ML20215K646

Partially Deleted Draft Sser Providing Results of Staff Evaluation & Resolution of Approx 400 Technical Concerns & Allegations in Mechanical & Piping Area Re Constr Practices at Plant

ML20215K646
Person / Time
Site:	Comanche Peak
Issue date:	03/15/1985
From:	NRC
To:
Shared Package
ML20215K227	List: ML20215K223 ML20215K646
References
FOIA-85-312, FOIA-87-A-18 NUDOCS 8706250403
Download: ML20215K646 (12)

Text

I 1. 1(v I ; 1r .,r l

l ABSTRACT Supplement 10 to the Safety Evaluation Report for the Texas Utilities Electric ,

Company application for a license to operate Comanche Peak Steam Electric Sta-tion Units I and 2 (Docket Nos. 50-445,50-446), located in Somervell County, Texas, has been jointly prepared by the Office of Nuclear Reactor Regulation and the Comanche Peak Technical Review Team of the U.S. Nuclear Regulatory )

Commission. This Supplement provides the results of the staff's evaluation l and resolution of approximately 400 technical concerns and allegations in the mechanical and piping area regarding construction practices at the Comanche

- ' Pea'k facility. Issues raised during recent Atomic Safety and Licensing Board hearings will be dealt with in future supplements to the Safety Evaluation Report.

I s

4

-L' 03/15/85 iii COMANCHE PEAK CPSES,SSER 10' 8706250403 870619?

PDR FOIA =

GARDE 87-#F-18 PDR

,_ s 3 '. Summary of Evaluations in The Mechanical and Piping (M&P) Area 3.1 Scope of~ Concerns and Allegations h j

~ The concerns and allegations in the mechanical and piping discipline involve aspects of the design, construction and documentation of piping, equipment and  ;

pipe supports. The allegations of' deficiencies in the pipe support design process byMessrs.M.WalshandJ.DoylherenotinvestigatedbytheTRTMechanicaland Safety and Licensing Board hearings and have not been ruled on to date by the Board. In general, the mechanical and piping allegations received or identified q by the TRT were broad in scope and . included concerns regarding problems in design and the design change process, traceability of materials, the use of unqualified-

~

i

~

Yelders,weldquality,anchorboltinstallation,thedispositionofnonconformances and discrepancies, and improper or questionable documentation practices. During the course of the TRT evaluations, new allegations were raised by an alleger..

' involving fitup and welding of component supports, bolt torquing, equipment problems, and other miscellaneous concerns. Findings related to these new allega-tions are also included in,this report. However, this report does not address ,

approximately 10 new allegations recently received f' rom CASE. i

' The mechanical and piping concerns and allegations, including the new ones noted above, as well as 8 Special Review Team (SRT): issues, but excluding.

thosehMessrs. M. Walsh and J. Doylehave been grouped into 49 categories.

The 49 categories are further divided into the following five general areas: i A. Welding B. Piping C. Hangers and Supports D. Construction and Documentation '

.E. Other 03/15/85 1-10 COMANCHE PEAK CPSES:SSER 10

e .-

Lhave appeared to the alleger .to be unclosed NCRs or' discrepancies later resolved in the normal QA/QC program were investigated by the TRT. The results show )

that the QA/QC system provided the necessary corrective action when required -l (See Attachment 2, Category 49.) . l l

i 3.4 Overall Assessment and Conclusion

]

The TRT reviewed and evaluated 149 allegations in the Mechanical and Piping Category.

Many of the allegations contained insufficient evidence with which to evaluate the alleged concerns. Often, there was no connection between the concern and plant safety. .Also,.further contact'with the individuals raising the concerns

' did not provide the required specificity to better focus the allegations. The  ;

Thf performed a detailed review of each concern and completely or partially '

substantiated 38aliegations. Five were of potential safety significance and

. required further action. Other concerns, while not'of safety significance, l I

' required further actions'by TUEC.. The TRT concludes that upon resolution of the open issues noted in Section 4, TVEC with one qualification will have complied with applicable li. censing commitments. The one qualification related totheconcernsgfMessrsM.WalshandJ.Doylehhichwerenotaddressedas part of this effort. Evaluation of these issue,s could affect ~ conclusions-regarding TUEC's ccmpliance with pipe and pipe support related licensing commitments.

