IR 05000387/1981011
| ML17139A481 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/01/1981 |
| From: | Christopher R, Reynolds S, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17139A480 | List: |
| References | |
| 50-387-81-11, 50-388-81-05, 50-388-81-5, NUDOCS 8112080277 | |
| Download: ML17139A481 (22) | |
Text
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U. S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
50-387/81"11 Report No. 50-388/81-05 50-387 Docket No. 50-388 CPPR-101 License No.
CPPR-102 Priority Category Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns 1 vani a 18101 Facility Name:
Sus uehanna Units 1 and
Investigation At:
Berwick Penns lvania Investigation Conducted:
Ma 12-15 1981 ec/.
R.
K. Chri stopher, 'Investi gator, Enforcement nd Inv tigation Staff
.F...~i
~
D. Rey'nolds, Jr.,
Reactor Inspector Engineering Inspection Branch 6'll../,p /
/ date
<<II<I date Approved by:
d%Z~
o lro/H g/Lowell E. Tripp', Chief M&PS, Engineering Inspection Branch date
/(/~i date Ins ection Summar
Investi ation Conducted Ma 12-15 1981 Combined Re ort 50-387/81-11
~/5 Areas Investi ated:
An investigation was conducted based on an allegation reporting that radiographic records of certain unidentified pipe weld joints were being falsified by representing multiple radiographs of one pipe weld joint as radiographs of other weld joints that were difficult to radiograph (by location).
Additional routine inspection activities were conducted including review of Welding Documentation, Radiography Technician Qualifications, observation of Q and Non-Q welding activities, and observation of Post Weld Heat Treatment (PWHT) activities.
Results:
The allegation related to falsification of Radiographic Records was determined to be unfounded.
Within the scope of the inspection activities, no items of noncompliance were identified.
Region I Form
8112080277 8l0715 (Rev. April 1977)
PDR ADOCK 05000387II G=
PURE
I.
SUMMARY An investigation was initiated following receipt of an allegation by telephone at the NRC Region I office alleging that radiographers at the Susquehanna Steam Electric Station were falsifying radiographic records by representing multiple radiographs of one pipe weld joint as radiographs of other weld joints that were difficult to radiograph (by location).
Subsequent inter'views of the alleger (Individual A) determined he had no affili-ation wi.th the Susquehanna construction project and his allegation was not based on personal knowledge or observations but was based on information received second hand from another individual, (Individual 8).
Interview of Individual
determined he was not affiliated with the plant construction activities nor did he have direct knowledge of any improper radiographic inspection conducted
. during plant construction.
Individual 8 stated his information was based on casual conversation he had with a welder, (Individual C) employed at the plant.'uring a subsequent interview of Individual C he denied any knowledge of wrong doing on the part of the radiographers as stated by Individuals'
and 8 and opinioned that Individuals A and 8 must have in some way misinterpreted the text of conversations he had with Individual 8 regarding plant construction activities.
Individual C denied having any knowledge regarding impropriety on the part of the radiographers at the plant and stated that to the contrary, he routinely observed them conducting PT and MT examinations and has found them to be extremely thorough.
Subsequent interviews of personnel from the sub-contract'ondestructive testing firm, GEO International Construction Testing Services (formerly Peabody Testing Services)
disclosed no indication of impropriety, no indications of improper radiographic procedures and no apparent motive for these personnel to falsify the records.
The NRC inspector reviewed NDE records, the NDE sequential operations regarding radiography and licensee results of a recent audit conducted on the GEO NDE program.
No items of noncompliance with radiographic requirements were identified.
Since no information was developed during this investigation to substantiate the original allegation and because Individual C repudiated the allegation, this investigation has been terminated.
During the course of the investigation, the NRC Reactor Inspector conducted additional routine inspections which is reported in Paragraph VII.
No items of noncompliance were identifie II.
PURPOSE The purpose of this investigation was to pursue a telephone call received by the NRC in which it was alleged that the radiographic records of certain unidentified weld joints were being falsified at the Susquehanna Steam Electric Statio I II.
BACKGROUNO On April 28, 1981, Mr.
Ebe C.
