inspection prior to use, and were later removed, scrapped, and replaced with certified hanger or strut 'i

_4_ components. This was done to assure that appurtenances of safety-related -ccmponents were not' overstressed during hoisting and rigging activities. 5. Conclusion and Staff Positions: The TRT concludes that onsite fabrication practices were properly: controlled by construction and inspection procedures and by instructions. The TRT review did not identify instances where the fabrication shop manufactured safety-related replacements without the appropriate procedures or without QC ~ Therefore, the TRT finds that this allegation has neither-supervision. safety significance nor generic implications. 6. Actions Reauired: flone. ,/ ~ 3.$kdhM ? paw &l%Ijpgh7g;gykdg$g'O@ h ~.9;q,d[jgpg,,g:bu:busyg { jb c 8. Attachments: tione. 9. Reference Documents: 1. CP-QAP-11.1, "Fabricatien and Installation Ins: action of Com:cnents, Ccmponent Supports and Piping." 2. CP-CPil-9.10, Rev.11, " Fabrication of AS !E Related Components Supports." 3. CP-CPil-9.13, Rev.10, ":ledi fication of Vendor-Supplied Ca talog." i

l I 94 - 5 4. A-3 Statement and Interview. 5. -GIAP Witness H #11.

10. This statement prepared by:

M. Bullock, TRT Date Technical Reviewer Reviewed by: H. Livermore, Date Group Leader Approved by: V. Noonan, Date Project Director O e l

/ .a-7..f l L, Q ' s',,.'. \\ \\ SSER WRITEUP DOCUMENT CONTROL / ROUTE SHEE'T Allegation Numbers A C-? ? Subject of Aliegation FA A n e A ne d o -P Le J f UtS&OC4 A A A 'YJ TRT Group b 0 4 kJ c C 6 *r A C, e,t y .S-R o n.c ; + T FABAzrnY;w Authar: Laom L PSd This sheet will be ialed by each reviewer. It stays with all revisions to the SSER writeup and serves as a routing and review record. It will be filed in the work package when the writeup is published. J _ _ __, _,_, _ n p + y.. i. ~ ._ _ -..... )... - - 4 Draft Author Group Leader -7 h [ Tech. Editor /} -h d Wessman/Viet ~ I'[ J. Gaoliardo T. locolito i g. ~ Final Author ~ Tech. Editor Grauo Leader ..e. ic_Yf1,3'.._ YY J. Gaaliardo ' i T. Ipoolito l' i ny Administrative f /y ~ Writeup integrated into-SSER f Potential Violations to Region IV // 0I Workpackage File Complete 7 Workpackage Returned to Group Leader k j cud vy -w ,,.m ,--_.-v .--.,----,.-w.--------,--,..-,e.- .,-ra

~ ' Y b

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te wg i l SEER WRITEUP DOCUMENT CONTROL / ROUTE SHEET j Allegation Numbers A C: - Y/ " c'. H N b VI^ e Subject of Allegation 4 n m=uwer r; "eahc m : m - TRT Group C A / c., r Author: c',; v n= /w A m o-e This sheet will be initialed by each reviewer. It stays with all revisions to the SSER writeup and serves as a routing and review record. It will be filed in the ~ work package when the writeup is published. Draft Number Draft Author % Q_ f Group Leader / Tech. Editor Wessman/Viet T[ opol t Final Author Tech. Editor Group Leader J. Gagliardc ~,,.., - , _., ~ i '" '~ f * ' i i ' T. Ippolito ~f ' ' ~ ' 'i' ,/; Administrative ...I'*1 Writeup integrated into SSER ..Y.' ' Potential Violations to Region IV g / Workpackage File Complete d Workpackage Returned to Group Leader 7lR 'k t\\T l i l I

Document flame: AQ-77 Requestor's ID: DEDIR02 Author's Name: Chet Poslusny / / Document Comments: I l

0: cum 6nt 'N' me : o...AQ-79 AQ-77 7i /3[ a j l

• ?"

, Requestor's ID: LAVERNE WC2. % Author's Name: 4-Poslusny Document Comments: 12/13/84 Redraft 1[ space. e f I L_

i h, ./ [ AQ-79 (; l Q-138 CP9 [ rj Rev. 1 m SSER Format /CP2 SSER v ,.. \\ 1. Allecation Grouo: QA/QC, Category 5B I !'/ 2. Allecation Number: AQ-77, AQ-79 and AQ-138. ffflY 3. Cha racteri u s: It is alleged that the ensite structural fabrication and hanger shop (iron fab shop) made component parts. such as eyebolts (I-bolts), AI AEf!ACEDf]V ?~1 fpM/W7J74fif*W7549Jf/]5%llCCEAKjfd'imrl [Md~77, d ' hat safety-relatec t parts were mada in the iron fab shop without any fabrication instructicns or the required quality control inspections (AQ-79); and that (1) craft personnel in the iron fab shop were asked by their supervisors to perform work withcut any knculedge of the paperwork, (2) the paperwork was illegal because it was post-dated, (3) nonsafety-related material was mixed with safety-relatad material, (4) the superviser had directed the alleger to improperly color ccda material, (5) during consolidation of the electrical and iron fab sheps, safety-related materials were mixed frca both areas, (6) electrical fab personnel used undocumented material, (7) ASME QC per-sonnel in the iron fab shop did not check fabricated threads, (S) undocu-mented weld repairs were mada en base metal (9) threaded red was cut i-tbYOI the iron fab shop without a QC check tt+t t.e heat numbers h44 6-en.. i 1 I L2r.md bifore cutting, cnd (10) arc gouging (cutting) on stainless steel was dona tco closa to the cut line to minimize cr nding time (/// 6fMM.'_.[J hAf rti:v'E.?E.f's U.,llAG :tlAlld O ' fAl3 dAT10.') fiU CE.$.5 AN.bhb A D5q/f tf( 37,1)ll25! fjh H)l.L Allb dllAt th '.!.45 AA %!!dT53 00TdS[G)/T;!Ot)Ttildf.tD TC \\ P A6tE3 025' J g-Assessment of Safety Sionificance: N5 lbl?Ll[Q'[Js' hfLY//g)//kO[fRpfyy,f gggg TuC 1 ULuni_f u p!;jg gir,i A 3.g gy7,yg/,p gg wyy,g 9,,9,,y 3 gyg. ;, 550A58-M.y /tlJ!s'[_ f!5ft)Lff[//L fHi_j/bff;Hjj[jy;f_ (C pygggCl, - N O f Il25, CL? /YOR h y LQl/]l.t(, s']diijJ,1 (__ptj z i;!,"s7 g y y pg,y g,,j g OSTA '4 9 {&& 0/%/7Y d/{D. h0/kL/n' 5/0E)M>>j/Htff. Q t I)s g.)-i [ The IRT review of this allegation f hj Q that the processes utilized Jf Ce nr M u T' for Brown & Root (ESR) fabrication m.li/ C(mygjp parts were addressed b:. 4