The.TRT further concludes that problems'found within the welding, piping',' hang *er and sup' port, and construction and documentation areas are- an indication of weak- ,  ;

ness'in the QA/QC area. The Mechanical and Piping-Group found examples of incomplete and vague procedures,' inspections that had not been performed,:and many duplicate and cumbersome procedures. These concerns will be considered in l the overall programmatic review by the QA/QC Group. This TRT activity'will consider the breadth and depth required to resolve all QA/QC-related concerns, including root cause identification with appropriate required corrective actions.

Therefore, the Mechanical and piping Group concludes that.all actions taken by TVEC 3 to resolve the. specific Mechanical and Piping concerns should not be considered' final until they are properly integrated with the results of the programmatic-review performed.by the QA/QC Group.

03/25/85 N-24 COMANCHE PEAK CPSES SSER'10- .

1

h;,;;;., jiy 1

7d C0r4 AMC HE PER L 55 E 0. ML'(A bC R iI 3 14 3 P ' 3 \ ; 19 M AQEG ATic d GMI'- , D'c4h , Mac to , W ts ccugm TER L %E (L 700 fABEL 10 ) ba$ , Maf 15 )1986 htt_EGBT10d SSElt , bryt ; Fe b u 3 19&5 9

Information in this record was deleted in accordance with t reedom ofjgformation Act, exemptions z ' Y 7U E01A i 7 / Y '

1

, - . l 3

If the QC record. reviewer believed the old records were required to make -

I a final detennination of documentation acceptability, the reviewer's s'upervisor submitted a written request to the Weld Engineering department.

' The stated purpose of the written request was to deter reviewers from asking for information which was-not relevant to the acceptability.of the hanger package. During the transition period from the old welding documentation format to the new one, the record reviewers made n' merous u ,

requests for historical. welding records. Finally, to' minimize'these v requestsj welding engineering turned over all historical records to the reviewers. The TRT found no. spect fic. examples of. records being purposely or specifically withheld by Weld Engineering during documentation review.

Af ter the' transition period . the hanger packages were developed, processed, s {

and reviewed in accordance with the-new documentation format and the corresponding revised procedures.

1$e TRT also interviewed documentation reviewers and documen personnel who performed the final QA/QC review and'found that no' one knew oR any weld data cards being destroyed or changed.

5. {enclusionsandStaffPositions: Based upon 1hefr' assessment of the ~

separate maintenance of hanger records, the TRT concludes that B&R imple-mented an adequate method to perform in-process surveillances and ~to re inspection results. Therefore, allegt.tions AQW-13, and AQH-1~ have. no safety significance or generic implications. W ) *( #ht g $g[E The AQH-1 concerns and. issues came from a Region IV inspectio'n report.

Regarding AQW-13, on October 29,1984,' the TRT was notified that the alleger had declined to have.any further contact with'the NRC. Accordingly, no closecut interviews were conducted.

6. Actions Raouired: None.

r s ..

8. Attachments: None.

.l 1

a er

I I

< l 7 Reference Documents:

1

1. Procedure Number DCP-3 "CPSES Document Control Program," Revision 16, August 5, 1983.

2. Frocedure Number CP-QP-16.0 "Nonconformances," Revision 14, July 2, 1984.

3. Procedure CP-EP-16.3 " Control of Reportable Deficiencies," Revision 3, June 15, 1984.

4. Operating Instructions D'CC Satellites, October 24, 1983.

I

5. Operating / Administrative - Guidelines for DCC Satellites (Craft),

issue date: June 26.-1984. -

i 6.

,Interofficekemo 35-1195, H. A. Hutchinson Jr. to R. Scott]

" Schedule-TransitionformControlNumberedDrawingDistributionto)

Satellite Controlled Distribution," June '16, 1983 ,

7. Office Memorandum, J. D. Hicks to R. G. Tolson " Comanche Peak Steam Electric Station CAT Inspection - Document Control, Ref. letter TUQ-1620," May 2, 1983.

