IR 05000445/1979009

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IE Insp Repts 50-445/79-09 & 50-446/79-09 on 790405-0507.No Noncompliance Noted.Major Areas Inspected:Allegations by Former RW Hunt Employees Re Insp & Testing Improprieties Appearing in Fort Worth Star-Telegram on 790404-06 & 08
ML19241C075
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/06/1979
From: Crossman W, Randy Hall, Stewart R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19241C073 List:
References
50-445-79-09, 50-445-79-9, 50-446-79-09, 50-446-79-9, NUDOCS 7907260561
Download: ML19241C075 (35)


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U. S. NUCLEAR REGULATORY ComiISSION OFFICE OF INSPECTION AND ENFORCDIENT

REGION IV

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Report No. 50-445/79-09; 50-446/79-09 Docket No. 50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tcwer Dallas, Texas 75201

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Facility Name:

Comanche Peak, Units 1 & 2 Investigation at:

Comanche Peak Steam Electric Station, Glen Rose, Texas Investigation Conducted: Ap ri 1979, thro h May 7, 1979

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Inspectors:

_ C. StetiaMactor Inspec' tor, Proj ects Section D$td R.

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6/6/w J. I.T(pja, heactor spector, Engineering Support Date

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R. G. Taylor, Resident Reactor Inspector, Projects Section D5te a

d-G/6/79 W. A. Crossman, Chief, Projects Section Date d

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R.

E. Hall, Chief, Eng'ineering Support Section Ifate

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Approved:

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W. A. Crossman, Chief, Proj ects Section Date hb R. E. Hall, Chief, Engineering Support Section datel 790726056l 467 029

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Investigation Su= mary:

Investigation During the Period April 5, 1979, through Bhy 7, 1979 (Report No.

50-445/79-09; 50-446/79-09)

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Areas Inspected:

Special, announced investigation concerning allegations by former R. W. Hunt employees whose statenents of inspection and testing impro-prJeties appeared in the Fort Worth Star-Telegram on April 4, 5, 6 and 8, 1979.

The investigation involved ona hundred forty-nine inspector-hours by five NRC inspectors.

Results:

No items of noncompliance or deviations were identified.

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INTRODUCTION Co= arche Peak Steam Electric Station (CPSES), Units 1 and 2, are under con-

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struction in Somerville County, Texas, near the town of Glen Rose, Texas.

Texas Utilities Generating Company is the Construction Permit holder with Brown and Root, Inc., as the constructor and Gibbs and Hill, Inc., as the Architect / Engineer.

REASON FOR INVESTIGATION

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As a result of allegations of concrete inspection and testing improprieties asserted to be stated by former employees of R. W. Hunt, which appeared in news articles of the Fort Worth Star-Telegram on April 4, 5, 6 and 8, 1979, Region IV inspection personnel were assigned to investigate the allegations and to assess the alleged activities as to their potential impact on safety related structures.

SUMMARY OF FACTS On Wednesday, April 4,1979, the evening Fort Worth Star-Telegram contained an article on the front page with a headline entitled, " Area N-Plant Tests Questioned." In this article and subsequent articles appearing April 5, 6 and 8, allegations were made regarding concrete testing activities at the Comanche Peak site.

As a result of the allegations contained in the newspaper articles, and subsequent telephone discussions with Mr. Fuchael Fullenson, the newspaper reporter who wrote the articles, the Region IV supervisory staf f initiated the investigation.

During the course of the investigation, RIV inspectors inter-viewed fif teen individuals who are or were associated with Comanche Peak.

The IE inspectors assigned to the investigation determined, through an interpretative review of the news articles, that there were ten specifically alleged concrete inspection and testing improprieties that warranted investigation. The ten alleged inspection and testing improprieties identified by the IE inspectors are as follows:

1.

A former R. W. Hunt employee alleges that aggregate tests were falsified by him and the foreman during the night shift.

The article further states that he was told by the R. W. Hunt QA Fanager to do what his foreman ordered '

him to do after he had complained of the falsification activity.

2.

Two former R. W. Hunt employees allege that equipment used to test aggregate appeared to be sitting unused on the shelves.

"The test, which stunk up the lab, involved putting the aggregate

'ulfuric acid solution to test its long-term resistance to breaking down anu _ racking." Equipment was marked by the allegers with wax to observe the lack of usage.

After three months, the trap remained unsprung; there was no covement of the equipment.

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3.

Several QC inspectors (unidentified) allege that shortcuts were taken on tests involving sizing of the aggregate and its' moisture content.

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An unidentified source alleges that truck drivers added excess water to the-concrete in transit from the batch plant.

5.

A f ormer R. W. Hunt employee alleges that (sometime between August 1976 and March 1977) he " flunked" some concrete for the Turbine Generator Building, but the concrete was placed anyway.

Other inspectors allege that Brown and Root construction employees made it difficult, to do the concrete tests and sometimes small pours were completed before the QC inspectors arrived to do the tests.

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6.

Three different persons (unidentified) allege that, during the placement of 6,600 cubic yards of concrete for the Unit 1 Containment Building foundation on February 21, 1976, some concrete was placed without testing.

7.

A former R. W. Hunt employea alleges that, during a placement in mid-1977 in the containment wall, he failed a truck load of concrete with a slump of 4-1/4" (4" maximum specified) and that the general foreman directed the lab technician to record a value of 4" on the cards.

8.

Two former R. W. Hunt employees allege that concrete cylinder compression strength test results were falsified at the direction of the general foreman and laboratory manager.

9.

Sources (unidentified) have alleged that tests on concrete cylinder compres-sion tests were run purposely faster than allowed by NRC Regulaticas/NRC sanctioned standards (NRC Regulations or Standards not defined).

10.

Two former R. W. Hunt employees allege the recertification of inspectors (after the NRC investigation of March 1977) was done "open book" with answers given.

CONCLUS IONS 1.

Allegation No. 1 The statement by individual "A"1! that. aggregate tests were falsified by him and his foreman cannot be refuted.

A review of the aggregate prequali-fication tests and of in-process concrete testing results indicates that the alleged testing impropriety would not have impacted on the quality of the concrete.

(see Details, paragraph 2.a)

1/ Alphabetical identifications are used to protect the identity of allegers and others involved in the investigation.

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2.

Allegation No. 2 Based on the results of this investigative effort, the allegation that the equipment used to run certain tests on aggregate had not been used cannot be substantiated.

(see Details, paragraph 2.b)

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Allegation No. 3 Although the allegation can neither be substantiated nor refuted as with Allegation 1, the tests in question were of a monitoring nature and not material acceptance tests.

(see Details, paragraph 2.c)

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Allegation No. 4

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This matter was the subj ect of an IE citation as identified in IE Inspection Report No. 50-445/75-10; 50-446/75-10, dated August 7, 1975.

The allegation, relative to safety related structure (s), cannot be substantiated.

(see Details, paragraph 2.d)

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Allegation No. 5 This allegation was neither substantiated nor refuted.

Although the falsi-ficatior of test records on the part of individual "C" may have occurred, no impact on the safety of the structures can be identified.

(see Details, paragraph 2.e)

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Allegation No. 6 This allegation was refuted.

The base mat concrete placement ' as properly batched and adequately tested.

'nspection of the base mat was included in IE Inspection Reports No. 50-435/76-04; 50-446/76-04, dated April 20, 1976, and 50-445/76-06; 50-446/76-06, dated June 25, 1976.