McCabe, Chief, Reactor Projects Section 2B, Region I, received an allegation by telephone from an individual hereafter identified as Individual A regarding radiographic practices at the Susquehanna Steam Electric. Station.
The alleger reported he had received information from welders at the site indicating that the radiographers were falsifying radiographic records by representing multiple radiographs of one weld joint as radiographs of different wel'd joints that were difficult to X-ray (by location).
Individual A provided the identity of one welder hereafter identified as Individual C who reportedly could provide further informatio IV.
DETAILS A.
Interview of Alle er Individual A c'ndividual A was interviewed on May 12, 1981 by Region I Investigator R.
K. Christopher and Reactor Inspector Samuel 0. Reynolds, Jr.
Individual A advised that he has no work affiliation with the construction of the Susquehanna Steam Electric Stati'on and has no direct personal knowledge of work conditions at that facility.
Individual A said his concern is based only on information he received during a conversation he had with Individual B sometime during the latter part of April, 1981.
He explained that Individual B had reportedly received the information directly from Individual C and that he was only relating the contents of his conversation with Individual B.
Individual A related that during this conversation he was told by Individual B that radiographers at the plant were taking multiple (as many as 15) radiographs of one weld joint and then were representing these radiographs as being for a different weld joint that was never radiographed because "it was too hard to get to".
Individual A did not identify specific piping or systems nor did he identify any radiographers or welders that were supposed to have direct knowledge of or be involved in this activity.
Individual A was unaware as to whether this practice was an isolated incident or was recurrent throughout the radiographic examination process at the construction project.
Individual A concluded with his opinion that Individual B, from whom he received the information, would in all probability have no direct knowledge as to the plant construction activities and that his information would be based only on that information he received from Individual B.
Interview of Individual 8 Individual 8 was interviewed on May 13, 1981 by NRC Region I Investigator R.
K. Christopher and Reactor Inspector Samuel D. Reynolds, Jr.
Individual 8 stated that he has no connection or involvement in the construction activities at the Susquehanna'Steam Electric Station nor technical knowledge in the radiographic process and has no personal knowledge of the information he was about to provide.
Individual 8 stated his information was obtained through general conversation with a welder employed at the plant (Individual C) ~
Individual 8 said he routinely had general discussions with Individual C covering a multitude of subjects, including construction activities at the power station.
Individual 8 said that during one of these conversations that occurred during March, 1981 Individual C relayed general information to him stating that radiograhers at the plant were taking "several x-rays of a good weld and then labeling them as representing other welds that were hard to get to" (for radiography).
According to Individual 8, Individual C did not tell him on what basis he knew this to be occuring nor did he identify other individuals, either welders or radiographers, who were aware of, or involved in the falsification of radiography records, Further, Individual 8 could provide no information that identified particular plant systems or piping that were'llegedly involved in the falsification of the radiography records nor did he provide any information that would indicate whether or not this was a recurrent practice or an isolated inciden C.
Interview of Welder Individual C
Individual C was interviewed on May 13, 1981 by NRC Region I Investigator R.
K. Christopher and Reactor Inspector Samuel D. Reynolds, Jr.
Individual C stated that he has been employed by the Bechtel Corporation as a pipefitter (welder) at the Susquehanna Steam Electric Station for approximately four years.
Individual C advised that his qualification limited him to 'structural plate welding associated with piping systems during his employment at the plant and he has primarily been involved in pipe hanger welding.
When questioned about the allegations, Individual C stated vociferously that he has never observed or heard rumors from other personnel that indicated the GEO radiographers were falsifying radiography records or in any way misrep-resenting the radiographic examinations they were conducting.
Specifically, he denied ever telling Individual B that the GEO radiographers were taking extra radiographs of welds and then identifying them as radiographs of different welds that were hard to get to.
Individual C acknowledged having general
"over the fence" type conversations with Individual B about various items including work at the power station and including his work as a
welder.
However, he stated that Individual'
has no knowledge of the workings of the plant or its construction activities and stated his opinion that Individual B must have misunderstood something he said about welding and radiography.
He stated Individual 8 had no knowledge of welding or welding inspection and could not interpret comments made on the subject.
Individual C said he has no knowledge. of radiographic activities of the GEO personnel and that his work (welding of pipe hangers)
does not require radiographic examination.
