IR 05000454/1979018
| ML19296C889 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/21/1980 |
| From: | Foster W, Hayes D, Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19296C884 | List: |
| References | |
| 50-454-79-18, 50-455-79-18, NUDOCS 8002290026 | |
| Download: ML19296C889 (34) | |
Text
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION , OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-454/79-18; 50-455/79-18 Docket No. 50-454; 50-455 License No. CPPR-130; CPPR-131 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name: Byron Nuclear Generating Station, Units 1 and 2 Investigation At: Byron Site, Byron, IL, Hatfield Electric Company Offices, Chicago, IL.
Investigation Conducted: August 28, September 27-28, October 11-12, and November 5, 1979.
Investigator: J. E. Foster / /@ , / / f8.bM ll;/lP C Inspector: P. A. Barrett-l -{. f) m lau.. Approved By: C. E. Norelius, Assistant ,[I4/b to the Director h EkD ?' ? D. W. Hayes, Chief ,/l: /lf: Engineering Support Section 1 Investigation Summary: Investigation on August 28, September 27 through 28th, October 11 through 12, November 5, 1979 (Report No. 50-454/79-18; 50-455/79-18).
Areas Investigated: Investigation conducted in response to allegations made by former electrical contractor QA engineer; review of records, inspec-tion of installed equipment, and interviews with various contractor personnel.
The investigation involved the total of 60 investigation-hours on site by two NRC personnel.
Results: Two items of noncompliance (infractions) were identified in re-gard to the use of controlled documents (Paragraphs 7.11, 7.15) and, fail-ure to inspect concrete expansion anchors to inspection criteria (Paragraph 7.16).
8002290 03
REASON FOR INVESTIGATION On the morting of June 7, 1979, Individual "A", a former employee of the Hatfield Electric Company, the Byron site electrical contractor, contacted the NRC Region III office (RIII) by telephone.
Individual "A", a former quality assurance inspector, stated that he had been fired the previous day by the Hatfield site Project Manager. He stated that Hatfield did not have an adequate separation between the quality assurance (QA) and con-struction departments, and alleged other deficiencies.
On the basis of this information, an NRC investigation was initiated.
Summary of Facts Individual "A" was contacted the afternoan of June 7, 1979, and his con-cerns discussed in detail. He advised that he had contacted various media reprerentatives concerning his firing.
Individual "A" was interviewed at lent,th by two RIII representatives on June 12, 1979.
Individual "A" stated that his employment at the Byron site consisted of 1-1/2 years with Blount Brothers, and approximately two years with the Hatfield Electric Company. From information received dur-ing the interview, 24 allegations relating to Commonwealth Edison (CECO) and.hree contractors (Hatfield Electric, Blount Brothers, and Pittsburgh Testing Lab) were developed. These allegations are as follows: (paraphrased) 1.
Lack of quality assurance / quality control and construction department separation at Hatfield Electric.
2.
CECO audits identified inadequate QC independence at Hatfield. This was not reported per 10 CFR 50.55(e).
3.
Hatfield Electric Co. production department refused to honor a Stop Work Order.
4.
Individual "A" was told not to document deficiencies until he had the Project Manager's approval to do so.
5.
Quality assurance personnel do drawing control and "brassing" duties which are inappropriate to their job.
6.
There is no Quality Control review of drawings.
7.
The requirements of American Welding Society Structural Welding Code DI.1-75 are not being met, in that Pittsburgh Testing Laboratories is only doing a 10 percent visual inspection.
8.
An October 24, 1978 memo, concerning welds covered by fire-proofing materials prior to weld inspections, was destroyed.
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t 9.
There are no second shift QC inspectors at Hatfield.
. 10.
Hatfield is not complying with 10 CFR Part 21 Posting Requirements.
11.
There are improper terminations materials (90 degree connectors) on the backfeed cables.
12.
Cable pulls have been made :nt
- nspected and incomplete cable trays.
13.
Non-seismically designed cable tray hangers, using all-thread rods, were installed on elevation 383 feet.
14.
A February 13, 1979 memo indicated that a 10,000 pound cable pulling tension had been realized, even though 8000 pounds was the maximum allowable.
15.
There is a prohibition against use of an anchor bolt at the bottom of a concrete beam.
Yet these exist at elevations 346 to 364.
16.
Concrete anchors are not being checked for plumb, edge and spacing, or exposed anchor length.
17.
A January 26, 1979 request for information on CIS-4 reports was refused.
18.
Questions regarding electrical penetration shipping temperatures were not answered.
19.
Weld rod required to be painted yellow was not painted yellow.
20.
Two Commonwealth Edison employees are not qualified for their positions.
21.
A part of the steam tunnel was poured with 3,500 pound per square inch concrete and 5,500 pound per square inch concrete was required.
22.
In the 31 line wall, the stone / sand proportions were reversed.
23.
Delta Delta Midstates reirforcement bar placement was improper in late 1976 and early 1977.
24.
A Pittsburgh Testing Lab inspector was qualified by a test to which he was given the answers.
Due to other priority investigative effort, the investigation of these alle-gations was delayed. A special inspection conducted on July 3, 5, and 6, 1979, reviewed the documented Hatfield QA/QC program to assess the independ-ence of QA/QC from production functions and the allegation that a Stop Work Order had been disregarded by production personnel. The inspection indicated acceptable QA/QC independence from construction, and that no Stop Work orders had been disregarded. This inspection indicated that further investigation-3-
of allegations concerning Hatfield could be delayed witnout concern that fur- ' ther electrical construction would be deficient.
A total of 4 visits to the Byron site (August 8, September 27-28, October 11, and November 5,1979) were made during the investigation, and one visit to the Chicago office of the Hatfield Electric Company was made on October 12, 1979.
The investigation indicated that Individual "A" had been terminated by the president of Hatfield Electric rather than the Byron Project Manager as alleged. Separation of the Hatfield QA/QC and production functions was considered acceptable as written and in practice. Allegations related to the separation of QA/QC and production were not substantiated.
Several of the other allegations accurately indicated circumstances which had occur-red within the Hatfield and other contractors organizations, bat these incidents had been properly controlled under the respective quality assur-ance and quality control programs of the contractore.. During the investigation of the allegation that concrete expansion anchors were not being inspected by Hatfield Electric Co., pertinent records were reviewed. The records indicated that inspections for plumbness, edge and spacing, and exposed length of the anchors were not performed due to an apparent misunderstanding of inspection responsibilities.
Failure to establish an adequate program to assure that these inspections were executed, was considered an item of noncompliance with NRC regulations.
During the investigation, NRC investigators independently identified two occasions where nonconformances had been properly dispositioned, but not recorded on controlled documents as required.
This was considered a se-cond item of noncompliance with NRC regulations.
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. DETAILS s 1.