(see Details, para-graph 2.f)

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Allegation No. 7 There is no evidence that an improper inspection slump test occurred.

It is evident that a 1/4" discrepancy in a slump measurement would not irpact on the quality of the concrete and is within acceptance tolerance.

(see Details, paragraph 2.g)

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Allegation No. 8 The allegation by individuals "A" and "K" that concrete cylinder compression strength test results were falsified cannot be substantiated.

(see Details, paragraph 2.h)

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Allegation No. 9 During interviews with individuals

"F" and "M," the IE inspectors were informed that th' alleged " fast loading" during concrete cylinder com-pression strenj_n testing was observed being done in April 1976 and that-5-467 033

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e corrective action was initiated by the R. W. Hunt laboratory tanager.

It was determined that alleged " fast loading" was -identified by a B5R QA inspector on January 24, 1977, and that corrective action was imple-mented.

The results of the investigation indicate that uo detrimental ef fects to safety related concrete resulted and that the t.lleged improprieties were corrected in accordance with the QA/QC progran requirements.

(see Details, paragraph 2.1)

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Alledation No. 10 The matter of qualification and certification of the R. W. Hunt Level I

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inspectors was a subject reviewed in detail during a March 1977 IE inves-tigation. The details regarding the resulting IE noncompliance citation and subsequent licensee corrective action are contained in the IE Inves-tigation Report No. 50-445/77 02; 50-446/77-02, dated thrch 23, 1977, and related licensee correspondence, dated April 25, 1977.

The IE inspectors cannot verify the validity of the stated allegation regarding the recertification of inspectors after Blarch 1977 beyond the oral statements given.

(see Details, paragraph 2.j)

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DETAILS 1.

Persons Contac*ed

?-incipal Licensee Employees B. R. Clements, Vice President R. G. Tolson, Site QA Supervisor J. V. Hawkins, Product Assurance QA Supervisor R. V. Fleck, Startup QA Supervisor Former R. W. Hunt Employees and One B&R Employee

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Individuals "A" through "u" 2.

Investigation - April 5, 1979, Through May 7, 1979 a.

Allegation No. 1 Individual "A" alleges that aggregate tests were falsified in January 1976 by himself and his foreman.

Findings Interview with Individual "A" Individual "A" states that while he was working the second r!.'ft he was encouraged to " dry lab" the aggregate gradation tests to elirainate the time censuming oven-drying process.

In t e rviews with Iridividuals "B, " "E, " "G,"

"H,"

"I," "J," "K, " "L,"

"N," and "O" These individuals expressed no knowledge of the allegation.

Interview with Individual "C" Individual "C" expressed hearsay knowledge only.

He stated that he did not work in the aggregate laboratory.

Interview with Individual "D" Individual "D" stated that he did not work it. the aggregate laboratorf and that he had never seen anyone falsify anything during employement with R. W. Hunt.

Interview with Individua,1

"F" Individual "i stated that on one occasion, duting the evening shift, he saw procedural shortcuts being taken.

He reported the matter to f(l Q -7-

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e the laboratory supervisor who subsequently took corrective action.

This action was to transfer the testing personnel involved to the day shift for closer supervision.

Interview with Individual "M" " Individual "M" stated that he and individual "F" were transfered to the night shift in April 1976, as a result of improper testing on the part of the individuals who preceeded them on that shift. He further stated that it took them approximately twelve hours to complete the volume of testing which their pradecessors completed in eight hours.

He also stated that he was aware that the previous night crews would " goof-off lot" and " play with homemade blow dart guns."

.. Investigation Effort A review was conducted of independent testing results performed by Texas Industries, the aggregate supplier, on aggregate supplied to the site b_ tween January and May 1976.

The Texas Industries Quality Ccntrol Department, North Central Texas Region, Bulk Materials Inspection Reports for the following materials were reviewed: Material Source Tons 3/4" to No. 4 (4.75mm) Cleburne 36,5000 sieve gravel 3/4" to No. 4 Boonsville 24,000 sieve crushed stone 1-1/2" to 3/4" Boonsville 24,000 crushed stone Maximum No. 4 sieve sand Cleburne 40,000 The results of the cbove tests were reported as Iplying to the following specification requirements: ASTM Cl36-76; Test for Sieve or Screen Analysis of Fine and Coarse Aggregates ASTM C142-71; Clay Lumps and Friable Particles In Aggregates ASTM Cll7-76; lbterials Finer Than No. 200 (75-pm) Sieve in Mineral Aggregates by Washing ASTM C127-77; Specific Gravity and Absorption of Coarse Aggregate-8-467 036

. ASTM C128-77; Specific Gravity and Absorption of Fine Aggregate ASTM C29-76; Unit Weight of Aggregate , ASTM C40-73; Organic Impurities in Sands for Concrete The testing performed by Texas Industries was conducted for the purpose of material prequalification, whereas, the tests done by R. W. Hunt during the night shift se ved to monitor the material for any deviation from the specification and to assure uniformity.

The qualification of the material was a shared responsibility between Texas Industries and R. W. Hunt.

A sample would be taken from a stockpile and equally . divided between the two companies for independent evaluation.

Material acceptance testing determined the suitabilicy of the aggregates and not the daily uniformity.

The specific daily uniformity checks which are the substance of the allegation are the moisture content and gradation de te naina tions. These checks served to assure uniformity of concrete batches and to inform the batch plant of any adjustments which would be necessary in order to take into account moistura content variations.

Failure to identify any substantial variation in material grading or moisture content, as a result of a failure to perform the checks, would result in a variable workability which would be identified in the field test for Slump of Portland Cement Concrete; ASTM C143-74.

A review of nonconformance reports issued during January and February 1976 did not disclose any noncenforming s.

.p test reeults which would indicate non-uniform aggregate.

IE Inspection Report No. 75-13 identified a recurring problem with aggre-gate gradation control during the period June 9, 1975, through November 18, 1975.

During this time, twenty-five Deficiency and Disposition Reports (DDRs) were written against aggregate which failed the gradation tests.

The Fort Worth Star-Telegram article dated April 4,1979, states that, "some tests on the sand and gravel... continually failed to meet stand-ards... despite Brown & Root efforts to prod Hunt into correcting the difficulty." This statement does not accurately represent the responsi-bilities shared between the two companies.

It was R. W. Hunt's duty to merely test material and ' port the results.

Brown & Root was in . charge of all other facets such as procurement and corrective action.

The newspaper article also quotes from the IE inspection rep - relative to the failure of the disposition of the DDRs to address and provide assurance that the previously placed containment f oundation base mat coacrete was of a uniform cuality.

This oversight on the part of Brown & Root was the subject of an item of noncompliance.

In response to the citation, TUGC0 conducted a detailed review of the approximately 6,000 cubic yard placement in order to verify the uniformity of the concrete.

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which ' id < > t meet specification were eithe.r rejected or return:d to the supplier where they were reprocessed, rewashed and retested <rior to being eturned to the site.

The newspaper article states in reference t; the response, "In a January 15, 1976, letter to the ~ NRC, TUCCO said that the problems had been corrected." It should be pointed out that the " problems" were not with the quality of the aggregate or concrete, but rather with the failure of the established administrative controls for Jeficiency and Disposition Reports to provide measures for proroct corrective action to preclude repetition.