_.)]JTONj[An&fiDn fApfBLIpit1PCPn 9,to FA&tiitRIGA d[ASHf_SEMG a dQdNedEhl3 Ad)).B BECHfNEdikib8Ti Alt 2C.Il/E al.?.ZN32fcTiDN tJ_fGATAfLW i / _._ _.!]V ?/2 tDdddI RAl-_*/{.l?A? N221LANONJ%Q!//WdM/tT[$d[R21FEGMAgE_ 0 MEDy_dinM danPbfAEHF"@ w Taiinn?aiLW/)Asocsr6N_fdo? NE50O N 5fE d5 W S lA Nd/M W /V N /p/Zji /N fry gE'f When vendar-k o and modifications were fabricated onsite, supplied item', replacements specific instructions were provided by engineerina on a construction L._ ~~ operation traveler and vendor concurrence was obtained, either by signof f by the site vendor representative or by correspondence, f//T pyff/gg7fpg l .~ A C? H I N I l/ U. b N N / Q W ? M 4 M E d b f pg_ f._/J 2 1p), fig 4 f/p y_ p j' y q ptz t ~ 4'7//E[/486f/fk/TEhc7 6 - TRT.l/AN/NO the following quality t controlled work packages from the iron fabnt#/oNJNv/ 4N3 /Dd/O THAT ~ l_; THE dbfLA WAf FEAFohMlQ Agfj jygyggfg jy cogpLINtf.Z Wii'll THi l A7PLil Ab LE hfLO LE30 M, Sway Strut / Eye Rod H-CS-2-SB-083-002-2 i Hanger CS-2-327-406-556R Rear Bracket VD-2-013-437-536R a l Sway Strut CS-2-SB-079-005-2 -4 Hanger MS-2-R8-040-004-2 Vortex Breaker Cage MW84-6811-8902 ,I - ~} This list of work packages included both safety-related and nonsafety- -4 related assemblies. Since both safety and nonsafety-related work was conducted concurrently at the iron fab shop, close examination of the Of A A7liN TilAvf LIRj AIG Thf was required to distinguish between them. The TRT also i H A W,6 fL Pall 4 A 4[5 ng and ~ reviewed the p'rocesses utilized in cutting, grinding, it l_ assembling components onsite. This review revealed that shop practices q in compliance with SE _n T]LiCA2Li r'1<cCE~.DollE6, itta fttal' MAGI 2ial ARE i _NDYbODf)A$$ . - 147. I&[JtML&2fpi SMA84iCardMLTEM,XL M T/L Thla.' JMf4&k ..Af(.?AdlMEnaf17/[/N7/ASAnt!NENflY $UE ?idd/MEAJf4TO.?!WW- -.. dHc0aSt2tt,tfit1THfZb7Md}MdddnZL.Ba Vf#wMiGdm/ RHT- _ uenon&sthMA&4 AwKxmL M Xhn wqLE McLe .-. 8/CG/6AM7 NfMitML YEiGok bM70197Le fHQf $20$ 4At2[.htf-.

YA/-f 0f THE GV4Uff CONfdeaf.? f/CM/f[ermanent, hanger and strutr subject to the same rigorous standards as Further TRT interviews with field. installation personnel components. indicated that the I-bolts rNbd. load tMg and iri 'pl[tNn prior Eo 'ad --a-ad

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safety-related components were not overstressed during hoisting and rigging activities. THE TRT 2/311DT fnB ANY 2XAMPLE$ df unbMDME*T@, FA8(UCATIDH 0F I 8DLT.b UAC.0 Fo 6 PF.AMANYHT'PLAMT lW ~ O ~ 59 7 - w= - -

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fo $21ET.17hi ALLMMf/#N' TMf)ff7V /(LATMatW. A/f4i AfdSE. /L1775 N2DN.LAjaJlA Ts DN JHf 9 41/1No V[_ds)' ABA$AN/dJ_/tHd&'1CNk dif/t[ AffffAc$ AMU &C_/n2[Cfl9N/j fitt YA7 /Nff2 VIE fd DifN/EduSML/JOA~ JEQEC/L4ff h/ pef]do_hE' /L, AiV/ EWE 2 TME APPt.ic_diktJ_ftletiJuts2 2,ies pn:JaVKiMP / Ar/A/(,tr/#N QVQlM /d ?/2t?C'E$3 ' Jf hMWet/NYJ YM'Af Y/fif <f/lQ0.[d5A/CAf/PdlGCAA isW Ofstepr512 Y PtwT3 usi t:P'.CP FI-f.J2_ /ABAffaf/fL dE. AJME.-J2Ebt1G. $Cf]P/pE}tl' t/hP/O8 T!4.Ad$5YN- $/$- W!ff dATION $5-.Il5AE0LIGEN55 _. 0AfAl0dr. Af5Mds- ?/f5h,..-.Sf[Gf/CN/)f8/(At5,/EIhNi.Ah6L/&. l&$$AEW 5Lf' hA?~ll-l'$b.0/W$AZ/GA 4N50/f.fi444Y/"Cdjd(/EEfDRM_ W 1 awiry sw:S dwfysiiv7M/wws.186 TALeiG rMBacGonL G-(.3M 4, &{$cnM.1J,LSTATG.!. Parts for a support, e.g. base plates, structural members, etc., may be fabricated without a drawing or Hanger Package provided they are described on the MIL and verified by QC as required by 2.1.1. However, when the parts are being assembled into a support, the Hanger Package shall be intact unless the MIL must be removed to fabricate another part. 4. dup w... -.. -.. y.u.r- .p.,a wen =.+- W ^-~.em= vea s n e.um e

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_ _ m, Q ffd){[$l dCA//WLJ' D5fS[dECAMf fd5 dl?/1/LWE2AlYNdk/t/dCt/W/N us;sua ro ret nrwrromEasex, arnaxsa azrainmonsay May1_tBEin Acd9MftJJ/lih W>TMwiDethfEM14tafAcW/edd, ddME 2/07 Qt' /NJPEUtM hA,YM47HMEFEA ff//f2 ttG[1Ad ACJZPTR/WEf AA Nf, /2 A5 QE MA15//dAL-[Aff$A$AJ(f /J-h%(28$0?& kW/EM&rtM,W /Neg&u)Ttet...u THE NaKiA. iMZffiMJEfosiaf@C*P Jl I*2C AT&YH & / ~l k.h.5h$ESN h!-- b Y$ --- - f -lN-.- llk$ h$$O 42EeE,24 rMEw&p'grQw/>fk2ptonD&T/0$(MJT/kxr/oM)A Y [N5 Y/BE-j2/d[.}t/D)$[// fT&/Z.HcW_/H_fdi_/SOf]_[jf/]f1/f/PHcfffGS____ Although the allegation specified no particular parts, the TRT reviewed work packages for a hanger (MS-2-RB-040-004-2), sway strut (CS-2-SB-079-005-2), and vortex breaker cage (MX84-6811-8902). The TRT identified the processes used in cutting material for hangers as mechani-cal sawing, grinding, and thermal cutting. The TRT [04J7 that traceability documentation was properly transferred to each piece cut and that QC inspector verification was recorded on the appropriate docunient. e-w..ep* wee 66 w Mw.Weo.em-mwn.--.m-mm-- -*wm

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1. j The TRT found that current shop practices a're also in compliance with the procedures reviewed.

The TRT interviewed representatives from Texas Utilities Electric Company . (TUEC). concerning the ' allegation, but could ' identify no specific examples of work performed as the result of telephoned instructions. TUEC personnel JHW acknowledged thatTaiIMN FA2Rl(Afas/,rnay have received telephone requests to FABAftgr a part, but only in accordance with a previously issued drawing to which the shop had access. When such a request was made, the shop work order was subsequently sent. TUEC personnel also. stated that if a hanger installation required a replacement part, they maintained the material , traceability by using the material identification log (MIL). The TRT reviewed the MILS on the shop work packages and determined that their statements were correct. AQ-138 To assess the allegation that iron fab she personnel were asked to perform s work without any knowledge of(the paperwor, the TRT performed an unan-eJ. DttawlNU Ta AVELEA $ AIO HMN &iA.!ACKA&E6) nounced audit of in process fabrication activity in the iron fab shop. The TRT assessed the availability of traveler packages and the included documentation to determine if the information provided was in accordance with procedures and if craft personnel had the required information (docu-mentation) to perform the assigned task. The TRT audited eight traveler packages at the location where the fab shop activity was in process. The travelers audited covered fabrication of ASME Code class supports, nonsafety supports, miscellaneous steel, electrical supports, and modification of vendor-supplied items (e.g., a snubber-spring hanger). The TRT reviewed procedures for fabrication / installation, inspection, material traceability, and receipt and storage, all of which are applicaWct_ivities performed in the iron fab shop. ThiTRT Fo0NS 7ttATTiti audited hanger packages and operation travelers contained the documenta-h tion (e.g. drawings and Mils) required by the applicable procedure and were current for the status of the work in process'. --r-w% - -, - - ~ -r--, ,,-y.

