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Revision $ 10/12/84 SSER AQ-131 CP5 SSER
- 1. Allegation Group: QA/QC, Category No. 5A
- 2. Allegation Number: AQ-131
- 3. Characterization: It is alleged that electrical boxes were shipped to Comanche Peak Steam Electric Station (CPSES) in a damaged condition or were damaged, then repaired, by unauthorized personnel.
- 4. Assessment of Safety SignifArance: Te mplied gni icance of hs al'ega nisth'at,ifth[alle tio is t e, e in gr he elec la q y be que onable.
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TheNRCTechnicalReviewTeam(TRT)reviewedthetestimonyanUinvoices 2
associated with this allegation. The electrical equipment S r was sold by RLS Industries Inc. to Tyson Building Co. This company was fulfilling ,the conditions of Subcontract CP-0712, which was issued for construction of.four nonsafety-related buildings at CPSES (an administra-tion- building annex, two combustible-material storage buildings, and the operations support center). The TRT learned that the electrical boxes in question.were located in the floor of the idninistration building annex. Tyson Building Co. was under contract 'o build the. administration annex and, therefore, was responsible f~ t t- eting this work.
The repair work involved filling in the floor aro g xes and U replacing the floor tile. The TRT determined Athat the electrical boxes, which distribute 120-volt power to the telephone lines throughout the center of the building, were never in a, damaged condition. T : " '4aa,
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- 5. Conclusion and Staff Positions: Based on the evidence reviewed, the TRT
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concludes that this allegation cannot be substantiated. The ele::rical boxes were not damaged, as alleged, and only the flaor arotnd the boxes and the tile covering the boxes were repaired. In addition, this electri- '
cal equipment is nonsafety-related and is installed in a nonsafety-related area. Accordingly, tSis allegation has neither safety significance nor generic implications.
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- 6. Actions Recuired: None. g "LA .
TfWWEG8MMiRMQ _
- 8. Attachments: None.
- 9. Reference Documents:
- 1. NRC allegation review case number 4-84-A-49, April 3, 1984.
- 2. Texas Utilities Service Inc., Subcontract Contract #CP-0712.
- 10. This statement prepared by: h. d. x!b 0 2 4 Lewis C. Rounds,l'TRT Date Technical Reviewer Reviewed by: -
Eb/uv7 E // M - h H. Livermore, Date Group Leader Approved by:
Vincent Noonan, Date
. Project Director s
- 1F M 395
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-. SSER WRITEUP DOCUMENT CONTROL / ROUTE SHEET g/0 Allegation Numbers /7 O - 8 D (O bA Subject of Allegation o ' u o a r- 4./ 27/-c ( a /f />, J v ,7 4#~ /berme/c TRT Group Oval //v Author: / , F. I40v d t 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. ,
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/W Y Draft Number t r _O
7 Draft 1 2 3 4 5 Author EI . N [4r-f .
Group Leader / M"4b% )
. Tech. Editor / W P3 7/l3 Wessman/Vietti /
J. Gaqliardo /
T. Ippolito _
Revision Number Final 1 2 / /,, f 3 4 5 .
Author ll/Pl, f Tech. Editor ~
s/MAf "
Group Leader ,/ I '/F i /
J. Gaaliardo Il 9 /s* / f F/P T. Ippolito e /
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Administrative Writeup integrated into SSER Potential Violations to Region IV Workpackage File Complete Workpackage Returned to Group Leader
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Document flame:
SSER AQ-68, AQ-82 Requestor's ID:
, DEEQB01 Author's flame:
Polusny Document Comments:
Comanche Peak Task Force M
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SSER AQ-68, AQ-82/CP4 Revision 4 10/24/84 SSER
- 1. Allegation Group: QA/QC Category No. 5A
- 2. Allegation Number: AQ-68,AQ-82
- 3. Characterization: It is alleged that: (1) periodic missed maintenance has occurred, (2) maintenance cards were signed off without the actual maintenance being performed, and (3) that quality control personnel accepted the work without actually inspecting it.
- 4. AssessmentofSafetySignificancedSQm;T ,
tgna ThH rm- L i he_ , _ s_ &_.bena rab s -nn e n _n_ _c H. n_ . .
rd i gn2;cfhi= GAAffdp#M y k4. The NRC Technical-Review Team (TRT) reviewed the Comanche Peak Steam Electric Station (CPSES) Equipment Maintenance Records (EMRs) and found a program in-place that included procedures CP-QAP-14.1 and MCP-10. The program
. requires that maintenance which is omitted is to be documented by nonconformance reports (NCRs). The TRT found no verifiable evidence to indicate that maintenance cards were signed without performing any maintenance at all; however, in the case of inaccessible or out-of-service equipment, for which the completion of total maintenance could not be performed, maintenance cards may have been signed off without all of the maintenance being performed; e.g., turning of shafts Interviews w y- g -
2-with maintenance and quality control personnel indicated that some EMR cards would have notes attached indicating that only partial maintenance could be performed because of components missin
. m .k. lor transferred, F- : u ,
Thlswasnotalwaysthecase,norAwassedmadepartofthepermanent record. When equipment was inaccessible or out-of-service, only partial maintenance was performed on occasions and the maintenance cards were signed as if all the maintenance h be comp ,w o io the cards indicating what was left undone A However,ythatmaintenance @-
which could be completed was completed. . N >
i A review of selected EMRs, and interviews with QC personnel who documen ed missed maintenance by NCR, indicated that there were e- M isolated-breakd0y:ns of the preventive maintenance -(PM) control program around the time frame of these allegations. QC acceptance of work not conducted or not inspected could have occurred during this time, but the TRT could not identify such occurrencer, Brown & Root (B&R) construction management recognized this problem an'd ordered ap a,udit "g'g -
Vs d of all PM EMR cards for location and status of signoffs. Also,$8&R management conducted special training sessions on maintenance control procedure MCP-10 and the importance of proper /on-time maintenance.
Since that timb the PM program appears to be functioning properly,[ m AD m fddym Yo The TRT also found that although Permanent Equipment Transfer forms (PETS) show the transfer of Unit 2 components to Unit 1, the EMRs show continuous maintenance and do not indicate when the Unit 1 components were either transferred or repaired. The process of transferring Unit 2 components to Unit 1 caused problems in the CPSES preventive
maintenance program. A TRT review of PET Nos. 4 through 1665 and of selected EMRs indicated a few cases in which total maintenance could not b2 performed or was delayed on some Unit 2 component parts (for example, pumps, pump shafts, and valves) which were transferred to Unit 1. The Unit I components were subsequently either repaired inhouse or returned to the vendor for repair. However, the maintenance cards do not reflect the transfer of Unit 2 c'omponents to Unit 1, nor do they reflect the partial maintenance which would have been required on the Unit 2 components awaiting the repair of Unit I components.
3 AprocedureexistswhichallowsforavarianceinthePMprogram.
This process would allow maintenance personnel to bypass maintenance.
Both Brown & Root (B&R) and Texas Utilities Electric Company (TVEC) provide maintenance programs at CPSES; k N + y,' t'.; an agc L w.a y Tir i t i t: "4",. A review of the B&R and TUEC turnover process reveals 2-t. recovery of ote k J ..; d kcontinuity of PM and revealed a the k E..d (;.s Z ...s. When equipment has been accepted by TUEC, the past construction maintenance history is placed in the operations vault and the equipment preventive maintenance (PM) requirements are entered into TUEC's maintenance operations data system.
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, ovidi a 'isii ie f-quanti con.:r m no n program e-p15~t +Nmeb e ,
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l ide itional as uran eetha pQr - v getned.
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The PM system for B&R is divided into two parts, nonsafety-related and safety-related, and provides specific requirements for QC inspection.
All maintenance on safety-related items requires both quality inspection and an independent quality verification, including verification of the signatures on the EMR cards. h - drement limit: t:w e mme 1
-r+h .;. a e.Y Interviews with '
QC inspectors indicate that it would be almost impossible for maintenance personnel to signoff maintenance cards for safety-related components without performing the work because of the checks and balances in the PM system.d For f h to occur in the safety-related h
part of the PM system, the fai. lure must occur in three independent ys: QC inspection, quality verification, and maintenance personnel.
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The nonsafety-related maintenance program was somewhat less formal, and was more susceptible to the type of failures alleged.
A review was performed of EMR cards for both the safety-related and nonsafety-related systems. This examination revealed proper 7s #
performed, inspected, and verified preventative maintenance, with the exception of those failures documented in NCRs and a corrective action reqyest (CAR S-40). Failure to perform on-time maintenance in the past i has occurred as documented by NCRs. A TRT review of current PM practices indicates that NCRs have been written for missed maintenance and that documented waivers to maintenance have been granted.
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- 5. Conclusion and Staff Positions: Based on a review of the applicable documentation, and interviews with CPSES personnel, the allegations of maintenance and QC personnel signing off and accepting quaiity controlled GM#,r -
maintenance work withoutAactual performance could not be substantiated.
However, the TRT concludes that the allegation is partially substantiated with regard to missed maintenance, a W J ~ u m u_ x. cr-f::' " d The reasons for missed maintenance were documented in tiCRs and a CAR was formulated which documented maintenance processes which were not being followed. This CAR also outlined the steps required to assure system correction. The TRT evaluation of the B&R PM schedule indicates that it exceeds most vendor specifications, MC _ _ _ ._ ces c^ - ._, therefore, periodic missed or delayed maintenance has n=-little safety significance prior to continuous operations, especially on equipment with limited use or limited stress. The total CPSES maintenance program has sufficient checks and balances to maintain system integrity. Accordingly, this allegation has neither safety significance nor generic implications.
The TRT was unable to locate this alleger to discuss the assessment and conclusions.
- 6. Actions Reouired; ficne.
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- 8. Attachments: fione .
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- 9. Reference Documents:
L j 1. PETS No. 4 through No. 1665.
- 2. NCRs,4782, 5293, 9640, 9717-9719,-9780-9783, 9792, and.
14501 through 14503.
l 3. Maintenance Control Procedure MCP 10, Rev. 4 through Rev. 7.
- 4. Selected EMRs.
i
- 5. AQ-68: A-26 Testimony, pp 2, 24 and Q4-84-001 dated January 9, 1984. .
- 6. AQ-82: A-26 Transcript pp 14-16 and 27-28 and Q4-84-001.
- 7. CP - QAP-14.1, " Inspection of Storage and Maintenance of Mechanical Equipment."
l
- 8. CAR S-4'0, " Maintenance Progress Not Being Followed."
- 9. Components: CP1 - CCFYCC-07 i' S/N 290950 through S/N 290959 ,
j_ S/N 12120
! CP 1 - SWAPSW - 01 & 02 CP 2 - SWAPSW - 01 & 02 .
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! CP 1 .TWAPTP - 01
! CP 2 - TWAPTP - 01 -
CP 1 - DDAPRM - 02 l
t CP 2 - DDAPRM - 02 CP 1 - CHCICE - 06 CP.2 - CHCICE - 06
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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
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L SER WRITEUP DOCUMENT CONTROL / ROUTE SHEET
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Allegation Numbers A O -(o f I 4 O Er A , 4,m [ '
Subject of Allegation L A c)c of M An 74w d sc'E U TRT Group Q A/O c C n 7 E riot t, A-L /h A 7kNfk A AfeF Author: M . No #, tic. / $
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 1 2 3 4 5 Author M N.
Group Leader / /"f h Tech. Editor / M fM//
Wessman/Vietti / /
J. Gaaliardo / /
T. Ippolito / / _
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Revision Number b4/ohrh Final 1 2 , 3 5 -
Author 4 1) /
Tech. Edi tor #fA%!V4Ce/fo
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Grouc Leader r// / // /
J. Gaoliardo H *///4 '
//Ph1N/4 TCdu) %d T. Ipoolito '
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Administrative , , ,
Writeup integrated into SSER Potential Violations to Region IV ,
Workpackage File Complete Workpackage Returned to Group Leader 9
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-AQ-61 2 Requestor's ID: i JEA!1
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SSER AQ-61/CP4 Revision 1 2/3/84-2-
SSER 3//3lPS
- 1. Allegation Group: QA/QC Category No. 5A
- 2. Allegation Number: AQ-61
- 3. Characterization: It is alleged that supervisors told welders to weld-up a " gouged" hole rather-than wait for the authorization that follows the engineering disposition of the discrepant condition.
- 4. Assessment of Safety Significance: The im lie -
icance of thia .,
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ile ation is that hen'. fab icatios proc e not! dhsrecto, york'
.ay e pe edi,ndscrimkn u[jeo y rdi pla'nngesign
-a. se try c n.tpois wn1 o tha q"al/ty of-installa 'f on.
~ n ine ailEg'aT pYbviced no specif information regarding thi allegati n, "and th A1RC Technical Review am (TRT) was unable to con a t the alTgger doobti additionaIdetails. In lieu of sfecific informati n regarding fhedlteoftheal!egedoccu ence or the Inecific identity fthecoha-rent, wel der, or el , the T reviewed the requiremen!sgove!ningwid I I- \
pa rs. The TRT al o revi ed Brown Roo< (B&R) pro cedures
/ CP-CPM-6.90 ah P-CP -6.9G for w Iding, stal ion, d docum ntation. In additic ,
- t. RT re a d B&R w id- recadure -spectfTra ions,c802h 88025 and11032.
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Tfe oun t M sp c#ific wri ten procedures define the criteria which determine whon defects require major, minor, or in process welding repairs.
These procedures also include tables defining the required inspections for each type of weld fabrication. The TRT also learned that these require-ments have been in place for at leas ~t 3 years.
The TRT found that welders are trained in the contents of the construction and welding procedures and that this training is updated as each procedure is revised. The TRT also found that weld technicians supervise the welding e, -+ ease.==* _ m,,,+-en- **= *-- ~ - - * - * - - - +
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try and serve as the first, unofficial, weld inspectors. Quality centrol (QC) personnel then inspect the welds and accept them or identify defects requiring major or minor repairs. Repair process sheets, which define the operational steps for making the repairs, are then generated for each weld repair.
I Fi e wel ers were randomly chosen from a list of 200 welders cyrrently '
7 1ders ad an verag f 5-1 year , work emplofedaTComa,nchePeak. The welders separately, ex erience at C SES. The d I
I TRT f anyo!
in.erviewf ne re I each/:f uesting:/\welders thto
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do work without as ng if they h d heard n up o corre ting pr per paperwork espejially.17tecontext f cover
- some marginh work. All fekelders \_/
stated that the had never eard of >
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an one either proposino_t_o E rk ne instructic v
- 5. Conclusion and Staff Positions: The "hkm . . ;. : : th: ; :- ;;:L .
urutH+ > :' .' ^ : ; 9 " M u t -- ~ :; -: : ' " : . . . f . .- _ t '. ; c . Hm m Based on a review of the applicable requirements governing weld repairs and on interviews of welders, the TRT concludes that this allegatica has neithersafetysignif.gcenorcenericimplications.
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- 6. Actions Recuired: None. ,
& . #.. $ $ W M E W L y.
- 8. Attachments: Ncne.
- 9. Reference Cacuments: .
- 1. CP-CP."-6.90, Rev. 6, " Welding and Related Processes," paragrach 3.19. .
- 2. CP-CFM-6.9G, Rev 6, "Decumentation for ASME Welding and Insta'liation Activities," paragraph 3.3.3. ,
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- 3. Brown & Root Weld Procedure Specifications 88023, 88025, and 11032.
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- 4. AQ-61: A-4 Testimony,84-006 3/7/84, pages 10-18.
- 10. This statement prepare.d by:
. Clyde Morton, TRT Date Technical Reviewer Reviewed by:
Herbert Livermore, Date
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Group Leader Approved by:
-- Vincent Noonan, Date Project Director
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Document Name: 'O COMANCHE PEAK AW-37 & AQ-52
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Requestor's 10: ,-
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Stang A h, ,
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- 1. Allegation Group: )ht$QA/QC,CategorySA
- 2. Allegation Numbers: AW-37 and AQ-52
- 3. Characterization: 'It was alleged that a 4- or 6-inch stainless steel check valve was disassembled for a weld repair without a written procedure for the disassembly and reassembly (AW-37) and site personnel inttrchanged parts of diaphragm valves during disassembly / reassembly operations (AX-52)
- 4. Assessment of safety Significance: The implied safety significance of the allegations is that valves may have been reassembled improperly and parts traceability is indeterminate)(. The valves may not function as required in system operation. ph The Technical Review Team (T reviewed site procedures, which were in effect prior to June 1983, for the control of materials.and equipment and the disassembly of valves. ThisreviewincludedB&RCP-CPM-6.93Rev.O,
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" Pipe Fabrication and Installation"; B&R ACP-3, " Receipt Storage and Issue" (replaced by B&R CP-CPM-8.1); B&R MCP-10, " Storage and Storage Maintenance - f of Mechanical Equipment"; and TUEC CP-EP-9.2, " Control of ASME Related jf[Ml Materials and Items." The TRT noted that CP-CPM-6.9E,Section 3.14 (ef fec .
tive February 6,1980), addressed the control of valve disassembly /reassbmbly,
- I including the control of disassembled valve parts as follows: !
/
All parts removed frca the valve shall be stored in a heavyduty plastic bag, or in the case of a large valve, a wooden or card-board box. The mechanical superintendent (MS) shall mark the
- box / bag witn the valve number.
Any valve that will remain dismantled for an extended period of time will have the bag / box of parts stored in a secure place in the Millwright shop or warehouse. If the MS estimates that the
. valve will remain disassembled for only a short period 'or that it i
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- is L o large to be easily removed from the work area, then the bag / box may remain in the field.