A subsequent NRC inspection, Report No. 76-03, involved a review of the measures for corrective action and found a substantial improvement in the timeliness of reporting and closecut of Deficiency and Disposition" Reports.

The inspection also involved review of compressive strength tests for concrete placed during the period when out-of-specification aggregate gradation was identified.

The concrete strength test results we re f ound to oe substantially above the required strength.

An addi-tional corrective step which was implemented involved improving the handling and loading procedures at the aggregate supplier's facility.

Conclusions The statement by Individual "A" that aggregate tests were f alsif ted by him and his "forecan" cannot be refuted.

It was determined through discussions with licensee representatives that the supposed " foreman" was not, in f act, in any management position, but rather a Level II inspector who was in charge of the work.

Unsuccessful efforts were made to locate and contact the Level II inspector during this investi-gation.

During the interview with the alleger, he stated that the " dry-labbing" occurred for the first three to four weeks of his employment. Through other interviews, it was disclosed that this night shift crew had a reputation of laxity which some felt affected the quality of the testing.

Corrective action was taken by R. W. Hunt to reschedule these night shift employees.

The dubious testing was conducted in conjunction with other tests performed by suppliers on the same materials which served as pre-qualification *ests.

A review of the aggregate prequalification tests and of in-process concrete testing results gives confidence in the quality of the concrete such that any ralsification of test results on the part of the alleger would rot have had a significant adverse impact on the quality of the concrete, b.

Allegation No. 2 Individual "B" alleges that the equipment used to test aggregates was marked by him and "A" with wax and the equipment was not used during three months in early 1976 The test referred to in the newspaper article involved putting the aggregate in a sulfuric acid solution to test its long-term resistence to breaking down and cracking.

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. . was also made to the test " stinking-up" the laboratory.

From this de-scription, it was assumed that the test referred to was the Test for Potential Reactivity of Aggregates (Chemical Method), ASTM C289-71 (1976), but from the interviews it has become evident that the test alluded to in the allegation could only have been the test for Light-, weight Pieces in Aggregate, ASTM C123-69 (1975).

Findings Interview with Individual "A" Individual "A" stated that the person in charge of the chemistry lab rarely did his work and that he was of the opinion that this person , was falsifying test results.

He also stated that the equipment which was marked with wax was kept in a storage room.

Individual "A" was unable to identify the equipment involved f rom photographs of all possible equipment involved in the sarious tests which were shown to him by the IE inspectors.

Interview with Individual "B" The interviewee stated that equipment used to perf orm the Test for Soundness of Aggregates by Use of Sodium Sulfate, ASTM C88-76, was unused for several months.

He remembered the bad odor made by the test.

He stated that he asked the chemist about not running the test and was told that he didn' t of ten run the test because the results alw ys came out the same.

He stated that the particular test gave oft a bad odor which made the test unp opula r.

Interviews with Individual "C", "G," "H," "I," "J," "K," "L," and "0" These individuals expressed no knowledge of the allegation.

Interview with Individual "D" Individual "D" believes that the alleger was only trying to make trouble for R. W. Hunt since he heard the alleger remark that he would "get this company one way or the other."

Individual "D" did not sub-stantiate the specific allegation.

Interview with Individual "E" Individual "E" doesn't know of the stated aggregate test.

He could only allude to the organic impurities test which he believes was conducted properly.

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. Interview with Individual "F" -- Individual "F" was in charge of the tet t for potential reactivity of aggregates.

He stated that this test wts 'hc ubj ec t of considerable - technical discussion due to the dif ferent aiques used by many laboratories.

He further stated that the ot was subsequently elim-inated due to the recommendations of Erlin Hime Associates.

Interview with Individual "M" Individual "M" was of the opinion that the only test that smelled excessively was the Test for Lightweight Pieces in Aggregates, ASTM C123-69 (1975).

He further stated that if this were the test -- alluded to, then he was of the opinion that the allegation could be true considering the pc sons in charge of it at the time.

Interview with Individuai "N" Individual "S" stated that the test described in the newspaper article was the test for Potential Reactivity of Aggregates (Chemical Method), ASTM C289-71 (1976).

He based this on the fact that this test involved putting the aggregate in a sulfuric acid solution.

He further stated that this test was performed at the Chicago office of R. W. Hunt until the summer of 1976.

It was individual "N's" opinion that the test which smelled-up the lab was the Test for Lightweight Pieces in Aggregate, ASTM C123-69 (1975).

When questioned about the Test for Soundness of Aggregates by Use of Sodium Sulfate, ASTM C88-76, he stated that this test did not smell at all.

Investigation Effort The IE inspectors conducted the interviews with personnel in an ef fort to clarify the allegation with respect to the test involved.

A tour of R. W. Hunt laboratory was also conducted in order to view the equip-ment and discuss its usage with the cognizant licensee representative.

The newspaper article described the test which used the equipment that was marked with wax as a test which " stunk-up" the lab and it invcived putting the aggregate in a sulfuric acid solution to test its long-term resistence to breaking down and cracking.

The test involving sulfuric acid was identified as the test for Potential Reactivitiy of Aggregates (Chemical Method), ASTM C289-71 (1976).

A study conducted by the licensee's quality assurance staff of potential reactivity test reports generated by the R. W. Hunt was addressed in the Nuclear Regulatory Commission Inspection Reports No.

78-09 and 78-11.

The study was conducted as a result of a comment made by a laboratory employee that he was not surprised that a failing-12-467 OL?0

, . test was the first one to appear in three years since he felt that the person in charge of the test had been falsifying the results. The NRC inspectors determined that the cause of the test failures was the result of a continuing irregular weight loss as a result of heating the platinum dishes used in the dissolved silica portion of the test.

An independent investigation performed by Erlin Hime Associates subsequently determined that the aggregates in question were acceptable for use.

Individual "B" stated that the equipment used to perform the sodium sulfate test of aggregate was unused for several months.

This test determines thu resistance of aggregates to disintegration by saturated solutions of sodium sulfate which do not cause a bad odor to be given off when tue test is run.

It can, therefore, only be assumed that the -- alleger was mistaken in addressing the test for soundness in sodium sulfate.

The test for Organic Impurities in Sands for Concrete, ASTM C40-7), uses a reference standard color solution made out of potassium dich.3-mate and sulfuric acid.

The solution does not come into contact with the aggregate and is kept in a closed container.

These facts exclude the possibility of this test as being the one in question.

The test which was determined to have the potential to smell excessively or " stink-up" the lab is the test for Lightweight rieces in Aggregate, ASTM C123-69 (1975).

This test uses a mixtura el carbon tetracholoride and 1,1, 2, 2 - tetrabromoethane which are highly toxic, both by absorp-tion through the skin and inhalation.

Note No. 1 of the ASTM standard is a cautionary statement which states that these chemicals should be used only in a hood.

During a tour of the lab, the IE inspectors viewed the hood and discussed its usage with the chemist who acknowledged com-pliance with the cautionary statement.

Conclusion Based on these findings and on the fact that the test for potential reactivity was conducted in the Chicago of fice of R. W. Hunt prior to July 1976, which is one month after the alleging Individual "B" was dismissed, the allegation with respect to the potential reactivity test cannot be substantiated.

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Allegation No. 3 According to the Fort Worth Star-Telegram article, several unidentified quality control inspectors allege that shortcuts were taken on tests involving sizing of the aggregate and its moisture content.