8. Memorandum, TUG-1620, R. G. Tolson to Distribution, " Construction Appraisal Team Inspection," April 18, 1983.

9. Results of Investigation into Allegations Regardino Document Control' at Comanche Peak by Law Offices of Bishop, Liberman, Cook, Purcell and Reynolds, July 19, 1984.

5. NCRs M-14524N, Rev.1, M-14531N, Rev.1, M-14370N, and M-14374, Rev. O.

6. Office Memorandum to Permanent Plant Records Vaults Employees, from[C.H. Welch,QASupervisor, Subject- " Retrieval of N-5 Data Packages from Vault," dated July 9,1984. ]

7. AQ-129: Interviews,A-1, August 1,1984I~Pages- 141, 142, A-5, August 2, 1984.

8. Field Notes of August 9,1984, Interviews with Vault Personnel.

9. AQH-16: GAP witness I and A-47.

10. Interview with A-1 ad A-5 on December 10, 1984, pp. 35-75.

I 4

l l

J 4

3. TUEC Management 3/84 Allegation. I

4. Evidentiary depositions:

5 L

~

i \

Deposition of Jack Pitts; July 31,1984; (Tr. 73,500-553)

Deposition of Ronald Tolson; July 10,1984; (Tr. 40,546-562)

Deposition of 8. R. Clements; July 10, 1984; (Tr. 40,096-105)-

Deposition of Thomas Brandt; July 11,1984; (Tr. 45,128-143)

Deposition of Boyce Grier; July 11,1984; (Tr. 45,591-599)

Deposition of Gordon Purdy; July 10,1984; (TR. 41,198-199)

, Deposition of James Cummins; July 17,1984; '(Tr. 54,009-055)

5. Hearing Testimony:

Testimony of Michael Spence, Tr. 14,924-930 (9/10/84 Testimony of Antonio Vega, Tr. 15,055-060; 1,5,191-193; 15,197-251; 15,278-416(9/10/84)

Testimony of B. R. Clements, Tr. 15,418-428; 15,470-503; 15,514-521 (9/11/84)

Testimony of Thomas Brandt, Tr. 16,107-133; 16,175-201 (9/13/84)

Testiwny of Gordon Purdy; Tr. 16,358-373 (9/13/84)

Testimony of Ronald Tolson, Tr. 16,399-575 (9/14/84); Tr.16,652-658 <

(9/18/84)

Testfeony of Gregory Bennetzen, Tr. 17,745-934; 17,954-968 (9/20/84)

Testimony of David Chapman, Tr. 17,969-18,301 (9/20/84)

Testimony of Doyle Hunnicutt, Tr. 18,515-669 (10/1/84) 01 Report 4-83-001 (24 August 1983)

6. Deposition of James Cummins; July 17,1984; (Tr. 54,072) ,

?,

The comments reflected a negative attitude and need not be pursued further.

• The concerns lacked sufficient merit for further investigation. .

i

5. Conclusion and Staff positions: The TUEC exit interview program was initiated in October 1983. However, the program began and was implemented in its current scope and formats in about April 1984, when TUEC initiated l its quality awareness program. The concern regarding the adequacy and effectiveness of the exit interview program was substantiated. Although

.still in its infancy, the exit interview ' questionnaire and followup, which

~

was reviewed by TRT, does not appear to meet its objective. However, this allegation does not have safety significance. l

. l The source of this concern was not a specific individual, therefore no exit interview was conducted. I

6. Actions Recuired: See Item No. 1G, of the enclosure to the D. Eise,nhut letter to M. D. Spence date January 8,1985. j l

i 7- R'far'ac' D'cua'at5:

1. Notice of Violation and Proposed Imposition of Civ11 Penalty to=

TUGCO, August 29,1983(EA83-64).

2. TUGC0 ' response .to EA 83-64, September 28, 1983.

3. Memorandum to distribution from D. N. Chapman, TUGCO, Corporate QA Manager,

Subject:

QA Allegation / Concerns, April 11, 1984.

4. Memorandum (C. H. Welch, TUGC0 Site QA Supervisor to J. D. Turner, B&R Assistant Project Manager, subject: . Exit Interviews, June 15, 1984.