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- The TRT assumed the intent of Section 3.14 to mean that control of the f disassembled valve parts would' assure the protection of the parts against fd damage or loss and the reassembly of the parts in or to the valve body from which the parts were originally removed. The TRT found, however (as detailed in later paragraphs of this assessme,nt), that this cont-ol was not effectively implemented. The TRT also noted that the procedures did not
' establish the measures nor provide instruction to prevent the interchange or mismatch of parts among different valves in the reassembly process.
Even though B&R procedure CP-CPM-9.18, Rev. O, " Valve Disassemblyf3easspbly" (June 8, 1983), instituted controls for identification of .
valves, it did not address the subject of mismatch or interchange of these parts. The TRT notes tha.t it is a standard and desirable practice in the industry to maintain the initial installation of the valve configuration in accordance with the manufacturer's code data report (NPV-1 Form and
[ Attachments). This practice provides traceability, and some assurance of valve integrity, performance, and reliability, under the specified service conditions for plant operation.
RIV inspection report (IR) 79-21 and 22 provided the details of the in-
. ,. vestigation of allegation AW-37, including interviews with the alleger .
and a witness to the alleged event. The report concluded: ,
~ "The witness identified by i.he alleger was interviewed. The witness stated that the valve in question was a 6" check valve /
) and that proper repair and resolution of the initial discrepancy was complete and documented. Furthermore, there is no evidence
. that would suggest that the procedure discrepancy cited by the alleger would have a potential detrimental impact on the health 3([J .
and safety of the public. m{
"Since the witness, who had first hand knowledge of the valve p repair, refuted the allegation, the IE inspector concluded that the allegation could not be substantiated." ,
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To assess the generic implications of the allegation concerningAvalve disassembly / assembly g e c 6 0s, the TRT reviewed safety related borated h
l . ~ water piping systems which contained 4- or 6-inch stainless steel check f valves. The systems were detailed on B&R drawings BRP-CS-1-AB-001 and l -002. Three 4-inch valves were installed in the chemical and volume con-L trol system CSEQ and four 6-inch valves in the safety injection system, i . C5RT. All nonconformance rfp for the seven valves were re. viewed to determine whether the valves were disassembled for weld repairs. The TRT found that Valve No. 1-8440 (Item 14 of DWG BRP-CS-1-AB-002) was repaired; however, the repair process sheet (RPS) WED-04158 did not require -
disassembly of the valve to accomplish the repair.
TRT discussions with the preparers of operation travelers (who were different from the preparers of the RPS) indicated that no special traveler was initiated for disassembly of valve Tag No.1-8440. Of the remaining six NCRs reviewed, none contained examples of valve weld repairs or valve disassembly. The TRT interviewed craft personnel who reported no knowledge of a valve disassembly without procedural instructions.
TheTRTreviewedTUGC0krawing2323-MI-0241and0242,demineralizedand reactor water make-up flow diagramss to determine th.% l_ocations of the type a'
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of valves referred to by the alleger (AQ-52). The P "; valves were
, 3-inch butt weld jhand operated diaphragm valves which were installed in -
systems such as the spent fuel cooling, boron recycle, and chemical and ,
~
, volume control systems.
The TRT found that installation of these butt welded valves required dis-assembly and removal of internals to prote'ct temperature sensitive parts.
Interviews with engineering and QC personnel, as well as review of docu-mented deficiencies verified that during installation, the valve parts were stored in uncontrolled areas, which resulted in lost and damaged parts and sometimes X interchanged parts.
Interviews with site personnel indicated that although the generic traveler used for original installation of these valves contained a requirement to package and identify loose parts per CP-CPM-6.9, it was not , adequate to C /C ','Ct 3 C9 ' ""' :: T:n A-li a nW
t prevent loss or intercharging of rarts. Subsequent revisions of this i
generic traveler, added a requirement to record the heat numbers of the valve body and bonnet prior to disassembly.
f ,
A TRT walkdown field inspection identified similar 3-inch ITT Grinnell (ITTG) diaphragm valves rated at different pressures. The TRT determined ff that if the valve bonnets on these valve bodies were interchanged, a I [
potential problem of safety significance would exist. Conversations with f r/1
. ITTG and TUEC engineering personnel identified a concern that if a valve j' bonnet rated below 275 psig was assembled with a valve body installed in a system with pressure greater than 275 psig, galling could occur in valve stem components. However, both ITTG and TUEC personnel indicated that l/
valves parts of identical design temperature and pressure could be 9 : C i interchanged. The TRT learned that this type of interchange occurred, and was documented by 51 permacent equipment transfers (PET) which involved valves reasseebied between July 1981 and Octobdr 1984.
The TRT obtained the receiving and inspection reports which document the body and bonnet heat numbers of 136 valves arriving onsite in May 1976.
The TRT conducted.a field inspection of 32 of these valves to ensure traceability of the heat numbers from receipt to installation. The TRT identifiedthreevalves(TagNumbers 1-70148,2-8475,and1-8683)witha mismatch between body and bonnet heat numbers from those identified by ,
receipt inspection. Further review by the TRT found that the mismatch r .
was documented on PET numbers 139, 183, and 219. A review of the pressure-
, and temperature ratings of the interchanged valve components indicated that[theywerecompatibleandcouldbefunctionallyinterchanged. The TRT found no examples of mismatch between valves of differing pressure ratings, although the potential for this existed due to the site practice of mass disassembly of valves using potentially ineffective procedures.
The TRT interviewed QC inspectors who knew of recent incidents intolving lost / misplaced or interchanged valve bonnett. The QC inspectors stated that when these valves were disassembled for system flush under the direc-
- tion of startup test engineers, one bcnnet was lost and a mismatch between 8:^-^446 4 CJ,.m. u c. rdi /6 4i a %-C i
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[l0 valve body'and bonnet was identified. Although th
[6/O sbME ncidents were docu- ,
mented in nonconformance reports (NCR M-11645 dated May 8, 1984 - typical) these type of problems associated with maintaining control of quality ,
certified valve compnnents indicated to the TRT that in spite of raa 1/ corrective action steps taken over the past years, the problem of lost ik and interchanged valve components still exists.
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- 5. Conclusion and Staff Positio ]ns: Based on the information obtained during A].)
field inspections, document review, and interviews with QC, engineering, and craft personnel, the TRT concludes that the valve disassembly / h reassembly process has resulted in components being lost / misplaced or interchanged (AQ-52). The TRT further concludes that failure of the corrective action system to adequately address this recurring problem see AQ-112) has safety significance in that potential galling or even valve failure may occur if valve bonnets and bodies of different pressure I ratings were mixed.
The TRT contacted the alleger's family on October 28, 1984, and was informed that the alleger wanted no further contact with TRT. No further contact with the alleger has been made Byar$1ewofdrawings,proce-duresj ead. record documents (NCRs), and concurrence with the conclusion statedintheRIVIR79-21and22theTRTfoundthattheallegation"k hlvewas%isassembledwithoutaKrocedure"(AW-37)wasnotsubstantiated.
Accordingly, the TRT concludes that there is no safety significance nor
. generic im'plications to the allegatio TrKTRT nt ed leger familyv Oct6ber 28, . 84 a, waf that alle wanted . urth entace t, t . No fu ther tact wi+ *he al .r has - made
- 6. Actions Required. Seeitemnumberf0ftheenclosurewithD.G.Eisenhut letter to M. D. Spence dated Junary 8,1985.
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S. Attachmn.s: Ncne.
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9 9
0 / 0 1,' E (~' 0.'M
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l .
- 9. Reference Documents: t i
References l
l
- 2. ACP-3 (replaced by CP-CPM-8.1 Rev.1), " Receipt, Storage and Issuance Items."
- 3. MCP-10, Rev. 7, " Storage and Storage Maintenance of Mechanical and Electrical Equipment."
- 4. CP-CPM-6.9E, Rev. O, " Pipe Fabrication and Ir.sta11ation."
3
- 5. QI-QAP-11.1.39A, Rey. 0 (issued June 8, 1983), " Valve Otsassembly/
Reassembly."
- 6. CP-CPM 9.18, Rev. 0 (issued June 8, 1983), " Valve Disassembly /
Reassembly."
- 7. Flow Otagram of Demineralized and Reactor Makeup Water,
- 2323-MI-0241,0242.
av
- 8. Valve Tag Number XSF-083, XSF-089 per SD-C-105686; 1-8616A and- ,
1-86168 per 50,C-100551.
- 9. Permanent equipment transfer Forms PET 139, 183 and 219.
- 10. Operation travelers: MW 80-673-4700, M4I 80-673A-4700, and MW 79-107-5600.
- 11. ITT Grinnell Corp., k3" Nuclear Diaghragm Valve H.W.0.," drawings -
SD-C-105686, Rev. 8, and SD-C-100551, Rev. H.
- 12. AQ-52: 84-006, March 7, 1984; A-7 testimony, pp. 12-14.
02/04/85 7 COMANCHE PEAV AW-37 & AQ-52
.aagne yr- =e ess- = *****=4- -e++
g -m <w ,
=+%e. mm - = v eme , e ee ssymmiya,e*-
\
i ,
- 13. MI-0225 (Valve Tag Nos. 1-8440, 1-8481A, and 1-84818).
t
- 14. MI-0263 (Valve Tag Nos 1-8949A thru D) l 15. RIV IR 50-445/79-22; 50-446/21.
t i
- 10. This statement prepared by:
C. Morton/M. Bullock, Date TRT Technical Review Team
, J. H. Malonson, TRT Date Technical Review Team 1 .
Reviewed by:
H. Livermore, Group Leader Date I
Approved by:
V. Noonan, Date Project Director ,
l l
l i
02/04/85 8 COMANCHE PEAK AW-37 & AQ-52
. Docum:nt Nare:
AQ-43,AQ-47,AQ-51 Requ stor's ID:
STEPH Author's Name:
Polusny Document Comments:
4/19/85 Return this sheet with future corrections 9 O
O 9
0 4
9
.w...-,<. .. - _ . . . .-. . .- -- -
SSER .
- 1. Allegation Category: QA/QC 5A, Re, air, Rework, and Maintenanhe '
. 2. Allegation Number: AQ-43, AQ-47, and AQ-51
- 3. Characterization: It is alleged that there were breakdowns in the quality control (QC) system for repair work. Specifically it is alleged that: (AQ-47)' undocumented weld repairs and modifications were made to material after QC acceptance; (AQ-43) craft workers " bootlegged" rework by performing rep, airs without any documentation; and (AQ-51) equipment was disassembled without authorization or proper documentation. '
- 4. Assessment of Safety Significance: A TRT review of nonconformance reports (NCRs) and permanent equipment transfers (PETS) revealed that disassembly work on pump couplings in the auxiliary bui.lding did occur without comple-tion of proper paperwork, as did repair work on the accumulator in Unit I as alleged in AQ-43 and AQ-51. However, the TRT determined by a review of NCRs that in each case a quality control (QC) inspector stopped the work until the proper paperwork was obtained.
There were 11 out of 378 nonconformance reports (NCRs) reviewed that involved undocumented / unauthorized work activities which required rework.
The dispositioning of these NCRs resulted in the work activity being redone with the appropriate reinspection completed.
While assessing the generic problem of undocumented repair / rework, the TRT determined by a review of PETS, that Texas Utilities Electric Company (TUEC) also transferred the service water systr.m components from Unit 2 to Unit 1 in order to meet scheduled startup dates. Eight montl.s later the pumps were switched back to their original position because the column supports did not align with the pumps. The TRT determined that although the moving of components from Unit 2 to Unit 1 may have had the appearance 04/19/85 1 AQ-43, AQ-47, AQ-5*.
-4 g ee.e e - .-e+ e e...w g ..+e-. a +. . + . . .sm .
- D-4 a of " bootlegged" rework, TUEC used an approved procedure, CP-EP-9.1, " Con-
. trol of Permanent Equipment Transfers (PET)," and properly documented the -
work. The TRT reviewed many documents related to the transfer of Unit 2 components to Unit 1. TUEC made these transfers in accordance with proce-dure CP-EP-9.1 in order to meet startup dates. ~
f The QC system breakdowns were alleged to have occurred prior to 1983.
From 1976 thru 1982 only 4700 NCRs had been written. Systems placed in effect since 1983, including as-built inspections, isometric drawing package reviews, N-5 walkdowns, and turnover reviews, resulted in 10,000 NCRs being written between January 1983 and August 1984. These NCRs iden-tified problems similar to those alleged, and the TRT found that these problems'had been corrected. The TRT selected 676 NCRs for review'from the period March 1976 to August 1984, and found NCRs written in the following areas:
- 1. work on hangers after system stamped,
- 2. rework of support after N-5 certification,
- 3. rework after final acceptance,
- 4. no documentation to support weld,
- 5. welding documentation missing, 6, welding performed after final acceptance,
- 7. work done without QC verificatien,
- 8. removed equipment without documentation, and
- 9. equipment installed without documentation.
The TRT review showed that these NCRs were dispositioned properly and did not support the allegation that these deficiencies were going unreported.
CPSES management, having recognized the repeated problem of undocumented repair / rework addressed by these NCRs, formulated three corrective action requests (CARS) during the time frame of these allegations. The proposed corrective actions are documented in the following CARS:
- 1. S-45: Unauthorized work performed during scheduled maintenance (traveler violation). Jan. 15, 1982 04/19/85 2 AQ-43, AQ-47, AQ-51
.. . . . . = _ .--
-.=-.
C
=---x-----
- 2. S-47: Work performed on system without inspection item removal .
notice (IRN). April l'3, 1982
- 3. S-50: Rework of items completed prior to disposition approval.
Oct. 22, 1982 I
'The check and balance systems appear to have worked properly in the detec-
, tion and correction of identified
- unauthorized repair / rework.
AQ-47 is assessed in Mechanical / Piping Category 4 (AQ10-29) and undocu-
- mented weld repairs and rework are also assessed in Mechanical / Piping Category 10,(AP-5). .
- 5. Conclusion and Staff positions: Based en their review of applicable documentation,jIheTRTconcludesthatallaspectsoftheallegationscan
- be substantiated,p However, identified unauthorized rework and welding
.are documented with NCRs. The TRT did not identify any significan break-down in the QC program, although occasional problems did occur. The safety significance of the allegations relating to undocumented repair welds is assessed in Mechanical and Piping Category 4.
In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of allegation AQ-43 and the TRT's conclusion.
ard
'A brief discussion ensued. There were no major items of disagreement, no new concerns or allegatiens were ioentified. The alleger associated
- w'ith AQ-51 could not be located thus no exit interview was conducted.
- 6. Actions Receired: None.
f f ?
~
(:, _.
t S. Attachments: None.
- 9. Reference Occuments:
- 1. 676 NCRs dated between March 1976 and August 1934 3
AQ .13, Ag_.: , ;g-5:
04/19/S5
- 2. Permanent Equipment Transfer Forms No. 4 through No. 1665. ~
- 3. CP-SAP-6, Revision 9.
- 4. CP-CPM-12.2.
- 5. AQ-43: GAP 2.206 Petition, dated March 19, 1984 and A-1 statement.
- 6. AQ-47: GAP Petition, dated March 19, 1984. I
- 7. AQ-51: A-14 Testimony pp. 1, 4, 5, 10, 14, 16, 25-28 and Q-4-84-001.
- 8. Components: CPI-CCEXCC-07 S/N 290950 thru S/N 290959 S/N 12120 CP1 - SWAPSW-01 & 02 CP2 - SWAPSW-01 & 02 CP1 - TWAPTP-01
^
CP2 - TWAPTP-01 CP1 - DOApRM-02 CP2 - DDAPRM-02 CP1 - CHCICE-06 CP2 - CHCICE-06
- 9. A-1 Interview, December 10, 1984, pp. 88-89.
- 10. This statement' prepared by:
. V. Watson, TRT Date Technical Reviewer Reviewed by:
H. Livermore Date Group Leader Approved by: .
V. Noonan Date Project Director e
04/19/85 4 A0-43, AQ-a , AQ-51
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SEER URITEUP DOCUMEllT C0ftTROL/ ROUTE SHEET q gg
/ legation flumbers .4 0 - /, / bb- c, - h '
je . f Subject of Allegation 4.h e-uwo= ro e ,C < .% d s
/ TRT Group n A / o r.
/ perma Author: e O -r n er l This sheet will be initialed by each reviewer. It stays with all revisions to the i
- SSER writeup and serves as a routing and review record. It will be filed in the j work pac,kage when the writeup is published.
Draft Number Draft 1 2 3 4 l 5
- Author ( h$ CM%~ -
Cr PI /%
Group Leader / ###W/G" %. ##e-/,
Tech. Editor Wessman/Vietti /
/ ~4 ef/4 ,// /
J. Gagliardo /. . # #/4J T. Ippolito / // ' _
r Revi ion Number Final
/ 2 3 4 l 5
. Author I Tech. Editor ,
Grouc Leader / /
' J. Gagliardo 4 /0/ 3 / # #/Te
- T. Ippolito '
/ /
, iM bY6 f Administrative i [
Writeup integrated into SSER .'439 l{F'
, l-J Potential Violations to Region IV Workpackage File Complete i
gl' 3 f//Y 3
Workpackage Returned to Group Leader 1
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Document flame:
AQ-77, 79 & 138 II J Requestor's ID:
. DEEQB01 Author's Name:
pf 3/15 Document Comments:
sser i
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- j. AQ-77 i AQ-79
! AQ-138 CP9 i Rev. 1 SSER Format /CP2 l
SSER
- 1. Allegation Group: QA/QC, Category 58
- 2. Allegation Number: AQ-77, AQ-79 and AQ-138.