Personnel Contacted Commonwealth Edison B. Aken, Electrical QA Coordinator R. Beyers, Field Engineer A. Deming, Electrical D. Lindvall S. Forsha, QA Structural Coordinator J. Mikovilovich, Lead Structural Engineer T. McIntire, QA Supervisor M. Pendleton, Engineer, SCD G. Smith, Lead Electrical Engineer G. Sorenson, Project Superintendent Hatfield Electric Company W. Brock, President W. Gratza, QA Manager C. Donica, QC Inspector G. Van Lyssel, Project Manager Blount Brothers R. Donica, QA Manager Pittsburgh Testing Lab J. Troutman, Site Manager American Welding Society M. Davis, Technical Secretary Individuals Individuals "A" through "C" 2.
Scope This investigation focused on allegations provided by Individual "A" pertaining to activities of CECO and three contractors at the Byron 1 and 2 construction site. These allegations pertain to several activ-ities, as noted in the Summary of Facts section of this report.
3.
Background Byron units 1 and 2, twin 1120 megawatt electrical pressurized water reactors supplied by the Westinghouse Company, are being built at a-5-
. site approximately 4 miles south of Byron, IL.
Sargent and Lundy - Engineers is the architect engineering firm for the plant which is being constructed by Commonwealth Edison Company. These plants were granted an NRC construction permit on December 31, 1975.
Hatfield Electric Company is the electrical contractor for the site, responsible for c;nstruction of cable raceway and the placement of electrical wiring and connectors.
Blount Brothers is the contractor responsible for construction of site concrete structures. Pittsburgh Testing Laboratory is an independent testing lab which performs various tests for several contractors on site.
At the time Individual "A" was terminated from the Hatfield Electric Company a very small number of safety-related electrical cable pulls had been made at the Byron Site, approximately 40 safety-related cables having been installed at that time.
Quality assurance / quality control procedures for construction at the site include quality control inspections of installations, testing prior to final acceptance, and internal audits.
The inter-nal audits of each company by their own auditors are to assure that they are meeting the quality requirements as specified in the con-tract and in the codes they have committed to meet.
Commonwealth Edison also audits the contractors as additional assu ance that the construction is of adequate quality.
4.
Receipt of Allegations On June 7, 1969, InJividual "A" contacted RIII by telephone.
He stated that he had been a Quality Assurance (QA) engineer for the Hatfield Electric Company (Hatfield) at the Byron site for the past two years, but was terminated on June 6, 1979. He advised that he had been fired by the Hatfield Project Manager for Byron for raising issues and refusing an assignment to " brass" (check to see workers have reported for work as recorded) workmen on the second shift.
He stated that there was insufficient separation of the QA/ QC and pro-duction functions in Hatfield, as demonstrated by his firing.
Individual "A" also indicated that Commonwealth Edison (CECO) per-sonnel had audited Hatfield and noted this lack of separation, but had taken no action to correct the situation or report it to the NRC.
Individual "A" stated that prior to his firing, his supervisor, the QC manager, had argued against his termination and praised his work.
Individual "A" stated that the Hatfield Project Manager had disre-garded a "Stop Work" order, advised QC personnel not to cooperate with the NRC during inspections and to keep reports of deficiencies verbal until deficiencies were corrected (then document them), and criticized individual "A"'s involvement in Stillman Valley (a nearby town) town government.
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. He stated that some 90 degree connectors were improper and that some ' criteria for concrete expansion anchors were not being inspected. He also stated that inspections of welds to the American Welding Society codes (AWS DI.1-1975) were not being properly performed, as Pittsburgh Testing Laboratory (PTL) was only inspecting a 10 percent sample of such welds.
Individual "A" indicated that he had contacted several news media personncl, and planned a press conference. NRC pcarsonnel advised that an immediate investigation of his concerns could not be per-formed due to other priority matters, and requested that he delay holding a press conference until initiation of the NRC investigation.
5.
Interview of Individual "A" On June 12, 1979, two RIII personnel interviewed Individual "A" at length.
He amplified on the comments previously made, providing greater de-tail, and provided additional allegations, some of which pertained to site contractors other than Hatfield.
These allegations, and those received via telephone are included in the Findings and Summary of Facts sections.
While critical of Hatfield management personnel, Individual "A in-dicated that Hatfield field QC inspectors had not been told to ignore nonconforming items, or refrain from documenting such items.
6.
Site Visits 1.
8/28/79 - on site at Byron 2.
9/27-28/79 - on site at Byron 3.
10/11/79 - on site at Byron 4.
10/12/79 - visit to Hatfield offices, Chicago 5.
11/5/79 - on site at Byron, close out meeting 7.
FINDINGS 1.
Allegation - There is inadequate separation of the QA/QC and production departments at Hatfield. This was shown when I (Individual "A") was fired by the site Project Manager, who also hired me.
I was fired for raising too many problems and a refusal to " brass" workmen one evening.
Findings: - It was found that Mr. George Van Lyssel, Project Manager for Hatfield, is also Vice-President for the company.
He stated that in the initial stages of organizing the Hatfield site organization, he did recruit QA/QC personnel. He also stated that on the advice of Individual "B" the site QA manager, he re-commended that Individual "A" be hired.
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. Records on site indicate Individual "A" was hired on May 5, 1977, . ' as a QA/QC engineer-inspector, and promoted to QA engineer / lead auditor on August 4, 1978.
Internal Hatfield memoranda indicate that in March of 1979, a decision was made to recruit new personnel, including an Elect-rical Engineer, and a QA Manager, due to problems noted in prior CECO audits of Hatfield. Advertisements to this effect were placed in the Chicago Tribune newspaper, copies of which were provided to RIII personnel.
Interviews with Hatfield personnel indicated that there had been considerable friction between Individual "A" and Mr. Van Lyssel on several occasions: Generally the friction was caused by differing interpretations of various specifications. Several of the issues in question are treated under other allegations, Several statements received from interviewees also indicated friction between Individual "A" and field construction person-nel, including foremen.
Statements from Individual "A", Individual "B", and Mr. Van Lyssel indicated that Individual "A" had volunteered to perform "brassing" of workmen at the start of the second shift for several months.
This involves checking the workmen's brass identification tags to assure they are present. This assignment was not related to QA/QC duties, paid an overtime wage, and allowed Individual "A" the use of a company truck for a period of time during the winter months.
On May 15, 1979, Mr. Van lyssel requested Individual "A" (who was working on developing a training program) to perform brass-ing of workmen on the second shift that evening.
Individual "A" refused to comply with Mr. Van Lyssel's request.
From statements by Individuals "A" and "B", Mr. Van Lyssel was very irritated by Individual "A's" refusal, and made two statements to the effect that Individual "A" should look for other employment.
On May 16, 1979, Individual "B" wrote memos to Mr. Van Lyssel and Mr. Brock, President of Hatfield, protesting the previous evening's altercation.
Interviews with, and signed statements received from Mr. Van Lyssel and Individual "B" (see Exhibits I and II) indicate that they sub-sequently met with Mr. Brock, President of Hatfield, and discussed Individual "A's" job performance.
Individual "B" stated that he discussed the issue privately with Mr. Brock prior to a joint meeting of these three individuals.
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. Mr. Brock was interviewed by an RIII Investigation Specialist on . October 12, 1979.