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, . Findings ' Interview with Individual "A" Individual "A" affirmed the allegation, however, he could not address specific identifying records.

Interviews with I nd ivid ua ls " B, " " F, " "C, " "H, " "I, " " K, " "L, " "N," and "0" These individuals expressed no knowledge about the allegation.

Interview with Individual "C" . Individual "C" expressed hearsay knowledge only.

Interview with Individual "D" Individual "D" expressed no knowledge of the allegation.

He went on to state that he could not understand why anyone would falsify a grada-tion or a moisture test considering the simplicity of the tests.

Interview with Individual "E" Individual "E" knew nothing of the allegation but he suggested that some confusion on the part of the testers was due to the fact that when an aggregate test failed, the stockpile would be reblended and the test run again.

He stated that this was in accordance with the specification although it would appear to be a snortcut to an unaware person.

Interview with Individual "M" Individual "M" stated that he was aware of one procedural shortcut taken in the removal of moisture.

He stated that he performed the test using a hot plate to remove the moisture from the aggregate as opposed to using the time-consuming even method as required by the R. W. Hunt procedure.

He further stated that the Level II inspector in charge of the aggregate testing (the same Level II inspector identified in Allegation No. 1 and the "former fellow employee" referred to in paragraph 6 of the Nuclear Regulatory Commission Inspection Report No. 78-09) had warned him not to get caught using the hot plate.

He also stated that this Level II inspector would occasionally adjust test results if they were borderline failures.

Investigation Effor_t Allegation 1 and 3 were treated as being essentially the same due to the lack of a definitive time frame.

The reference to the Level II inspector has been the subj ect of pr'"ious NRC inspections (78-09 and 78-11).

American National Standard JSI N45.2. 6-1973, " Qualifications-14-467 042

. of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants," establishes minimum levels of capabil-ity for project functions.

A qualified Level I inspector is authorized to implement specific inspection and test procedures while the reporting of the inspection and test results may only be accomplished by a Level Il inspector.

Conclusions Although the allegation cannot be refuted, it appears, as with Allegation No. 1, that the tests in question were of a monitoring nature arsd not material acceptance tests.

The matter is deemed not to have an impact on the quality of the concrete.

. The one procedural shortcut which could be identified involved the use of a hot plate as opposed to tne oven required by ASTM C136-76, " Sieve or Screen Analysis of Fine and Coarse Aggregates." This standard requires drying of the sample in an oven to a constant weight at a temperaturc of 230 F.

Through conversations with cognizant TUCCO per-sonnel, it was learned that tests for information purposes only were also run on the material. These tests served as a preliminary indicator of material quality and employed the hot plate as a means of expediting the results.

The material acceptance tests would be subsequently run in conf ormance with the AST I standard.

Considering that the important point in the drying of the material was the requirement for constant weight, it is unlikely that the use of the hot plate would give signi-ficantly different results had the oven been used.

This philosophy was incorporated in the engineering approval to the request for use of the hot plate on tests for information.

As a result of this approval, the alleged shortcut was incorporated into the R. W. Hunt test for infor-mation.

It is not considered detrimental to obtaining test results for information purposes.

As with Allegation No. 1, no impact on the quality of the concrete can be identified.

d.

Allegation No. 4 Sources allege that despite earlier company assurances to the NRC, truck drivers added excess water to the concrete in transit from the batch plant ta the pour site.

Findings Interviews with Individuals "A," "F," "K," and "M" These individuals expressed hearsay knowledge only.

Interviews with Individuals "B," "G," "I," and "N" These individuals exprcssed no knowledge of the allegation.

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The corrective steps which were taken to ~ avoid further noncompliance included: a concrete placement training course for construction personnel which euphasized the necessity for a test lab representative to verify all batch t'ckets, assignment of . additional test lab personnel on large placement' to ensure that water would not be improperly added, and initiation of first line inspection of concrete truck discharges by Brown & Root Civii Engineering to ensure conformance with specification and procedure requit'ments.

Subsequent to the initiation of these corrective steps, two add tional instances where water was added were identified and documented 'n two Deficiency and Disposition Reports.

The first instance involved he addition of ten gallons and the second, eight gallons.

. The provisions of the batch plant procedure required that the water usage meter be set back to zero for each load.

The batch plant tickets include a provision for additional water which is called " water temper."

Consequently, any water added subsequent 'to batching is indicated on the usage meter.

Conclusions As a result of the corrective.ction initiated in response to the IE citation (Report No. 75-10) and in consideration of the requirement for zeroing of the water meter and the provision for additional water temper, the allegation cannot be substantiated.

This conclusion is also based on the interviews with personnel and on the lack of specific information on the part of the allegers.

The reference to the "401 mix" was not considered to be relevant to the question of safety because it was deter-mined that this mix was only used for tilt-up wall construction for the administration and warehouse buildings, which are not safety related.

e.

Allegation No. 5 Individual "O" alleges tha t he " flunked" a load (one truck) of concrete f or a slab in the Turbine-Genera tor Building, but that it was still placed.

Findings Interviews with Individuals "F," "G," "H," "I," "K," "L," "M," and "N" These individuals expressed no knowledge concerning the allegation.

Interviews with Individuals "A" and "B" Individuals "A" and "B" expressed hearsay knowledge only.

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Interview with Individual "C" Individual "C" stated that he saw truck drivers add water at the point of placement.

He fu-ther stated that the placements involved a Unit l~ containment interior pedestal placement, a Unit 2 containment wall placement, and a placement in the Unit 2 Turbine-Generator Building.

Interview with Individual "D" Individual "D" stated that the truck drivers did not care what the slump was and, therefore, he saw no reason for them to add water.

He also stated that they would always clean their trucks out icmediately after " they would be emptied so that no residue would be Icf t.

Interview with Individual "E" Individual "E" expressed no specific knowledge of the allegation but he did state that he doubted the accuracy and intent of the allegers because if the allegation were true, only the truck driver would be aware since it supposedly occurred in transit.

Interview with Individual "H" Individual "H" called the allegation " pure nonsense." He stated that the trucks were checked for slump at the point of placement.

Interview with Individual "J" Individual "J" stated that he could not understand how they could do it or why they would want to.

Interview with Individual "L" Individual "L" stated that he had heard of one instance where a driver was caught adding water to his mixer at the point of placement.

He stated that the truck was rejected and the driver dismissed.

Interview with Individual "O" Individual "0" stated that the addition of water to the mixers by the drivers was somewhat of a standard procedure for the "401 mix."

He said they did it to wash out the mixers.

Investigation Effort The IE Inspection Report No. 75-10, dated August 7, 1975, cited six loads of transit mix concrete for the Unit 1 base mat that had water added to them without approved supervision and signacure of the testing-16-467 045

. Interview with Individual "C" ,, _ _ Individual "C" claims that, "this sort of thing happended on a regular basis."

He alluded to a placement in the Reactor Building during which he witnessed several unsuccessful attempts by his co-worker (there were two inspectors at each test station) to run an air content test.

Ac-cording to "C," his fellow employee was incompetent.

He also made reference to a placement in the maintenance building wherein he rej ected two trucks for having exceeded the time in transit limit.

His concern was that the trucks were already in the process of discharging when he arrived at the placement.