- 3. Characterization: It is alleged that the onsite structural fabrication and hanger shop (iron fab shop) made component parts, such as eyebolts (I-bolts) (as replacements) for parts that were lost after receipt f/ [ #en 60 /f4Eb
. shop without any fabrication instruc'tions 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 t
the paperwork, (2) the paperwork was illegal.because it was post-dated, j nonsafety-related material was mixed with safety-related material,
! (3)hsupervisor (4) directed personnel not to mark indeterminate
- material b 1 ~; % as scrap, (5) during consolidation of the ;
electrical and iron fab shops, safety-related materials were mixed from both areas, (6) electrical fab personnel sed undocume ted aterial,
[
(7)ASMEQCpersonnelintheironfabshopd'idMtc.eck ricated threads, (8) undocumented weld repairs were made on base metals, j (9) threaded rod was cut.in the iron fab shop without a QC check to verify the heat numbers before cutting, (10) arc gouging (cutting) on stainless steel was done too close to the cut line to rinimize grinding time (11) beam clips may have been cracked during the fabrication process s j and (12) a device (stainless steel hook and chain) was fabricated est-of>
without regard to ocedure.( P- 3 ', g{ ,
y .
s
- 4. Assessment of Safety Sionificance:
um The implied safety significance of the allegations, is that if true, the g failure to comply with fabrication / installation and inspection
. procedures may have resulted in the installation of incorrect, defective,
' or non traceable' material or items, thus rendering systems operability 7
ality indeterminate.
- A0 79 - The TRT review ofgis allegation found that the processes utilized for Beer & P.: chb &R) shop fabrication and QC inspection of componentpartswereaddressedbysiteconstructionproceduresCP-CP(
9.10,fgbrication of ASME g lated gmponents and cgmponent p pports, and theQCinspectionwascontrolledbyprocedureQI-QAP-11.1-28gabrication
-installation inspection of safety class c,omponent supports.
a The TRT interviewed fabrication shop personnel and observed fabrication work in process. When vendor-supplied item 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. ik$hd Nchtfon acti+44y was controlled by procedure
- r. -
CP-CP0-9jl3, modification of vender-s_upplied catalog j_tems. TRT examined the following quality controlled work packages from the iron fabrication shop and found that the work was performed and inspected in compliance with the applicable procedure. .
i Sway Strut / Eye Rod H-CS-2-SB-083-002-2 Hanger CS-2-327-406-556R
- Rear Bracket VD-2-013-437-S36R l Sway Strut CS-2-SB-079-005-2 L Hanger MS-2-RB-040-004-2 Vortex Breaker Cage MW84-6811-8902 i -
t I
l L
i .
i f -
This list of work packages included both safety-related and I nonsafety-related assemblies. Since both safety and nonsafety-related work was-conducted concurrently at the iron fab shop, close examination
. of the operation travelers and the hanger packages was required to distinguish between them. The TRT also reviewed the processes utilized in cutting, grinding, fitting, and assemblin'g components o'nsite. This review revealed that current shop practices are in compliance with the applicable procedures, and that material acceptability and traceability were documented as required by those procedures.
The TRT discussed the B&R fabrication of I-Bolts with the supervisor and foremen in the iron fabrication shop. Those personnel stated that the shop fabricated the.I-Bolts as replacements for vendor supplied items that! were missing.or lost after receipt on site. The I-Bolts were used.
l - for rigging and hoisting vendor components. These I-Bolts.were not part
! of the quality controlled package; that is, they were not subject to the I
same rigorous standards as permanent hanger and strut components.
Further, TRT interviews with field installation personnel indicated that i ' the I-bolts were load tested and inspected prior to use to assure that appurtenances of safety-related components were not overstressed during hoisting and rigging activities. The TRT did not find any examples of *
- undocumented fabrication of I-Bolts used for permanent plant' installation.
A0 To assets tne allegation that safety-related parts were made in the f ron fabrication shop without any fabrication instructions or the required QC inspections; the TRT interviewed the shop supervisor and shop l
craft personnel, reviewed the applicable procedures, and observed shop
- . fabrication work in process. It was found that this shop fabrication
- work was controlled by procedure CP-CPM-9.10 fabrication of ASME-related n J ' of =
component gupports and CP-CPM-9.13, pdification vendor- supplied c_atalog l items. The QC inspections, applicable to this activity, were required by l QI-QAP-11.1-28 .~
fabrication and~ installation inspection of safety class ~
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. c_omponer.t . supports . TheTRTnotedthatprocedureCP-CPh.10,Rev.11 j Section ?,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 pflgpd . describ_edontheMI4andye'ifiedbyQCasrequiredby2.1.1.
being assembled into a support, the
.# [ V , p wever, when the shall parts .
Hanger Package be intact unless the MIL must be remove'd to fabricate another part.
[i The TRT found that the parts referred to in the allegation were N additional parts needed g replacements for parts which (for some unspecified reason) were not us able at the time when the support was in the process of being installed. The fabrication shop requirement consisted of selection of the correct material and cutting the material to the requested dimension. Although the shop fabrication may have been accomplished without documented instructionsgand the shop QC inspe: tion may na have been performeh, the acceptability for usey and the material traceabilitywasdocumentedybyQCinspectiongatinstallationKonthe hangerinspectionreport[QI-QAP-11.1-28gttach.2hTheTRT I, assessment of allegation AQ-138 in this SSEii also addresses the lack p /
required documentation (instructions) at the time that work is peiformed '
in the iron fabrication shop.
Although the allegation specified no particular parts, the TRT reviewed work packages foi a hanger (MS-2-RS-040-004-2), sway strut (CS-2-SB-079-00d-2),andvortex.breakercage(MX84-6811-8902). The TRT identified the processes used in cutting material for hangers as mechanical sawing, grinding, and thermal cutting. The TRT found that traceability documentation was properly transferred to each piece cut and that QC inspector verification was recorded on the appropriate document.
M The TRT found that current shop practices are a4ee in compliance with the procedures reviewed.
9 4
- w s. e asme e -. w.w e o =- e .am-r m.- .-
j- e The TRT interviewed representatives from Texas Utilities Electric Company j (TUEC) concerning the allegation, but could identify no specific examples ofworkperformedastheresultoftelephoned, instructions. TUEC
- personnel, acknowledged that the iron fabrication shop may have received l tel'ephone requests to fabricate 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 part, M I M also a D estated thattr ifceabili material a hanger h b installation reg [uired a repl the s tuial
, u,e . prsarAMtumr Wobus$n ac.
ident 4 #4 c a t4n-4eJe MIL The TRT reviewed the MILS on the shop work packages and determined t at their statements were correct.
AQ-138 To assess the allegation that iron fab shop personnel were asked to perform work without any knowledge of the paperwork (e.g.
drawings, travelers,and hanger packages) the TRT performed an unannounced audit of inQrocess J
fabrication activity in the iron fab shop.
r The TRT assessedtheavailabilityoftravelerpackagesandthefincluded documentation to determine if the information provided was in accordance with procedures and if craft personnel had thef' required information (documentation) to perform the assigned task, t
The TRT audited eio ,
raveler 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., F snubber-spring hanger). The TRT reviewed procedures for fabrication / installation, inspection, material traceability, and receipt and storage, all of which are applicable to activities performed in the iron fab shop. The TRT found that the audited hanger packages and operation travelers contained the documentation (e.g. drawings and MILS) required by the applicable procedure and were current for the status of 4 the work in process.
E .
The TRT noted that procedure CP-CPIEh .10, far? h ien ~ = M N
_re..... wer ects.section 2.1.4 allows the shop fabrication of parts for a support without a drawing or hanger package provided h the parts Q are described on the "-" " ' ' 'i x . m - p MIL and verified by \
QC.
The TRT did not find any examples of shop fabricationg of safety related materialgin^ process .without the availability of the required documentation (hangerpackage(drawing)atthelocationwherethework was performed.
During discussions with the iron shop foremen and he assigned QC inspectors j jdieTRTfoundthattheshopforemen[assignedtoshop fabrication of non-nuclear safetyfe mi category II pipe supports ( g g CP-CP -9.9), miscellaneous steel (bCP-c and electrical supports
& C -1 o d not identify and were not familiar with the shop fabrication procedures which controlled the work performed under their supervisory responsibilities. Although the TRT did not find any examples -
guanew ar of unacceptable quality mmj dr (heqroced,W ures indicatesofs, r,1rnvir3me gegneed (or&ppcmjipUWg/
_ ,4os t procedure indoctrination and add 5 N aI training for 3 e foFe W "
$ s The TRT reviewed the documentati n furnished by the alleger which identified material requisitions 4as sp6cific examples for the allegation that iron fab M e shop personnel were asked to perform work without any knowledge of the paper work (e.g. centrolled drawing (, hanger package,[ravelle TRT interviewed the shop general foremh and the MR r*hl . -4 . '. q coordinator, reviewed the applicable proceduresg and the shop MR file. The TRT found telephone requests, memosg and sketches attached to the MRs. In further discussion with the foreman and coordinator, the TRT f ,gnd that the shop fabrication work was performed per the MR instead off he hanger package as required by procedure CP-CPM-9.9;Section 3.1j which states," fabrication shall be accomplished in accordancewiththehangerpackage"janFcontrolleddratingsper l
l
.--_..__.7
procedure CCP-21,Section 3.1.3 g which states ; "all work shall be accomplished in accordance with controlled drawings." rocedureEC{-19, exposed conduit / junctionc boxgharger fabrication and installationj doYs not c = =
contain a requirement for the availability of the hanger package or traveller at the location where fabrication is performed (however, the' TRT also found that parts were fabricated per the MR without the availability of the hanger package or traveller in the iron fabt "w shop. The TRT foun $[QCinspection(andmaterialtraceabilitywere recorded on the MR.
The TRT found that MRs issued in the iron fab shop (werenot properlypreparedinaccordancewithprocedureCP-CPM 31geceiptstorage '
i The MRs did not contain the and {sstS$se of items section 3.4.
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 applicable drawing, hanger package, or traveler. Considering these conditions the TRT agrees with the allegation that the ironhhop [ M s performed their work without the required paperwork 4mSf46#' /E9W44d 8f NI#0"M 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 traveler was written to document the fabrication process, thus the allegation. The TRT found that although sketches were used, the material issue, fabrication activity, material traceability, and QC inspection kumentedonanacccmpanyingMR. The MR traveled with the fabricated items to the installation location, where subsequent QC inspections documented'the acceptability of the item in the hanger padkage or on the operation traveler.
- . . w n m-oo n , s ,, ,,,..p. , e.. -_m_
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 6 . '% B&R Q rial control group, examined the bulk material and vendor-supplied supports storage areasto learn the standard onsite procedures and methods for segregating safety and nonsafety materials. The materials were identifiable and segregated as required.
ST N Bas n the satisfactory compliance with methods and procedures in those ares,TheTRT,accompaniedbyfabshpgersonnel,alsoexaminedtheiron fab shop material storage (laydown) areas e TRT found designated areas for the storage of safety related bulk materials. A sampling of
' the material revealed heat number markings, as required. The TRT found i.;..i , [. -t a pile'of what was obviously scrap material,nalthoughM'uym-separated,hs 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 safe ~ty and nonsafety material in the lay ard adjacent to the former electrical hanger shop. This condition ts- in noncompliancewithprocedureCP-CPMhl, Sections 3.3and3.5which requireg 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.
i- 3.5 Items which have been withdrawn from the warehouse and are not needed shall be transmitted to the warehouse by the " Material l Return to Warehouse" form (Attachment 3),
hehtoi In further assessmg this allegation, the TRT noted that procedure QI-QP-11.14-pSection3.1,requiresthat"TheQCinspectorshallperform random surveil ance over storage and control of materials in the Structural /
l j ingai lnWNca' Wg gxpras g) infjing;y rf 's/MR@l W -
- >Q
~
i _
4 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 de w at e evidence that the required random surveillances were performed, a condition in noncompliance with the proce-dure quoted.
It was alleged that a supervisor directed craft personnel not to mark indeterminate (non-traceable) material t e r $ 6 ... m . .J as scrap. The TRT did not find any procedural requiren,ent for identification marking or color coding of,_ scrap. ThATRT g iewed record documentation a,nd,found that the gat-:dM'e'ria'l wasqtraceable by
( ' h7)'
6 W o<.>W n.wjb
,4 7 It was alleged that during consolidation of the electrical and the iron fabM= shops, safety related ("Q") materials from both areas were
- mixed. In its assessment, the TRT observed that the storage area (laydown yard) tper.)e a common area for the storage of material for the fabricationofbothelectricalandcomponentsupports.g A m. '
FdIeTRTfoundthatB&RprocedureECP-19,Section1.1.,statesinpar Th
!N b "
Structural steel members are to be those obtained from the electrica fab shop or [from] designated "Q" rygeareas." The TRT noted that according to the procedure, there w no conflict in regard to the 3
location [fe ; the "Q" materials " Dred or obtained. ,. b
>NEg '
To assess the allegation concerning the use of undor rented material in
'f the electrical fabrication shop, the TRT b tricalsupport(
traveler packages and observed the shop fabrication work in^ process. The TRT also considered the assessment of this allegation during the @
verification of documentation for the assessment of other allegations O
w . ,. .+ -~ . . , ., e - - - , - . - . , -~.
.- ~ . .
i
, au9 reported in this SSER (e.g. material traceability x work performed without knowledge of the' paperwork).
The TRT found compliance with traceability requirements for heat number, unique number, and coating code number. The TRT also found that the QC l inspection process for verification and documentation assures the use of and documentation for traceable material. Although the alleger did not uv und identify a specific instance of undocumented material \ the IRT s that uudS the procedures as implemented4 prevent the use of undocuraented materials.
It was alleged that the ASME QC A n feb shop did not check threads on any job unless it was a prescrilla operaticn on a traveler that required QC inspection. To assess.this alletation, 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 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 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 threadspin conformance with design specifi-cation, to assure quality (e.g., size, pitch, length, and class of fit).
The TRT interviewed a B&R quality engineer assigned to ASME related construction activities who explained that B&R relied on an acceptable inspection during installation as the means to assure the quality and acceptability of the B&R fabricated threads "as defined in QI-QAP-11.1-28.
The Ta o reviewed a typical hanger inspection report and verified that they nspection requirement was defined. The TRT found that the threads fabricated in the iron fab shop were inspected in compliance with the requirementsoftheapplicableprocedures{atinstallation.
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) It was alleged that undocumented weld repairs were made on base metal
) (plate) which was damaged by flame cutting during the fabrication process.
i To assess the allegation, the TRT reviewed TUEC procedure QI-QP-16.0-5, XReporting of Base Metal Defects,Y and B&R procedure CP-CPMWelding 6.9fX and Related Processes,X thatcontrolkeallegedactivity. The TRT
~
interviewed the shop general foreman, foremen, QC inspectors, and welders, all of whom stated that it was standard shop practice to discard a damaged T 31 -
piece and cut a new piece as a replacement. The._n'ssnop personnel y .13,, W %
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 practice during its audit and shop walkdowns. The TRT found that procedures were implementedandthattheallegedrepairgiftheyoccurredwerenot j standard or common shop practice.
It was alleged that QC inspection verification of heat number was not done before'Sh3. threaded rod was cut into pieces. In its assessment of this allegation, the TRT found that BAR procedure CP-CPM-9.la Section 2.1.2, required that the transfer of traceability marking be verified by QCpriortocutting,exceptwheremarkingwasnotpossiblegsuchason
. 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 documentation, thread the rod, cut the required number of pieces, and mark the heat number on the ends of the cut pieces. Thef cut pieceM, and any remaining length of the threaded bulk rod, were then OC inspected. By comparing the number N[on the cd pieces.rzt 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-2-031-430-532A and found that the activity was done in compliance with use d procedures CP-CPM-9.10 and QI-QP-11.1-28, which are applicable to the t
pg WCD o!!!4di470 fabrication and inspection. The TRT that traceability was maintained.
[.- .
It was alleged that arc gauging (cutting) on stainless steel was done ascloseftothecutlin'e\aspossible)tominimizegrinding.
e B&R procedure CP-CPM-9.10, Section 3.3.5, states thatg " Stainless steel base plates may be thermally cut by are gouging. After the thermal cutting process, 1/8 2 inchofmaterialshallberemovedfrcmthethermally+cutedgesby t' T T N To assess the allegation, the TRT interviewed the iron fab shop foreman and TT ,
1% .recunMarx QC inspector who were responsible for theyf.Mr and inspection of ASME-related
. t/g&ssr7 , supports . The foreman stated that it was standard shop practice to layout stainless steel materials to an oversize cut dimension of I/8 inch minimum when the prescribed method of cutting was by are 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 Iyouts,hestatedwithconfi-
/
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 '
foremanthenstatedthatheperformedacheckofthetgvelerpackageand a visual check of the condition of the fabricated itemAassure its accept- /
ability before it was released for field installation. No arc gouging was n
.inyprocess during the TRT's assessment. Arc gouging and removal of the heat [affectedzoneadjacenttothecutisstandardindustrypractice.
[ The TRT could find no exampies 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-foot long stainless steel chain which was hot . formed and documented after it was built.
, - .
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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 2323-51-0525 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'(w'ith 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 met d;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 interviewed TUEC project engineers to determine the identification and application of the device described by the alleger. The device could not be identified by the TRT. The TRT interviewed the iron fab shop general foreman and learned that although the stainless steel chain was an odd or unusual. item, he could not remember its fabrication. The TRT also inter-viewed representatives from the material control group M the millwright department k /c b ##not tYk a exa[pYoftheallegeddevice.
fY
f:
[ .
- 5. Conclusion and Staff Positions: The TRT concludes:
A0-77
{ct,1M5ARQJ(_A11bli bf RE?LAGHElfiPAK.S $cXA 0 IW
-l ,
, ' 1 Onsite fabrication practices,were properly controlled by construction
~%.inspectionproceduresandinstructions. The TRT review did not identify J
g instances where the iron fab %. shop manufactured safety-related replacements without the ap riate procedures or without QC Ann uMannaLe qThnrurE YMMLEkkr/0N-ep,f inspection g Therefore, tne rinds that this allegation has neitrer b safety significance nor generic implications.