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t applicable drawing, hanger package, or traveler. Considering these condi-tions the TRT agrees with the allegation that the iron shop fabricators performed their work without ' the required paperwork. The alleger did not identify any specific items for the allegation that the paperwork was illegal because it was postdated. This allegation is addressed in the previous paragraph as it relates to work performed without knowledge of the paperwork. In the TRT interview with the alleger, the alleger had refused to do work per a note paper sketch, and a day later, a hfs,thustheallegation. ' traveler was written to document the fab The TRT found that although sketches were used the material issu,e, fabri-j cation activity, material traceability, and Q.C. inspectionjyt; documented on an accompanying MR. The MR tra eled with the fabricated items to the is[tallationlocation,wheresubs'eugentQCinspections.documentedthe acceptability of the item in the hanger package or on the operation traveler. To assess the allegation that nonsafety material was mixed with safety material in the iron fab shop, the TRT, accompanied by a representative from the Brown and Root (B&R) material control group, examined the bulk material and vendor-supplied supports storage area to learn the standard { onsite procedures and methods for segregating safety and nonsafety mate- ] rials. The materials were identifiable and segregated as required. Based on the satisfactory compliance with methods and procedures in those areas, the TRT, accompanied by fab shop personnel, also examined the fron fab shop material storage (laydown) areas. The TRT,fenad d i t d areas for the storage of' ft#ETY M.thT(y Sum Marid)Alf M,es,gna e A sampling of ~ ' the material revealed 3 eat number markings, as required. The TRT found however that a pile of what was obviously scrap material, although sepa-rated, was not identified as scrap, nor was the area identified as a scrap / salvage area. The TRT also found that there were unidentified bulk materials mingled with safety and nonsafety material in the laydown yard adjacent to the former electrical hanger shop. This condition is in n'oncompliance with procedure CP-CpH 8.1, Sections 3.3 and 3.5 which requires:

3.3 Within each of the storage areas (type A through E as delineated j-in Appendix 1) safety-related items should be physically separated from non-safety-related items, and identified. Where i segregation is not practical, due to size, configuration, or specific storage requirements, etc., positive identification shall be maintained which clearly identifies the material. 3.5 Items which have been withdrawn from the warehouse and are not i needed shall be transmitted to the warehouse by the " Material 1 Return to Warehouse" form (Attachment 3). In further assessing this allegation, the TRT noted that procedure - QI-QP-11.14,1, Section 3.1, requires that "The QC inspector shall perform random surveillance over storage and control of materials in the Structural / Miscellaneous Steel shop area to assure proper storage and control of mate-rials in accordance with Reference 1-C and as follows: safety-related material for items requiring traceability through installation shall be segregated from other materials and shall be identified by heat number at all times." The TRT fouhd no documented evidence that the required random 4 surveillances were performed, a condition in noncompliance with the proce-dure quoted. IT UALALLEGED_ZBRT A _JdflMDA hAECZE1LLOAU 7EdDNNELH07~ TD.. BM/ UNDE.TEt2MIMIE_lcrA1TMCEABL f-) MATEMhL10.1 DEN T) ElStti.MA

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r /d ThE 7p.7FotNG THM B&R procedure ECP-19, Section 1.1., states in part " Structural steel members are to be those obtained from the electrical fab shop or [from] designated "Qa storage areas." The TRT noted that ..u. according to the procedure, there 1.s no. conflict in regard to the location .from which.the "Q" materials arFlo?aM.a. fY_," ' f % y ' _ % +t : ^ L Lg 4 ,A THt MtM 1H Tag cdtraucal r,4eatcarnu $147, To ass ss the allegation concerning undocumented material, the TRT audite vr ELECIRKALlo7?DATS 7AAuftfA Pitube&D AD bBJEB.vELDIE 3DP FABA 1(.ATLDs AfbAk. tH 9RbLfsS, THC Tr(T ALIa toML'% RED THG A 33W WNLb(_DiLLALUl4kT10N-00lM% THE TRT HRICnCMIDh bf 3DLddHTNTI6 d fDR. 7)fLA 1L($$hDtT15_6 DER _ ALLCLATIDN.4 9C9aR* FED /hl TH1LLSXfR (e 9 M ATEluhLTMC.EABlLl'Lt-Luc &aLtT8fol1MG-WGJibuLLL ;1 hqi s*Dtd nC Th*C %2EE.l.)biUD. ! The TRT found compliance with traceability requirements for heat number, unique number, and coating code number. The TRT also found that the QC inspection process for verification and documentation assures maNb. Although the alleger did not identify a theuseoftake'ab 1 specific instance of undocumented material, the TRT f#nds that the proce-dures as implemented prevent the-in S t use of undocumented materials. It was alleged that the ASME QC in the iron fab shop did not check threads on any job unless it was a prescribed operation on a traveler that required QC inspection. 'To assess this allegation, the TRT reviewed fabrication procedure CP-CPM-9.10 and the QC inspection procedure QI-QAp-11.1.-28 and a found that neither document requires the QC inspection of threads fabri-cated in the iron fab shop. The TRT found that operation travelers were neither required nor used for the fabrication and inspection of threaded rod used in ASME-related safety class components supports. In its review a of the fabrication procedure, the TRT found that the procedure did not provide a general reference to design drawings nor the identification of ] the design specification or specify a national standard that would enable the acceptable fabrication of threads, in conformance with design specifi-l cation, to assure quality (e.g., size, pitch, length, and class of fit). e

l Th4TRT interview d d. B&R quality sngineer -/JJ/S/rE) T4 4fM( Af4 7gg 7 ~ ppl8 ' CeA frAccnoM#fWITIES WHg4 l $tr' explained that B&R relied on an acceptable inspection during.installa- ' tion as the means to assure the quality and acceptability of the-B&R fabri- .cated threads as defined in QI-QAP-11.1-28. The TRT also. reviewed a typical hanger inspection report and verified that the inspection riquire-ment was defined. The TRT found that the threads fabricated in the iron fab ~ shop were inspected in compliance with the requirements of the [' applicable procedures, ATM/TW4/FMM - It was alleged that undocumented weld repairs were made on base metal (plate) which was damaged by flame cutting during the fabrication process. f To assess the allegation,-the TRT reviewed TUEC procedure QI-QP-16.0-5, } " Reporting of Base Metal Defects," and B&R procedure CP-CPM 6.9, " Welding h and Related Processes," fy '""'_- E Um 7 "4-rj;ts that control. the alleged' activity. -The TRT interviewed the shop general foreman, fore- ' men, QC' inspectors, and welders, all of whom stated that it was standard shop practice to discard a damaged piece and cut a new piece as a replace-ment' The shop personnel demonstrated a knowledge of the procedural' requirements for reporting base metal defects. During discussions, welders L demonstrated an awareness of the procedural constraints on repair welding, and the requirements for authorization of, and documentation for, repairs made by a welding process. The TRT could not find any occurrences of the alleged M during its audit'and shop walkdowns. The TRT found that j procedures were implemented kfat the alleged repairs lHiefNSW49 $1 were not standard or /1 4 common shop practice. I l GA>Fisq' 1Dit BF HENTIW1EA. C ins ectioof e'WRph _WA3 kJT M70'fiECO:.: Ad "**~_e-"-:':-'"- It was alhged that G THWEAD t r:_f:5 NeTUDME BG QE w -