Individual "C" also stated that he had falsi-fled some test results on a ten cubic yard placement in the cooling water intake structure (a non-safety related structure).

He said that " while the first air content and slump tests were performed and found to ba acceptable, the second set of tests were not performed.

"C" also stated that during a three cubic yard placement of patch concrete in the Fuel Handling Building, he falsified the rest records for the air content, slump and temperature determinations.

He also claimed to have knowledge of falsified records for a placement in a west wall of the Turbine-Generatar Building.

Interview with Individual "D" Individual "D" had no knowledge of the allegation but he did relate to circumstances surrounding the placement in the maintenance building which was referred to by Individual "C."

He stated that there was some concrete left over from a safe-y related placement and that it was sent to the maintenance building which is a non-safety related structure.

He also stated that when "C" crriv2d only about three cubic yards had been poured out.

The rest of the concrete was rejected and never placed acccrding to "D."

, Interview with Individual "E" Individual "E" stated that he knew nothing of the allegation, but that he could not understand it since the inspectors all had the authority to stop any placement.

Interview with Individual "0" Individeal "0" stated that the placement involved was a small, approxi-mately ten cubic yard, slab in the Turbine-Generator Building (non-safety related).

He also stated that approximately three quarters of the load had been placed by the time he got there.

Investigation Effort No direct investigative ef fort was made to address the allegation due to the non-safety related category of the Turbine-Generator Building.

The statements made by "C" concerning the Reactor Building, the cooling-18-467 046

. water intake structure, and the Fuel Handling Building were inspected in an effort to assess their veracity and impact on safety.

The qualifications of the co-worker referred to by "C" were reviewed and found to be in order.

The statement by "C" that he had falsified the second set of test results for a placement in the cooling water intake-structure cannot be refuted.

The same is true for his statement con-cerning the Fuel Handling Building.

Conclusions Although the falsification of test records on the part of Individual "C" may have occurred, no impact on the safety of the structures can be identified.

This determination is based on the minuscule amount of concrete involved and on the following facts: the strength of the - concrete in the Intake Structure was determined by concrete cylinder compression strength testing to meet specifications; the field tests for slump and air content met specification; the uniformity of batching assures similarity of properties; and the patch job in the Fuel Handling Building referred to by individual "C" above was not of a structural nature but rather filling of a void.

The placements in the Turbine-Cenerator Building and the Maintenance Building are not safety related and as such do not impact on the safety of the plant.

f.

Allegation No. 6 According to the Fort Worth Star-Telegram article, three different un-identified persons allege that during the Unit 1 Containment Building base mat placement on February 21, '976, "some concrete was placed without testing."

Findings interview with Individual "A" Individual "A" stated he had heard hearsay about a void in the contain-ment base mat.

Interview with Individual "B" Individual "B" was of the opinion that the Unit 1 base mat was placed so fast that all of the required concrete tests were not performed.

He could not identify nor substantiate the omission of specific tests.

Interview with Individual "C" Individual "C" stated that he heard rumors about the lack of testing during this placement but that he was not employed by R. W. Hunt at the time of the placement.

467 047-t9-

. . Interview with Individual "D" Individual "D" stated that he was not aware of any test omissions.

He also stated that R. W.

Hunt had recruited and certified inspectors, f rom Mason-Johnston Associates and from Brown & Root prior to the base mat placement in anticipation of the need for a sufficient number of testing personnel to cover the three 12 hour shifts which were required for the placement.

Interviews with Individuals "E," "I," "J," "K," and "L" These individuals stated that the placement in point occurred prior to their employement with R. W. Hunt.

.. Interview with Individual "F" Individual "F" stated that he was aware of hearsay about the placement being tto fast; but that he had no knowledge of any tests being omitted.

Interviews with Individuals "G," "H," "M," "N," and "0" These individuals stated that they had no knowledge of the allegation.

Investigation Effort A review was conducted of batch tickets and test records for the subject placement.

It was determined that 6,600 cubic yards of concrete were placed using two design mixes.

The review of the batch tickets assured the uniformity of batching while the review of the compressive strength test results gave confidence in the integrity of the base mat.

The specificatien in force at the time, along with the draft version of ACI 359, required that slump, air content, temperature and cylinders be taken every one-hundred yards.

This would require a set of sixty-six test results.

Sixty-seven QC test records were identified and, in all cases, the results were found to satisfy the specification requirements.

Conclusions The base cat concrete placement was adequately tested and properly batched.2/ The allegation was refuted.

g.

Allegation No. 7 Individual "K" alleges that during a placement of concrete in the Unit No. 1 containment wall in mid-1977, he failed a load of concrete with a slump of 4-1/4" inches (4 inches maximum specified) and that a foreman directed a lab technician to record a value of 4 inches on the card.

2/IE Inspection Reports No. 50-445/76-04; 50-446/76-04, dated April 20, 1976, and 50-445/76-06; 50-446/76-06, dated June 25, 1976.

- - 467 048

. Findings Interviews with Individuals "A," "B," "C," "E," "G," "J," "L," "N," and "0" . These individuals expressed no knowledge of the allegation.

Interview with Individual "D" Individual "D" stated that during this placement, there were three pump stations and six concrete inspectors involved.

He said that the slump averaging method of Gibbs & Hill Specification SS-9 was being used and that this method allowed them to go to a 5 inch slump if allowed by the . slu2p monitor's calculation of the running average of ten results.

He feels that the alleger was not aware or capable of the calculation in-volved.

He also said that the specification calls for the recording of data to the nearest quarter inch which he feels also contributed to "K's" confusion.

As for the statement that he directed a lab technician to record a value of four inches, he emphatically denied it.

Interview with Individual "F" Individual "F" stated that there was a strong dislike between the two individuals involved ("D" 6 "K"). Interview with Individual "H" Individual "H" was of the opinion that "K" was not aware of the slump averaging process.

Interview with Individual "I" Individual "I" stated that "K" was usually in the lab and that if he was in the field during that placement it was because of a shortage of in-spectors.

Because of this, he thinks "K" was not very knowledgeable about slump averaging.

Interview with Individual "K" Individual "K" stated that he was misquoted in the Fort Worth Star-Telegram article with respect to the disposition of the excessive slump.

He said he was at a slump testing station along with the principal tester "C," and "M" was the slump monitor.

He stated that "D" was also prcscnt.

What happened, according to "K," was that they had built up some safety margin (amount wasn't known) and that he subsequently heard 'll" say that there was no margin when a slump test result was 4-1/4 inches.

He stated that, contrary to what was stated in the newspaper, he did not know what was to be done about it at the time, but that he subsequently saw the card with 4 inches recorded.

He stated that the testing of cylinders was his main duty and that he was at the slump station as a backup.

-21-467 049

. Interview with Individual "M" , _ Individual "M'" stated that although he was the slump monitor, he does not remember this particular instance.

He explained that they were - operating with slump averaging and that one man at one test station could not know what the average was due to the fact tha t there were three stations.

He also stated that "K" was usually in the lab which could be the reason "K" did not fully understand the averaging techni-que and, therefore, could possibly be mistaken.

Investigation Effort A review was conducted of Gibbs & Hill Specification 2323-SS-9, Revision-4.

Section 5.2 states, "A tolerance of up to 1 inch above the indicated maximum shall be allowed for individual batches provided the average of all batches tested or the most recent ten batches tested, whichever is fewer, does not exceed the maximum limit, i.e., 4 inches.