[. i
.. . 0-79 L _
my' - ^
' Based on a review of applicable documents, shop inspections, and interviews
.O with TUEC personnel, the TRT concludes that the allegation that the iron fabrication shop made parts in response to telephoned instructions rather than to written instructions cannot be traced to a sp'eAific event and, therefore, cannot be substantiated. For 4M-5 elleg i(DUO.renjsee AQ-138,)y Some nonsafety-related parts may have been fabricated based on telephoned instructions; however, safety-related parts were fabricated in compliance ,
with applicable procedures. -Current iron fab 18(Q shop practices also provide adequate assurance that material traceability was ma,intained in compliance with the applicable procedures. Accordingly,thisallegation
%,, has neither safety significance nor generic implications. I g*1
'W D q '
In a meeting with-the alleger on December 10,1984,jhgL , genNib
) EA Jul_D N '), l its findings and conclusions for AQ-77 and A0-79. T" ' 7 - ::e N# witi the m ' p - N s end -reclusicr- 'rd rc Mdit# W car.ccrn: or 31 u 7 t 4 n.,- .. .n ,- e <se nt4 ng, A0-138 The TRT assessed the allegations by a review of procedures and documenta-tion,anauditoffabworkin9rocess,witnessingthefabricationandPT
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. examination of a comparison sample, witnessing the fabrication of threaded 1 rods, and by a walkdown verification of 6:aterial laydown storage areas.
i The assessment also included interviews with B&R shop foremen and craft ~
_::we- personnel, QC inspectors, quality engineers, material control personnel, SM . and a TUEC instrumentation engineer.
~
~
{% .- The TRT substantiated the allegation (1) that iron fabrication shop 63 personnel were asked to perfom work without knowledge of perwork.
i , y. .. -41
\.
, n The TRT's assessments did not substantiate the allegations, ' safety and
% ' nonsafety materials were mixed j (4) identification marking on scrap material;(5) electrical shop safety related material was mixed with iron fabi An shop material (7)j ASME QC did not check threads in the iron fabMS shop (9) ASME QC did not verify heat number on threaded rod before cutting, and (11) beam clips were cracked in the fabrication process. .TheTRT'sassesmentwasunabletosubstantiatetheallegations,'d; (2) paperwork was illegalo t %was p,'st dated,(6) the electrical shop used undocumented materialj (8) undocumented weld' repairs were made on base metal j (10) arc gouging on stainless steel was too close to the cut line to minimize pme,and(12)astainlesssteelhookandchainwas fabricated at procedure."
j The TRT found procedur oncompliances, however, the documentatio~n j ,
examined /Ay the TRL.in the iron fabesh:sMen, shop g indicated that the i requiredQCinspectionswereperformedpandmaterialtraceabilitywas I
maintained and documented. The TRT therefore concludes that the allegations have neither safety significance nor generic implications.
l
(
- 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 &a crags;.ir c'tDHCm DD den %!5'c!v.No new concerns or allegaticns were c
identified.
(
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- 6. Actions Recuired: See item 8 of enclosure 1 with D.G. Eisenhut letter to M.D. Spence dated January 8,1985.
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- 8. Attachments: flone .
- 9. Reference Documents:
- 1. CP-0AP-11.1, " Fabrication and Installation Inspection of Components, Ccmponent Supports and Piping."
- 2. CP-CPM-9.10, Rev. II, " Fabrication of ASME Related Components Supports."
- 3. CP-CPM-9.9, Rev 8, "tmS-Seismic Category II Support."
- 4. CP-CFM-9.13, Rev. 10,.Medification of Vendor-Supplied Catalcg items." .
- 5. TUGC0 letter TXX-4180 dated May 25, 1984
- 6. AQ-138: TRT interview with alleger A-59, September 13, 1984 7, F3AR Figure 9.5-52, sheets 1 and 2.
i
- 8. B&R ECP-19, " Exposed Conduit /Junct cn Eox and Hanger Fabrication and Installation."
- 9. B&R CCP-21, " Fabrication of Miscellaneous ! teel."
- 10. B&R CI-CPM-8.1, " Color Coding of Fiping Materials."
11, G&R CT-CFM-6.9C, " Material Identificaticn."
- 12. B3R CP-CAP-14.1, " Inspection of Storage and Maintenance of Permanent F3 ant Equipment."
- 13. SSR CP-CAF-8.1,." Receiving Inspection."
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l.
- 14. .B&R QI-QAP-11.1-28, " Fabrication and Installation Inspection of l- Safety Cl Component Supports."
- 15. B&R CP-C M-6. D) Welding and Related Processes. , ,k ,,-
- 16. B&R MCP-1 , Storage and Storage Maintenance of Mechanical and "
Electrical'Iquipment."
- 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:
! J. Malonson, Date I
Technical Reviewer i
M. Bullock, Date j Technical Reviewer i
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H. Livermore, Date Group Leader Approved by: .
V. Noonan, Date Project Director t
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Polusny, CPTF Document Ccements:
1/15/85 Comanche Peak Allegations - Pls return w/ revisions
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". , ' - SEER WRITEUP DOCUMEtiT C0lTROL/ ROUTE SHEET
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Author: /.), v 4J , _! ./ ,,,,R This sheet will be initialed by each reviewer. It stays with all revisions to the SSER writeup and serves as a routing and review reccrd. It will be filed in the work package when the writeup is published. ], ,, 3 , .. . f j j-
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10/11/84 CP2 SSER AQ-54/AQ-65 Revision 4 SSER
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- 1. Allegation Category: QA/QC 5.C, Housekeeping
- 2. Allegation Number: AQ-54, AQ-65 4
- 3. Characterization: It is alleged that: (1) cleaning procedures for and cleanliness of components and areas were not maintained during construction of the plant, (2) a worker assigned the task of cleaning was instructed to find out what three areas QC inspectors were going to check, clean those areas, and forget the rest.
- 4. Assessment of Safety Significance: The implied safety significance of these allegations is that if proper cleanliness of piping and equipment was not maintained, the quality of safety-related systems could be questioned.
Cleanliness standards at Comanche Peak are detailed in FSAR, Table 1.(A)N " Discussion of Regulatory Guides." These standards are based on Regulatory Guides (RGs) 1.37 and 1.39, which in turn cite ANSI standards N45.2.1 and N45.2.3 as acceptable methods of implementing cleanliness controls.
The NRC Technical Review Team (TRT) reviewed 15 of the procedures by which the ANSI requirements are implemented. After this background review, the TRT examined 125 plant surveillance inspection reports (irs) for 1981 and 1982, 16 of which cited unsatisfactory conditions which were subsequently l
corrected. In ad'dition, the TRT reviewed 50 plant surveillance irs for January through June 1984, among which were three reports noting unsatis-
[ factory conditions taat were later corrected. The TRT also reviewed all f plant surveillance reports for January and February, 1979, and found that, although the inspectors found a large percentage of deficiencies, all unsatisfactory conditions were signed by QC as having been corrected.
1, e
The TRT observed that the B&R QC inspectors performing plant surveillance were scheduled to rotate throughout various areas of the plant on a weekly basis, thus minimizing the possibility that craft personnel would know in advance the QC inspector assigned to their area.
The TRT reviewed cleanliness control proceduras and records for adequacy.
The TUEC and Brown & Root (B&R) procedures requibd a final rinse with grade A water, followed by a " Swipe Test" (for determination of chloride and fluoride concentrations) "just prior to installation of insulation" to assure that cleaned surfaces were not recontaminated before insulation was installed. The TRT discu:: sed procedure implementation with TUEC QC labora-tory inspection personnel. The.TRT learned that QC inspectors take swipe samples on a random basis, after written notification that a specific com-ponent or section of pipe has been cleaned and is ready for inspection.
The QC personnel sample hard-to-reach areas, where cleaning may have been inadequate, in addition to easily accessible areas. Like the B&R inspectors, the.TUEC laboratory inspectors were rotated throughout.the plant, so that craft people did not know in advance which inspector would be assigned to
- their area. The swipe samples are analyzed in the TUEC QC laboratory, and the~results are transmitted to the field. QC verification of acceptable swipe tests ~is one of the inspection criteria that must be satisfied just prior to insulation installation. All swipe test laboratory reports are then stored.in the permanent plant records vault. ;
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The TRT reviewed 100 swipe test reports from 1979 and 100 swipe test reports from 1984. For 1979, 31 reported that chloride or floride exceeded specifications. The 1984 reports contained two items exceeding specifications. In all cases, the items involved ware cleaned and retestec j with acceptable results. The TRT observed flush plans (FP2-11-01 and
< FP2-33-01) in use. The TRT also rev'ewed startt.p and turnover surveillance reports DSR-82-017, DSR-83-053, DSR-33-052 and DSR-83-044 for completeness and close-out of deficient items and found that these items were properly closed. The TRT reviewed eight completed flush plans to verify the
. cleaning of various primary crolant system components and found that the components were properly flushed.
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i The TRT reviewed a draft of flush procedure FP-55-08, dated August 6,1984, that was in the initial stages of preparation. The purpose of this proce-dure was to verify cleanliness of Unit I reactor coolant loops, including the reactor vessel (RV), by means of handwiping, visual inspection, and swipe testing. Those tests to determine surface chloride and fluoride contamination were performed by TUEC systems test engineers and Westing-house representatives. The TRT noted, however, that FP-55-08 required only two swipe tests of the RV (one on the side and one on the bottom). This matter will be reviewed further.
The TRT inspected implementation of cleanliness controls by performing inspections of Safeguards Building Unit 2, Diesel Generator Building Unit 2, and the Containment Building for Unit 1. The inspection was con-ducted to verify the implementation of housekeeping and cleanliness con-trols, during which the following conditions were found.
- 1. HOUSEKEEPING .
- a. Work areas were sufficiently clean and orderly,
- b. Garbage, trash, scrap, litter and other excess materials had been removed or temporarily stored neatly.
- c. Areas of' activity were adequately lighted, ventilated, protected, and accessible as appropriate for the work being performed, consistent with the quality requirements.
- 2. CONTAMINATION OF STAINLESS STEEL
- a. Slings handling stainless steel w?re made from nylon, stainless steel, or had adequate protection, such as being covered with rubber or wood to prevent contact with carbon steel slings.
J
. . . . . - . . - . . . . - _ . . . , . . , _ . ~ . - -
o 4
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- b. Tools (e.g. wire brushes, files, flapper wheels, and drills) used on stainless steel materials were designated by a fluorescent orange color code.
- 3. MATERIAL / EQUIPMENT STORAGE
- a. Material and equipment were checked for evidence of damage or deterioration.
- b. For pipe spools, Stainless steel pipe ends were capped with plastic caps or wood covers and plugs
- Carbon steel pipe ends were capped with plastic / metal caps or. wood covers and plugs
- Pipes were stored off the ground in racks or on dunnage.
- c. Weld rods were field-stored in plugged-in ovens.
- d. Motors were stored with ventilation holes covered with fine screening to ensure that motor internals were free from debris and rodent infestation.
- e. Space heaters were energized, if provided on motors and motor-operated valves.
1
- 4. INSTALLED ITEMS:
i i
- a. Cables and Cable Trays a (1) Cables were covered with fire-resistant materials any time welding, grinding, or torch cutting was being perfornied in j an area that could damage cable.
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1 (2). Items such as r.uts, bolts, structural steel, pipe fittings, etc., had not been stored or left in cable trays.
(3) Metal gratings were installed over cable trays to prevent trash from falling or accumulating in the trays.
(4) Flex conduit to. equipment was not broken, damaged, or used to support any weight.
(5) Trays containing cables were not used as walkways.
(6) Trays were not used as work platforms.
EXCEPTIONS: When standard work platforms were not feasible, the following procedures applied:
- 1. A 1/2-inch or thicker piece of plywood extending across the top of the cable tray from siderail to siderail and stabilized so it could not be accidently dislodged was used as a temporary work platform.
NOTE: This exception was not used when additional
- siderails were added to extend the depth of the cable I tray.
I
- 2. Alternatively, a three-fold fire blanket covered with an approved electrical rubber blanket was used when workers leaned over or into a cable tray but not for the purpose of supporting their full body weight (i.e., standing, kneeling,etc.).
(7) Cable trays were not used as structural supports, or to li ft from.
- . ~ . . _ _ _ , . .. .. _- _
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-(8) Hoses and cables were not laid across the trays.
, (9) Doors and covers to electrical equipment were in place when no work was being performed on the item.
- b. Mechanical
- (1) In rooms 67, 72, and 74 of the Unit 2 Safeguards Building the TRT observed that not all snubbers were wrapped with
. protective covering when welding was being done in close proximity to them. This was a violation of B&R procedure CP-CPM-14.1, which required protection of. installed equip-ment during welding. This condition was immediately cor-rected when the TRT reported it to TUEC quality assurance management, and an inspection was performed by TUEC to correct similar conditions in other areas as well.
(2) Open ends of components were covered unless work was being performed on them.
I (3) Installed pipe, especially pipe connected to valves and
. equipment, was properly supported (by permanent or l
temporary supports).
(4) No rigging was off supports (unless authorized by engineering in writing on a traveller, etc.').
- c. Instrumentation
{ Protective coverings were installed and maintained whenever work j was done,around indicators, gauges, tubing, etc.
l- 5. Conclusion and Staff Positions: Based on its review of inspection reports i- for 1981, 1982, and January through June 1984, and on facility inspections, 4
i
t
, the TRT concludes that the allegations relating to inadequate cleanliness t.
controls during the early stages of construction can be substantiated.
i TUEC QA found a substantial number of cleanliness procedure violations fi when it began plant surveillance inspections in 1981. Review of current inspection reports indicates that occasional infractions do occur, but the
'QA program for detection and correction of plant cleanliness problems appears to be effective. The cleaning / flushing / cleanliness verification procedures of nuclear systems provide for effective removal of any dirt, debris, and litter that may have inadvertently been introduced into nuclear systems, including the reactor vessel.
Because extensive preinstallation/preoperational cleaning, flushing and cleanliness verification have been accomplished, the TRT concludes that this allegation has no safety significance.
Except for the gap between the reactor vessel and the biological shield wall (cited in the NRC letter to TUEC, November 29, 1984) the TRT concludes that the cleanliness controls implemented since 1981 indicate that manage-ment recognized the problem and implemented procedures to correct it.
Thus, this allegation has no generic implications. The allegation of improper guidance by a supervisor could not be substantiated.
The results of this assessment were not presented to the alleger. On October 29, 1984, the alleger's parents informed the TRT that the alleger declined any further contact with the TRT.
- 6. Actions Required:
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welding, torch cutting, sandblasting, and other damaging or contami-nating operations, while such oper.tions are in process. The TRT recommends that a QC hold point be added to operations travelers to verify that installed equipment is adequately protected prior to the start of such work.
- 3. Revise Procedure CP-QP-19.5 to include surveillance inspection of permanently installed snubbers for adequate protection. ,
- 8. Attachments: None.
- 9. Reference Occuments:
- 1. Flush plans FP-55-01, GP-55-02, FP-55-03, FP-55-04, FP-55-05A, FP-55-05B, FP-55-05C, FP-55-06, FP-55-03, FP-2-11-01,. FP-2-31-01.
- 2. Startup/ turnover surveillance reports DSR-83-053, DSR-32-017, DSR-S3-052, DSR-33-044.
- 3. Plan; Surveillance insoection Reports PSI 0001-PSI CO20.
- 4. Plant Surveillance Reports PS C0001-PS 00030, PS 00300-PS C0375, PS OCS50-PS 00900.
i . .-
i 5. Swipe test laboratory reports, numbers J-1 thru J-99 dated 3/26/79 through.11/15/79.
i
! 6. Swipe test laboratory reports, numbers J-600 through J-699, dated 2/28/84 through 4/27/84.
- 7.84-006 3/17/84 A-4 Testimony, pp. 18,19,24,25,29,39.
i
- 8. GAP 2.206 Petition 3/19/84 #26.
- 9. B&R CP-CPM-6.9, " General Piping Procedure."
- 10. B&R CI-CPM-6.9E-2, " Maintaining System Cleanliness During Weld Repairs."
- 11. B&R CP-CPM-6.9H (Appendix H), " Cleanliness Control."
- 12. B&R CP-CPM-9.2, " Control of Chemical Substances."
- 13. B&R CP-CPM-6.12 " Installation, Rework & Modification of Reflective Insulation."
- 14. B&R CP-CPM-10.2, " Cleaning and Insulating Stainless Steel Pipe and Equipment."
-15. B&R CP-QP-19.5, " Surveillance of Plant Conditions"
- 16. ,TUGC0 MEI-8, "NSSS Cleanliness During Coolant Loop
. Installation."
, 17. TUGC0 CP-SAP-24, " System Cleanliness Requirements and Control" i 18. TUGC0 XCP-ME-4, " System Cleanliness Verification."
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- 19. B&R MCP-10, " Storage and Storage Maintenance of Mechanical and.
l.
- Electrical Equipment."
,' 20. TUGC0 QI-QP-11.1-65, " Determination of Contamination'of Flourides and Chlorides on Stainless Steel."
P
- 21. TUGC0 QI-QAP-11.1-40, "Insu7ation-Installation' Inspection."
- 22. .TUGC0 QI-QAP-11.1-65, " Determination of Surface Contamination of-Chlorides and Flourides on Stainless Steel."
l I 23. B&R CP-CPM-14.1, " Guidelines for the Protection of Permanent Plant Equipment."
- 24. A-7 testimony.(AQ-54)84-006 March 7, 1984 pages 19, 24, 25, 29, & 39.
I
- 25. A-7 testimony (AQ-65)84-006 March 6, 1984 page 18.
- 26. GAP 2.206 Petition March 19, 1984.