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'u c.... ts t e-- t"**4-weerTMe. In its assessment of this allegation, the TRT found that B&R procedure CP-CPM-9.1, Section 2.1.2, required that the transfer of trace-ability marking be verified by QC prior to cutting, except where marking was not possible, such as on rods threaded the complete length of the piece. Standard practice in the iron fab shop was to obtain a length of bulk rod, record the heat number on the MIL or other required documenta-j tion, thread the rod, cut the required number of pieces, and mark the heat 1~[ number on the ends of the cut pieces. The cut pieces marked, and any remaining length of the threaded bulk rod, were then QC inspected. By [ comparing the number etched on the pieces cut to the number recorded on i. the MIL and on the remaining bulk rod, the QC inspector verified the accuracy of the number transferred. The TRT witnessed the threading of I i 4 ~.,.. -,. _ _ _ _ - - -. .,.m__ ___,__..m__.,_,~_.c__.___.m_ _.m._,,_,_,--_,_w_,_,,-.

rod for drawing Item 15 of hanger SI-2-031-430-S32A and found that the activity was done in compliance with procedures CP-CPM-9.10 and QI-Q51.1-28,whichareapplicabletofabricationandinspection. The TRT finds that traceability was maintained. It was alleged that are gouging (cutting) on stainless steel was done as close to the cut line as possible to minimize grinding. B&R procedur'e CP-CPM-9.10, Section 3.3.5, states that " Stainless steel base' plates may be thermally cut by are gouging. After the thermal cutting process, 1/8 inch of material shall be removed from the thermally cut edges by grinding." 1 To assess the allegation, the TRT in.terviewed the iron fab shop foreman and QC inspector who were responsible for the fab.and inspection of ASME-related i supports. The foreman stated that it was standard shop practice to layout stainless steel materials to an oversize cut dimension of 1/8 inch minimum i when the prescribed method of cutting was by arc gouging. The foreman also stated that it was standard shop practice for him to check layout dimensions prior to the cutting of materials by the craft personnel. Although not able to check 100 percent of layouts, he stated with confi-t dance that he does check more than 90 percent. The assigned QC inspector stated that the cut edges were checked visually for acceptability concur-rently with dimensional inspection prior to release from the shop. The foreman then stated that he performed a check of the traveler package and a visual check of the condition of the fabricated item assure its accept-ability before. it was released for field installation. No are gouging was 1 in process during the TRT's assessment. Arc gouging and removal of the i. heat-affected zone adjacent to the cut is standard industry practice. i-The TRT could find no examples that this practice was violated. ]. The alleger requested that the TRT look specifically at two jobs: (1) beam clips that may have been cracked, and (2) a triple hook on a 30-foo long stainless steeT chdin which was hot formed and documented after'it d was built. l f i

7 f i In its assessment of the beam clips, the TRT found that the allegation 1 referred to beam clips bent to prescribed angles for welded installation in the patch panel platfctm in the reactor building (RB), Unit 1. The clips were identified in the bill of material included in DCA 17551, Revision 6, to drawing 2323-51-0525 as piece 20, SA36 plate (structural steel) 3/8 x 3 1/2 x 8 inches. The TRT was unable to verify the alleged condition of the clips because they were welded in place with the outside radius on the side hidden from view. To assess the potential for the alleged condition, the TRT requested that the iron fab shop form a 90* bend on a like piece of the same heat number material from which the original clips were fabricated. The sample piece was cut as a longitudinal section (with the grain) and cold formed to a 90* angle. The outer radius was then wire brushed. Visual inspection (without magnification) by the TRT detected minute surface ind'ications l which the TRT assessed as not a relevant indication (defect). The sample was then checked by the craftsman who cut and formed it, and inspected by the QC inspector responsible in that area of the shop where the original clips were produced. Both agreed that the sample piece was acceptable. The piece was then subjected to a nondestructive examination by liquid dye penetrant (PT), visible color contrast method and found to have no indica-l tions. The TRT found that this method of forming clips was done in accordance with acceptable practice as detailed in the American Institute for Steel Construction (AISC) handbook. In its assessment of the 30-foot chain, the TRT reviewed the FSAR and interviewed TUEC project engineers to determine the identification and applicationofthegzicadescribedbythea'11eger. The device could not be identified d-*---4a d "'+ +k----^ '- '"^' '***r"ha n41[ 4 :tp1H 4, +so 1 ..,4 + n e <nol o emee-- s z. -.....xr... -.., -. _~ , ~.. .m 7 e.t :.;-~.eg wu, /ue n s,. wh 4 -w an nn+ conn 4,o snu seenr4s+ma e4te <,5-' a-z!4 ^ a The.TRT interviewed the iron fab shop general. fora-tim f +- that although the etainless steebchain was an odd or d/hMMM '1 '1

I unusual item, he could not remember its fabrication. The TRT also inter-viewed representatives from the material control group and the millwright. a'nd could not find an example of the Alleged device. y t [ departmen a r i' .aT. 7 5. Conclusion and Staff positions: The TRT concludes: AC-77 4 'Onsite fabrication practices were properly controlled by construction inspection procedures and instructions. The TRT. review did not identify instances where the iron fab 'No# ianufactured safety-related replace-s p ments without the appropriate procedures or without QC ir.spection. There-fore, the TRT finds that this allegation has neither safety significance nor generic implications. I A0-79 / I Based on a review of applicable documents, shop inspectiom and interviewk / with TUEC personnel, the TRT concludes that the allega that the iron hidlCATIMJ#d M43f parts in response to telephoned ins uctions rather an to written instructions cannot be traced to a speci vent ar.d.4 herefore,. psfeme nonsafety-req [p/ar s may have been fab-7 Ass ALLiGAlleh( cannot be substantiated.y ricated based on telephoned instructions; however, safety-related parts were fabricated in compliance with applicable procedures. Current iron fab"skppracticesalsoprovideadequateassurancethatmaterialtrace-ability was maintained in compliance with the applicable procedures. Accordingly, this allegation has neither safety significance nor generic 6Nl$$' implications. the TRT prese p [ l In a meeting with the alleger on December 10, 1984, The alleger agreed its, findings and conclus' ions for AQ-77 and AQ-79. l l-with the TRT's findings and conclusions and no additional concerns or { allegations were identified, g b

