IR 05000461/1981015
| ML20053E216 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/14/1982 |
| From: | Livermore H, Phillip G, Walker R, Warnick R, Wescott H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20053E185 | List: |
| References | |
| 50-461-81-15, NUDOCS 8206070704 | |
| Download: ML20053E216 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/81-15 Docket No. 50-461-License No. CPPR-137 Licensee:
Illinois Power Company Decatur, IL Dates of Investigation: June 2-19, 1981, January 5 and February 5, 1982 Investigation At: Clinton Nuclear Power Station, Clinton, IL
.;f 7/M-Investigator
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Inspectors:
H. M. Wescott
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H. H. Livermore Rfma~~k Reviewed By:
R. F. Warnick, Director 8/IF/f2 Enforcement and Investigar*,n Staff
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R. Walker, Chief]
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Reactor Project Section 1C Investigation Summary Investigation on June 2-19, 1981, January 6 and February 5, 1982 (Report No. 50-461/81-15)
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Areas Investigated: TVenty-one allegations or matters of concern received from several sources were investigated. The investigation consisted of an examination of pertinent procedures and records, observations, and interviews of personnel and involved 214 investigation hours by three NRC representatives.
Results: As a result of investigating the 21 allegations, four items of noncompliance were identified - failure to assure proficiency of electrical QC inspectors, (Paragraph 3, Item 1), failure to follow procedures (two examples)(Paragraph 3, Items 2 and 4), failure to control n nconforming condition (Paragraph 3, Item 5), and failure to establish measures to preclude inadvertent bypassing of inspections (Paragraph 3, Item 6).
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REASON FOR INVESTIGATION On May 2 and 20, 1981, Region III received telephone calls from individuals who alleged, among other things, that QC inspectors were provided copies of certification tests before they took the tests. During the investigation of this allegation, other allegations were received and were investigated.
SUMMARY OF FACTS Region III received an allegation from two individuals, one on May 2, 1981, and the other one on May 20, 1981, that Baldwin Associates QC inspectors had prior access to certification tests. The second individual made additional allegations and, after the investigation was initiated, further allegations and concerns were received from employees and former employees.
On April 24, 1981, the licensee had advised the NRC Senior Resident Inspector that a charge had been made that an individual had an answer sheet in his possession while taking a certification test.
A charge was also made that there had been other instances of improper assistance being given to personnel to help them pass certification tests.
In response to these charges an investigation of the matter was conducted by a private investigator hired by the licensee and/or Baldwin Associates, and all Baldwin Associates QC inspectors were given a retest under controlled conditions during the period May 2-4, 1981.
The twenty-one allegations / concerns received during the NRC investigation regarding the Baldwin Associates QC activity were examined. Four items of noncompliance were identified during this investigation. One item is considered to be unresolved.
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DETAILS 1.
Personnel Contacted Illinois Power Company
- L. J. Koch, Vice President
- G. M. Brashear, Manager, Clinton Site
- A.
J. Budnick, Director, QA M. C. Hollon, QA Supervisor, Construction
- E. E. Connon, Director of Compliance
- D. G. Tucker, Compliance Supervisor
- R. W. Morgenstern, QA Engineer D. Schweickert, Compliance Analyst Baldwin Associates
- W. Harrington, Project Manager
- T.
Selva, Manager of Quality and Technical Services
- L. Gelbert, Manager, QC
- J. Findley, Kesident Engineer J. Harris, Senior Electrical Engineer, QC M. Gassman, Training Coordinator D. Cordy, QC Engineer D. Threatt, Senior Civil - Structural Engineer, QC L. Prather, Field Engineer, Containment T. McGuire, Raceway Engineer D. Richter, Lead Electrical QC Inspector W. Shinneman, Lead Electrical QC Inspector A. Trummel, Secretrary In addition to the above, 3 allegers and 16 QC inspectors were contacted.
- Indicates those present at the exit meeting on June 19, 1981.