'l j 27. NRC letter to TUEC' dated November 29,_1984 (Comanche Peak Review).
l
- 10. This statement prepared by:
R. Hedderick, TRT Date Technical Reviewer Reviewed by:
H. Livermore Date Group Leader j Approved by:
V. Noonan Date Project Director i
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M Q 65 I R: questor's ID:
JANICE :
Author's Name: ,
.Pol usny, CPTF Document Comments:
3/15/85 - Redraft /Please return this sheet w/any revisions f
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10/11/84 CP2 SSER AQ-54/AQ-65 Revision 4 :
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'* SSER
- 1. Allegation Category: QA/QC 5.C, Housekeeping -
-2. Allegation Number: AQ-54, AQ-65
- 3. Characterization: It is alleged that: (1) cleaning procedures for and cleanliness of components and areas were not maintained during construction of the plant, (AQ-54), (2) a worker assigned the task of cleaning was instructed to find out what three areas QC inspectors were going to check, clean those areas, and forget the rest (AQ-65).
?
- 4. Assessment of Safety Significance: Cleanliness standards at Comanche Peak are detailed in FSAR, Table 1.(A)N " Discussion of Regulatory Guides."
These standards are based on Regulatory Guides (RGs) 1.37 and 1.39, which in turn cite ANSI standards N45.2.1 and N45.2.3 as acceptable methods of implementing cleanliness controls. 's The NRC Technical Review Team (TRT) reviewed 15 of the Brown & Root ( &R)l 4td2 Texas Utilities Generating Company (TVEC/TUGCO) procedures by which t ___, -
ANSI requirements are implemented. After this background review, the TRT examined 125 plant surveillance inspection reports (irs) for 1981 and 1982, 16 of which cited unsatisfactory conditions which were subsequently corrected. In addition, the TRT reviewed 50 plant surveillance irs for January through June 1984, among which were three reports noting unsatis-factory conditions that were later corrected. The TRT also reviewed all plant surveillance reports for January and February,1979, to assess the implementation of cleanliness controls during earlier phases of construc-tion. The TRT noted that the QC Inspectors reported deficiencies which were subsequently documented as having been corrected. in interviews with
' B&R QC Inspectors and Inspection supervisors, the TRT found that the B&R QC inspectors performing plant surveillance were scheduled to rotate through-out various areas of the plant on a weekly basis, thus minimizing the
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. possibility that craft personnel would know in advance the QC inspector assigned to their area. The TRT reviewed cleanliness control procedures and records for the adequacy of the implementation of the ANSI requirements and the performance of the QC inspections required by those procedures.
~
The TUEC and E d i' B procedures required a final ' rinse with grade A water, followed by a " Swipe Test" (for determination of chloride and fluoride concentrations) "just prior to' installation of insulation" to assure that cleaned surfaces were not recontaminated before insulation was installed. (A swipe test consists of wiping the cleaned area with a spect-fied absorbent material which is , subsequently analyzed to determine the amount (if any) of specified contaminants remaining on or in the previourly cleaned area). The TRT discussed procedure implementation with TUEC QC laboratory inspection personnel and found that the TUEC lab inspectors take swipe samples on a random basis, after written notification that a specific component o. section of pipe has been cleaned and is ready 'for inspection.
These lab inspectors also sample hard-to-reach areas, where cleaning may have been inadequate, in addition to easily accessible areas. Like the B&R inspectors, the TUEC laboratory inspectors were rotated throughout the plant, so that craft people did not know in advance which inspector would be assigned to their area. The swipe samples are analyzed in the TUEC QC .
laboratory, and the results are transmitted to the field. QC verification f of acceptable swipe tests is one of the inspection criteria that must be l
satisfied just prior to insulation installation. All swipe test laboratory reports are then stored in the permanent plant records vault.
The TRT reviewed 100 swipe test reports from 1979 and 100 swipe test reports from 1984. For 1979, 31 reported that chloride or floride exceeded specifications. The 1984 reports contained two items exceeding j specifications. In all cases, the items involved were cleaned and retested with acceptable results. The TRT observed flush plans (FP2-11-01 and FP2-31-01) in use. The TRT also reviewed startup and turnover surveillance i
reports DSR-82-017, DSR-83-058, DSR-83-052 and DSR-83-044 for comoleteness and close-out of deficient items and found that these items were properly I
l
i y .
closed. The TRT reviewed eight completed flush plans (essentially the f . .
! procedures) to verify the cleaning of various primary coolant system components and found that the components were properly flushed.
The TRT reviewed a draft of flush procedure FP-55-08, dated August 6,1984, that was in the initial stages of preparation. The purpose'of this proce-dure was to verify cleanliness of Unit I reactor coolant ' loops, including the reactor vessel (RV), by means of handwiping, visual inspection, and i swipe testing. Those tests to determine surface chloride and' fluoride contamination were performed by TUEC systems test engineers and Westing-house representatives. The TRT noted, however, that FP-55-08 required only two swipe tests of the RV (one on the side and one on the bottom). Although i th,e procedure was still in draft the TRT expressed its concern in regard tit)e adequacy of only two swipe tests to verify the cleanliness of an I
item of the size of the reactor vessel.
The TRT inspected implementation of cleanliness controls by performing inspections of Sa.feguards Building Unit 2, Diesel Generator Building Unit 2, and the Containment Building for Unit 1. The inspection was con-l ducted to verify the implementation of housekeeping and cleanliness con-trols, during which the following conditions were found. .
t
- 1. HOUSEKEEPING j,
- a. Work areas were sufficiently clean and orderly.
- b. Garbage, trash, scrap, litter and other excess materials had been removed or temporarily stored neatly.
- c. Areas of activity were adequately lighted, ventilated, 1
protected, and accessible as appropriate for the work being U performed, consistent with the quality requirements.
4 I
. - - . . ~..-. - ...._. . ,_ m .- - . _ _ . . . _ .. . . . _ . , ,
... 2. CONTAMINATION OF STAINLESS STEEL l a. Slings handling stainless steel were made from nylon, stainless l- ' steel, or had adequate protection, such as being covered with l
rubber or wood to prevent contact with carbon steel slings.
1 ,
- b. Tools (e.g. wire brushes, files, flapper wheels, and drills)
- used on stainless steel materials were designated by a i
fluorescent orange color code.
l'
- 3. MATERIAL / EQUIPMENT STORAGE
- a. Material and equipment were checked for evidence of damage or deterioration.
- b. . Pipe spools, both carbon and stainless steel were protected by the use of plastic metal caps and/or wood covers and plugs
~
appropriate to the material type (carbon or stainless). The ,
pipes were stored off the ground in racks or on dunnage. .
- c. Weld rods were field-stored in plugged-in ovens. ,
I d. Motors were stored with ventilation holes covered with fine
! screening to ensure that motor internals were free from debris and rodent infestation.
- e. Space heaters were energized, if provided on motors and i
motor-operated valves.
> 4. INSTALLED ITEMS:
).
)
- a. Cables and ble rays 1
,- _, -. -,.,%. . . . - , -f ~ _ . . , ; .
t (1) Cables were covered with fire-resistant materials any time welding, grinding, or torch cutting was being performed in an area that could damage cable.
(2) Items such as nuts, bolts, structural steel, pipe fittings, etc., had not been stored or left in cable trays. ,
(3) Metal gratings were installed over cable trays to prevent trash from falling or accumulating in the trays. .
(4) Flex conduit to equipment was not broken, damaged, or used to support any weight.
(5) Trays containing cables were not used as walkways.
(6) Trays were not used as work plat' forms. -
EXCEPTIONS: When standard work platforms were not feasible, the following procedures applied:
- 1. A 1/2-inch or thicker piece of plywood extending across the top of the cable tray from siderail to siderkilandstabilizedsoitcouldnotbeaccidently dislo'dged was used as a temporary work platform.
NOTE: This exception was not used when additional siderails were added to extend the depth of the cable tray.
- 2. Alternatively, a three-fold fire blanket. covered with an approved electrical rubber blanket was used when workers leaned over or into a cable tray but not for the purpose of supporting their full body weight
~
(i.e., standing, kneeling,'etc.).
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.. (7) Cable trays were not used as structural supports, or to lift from.
(8) Hoses and cables were not laid across the trays.
(9) Doors and covers to electrical equipment were in' place when no work was being performed on the item. -
- b. Mechanical (1) In the Safeguards Building, Unit 2, Rooms 67, 72 and 74, ,
the TRT observed that not all snubbers were wrapped with protective' covering when welding was being done in close proximity to them. This was a violation of B&R procedure CP-CPM-14.1, which required protection of installed equip-ment during welding. This condition was immediately cor-rected when the TRT reported it to TUEC quality assurance ma,nagement, and an inspection was performed by TUEC to correct similar conditions in other areas as well.
(2) Open ends of ccmponents were covered unless work was being ,
performed on them.
(3) Installed pipe, especially pipe connected to valves and equipm'ent, was properly supported (by permanent or temporary supports).
(4) No rigging was off supports (unless authorized by engineering in writing on a traveller, etc.).
- c. Instrumentation Protective coverings were installed and maintained whenever work was done around indicators, gauges, tubing, et'c.
(A&ff The TRT did not find any evidence to support the allegation of improper
- I guidance by a supervisor. Although the reported conversation between the worker and the superygr may have ocurred, (as stated in Mc fr,lV4AU g/T#(t M77/7///
/ allegerb)p the TRT found in its assessment of a related allegation Q-[4)thathousekeepingandcleanlinessprocedureswereimple-mented. , g g c- ge g'
~ ~
4 y,appfqtM &
- 5. Conclusion and Staff positions: Based on its review efginspection r.eports for 1981, 1982, and January through June 1984, and on facility inspections, the TRT concludes that the allegations relating to inadequate cleanliness controls during the early stages of construction can be substantiated.
Because extensive preinstallation/preoperational cleaning, flushing and cleanliness verification have been accomplished, the TRT concludes that n
this allegation (AQK-54) has no safety signiff.cance. Except for the gap between the reactor vessel and the biological shield wall (cited in the NRC letter to TUEC, November 29,1984) the TRT concludes that the clean-liness controls implemented since 1981 indicate'that management recognized the problem and implemented procedures to correct it. Thus, this.allega-
- tion (AQX-54) has no generic implications. The_a N at kn n' yner '
gWanen-4 a supr"i s- )
The results of this assessment were not presented to the alleger. On October 29, 1984, the alleger's parents informed the TRT that the alleger declined any further contact with the TRT.
.The TRT was unable to substantiate the allegation that a worker was impro-perly instructed by.his supervisor in regard to cleanliness inspections n (AQ-65). Based on the assessment of a related allegation (AQX-54) the TRT concluded that there is no safety significance nor generic implications to the allegation AQ-65.
- 6. Actions Required: See Item Number 9 of the enclosure with D. G. Eisenhut letter to M. D. Spence dated January 8, 1985.
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- 9. Reference Documents:
- 1. Flush plans FP-55-01, GP-55-02, FP-55-03, .FP-55-04, FP-55-05A, FP-55-05B, FP-55-05C, FP-55-06, FP-55-08, FP-2-11-01, FP-2-31-01.
- 2. Startup/ turnover surveillance reports DSR-83-058, OSR-82-017, DSR-83-052, OSR-S3-044.
- 3. Plant Surveillance Inspection Reports, PSI 0001-PSI 0020.
- 4. Plant Surveillance Reports PS 0000l-PS 00030, PS 00300-PS 00375, PS 00S50-PS 00900.
- 5. Swipe test laboratory reports, numbers J-1 thru J-99 dated' 3/26/79 through 11/15/79.
- 6. Swipe test laboratory reports, numbers J-600 through J-699, dated 2/28/S4 through 4/27/S4.
i 7.84-006 3/17/S4 A-4 Testimony, pp. 18,19,24,25,29,39.
5 i .
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..- 8. GAP 2.206 Petition 3/19/84 #26.
- 9. 'B&R CP-CPM-6.9, " General Piping Procedure."
- 10. B&R CI-CPM-6.9E-2, " Maintaining System Cleanliness During Weld Repairs." -
- 11. B&R CP-CPM-6.9H (Appendix H), " Cleanliness Control."
- 12. B&R CP-CPM-9.2, " Control of Chemical Substances." '
- 13. B&R CP-CPM-6.12 " Installation, Rework & Modification of Reflective Insulation."
4
- 14. B&R CP-CPM-10.2, " Cleaning and Insulating Stainless Steel Pipe and Equipment."
- 15. B&R CP-QP-19.5, " Surveillance of Plant Conditions"
- 16. TUGC0 MEI-8, "NSSS Cleanliness During Coolant Loop Installation." *
- j. 17. TUGC0 CP-SAP-24, " System Cleanliness Requirements and Control"
- 18. TUGC0 XCP-ME-4, " System Cleanliness Verification."
- 19. B&R MCP-10, " Storage and Storage Maintenance of Mechanical and Electrical Equipment."
- 20. TUGC0 QI-QP-11.1-65, " Determination of Contamination of Flourides and Chlorides on Stainless Steel."
- 21. TUGC0 QI-QAP-11.1-40, " Insulation Installation Inspection."
a
. . - - - .. ,. . ~ - . - - - - - . . . - - - -~--~-
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l t 9 22. TUGC0 QI-QAP-11.1-65, " Determination of Surface Contamination of Chlorides and Flourides on Stainless Steel."
223. B&R CP-CPM-14.1, " Guidelines for the Protection of Permanent l_ Plant Equipment."
i . .
- 24. A-7 test:. mony (AQ-54)84-006 March 7,1984 pages 19,' 24, 25, 29, & 39.
i
- 25. A-7 testimony (AQ-65)84-006 March 6, 1984 page 18. -
_ 26. GAP 2.206 Petition March 19, 1984.
- 27. NRC letter to TUEC dated November 29, 1984 (Comanche Peak Review).
l 10. This statement prepared by:
Y D8DRT
~
! Date Technical Reviewer Reviewed.by:
i
, H. Livermore Date I
Group Leader Approved by:
V. Noonan Date Project Director L
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SEER WRITEUP DOCUMEt;T C0!? TROL / ROUTE SHEET */- 6
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n RT Group 6 fi-lR c' C A-T2.c- c d.v 5~f/ '
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Author: 7 r -~ 7. , /
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This sheet will be iniNaled by each revi wer. It stays with all revisions to the SSER'writeep and serves as a routing and eview record. It will be filed in the work package when the writeup is publisbd.
Draft tiumber Draft 1 2 { 3 4SI //. 4y , -
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Author bev-/ [L ( W/- beLw -
n W /- #s . ,7 Group leader V -f /- \ V/ s# /' #7- Ady' / -%3 Tech. Editor N N // ' Y \ / / ' ' "
Ru 7/jj Wessman/Vietti V /\ )/ / l J. Gaoliardo /\ / \ /\ /
T. 10001ito / \
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Revision fiumber Final 1 2 3 4 5 Author Tecn. Editor i Grouc Leader J. Gaoliardo '
T. Icoolito l .
l Admi nis t ra tiv e_ *
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f .#
I,'riteup intccrated into SSER /
Potential Violations to Region IV /
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SSER QA/QC Category 50 f SSER Ad!
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Allecation Catecory:
QA/QCp,NCRs F
- 2. Allecation Number: AQ-30, 31, 32, 34, 36, 37, 80, 85, 86, 87, 95, 96, 97, 106, 109, 114, 116, 120, and 124
- 3. Characterization: It is alleged that nonconformance reports (NCRs)-axa my.
Initiated, processed, controlled, and dispositioned improperly. Similar allegations related to specific NCRs for electrical work and protective wUA coatings e reported in Electrical and Instrumentation Category y Protective Coatings Category 58.
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4 Assessment of Safety Sionificance: The allegations in this category are general in nature and the implied significance is that nonconformances concerning safety-related systems, structures, and components may not have been adequately identified and dispositioned; thereby rendering the _
quality and function of those systems, structures, and components suspect.
In assessing these allegations, the NRC Technical Review Team (TRT) reviewed applicable procedures, NCRs, component modification cards (CMCs),
design change authorizations (DCAs), inspection reports (irs), and N-5 data reports. In addition, interviews were held with both Texas Utilities or Electric Co. (TUEC) and Brown & Root (B&R) personnel in engineering, QA, dwi QC, accounting, scheduling, and document controlglW3 gThe foll6 wing are the results of the TRT findings relative to each allegation, by number.
AQ-30 and AQ-31 alleged that interoffice memos (IMs) were being used to void NCRs and make other unauthorized changes. There were no specific examples identified.
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", Texas Utilities Generating Ccmpany (TUGCO) procedure CP-QP-16.0, "Non-conformances," and B&R procedure CP-QAP-16.1, "Centrol of Nonconforming Items," allcwed NCRs to be voided under specified conditions. In assessing these allegations, the TRT interviewed TUEC and B&R QC, engineering, QA staff, and document control personnel. The TRT also reviewed 154 NCRs, of which 64 had been voided. Three NCRs (82-0005, 82-0006, and M-12354) had been dispositioned by IM and one (M-83-02647) had been voided b IM, wiU w gh NCRs can also be voided by writing "VOIO" in the disposition block and adding the appropriate justification. !
All NCRs that had been dispositioned or voided by IM had the IM attached
.M to the NCR as supplementary information for disposition or voiding of the NCR. This practice was consistent with procedure CP-QP-16.0, which required that "any pertinent supporting documentation shall be attached to the NCR and referenced in the reason and ,iustification statements." Voided NCRs required and had the approval of the QE supervisor.
AQ-32 alleged that corrective actions were not being implemented; speci-i ally, that 35 NCRs identified in corrective action request (CAR) 5-41 M not be Ng. cleared, as of September 10, 1980.
The TRT reviewed CARS S-41 through 5-57. CAR S-41, related to hanger e.A NCRsg referenced 36 NCRs. All 36 NCRs had been cicsed, with closing dates ranging from May 14, 1980, to February 19, 1981; 19 of the 36 referenced NCRs had been closed by September 10, 1980.