r t l A0-138 d, y TheTRTassessedthJsallegationbyareviewofproceduresanddocumenta-tion, an audit of fat work in process, witnessing the fabrication and PT examination of a comparison sample, witnessing the fabrication of threaded rods, and by a walkdown verification of material laydown storage area's. The assessment also included interviews with B&R shop foremen and craft personnel, QC inspectors, quality engineers, material control personnel, and a TUEC instrumentation engineer. 6) DslezsuaswnMiD_Edf.AuEknTLoa rag,catetspucarMdnoEraucMEEl f 45Afauxo p FEnaAK psefulaJirHo 07 /0!o4112&5_of_fdi_FtlPAtande-IAT. TAI / S ]JJianinD_&f)por JPRJrsNT/M/ fn/ A4(CardLJ.())_daMtANTi. nom Jiuity mzwns wraisuxGL(A)2ciFiMnw knMi1%ed Haa2Masmq((} zacawsua,a serry wra_mzini.ru>ss uaawimpini rewersx .fapf})d2fAiA L [7] AJME Od Jild NJ1d/fE41L*TH8f631 iM T///Incd_& LAY 47/Thu1/oF (4) Arut Oc 3GNo7pr.ofr wir ava2LLAN<1//n&DJDJpD EEEnA hDTGb E it43h/)_jfdKWrV Miss.,4&t'Ms)iit THE Fannifanon Pnuf33 . ra i r a r &_ g sa u siazarwm unsaa n staastarizarsaiura's 0).$A5dlLJu'D1214 b/eJ l/Lf & AL /[* WN} f0${}g[&fh)_[fE[L_[dff/C$i...*H0? qJ& uuDesxwTJ.arssinL (?) viGpcDsEd1%fAL Bnnau_vfaLtt&L M24Md*' i [lD]Ac_caotain L. mi JrsintEJJ J7EEi. >iM no c4eliTO 'THE CO_T aisinizEt;xicinnyt,_+vXa) s m)ine;rsrrtigosx ajpg_ia_cm ___ fif b $ $ h W 0 0 b O Y O /?. 5 -6g-' 9 6a -a ep- , ERdH//.!Eh,ELTAdZdX tL22i'E //LON F48&ltAT&n2 MOP _D/2/C47[2 e 6 nit AE9aasrLqcwearioan oeat 7txrwac2,.spauarim. 3% cia 3/uTyALn11deayreNELanLh_ caster 4L_7ar rn7isturest fMg[fdatlit#1aNLRRWiL*N41EHf/LlddCf J/d#d}Cadli MM -.finCLu2fI

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. _ c ;,' _... y 3 ;; ; *,. t s z.= *, g 1 s s ~.. 8. Attachmants: !!c n a. ~ ^ ~- 9. Referenca Cccuments: 1. CP-CA:-11.1, " Fabrication and Installation Inspection of C ::nants, Cem:enant Su:e. cres and Piping." 2. CP-C?:1-9.10, Ray. 11, " Fabrication of ASME Ralated Ccacenants S L,,,,... a. n 3. C?-CF:1-9.9, Rav 8, "MS-Sei smic Cata; ry II Support." 4. CP-C?M-9.13, Ray. 10, ":!:dification cf Vend:r-Supplied Cata":; Itams." .c.. TLi,.. 1.,.. w i a a _. r.3 c..] d. w u.,,sc.,..c.:. a s G. ^Q-123: TRT in:arviaw with allegar A-59, S2;; ::ar 13,1.09. 7. FSAR Figure 9.5-52, sheet: I and 2. 3. ElR E:?-19, " Exposed Conduit /Juncti:n E x a-d Hang 2r Fabri -ica and Installation." n a r1 Cat 10n O<..115 C 0 t l a..90 U s 'itaal. n rD - L. .:..i,

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Eu-n - c 10. Ea3 C:-CFM-5. '.. " Color Ccding o f Piri g M2 arial s." 11. E2R C?-CPM-6.9C, "Matarial Idantifica:1cn." 1:'. Ea3 C?-C.iP-la.1, " Inspection of Ster:ga and Maintenance o f t Perman2nt Plant Equipment." 13. ESP C.-Q.'J-3.1, "Racaiving Inspaction " \\ '~ ',,g I

14. B&R QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports."

15. B&R CP-CPM 6.90 Welding and Related Processes.

16. B&R MCP-10, " Storage and Storage Maintenance of Mechanical and Electrical Equipment."

17. B&R CP-CPM-8.1, " Receipt Storage and Issue of Items."

18. TUEC QI-QP-11.10-1, " Inspection of Seismic Electrical Support and Restraint Systems."

19. TUEC QI-QP-11.16-1, " Installation Inspections of NNS Seismic Category II Supports for Class V Piping."

20. TUEC QI-QP-11.14-1, " Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel."

21. TUEC QI-QP-16.0-5, " Reporting of Base Metal Detectors."

22. TUEC QI-QP-11.4-4, " Control of Material Traceability for Site Fabricated Structural / Miscellaneous Steel."

23. Design Change Authorization 17551.

24. Hanger Packages, CP-82-086-8903, CP-82-008-8903, and CP-84-224-02-8902.

25. AQ-77 and AQ-79: A11eger A-3 statement and interview.

26. TRT meeting with A-59 November 14, 1984.

27. TRT meeting with A-3 December 10, 1984, pp. 115-138.

10. This statement prepared by:

J. Malonson, Date Technical Reviewer M. Bullock, Date Technical Reviewer C. Morton, Date Technical Reviewer i:. _

f i Reviewed by: H. Livermore, Date Group Leader Approved by: V. Noonan, Date Project Director t 9 l iL i s I l 9 l 4 i

f AQ-79 fil AQ-138 CP9 Rev. 1 SSER Format /CP2 SSER 1. Allegation Group: QA/QC, Category 5B 2. Allegation Number: AQ-77, AQ-79 and AQ-138. Y CharacteriQATI / 3. s: It is alleged that the onsite structural fabrication and (f g hanger shop (iron fab shop) made component parts, such as eyebolts (I-bolts), that had been lost after receipt inspections (AQ-77); that safety-related f parts were made in the iron fab shop without any fabrication instructions k or the required quality control inspections (AQ-79); and that (1) craft personnel in the iron fab shop were asked by their supervisors to perform work without any knowledge of the paperwork, (2) the paperwork was illegal because it was post-dated, (3) nonsafety-related material was mixed with safety-related material, (4) the supervisor had directed the alleger to improperly color code material, (5) during consolidation of the electrical and iron fab shops, safety-related materials were mixed from both areas, (6) electrical fab personnel used undocumented material, (7) ASME QC per-sonnel in the iron fab shop did not check fabricated threads, (8) undocu-mented weld repairs were made on base metalg (9) threaded rod was cut in the iron fab shop without a QC check t M fHe heat numbers h+d t r aroo - fa ~ d beforo cutting, and (10) arc gouging (cutting) on stainless steel was done too close to the cut line to minimize grinding time (AQ-138). 4. Assessment of Safety Significance: The implied safety significance of these allegations, is that if true, incorrect material may have been installed in the plant rendering system operability and quality indeterminate. AQ-77 Tne TRT review of this allegation indicates that the processes utilized for Brown & Root (B&R) fabrication of some vendor parts were addressed by N' f /pbgil 4 /' site construction procedures, and that the required inspections were identified by quality control procedures and instructions. When vendor-supplied items, replacements, and modifications were fabricated onsite, specific instructions were provided by engineering on a construction operation traveler and vendor concurrence was obtained, either by signoff by the site vendor representative or by correspondence. In assessing this allegation, the TRT he following quality controlled work packages from the iron fab shop: Sway Strut / Eye Rod H-CS-2-SB-083-002-2 Hanger CS-2-327-406-556R Rear Bracket VD-2-013-437-536R i Sway Strut CS-2-SB-079-005-2 Hanger MS-2-RB-040-004-2 Vortex Breaker Cage MW84-6811-8902 This list of work packages included both safety-related and nonsafety-related assemblies. Since both safety and nonsafety-related work was conducted concurrently at the iron fab shop, close examination of the paperwork often was required to distinguish between them. The TRT also reviewed the processes utilized in cutting, grinding, fitting, and s - 3 assembling components' onsite. This review revealed that shop practices were in compliance with approved procedures. Ih ava-r4aca nnt all--we r k ir th: * = A b shoo _w N i ted s%cmf h c-t 15ih ( 7 i,r.-eempU a n c a wi + Larad.iW S. The TRT found, however, that safety i and nonsafety-related materials were adequately identified and segregated during processing in the iron fab shop. J The TRT discussed the fabrication of I-bolts with the iron fab shop super-visor and foreman. The fron fab shop s fabricated lost or missing I-bolts for hoisting and rigging vendor components. Y, these I-bolts were not part of the quality-controlled package; that is, they were not k