Mr. Brock indicated that he met with Individual "B" and Mr. Van Lyssel, and later made a visit to the Byron site on May 24, 1979.
He stated that he then decided to terminate Individual "A", and documented this decision in a memo to Mr. Van Lyssel (see Exhibit III).
A signed statement to this effect is included as Exhibit IV.
From statements received, and documents reviewed, it was con-cluded that Individual "A" was terminated by the President of Hatfield after consideration of input from both Individual "B" and Mr. Van Lye- ' Records reviewed at the Byron site did not indicate that In-dividual "A" had raised significant quality questions.
Records reviewed indicated that the majority of questions raised by Individual "A" dealt with questions regarding implementation and inspection to various codes and specifications.
Hatfield personnel steted that a post-termination audit of the areas of responsibility assigned to Individual "A" indicated that he had not been fulfilling job requirements (see Exhibit V).
The allegation of inadequate separation of QA/QC and production is discussed further in section 2 below.
No items of noncompliance were identified.
2.
Allegation - A Commonwealth Edison Company (CECO) audit of Hatfield identified inadequate QA/QC and production indepen-dence. However, this was not reported under the requirements of 10 Code of Federal Regulations Part 50.55 (e).
Findings - CECO audit Report 66-79-190, of Hatfield conducted during May 2-11, 1979, was found to be the audit referred to by Individual "A".
The audit report indicates that the audit was performed to verify the adequacy of Hatfield's QA program as to organization, audits, and overall QA program implementation.
The audit report indicates four findings (problem areas), and one observation.
It notes the need for improved routes of com-munication between the site QA Manager and Company President, the need for periodic " spot checks" of the QC program, the need for annual re-training programs and requirements reviews, and-9-
. designation of an individual responsible for the over-all QC program. The " observation" was that Hatfield did not send QC manual revisions directly to CECO.
The results of this audit were presented to Hatfield at exit meetings on April 4 (off-site) and April 11, 1979 (on-site).
Hatfield answered the findings in the report in a letter dated May 31, 1979, detailing their corrective actions.
Hatfield personnel indicated that, partially on the basis of this audit, it was decided to revise their QC manual to provide for better routes of communication and provide for a clearer delineation of QC functions and responsibilities.
RIII personnel reviewed the section on organization of both the former and revised QC manuals, and found both to be acceptable.
The revised version does more clearly delineate responsibilitt- , channels of communication, and contains more detail on some points, including individual responsibilities.
10 Code of Federal Regulations (CFR) 50.55 " Conditions of Con-struction Permits", indicates in section (e) (1) that the permit holder shall " notify the Commission of each de'iciency which, were it to have remained uncorrected, could 'aave af fected adver-sely the safety of operations of the Nuclear Power Plant".
Section (i) indicates that one such a deficiency would be "a significant breakdown in any portion of the quality assurance program". None of the findings of the CECO audit were consid-ered as approaching the significance required to warrant a report pursuant to 10 CFR 50.55 (e).
Byron QA Site Surveillance reports 1377 and 1432, dated July 13, 1979 and August 22, 1979 reflect follow-ups of Audit number 6-79-190 by CECO to review corrective actions on the part of Hatfield.
No items of noncompliance were identified.
3.
Allegation - The Hatfield Production department refused to honor a Stop Work order.
Findings - This item was reviewed during a special inspection on July 3, 5, 6, 1979, (see IE Inspection Report 50-454/79-11, 50-455/79-11).
. A review of site records indicated that on April 12 through 26, 1979, CECO performed an audit of the installation of concrete expansion anchors. This audit by CECO noted the lack of a calibrated torque wrench on the part of Hatfield. Hatfield - 10 -
. documents and discussions with personnel indicated that Individual "B" initially agreed with this recommendation, and . wrote a memo to Mr. Van Lyssel indicating a formal "stop work" order on CEA installation.
Individual "B" stated that he provided this memo to Mr. Van Lyssel in the presence of Mr. Gordon Smith, CECO electrical coordinator, and they discussed the necessity for an immediate stoppage of CEA installation work.
Individual "B" stated that it was concluded that an immediate stoppage was not necessary, and he concurred in this decision.
A memo from Mr. Smith, dated May 1, 1979, clarified when com-pliance with the new CEA installation specifications would be required.
RIII personnel, during document reviews, noted that the CECO audit of CEA installations took place in the same time frame as the discussion of the "stop work" order and is noted in the CECO audit report on the Hatfield Electric QA program.
Individual "B" wrote a memo to file, dated June 18, 1979, docu-menting these details, and a memo which provided supplemental detail and formally closed out the proposed stop work order, dated July 5, 1979.
Individual "B" indicated that PTL final inspects all CEAs for torque, so that a change in calibration requirements for in-stallation equipment has no significant effect on the quality of the finally accepted CEA. Final acceptance of torque values of the installation is based on the PTL inspection.
No items of noncompliance were identified.
4.
Allegation - Individual "A" was told not to document deficiencies until he was given the Project Manager's approval to document them.
Findings - No information could be developed to support this allegation.
Statements by Mr. Van Lyssel and Individual "B" indicate that no such instructions were issued. They both noted, however, that the Project Manager had asked Individual "A" to process communications with CECO Construction through his office, for coordination.
No items of noncompliance were identified.
5.
Allegation - QA personnel do "brassing", drawing control, and other duties inappropriate with their jobs.
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. - Findings - Hatfield personnel stated that QA personnel do " brass" workers on the second shift to assure they are present.
They indicated that this assignment was separate from their QA duties, and additional wages are paid to QA personnel who accept the assignment.
There was no evidence that performing these duties interferred with any QA functions.
Records indicated that Individual "A" performed an extensive audit of drawing control in March, 1978, in response to a previous audit finding which indicated drawing control defici-encies. This was considered a proper response to an audit finding of this nature.
No items of noncompliance with NRC requirements were identified.
6.
Allegation - There is no Hatfield QC review of drawings.
Findings - There is no requirement for such a review, per appli-cable codes, specifications, or contract.
7.
Allegation - Weld inspections to the American Welding Society Code (AWS D1.1-1973) are improper, as PTL is only inspecting 10 percent of these welds.
Findings - Individual "A" stated that the AWS D1.1 structural welding Code, Section 6 (6.1-6.5), requires 100 percent in-spection by both the contractor and the owner.
Site documents indicated that the Hatfield QA Manager inquired concerning AWS inspection requirements via memos on October 14 and 17, 1977.
File memos reviewed indicate that a meeting between Hatfield and CECO took place on August 14, 1978, to clarify AWS requirements, including those of Section 6.
By memo of January 23, 1979, Mr. Gordon Smith informed Hatfield that their inspections satis-fied AWS requirements.
Due to identified weld inspection problems, PTL was requested to perform 100 percent re-inspection of all AWS weldments for a time period in 1978, until confidence could be established in the Hatfield inspection program. Then, PTL re-inspections or surveillances were reduced to a 10 percent random surveillance inspection which has been continued.
