ML20136B766

Sets Forth Principles,Expectations & Responsibilities for Mgt & Execution of Region IV Activities on Coatings Efforts at Facility

ML20136B766
Person / Time
Site:	Comanche Peak
Issue date:	02/09/1984
From:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20136B196	List: IA-85-779, Further Response to FOIA Request for Repts Listed in Board Notification 84-149 & Documents Re Rept Release.Forwards Documents Listed in App B.Portions of App C Withheld (Ref FOIA Exemptions 6 & 7).App D Withheld (Ref Exemption 5) IR 05000445/1983003 ML20136B192 ML20136B255 ML20136B339 ML20136B657 ML20136B688 ML20136B698 ML20136B706 ML20136B715 ML20136B731 ML20136B741 ML20136B752 ML20136B766 ML20136B782 ML20136B794 ML20136B826 ML20136B838 ML20136B858 ML20136B878 ML20136B938 ML20136B964 ML20136C328 ML20136C368
References
FOIA-84-779 NUDOCS 8511200284
Download: ML20136B766 (4)

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FEB 9 1934 MEMORANDUM FOR: E. H. Johnson, Chief, Reactor Project Branch 1 FROM: Richard P. Dant se, Director, Division of Resident, Reactor Project and Engineering Programs

SUBJECT:

RESPONSIBILITIES FOR COATING ACTIVITIES AT COMANCHE PEAK (DN: 50-445; 50-446)

This memorandum sets forth the principles, expectations, and responsibilities for canagement and execution of NRC RIV activities on the coatings effort at Comanche Peak.

Lead Responsibility - Doyle Hunnicutt has the lead responsibility to manage this activity and to bring it to timely and successful closure.

Technical Assistance - Expert technical assistance will be provided by BNL and a consultant to BNL. The BNL personnel are Vince Lettiere and Jim Higgins. The BNL consultant is S. John Oechsley, working under a contract between BNL and Steve Penny & Associates.

NRC - RIII Consultation - Frank Hawkins of RIII will provide overview and consu)tation for RIV at appropriate times at the request of Doyle Hunnicutt.

The following principles are to be followed in this effort:

1. A schedule is to be established and followed, including closure;

2. The end product (e.g., report and content) is to be defined;

3. The process for achieving the end product is to be defined;

4. Doyle Hunnicutt will ensure that RIV involved personnel (including the resident inspectors), the RIII consultant, and the BNL/ consultant are ~'

fully and currently informed so that the BNL/ consultant product fulfills RIV requirements.

ORRP&EP RA-RIV RP0enise:Je JTCollins 2/ /84 2/ /84 8 1 351025 P RDs. m PDR g e)

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i Tre licensee will be advised of our requir access, access to personnel, etc., (as we knements for documents so that the licensee can fulfill these expect tiow them) prior to a ons Such planning is not toare which be identified viewed as a limitation subsequent on plannional to the additi appro.

priate activities visit.

those identified in the course ofngaeffort, sit particularly I k 6. e visit for inclusion during the

, To help assure the availability of current i f

site are to be preceded by a briefr visit to A lin ormation, visits progress and the pending site visit j

debriefing after the site visit ngton to discuss

. , and is to be followed by a i

efficiency,that there is minimal interference withThese session .

7. the site visit and travel necessary to prompt closure / completion acti I

a i

achieved otherwise. m ted to those appropriate and

. sta tus. i 1

guidance to avoid, dilution product most efficiently.

of effort which iTh y to convey e reports, it is simply i mpacts achievement of the end

guidance of the work.I would be pleased to receive any commen

! s or additional suggestions for 1

Richard P. Denise, Director

CC* Division of Resident, Reactor Project

,' and Engineering Programs J. T. Collins P. S. Check r

W. C. Seidle D. M. Hunnicutt D. L. Kelley J. E. Cum. mins -

0. M. Meyer F. Hawkins, RIII 4

J. F. Streeter, RIII l

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U.S huCULARAEGUuTORY COMMISSION 11 a2) ALLE2,.ATION i m. coon, onDATA r .ru FORM RECEIVING OFFICE Docket Number (if applicable)

1. Focility(les) Involved: INamel tre mor. men 3. or n gerww. wnte GENEMICI e a A kk H L FEM .$ffam 0 SO OO if Il $

Av rt ic crark & : O 5' O o n (/  % 6 CMA tost, ricxn s

2. Functional Arestal involved:

tcheca sooroonete bout => I operations . onsite health and safety I cor'struction _ offsite health and safety safeguards emergency preparedness other (se.cdys 3.