. f 4 [~. subject to the same rigorous standards as permanent hanger and strut 4},- components. Further TRT interviews with field installation personnel 4 indicatedthattheI-boltsreceivedloadtestingandin.spectionpriorlo use, and were later removed, scrapped, and replaced with certified hanger or strut components. They were replaced to assure that appurtenances of safety-related components were not overstressed during hoisting and rigging activities. AQ-79 In assessing this allegation, the TRT interviewed the iron fab shop super-e visors and the millwright shop supervisor and toured the shops to observe the work being performed. The TRT found that shop personnel were perform-ing work in accordance with procedures CP-CPM-9.9, CP-CPM-9.10, and / CP-CPM-9.13. The TRT noted that procedure CP-CPM 9.10 " Fabrication of ASME-Related Components Supports," Section 2.1.4, stated: Parts for a support, e.g. base plates, structural members, etc., may be fabricated without a drawing or Hanger Package provided they are described on the MIL and verified by QC as required by 2.1.1. However, when the parts are being assembled into a support, the Hanger Package shall be intact unless the MIL must be removed to fabricate another part. Although the allegation specified no particular parts, the TRT reviewed work packages for a hanger (MS-2-RB-040-004-2), sway strut (CS-2-SB-079-005-2), and vortex breaker cage (MX84-6811-8902). The TRT identified the processes used in cutting material for hangers as mechani-cal sawing, grinding, and thermal cutting. The TRT determined that traceability documentation was properly transferred to each piece cut and that QC inspector verification was recorded on the appropriate docusent.

The TRT found that current shop practices are also in compliance with the procedures reviewed. The TRT interviewed representatives from Texas Utilities Electric Company (TVEC) concerning the allegation, but could identify no specific examples TUECpersonnel[ 'of' work performed as the result of telephoned instructior.3. acknowledged that craft personnel may have received telephone requests to ff f supplyapart,butonlyinaccordancewithapreviouslyissueddrawingtof which the shop had access. When.such a request was made, the shop work order was subsequently sent. TUEC personnel also stated that if a-hanger installation required a replacement part, they maintained the material traceability by using the material identification log (MIL). The TRT reviewed the Mils on the shop work packages and determined that their statements were corre'ct. AQ-138 ,Y To assess the allegation that iron fab shop personnel were asked to perform work without any knowledge of the paperwork, the TRT performed an unan-nounced audit of in process fabrication activity in the iron fab shop. The TRT assessed the availability of traveler packages and-the included documentation to determine if the information provided was in accordance with procedures and if craft personnel had the required information (docu-mentation) to perform the assigned task. The TRT audited eight traveler packages at the location where the fab shop activity was in process. The travelers audited covered fabrication of ASME Code class supports, nonsafety supports, miscellaneous steel, electrical supports, and modification of vendor-supplied items (e.g., a snubber-spring hanger). The TRT reviewed procedures for fabrication / 11/ b$ installation, inspection, material traceability, and -eceipt and storage, all of which are applicab ctivities performec :a f1 iron fab shop. - The TRT also noted th significanc of procedure Cp-L 10, Section 2.1.4, for the assessment of allegation AQ-79. The TRT found that the 8 [

audited hanger packages and operation travelers contained the documenta-tion (e.g. drawings and MILS) required by the applicable procedure and were current for the status of the work in process. 6t 9 During discussions with the iron fab shop foreman and the assigned QC in-spectors, the TRT found that the shop foremen assigned to nonsafety supports, miscellaneous steel, and electrical supports could not identify, and were h not familiar with, the fabrication proceriures applicable to the activities h under their responsibilities (e.g. B&R procedures CP-CPM 9.9, B&R CCP-21, 'and B&R ECP-19). The TRT found that the foremen's lack of knowledge of (/$f procedures indicates the need for procedure indoctrination and additional h0 training for the foremen. $$4/h *WW The TRT then reviewe)d 43 of tne alleger's concerns about material requist-tions (MR), design change authorizations (OCAs), and shop work orders (SW0s). In its review of the documents identified by the alleger, the TRT found that fabrication activity in the iron fab shop was performed by use of an MR as a result of a memo request or sketch, instead of by the hanger lg.,- package or traveler, as required by procedure CP-CPM-9.9, Section 3.1, N(b[ p which states " Fabrication / installation shall be accomplished in accordance with the hanger package." TheTRTalsofoundthesamecfffydl{dh netTTFn for fabrication per procedure CCP-21, Section 3.1.3, which states, "All work shall be accomplished in accordance with controlled drawings." Although the han er number was identified on theMRforelectricalsupports,fabricationwabdN[withoutthehanger 1 package actually in the iron fab shop where the work was performed. The TRT found that MRs were not properly prepared per procedure CP-CPM-8.1, Section 3.4, " Issuance of Items." MRs issued in'the iron fab shop did not l contain the information required by the block titles, e.g., material type was entered in the code class column, the code class was not identified, and the vague information entered for intended use was taken from the requestor's memo or sketch rather than specific information given on the l l applicable drawing, hanger package, or traveler. Considering these condi-tions the TRT agrees with the allegation that the iron shop fabricators performed their work without know[pde the required paperwork. rT The alleger did not identify any specific items for the allegation that the paperwork was illegal because it was postdated. This allegation is L addressed in the previous paragraph as it relates to work performed without knowledge of the paperwork. In the TRT interview with the alleger, the alleger had refused to do work per a note paper sketch, and a day later, a ' traveler was written to document the fab [pNs, thus the allegation. The TRT found that although sketches were used the material issue, fabri-j cation activity, material traceability, and Q.C. inspection [ documented on an accompanying MR. The MR traxeled with the fabricated items to the 1 SV isgtallation location, where subseugent QC inspections documented the acceptability of the item in the hanger package or on the operation traveler. To assess the allegation that nonsafety material was mixed with safety material in the iron fab shop, the TRT, accompanied by a representative from the Brown and Root (B&R) material control group, examined the bulk material and vendor-supplied supports storage area to lear.1 the standard onsite procedures and methods for segregating safety and nonsafety mate-rials. The materials were identifiable and segregated as required. Based on the satisfactory compliance with methods and procedures in those areas, the TRT, accompanied by fab shop personnel, also examined the iron fab shop material storage (laydown) areas. The TRT f 'a designated areas for v the storage of "ASME bulk material," safety related. A sampling of the material revealed ' heat number markings, as required. The TRT found however that a pile of what was obviously scrap material, although sepa-rated, was not identified as scrap, nor was the area identified as a scrap / salvage area. The TRT also found that there were unidentified bulk materials mingled with safety and nonsafety material in the laydown yard j adjacent to the former electrical hanger shop. This condition is in noncompliance with procedure CP-CPM 8.1, Sections 3.3 and 3.5 which requires:

. i 3.3 Within each of the storage areas (type A through E as delineated in Appendix 1) safety-related items should be physically separated from non-safety-related items, and identified. Where segregation is not practical, due to size, configuration, or specific storage requirements, etc., positive identification shall be maintained which clearly identifies the material. ~ 3.5 Items which have been withdrawn from the warehouse and are not needed shall be transmitted to the warehouse by the " Material Return to Warehouse" form (Attachment 3). In further assessing this allegation, the TRT noted that procedure QI-QP-11.14-1, Section 3.1, requires that "The QC inspector shall perform randem surveillance over storage and control of materials in the Structural / Miscellaneous Steel shop area to assure proper storage and control of mate-rials in accordance with Reference 1-C and as follows: safety-related material for items requiring traceability through installation shall be segregated from other materials and shall be identified by heat number at all times." The TRT found no documented evidence that the required random surveillances were performed, a condition in noncompliance with the proce-dure quoted. t 'Lh he allegation was that the alleger's supervisor directed him to not color j code (with red paint) what the alleger believed to be indeterminate (scrap) materials. In assessing this allegation, the TRT was unable to find any procedural requirement that color coding be applied to indeterminate (or ( scrap) material by fab personnel. fj f//ef' In assessing the allegati ht related ("Q") materials were mixed, e theTRTobservedthafthestoraq,egrea(laydownyard)isacommonarea hl M tIbrYcNikodothelectricalandcomponentsupports. B&R procedure ECp-19, Section 1.1., states in part " Structural steel l members are to be those obtained from the electrical fab shop or [from] l designated"Q"fQ! storage areas." The TRT notes that t

according to the procedure, there is no conflict in regard to the location / AUG hM from which the "Q" materials are obt ined. To assess the allegation concerning undoc.ented material, the TRT audited traveler packages _for work in process during its verification of docu-mentation which was used in the assessments of other allegations reported in this SSER. The TRT found compliance with traceability requirements for heat number, unique number, and coating code number. The TRT also found that the QC inspection process for verification and documentation assures theuseoftake'ab mNNf. Although the alleger did not identify a 1 specific instance of undocumented material, the TRT finds that the proce-dures as implemented prevent thet S t use of undocumented materials. It was alleged that the ASME QC in the iron fab shop did not check threads on any job unless it was a prescribed operation on a traveler that required QC inspection. To assess this allegation, the TRT reviewed fabrication procedure CP-CPM-9.10 and the QC inspection procedure QI-QAP-11.1.-28 and found that neither document requires the QC inspection of threads fabri-cated in the fron fab shop. The TRT found that operation travelers were neither required nor used for the fabrication and inspection of threaded rod used in ASME-related safety class components supports. In its review of the fabrication procedure, the TRT found that the procedure did not provide a general reference to design drawings nor the identification of the design specification or specify a national standard that would enable the acceptable fabrication of threads, in conformance with design specifi-cation, to assure quality (e.g., size, pitch, length, and class of fit). (, f I The TRT interviewed the B&R quality engineer responsible for the applicable QC inspection procedure fer the fab / installation of ASME-related supports. He explained that B&R relied on an acceptable inspection during installa-tion as the means to assure the quality and acceptability of the B&R fabri-cated threads as defined in QI-QAP-l'1.1-28. The TRT also reviewed a typical hanger inspection report and verified that the inspection require-ment was defined. The TRT found that the threads fabricated in the iron

6' e _g. fab shop were inspected in compliance with the requirements of the gfpL/ '/V applicable procedures. It was alleged that undocumented weld repairs were made on base metal (plate) which was damaged by flame cutting during the fabrication process. u To assess the allegation, the TRT reviewed TVEC procedure QI-QP-16.0-5, " Reporting of Base Metal Defects," and B&R procedure CP-CPM 6.9, " Welding and Related Processes," fy #-- % g w % s that control the alleged activity. The TRT interviewed the shop general foreman, fore-men, QC inspectors, and welders, all of whom stated that it was standard shop practice to discard a damaged piece and cut a new piece as a replace-ment. The shop personnel demonstrated a knowledge of the procedural requirements for reporting base metal defects. During discussions, welders demonstrated an awareness of the procedural constraints on repair welding, and the requirements for authorization of, and documentation for, repairs made by a welding pro' cess. The TRT could not find any occurrences of the alleged during its audit and shop walkdowns. The TRT found that IHheyWVA/G procedures were implemented that the alleged repairs were not standard or 4 common shop practice. h VEAJFIdNTIDH BF HENE'lidM$fA-G THkfhuEliRbh WA3 CUT IN70 PiGC~d :d:d tiong n# *

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wertrTaTe. In its assessment of this allegation, the TRT found that B&R procedure CP-CPM-9.1, Section 2.1.2, required that the transfer of trace-ability marking be verified by QC prior to cutting, except where marking was not possible, such as on rods threaded the complete length of the piece. Standard practice in the iron fab shop was to obtain a length of bulk rod, record the heat number on the MIL or other required documenta-tion, thread the rod, cut the required number of pieces, and mark the heat number on the ends of the cut pieces. The cut pieces marked, and any remaining length of the threaded bulk rod, were then QC inspected. By comparing the number etched on the pieces cut to the number recorded on the MIL and on the remain'ng bulk rod, the QC inspector verified the accuracy of the number transferred. The TRT witnessed the threading of i

rod for drawing Item 15 of hanger SI-2-031-430-S32A and found that the activity was done in compliance with procedures CP-CPM-9.10 and QI-Qkl.1-28, which are applicable to fabrication and inspection. The TRT finds that traceability was maintained. It was alleged that arc gouging (cutting) on stainless steel was done 1) as close to the cut line as possible to minimize grinding. B&R procedure CP-CPM-9.10, Section 3.3.5, states that " Stainless steel base plates may be thermally cut by are gouging. After the thermal cutting process, 1/8 inch of material shall be removed from the thermally cut edges by grinding." To assess the allegation, the TRT interviewed the iron fab shop foreman and QC inspector who were responsible for the fab and inspection of ASME-related supports. The foreman stated that it was standard shop practice to layout > stainless steel materials to an oversize cut dimension of 1/8 inch minimum when the prescribed method of cutting was by arc gouging. The foreman also stated that it was standard shop practice for him to check layout dimensions prior to the cutting of materials by the craft personnel. Although not able to check 100 percent of layouts, he stated with confi-dence that he does check more than 90 percent. The assigned QC inspector stated that the cut edges were checked visually for acceptability concur-rently with dimensional inspection prior to release from the shop. The foreman then stated that he performed a check of the traveler package and a visual check of the condition of the fabricated item assure its accept-ability before it was released for field ' installation. No are gouging was in process during the TRT's assessment. Arc gouging and removal of the heat-affected zone adjacent to the cut is standard industry practice. The TRT could find no examples that this practice was violated. y The alleger requested that the TRT look specifically at two jobs: (1) ,D, beam clips that may have been cracked, and (2) a triple hook on a 30-foot long stainless steel chain which was hot formed and documented after it was built. l l l