As a permanent local resident, Individual C stated his concern that the plant be built properly and said he had no hesitation about reporting any concerns should he become aware of deficiencies in the work at the plant.
He concluded with his opinion that the GEO radiographers were thorough and very strict and cited examples regarding his observation 'of magnetic particle and dye penetrant examinations of hanger welds and said that
- they were not following the code requirements in that they were applying a much stricter acceptance criteria to the welds that the code required.
Individual C could provide no further information to support this allegatio D.
Contact with Licensee Nuclear ualitv Assurance N A Mr. Edward Carroll, PP&L NgA, was interviewed on May 13, 1981 and he provided general information with respect to the sequential operations involved in welding, gC inspection, and subsequent radiography and radiographic review at the Susquehanna construction project.
He said that when welds are complete and the weld package (WR 5) has been reviewed, the Bechtel gC department identifies welds that require radiography by placing a colored
"flag" around the weld joint to identify the joints for radiography.
He said the Bechtel field quality control engineer then initiates a request for radiography to the GEO project manager.
This request includes the weld identity, class, ISO number and system to be radiographed.
According to Carroll, the GEO project, manager, (Michael Whalen) identifies the work to be done to his night shift supervisor who assigns a crew to perform the work based on the areas where the joints are located.
He said to his knowledge, GEO currently has four to six radiographic inspectors and that they usually work in two-man teams with a Level I and a Level II comprising the team.
He said the majority of the radiography is done on the third shift, usually starting after midnight and ending before 8:00 a.m.
Carroll advised that all staging for the radiography is set up in advance by Bechtel and all they, (the radiographers)
have to do is to set up the radiographic equipment to take the required radiographs.
Carroll said in most cases the radiography is done within twenty-four hours after the weld is completed and the film is then forwarded to the Bechtel gC department for code inter-pretation.
Carroll opinioned that there is no incentive or inducement for the radiographers to attempt to duplicate the radiography records and"that it is more to their benefit to determine welds that are unacceptable as it prolongs their employment.
Additionally he said welders do not work the third shift and would have no knowledge of the activities of the radiography teams.
In conclusion, Carroll stated that as part of a routine scheduled audit of the radiographic records he has reviewed the weld packages for 50 welds and has conducted an overview of the radiographic examination procedure and has discovered no anomalies that would indicate falsification of radiog-raphy record E.
Joint Interviews of GEO Project Mana er and C Monitor Mt. Michael Whalen and Mrs. Diane Whalen were interviewed on May 14, 1981 by NRC Investigator R.
K. Christopher and Reactor Inspector Samuel D.
Reynolds, Jr.
Mr. Whalen identified himself as the GEO Project Manager and Mrs. Whalen as the gC Monitor.
He identified his company affiliation as GEO International Construction Testing and further explained that this was formerly Peabody Testing Services.
Whalen stated his opinion, that based on the phraseology used in the allegation, it indicated to him that whoever
'made the allegation was not familiar with radiographic requirements, terms
- or its techniques.
In the interview, both Mr. and Mrs. Whalen denied having any knowledge of or indications that their radiographic personnel were in any way duplicating radiographs or falsifying radiographic records.
Mr. Whalen said that he was aware that in the past there were several isolated instances when weld radiographs were incorrectly identified (in-correctly flagged)
by the Bechtel gC personnel.
He said these instances were always caught and corrected by the Bechtel gC personnel during inter-pretation because they didn't match the WR 5 Forms.
He explained that the process for radiography begins when the Bechtel guality Control department releases a weld for NDE.
He said the Bechtel gC engineer attaches a ribbon ("flag") to the weld along with the weld record (WR 5) to signify the weld joint to be radiographed.
He said the Bechtel gC department then submits a
request for radiography to him identifying the weld to be radiographed, the ISO number and plant (area and elevation) location.
He said this request is then given by him to his night shift supervisor who details the radio-graphic assignments to a crew.
He said his crews work in two-man teams consisting of a Level II and a Level I and that their work is done almost exclusively on the third shift after midnight and before 8:00 AM in the morning.
