ML20198D471

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Partially Withheld Assessment of Allegations AQ-43,AQ-47 & AQ-51 to Allegation Category Qa/Qc 5A, Repair,Rework & Maint Re Breakdowns in QC Sys for Repair Work
ML20198D471
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Molonson J
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230286
Download: ML20198D471 (5)
v • d • e


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l'. Allegation Category: QA/QC 5A, Repair, Rework, and Maintenance

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. 1 'fically it is alleged that:

undocumented weld repairs and modificatc ere made to material after QC acceptance (AQ-47); craft workers " boom.;ged" rework by performing ,

repairs without any documentation (AQ-48); and equipmant was disassembled I without authorization or proper documentation (AQ-51).

4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) review of nonconformance reports (NCRs) and permanent equipment transfers (PETS) revealed that disassembly work on pump couplings in the auxiliary building did occur without completion of proper paperwork, as did repair work on the accumulator in Unit 1, as alleged in AQ-43 and AQ-51. However, the TRT determined from a review of NCRs that in each case a QC inspector

. stopped the work until the proper paperwork was obtained.

Out of 378 NCRs reviewed, 11 involved undocumented / unauthorized work acti-vities which required rework. The dispositioning of these NCRs resulted in the work being redone and the appropriate reinspection being completed.

While assessing the generic problem of undocumented repair and rework, the TRT determined from a review of PETS that Texas Utilities Electric Company (TVEC) transferred the service water system components from Unit 2 to Unit'1 in order to meet scheduled startup dates. The pumps were switched back to their original position 8 months later 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 of " boot-legged" rework, TUEC used an approved procedure, CP-EP-9.1, " Control of Permanent Equipment Transfers (PET)," and properly documented the work.

The TRT reviewed many documents related to the transfer of Unit 2 compo-nents to Unit 1. TUEC made these transfers in accordance with procedure CP-EP-9.1 in order to meet startup dates.

l The QC system breakdowns were alleged to have occurred prior to 1983.

From 1976 through 1982, only 4700 NCRs had been written. Systems placed in effec.t since 1983, including as-built inspections, isometric drawing

( package reviews, N-5 walkdowns, and turnover reviews, resulted in 10,000 l' 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 for the period from March 1976 to August 1984, and found NCRs written in the
following areas:

l 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, f 5. Welding documentation missing,

!- 6. Welding performed after final acceptance,

7. Work done without QC verification,

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c. Areas of activity were adequately lighted, ventilated, protected, and accessible as appropriate for the work being performed and consistent with the quality requirements.
2. CONTAMINATION OF STAINLESS STEEL
a. Slings handling stainless steel were made from nylon or stainless steel or had adequate protection, such as being covered with rubber or wood, to prevent contact with carbon steel slings.
b. Tools (for example, 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. Pipe spools, both carbon and stainless steel, were protected by the use of plastic or 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.
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 on motors and motor-operated valves were functioning.
4. ' INSTALLED ITEMS:

Cables and Cable Trays,

a. Cables were covered with fire-resistant materials any time welding, grinding, or torch cutting was being performed in an area that could damage cable.
b. Items such as nuts, bolts, structural steel, pipe fittings, etc., had not been stored or left in cable trays,
c. Metal gratings were installed over cable trays to prevent trash from falling or accumulating in the trays.
d. Flex conduit to equipment was not broken, damaged, or used to support any weight, 1
e. Trays containing cables were not used as walkways.

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f. Trays were not used as work platforms, except when standard work platforms were not feasible. Tha 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, which was stabilized so it could not be accidently dislodged, was used as a temporary work platform.*

(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 supporting their full body weight when standing, kneeling, etc.

g. Cable trays were not used as structural supports, or used to suspend lifting devices.
h. Hoses and cables were not laid across the trays.
1. Doors and covers to electrical equipment were in place when no work was being performed on the item.

Mechanical:

a. 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 management, and an inspection was performed by TUEC to correct similar conditions in other areas as well,

b. Open ends of components were covered unless work was being performed on them.
c. Installed pipe, especially pipe connected to valves and equipment, was properly supported by permanent or temporary supports,
d. No rigging was off supports (unless authorized by engineering in writing on a traveler, etc.).

Instrumentation:

Protective coverings were installed and maintained whenever work was done around indicators, gauges, tubing, etc.

  • This was not used when additional siderails were added to extend the depth of the cable tray.

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5. Conclusion and Staff Positions:

AQ-54 Based on its review of records of QC surveillances for January and February 1979, and inspection reports for 1981 and 1982 the TRT finds some merit in the allegation relating to inadequate cleanliness controls during the early stages of construction. The TRT concludes that the cleanliness con-trols implemented since 1981 indicate that management recognized the clean-liness problem and implemented procedures to correct it.

AQ-65 The TRT was unable to substantiate the allegatioq that a worker was impro-perly instructed by his supervisor in regard to cleanliness inspections.

On October 29, 1984 the alleger's parent informed the TRT that the alleger declined any further contact with the NRC; coisequently, the results of is assessment were not es M

. Attachments: None.

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, and FP-2-31-01.
2. Startup/ turnover surveillance reports DSR-83-058, DSR-82-017, DSR-83-052, and DSR-83-044,
3. Plant turveillance inspection report PSI 0001-PSI 0020.
4. Plant surveillance reports, PS 00001-PS 00030, PS 00300-PS 00375, and PS 00850-PS 00900.
5. Swipe test laboratory reports J-1 through J-99, dated March 26, 1979 through November 15, 1979.
6. Swipe test laboratory reports J-600 through J-699, dated February 28, 1984 through April 27, 1984.
7. B&R CP-CPM-6.9, " General Piping Procedure."
8. B&R CI-CPM-6.9E-2, " Maintaining System Cleanliness During Weld Repairs."
9. B&R CP-CPM-6.9H (Appendix H), " Cleanliness Control."

' 10 . B&R CP-CPM-9.2, " Control of Chemical Substances."

11. B&R CP-CPM-6.12 " Installation, Rework and Modification of Reflective Insulation."

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12. B&R CP-CPM-10.2, " Cleaning and Insulating Stainless Steel. Pipe and Equipment." .
13. B&R CP-QP-19.5, " Surveillance of Plant Conditions."
14. TUGC0 MEI-8, "NSSS Cleanliness During Coolant Loop Installation."
15. TUGC0 CP-SAP-24, " System Cleanliness Requirements and Control."
16. TUGC0 XCP-ME-4, " System Cleanliness Verification."
17. B&R MCP-10, " Storage and Storage Maintenance of Mechar.ical and Electrical Equipment."
18. TUGC0 QI-QP-11.1-65, " Determination of Contamination of Flourides.

and Chlorides on Stainless Steel."

19. TUGC0 QI-QAP-11.1-40, " Insulation Installation Inspection."
20. TUGC0 QI-QAP-11.1-65, " Determination of Surface Contamination of Chlorides and Flourides on Stainless Steel."
21. B&R CP-CPM-14.1, " Guidelines for the Protection of Permanent Plant Equipment."
22. AQ-54: A-7 testimony, March 7, 1984, pages 19, 24, 25, 29, and 39.
23. AQ-65: A-7 testimony, March 7, 1984, page 18.
24. GAP 2.206 Petition, March 19, 1984.
25. NRC letter to TUEC, dated November 29, 1984 (Comanche Peak Review).
8. This statement prepared by: MP1 frwihyv [

J/ Melons ~on7 TRT " ' Date I Tqphnical viewer Reviewed by:

H. Livermore, (tot P d-%k5

'-' Date '

Group Leader Approved by:

V. Noonan, Date Project Director l l l

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