In its assessment of the beam clips, the TRT found that the allegation referred to beam clips bent to prescribed angles for welded installation in the patch panel platform in the reactor building (RB), Unit 1. The clips were identified in the bill of material included in DCA 17551, Revision 6, to drawing 2323-S1-0525 as piece 20, SA36 plate (structural steel) 3/8 x 3 1/2 x 8 inches. The TRT was unable to verify the alleged condition of the clips because they were welded in place with the outside radius on the side hidden from view. To assess the potential for the alleged condition, the TRT requested that the iron fab shop form a 90 bend on a like_ piece of the same heat number material from which the original clips were fabricated. The sample piece was cut as a longitudinal section (with the grain) and cold formed to a 90 angle. The outer radius was then wire brushed. Visual inspection (without magnification) by the TRT detected minute surface indications which the TRT assessed as not a relevant indication (defect). The sample was then checked by the craftsman who cut and formed it, and inspected by the QC inspector responsible in that area of the shop where the original clips were produced. Both agreed that the sample piece was acceptable. The piece was then subjected to a nondestructive examination by liquid dye penetrant (PT), visible color contrast method and found to have no indica-tions. The TRT found that this method of forming clips was done in accordance with acceptable practice as detailed in the American Institute for Steel Construction (AISC) handbook. In its assessment of the 30-foot chain, the TRT reviewed the FSAR and j 4 interviewed TUEC project engineers to determine the identification and l application of the device described by the alleger. The device could not l be identified. Th T deternined that ther re low fuel limit s hes a installed in the sel ge ator fuel oil race transfer s " m-o however, th Tv-led that the ~ ches were an inte ectrical unit sup ie by a vendor which do not require any associated site fabrica-tion f r nstall ion. The TRT interviewed the iron fab shop general fore-r. an la ed that although the stainless steel chain was an odd or cWJv/S l l t l unusual item, he could not remember its fabrication. The TRT also inter-viewed representatives from the material control group and the millwright department and could not find an example of the alleged device. % f acti ke TRT. 5. Conclusion and Staff Positions: The TRT concludes: AQ-77 'Onsite fabrication practices were properly controlled by construction inspection procedures and instructions. The TRT review did not identify instances where the iron fab shop manufactured safety-related replace-ments without the appropriate procedures or without QC inspection. There-fore, the TRT finds that this allegation has neither safety significance nor generic implications. [ AQ-79 / I Based on a review of applicable documents, shop inspection and interviewb / with TUEC personnel, the TRT concludes that the allega that the ironj' / fab shop cut new parts in response to telephoned inst uctions rather an to written instructions cannot be traced to a specifi vent anj,4herefore, cannot be substantiated. Some nonsafety-related parts may have b'een fab-ricated based on telephoned instructions; however, safety-related parts were fabricated in compliance with applicable procedures. Current iron fab shop practices also provide adequate assurance that material trace-ability was maintained in compliance with the applicable procedures. Accordingly, this allegation has neither safety significance nor generic implications. In a meeting with the alleger on December 10, 1984, the TRT prese p [ its findings and conclusions for AQ-77 and AQ-79. The alleger agreed with the TRT's findings and conclusions and no additional concerns or allegations were identified. g

AQ-138 The TRT assessed this allegation by a review of procedures and documenta-tion, an audit of fab work in process, witnessing the fabrication and PT examination of a comparison sample, witnessing the fabrication of threaded 7 rods, and by a walkdown verification of material laydown storage areas. 7, The assessment also included interviews with B&R shop foremen and craft 'g personnel, QC inspectors, quality engineers, material control personnel, M[F and a TUEC instrumentation engineer. The TRT substantiated the allegations of craft personnel working without knowledge of the paperwork and QC not checking threads did not ubstantiate the allegations that safety and nonsafety materials were ((MImixed,thatelectricalshopsafetymaterialsweremixedwithiron materials, that there was no heat number transfer on threaded rod, that there were cracked beam clips, and that color coding was improper. The TRT was unable to substantiate the allegations that paper work was post-dated, that undocumented weld repairs were made on base metal, that there was arc gouging of stainless steel, that there was the undocumented fabri-cation of a triple hook on a steel chain, and that the electrical shop used undocumented material. The TRT did find procedural noncompliances; however, the items were of a localized nature and therefore have neither safety significance nor generic implications. O In a meeting with the alleger on November 14, 1984, the TRT presented its assessment of AQ-138 and its conclusion. The alleger had no major dis-agreements with the TRT's findings. <//0 ME W dOW,f/INj WL ALLf4h T/On! W Eh.E iM d TIFILL, 6. Actions Reauired: TUEC shall initia' corrective action to assure that gpf ap and salva pile in the nf shop laydown yard is identified ricted to prevent access to and' and sufficiently segregated an a inadvertent use of t.he rial. .SEE ITl M 2 of fnlLO SfM } To 3 C, EM En duTT anin to nn.sPau we sn8voars,19ff n. c y

TUEC shall conduct a docur nted raining.ssion for those persons who [frepareandprocess. atrial quisi+'ns\\toassurethatinformationis entered where and as equ ed that the descriptions enable craft I personnel to deter in quality requirements and establish traceability identification foVthe item in or on which the fabricated parts are used. T{ECshallconductadoamente ooctrination and training session for 4 a hose spons' le # iron shop fabrication activities controlled by procedures CP-CPM ) , CCP-21 and ECP-19. TUEC shall review a nd r vise th icable procedures to identify the pecificationorspe[ificgyfonrequiremethwhichassures that the threaded items mply tb esign specification requirements. A typical example of indu ry s ard identification of threads is given as 1-8"X6"L UNC CL2A, whic vides a typical specification and design requirement for a threa d item 1-inch diameter, 8 threads per inch, 6 inches long to a nMonal standard class of fit (thread interference with the mating device). / TUEC 1 take ap repriate action o as re at the return of unused or unneeded material complies with roce -

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The action may be in the form of an audit or documented 2urv ance. Although the noncompliance is identified as a singular ev , the TRT noted that the site is effec-tively undergoing cleanup nsolidation of fab shops) and there is poten-tial for repetition of t e noncompliance. performing and documenting the UEC shall iti te corrective a i i site surveillances,equired by -11.14-1. {$ TUEC shall nitiate corrective a

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ocumentat hanger packages, .--s._ s. travelers and drawings at the t'..e and location where the activity is performed. l l \\

_ u,_ a / 6 h SEC shall initiate acticr go., ssur one re=vai cf (cr the identifica.i:- t ~ ~. _. s._ ar.d segrecaticn of) the in.n _rm:nate ma er.ial.w...cn is m;nc ied m:n saw./ ~ ._ w-ar.d nonsafety. materia in the fcrmer-electrical shcp layd wr, yard. W Ws (~ f}TUEC shall identify and report the usage application for a treble ha a 30-foot stainless steel chain fabricated in the iron fan shop identifie: 2 as an emercency low fuel limit switch. -= _._ c,,, -. Wes

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14. B&R QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Supports."

15..B&R CP-CPM 6.9D Welding and Related Processes.

16. B&R MCP-10, " Storage and Storage Maintenance of Mechanical and Electrical Equipment."

17. B&R CP-CPM-8'.1, " Receipt Storage and Issue of Items."

18. TUEC QI-QP-11.10-1, " Inspection of Seismic Electrical Support and Restraint Systems."

19. TUEC QI-QP-11.16-1, " Installation Inspections of NNS Seismic Category II Supports for Class V Piping."

20. TUEC QI-QP-11.14-1, " Inspection of Site Fabrication and Installation of Structural and Miscellaneous Steel."

21. TUEC QI-QP-16.0-5, " Reporting of Base Metal Detectors."

22. TUEC QI-QP-11.4-4, " Control of Material Traceability for. Site Fabricated Structural / Miscellaneous Steel."

23. Design Change Authorization 17551.

24. Hanger Packages, CP-82-086-8903, CP-82-008-8903, and CP-84-224-02-8902.

25. AQ-77 and AQ-79: Alleger A-3 statement and interview.

26. TRT meeting with A-59 November 14, 1984.

27. 'TRT meeting with A-3 December 10, 1984, pp. 115-138.

10. This statement prepared by:

l J. Malonson, Date Technical Reviewer M. Bullock, Date Technical Reviewer C. Morton, Date Technical Reviewer k r ea6 Reviewed by: H. Livermore, Date Group Leader Approved by: V. Noonan, Date Project Director

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