He said depending on the diameter of a weld joint and thickness, a crew could radiograph as many as eight joints per shift or as little as one joint per shift.
In terms of making, work assignments, Mr. Whalen advised that plant area location is a primary consideration used when assigning radiographers to do certain weld joints and that it is a unique situation for a radiographer to have multiple weld joints on the same shift that are the same size and thickness (which would be a necessary prerequisite for duplicating radio-graphs.)
Both Whalens agreed that there was more incentive (to the radiog-raphers)
to complete less radiographs per shift in that it keeps the job going longer and that it is more advantageous to find unacceptable welds than to represent unacceptable welds as good welds.
Further, he said his radi'ographers are paid a straight hourly wage and there is no incentive to radi'o'graph larger numerical numbers of weld joints per shift.
Additionally, Whalen stated that during these shifts, the supervisor (Mr. Warren Baublitz),
who is also the Radiation Safety Monitor, makes unannounced inspections of the radiography work areas intermittently during the night so that a radio-grapher, would be taking a great risk to attempt to duplicate radiographs during a shift.
Whalen also confirmed that the radiographers do no inter-pretations and that the films are immediately turned over to the Bechtel gC
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department after they are reviewed for film quality:
Whalen also advised that. both PP&L and Bechtel do periodic field audits of the radiographers in-process work, and that they have no idea when the auditors are going to be onsite to examine their work product.
Whalen concluded that the amount of time saved by attempting to duplicate radiographs, and radiography records was negligible and did not appear to be consistent with the risks that would be involved in operating in such a manne ~
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F.
Interview of GEO Ni ht Shi ft Su ervi sor Mr. Warren Baublitz was interviewed on May 15, 1981 by NRC Region I Investigator R.
K. Christopher and Reactor Inspector Samuel D. Reynolds, Jr.
Baublitz said he has been the night shift supervisor for GEO for five years and has been at the Susquehanna site for six years.
He said he is qualified as a
NDE Level II radiographer.
Baublitz denied possessing any information indicating that activities as described in the allegation were present at this construction project.
As a supervisor and Radiation Safety Monitor, Baublitz said he assigns the jobs each night to the various crews and stated the assignment of specific weld joints for radiography is based on plant geographic consid-erations and not similarity of piping joints which would be required for duplicating radiography.
He said it would be rare to have identical piping weld joints on the same radiography request sheets that would create a situation conducive for duplication.
Additionally, Baublitz said he routinely makes unannounced visits to the work locations to examine the work area and the radiography itself and also to fulfillhis responsibility as a Radiation Safety Monitor.
Baublitz said that as a norm he expects his crews to radiograph an average of five pipe joints per shift (depending on the diameter and thickness of the pipe). but that there is no particular-quota to be met or inducement to shoot a numerically large number of radiographs.
Baublitz said he has trained almost all of the radiographers currently working for him and said he has no reason to suspect their credibility with respect to their work activities.
Baublitz opinioned that he could see no motive for or advantage to be gained by duplicating the radiographs other than sheer laziness on the part of the radiographers.
He stated that all staging is prepared for the radiographers and that they have to do -nothing other than set up their radiographic equipment and shoot the radiograph.
He said there is no financial advantage or incentive to complete more radiographs and that it was actually more beneficial to their radiographers to actually do the work and find unacceptable welds.
He also stated that if a weld has difficult accessibility there is no pressure exerted on the radiographers to make a great effort to make the shot.
He said the radiographer simply informs him that a weld was hard to get to and for that reason they didn'
shoot it and he (Baubllitz) contacts Bechtel for more appropriate staging or whatever is required to make the weld joint more accessible.
He concluded, that in addition to his spot checking the radiographers during the shift, both the licensee and Bechtel gC do periodic in-process audits of the radiography work including observation of field activities and spot re-radiograph of some joints showing explicit identifiers, i.e., tungsten inclusions.
He said these audits and observations are on an unannounced basi,
G.
Intei view of GEO Radio ra hers 1..Mr. Ronald Craig Long was interviewed on May 15, 1981 by NRC Investigator R.
K. Christopher and Region I Reactor Inspector Samuel D. Reynolds, Jr.
Long said he has been an NDE Level II for GEO for two and a'alf years and has been at the Susqhanna Steam Electric Station for approxi-mately four years.