RIII personnel advised Individual "A" that the AWS D1.1 Structural Welding Code does not require inspections by, the " owner" if AWS welds are (100%) inspected by the contractors QC personnel. This would, in effect, result in 200 percent visual inspection of AWS - 12 -
welds. The action taken to provide overview inspections due to identified inspection problems was considered good practice, as was the reduction of the overview program when confidence in the contractor's program was achieved.
It should be noted that the 10 percent overview inspection presently performed by PT). is beyond AWS code requirements.
Individual "A" contacted RIII personnel by telephone on October 30, 1979. He stated that he had contacted the American Welding Society directly, and received a letter from them which he felt supported his interpretation of the AWS code. He advised that this letter, from Mr. Moss Davis, Technical Secretary of the AWS stated: "In the 1975 Code the Inspector is defined as the duly designated person who acts for and in behalf of the engineer (owner) in all inspections and quality matters within the scope of this code.
Unless otherwise specified by the engineer, an Inspector designated by the engineer should conform to ill the requirements of Section 6.1-6.5.
This includes, as stated, in 6.5.1, that the Inspector shall inspect all welds. The Code has no provision for any accep-tance sampling program and requires that all welds must be inspected for acceptance to code quality criteria. The contractor is also obliged to carry out visual inspections of all welds as defined in Section 6.6.3 of the Code".
The RIII Investigation Specialist contacted Mr. Moss by telephone to discuss this letter.
Mr. Moss advised that the NRC interpre-tation of AWS code requirements was correct, and that Individual "A" had misinterpreted his letter.
Please see Exhibit VI, page 16 of commentary on structural welding code.
The correct interpretation of the AWS structural welding code DI.1-1975 as applicable to the organization at the Byron site is as follows; the contractor producing welds to the AWS code must inspect (visually) 100 percent of the welds to assure that they meet AWS code requirements. The owner, CECO, may at its option designate an inspector or inspection agency to perform inspections above and beyond the minimum requirements of the AWS code, as it has done in the case of requesting PTL to perform an additional 10 percent surveillance of AWS welds.
No items of noncomplance with NRC requirements were identified.
8.
Allegation - A memo written on October 24, 1978 of problems re?- A to having welds covered by fireproofing was destroyed.
Fir. din.
- A review of the Hatfield files produced memos related to fireproofing prior to weld inspections dated October 5, 1978, October 23, 1978, October 25, 1978, and October 30, 1978. Also - 13 -
included was a letter to CECO de cd November 6, 1978 naming in-dividuals to sign approvals (on a check sheet) for fireproofing.
Memos dated October 23 and 25, 1978, had been generated by Individual "A".
Documentation indicated that hangers which were fireproofed prior to visual examination of hanger welds were identified, and that the fireproofing had been removed from connections so that the effective welds could be visually inspected.
Corrective Action to prevent recurrence was use of a " Check Sheet" to authorize are fireproofing work only after applicable veld inspections.
No memo dated October 24, 1978 was found. When recontacted, In-dividual "A" stated that he might have misjudged the actual date.
No items of noncompliance were identified.
9.
Allegation - There are no second shift QC inspectors at Hatfield.
Findings - The Hatfield QA Manager indicated that this was a true statement. He stated that a limited number of Hatfield personnel performed welding on '.he second shift, and their welds are inspected by personnel on t.:e day shif t.
These inspections are performed based on weld locations derived from weld traveler sheets generated by the welders. These weld traveler sheets indicate the location and drawing for the installations manufactured during the second shift.
No items of noncompliance were identified.
10.
Allegation - Hatfield is not complying with 10 CFR Part 21 Posting Requirements.
Findings - 10 Code of Federal Regulation Part 21 " Reporting of Defects and Noncompliance" required certain information to be posted as of January 6, 1978. The information to be posted included the regulations in Part 21, and telephone numbers of NRC offices to contact.
RIII personnel noted signs and memos posted at Hatfield containing the basic Part 21 information, and providing the NRC telephone number. The notices were considered acceptable, and from their discoloration, had been posted for some time.
Similar notices were also observed at CECO and other site contractors offices during the investigation.
No items of noncompliance were identified.
11.
Allegation - Some of the 90 degree electrical connections in-stalled in the control room on backfeed cables were improper.
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. Findings - Through discussions with Hatfield personnel and a review of documentation, it was found that improper connections on control room cable terminations had been identified in April, 1979.
In-house Observation Memo Number 53, dated April 25, 1979, identified the connectors utilized, their specifications, and the connectors actually requ' red.
Installation of the incorrect connectors was apparently caused by confusion as to the proper termination specification.
RIII personnel inspected the control room cable terminations, reviewed termination specifications and the action to correct the installations. Als terminations had not been corrected at the time of this inspection, but in process corrective actions were verified. A new specification list had been generated to preclude similar mistakes in the future.
While identification, corrective actions and action to prevent recurrence were accep-table, it was observed that the above actions had not been documented on controlled documents. This is contrary to 10 CFR 50, Appendix B, Criterion VI " Document Control", and is consid-ered an item of noncompliance with NRC requirements (50-454/79-18-01; 50-455/79-18-01).
12.
Allegation - Cable pulls have been made into untnspected and incomplete cable trays.
Findings - Discussions with RIII electrical inspectors indicated that cables installed as " temporary" (not in completed pan systems) were identified during an NRC inspection during February 7-9, 1979 (see IE Inspection Report numbers 50-454/79-03 and 50-455/79-03, Section II).
Inspection and proper disposition of these cables was considered an unresolved iteni.
Hatfield file documents indicate questions as to the installation of Auxiliary Backfeed cables were raised during a CECO surveillance conducted December 7, 1978, as documented in CECO letter BY 3472.
Individual "A", by memo to CECc, Cated April 30, 1979, requested information as to requirements for raceway systems to be 100 percent complete prior to cable pulling.
Mr. G. Smith of CECO replied to this memo, advising that omissions in cable pans should be bridged with plywood or other material.
The Hatfield QA Manager advised CECO by letter of March 8, 1979, that it was his decision to reject the " temporary" backfeed cables as permanent Class IE cables. CECO personnel advised that they felt use of the cables could be justified through 100 percent visual inspection. This matter is still considered as unresolved, as in Report 79-03, and will be covered in a subsequent inspection.
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13.
Allegation - Non-seismic hanger design was utilized at the 383 foot elevation.
Findings - RIII inspectors inspected cable trays on the 383 foot level, and located a short run of cable tra, supported by thread-ed rod, a non-seismic design. Drawings reviewed indicated that this was not a safety-related installation, and that the pans were as designed.
No items of noncompliance were identified.
14.
Allegation - A memo dated February 13, 1979, advised of a multiple cable pull where the specified pull tension was violated. Specified for a single cable was a pull tension of 8,000 pounds, and the measured tension was 10,000 pounds.
Findings - Hatfield files contained a memo from Individual "A" dated February 13, 1979, which recorded cable pull readings for a bulk cable pull.
Values recorded in this memo range from 7,400 pounds to one reading of 10,000 pounds. The memo states "there were three single conductor cables of this size pulled simultaneously, no criterion exists to suggest that maximum allowable tension should be different when pulling more than one cable at the same time".