Whenever the measured slump exceeds the indicated maximum by more than 1/4 inch, successive batches or truck loads as deposited shall be measured until the slump is within the maximum limit."

A review of slump test results for the period identified included the calculation of the running average.

This investigation disclosed that all the slump tesc results f ell within the values allowed and that the difference of 1/4" for the test in question would not have altered the acceptability of the concrete.

Conclusions Considering the fact that the alleged discrepancy involved only a quarter of an inch, and the fact that a review of the records indicated that this small amount did not influence the running average.

It is the IE inspector's determination that the allegation is not an influence on the quality of the concrete, even if it were true.

Since the concrete in question was being pumped, a reduction of slump would be expected to occur through the pipeline.

This factor alone would reduce the reported slump to a value under four inches.

This allegation is determined to be insignificant relative to the quality of the concrete placed.

h.

Allegation No. 8 Individuals "A" and "K" allege that cylinder compression test results were falsified by directions from the R. W. Hunt laboratory manager and individual "D."

46/ ":0-22-

t Findings Interview with Individual "A" . Individual "A" stated that he was told that other people were doing it.

He did not admit doing it himself.

Interview with Individual "B," "E," "L," and "M" These individuals stated that they knew nothing of the allegation.

Interview with Individual "C_' .. Individual "C" believes that it was done, but could not be specific about who did it or when it was done.

Interview with Individual "D" Individual "D" stated that he had nothing to do with the testing of cylinders.

He said he was in the field all of the time.

He also stated that a Level II inspector was supposed to be supervising the Level I inspectors while they were breaking the cylinders and that "K" was the person in charge of the cylinder break cards.

Interview with Individual "F" Individual "F" believes that neither the lab manager nor "K" would allow falsification.

He also stated that most of the R. W. Hunt technicians were dissatisfied with their wages which led to a lot of grumbling.

Interview with Individual "G" Individual "G" does not believe it would matter to the lab manager if a cylinder passed or failed and, therefore, does not beliave that aspect of the allegation.

Interview with Individual "H" Individual "H" does not believe "D" had anything to do with the cylinder breaks.

He stated that "K" was the only person in charge of the cylinder break paperwork.

Interview with Individual "I" Individual "I" said he prepared the cylinders for breaking by applying the capping compound but never tested any.

He did witness a lot of breaks but was never aware of any f alsification.

-23-467 051

a e Interview with Individual "J" It was individual "J's" opinion that the allegation was " stupid" because the R. W. Hunt laboratory manager was a smart man who wouldn'e cut corners.

He stated that the canager was conscientious but not a leader, which led to personnel problems.

Interview with Individual "K" Individual "K" stated that he believed he was misquoted in the newspaper article.

He stated that he had no knowledge of any falsification as was stated in the newspaper.

He said that some field-cured cylinders were 5 t he went to pick them up.

He -- found by the construction group and t noticed that they were overdue (passed the 28-day test inte rval). He also stated that he didn't know what kind of paper was turned in on the cylinders. When asked by the IE inspector whether he knew that field-cured cylinders do not necessarily have to be broken, "K" answered, "yes."

Interview with Individual "N" Individual "N" stated that the allegation could only be possible if the persons who did the test were the ones who falsified the results.

"N" also stated that "D" did not review the test results.

He stated that Level II inspectors were the ones who would sign the reports after review.

Interview with Individual "0" Individual "0" stated that "K" was responsible for the cylinder breaks until some inspectors complained because they also wanted to test cylinders.

He said that Level I inspectors subsequently broke cylinders on a rotating assignment basis.

Investigation Effort A review of the statistical analysis of concrete cylinder breaks for all of Class I concrete placed to date was conducted.

The statistical standard deviation of the results indicates that concrete of uniform strength and quality has been produced throughout the overall con-struction period.

It was identified in the IE Investigation Report No. 77-02, that individual "A" conducted cylinder 28-day compressive strength tests during the period September 3. 1976, through November 17, 1976 (see Allegation No. 9 as a related item).

Individual "K" denied any knowledge of falsification of test records.

-24-467 052

. Conclusion - It was determined that the allegation by individuals "A" and "K" that concrete cylinder compressive test results were falsified cannot be substantiated.

"A" does not admit doing it and "K" denies it.

The review of test result statistics did not disclose any apparent variation in the uniformity of the concrete produced to date.

If any falsitication did occur on the part of "A," it was possible only during an approximate 6 month period of time.

The uniformity of the concrete produced along with concurrent testing by other personnel derogates itt ' ignif icance. The Comanche Peak facility concrete batch plant and adjacent concrete laboratory are located approximately one thousand yards f rom the plant .. complex. The batch plant consists of a standard, automated, 200 cubic yard per hour unit and a standard 100 cubic yard per hour backup unit.

Both units are certified to the National Ready Mix Concrete Association (NFLCA) requirements.

On-site QA/QC documentation reflect that NRMCA tecertifications, QC inspections, and B&R QA/QC monthly surveillance checks have been conducted as required since May 19'5.

On-site records indicate that approxi..tately 478,000 cubic yards of concrete have ueen placed to date at the Comanche Peak facility.

An estimated 52,000 cubic yards remain to be placed.

During this investigation, the IE inspectors conducted a random sampling review of batch plant production printout tickets for the period March 1975 through December 1978 and found no deviations from the batching tolerances and design specifications.

This, not only confirms prior NRC inspection findings, but adds significantly to the conclusions drawn.

i.

Allegation No. 9 Unidentified sources have alleged that tests on concreta cylinder com-pression tests were run purposely faster than allowed by NRC Regulations / NRC sanctioned standards (Regulations or Standards not defined).

Findings, Interview with Individual "A" Individual "A" substantiates the allegation.

He stated that he saw quite a few that were done rapidly.

He also said it occurred during one entire Saturday morning.

It was not performed in front of the R. W. Hunt manager or when a QA inspector was around.

Interview with Individiual "B" No specific knowledge of incident.

-25-467 053

. . Interview with Individual "C" Individual "C" statc'1 that he f alsified records when the work load was heavy.

He stated that he was supposed to fast load to 50% of expected-break strength based on previous breaks but he fast loaded the test machine until breaks occurred.

He could not identify a specific instance or time period.

Inte rview wi th Individual "D" Individual "D" said he never saw it happen.

He stated that they were making 2-30 day spares, if 28-day break passed, the spares were never used and were thrown out.

" Interview with Individual "E" Individual "E" heard rumors but nothing specific.

He alluded to a personality conflict between B&R QA/QC manager and R. W. Hunt QC ma nage r.

Interview with Individual "F" Individual "G" stated that a B&R QA inspector observed individual "A" loading cylinders to 75% of expected break strength and wrote a noncon-formance report.

Individual "F" also stated that in April 1976, the R. W. Hunt replaced the night shift Level II inspector because of rumors regarding fast loading activities by individual "A."

Interview with Individual "G" Individual "G" stated that the problem was identified by an internal audit and was documented in a Nonconformance Report (NCR) which he offered to locate in a document search.

Interview with Individual "H" Individual "H" could not express any knowledge of allt;stion or such activity.

Inte rview with Individual "1" Individual "I" was not aware of any such activity.

He knew that B&R QA checked load rates every three months.

He stated that a chart is in plain view above machine giving load rate test results.