Long also advised that he is a local resident and that he has received his training in radiographic techniques from the night 'shift supervisor,,
Mr. Warren Baublitz.
2.
Long denied any knowledge of or participation in any activities relating to the falsification of radiography records at the Susquehanna Steam Electric Station construction project.
He said that as a local resident it is his desire to see the plant constructed in a safe, efficient manner.
Further, he stated there is no incentive to falsify the radiography records nor was there any pressure exerted on him or any of the other radiographers when they had difficulties radiographing inaccessible locations.
Long said all they had to do was notify the night shift supervisor that he was unable to radiograph a joint because of its location or accessibility and the supervisor would arrange with Bechtel to have the area restaged for easier accessibility.
Addition-ally, Long said that the night shift supervisor and both the licensee and Bechtel routinely make unannounced inspections of the in-field radiography processes and that would make it very difficult for a radiographer to duplicate the records or the shots if he desired to do so.
Additionally, he said that the amount of work saved would be negligible compared to the risk that would be involved.
David Peter Morgantini was interviewed on May 15, 1981 at the Susquehanna Steam Electric Station by R.
K. Christopher and Samuel D. Reynolds, Jr.,
NRC Region I.
Morgantini advised that he has been at the S'usque-hanna project for three years and is currently qualified as an NDE Level II examiner.
Morgantini denied having any knowledge of or participation in the falsification of radiography records and said in his opinion there was no advantage to be gained by duplicating radiog-raphy.
He said there were no financial bonuses or incentives for shooting numerically large numbers of radiographs and that there was no pressure exerted when difficult locations were not shot during a
shift.
He said it merely required notification of his supervisor who requests restaging by Bechtel
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Further, Morgantini felt that if an individual wanted to conduct this type of activity it would be extremely difficult and risky because of the many unannounced inspections that are made during the shift by both the GEO supervisor and the periodic inspections by the licensee and Bechtel guality Contro V'.
STATUS OF INVESTIGATION In light of'he repudiation of the allegation by Individual C and the absence of any information surfaced during the investigation to the contrary, this investi-gation is being submitted close VI'., OTHER INSPECTION FINDINGS DETAILS A.
Persons Contacted Penns lvania Power and Li ht Com an (PP5L)
".R.
- F
" R.
G.
~ H.
A. Beckley, RNQAE M. Carroll, Senior NQA Analyst Fenton, NQA Analyst E. Lockyer, NDE Consultant F. Stokes, Project Construction Bechtel Power Cor oration (Bechtel)
G.
K.
G.
- H C. Bell, QA Engineer Durland, Assistant Lead Engineer Welding QC Finnan, Lead Engineer Welding QC (LQCME)
F. Lilligh, Project Quality Assurance Engineer G. Stout, Project Field QC Engineer J. O'ullivan, Assistant Project Field Engineer M. Ross, Lead Field Melding Engineer E. Mullen, Welding Quality Control Engineer GEO International Construction 'Co.
GEO
".M. Whalen, Project Engineer NRC Resident Ins ectors
" G.
G.
Rhoads, Resident Inspector
" denotes those persons present at the exit interview.
Other craftsmen and technicians were interviewed as necessary when the inspection interfaced
.
with their work.
B.
Ancillary to the investigation the NRC inspector performed routine inspection activities.
These activities consisted of additional review of site welding activities in areas closely related to the substance of this allegation.
C.
Review of Weldin Documentation The NRC inspector reviewed welding documents and the radiographic procedures used to inspect for the following welds:
~f)
DBA-101"2:
EBB-202-1:
HBB-202-2:
OCA-211-2:
GBB-211-2:
OBA-202-2:
FW12 6"x0.432 FM12R1 FWl 10"x0.593 FM3 6"x0.280 FW3 6"0.432 FW6 4nx0.237 FW1 10"x0.593 RWCU Line (")
(0)
~nUnit
The NRC inspector reviewed the welding documentation associated with the routine volumetric inspection of welds.
The following Peabody Testing Company (GEO) documents were reviewed:
(The NRC inspector noted the recent change in name of Peabody Testing to GEO Corp.)