Hatfield addressed the question of appropriate criteria to CECO in Byron letter BY-3670, dated March 7, 1979.
Mr. G. Smith replied by memo of May 2, 1979, providing a formula for calculating maximum allowable cable pull tension per cable given the number and material of conductors, and the circular mill area of each conductor. This value was used to calculate the maximum allowable tension per pull based on the number of cables.
A CECO Station Nuclear Engineerimg Department memorandum dated September 11, 1979, containing this information was issued on September 21, 1979. The memorandum establishes guidelines for cable installation, including use of tension meters to insure that the cable manufacturer's prescribed maximum pulling tension or maximum side wall pressure will not be exceeded.
Cables noted by Individual "A" in his memorandum were determined not to be safety-related. No items of noncompliance with NRC requirements were observed.
15.
Allegation - Anchor bolts had been utilized at the bottom of concrete beams at elevations 364 and 346, in violation of the concrete expansion anchor standard. No nonconformance report has been issued.
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Findings - RIII personnel toured the plant at the noted elevations. Expansion anchors at the bottom of concrete beams, holding small conduit (lighting) and several temporary attach-nents were observed during the tour.
Discussion with CECO personnel indicated that standards for concrete expansion anchors had undergone several changes. The standard BY-BR-CEA (Byron-Braidwood Concrete Expansion Anchor) is presently in revision 6 and further revisions arc anticipated.
They advised that anchors at the bottom of a beam were prohibited by the standard to insure that reinforcement bars and beams were not damaged during anchor installation.
CECO representatives advised that Sargent and Lundy had approved anchor installations (under beams) which predated it lementation of BY-BR-CEA.
RIII ' personnel requested to review the documentation of Sargent and Lundy's review and disposition, but none was available.
CECO personnel stated that this documentation could not be located.
This was considered as a second example of failure to use control documents to disposition a nonconformance, contrary to 10 CFR 50 Appendix B, Criterion IV. (50-454/79-18-02; 50-455/79-18-02) At the request of RIII personnel, a survey of the plant was made, and 85 locations of anchor bolts on the underside of beams were documented on CECO Field Change Request number 1140, dated September 19, 1979. CECO personnel advised that the chronology or anchor installation (prior to delivery of core drill bits) intured that no reinforcement bars had been damaged during insta.lation of the subject anchors.
16.
Allegation - Concrete anchors are not being checked by Hatfield for plumb, edge and spacing, or exposed length as required.
Findings - As previously noted in this report, it had been found that the concrete expansion anchor standard BY-BR-CEA, had gone through several revisions. Site documentation indicated that numerous meetings had been held between contractor and CECO per-sonnel to clarify installation and inspection responsibilities during the ongoing revisions of this specification.
A revt of Hatfield expansion anchor inspection records indicated that spaces were provided for these inspections on their inspection forms, but they had not been performed. Hatfield personnel stated their belief that PTL was performing these inspections.
PTL repre-sentatives stated that they were not performing these inspections.
A review of site files indicated that in letter BY-3930, dated May 16, 1979, CECO instructed PTL to include provisions for performing the inspections in question. On June 12, 1979, letter BY-4007 from PTL advised that they would only be responsible for (1) layout of rein- - 17 -
. forcement bars (2) torque testing of each anchor, and (3) ver-ification of full anchor nut engagement. A speed letter (651) dated May 22, 1979, noted that any other inspections would be the contractors responsibility.
CECO Audit 6 '.o-184 reviewed the contractor's concrete anchor installations. This audit, conducted during April 12-26, 1979, noted lack of a calibrated torque wrench at Hatfield, and the fact that some nuts were not fully engaged. No anchors were noted as being out of plumb during this audit.
From discussions with Hatfield personnel, it was apparent that concrete anchors had not bee., inspected for plumb, edge and spacing or exposed length. Failure to fully inspect concrete expansion anchors to the approved specification, BY-BR-CEA, was considered an item of noncompliance, contrary to 10 CFR 50 Appendix B, Criterion X. (50-454/79-18-03, 50-455/79-18-03) 17.
Allegation - Copies of CIS-4 reports were requested but none were provided.
Findings - CIS-4 " Progress Report for Byron Station Cable Information System" was reviewed by RIII personnel. These forms are broken into the following sections: B. Cable progress report, C. Cable length summary, and L. Cables / equipment report.
These forms were considered as not necessary for the Hatfield QC function, but do provide useful information as to electrical construction progress.
Hatfield files indicated a request for CIS-4 forms dated January 26, 1979. The request was denied by reply dated January 31, 1979, on the basis that the documents were not needed. A letter from Sargent and Lundy dated February 28, 1979, declined a similar request for CIS-4 forms in response to a February 15, 1979 request received from Hatfield.
No itemt of noncompliance were identified.
18.
Allegation - Questions as to shipping temperatures of elect-rical penetrations were not answered.
Findings - The Hatfield QA Manager indicated that Individual "A" had requested information on the minimum shipping temper-atures of electrical penetration assemblies. The QA Manager stated that he had discussed the question with CONAX, the pene-tration manufacturer. He advised that Individual "A" felt that Conax was committed to an IEEE standard that Conax had not endorsed.
- 18 -
. Discussion with CECO person.-l. and RIII electrical inspectors indicated that shipping temperatures are not a consideration for electrical penetrations as long as nitrogen purge pressure is maintained within required limits.
In a possibly related matter, Sargent and Lundy provided in-formation to CECO on December 7, 1977, that the minimum tempera-ture for pulling cables from their storage reels was minus 4 degrees fahrenheit.
No items of noncompliance with NRC requirements were observed.
19.
Allegation - Weld rod which was to be painted yellow was not painted yellow.
Findings - Hatfield records indicated that weld rod control audits were conducted on February 17, 1978 and February 28, 1978.
Hatfield in-house memo number 30, dated February 21, 1978, from Individual "A" to Individual " B" noted that approximately 150 pounds of type 7018 weld rod did not have the ends painted yellow as required.
A notation on the memo indicated the Hatfield Project Superin-tendent was advised of the problem and asked to correct it.
A memorandum dated March 2, 1978, noted that the problem had been corrected. On this memorandum, Individual "A" noted that " reinspection of these deficiencies conducted on March 1, 1978.
High-temp (1200 degrees fahrenheit) yellow paint is now avail-able at rod issue stations and all weld rods are color coded.
Unacceptable 11 ems from audits of February 17, 1978 and February 28, 1979 are now considered closed".
No items of noncompliance were observed.
20.
Allegation - Two CECO employees were not qualified for their positions.
Findings - RIII personnel reviewed the positic, responsibilities, education and applicable work experience of these individuals.
It was concluded that they met the qualifications required for their positions.
21.
Allegation - Part of the Steam Tunnel was poured with concrete having a final strength of 3500 pounds per square inch (PSI) when 5,500 PSI concrete was specified.
19 - -
Findings - Through discussions and a review of documents at . Blount Brothers Corporation (BBC), the Byron concrete contractor, it was found that this allegation was correct.