Description:

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4. Source of Allegation: -

icn.cneneroon boni U contractor employee security guard

_ licensee employee news media

_. NRC employos private citizen organization tse.enye other ise.cnyt MM 00 YY

5. Date Allegation Received: , 7 g

6. Name of Individual thmt two inio.4 and i.et name: J. T 841M5 Receiving Allegation: -

7. Office:

ACTION OFFICE

8. Action Office

Contact:

irint twe in.nese one seet ner ei EN NAk S. FTS Telephone Number:

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S ll I D

10. Status:

% ,,,, Open,if followup actions are pending or in progress l Closed,if followup actions are completed MM 00 vy

11. Date Closed:

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12. comuks: lglyl_g ly j,jo) ; lql jl l l l l l l l l l l l l ; ;

furrut to so crureceria i IIIIIII IIIIIIIII IIIIl l l !l OfMee Year Number -

13. Allegat.on Number: l- ^

o I R y. -

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.Feb.14.1984 AI.LAS TBiES HERALD Plant spokesm'an Dick Ramsey in5Pectors were bemg harasseo, and baause said Cygna provided adv&nce lists he reported the situauon to the NRC staff.

UC cat of documents it needed, but only Dunham, now a supervtsor at the South in cases where it was not con. Tem project sa2d the main supervisor for the o cerned about whether the records paint department repeatedly tned to pressure

= were complete. The lists wer, inspecmts to overlook defective work so that

= provided only when large num- constnaction schedules could be kept.

" bers of records were gomg to be i

used to evaluate plant psocedures.

He said the inadents of harassment in.

and the advance notice gave the cluded a meeting in which supervtsors s.ud l1@V d -

unhty ume to promptly assemble the records. Ramsey said.

He said the lists usually wer, they were thinkmg of hnng mott, the in.

spector who now works at the South Texas pfant, because Elliott was reportmg defects, Dunham said he successfully cormnced them not provided 'until the af ternoon n t to fire Elhott. Elliott said in an interview

• i=pation, and thus Panel told clant r *the utdity would not have had that he was warned by an angry supervisor to

aa <*aor'== the d ' ct= aa 'ar=ai report-

= = -y erabte== be-knew of reviews fore Cygna arnved, required by the NRC.

t h M ,$'gg* [d ou Dunna emxarmnadon. Dt'nham ad-3y JACK BOCTTH p ____

mitted he se ved a year in pnson af ter a 1974

.taff Wnter specfic rules for keeping conviction for burglary, and he said he re-

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g wwn the comultant and ceived a suspended six-month sentence in 1977 A former documents supervisor ,commumcauon

.t th?

Comanche Peak nuclear ,the utdity to a mm2 mum, ll correspondence including between the twothe provi- for a convicuon for breaking and entenn

)lant has charged that utility offi. si n that a d have to be kept on file for NRC

.tals were given Myance notice of groups woul which records a supposedly inde- 5""'N* h d dd h study m-

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• I ne dunng a review of the plant meanss 'perfical of determmmg afterhow its completion, thorough the con. saytng it lacked a i2 Hatley, who was fired sultant's inspecurs wne.he NRC suggM Dec. 28 mat de uul-

' rom the plant near Glen Rose on ity order yet another study. Two weeks ago.

Fc. 7. said her supenisors gave

.ser a handsntten hst the day be TUGCO suggested a more extensive study by Cygna. At the same time, two former engt.

' ore the consul'. ant arnved and nms at me pht charged in aWants e me told her to make sure the secords licensing board that the first Cygna report was rde biased in TUGCO's f avor. .

e next d y a consultant from M am6er d Pment, two fow qual.

Cygna Energy Services of San ity c ntrol inspectors at Comanche Peak said 88"

• Francsco %M at those specthe hents and m omus.** Mrs. M nday to thethat South thev Texaswere oenuaded Nuclear Projecttoneatransfer Bay *

'I da" City after it became obvious that they would n to t e ey .

and Iicenstng Board, which over be called harassment to tesufy of inspectors in a heanng at Comanche Peak. about alleged t sees work at Comanche Peak. .ferrv Ar*rm and Walter Elliott said they,

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-It was obvious that someone al r g with four other mspectors, were.ggdm w#a i had been given information about January eat mey had de option of transfu.

i which specific documents Cygna I

would be reviewmg." said Mrs.probable ring to the South layoffs in 120Texas days nuclear plantator face if they stayed j '

Comanche Peak.