A67 054-26-

Interview with Individual "J" ,. Individual "J" could not express any knowledge of such an allegation.

He stated that a cha.-t above the nachine gave the loading rate to use.' Interview with Individual "K" Individual "K" stated that he was aware that fast loading occurred in the early stages of construction but that fast loading was never done ?.o 100% of the expected breaking load.

He stated that B&R QA identified the activity and it never occurred again.

He further stated that cylinder strength test resu'.ts were never falsitied.

Interview with Individual "L" Individual "L" stated that he did not believe it happened.

Interview with Individual "M" Individual "M" stated that allegation is true.

He obsarved individuals "A" and "B" fast loading cylinders to 80-95% of the expected breaking load.

Individual "M" further stated that he and individual "F" were transferred to the night shift in April 1976 by R. W. Hunt management as a result of rumors of " goof-off" activities going on during the previous nights.

~m Interview with Individual "N" Individual "N" stated that ftoc loading wcc possible, but only done by the individuals claiming to have falsified records.

Interview with Individual "0" Individual "0" stated that fast loading was done.

He said that the individuals doing it thought it was a big joke to see cylinders explode.

Fast loading was done when large number of breaks were required in one day.

He further stated that he had no knowledge of test results being falsified.

Investigatton Effort (1) The IE inspector obtained a copy of the B&R Nonconformance Report (NCR) (DDR No. C-473 R-1) dated J;nuary 24, 1977, and observed that the deficiency states in part, "It was obse rved tha t approxi-cately 3/4 of the load was applied to the concrete compressive strength test cylinder at the higher rate of loading rather than to just the first half of the anticipated load."

-27-467 055

' . . Attached to the DDR are R. W. Hunt reports No. HCp-21585 through 21598 for concrete test cylinders affected by this violation.

It is stated in the disposition of the DDR that, "Although the cited procedure was violated, the deficiency occurred while testing 90-day cylindu.s uhich were made for engineering information only.

In comparison with the 28 and 56-day test results, the test results of the 90-d,y cylinders are consistent with what might be expected in strength gain."

An engineering concurrence by the Architect-Engineer with the disposition of this matter is attached to the DDR memo, dated Feburary 14, 1977.

. The IE inspector also determined by a records review that the overspaed loading involved 28 cylinders broken at 90-days on a Wednesday, January 19, 1977, by individual "A," a principal alleger.

(2) As a comparable review, the inspectors conducted a random sampling review of the computer printout batch plant ptoduction tickets for the period March 1975 through October 1976.

There were no devia-tions from the batching tolerances and design specifications.

(3) An additional comparable 6 view was condacted of the B&R " concrete testing data management remords" which provides the statistical analysis of concrei e cylinder comprcssion strength tests prescribed by AC 214.

The statistical analysis, reflecting 8,264 concrete cylinder breaks of safety related concrete placed during the period Fbrch 1975 to January 1979, are within the acceptance standards prescribed by ACI 318 with average compression strengths exceeding 5000 psi at 28-day versus the minimum 4000 psi at 28-day.

Conclusions (1) It was determined that the alleged " fast loading" during concrete cylinder ccmpression strength testing was ident.fied by a B&R QA i inspector January 24, 1977, and that corrective action was imple-mented.

(2) There are no other incidents that could be specifically identified by the allegers c.r by the IE inspectors.

(3) The QA/QC testing records and employme.

records of allegers indicate that the " fast loading" could only have occurred during a limited time.

(On the order of three months) (4) The B&R DDR C-473-R-1, dated January 24, 1977, indicates that no detrimental effects to safety related concrete resulted when " fast loading" did occur.

-28-467 C5o

. (5) Cylinder compression strength tests were conducted by more than seven different R. W. Hunt Level I inspectors, on a rotating job assignment basis, during the period Bbrch 1975 through Fbrch 1978.

Since there were no wide variances in test data recorded by other Level I inspectors, the consistent batching records and the high concrete strengths achieved, the fast loading would not have an adverse ispact on the safety of the structures.

j.

Allegation Nc. 10 Two rormer R. W. Hunt employees allege that recertification of inspectors after the March 1977 NRC investigation was "open book" examinations and answers were given during the test.

.. Findings Interview with Individual "A" Individual "A" supported the allegation and also stated that when he first reported to work hc did not possess the minimum education and experience f or his job as defined by the R. W. Hunt procedures.

Interview with Individual "B" This individual expressed no knowledge of the allegation.

Interview with Individual "C" Individual "C" stated that he failed Level I soils test and that he was subsequently given answers (orally) by the laboratory manager and took test over using notes he took.

He also stated that to obtain his recertification (after March 1977) he needed only to have a supervisor sign the recertification form.

Interview with Individual "D" He did not administer any of the written or practical tests. He stated he was aware of one man being caught cheating and the man was terminated.

He thought the incident was comical because the answers were wrong anyway.

Interview with Individual "E" Individual "E" stated that to his knowledge the examintions were run correctly and above board.

Interview with Individual "F" Individual "F" stated that he was it.

'ved in administering tests and that he never permitted cheating nor open book examinations.

He further stated that he doubts the validity of the allegation.

-29-467 057

' . - . Interview with Individual "G" Individual "G" stated he had no knowledge of the allegation. He was aware methods of certification were changed in cbrch 1977.

. Interview with Individual "H" Individual "H" stated that if the allegation did occur he never was aware of it.

He further stated that the portion of the test involving concrete mix design was, and properly had to be, an open book test.

Interview with Individual "I" .. Individual "I" stated that he never took an open book examination. He was only told what material to study in preparation for the examination.

Interview with Individual "J" Individual "J" stated that he doubted the allegation.

Someone was always monitoring the examinations.

Interview with Individual "K" Individual "K" stated that he never witnessed an open book examination.

He further stated that examinations were given correctly, especially after March 1977, because B&R QA monitored the examinations. He felt that the forty hour study program was inadequate in view of the inexpe-rience of personnel hired.

Interview with Individual "L" . Individual "L" stated he was never given a test like that alleged.

He further stated that he has taken one test three times and hasn't passed yet.

Interview with Individual "M" Individual "M" stated that he doubted the allegation.

He further stated that his first certification was with answers given; however, recertifi-cations were, and are, given correctly as most gained enough experience and knowledge that it is not necessary to give answers.

Interview with Individual "N" Individual "N" stated that he gave examinations and never permitted, nor had he observed open book answers being given or used.

-30-0rB 467

' . < . Interview with Individual "0" ,, _ Individual "O" stated that he never took a test that was honest.

He further stated that the laboratory manager told him not to worry, he - would never lose his job if he failed an examination.

Investigation Effort No specific investigative effort was pursued.

Conclusions (1) The matter of qualifications and certification of the R. W. Hunt " Level I inspectors was a subj ect reviewed in detail during the March 1977 IE investigation.

The details regarding the resulting IE noncompliance citation and subsequent licensee corrective action are contained in the IE Investigation Report No. 50-445/77-02; 50-446/77-02, dated Fbrch 23, 1977.

(2) The IE inspectors cannot verify the validity of the stated allegation beyond the oral statements given.

3.

General Comments Expressed by Interviewees Interviews with Individuals "A" and "C" Individual "A" stated that he could not comment on the quality of the concrete with respect to the safety of the plant since he was not an engineer.

He also stated that he saw some concrete which, "I wouldn' t use in my patio."