BBC deviation report, DR Q3-13A, indicates that on June 22, 1976, class BA-35 concrete (approximately 62 cubic yards) was placed in a portion of the auxiliary building feedwater pipe tunnel for Unit 1.
Documentation indicates that class BA-55 was specified for this installation. The section concerned was bounded by column line 7-10, Q-N, from elevation 357 to 363 (S&L drawing S-709).
The apparent cause of this mistake as noted in the file report was that " general concrete notes on S&L drawing S497 prescribe class BA-35 concrete for the Auxiliary Building.
The general notes on S-497 are superseded by a note on drawing S-709 which calls for class BA-55 concrete for the auxiliary building feed-water pi-a tunnel.
The note . S-709 was overlooked by all parties' CECO Nonconformance eport for Construction and Tests, F-20; dated June 27, 1976, locumented the nonconformance, which was reviewed by Sargent e d Lundy for disposition.
Based on concrete strength observed at 9. day concrete compression tests, the con-crete was considered acceptable and left in place.
Instructions to personnel to review design drawings and QA personnel review of pour " check out sheets" were shown as corrective actions. This was considered proper identification and disposition of the non-conformance within the required systems. No items of noncompliance were identified.
22.
Allegation - On the 31 line wall, the stone / sand proportions of the concr/.te mix were reversed.
Findings - Blount Brothers deviation report number Q3-206 was found te describe the situation alleged.
The report indicates that Individual "A" observed this deviation on March 23, 1977.
CECO nonconformance F-95 dated 'i/6/77, documents the problem and its disposition.
The nonconformance package indicates that concrete mix design M-35-7 had been recently introduced on site at the time, and was apparently misprogrammed at the concrete batch plant. Approxi-mately 128 cubic yards of concrete with the design weights of fine and coarse aggregate (stone) reversed were placed in an auxiliary building wall which was part of pour 2-C-401-0-4W (30 line wall).
- 20 -
, The nonconformance was dispositioned by review of compressive strength tests of the concrete in question which indicated the concrete met design strengths and was therefore acceptable. As corrective action, QA/QC personnel were assigned to review new design mix programming at the batch plant.
RIII personnel requested Blount personnel to review all earlier concrete pours to assure that similar errors had not occurred prior to their corrective action.
RIII personnel reviewed the results of this record review, which did not indicate any other such errors. No items of noncompliance were identified.
23.
Allegation - Delta Delta Midstate's (a contractor) reinforce-ment placement was improper in several cases in late 1976 and early 1977.
Findings - Discussion with the Blount QA Manager indicated that Individual "A" had performed an audit of Delta Delta Midstates (DDM) and participated in several preplacement surveillances of reinforcement positioning. He stated that the audits and sur-veillances had indicated some problems, which had been corrected as required by their QC program.
Blount records indicated that surveillances in whi;h individual "A" J,articipated included: Pour number Date 1-c-391-6-1-s 1-31-77 2-c-392-6-3-s 3-18-77 1-c-393-6-3-s 3-31-77 Records indicated that nonconforming items observed had been corrected prior to concrete placement.
Audits of DDM by Blount for the period 6/76-7/77 were reviewed by RIII personnel and found to be acceptable.
No items of noncompliance were identified.
Allegation - A PTL inspector was qualified by a test to which he was given the answers.
Findings - Individual "A" stated that Individual "C" told him he had been given a nondestructive testing examination during which a Level II inspector sat next to him and provided the answers to the test.
Individual "A" was not able to advise of the date of this test or the level or type of examination performed.
- 21 -
It was found that Individual "C" had worked for Hatfield during part of the time period Individual "A" was employed there.
This following Individual "C's" employment at PTL. He had left employment with Hatfield, but was presently employed by a site contractor.
Individual "C's" training records were reviewed by RIII per-sonnel. They indicated that he had taken a written exam to qualify for a level I certification to AWS D1.1 (visual in-spection of structural steel welding) on June 29, 1978. Site records indicated that one true-false question out of a tital of nine true-false questions and six fill-in questions had been missed on this exam for a test score of 93.
A copy of the exam was reviewed by RIII perronnel.
No changes or erasures were evident on the test form.
Individual "C" - privately interviewed by RIII personnel on September 28, 19iv.
He stated that he had not been given the answers to the PTL AWS D1.1 exam, but noted that some PTL exams are conducted as open book exams. He indicated that he had worked at Hatfield with Individual "A" and observed a series of personality clashes between him and the Project Manager. He stc'<d that there had been no prescore on him to overlook un-acce...able items while working as an inspector at Hatfield.
No evidence could be developed to show that Individual "A" had been improperly tested at PTL. No items of noncompliance were identified.
9.
Contact with Individual "A" - During and following the investigation, several telephone contacts were made with Individual "A" to gain additional information and to advise him of the progress of the in-vee gation. During later contacts, Individual "A" expressed dissatis-faction with the findings of the NRC investigation, and with their interpretation of the AWS DI.1-1975 strt. rural welding code.
10.
Exit Interviews Exit interviews were held at the close of each site visit during the investigation. During these meetings, the status of completed items of investigation were discussed, including those reflecting possible noncompliance with NRC Regulations. The licensee acknowledged the items of concompliance observed.
- 22 -
Atta.-hmen t s : Exhilit I - Statement of Mr. George Van Lyssel Exhibit II - Statement of Individual "B" Exhibit III - Memo to Mr. Van Lyssel 6td May 29, 1979 Exl'ibit IV - Statement of Mr. William Brock Exhibit V - Special Study of 9A Program (Hatfield) Exhibit VI - Page 16 of AWS Commentary - 23 -
I, George Van Lyssel, make the following statement freely and volun-tarily to Mr. James E. Foster, who has identified ' imself to me as an a Investigation Specialist, U.S. Nuclear Regulatory Commission.
Mr. Foster has informed me that I do not have to make a statement and that any state-ment I do make may be used in a judicial proceeding.
I am Vice President of Hatfield Electric Co., and Project Manager for the company at the Byron construction site.
I met with the President of Hatfield Electric and the sC Manager in early May to discuss, amoung 2ther issues, the hiring of an Electrical Engineer and the status of Indi.'idual "A", a QC inspector.
Previously, the deci-sion had been made to hire an Electrical Engineer. We discussed whether to demote Individual 'A" and place him under the supervision of this Engineer or to terminate his employment. On the basis of my observations, I felt Individual "A" was not performing adequately and I recommended his te rmina tion. However, no final decision on this was made at this meeting.
On approximately May 26th, Mr. Brock, the company President, visited the Byron site. During this visit, Individual "A"'s status w.s again dis-cussed, and Mr. Brock informed me he had decided to terminite Individual "A".
Individual "A" was therefore terminated during the first week in June.
I have not advised QC personnel to refrain from documenting deficiencies until I give my approval.
I did request that all communication between Commonwealth Edison station construction and Hatfield go through me.
I have read the above statement consisting of two handwritten pages, and it is true and correct to the best of my knowledge and belief.