g,gV' Juarutag' lhs, E president of the W h Wu ph a M -

I Citizens Assocanon for Sound En the day after heanngs were scheduled for Fort .

ergy, o public interest group, said Worth on the harassment issue. Artrip said the th> list casts doubt on whether Cygna was as independent as it aj!1of d2ificult thesixtraitsfer for the inspectors appeand to appearm at be the m make it was supposed to be during the Fort Worth bearing, because they were not

$500.000 study. The study was commissioned by Texas Unlities given paid days off to attend the hearing, nor Generating Co., the consortium of were their traveling expenses paid. Dey said only the six inspectors who were subpoenaed ax utdices that owns the plant, were approached about transfers.

cf ter the U.S. Nuclear Regulatory f Ccmmission staff said it had Both men said they were not needed at doubts about the plant's safety. the South Texas plant, and Elliott said he was Mrs. Ellis said advance notice even assigned to a different type of work be-ctndd have given the utihty the cause no openings existed in the paint opporturuty to track down any department.

erussmg documents before Cygna Dunns the harassment heartrig Monday I inspectors arnved. The adequacy in Fort Worth. William A Dunham, a former of1the utdity's record keepmg has supervisor of paint qual:ty control inspectors, , <.

been a key issue in the licensmg tesuffed befor,11S. Labor Department Ad.

Marines for the plant. ministrative Law Judge Robert Feldman that [' *) r

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In Reply Refer To:

Docket: 50-445/83-52 M 21 W Texas Utilities Electric Company ATTN: R. J. Gary, Executive Vice President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:

This refers to the inspection conducted by Mr. C. R. Oberg of this office during the period December 20, 1983, to January 30, 1984, of activities authorized by NRC Construction Permit CPPR-126 for Comanche Peak, Unit 1, and to the discussion of our findings with Mr. R. G. Tolson of your staff at the conclusion of the inspection.

Areas examined during the inspection included inspection of alleged poor cable tray clamping methods and other concerns expressed by an individual who has requested confidentiality. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. These findings are documented in the enclosed inspection report.

Within the scope of the inspection, no violations or deviations were identified.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the ~~

date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

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E0 RPS-/h C0berT;g RPS-Ah DHunnicutt TWes$

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I Texas Utilities Electric Company Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, Original Signed 8/.

s E. H,Johnscm E. H. Johnson, Chief Reactor Project Branch 1

Enclosure:

Appendix - NRC Inspection Report 50-445/83-52 cc w/ enclosure:

Texas Utilities Electric Company ATTN: H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201 Texas Utilities Electric Company ATTN: B. R. Clements, Vice President, Nuclear Skyway Tower 400 North Olive Street Lock Box 81 Dalles, Texas 75201 bec to DMB (IE01) -

bec distrib. by RIV:

RPB1 Resident Inspector-Ops ..

RPB2 Resident Inspector-Cons TPB Section Chief (RPS-A)

J. Collins, RA R. Denise, ORRP&EP C. Wisner, PA0 Enforcement Officer S. Treby, ELD C. Oberg MIS SYSTEM RIV File TEXAS STATE DEPT. OF HEALTH Juanita Ellis David Preister 1

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-445/83-52 Docket: 50-445 Construction Permit: CPPR-126 Licensee: Texas Utilities Electric Company (TUEC)

Skyway Tower 400 N. Olive Street L.B. 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES), Unit 1 Inspection At: Glen Rose, Texas Inspection Conducted: December 20, 1983-January 30, 1984 Inspector: h. [. 44 %

C. R. Oberg, ReactqffInspector Dafe h/7/f/

Reactor Project Secfion A Approved: Jhl M k 7/89 D. M. Hunnicutt, Chief D6te' Reactor Project Section A Inspection Summary Inspection Conducted December 20, 1983-January 30, 1984 (Report 50-445/83-52)

Areas Inspected: Special, unannounced inspection of alleged poor electrical cable tray clamping practices and other concerns expressed by an individual who requested confidentiality. The inspection involved 42 inspector-hours onsite -

by one NRC inspector.

Results: Of the four concerns regarding poor construction practices, one was found to be unsubstantiated; one was found to be substantiated, but had no techni-cal merit; and two were found to be related to internal Brown & Root, Inc. (B&R) administration and policy matters over which the NRC has no direct jurisdiction or responsibility.