Individual "C" also stated that he was not an engineer and, therefore, not qualified to comment on the safety of the plant.

Interviews with Individuals "B," "D," "E," "F," "G," "H," "I," "J," "K," "L," "M," "N," and "O" Individual "B" stated that he had no concern regarding the safety of the concrete but merely had intended te point out the poor management on the part of R. W. Hunt.

Individual "D" believes that the concrete is of high quality and he has no concern for the safety of the plant.

Individual "E" expressed no concern with the safety of the plant.

Individual "F" believes that the concrete is of high quality and that no safety concern exists.

He believes most of the allegations are a result of disgruntled employees.

-31-467 059

. . Individual "G" stated that he had no concern about the safety and that it was his opinion that the concrete was goad.

Individual "H" stated, "the worst concrete out here is ten times better than anything on the outside.

I was born and raised in Cleburne and when - the plant starts up I will continue to live there and I won't worry about the concrete."

Individual "I" stated that the concrete was good and that he had no safety Concern.

Individual "J" stated, "I live about five miles away and I intend to stay there cause I have no concern about the safety of the concrete."

.. Individual "K" stated that he had no concern with the safety of the plant.

He also stated that he was unhappy with the newspaper article because it was directed against the Comanche Peak plant and not R. W. Hunt as he was led to believe would be done.

He said that it was not his motive to question the concrete quality.

Individual "L" stated that he had no safety concern and would not move away from Granbury when the plant started up.

Individual "M" believes that the concrete at Comanche Peak is the "best poured in Texas."

He expressed no concern with safety.

Individual "N" stated that Comanche Peak had good quality concrete and that he had no safety concern.

Individual "0" expressed no safety concern.

4.

General Findings a.

As a result of the Region IV investigation relating to the ten alle-gations appearing in the newspaper articles, there is no substantive evidence that the overall quality and structural integrity of the safety related concrete has been impaired.

b.

During the period Fbrch 1975 through thrch 1977, which is the time frame of the allegations in question, 182,041 cubic yards of concrete were placed in safety related structures.

From the information obtained through personal interviews, the review of record files, and personnel employment files, it is evident tha t the alleged inspection improprieties, that warranted the indepth investigation, occurred during the above time frame.

c.

The alleged improprieties did not involve activities that caused an undue risk to the health and safety of the public.

-32-467 060 .

., . d.

Essentially all principals interviewed, including the named individuals in the news article, stated that their specific intent was to relate an expressed dislike for R. W. Hunt site management.

e.

With the exception of one individual, all principals interviewed, " including the named individuals in the news article, stated that they had no intent to question the plant safety or overall quality of the concrete structures.

f.

It appears that the alleged inspection improprieties involved only a few individuals of the approximately thirty-five inspectors engaged in identical or similar concrete inspection activities within the same time frame.

_ g.

As can be derived from the details section of this report, the alleged inspection improprieties that had the potential of impacting on the quality of the concrete were acknowledged by only three R. W. Hunt Level I inspectors with limited responsibility and assignments.

Records are in evidence that the three Level I inspectors were involved only during short time durations, as compared to the total 182,041 cubic yards placed.

In addition, correlation of production and test records do not reflect a measurable deficiency with regard to the concrete strength, serviceability or safety of the structures.

h.

The type of tests involved in the alleged improprieties were of a routine, first level, concrete production / placement monitoring function, as distinguished from that of qualification-final acceptance tests.

1.

With few exceptions, as identified in paragraph 2 of the report, the alleged improprieties had been previously identified by Brown & Root QA/QC, R. W. Hunt QC, TUSI QA and NRC inspections.

Corrective action had been implemented and recorded as evidenced by QA/QC inspection documentation.

5.

Additional Assertions During the investigation, the IE inspectors were informed of the alleged use et.'arijuana, inclugpng on-site sale, during the j ob tenure of f our R. W.

Hutt individ uals.- In addition, it was alleged that " dice games" were a common activity in one of the R. W. Hunt facilities.

NRC inspectors had no previou: knowledge of such activities; however, information regarding the use and sale of marijuana was provided to the licensee's corporate man-agement during a meeting between RIV representatives and Mr. B. R. Clements in the TUGC0 offices on Thursday, April 26, 1979.

There was no evidence that the above activities had a direct impact on safety related structures and/or components and these activities had not been observed by Region IV inspectors during previous site visits.

3/During the period October 1975 through January 1976 kb7

-33-

~ . ,,

. 6.

Referenced NRC Reports Because of the congruity of matters being investigated, the IE Investigation Reports No. 50-445/77-02; 50-446/77-02, dated dbrch 23, 1977, and 78-07, dated May 10, 1978, are by reference, an integral part of this report.

In addition, the f ollowing IE Inspection Reports and corresponding licensee replies are referenced for additional information regarding IE concrete inspection activites: IE Inspection Report 50-445/75-06; 50-446/75-06, dated April 28, 1975 IE Inspection Report 50-445/75-07; 50-446/75-07, dated June 11, 1975 .. IE Inspection Report 50-445/75-09; 50-446/75-09, dated July 14, 1975 IE Inspection Report 50-445/75-10; 50-446/75-10, dated August 7, 1975 IE Inspection Report 50-445/75-11; 50-446/75-11, dated August 28, 1975 IE Inspection Report 50-445/75-12; 50-446/75-12, dated October 1, 1975 IE Inspection Report 50-445/75-13; 50-446/75-13, dated December 12, 1975 IE Inspection Report 50-445/76-03; 50-446/76-03, dated April 1, 1976 IE Inspection Report 50-445/76-04; 50-446/76-04, dated April 20, 1976 IE Inspection Report 50-445/76-05; 50-446/76-05, dated bby 26, 1976 IE Inspection Report 50-445/76-06; 50-446/76-06, dated June 25, 1976 IE Inspection Report 50-445/76-07; 50-446/76-07, dated August 3, 1976 IE Inspection Report 50-445/76-03; 50-446/76-08, dated August 19, 1976 IE Inspection Report 50-445/76-10; 50-446/76-10, dated October 14, 1976 IE Inspection Report 50-445/76-11; 50-446/76-11, dated November 2,1977 IE Inspection Report 50-445/76-12; 50-446/76-12, dated January 3, 1977 IE Inspection Report 50-445/77-03; 50-446/77-03, dated March 31, 1977 IE Inspection Report 50-445/77-04; 50-446/77-04, dated May 17, 1977 IE Inspection Report 50-445/77-06; 50-446/77-06, dated >by 27, 1977 IE Inspection Report 50-445/77-07; 50-446/77-07, dated July 7, 1977 IE Inspection Report 50-445/77-09; 50-446/77-09, dated September 6, 1977-34-

. . .. . IE Inspection Report 50-445/77-10; 50-446/77--10, dated October 18, 1977 IE Inspection Report 50-445/77-11; 50-446/77-11, dated November 2,1977 I-i..spection Report 50-445/78-01; 50-446/78-01, dated January 30, 1978 IE Inspection Report 30-445/78-09; 50-446/78-09, dated June 6, 1978 IE Inspection Report 50-445/78-11; 50-446/78-11, dated June 29, 1978 IE Inspection Report 50-445/78-13; 50-446/78-13, dated September 18, 1978 IE Inspection Report 50-445/78-16; 50-446/78-16, dated November 17, 1978-- . - 35-467 063 }}