James E. Foster Witness George Van Lyssel 10-11-79 h'RC 10-11-79 Exhibit i page 1 of 1
I, Individual "B", make the following statement freely and voluntarily to Mr. James E. Foster who has identified himself to me as an Investiga-tion Specialist U.S. Nuclear Regulatory Commission.
Mr. Foster has in-formed me that I do not have to make a statement and that any statement I do make may be later used in a judica.al proceeding.
I am presently employed by the Hatfield Electric Company at the Byron construction site, and supervised Individual "A" during his employment there.
In hay of 1979, Individual "A" and the Hatfield Production Manager, Mr. George Van Lyssel, had a disagreement over a work request (brassing of workers). This disagreement was preceeded by other disagreements with Individual "A", and he stated to Individual "A" that he should "look for another job" I initially disagreed with Mr. Van Lyssel's decision to recommend removal of Individual "A".
I went to the company President, Mr. Brc ., and presented my viewpoint.
Subsequently, myself, Mr. Van Lyssel and Mr. Brock met and discussed the matter. Following discussion, Mr. Brock indicated he had decided to replace Individual "A" Individual "A" was notified ci his dismissal some 3-4 weeks later.
I feel that the separation between QA/QC and production in Hatfield is adequate, and I have adequate communication with the company President.
I am not aware of any improper actions by Hatfield at this site, and feel that they are trying to produce quality work.
Mr. Foster has advised me that Individual "A" has commented that in-spectors were asked "not to document deficiencies until approved by the Production Manager".
I have no knowledge of any such instructions to inspectors.
Mr. Van Lyssel at one time advised Individual "A" that he was covering to many items by way of memos to file without first discuss-ing corrective actions or getting clarification.
Exhibit II page 1 of 2
Regarding QC inspections on 2nd shift a minimal (4-8 men) crew performs welding on the second shift, and visual inspections (QC) are performed on the basis of weld traveler information. Weld travelers are written when a hanger is completed, and contain information as to hanger identification and drawing number.
I have no current concerns regarding irregularities or adverse quality in relation to the work performed by Hatfield Electric Company at the Byron site.
I have read the above statement, consisting of three handwritten pages, and made corrections where necessary.
It is a true and correct represen-tation to the best of my knowledge and belief.
Signed Individual "B" 10-11-79 James E. Foster Witness 10-11-79 Exhibit 11 page 2 of 2
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I, William Brock, make the following statement freely and voluntarily to Mr. James E. Foster, who has identified himself to me as an Investigation Sepcialist, U.S. Nuclear Regulatory Commission.
Mr. Foster has informed me that I do not have to make a statement, and any statement I do make may later be used in a judicial preceeding.
I am President of Hatfield Electric Company.
The job performance of Individual "A" was discussed during a staff meeting held in March-April of 1979.
In early May, I met with both Mr. Van Lyssel and Individual "B", and discussed both a refusal by Individual "A" to " brass" workers and his overall job performance.
On May 24, 1979, I visited the Byron construction site.
During this visit, Individual "A"'s status was again discussed, and I made the de-cision to terminate his employment with the company.
This decision is reflected in a memo to Mr. Van Lyssel dated May 29, 1979.
I considered the inputs of both Ind;vidual "B" and Mr. Van Lyssel in reaching this decision.
I have read this written statement consisting of two handwritten pages, and made corrections where necessary.
It is true and correct to the best of my knowledge and belief.
James E. Foster Witness William Brock 10-12-79 NRC 10-12-79 Exhibit IV page 1 of I
. - HATFIELD ELECTRIC COMPANY 0.A. MANAGER'S SPECIAL STUDY OF THE BYRON Q.A. PROGRAM On 6/6/79, the individuel holding the position of Quality rurance EnCineer was terminatcC from that position.
It war it that s2nce scie cf the resp:nribilities of that posititr
- ayed c hey roit in the C. A. Fr
- gram, a special study of tne atus of the C.
A. Engineer's activities were in order.
Thir .t dy could then serve as a refercace 7oint in any future dir-cussions about the status or adequacy of these activities and could also serve as a starting point for the individual performing these functions after 6/6/79.
The O. A. Engineer's responsibilities included the following: 1.
Training of QA/QC personnel 2.
Inspection planning including verification that required inspections have been pe.Tormed.
3.
Review of all inspection reports for adequacy, completeness, and re-inspections.
4.
Controling the issuance and maintaining the cali-bration program for instruments.
5.
Audit planning and follow-up of audits performed.
6.
Coordination and control of weld traveler card system.
7.
Coordination and control of concrete expansion anchor traveler system.
8.
Control of Class I cable card issuance and routing point verification programs.
9.
Maintenance of correspondence files and inspection results files.
10.
Guidance and assistance to Q.C. inspectors.
The study of these activities was commensed on 6/18/79 and completed on 8/8/79 The study required almost 8 weeks of effort due to the fact that many deficiencies were dis-covered and had to be corrected during the study.
Exhibit V page 1 of 5-1-
..n.
w.
, w : w... i' ace 2 The ciudy included investigations of recordc.
.:c, metho-dology en 1;yed, and where possible a check of the trical items repiccented by the records.
Each item of re.
ribility was checke: individually with the follc.ing resul.. 1.
Training - Although all perccr.nel are ade: .ely cualified to perform their jcbs, additicn: 1 1.mr inir.c to up-Grade personnel was not properly per.:..ed.
Additional training had, in some cases, been ini-tiated but not followed up on or completed.
Records were disorderly and required some effort to re-arrange.
Questioning of inspectors revealed that the Q. A. Engineer had given very little personal attention or instruction when performing training.
The basic approach used was to give an indiv$ dual a list of items to read and to let the matter rbst at that point.
This will be followed-up by the Q> A. Manager.
2.
Inspection planning and verification - No evidence existed which could indicate that inspection planning or verification had been performed.
There was no evidence that inspection progress had been tracked in any area.
This is currently in the process of being corrected by the Q. A. Manager.
Review of inspection reports - It appears that this activity was adequately performed.
Although, there were a few cases of reports in the files which lacked a review.
The reports lacking a review were reviewed during the study by the Q. A. Manager.
4.
Calibration program - All the records were in general disorder.
There were only 8 folders in the file cabinet, yet there are about 100 instru-ments under Q. A. cont,rol.
The calibration log had not been maintained and uas not current.
The instrument sign-out log used for issuance of tools was not the one specified in the procedure.
The master list of instruments was not current and had erroneous entries.
In a few cases, the same Hatfield I.D. No. was assigned to more than one instrument (HE-10 was assigned to 3 different items).
Some I.D. his. were shown as having been assigned to an instrument, but there was no record of which instrument.
A few items were overdue for calibration.
Exhibit V page 2 of 5
.Lacc ; . The: .re no manufa turer certificate. c 1; Eny of 6 B crimp tguls.
Some T 6 E ' or _ ere . in u .ut had no nur. Der assiEned.
Tnis of u act; was also ident:fied as beinc def_.ent our
- he June, 1979. Er.ercy Inc. audit t.