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Introduction On April 24, 1981, the NRC Senior Resident Inspector at the Clinton site advised Region III that the licensee had informed him Baldwin Associates (BA) and Illinois Power Company (IPC) employees had charged that the Training Coordinator had given the answers to an individual who was taking the Level II Piping / Mechanical QC InsFactor Test earlier that day. A ger.eral allegation was also made that other individuals had received improper assistance in passing certification tests.
Through telephone conversations during the following week, the Senior Resident Inspector advised that a retest program for all BA QC inspectors was being undertaken. New tests were being devised which were intended to determine whether the inspectors possessed adequate knowledge to perform the inspections they had been conducting but were
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not intended to be a basis for recertificatior;.
It was also indicated that an investigator had been hired to investigate the allegation.
The investigator who conducted an investigation at the request of IPC and/or BA provided his findings to those organizations prior to the initiation of the NRC investigation. The private investigator concluded that the individual taking the test on April 24, 1981, did not have the answer sheet in his possession but had a second test paper he had picked up by mistake. He aise concluded that improper assistance had been given to inspectors in the past, but provided little specific information other than that it had occurred primarily in the electrical discipline.
On May 2, 1981, an individual alleged by telephone that the BA Training Coordinator had given the answers to a Level II QC inspector certification test to individuals before they were given the test. On May 20, 1981, Region III received a similar allegation, among others, from another individual. During the period of the investigation further allegations and concerns were received from site employees and former employees.
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Allegations and Concerns Based upon information obtained during the above contacts, twenty-one allegations / concerns were derived. These items and the information obtained regarding them are set forth below.
Item No. 1 Certification tests for some BA QC inspectors were invalid.
TWo individuals alleged that copies of the BA QC inspector certifi-cation test with answers were available to personnel before they took the test.
One individual alleged that inspector's tests "... Were about as hard to get as a telephone book."
Another individual said that in January 1981 he had conducted a session with about six new BA QC employees in which he reviewed the questions and answers of the Level I test they took the following day. The individual said that immediately before this review session, he had a discussion with the BA QC Manager during which the latter said he did not want anyone to fail the test.
Tne individual said the QC Manager saw the copy of the test questions and answers in his hand during the discussion and that he informed the QC Manager that he was going to review the test questions and answers with the inspectors. After this review, a lead inspector requested a copy of the test so that he could give a copy to each of the new inspectors. The individual said he gave a copy of the test to the lead inspector.
This individual also said that in February 1981 he took the vendor surveillance test.
The Training Coordinator gave him the test paper and, as he did so, he told him it consisted of ten questions and that numbers two and eight were true, the rest were false. This individual provided a signed statement regarding the above.
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Finding Prior to May 1981 BA used a standard set of tests for QC inspector certification purposes.
Electrical QC inspection personnel, including lead inspectors, advised that copies of the Level I and Level II electrical QC inspector tests were readily available on the site dating back to at least December 1980 or January 1981. Eight indi-viduals stated they had seen the test, were provided an answer key, and/or attended a test review session before they ' >ok the Level I
QC Electrical Test for certification. Two individuals had a similar experience regarding the Level II test.
Signed statements were obtained from four individuals confirming that they had attended the alleged review session, but that it took place in early February 1981.
The lead inspector who was alleged to have requested a copy of the test so he could distribute it, provided a signed statement that he did not recall giving a copy of the test to anyone. He stated that this was not necessary because he was aware that copies were already readily available.
From interviews with QC personnel it was determined that in most instances tests were taken under uncontrolled conditions.
In some instances they completed the test in a general office area and there was no effort to prevent them from discussing the questions with others or from referring to notes, an answer key, or QC procedures to obtain the answers. Ten individuals said they obtained help of one kind or another during the test.
Two said they were given the answer to one question. TWo said they had access to materials from which they could get answers. One stated he discussed the questions and answers with other persennel taking the test.
One individual stated he and another individual placed an answer key between them for ready reference while they took the test.