5. CPSES Exit Interview Questionnaire.

6. . ' Questionnaire for QA/QC persons leaving.

.. i I

2. TUGC0 CP-QP-4.6, " Field Design Change Control."

l

3. TUGC0 CP-QP-16.0, "Nonconfomance."

'4. NRC TRT QA/QC Category 8, Allegation No. AQ-50, AQ-55,and AQ-135, )

"As-Built Program." ^

1

5. GAP 2.206 Petition No. 13, dated March 19,1984(AQ-44).

6. AQ-44 and AQ-128: A-1 Statement dated March 19,1984, and A-1 Interview pp. 57-63, dated April 6,1984.

7. A-1 Interview pp. 136-137, dated August 1, 1984. ,

1

8. TUEC Letter TXX 4180 dated May 25, 1984 Nonconfomance Reports )

(NCRs) as follows:

83-03110 84-00686 84-00607 03114 00398 00609 03093 00469 00596 03089 00470 00578 .

03090 00456 00570 03063 l

00463 00554  !

03066 00444 00557 1 03048 00434 00560 03053

. {

00443 00551 '

1 03035 00424 00537 03039 00397 00519 03040 00375 00495 03042 00709 00500 .

03025 00713 00483  !

03027 00673 00339 l 03010 00645 00340 J 03015 00627 00341 1 02988 00633 00343 1 02992 00605 00344 02981 00473 00346 03017 00458 00337 03004 00459 00361 02475 00608 00371 00579 00485 00362 ,

I

9. Deposition of Mrs. Stiner (July 13,1984),Tr.52,055Line21;'52, 079-52,084; 52,182-52,190; Case Exhibit _667, pp. 54-55. ,

k

/. ,

, l

10. Deposition of C. Thomas 8randt, Tr. 45,273-45,276(submittedas prefiled written testimony).

11. 01 Report 4-84-008 (July 9, 1984). I

12. 01 Report 4-84-006at26(March 7,1984). .

F 9

.13. Deposition of Mrs. Stiner (July 13, 1984), Tr. 52,085-52,105..

~

14. Deposition of C. Thomas Brandt, Tr. 45,287 (submitted as prefiled writtentestimony).

15. March 19-20, 1984 Hearing Session Transcripts Tr. 10,383-11.018.

16. April 24, 1984 Hearing Session Transcripts Tr. 12,138-12.285.

17. Deposition of Mrs. Stiner (July 13,1984),Tr.52,108-52,111; 52,199-52,202.

~

18. Deposition of C. Thomas Brandt, Tr. 45,280-45,287(submittedas prefiledwrittentestimony).

y

. . o t'

t

15. Prefiled Testimony of C. Thomas Brandt, October 3,1984 (Tr. 45,356-480).

16. " Case's Further Evidence of a Quality Control Breakdown in the Con-struction, Installation and Inspection of the Stainless Steel Liner Plate" dated November 15, 1984.

17. Testimony of C. Thomas Brandt', Tr. 15,629-697 (9/12/84); 15,978-16,214 (9/13/84); 16,728-777 (9/18/84); 17,264-363 (9/19/84); 20,569-774 (11/26/84);20,778-21,091(11/27/84).

~

j T18. Deposition of Sue Ann Neumeyer, August 1, 1984 (Tr. 59,516-536, q

59,640-676) and August 2, 1984 (Tr. 59,773-825).

r-- .

].

19. Deposition of Meddie Gregory, July 31, 1984 (Tr. 54,596-617).

L ~

l

20. Deposition of Dwight Woodyard, July 24, 1984 (Tr. 56,561-566). 'j

21. Deposition of Ted Blixt, July 25, 1984 (Tr. 57,015-036) ,

I

22. Deposition of Robert Stever, July 25, 1984 (Tr. 58,024-056).

23. Profiled Testimony of C. Thomas Brandt, October 16,_1984 (Tr. 45,373).

24. Transcript of TRT Interview, December 10, 1984 beginning on page 166.

25. NRC letter D. Eisenhut to M. D. Spence dated' January 8,1985.

26. Liner inspection travellers as noted in text.'

.