ML20199H051
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Mi m 2 8 1985
%)you very much for3eting with the Comanche Peak TRT, on Thank to discuss the TRT's findings on several concerns you have raised previously regarding construction activities at the Comanche Peak Steam Electric Station. The TRT has determined that one additional concern was not discussed with you during that meeting. As_,you requested in your telecon with John Zudans of my staff on{ that remaining issue in this letter.
we are providing you the TRT's conclusion (see enclosure) on Should you have any comments regarding these conclusions, please call either Mr. C. Poslusny or me, collect at (301) 492-7209.
Sincerely, p_. pnet signed M' Vincent S. Noonan, Director Comanche Peak Project
Enclosure:
As stated i
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.~d, 0FFICIAL RECORD COPY 8607030081 860623 PDR FOIA C O GARDE 86-A-18 PDR 1
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..f ENCLOSURE Summary of Tentative Conclusions Regarding Concern Raised by Concern:
It is alleged that QC inspectors were harassed by being '" told to ignore problems."
This allegation related specifically to the inspection of Chicago Bridge & Iron Company (CB&I) pipe whip restraints, in that an inspector noticed weld defects on vendor-inspected restraints after their delivery to the site.
Assessment of Safety Significance:
NRC Region IV, and the results were published in inspection report (IR) dated June 30, 1982.
The evaluation documented in that report states:
82-10/82-05,
(a)
Defects had been noted previously in CB&I welding.
The NRC had issued a notice of violation (50-445; 50-446/80-20) dated September 24, 1980, to TUEC for welding defects in CB&I supplied moment limiting restraints, which are similar to pipe whip restraints.
were reworked to meet acceptance criteria.
The moment limiting restraints i
(b)
CB&I continued to have difficulty meeting vendor requirements established I
by Texas Utility Electric Company (TUEC); TUEC's inspection of CB&I in February, March, and April of 1982, rated the performance of C8&I as un-acceptable in each month.
(c) A nonconformance report [NCR] written by I
against pipe whip restraints in January 1982 could not 6e locatedMhe NCR, although prepared in draft form, was never released into the TUEC NCR visors that discouraged releana of the NCR. system, possibly because The earliest related NCR the TRT could locate was NCR M-82-00296, dated Marcn 2271982, which noted defects in four pipe whip restraints.
The NCR had been dispositioned on March 31, 1982, as requiring repair of the defects noted on the four restraints.
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Th T identified 36 additional NCRs' defects.
These] weld defects were generally identified af ter restraints were against CB&I welds on pipe whip restraints to document weld painted.. Twelve of the NCRs specifically affected weld defects for 115 pipe whip restraints of the total of 118 supplied by CB&I. In order to disposition the 12 NCRs, TUEC initiated the following actions.
a.
Gibbs & Hill (G&H) structural engineering reviewed the documentation of the weld defects on the 115 pipe whip restraints, marking all defects on restraint drawings.
In addition, G&H engineering evaluated each restraint based on the load transfer mechanism and evaluated the seriousness of each defect in each restraint.
As a result of this review, G&H dispositioned 67 restraints as having insignificant defects.
b.
Of the remaining 48 restraints, those with the most defects (21 restraints) were reinspected by a special team that consisted of a welding engineer, a QC inspector, and a structural engineer to quantify the defects.
As re-quired, paint was removed from the welds on these 21 restraints for this reinspection.
c.
Stress analysis was rerun on the 21 restraints, and no welds were found to be overstressed.
Since, according to TUEC, these 21 had the worst defects of all pipe whip restraints initially identified as having potentially significant defects, all restraints'were considered acceptable.
Because of the CB&I welding discrepancies, on September 30, 1982, TUEC initi-ated a complete inspection of all vendor shipments of non-ASME code structural components (i.e., pipe whip restraints) upon receipt.
This was, in fact, a reinspection, since these items had been vendor-inspected before shipment. This reinspection of all vendor shipments continued until February 22, 1983, at which time TUEC returned to inspecting only those items that had not been vendor-inspected before shipment.
In addition to the pipe whip restraints, CB&I also supplied 105 moment limiting restraints to the Comanche Peak Steam Electric Station (CPSES) site.
Some weld defects in these restraints were noted early in the manufacturing process.
Because the moment limiting restraints are ASME-code stamped (pipe whip re-straints are not), they were reinspected upon receipt, and restraints having weld defects were reworked or returned to CB&I for repair, as documented in TUEC letter TXX-3544, July 19, 1982, and in NCR M-2512.
Because of personal lawsuits pending at the time of this evaluation, some indi-viduals at CPSES were reluctant to talk to the TRT about this subject; there-fore, the TRT could not adequately identify the circumstances surrounding the,
preparation and lack of submittal of the initial NCR in January 1982.
- However, the generation of the additional NCRs caused the weld defects to receive some degree of evaluation and disposition in accordance with the NCR system.
Because of the lack of specific information provided by TUEC related to paint removal and the weld reinspection process, the TRT could neither confirm'nor refute that the evaluation and disposition were adequate.
Consequently, additional explanation for this reinspection process has been requested from TUEC.
Conclusion and Staff Positions:
The decision regarding the allegation of in-spector harassment is documented in Brown & Root vs. Donovan, 747 F. 2d 1029 (5th Cir. 1984).
Vendor weld defect. initially
I were s sequent F dentified and ulfi- ~
mately dispositioned in accoraance wit the NCR system.
Therefore, the allega-tion that inspectors were " told to ignore problems" was essentially substantiated.
The open issue regarding weld reinspection will be evaluated and documented in a subsequent SSER.
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