QAP-"2.3 Rev A QAP-2.4 Rev A 1PRT-100-39-03 Rev E
The qualification records of the technicians currently performing radio-graphic examinations were reviewed.
The detailed sequence of operations for radiographic testing was discussed with Peabody management personnel.
The Bechtel QC-Peabody-Bechtel LQCWE's recent Nuclear Quality Assurance
.SSES Audit ¹105 on "Implementation of Peabody Testing's QA Program and Plan." was reviewed.
No items of noncompliance were identified.
D.
Review of PWHT Activities The NRC inspector observed the completion of postweld heat treatment activi-ties associated with HAO-201-2, FW5.
This is an 18" 00 x 0.375 wall P4 to P5 Unit 2 weld in area 14 at elevation 706.
The inspector visually observed the resistance blanket setup, insulation, resistance
"choke" blanket, thermocouple arrangement, power sources, Saban Electric heatup and cool down controllers, proportional soak-controllers, and the time-temperature recording of the thermal cycle.
The inspector reviewed the Bechtel
"Code Requirements for PWHT of Field Welds" PHT 500, Rev 6, dated 10/17/78, and
"Procedure Specification for PWHT of Field Melds PHT-501 Rev 7, dated 8/10/79.
PHT-501 Table SA permits a Larson-Miller type adjustment for lower temperatures, e.g.,
ASME Code Section III temperature requirements for the joint would be 1250-1400F (P5 requirements per NB, C.
0 4622.5).
The actual highest achievable temperature was approximately 1275F where the WPS required 1300F.
Amendment 7 of Rev 7 of PHT-, 501 permits the use of Section III requirements in lieu of B31. 1. PWHT requirements.
The Bechtel reference for the utilization of NB4622.5 requirements is PHT-500 paragraph 5 '.10.1.
No items of noncom'pliance were identifie A rW
15.
E.
Observati on of Wel di n Activities The NRC inspector observed, the following Q and non-Q welding activities
'which were being carried out in the combo shop.
Welding of SP-HBB-210-2 (RHR system)
socket fillet welds ¹2, 4, 6, 8 and 10 (P1 to Pl) with E7018 electrodes, SP-DBD-222-2BW10 open butt GTAW P8 to Pl 3/4" 0.308 "wall pipe with ER'09 filler metal, and SP-JRD-262-3 steam packing exhaust chamber (P1 to P1) complete fabrication.
The NRC inspector reviewed the quality records, filler metal issue sheets, welder qualification, weld history records,.
and visual appearance of the welds'.
No items of noncompliance were identified.
F.
Licensee Action on Previous Ins ection Findin s
(Open)
Noncompliance (387/79-30-01):
Failure to apply design control-measures in the recirculation system field modification.
The NRC followup of this item is also discussed in inspection reports 387/79-33, 387/79-37, 387/80-03, 387/81-03 and 387/81-05.
Representatives of NES and the Licensee met with the NRC at the Region I offices on May 1, 1981.
The Licensee's actions and response to the NRC position on the pre-service and ISI volumetric inspection were discussed.
I't was agreed that all of the elements of the NRC position stated in inspec-tion report 387/79-37 paragraph 4 had been satisfactorily addressed with exception of the double weld fabrication mockup.
The Licensee committed to the production of the fabrication mockup at the meeting and documented that commitment in a May 15, 1981 letter to NRC entitled,
"Susquehanna Steam Electric Station Final Report of a Noncompliance Relating to the Failure to Apply Design Control to Meet Section XI Examination Requirements for Recircu-lation System Field Modifications ER 100450-File 840-4/899-M-191, PLA 787".
This item will be closed upon satisfactory review of the proper utilization of the fabricated double weld ultrasonic calibration test block for preser-
-vice inspection as committed to in May 15, 1981 letter.
(Closed)
Unresolved Item (387/80-28-12):
Evaluation of reported "cracklike" ultrasonic indications in the CRD housing to stud tube welds.
The NRC followup of this question is also discussed in inspection reports 387/80-23 and 387/81-05.
The NRC letter dated May 6,'981 indicates the NRC measures taken to resolve the subject issue.
No further Licensee action is required.
This item is considered close 'l~i~~
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