Other CARS reviewed by the TRT indicated that the req ~uired corrective actions had been completed. For example, CAR S-48, relating to arc strikes, resulted in 419 welders being given reindoctrination for the pre-vention of arc strikes, plus additional equipment protectiot measures.
Welder attendance was verified by signed attendance sheets. This specific allegation was not substantiated; however, see allegatican AC-116, which examined implementation of the corrective action system.
_3_
AQ-34 alleged that NCRs were disapproved and destroyed, but no specific examples were identified. -
Thedisapproval(voidingjofNCRsbyuseofIMsisaddressedintheasess-ment of allegations AQ-30 and AQ-31, above. The destruction of NCRs was previously reviewed by the NRC in September and November of 1980. The results of that investigation, published in Region IV Inspection Report
'No. 50-445/80-22, indicated that at that time some NCRs were voided and these NCR numbers were then reassigned. The report also indicated that new procedure;, issued in August 1980, required voided NCRs to be for-warded to the records vault, and prohibited the reissuance of their NCR numbers.
The TRT initially reviewed 131 NCRs (dated between 1980 and 1984), of which 41 had been voided. The voided NCRs were available.in the records vault, except for six originated by TUEC, which were not available. Adai-tional interviews with the TUEC Open Records Vault Coordinator indicated that, at times, an NCR number was assigned, then subsequently was not used because the individual obtaining the number decided that an NCR was not required. The Open Records Vault Coordinator stated that the six missing NCRs had never been written. This approach is consistent with procedure CP-QP-16.0, which stated, "NCRs may be voided at any time if it is deter-mined that nonconforming conditions do not exist, the nonconformance was previously reported on another NCR, or other similar conditions exist."
Additional review disclosed that, of the six missing NCRs, one duplicated the subject of a preceding NCR, and two others duplicated the subjects of preceding inspection reports. The three other NCRs (No. E-81-00024, E-80-00143, and E.-80-00228) could not be located. The three missing NCRs occurred in approximately the las+ quarter of 1980, shortly after issuance of the revised NCR procedure. Subsequently, the TRT reviewed an additional 23 NCRs voided in the last quarter of 1983, and all were available in the vault. -
A TRT review of NCR procedures verified that B&R procedure CP-QAP-16.1 required voided NCRs to be transmitted to the records vault. TUGC0 pro-cedure CP-QP-16.0 stated that "The origin.1 voided NCR will be forwarded to the (PFG) NCR Coordinator," with no additional instructions to the NCR Coordinator for handling voided NCRs. The NCR log books list voided NCRs, i
and numbers were not reissued. These change: appear to have adequately corrected the process for handling voided NCRs; however, TUGC0 procedure CP-QP-16.0, Rev. 14, should have contained explicit instructions to the NCR Coordinator for handling voided NCRs.
AQ-36 alleged that DCAs were being used to " cover-up a condition for whien an NCR should be written," since the DCA does not receive QA/QC review, as does the NCR. No specific examples were identified. This allegation implied that the DCAs were not controlled cocuments and that they were used to facilitate repairs without an NCR being written.
TRT interviews with the TUEC Engineering Manager indicated that DCAs and CMCs were used by TUEC to change design documents (drawings, etc.). Draw-ings were originally prepared by Gibbs & Hill (G&H), the architect-engineer firm for Comanche Peak Stream Electric Station (CPSES)." The original
~
drawings were signed by a professional engineer and were not signed by OA/QC personnel. TUGC0 procedure CP-EP-4.6, " Field Design Change Centrol,"
Revisiun 10, stated that changes must be approved by the " original design-ers designated site representative." In April 1983, the G&H site representa-tive approval function was supplemented.by a G&H site design review team, as described in CP-EP-4.6 and CP-EP-4.7, " Control of Engineering / Design Review of Field Design Changes". This indicated to the TRT that the DCA l was certainly a controlled document.
Procedure CP-QP-16.0, "Nonconformances," Rev. 14, defined a nonconformance as "a deficiency in characteristic, documentation, or procedures, which renders the quality of an item unacceptable or indeterminate. Because this definition is so all-encompassing, it may have been difficult to determine when an NCR was required and when a CMC or DCA was adequate.
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Certainly, all CMCs or DCAs were not prepared as a result of an NCR. Also
" tracking NCRs" were frequently written, in which the NCR was ny used to describe a noncc,forminc cundition, as defined above, but was used to record removal of a part from equipment on a permanent equipment transfer (PET). The purpose of the NCR, in this case, was to ensure eventual re-placement of the removed parts. This usage, which does not appear to be consistent with the definition of nonconformance, should be clarified or discontinued.
Procedure OP-QP-16.0, Revision 14, was not entirely clear on nonconformance reporting. Specifically, Paragraph 2.1 stated, "I' is the responsibility of all site employees to report items of nonconformance to their supervisor or to the TUGC0 Site QA Supervisor," and paragraph 3.1.2 required using the NCR form for that reporting. However, paragraph 3.2.1 indicated that non-QA/QC personnel should transmit the NCR to the Paper Flow Group (PFG)
NCR Coordinator, who in turn would transmit the NCR to the " appropriate" QE, who was neither the individual's supervisor nor the Site QA Supervisor required by paragraph 2.1.
Additionally, the NCR form had no form number or'r vis'ioW date',~in~dicatinc that the form may not have been adequately controlled. The TRT identified two versions of the form, one having space for ANI review. This version apparently was not used and should be eliminated. The TRT also noted that the form had no space to identify the cause of the nonconformance and steps taken to prevent its recurrence, and that there was no provision for quc.1-ity assurance review, as described in allegation AQ-116.
DCAs and CMCs may be prepared as a result of NCRs and inspection reports, as described in the following assessment of AQ-37 and AQ-80, and the possi-bility for overlap exists. Following the previously noted procedural guidelines, the 90 CMCs and S2 DCAs reviewed by the TRT did not appear to have been written for itemt that should have been the subject of NCRs.
, Additional comments about NCR procedures are contained in QA/QC Category S.
AQ-135. I'(
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AQ-37 and AQ-80 alleged that deficiencies were reported on irs rather than on NCRs, without identifying specific examples. The reasons given were that: (1) irs could be "dispositioned by anyone," and (2) items reported on irs might not be reinspected. Also it was alleged that inspectors were under " pressure" not to write NCRs.
The procedures for irs are contained in B&R procedure CP-QAP-16.1, " Control of Nonconforming Items," and in TUGC0 procedure CP-QP-18.0, " Inspection Report;" The intended use of an IR was.to document conditions that did not conform to drawing requirements and that could be repaired using existing procedures. If a drawing change would resolve the condition, a DCA or CMC was issued. If engineering disposition was required or the deficient item required a hold tag, an NCR was issued. The TRT reviewed 63 irs that had originally been dispositioned as unsatisfactory. The irs did.not appear to have been written against items that should have been written as NCRs. In those cases where the IR required engineering dis-position, the appropriate documents were prepared. For example, the following irs resulted in the preparation of the listed CMCs or DCAs:
IR I-1-0043092 resulted in CMC-66621 IR ME-1-0043113 resulted in CMC-99152 IR I-1-0043118 resulted in CMC-66646 .
IR ME-1-0043054 resulted in DCA-16947 IR ME-1-0043055 resulted in DCA-16947 The 63 closed irs had been reinspected after repair and were signed off as satisfactory. Th'e signature of a certified QC insoector CP-G Af*was IG.I& required to close an unsatisfactory IR, as defined in procedurer CP-QP-18.0, not the' 4 ,
signature of "anyone" as alleged. The TRT noted no misuse of this require-ment. o'cedure5CT ! : M aiso require [ hat a quarterly report of WM. th y '
M! .# - .;;.. _ ; be sent to the QE supervisor for trend analysis in accordance /
y with the corrective action system,
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The TRT located two TUEC interoffice memos stating, in effect, that only .
items that could not be resolved with an IR, DCA, or CMC were to be writ-ten as NCRs. Some employees may have interpreted these memos as pressure not to write NCRs; however, the memos were consistent with the above procedures.
The inspectors interviewed by the TRT :- "
not relate any incidents of pressurebymanagementf)craftspersonnelnottowriteNCRs. The TRT reviewed the QA/QC orientation film, " Introduction to Quality Assurance and Quality Control" used in the training of all CPSES QC inspectors. The film made many references to the organizational independence of QA/QC from construction._ Additionally, the training emphasized the establishment of good working relationships with craft personnel to avoid personality con-flicts. The allegation that there was pressure on inspectors not to write NCRs was also addressed in TUEC letter TXX-4180, dated May 25, 1984. Fur-ther TRT evaluation of this matter is presented in AQ-35, QA/QC Category 6.
h A0-85 alleged that the use of test deficiency reports (TDRs), irs, and
, maintenance action requests (maos ) was being abused in that these forms were used for conditions that warranted NCRs. Specific examples were'~not identified.
TUGC0 procedure CP-SAP-16, " Test Deficiency and Nonconformance Reporting,"
specified the use of TDRs and NCRs. Specifically, TDRs were used to de-scribe deficiencies in operating characteristics, test documentation, startup procedure compliance, or any other deficiency identified by startup personnel. NCRs were used to describe deficiencies in physical characteristics, vendor documentation, or construction documentation.
The TRT reviewed 42 TDRs which were originated from July 1983 to May 1984.
All TDRs described items in the categories appropriate for TDRs.
The TRT also reviewed a listing of MARS issued in March 1980, and March 1981. The MARS described normal maintenance work and did not cover mate-rial that should have required an NCR.
The use of irs versus NCRs has been desc bed in allegations AQ-37 and AQ-80 above and in AQ-35, QA/QC Category 6. Procedure CP-SAP-16 also required that the Startup Quality Specialist and lead Startup Engineer identify trends adverse to quality and initiate corrective action.
The TRT found no exanples of abuse of the MAR, TDR, or IR system.
AQ-86 alleged that QC supervisors made it difficult for QC personnel to do follow up inspections of NCRs by not permitting the source inspector to closecut NCRs identified. No other specific examples were identified.
B&R procedure CP-QAP-16.1, " Control of Nonconforming Items," required that: "The applicable QC Superintendent /QCE shall ensure that the work activities required by the NCR disposition are verified and/or witnessed by qualified inspection personnel. The inspector shall document the completion of the NCR disposition by:
- a. Assuring documentation is available to verify that the disposition'~~~
has been satisfactorily implemented. This documentation shall be attached to or referenced on the NCR; and
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- b. Signing the verification block on the NCR. This signature provides-objective evidence that the hold tag has been removed.
"QE will coordinate obtaining ANI concurrence. Should any discrepancies arise, they will be referred to the QCG and/or QEG Supervisors for resolu--
tion. Following ANI concurrence, the QE will review the NCR and applicable supporting documentation for legibi,lity, clarity and specificity and then sign for ' Closure' of the NCR."
TUGC0 procedure CP-QP-16.0 contained similar language.
The TRT noted that there was no requirement stating that the original inspector was required to follow-up the NCR disposition implementation.
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Such follow-up would have advantages, as would the forwarding of a com-pleted NCR to the originators, but it was not a requirement.
In assessing this allegation, the TRT reviewed 154 NCRs. Required rein-spection had been ' completed and signed off on inspection documents attached to, or referenced in, the NCRs. QA/QC had also signed the NCRs separately for closure.
The TRT found no examples of QC difficulty in performing follow-up inspec-tions and closing NCRs.
A0-87 and A0-124 alleged that craft rather than QC personnel have been signing off NCRs that QC refused to sign, and that some NCRs were disposi-tiened inaccurately. Specific examples were not identified.
The TRT reviewed 154 NCRs, and found no evidence of incorrect or falsified signatures. Falsification of signatures is very difficult to substantiate unless specific individuals voluntarily disclose that specific signatures are not theirs or the signature handwriting is widely different from their
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usual ~ hanewriting'.~ 'The~ TRT identi fied"no"ca~ sis" of ~this~ kind f6r' NCRs; however, NRC Region IV is investigating a case of this kind that was dis-covered after the TRT left the site.
The TRT determined that the QA staff, or the QE who signed an NCR for closure, reviewed' previous signatures. The signatures of the_QE, engineer, and addressee on the NCR typically are very familiar to the QA. staff or QE. One QE stated that there had been instances in which he had refused to sign an NCR b'ecause of an unfamiliar signature; however, in each in-stance the question was resolved, and he then signed the NCR.for closure.
Part of this allegation referred to NCRs for flanges on 12-inch piping shown in isometric drawing VA-2-AB. There are two isometric drawings in that series: BRP-VA-2-AB-001, and BRP-VA-AB-002. Both of these drawings l show only 3/4-inch piping without f'4anges.
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. E -4 Another part of this allegation referred to NCR M-13932, in that the NCR was dispositioned by voiding. This NCR specified that the document vio-lated was B&R procedure CP-QAP-11.1, Revision 4, Parz graph 2.3.2. The TRT noted that the only Paragraph 2.3.2 contained in this procedure was in Attachment 1, which did not relate to the subject of NCR M-13932. After a review of the NCR, the TRT determined that the NCR was voided in accord-ance with procedures.
However, the TRT review did identify specific cases of inaccurate dpposi-tioning of NCRs. One such case is described in Electrical Categor' ' .
(AQE-36). Another, in which the description of the nonconforming condi-tion was changed by two successive revisions e7 of the NCR, is described in QA/QC Category TAIT 55). Also, M,in changiiig order to,. chang the description of the nonconforming condition without obtaining the
- approval of the inspector that prepared the original desc'ription, as described in AQ-55, appeared to be a noncompliance with the requirements of TUEC procedure CP-QP-16.0, paragraph 3.2.7, which stated "the necessary approvals shall be obtained in accordance with this procedure for the -
portion affected by revision." .
Inaccurate dispositioning of NCRs by B&R was also investigated by the Authorized Inspection Agency, Hartford Steam and Boiler, in Citizens Association for Sound Energy (CASE) Exhibit No.1050, dated October 21, 1983, with responses thereto by B&R. .
- AQ-95 alleged that NCRs were misused in that an NCR was written to apply to more than one, traveler. Specific examples were'not identified.
4 The TRT found that there were a number of NCRs that were used as " generic" NCRs, i.e. , each NCR applied to one type of problem identified in a number ,
of locations. For example, NCR M-83-01162, " Stairway Framing," listed 17 ;
affected travelers. Each traveler applied to a specific stairway and each !
individual traveler had QC sign-off for repair of that stairway. Proce- !
dure CP-0P-16.0, "N.onconformances" had no requirement that prohibited the !
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use of multiple travelers in NCRs. The TRT found no examples of generic
- NCR misuse.
3 AQ-96 alleged that the use of open-ended field job orders (FJ0s) cade work appear to have been preapproved. Specific examples were not identified. }
The TRT reviewed the FJO files. Approximately 330 FJ0s were written for repair work to vendor equipment. Of these, two were open: No. 49, for Allis Chalmers, and No. 261, for ITT Grinnell. The two were open because of continuing repair work required for equipment supplied by those compan-2 ies. FJ0s were used as financial documents to backcharge the vendors for repair to vendor equipment rather than returning the equipment to the vendor. The FJO was an accounting mechanism only; it was not a construc-tion document and craft personnel could not do work to an FJ0.
AQ-97 and AQ-116 alleged that permanent documentation was pulled out of the records vault and NCRs were written because the documentation did not l match the " log book" (i.e., the documentation was deficient), and that B&R procedural changes have resulted in the violation of procedures for document review of ASME documentation and manipulation of safety-rElated ~
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(i.e., ASME) documentation. Specific examples were not identified.
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The TRT reviewed 32 B&R NCRs that had been written after acceptance of the i isometric N-5 data report. The 32 NCRs noted the lack of ANI sign-off on flange travelers related to the N-5 data reports. The 32 NCRs were dated between January and April of 1984. Eighteen of the NCRs resulted in
" cosmetic repair" that did not require any change in the N-5 data report;
- 14 of the NCRs resulted in repair that caused an amendment of the N-5 data report, with QA sign-off and ANI concurrence. B&R established an N-5 data report documentation checklist, which required ch cking for the latest flange traveler.
The TRT reviewed B&R procedure CP-QAP-12.1, "ASME Section III Installation Verification and N-5 Certification," which was revised and reissued as 4
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Revision 11 on June 11, 1984. The TRT also noted that at least 14 other quality assurance procedures were revised and reissued on June 11, 1984, apparently as part c f an ov3rall procedure updating.
A TRT interview with the N-5 lead QA/QC engineer indicated that the intent in issuing Revision 11 of CP-QAP-12.1 was (a) to incorporate detailed instructions for preparing N-5 data reports, which had been contained previously in a separate, informal document; and (b) to require documenta-ion for recently completed activities to be sent directly to the N-5 hroup,whoassembledthecompleteN-5reportpackageandtransmitteditto the ANI for review and approval. The previous procedure required that the' documents be sent from the field to the records vault, which required the ANI to wait until the documents were processed and indexed by vault personnel before obtaining a copy to add to the N-5 report-package, and then proceeding with their review. When compared to the previous process, this change may appear to be a violation of procedures; however, the revised procedure made no change in the review required for the report package nor in the use of the N-5 documentation checklist. The change involved the sequence for transmitting documents to the vault. The N-5
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QA/QC lead engineer" indicated ~it'was a more satisfactory process.
Review of the B&R NCR log indicated that 50 NCRs related to incorrect docu-mentation were issued during August,1984. The TRT attributed part of this increase to an increase in the amount of documentation being transmitted to the records vault; however the issuance of that many NCRs would seem to warrant the preparation of a CAR, but none was available.