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2 DETAILS

1. Persons Contacted Texas Utilities Services Incorporated (TUSI)

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• R. G. Tolson, Site QA Manager Brown & Root (B&R)

Individual A - Supervisor Individual B - Employee (not interviewed)

Individual C - Employee C. Randall, QC Supervisor M. Warner, Staff Engineer

• Present at exit meeting

2. Alleged Poor Construction Practices and Other Concerns Four concerns were identified to the NRC inspector by Individual A, the alleger. They were identified during discussions and a folJowup tour of the area of concern in the Safeguards Building. They are:

a. Untrained Electrician Used in Safety-Related Wor <

A pipe fitter (identified as Individual B) was hired as an electrician.

His work in the 810'6" level of the Safeguards Building had to be done over due to his inexperience. A portion of the rework had to be done by the alleger, Individual A. The alleger indicated that supervision and management continued to use Individual B even after becoming aware of his lack of training in the electrical area. --

b. Undue Pressure and Restrictions The foreman (Individual C) of Individual A applied " pressure" to get -

assigned rework done, but restricted Individual A by: (1) not allowing him to get materials for his work; (2) not permitting him to go to the Fab Shop; and (3) not providing any needed documentation such as ,

drawings, sketches, or component modification cards (CMC). Only verbal instructions were given to the alleger.

c. Threatened With " Firing" The alleger was threatened with " firing" .for looking around and

" scrounging" for materials for use in his work.

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d. Unsatisfactory Cable Tray Attachments The alleger, Individual A, had stated that he had a " problem" with 60 or 70 cable tray hangers on elevation 810' in the Safeguards Building.

The cable tray attachments wer'e not done in accordance with DCAs and CMCs. (All of the 60 or 70 cable tray hangers were not identified to the NRC inspector.)

3. Inspection Results On December 20, 1983, Individual C was interviewed by the NRC inspector.

Individual C said he knew Individual A and that he had worked for him.

He stated that Individual A was not an outstanding worker and was limited in his knowledge. He felt that the primary problem was a personality conflict with Individual A. He also stated that Individual A had quit, but was now back onsite working in Cable Spreading Room 2, Unit 2.

Individual C could not identify the specific items on which Individual A had worked. Individual A did not assemble any cable tray supports, but he did work on backfit problems and on the identification of supports in the Unit 1 Safeguards Building, 810' level.

On January 3,1984, the NRC inspector interviewed Individual A, the alleger.

He stated he had worked in the 810'6" level, east side, Safeguards Building, Unit 1. He said that with the appropriate prints he could identify the specific areas and cable tray hangers that he had worked on. He said that primarily he worked on finding the correct identifying number of the hangers.

His concern regarding . Individual B was that Individual 8 did not know the electrical trade. He stated that Individual B had quit work and was no longer on the site. (This was confirmed by contacting the B&R employment office.) ,

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On January 16, 1984, the NRC inspector again interviewed Individual A. He identified the two areas where he worked from Drawing FSE 00195 - Electrical Equipment Area, Cable Tray Support Plan, 810'6" elevations: (1) " Big Room Area" (areas bounded by: G3-G2, G2-D/E3, D/E3-D/E2, and D/E2-G3 and (2) " East Hallway" (areas bounded by: Al-B1, B1-82, B2-B1, and 81-A1). In the " Big Room" area he corrected supports worked on by Individual B, as well as doing some of his own. This is also the area where Individual C prevented him from obtaining materials. Individual A stated he did not use any unauthorized materials, but when faced with a lack of materials, he went ,

onto something else for *which he did have materials. Individual A said that he was not given site work authorization (SWA). In addition, Individual C would not answer questions and that Individual C withheld information deliberately in order to give him a reason to fire Individual A. (Individ-ual A was never told this directly.) Pressure to increase work output was applied to Individual A. He also states that B&R supervision was " covering up" Individual B's work by having it redone by someone qualified. Later, Individual B quit because he was not able to do the work, according to Individual A. Individual A said he corrected all problems found wrong in any " rework."

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On January 16, 1984, Individual A, in company with the NRC inspector, walked through the areas of concern in the Safeguards Building. He pointed out some of the specific supports that he and Individual B had worked. The specific tasks involved fastening the cable trays to the supports with bolts and nuts and inserting beveled washers, hardened washers, and other hardware items where necessary. Some holes had to be drilled. In the switchgear room, Hangers 12493, 12494, 1587, 1586, 1452, and 1453 were identified as having been worked on. In the Passageways 1548, 1549, 1552, and 1551 were worked on for identification of numbers. He did not work on any cable tray supports.

Individual A made the statement that it looked as if the hangers had been reworked. He saw "nothing wrong with tnem now."