Ine p::q It took ap;.ro:.ir.a.ely four week . . efft:. ty the Q. A. Mantger and the Q.
C.
1:.rpector, R.
F.. Donica, to correct the situation.
5.
Audit planning and follow-up - No schedule or log could be found to indicate that audit planning had been performed.
The Drawing Control audit of 11/8/77 is missing a response and follow-up.
Some of the bi-weekly E-7018 weld rod control audits were not performed at the specified periodicity during early part of 1979.
A number of field activities have never been formally audited (such as cable installation, cable pan systems, exposed conduit, receiving, etc.). 6.
Weld traveler card system - The weld traveler cards and records were in general good crder.
However, the cards had not been processed in a timely manner.
There was a 6 month backlog of processing.
This required two days of effort by the Q. A. Manager to bring up to date.
7.
Concrete expansion anchor traveler system - The records and logs for CEA travelers were in very bad shape.
a.
The CEA traveler log was not current and lacked necessary information to trace reports.
b.
8 reports were on file, sho:n as complete, but with no PTL inspection report.
c.
6 completed reports vers on file showing PTL rejection but with no follow-up for corrective action.
d.
14 reports were on file with uncertain status.
Half completed copies were on file.
The originals were missing.
e.
40 report numbers were shown as having been assigned to field personnel, but there was no record of to whom they were assigned.
Exhibit V page 3 of 5
.... M A':I. 0 E h '. J:, ZULi . Face 4 f.
Report num' C50 thru 100' were skippc' for no appm.
.. reason.
We are current 1.
at report m er 1695.
g.
There werc : cases of the same report number bein; uced for two different rept: c.
h.
281 blank reports were on file and star.pa.
" void" for no apparent reason.
i.
100 blank reports were on file with numbers assigned which were already assigned to completed reports.
This activity took two weeks of effort by the Q. A. Manager to correct and is now operating properly.
8.
Class I cable card and routing point verification - This program was in complete disorder and not current.
There was a backlog of approximately 500 cable cards requiring routing point veri-fications and/or follow-up on pan system status.
No follow-ups were made on a large number of routing points needing corrective actions.
The status of this program was uncertain and required a special inspection of the entire pan system.
The Q.
A.~ Department performed a special inspection of the pan systems during the week of 7/16/79 and brought all records up to date.
This program is now operating properly.
9.
Maintenance of correspondence and inspection results - The correspondence file had numerous unnecessary extra copies of correspondence.
Some original copies were missing, with xerox copies in their place.
There were also many non-correspondence items in the correspondence files.
A check of the inspection results showed many reports filed out of sequence and in wrong folders.
Two embedded conduit inspection reports are missing, reports #37 and #38 of 1978.
Also, one duct run inspection report was missing, report #15.
These repor+s were on file prior to 6/1/79.
Additionally NCR #6 only has a xerox copy on file.
The original is missing.
No adequate corrective actions can be taken with the missing reports.
10.
Guidance and assistance to Q. C.
inspectors - Questioning of inspectors indicated that very little was ever done in this area by the Q. A. Enginee:. Exhibit V page 4 of 5
.. J.
s an. '. ... _ 6 _' D1 e5 . . . was made of the During the course of the study, a - - .,nmer O. A. Engineer's personnel file _; was disco'.:: red _f.et all original documents had been rc c and replaced with .:erox copies.
With the exception of the missing _... ection reports unde.- its: number 9 above all other deficient;tc noted in th s repor: . ; /e been or are in the process of beir.r ::rrected by the C. A.
.5..ager and the C.
C. Inspector, R. E. L;.'.aca.
Q. A. Manager cc: W. A. Brock - President G. Van Lyssel Files Exhibit V page 5 of 5
t J i l i
6. Inspection f)af1A 6.5.6 It is important that the inspector properly identify . GeneralRequirements " elds that hase been inspected and accepted. WelJs in-spected and rejected for any reason should also be identi- . , fied Any idenufiable mark agreeable to the contractor and The first four paragraphs (6. l-6.O refer to the inspection owner may be used.' of base metal, w eldmg pmcedures, equipment, and person- ' nel insobeJ in uelding.
The duties and responsibihties of the inspector,' when 6.6 Obligations of the Contractor one is retained by the ou ner, are stated in 6.1 through 6.5.
He performs the quah:> auurance function for the Engineer The responsibihties and obligations of the contractor and owner. His responsibility under the Code is to assure uith respect to inspection are gisen in 6.6. The contractor that the work is pertomied m. confonnance with the pro-is responsib!c for hn work; therefore, quality control must , ~ snions of the Code as c} pressed in either acceptance or be perfomied by his own inspectors. The contractor's in-spection personnel should make checks necessary to com-h ' E " " " P n or as auth ty to stop the work if the C ' contractor eletts to pnxced after he has been informed that matenals, proc-esses, welder qualification, workman.
6.6.3-6.6.4 The contractor must sisually mspect all ship, or o.' er pros nions relating to the contract are unac-welds and perform any nondestructive testing required by ceptable. Howeser, proceeding with unacceptable prac-the contract. It is the contractor's obhption to insure that
tices may lead to rejection and to extensise repairs.
all wcidments meet the appropriate quahty requirements Draw ings, specifications, and other pertinent documents of the Code.
relating to weldmenti, to be inspected must be made avail-able to the Inspector. He should be paniculariv a!crt to any 6.63 he comractor.s responsibihty with respect to . revisions or changes in the origmal contract documents.
nondestructive testing of weldments is defmed in 6.6.5 ' ' When an inspector finds that inconect or defectise mate-and m rial, improper procedures, inadequate equipment, c un-Inspect n at appropriate stages is important to econom> ' "" #
- "#I I
"' "C# I"
- '
- "I quahfied yarsonnel are being proposed or being used for welding, he should inform the contractor and the Engineer and c rrected early in the work can save both time and e
at the t;arliest practical opportunity.
m ney, w elders, supervisors, and inspectors should be alert to identify defects and potential defects during fabncation.
Visual mspection cannot disclose intemal discontinui-
6.5 Inspection of M,ork and Records ties in completed weldt When nondestructive testing is . not specified in the contract document. it must be auumed 6.5.2 When the Code provisions have not been fully that in the judgement of the Engineer the welds can tolerate
met, it does not necessarily mean that the weldmg is some internal imperfections. When the contract does not poor; it does increase the possibility of prodtag unac.
specify nondestructive testing, but it is subsequently re- , j reptable weldments for structural or contractual reasons quested by the ow ner, all costs related to such nondestrue'- or both, tive testing must be paid by the owner, except as prosided e in 6.6 5.
l 4. The term inspettor as defined m the Code is the Engmeer's _._ (owner's) duly deugnated mspector. All other inspectors, for 5. The s se of a steel stamp may provide a site for mitiating g
the purposes of thn Commentary, are either contractor per-fatigue or other cracks and generally n not recomme.;ded for T sonnel or outside agencies' personnel retained by the contractor.
use on m eld or base metal subject to tensile stress.
Exhibit VI l
Page 1 of 1 i i .. v.,, y v.v. -. pp
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