/ ~
TheTRTnotedotherinstance7inwhichspecificnonconformanceswerecor-rected, but programmatic corrective action was not taken. An example is described in QA/QC Categoryk3A. The TRT also noted from the CAR log that no CARS were issued between June 11, 1980, and January 14, 1982, then four were issued on January 15, 1982, and that four separate CARS (22, 27, 32, and 43) related to hold point violations were issued. This indicated to the TRT that an overall Quality Assurance (QA) organization (as distin-guished from QE and QC) was not available. Indeed, the NCR form did not
identify any review of NCRs by an overall QA organization. The QA review identified in TUGO Procedure CP-QP-16.0, Paragraph 3.2.6, was in reality a QE review, and the only reference to QA review in B&R Procedure CP-QAP-16.1 was to a managerial review. Addition &1 comments about the CAR system are contained 1.n QA/QC Category 8 (AQ-135).
The TRT noted that hanger packages may continue to be modified (by NCR) to add revised drawings that require adjustment rather than structural modification, e.g.. snubber loading or adjustment of spring cams. The TRT did not consider this to be an abuse of procedures. The lack of jefor-untimely documentation review by the ANI is addressed in QA/QC Category 2 (AQ-134). Id3--
g AQ-106 alleged that NCRs were written against startup work authorizations (SWAs) to correct uncontrolled design change documents that were released for use with the SWAs. Specific examples were not identified.
The TRT conducte'd a computer search of the entire SWA file to locate the SWAs that had resulted in NCRs. Three were found, NCRs 83-0083, 84-0111,
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and 84-0066. Thes~e' three NCRs were not.related to ths'use of uncontrolled design _ change documents. The TRT found no evidence that NCRs were written against SWAs to correct uncontrolled design changes.
AQ-109 alleged that the dismissal of a QC inspector had a negative (chill-ing) effect on the preparation of NCRs.
l This allegation was the sub' ject of a previous inspection conducted by ,
Region IV and was reported in Inspection Report 50-44/83-34, dated September 10, 1983. That inspection determined that for the 6-month period after the dismissal of a specific QC employee, the issuance of non-ASME NCRs increased by 210 percent, and th.e issuance of ASME NCRs increased by 170 percent ov'er the 6 months preceding the QC employee's dismissal. The TRT inferred from these increases that the dismissal did not have a negative effect on the preparation of NCRs.
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The TRT also interviewed two of the three individuals still onsite who remerber the dismissed QC employee. Both individuals were familiar with the NCR system, and neither could confirm the allegation. Interviews with other QC inspectors onsite did not disclose any indications of reluctance to write NCRs because of fear of dismissal.
AQ-114 alleged generally that, instead of writing NCRs, B&R inspectors kept personal logs of " problems" they discovered, then obtained their disposition and that " keeping such logs is in accordance with Construction Procedures in the section on procedures for nonconformance reports."
Specific examples were not identified.
The TRT reviewed both TUGC0 and B&R NCR procedures and found no reference to inspectors keeping personal logs of problems. The TRT found that the NCR procedures were in the book of quality procedures, not'in the construc-tion procedures, as alleged. Lead B&R QC inspectors did maintain a log of unsatisfactory irs. B&R procedure CP-QAP-16.1, " Control of Nonconforming Items," provided that each QC group be preassigned a block of IR numbers, which they used as unsatisfactory irs were written.
The TRT found that a protective coatings exemption log was maintained, according to procedure CP-EP-16.4, which identifies protective coating areas that do not meet the requirements of G&H specification 2323-AS-31,
" Protective Coatings." Each entry on this log was accompanied by a DCA to exempt the area shown on the drawing from the G&H coating requirements. ,
Interviews conducted by the TRT with two QC inspectors and three QC super-visors disclosed that, during the first few years of the CPSES project, QC -
inspectors kept logs of all the jobs they inspected. Such logs supposedly are no longer maintained; some inspectors do maintain a personal log of jobs worked in case supervision questions the amount of work they have completed.
} , The TRT discovered a personal QC log book with the following entries:
Date Entry 1
12-18-81 " Night shift personnel (paint) have been verbally directed by to violate paint QI and inspect via 3 part memo - (who's on first?) -
program violation."
1 03-02-82 " Duplicate hanger numbers on supports to phantom steel-howtoinspect,howtoas-built,howto code certi fy."
1, 05-20-82 " Talk to on spread room:
- 1. Bolt torquing
- 2. Coping (?) by 05-24
- 3. As-Builttrain[ing]
- 4. 100% reinspection" 07-08-82 " Overtime _for As-Built denied by and
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~ for budg'et" considerations. ~35" problem backlog."
- Obviously, inspectors are entitled to keep personal logs if desired; how- -
ever such 16gs should not 'to be used in place of the formal nonconformance or deficiency reporting system. It appeared that some of the above items should have been'the subject of irs or NCRs, but could not be identified
- . as such.
i- AQ-120 alleged that "during the time Reactor Building Unit I was starting to be turned over, there were a number of NCRs written, the disposition of which was questionable." Specific examples were not identified.
-The TRT interviewed engineering and scheduling personnel to identify the turnover process. Turnover is accomplished piecemeal as a specific sub-
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areas and 331 subsystems listed for Reactor Building Unit 1, 317 D. .e s tm.
e .- .c.~ . :;.,.; r.q nd 323-subsystems had been accepted by TUEC as of July 20, 1984. F ~ f ':9-Qjh .
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.~a.e e of Reactor Building Unit 1 is still in process.
Consequently,
,- _.e, d ?.i; lication of a rush to complete turnover of Reactor Building Unit 1 ':
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supported by the actual schedule. h 72%.d '/j.
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i.lso reviewed the B&R NCR log for the time period around September ,,.w 1 d.R
- J.f 56 There wat no apparent reduction in the time required to disposition (.
e _-
. mediately before September 1978. Some NCRs issued in the first t , g- :
September required over a year to disposition, which also does not '
jhb/
,..m.y 1
i e a rush to complete disposition of NCRs. The NCRs issued during L.J,{. :n ,
tod of August to October 1978 related to a wide variety of systems {:l,, ,^ j)g j st system 85-01). A TRT review of these NCRs indicated they were [ , fy? : l tioned satisfactorily. k -, : .,U'i
,[ !
i
[
,.4 .
ion of the B&R Open NCR Status Report of July 18, 1984, indicated [.'. .C :.;'. .?T&: .
.? -
f typical open NCRs listed, approximately 83% were to be closed by ['~~. M.. . .
A e work of some kind, and approximately 17% were to be closed by C,. . . 1,2-
~
n of paperwork. if ,3 ,,
If : G;.
ion and Staff positions: Allegations AQ-30, AQ-31, AQ-32, AQ-36, j' "i. -
AQ-80, AQ-85, AQ-86, AQ-87, AQ-95, AQ-96, AQ-106, AQ-109, and [ , $
werenotsubstantiatedandthesehaveneithErsafetysignificance f'1
[
eric implications. Allegations AQ-34 and AQ-97 were substantiated; f W.(
, the occurrences have been corrected, and have neither safety I t.
_.W. :n.
[ .' . .- n:d.h cance nor generic implications. Allegations AQ-114, AQ-116, and -
were, c subsyantiated, and have safety significance and generic k :- '. f.g .-Q itions q
A/QC breakdown.
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N The initial NCR precess was deficient in some areas; however, a r. umber of prh audits have resulted' in revisions to correct those deficiencies.
Current procedures are generally adequate, with some clarifict.cians required as indicated in AQ-34 and AQ-36. Additionally, implementation of the procedures needs improvement, as identified in AQ-114, A"-116, and AQ-124, including improvement in the corrective action process.
,kn . o f t' e r e. ' ' ' : s ' 4 - ~ = : _ ; b i : " ' -- - -
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'"-" ' ~1-t ':- ' .a In a meeting nith the individuals concerned on December the TRT presented the results
- ,,c-=~- 10,1984,$G
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. i z . al legations inc ~3I .
c-~r/
D dG l@uc of their assessment of tu- .
4 There were no major dis-TRT conclusions. A brief discussion followed.
and no Md' '/M acreements allers.fc.u or ,concerns!I ha.- h-bs. al ecations&were QllG jdentified.**tE %C' ~ '^ ' %.wd'E mrCC ie
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- 8. Attachments: None. _
- 9. Reference Documents: TJGC0 menos on NCRs. Procedures: TUGC0 CP-QP-16.0,
'Rev. 14, Nonconformances; B&R CP-QAP-16.1; Rev. 21, Control of Nonconform-ing Items; TUGCO, CP-QP-17.0 Corrective Action; TUGC0 CP-QP-18.0, Rev. 19, ,
Inspection Report, TUGCO. CP-EP-4.6, F'ield Design Change Control, Revision 10; TUGC0 CP-SAP-16, Test Deficiency and Nonconformance Reporting, Revi-sion 8, TUGC0 CP-EP-4.7, Control of Engineering / Design Review of Field Design Changes, TUGC0 CP-EP-16.4, Protective Coatings Exemption Log. B&R Procedure CP-QAP-11.1, Fabrication and Installation Inspection of Compo-nents, Component Supports, and Piping, B&R Procedure CP-QAP-12.1, ASME Section III Installation, Verification, and N-5 Certification. B&R NCR L'og June 15, 1984 to September 13, 1984.
TUGC0 letter TXX-4180, May 25, 1984.
NRC Inspection Reports: 80-22, 83-34 N-5 Data Reports: VA-1-34A, SF-1-38A, DD-1-45A, CH-1-05A, CH-1-27A,
~ ~ ~ ~ ~ ~ ~ '" ~ ~
CC-1-58A and related flange travelers.' ~ '
CMCs: 5301.through 5343 DCAs: 10763 through 10775 57051 through 50775 11620.through 11645 86551 through 86575 16301 through 16342 Corrective Action Requests CAR S-41 thru S-57 and CAR log.
B&R NCRs (ASME) (Ref. CAR-541)
M-2234 M-2239 M-2316 M-2318 M-224S M-2263 M-2322 M-2324 M-2265 M-2277 M-2325 M-2326 ft-2281 M-2283 M-2334 M-2338 M-2289 M-2292 M-2341 M-2346
M-2294 M-2296 M-2347 M-2352 M-2297 M-2298 M-2354 M-2359 P-2300 M-2303 M-2361 M-2362 M-2308 M-2312 M-2365 M-2366 B&R NCRs (ASME):
M-2840 M-14222 M-12163 M-2846 M-2658 M-12354 M-13788 M-2627 M-2577 M-12305 M-12306 M-2523 M-12382 M-2837 E-1905 B&R NCRs (ASME):
M-11652N through M-11681N M-1135N and M-11687N
~
TUGC0 NCRs (Non-ASME):
E-81-01573 E,,81-01536 E-81-01483 82-0001 E-81-01456S E-81-01393 E-81-01286 82-0002 E-SI-00061 I-84-00378 I-84-00341 82-0003 I-84-00284 E-84-01688 M-84-01602 82-0004 I-84-014425 C-84-01374 E-84-01339S 82-0005 E-81-00027 E-81-00024 E-81-00144 81-0001 E-SI-00178 E-81-00195 E-80-00086 81-0002 E.S3-00143 E-80-00162S E-80-00228 81-0003 M-S2-02395 M-82-02399 M-82-02385 81-0004 M-S2-02360 E-82-02347 M-82-02275S 81-0005 E-S2-02203S E-82-02153 M-82-02138S E-83-03152 M-S2-02113 E-82-02078 M-82-01131 E-83-03128 M-S201055 M-82-00953 M-82-00910 E-83-03075 M-S2-00807 E-83-02730 E-83-03036
..e ,
(w TUGC0 NCRs (flon-ASME):
E-83-03003 M-83-02736 E-83-02651 E-83-03005 M-83-02738 E-83-02652 E-83-03008 11-83-02725 E-83-02653 E-83-02902 E-83-02732 E-83-02654 I-83-02853 E-83-02703 E-83-02628 M-83-02847 E-83-2692 E-83-02620 E-83-02830 63 Unsatisfactory Inspection Reports 42 Test Deficiency Reports TUGC0 Turnover Status Report for week ending July 20, 1984.
' A-A7Af fidavit, p.15 and 16 ; -) I l f( f r<f. (M-N$
St~ --i-;r.c T;y M esd aco3 &S6% nd 47- A
- w. :w.;J II" 9S$!jtj? letter, March 7, 1984 [, q -21 ihJ a
'IDEFJettbr,, March 19, 1984 [/.- Q-3 : (M-5'c)(d'EEJg ( b~
j T-)3 foo1 4 ',9-2 20 m ^ ','---'_/ /,,~C 'J ch en->.t -% i1C " ~~ ' - ~ ~
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A-1 Interview,4pp.
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Tucwy ) ,ll' TRTnw3n% dnu' & /4l, m /) gfd I39 I ti-f l 52',
}
- 10. This statement was prepared by:
T. Curry, TRT Date Technical Reviewer Reviewed by:
H. Livermore Date Group Leader Approved by:
V. Noonan Date Project Director S
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- SEER WRITEUP DOCUMENT CONTROL / ROUTE SHEET 9
- C7
/*
Allegation Numbers , , _ ,, _ ,
Subject of A11egatfon h;-MT) k,(/ % w po ltd/)ft ,
TRT Group rUl4/ 6)C , Ndu pr / ?. /
Author: '
A. W Al<v w / F. Wa f a U / .
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.
D-aft Number Draft .
.,W 2 3 4 5
Author 'E7 "I '- [O'w b - - .
Group Leader . / y#: f A 7 e/.a/.- ##/s -/O+66j '
Tech. Editor \ f l. kJ4 W/e0 Wessman/Vietti ALMilt ,p /
J. Gaaliardo /Y '
// 4 /14 '
/ '
/
T. Ippelito \
Revision Number i
Final 1 2 3 4 5 Author Tech. Editor Grouc Leader ], ,
J. Gaoliardo h'" it/ s 4 T. Ippolito l Administrative Writeup' integrated into SSER fi G. VM i
[ Y (,r,i O.[ k!V j Potential Violations to Region IV '
Workpackage File Complete i g $1
- Workpackage Returned to Group Leader O
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- - - Document Name:
f!.- . AQ-5 SSER
}-. ' Requestor's ID:
. JEAN
'j - . Author's Name:
Chet Poslusny i Document Comments:
1/2/85 - Redraft 1[ space S
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Revision y - 10/11/84 1* AQ-5/SSER/ CP2A l
i
- j SSER i i
- 1. Allegation Category: QA/QC 5.E, Lack of Material Traceability
- 2. Allegation Number: AQ-5
- 3. Characterization: It is alleged that lack of' material traceability for safety-related materials and components has occurred.
- 4. Assessn)ent _of Sa_fety Significance: 7 impli ety sig ifi M f t is 11 ain t at i' ric om ny TUE fai exasUti}it s Ele (ct td ai tai sa egia ac abi ty for. safe -r ated m rials an har ware componen , defe e, mater talled that will no erform its in ded sa ty function.
The NRC Technical Review Team (TRT) reviewed the Brown & Root (B&R)
Quality Assurance Manual, Section 8.0, dated May 17, 1978. Paragraph 8.2 of the manual requires that if material with material traceability identi-fication is cut into more than one piece, the identification (or heat num-bers) shall be transferred, before cutting, to the other pieces. A QC inspector shall then verify that heat numbers have been transferred. Sec-tion 8.0 of the B&R manual, dated August 14, 1981, continued to require verification of heat numbers by a QC inspector prior to subdividing material. Quality Instruction QI-QAP-11.1.28, Revision 25, required QC l verification of material heat numbers price to subdividing and also
- required that this heat number remain distinguishable until the fabrication and installation of component supports were accepted by quality control
, (QC) inspectors.
l l- During an ASME Boiler and Pressure Vessel Code ;urvey at Comanche Peak j Steam Electric Station (CPSES) on October 12 - 14, 1981, the ASME survey
[ team determined that B&R did not verify the transfer of material identi-fication. The ASME survey team also determined that control of material.
i f
salvaged from vendor-supplied components was inadequate. As a result, i
l ,
. - . __-x. __-___-+_ .
s .
1 i..
4 significant. changes to the QA program were made prior to ther survey )(
j by the ASME team on January 20 - 21, 1982. In addition, B&R appointed a l new quality assurance (QA) manager on November 6, 1981, as a result of the '
- October 1981 survey. The ASME survey in January 1982 also required minor
- changes to the QA program. After these changes were implemented, the ASME survey team recommended acceptance of the program.
In response to the ASME survey team's findings concerning salvaged mater-ial, TUEC obtained fabrication records from two vendors, ITT Grinnell and Nuclear Power S.ervices Incorporated (NPSI). The records contained Certi-fied Material Test Reports (CMTRs) and other fabrication data that provided the necessary material control information. TUEC incorporated this data into the record packages for those cases in which B&R had used salvaged material to fabricate component supports.
The TRT found that from November 1981 through January 1982, B&R received procurement documentation and issued numerous interoffice memoranda which documented material reclassification. In addition, TUEC procurement d'ocu-ments specified that material be purchased with CMTRs. Therefore, purchase orders were issued with standard paragraphs requiring material traceability.
This allowed B&R to review procurement documents and verify that the mate-rial was acceptable for reclassification.
In response to the ASME review, TUEC reviewed ap;iroximately 17,600 data packages, reinspected material where necessary, and scrapped material unacceptable for reclassification, which would significantly reduce the
[
t likelihood of any safety-significant deficiencies in design, construction, L inspection, or operations. In February 1982, B&R initiated a program to review all hanger packages to confirm acceptability of material. The
[ review identified that ASME Class 2 and 3 material had been installed in 45 Class I component supports, as documented on NCRs M-30'33, Rev. 1 and M-3258, Rev. 1. As a result of this review and subsequent reinspection, 4
some material was identified as unacceptable and was scrapped.
4 1 .
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1 Based on a review of records and interviews with craft, inspection, and engineering personnel, the TRT determined that since the identification and correction of the deficiencies reported by the ASME survey team, clarification of the QA program for material control has been maintained and has been handled in accordance with TUEC's accepted QA procedure
~
CP-QAP .8.5, " Reclassification of Code Material," Rev. 4.