The following pertinent information was obtained by review of B&R personnel records:

a. Individual A was employed by B&R from March 7, 1983, to September 13, 1983. He had quit to work "elsewhere." Individual A was rehired on October 20, 1983, and is currently working in Unit 2 of CPSES. He had a " good" rating for rehiring.

b. Individual B was hired as an electrician's helper on June 10, 1983.

He left on September 2,1983, to work elsewhere. He had 7 years experience as a pipefitter.

c. Individual C was made a foreman in February 1983 and is currently working onsite in Unit 1.

4. Discussion The NRC inspector reviewed the requirement for attaching cable trays and reports regarding the general area of cable tray fasteners.

On July 19, 1983, a 10 CFR Part 50.55(e) construction deficiency report was sent to Region IV identifying a generic problem with cable tray clamps.

It was reported that mild steel bolts (ASTM-A-307) had been used in place of the designed high strength bolts (ASTM-A-325). It was determined that the mild steel belts were acceptable for regular cable tray support clamps.

Other applications where A-325 bolts are required will be verified by site QC. Rework will be done as required. The corrective action on this construction deficiency includes verifying the correctness of bolting -

practices.

Twenty-one separate nonconformance reports (NCR) have been issued by site QA covering all areas of Units 1 and 2. Closure of an NCR will utilize requirements of QI-QP-11.10-2, described below. The specific NCR covering 1 the area in the Safeguards Building, Unit 1, is identified as M-83-01670 (below 831' level).

A more general and overall inspection is done under the cable tray hanger inspection procedure. QI-QP-11.10-2, " Cable Tray Hanger Inspection,"

provides inspection criteria, attribute and inspection frequencies to be 1

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5 used when inspecting Class IE cable tray components. These components include splice plates, side plates, heavy duty clips, and other miscel-laneous tray components. Specifically, paragraph 3.1.7.2 covers the inspection of bolted cable tray clamps. All bolted connections are required to be documented on an inspection report. Revision 23 of this instruction requires that all previously inspected cable tray clamps are to be inspected in accordance with the provisions of paragraph 3.1.7.2.

Included as part of the report is a list of applicable drawings and the applicable NCRs, DCAs, and CMCs. The cable trays are inspected to these documents.

NRC inspectors examined the cable trays in the area identified by Individual A. No discrepancies involving cable tray clamps were identified.

The following cable tray hanger inspection records were reviewed: ,

Cable Tray Inspection Inspection Hanger Number Report

• Results 01453 ME-45500 Satisfactory 01452 ME-45499 Satisfactory 01548 ME-1-0016172 Satisfactory 01552 ME-1-00151296 Satisfactory 01586 ME-1-0016168 Satisfactory 01587 ME-1-0016169 Satisfactory The following hangers had not been inspected by QC, but are scheduled to be inspected in the near future: .

. 012493 012494 01551 00824 ..

00822

• Inspection Item Description " Inspection of Cable Tray Clamps."

5. Conclusion

a. Allegation: Untrained Electrician (Individual B) Was Used in ,

Safety-Related Work No safety-related discrepancies were identified as a result of the

" untrained electrician" effort's. The records indicate that he had no experience as an electrician, but tnat he was hired as an electrician's helper. Work assigned to him was not beyond that normally assigned to a "b91per." The allegation, therefore, has no technical merit, although true.

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b. Allegation: Undue Pressure and Restriction No safety related discrepancies could be identified as a result of this allegation. Individual A had stated that when he was unable to obtain proper materials, he would leave that support and proceed to one where materials were available. The activities associated with this specific allegation thus cannot be considered within the jurisdiction of the NRC. This appears to be a problem of supervision and management within the constructor organization.

c. Allegation: Threatened With Firing There appears that a personality problem existed between Individuals A and C. There is no direct association to safety-related functions in this allegation. Again, this appears to be a matter of management for B&R, and beyond the jurisdiction of the NRC, since Individual A is a craft worker and not a QC inspector.

d. Allegation: Unsatisfactory Cable Tray Attachments Based on the information from QC inspection reports, actual observations by the NRC inspector and statements by the alleger, the presence of unacceptable cable tray attachments was not substantiated. No impact upon the health and safety of the public was considered to be present.

6. Exit Meeting On January 30, 1984, the results of this inspection were discussed with the licensee repi'es'ntative. Individual _A was contacted by the NRC inspector by telephone subsequent to the inspection. The results of this allegation were discussed with him. He stated he was satisfied with the results of the inspection. .

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