- 5. Conclusion and Staff Positions: Based on its review, the TRT concludes that the allegation that TUEC failed to maintain material L. ca, n 9 t s traceability for safety-related material and numerous hardware omponents4was substantiated.
l TUEC did have procedures for material traceability, as required by 10 CFR 50,.Appen' dix B, Criterion VIII; however, TUEC did not follow s these procedures, 6 *M'- A Q4 M ew, A partial breakdown in the QA program did occur, as documented in NCRs l M-3033 and M-3253; and although corrective actions were taken and were documented in accordance with TUEC QA procedure CP-QAP-8.5, TUEC failed to report the breakdown to the NRC per 10 CFR 50.55(e) requirements. The TRT notes that the allegation itself has neither safety significance nor generic i.clications in th t the condition h since been c rected W Qi %
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- 8. Attachments: None.
- 9. Reference Documents:
- 1. Procedure CP-0AP-8.5.
- 2. E&R Manual, Section 8.0
- 3. M- 4 A [ letter r t . m & - md - w dated Marcn 7, _
1984.
- 4. Pages26througn31ofA-/ interview.
- 5. Special Inspection Services (SIS) reports 367A, and 367.
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- 10. This'-statement prepared by:
1 L. Jackson, TRT Date Technical Rediewer t
V. Watson, TRT Date Technical Reviewer .
Reviewed by: ..
. H. Livermore. Date Group Leader.
Approved by: -
V. Noonan, Date Project Director !
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-epq SEER WRITEUP DOCUMENT CONTROL / ROUTE YHEET 5$.2 .
-}k]f J' / Allegation Numbers AQ-/2, #g U.7, sne' -/ . n bY _ Mcc,h Subject of Alleg ion /Jwd u , 6 ,,-a,/ w e 3. />/& f ;4 1RT Group O,q on ' 1 ' *
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Author: 2. A'.' Jep s a '
! 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 i work package when the writeup is published. -
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Draft Number Oraft' _ 1 2 3 4 '
5 LHJ j.rt !
AQhor d.1/.al ?-21 1 se N /./
Group Leader /
Tech. Edito'r
/ #8d/6 44
/ / fJ E. M JP" Wessman/Victti / / ' ' '
Tu t d'M 9 h l
,' J. Gajliardo / '
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, T. Ippolito / / i
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i Revision Number g-Final _
1 1M 3 5
, Author Tech. Editor T Group Leader / , u/ /
J. Gaoliardo # /a// /f /0/3/
T. Ippolito f' ,
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I Administrative 1 L
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!'. Writeup integrated into SSER T Potential Yiolations to Region IV #
Workpackage File Complete -
. Workpac,kage Returned to Gr up Leader .
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Document Name:
AQ-12, AQ-13, AQ-14 i
!. - Requestor's ID:
JOANNE l
Author's Name:
Polusny Document Comments:
1/15/85 REVISED IN CRESS I
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? AQ-12,AQ-13,AQ-14/CP4
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, SSER ,
I
- 1. Allegation Category: QA/QC SE, Materials
- 2. Allegation Number: AQ-12, AQ-13, AQ-14, and AQ-115
- 3. Characterization: It is alleged that nonsafety grade materials were upgraded to safety grade through the use of interoffice memorandums or other unauthorized means; that material was upgraded from one safety class to another; and that safety-related systems were downgraded to avoid in-spection by the Authorized Nuclear Inspectors (ANIS).
~
- 4. Assessmertt of Safety Significance: The implie ignificaTee of these alleg\ tion is hat the al,legat ns are/true, i a11ation p?b teria'1s cottl{(esult e failu e o safety-re ated syst /
The TRT reviewed Section 17.1.4, " Procurement Document Control," Sec-
~
tion 17.1.7, " Control of Purchased Material, Equipment and Services," and
[ Section 17.1.8, " Identification and Control of Materials, Parts, and Com-ponents," of the Final Safety Analysis Report (FSAR). Section 17, Table 17A-1 of the Comanche Peak Steam Electric Station (CPSES) FSAR commits to the American Society of Mechanical Engineers (ASME) Code, including ASME Boiler and Pressure Vessel (B&PV), 1974 Edition and Summer 1974 Addenda for piping and tubing, and Winter 1974 Addenda for component supports.
ASclE Section NA-2134, " Optional Use of Code C' ass," paragraph (a) allows any item classified as Class 2 to be constructed and stamped in accordance I with code rule NB (Class 1). Paragraph (b) permits items classified as
~
[ Class 3 to be constructed and stamped in accordance with the rules of NB or NC (Class'l or 2). Sections NB-2551, " Tubular Products and Fittings,"
4
! and NB-2530, " Examination and Repair of Plate," specify examinations re-quired to meet ASME Class 1. If these examinations are performed and f ,
documented,thematgial ay gupgraded (reclassified). B&R procedure CP-QAP-8.5, Revision 44, " Reclassification of Code Material," allows re-classification of either plate or pipe.
. In assessing the allegations concerning material upgrades, the.TRT re-viewed 33 documentation packages of random heat numbers from the permanent l
plant records vault (PPRV) to assess the B&R program for reclassification '
of materials from one safety class to another. In these 33 packages, the TRT found only 1 material heat number that had been reclassified from Class 2 to Class 1 by an interoffice memorandum (IM). This heat number, M20484, was reclassified by IM number 22,281 on December 8, 1981. This IM documents that the requirements of the material specification and y E4g
, code, Subsection NF, Article 2000 had been met. The TRT reviewed"theAre-qu'irements r' "" 2213 and verified that the material was reclassified in accordance with requirements. This IM also included 10 other heat numbers that were properly reclassified and was concurred in by the engineer and quality assurance manager.
PastpracticesatCPSE,Sweregogsu y, me g a g tog e- 4 classify material o the PPRV. fim> were discontinued as s means of docu- 4 j menting material reclassification activities with the issuance of CP-QAP-8.5, Revision 4 (June 1984). The present system requires pipe and plate reclassification to be documented on a nonconformance report (NCR).
l The use of either memoranda or NCRs to document material upgrade is con- f
, nations be performed and documented; it does not specify a particular method for documenting examinations. NCRs and IMs are lifetime records as defined by ANSI N45.2.9, and are also on file in the PPRV.
I l One of the allegations concerning the upgrade of nonsafety grade materials 3 included the assertion that 70,000 IMs were issued upgrading material in j the iron shop alone. This allegation is apparently incorrect since only b 27,541 IMs were written, as of August 5, 1984. Further, these IMs i
- 3 8 .
- k. _ _ _
_ _ - -___. ,i _ _. _ . _ -
j . .
l document actions by B&R in all areas which affectgropct,, Jot just '
4 material reclassification. The TRT reviewed 22 IMsAand verified'~t'h'at 21 j different heats of material with acceptable certified material test re-1 ports necessary to reclassify the materials used at the iron fabrication l shop were on file in the PPRV.
It is also alleged that systems have been downgraded to less than safety related to avoid ANI review. In assessing this allegation, the TRT re-viewed all cases where systems were reclassified, a total of nine. Seven cases (DCA 18,227, CMC 39505, ECN 555, CMC 79822, DRCP 99, DCA 4061, and OCA 15118) involved vent and drain lines open to the atmosphere. Since the lines are outside the last isolation valve, they are not subject to ASME requirements. In the eighth case, a class 3 piping system (BRP l MS-1-SB-019 R8) was extended to include the downstream side of a moment restraint, which was previously unclassified. In the ninth case, the de-sign of the die.sel generator (DG) exhaust system was deleted from ASME B&PV code requirements. However, the DG exhaust is seismically supported, as required for safety-related equipment.
Section NA3253 of the ASME B&PV code requires the owner or his agent to establish the code classification of items. All changes in ASME B&PV code classifications were reviewed and approved by the owner' a bs & .
! Hill, the plant architect-engineer. The TRT has verified that 4 these l
- changes were consistent with the provisions of the ASME code. -
I ~
f The TRT interviewed the ANI lead inspector, who stated that the owner or his AE agent establishes the ASME code classification of safety-related l items and that the ANI inspects in accordance with that ASME-code classi-fication. The ANI was not aware of any downgrading to less than safety-related to avoid ANI review. However, on a few rare occasions, safety-related items had been reevaluated to discern whether an item should be corrected or whether a lower ASME code classification would be acceptaale.
The latter, however, did not avoid an ANI review. .
l . -
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- 5. Conclusion and Staff Positions: Reclassifying material to upgrade it or dewngrade it is acceptable when done in accordance with ASME code. In implementing code requiremerts, TUEC has verified that materials have had the required testing performed or that the required tests were performed under their approved program when materials were reclassified. The TRT verified, by review of Certified Material Test Reports, that TUEC per-
- formed th necessary tests or verified that..oad. the tests ware previously per-y ov e,0 p m formed Consequent y, tne TRT concludes that the TUEC rec?assification of materials program is acceptable.
The TRT verified th2t materials were classified frcm one safety class to another. However, the reclassification wcs performed in accordance with ASME code. Accordingly, this allegation has neither safety significance nor generic implications.
The TRT reviewed nine cases where TUEC upgraded or downgraded parts of systems based on a review of requirements. There changes were approved by the architect-engineer, as required. The TRT review did not substantiate the allegation that systems were downgraded to eliminate ANI inspections.
Accordingly, this allegation has neither safety significance nor generic impl i cati or.s .
$ In a meeting with the alleger on December 10, 1984, the TRT presented the t
results of the assessmsnt of the allegation and the TRT's conclusion. A f u ; w. g r e = .... .-, e c . ~ .~
brief discussion ensued. Pe-: -. : - : x x. . . . c .. . a ..
L ne' - m .. w ...e,....... ,, e t e .c......m.
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- 6. Actions Reouired: None.
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- 8. Attachments: None.
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- 9. Reference Documents: CPSES/FSAR, ASME B&PV Code, B&R CP-QAP-8.5 Rev. 4 i and ANSI N45.2.9.
d IM-22179, IM-22138, IM-22175, IM-22245, IM-2281, SI-2-RB-13-4, SC-1-513-032, CT-1-SB-14, CC-2-SB-042, BR-1-SB-05, SPOOL IQ3, BR-1-SB-004, SPOOL IQ3, l
BR-1-SB-006, MS-1-SB-050, CC-2-SB-042 ITTI; DCA 4061, DCA 18227, CMC 39505, 1
7 ,
ECR 555, CMC 79822, DCRP 99, and DCA 15118; NCR M3778, NCR M3390; GIBBS &
] HILL Specification 2323-MS-43A Rev. 4, CP-QAP-8.5 Rev. 4; CP-QAP-8.1 Rev.
9 8; ASME B&PV Code NB 2510, NB 1510(2), NB 2510(b), NA-2134(a), NA 2134(b),
NB 1551, and NB 2530; NRR 78395 Rev. 1; AQ-12; 3/7/84 letter #9; A-3 statement and interview PP 26-34; AQ-13; GAP petition 3/9/84; A-3 state-ment and interview PP 55-60 8/1/84 PP 24-25; AQ-14: GAP petition 3/19/84; j A-1 statement and interview PP 48-51; 8/1/84 interview P,P 24.
& I A A 'I "'W=h b& to, itV4, fy. 10 l- to3 i
l 10. This statement prepared by:
! L. H. Jackson, TRT Date
, Technical Reviewer T. Workinger, TRT Date j
Technical Reviewer i.'
i H. Livermore Date Group Leader ij !
Approved by:i li - I V. Noonan Date 1 Project Director a
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f' SSER WRITEdP DOCUMENT CONTROL / ROUTE SHEET Allegation Numbers 86- W bd EE
- Subiect of A1iegation 45x,w, 7 c/ &M M. ,tm si, m //a,' -A, s w.1.w ,'4.
] TRT Group CA'/CKL. Ca.h m r/JE- ,
. Author: / '% ~r-w.,j/ d Vm MJa2Wh %
This sheet will be initiale y 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
~
'i work package when the writeup is published. '
o Draft Number j Draft 1 2 3 4 5 Author Group Leader 7/7 Sb/
(/. / 1&dV#/#-ta-4 ,
Tech. Editor YY WE6 /0/M/
Wessman/Vietti t/7 d/ i oA & i J. Gagliardo .f/ // n/n B'T4&& }
T. Ippolito mV/ ' / /'
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Revision Number Final 1 2 , / 3 .4 5 -
4 Author Tech. Editor hF , s1 _
Group Leader .// , pp*FJ #-73C ~
J. Gagliardo ff . ,i/ // 2R O i/.v 1
- T. Ippolito / /
Administrative l.
Writeup integrated into SSER ,.
Potential Violations to Region IV , ' ,
3 Workpackage File Complete CJ p l Workpackage Returned to Group Leader J
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PAT Author's Name:
Chet Poslusny j Document Coments: .;
t 12/13/84 Revisions RETURN TliIS SHEET i T-t l
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. . . . .. .- -- 2.. ....--.....a l Revision 2 - 10/9/84 l- y SSER AQ-40/CP1 1
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- 1. Allegation Category: QA/QC SE, Assignment of heat numbers in the field to j materials used in safety-related construction.
- 2. Allegation Number: AQ-40
- 3. Characterization: It is alleged that heat numbers for materials used in safety-related applications were obtained inappropriately in the field.
i 4. Assessment of Safety Significance: The i ed safety 'gni ance of J is alle t n is that cceptabil of rfo with o at ers wo 1Quaore ancythgi the installed materdiswo\ termin U In assessing this allegation, the NRC Technical Review Team (TRT) reviewed the Brown & Root (B&R) quality assurance manual and procedures addressing material traceability and interviewed inspection personnel. The TRT could find no evidence that material heat numbers were being assigned in the field, with the exception of color-coded material. Texas Utilities Elec-tric Company (TUEC) used a color coding system to maintain heat number
, traceability for tubing material. Over the years of the plant construc-tion, various colors of the paints which were compatible with nuclear l stainless steel tubing were depleted. TUEC then assessed the feasibility 3
of using the same paint colors for different materials requiring trace-en Osc.. R Mr3 4
ability. The engineering personnel made the decisi,onAto use, green to identify tubing for heat number M7632, even though green had previously j been used to denote tubing heat number 402095. The Comanche Peak Steam Electric Station (CPSES) quality assurance (QA) manager had extensive s material testing conducted on M7632 to assere its conformance to specifi-cation an its intended use. This testing prevenfedtheuseof l an % f= Mza m ' rial.
CPSES Engineering acknowledged the fac.t that if either heat number 402095 or M7632 was identified later as defective, both heats of material' would
a
, have to be removed from the facility. The systems using these tubing .
j heats were labeled as non-ASME code material, as defined in Paragraph 41, j Table 17A-1, Amendment 50 of the CPSES FSAR.
5 The TRT found that CPSES had a material control system consisting of ca.rd files and/or computer printouts containing acceptable material heat numbers and detailed material descriptions. These were available in many locations throughout the plant, such as the Permanent Plant Record Vault (PPRV),
material warehouse, receiving inspection office, pipe fabrication shop, iron fabrication shop, and the quality engineering offices. When it was necessary to verify or obtain a heat number or material description of any material in question, the requester could call any of these locations.
The heat numbers of tubing material were ascertained by observing the color code on the tubing. This color code was painted on the tubing by receiv-ing inspection personnel after their final material acceptance and after they measured the tubing. Using the color code information, the requester could, for example, check drawing number FSC-00075, Revision 6, and CMC number 96165R2, to obtain the heat number. This method of obtaining heat numbers for color-coded tubing is acceptable. The TRT noted that none of the inspectors interviewed were aware of any abuse in the material control system.
- 5. Conclusion and Staff Positions: Tne TRT' concludes that this allegation could not be substantiated. Accordingly, this allegation has neither safety significance nor generic implications.
iN A Hfii)ti? W11H THE titLC&EA DH E>Ec !o,19e/ 7df TliT' iMEJEHTh THC AEJULid of THE ASSE6SMLh7 of THE ALLEC47iDX AtG) TN[ 1ATI imCMilts-A EnitraidCossion EAruzli . fittM Wfaikb HAJoa. irtHJ D1fi//A&REEMinT AN1 Nt NiLU CDhlEAAC bf. AlLl&ATICH6 WERE 10Et4TiftEi>-
- 1. Southwestern Laboratories, file number 2-8487-01.
- 2. Report Number 84376 for tubing, heat number M7632,
- dated June 29, 1984.
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- 3. Statement of interview by L. " A W - , 10:45 a.m. on August 7, 1984.
- 4. A-5 Interview on August 1, 1984, pages 8, 9, and 47-50.
- 5. GAP letter, dated March 19, 1984.
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A-5 % 4- m k.,to,ien, pp to 7-!!o l 10. This statement prepared by:
!- V. Watson, TRT Date Technical Reviewer Reviewed by:
H. Livermore, Date .
Group Leader Approved by:
V. Noonan, Date Project Director
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CPl" g SSER WRITEUP DOCUMENT CONTROL / ROUTE SHEET I Allegation Numbers AG- / hrd. (
-l 1 Su6)ect of A1iegationL11' r,sdA;:A m, M A11/ab M MbdQ TRT Group E ' " C e'4 SrF 6 Author z'-77. Jae # r m- # Tl This s eei wiii ce 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 1 2 3 4 5 4.//J Author 9-/2-//', bNk Group Leader / > V # /p-d, Tech. Editor / WR) 1Q6/
Wessman/Vietti / s/ 'l ,ff /
J. Gagliardo / , / /t ,P TV /* /"
T. Ippolito ,/ /' /
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Rev n mber Final 1 2 3 4 5 .
Author llk}f) I//#[
Tech. Editor ,
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Group Leader _,f / //Mi-t- -r J. Gagliardo fV i'l & M' s/
T. Ipoolito / I Administrative m-l Writeup integrated into SSER Potential Violations to Region IV Workpac'kage File Complete Wo: nackage Returned to Group Leader
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