Two individuals said that lead inspectors who were giving them the test had implied some of their answers to true-false or multiple choice questions were incorrect by challenging them. They were then allowed to change the answers.
A review of the test papers of these individuals showed that several l
answers had been changed.
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All of the above related to electrical QC activities during the period December 1980 - March 1981.
Four individuals said that they had observed a lead inspector provide assistance to an individual while he was taking the Level II electrical test for certification in April 1981. Each one provided a signed I
statement to this effect. The lead inspector, however, denied any i
recollection of being present when the individual took the test.
The individual who had taken the test was unavailable for interview during this investigation.
Some individuals said that an individual, who formerly had been the Level III Electrical QC Engineer but who is no longer employed at Clinton, had provided improper assistance to personnel. One former Level II inspector stated that when he took the Level II test the
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former QC Engineer provided him with any answer he did not know.
Another Level II inspector stated he was given only one answer by the former QC Engineer when he took the test.
A third Level II inspector stated that the former QC Engineer gave him the answer key to the Level I test before he took that test and that he had the answers to the Level II test in a small note pad when he took that test.
Regarding his Level I test, this individual said that, at the instruction of the former QC Engineer, he intentionally answered three questions incorrectly to make the test appear legitimcte. A fourth individual stated he received coaching assistance from the former QC Engineer when he took the Level It test.
Regarding the activities of the Training Coordinator, two individuals stated that prior to their taking the test the Training Coordinator reviewed the questions and answers with them.
In one instance this review took place a few feet from two other individuals who were taking the test.
The two individuals who were taking the test on this occasion confirmed that this was done. They indicated that while it would have been possible for them to obtain some help under those circumstances, they did not.
Another individual stated that prior to taking his Level II piping /
mechanical test, the Training Coordinator had held a review session with him. The :, view included at least some of the answers to test questions. A review of the individual's test paper showed a whiting out material had been applied in the answer space for parts of two questions and an answer had been written over it.
The individual said he did not have any knowledge of the whiting out material being applied, but did indicate he had been prompted by the Training Coordinator to change one answer.
In this regard another test paper was noted on which whiting out material had been used and an answer written on top of it.
The individual, whose test paper it was, said he had not applied the whiting out material, but said that this was one of the answers he had been allowed to change when he took the test.
One individual stated that the Training Coordinator told him that the vendor surveillance test consisted of ten questions and that two answers, numbers two and six as he recalled, were true and the rest were false. This individual provided a signed statement to this effect. Another individual said that he heard the Training Coordinator make this statement on more thaa one occasion. He said he had heard the Training Coordinator make that statement to the QC Manager in early March 1981.
During an interview on sune 11, 1981, the Training Coordinator stated he had occupied that position since early February 1981. He said he was instructed by the QC Manager to conduct training lectures, to write a training manual, and to administer all tests.
He said there was no discussion between the QC Manager and himself regarding any pressure to get inspectors qualified. The QC Manager had said that individuals must qualify on their own and that he did not want anyone in the field performing inspections who were not qualified.
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The Training Coordinator said that about February 1981 he had become aware that the inspectors tests were being kept in an unlocked file cabinet near the desk of the Secretary of the QC Manager. He said that he arranged to have them placed in a locked file cabinet in the QC Manager's of fice. He said he was unaware that copies of the tests were available in the plant until late April 1981.
The Training Coordinator said he held review sessions with personnel before they took a certification test.
He said he reviewed the test questions and answers but that the review included other material as well and the inspectors did not know the questions reviewed were the actual test questions.
The Training Coordinator said that he had proctored most of the tests since he became the Training Coordinator. He said he did not allow any talking or reference to notes.
He said, with one exception, he did not give any answers to those taking the test.
He said one test contained one or two questions which he considered unfair because
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those taking the test could not be expected to know the answer.
i After an individual completed the test he reviewed it with him. He
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said he reviewed the test also as a teaching tool and he reviewed an l
Individual's test paper to point out incorrect and incomplete answers.
He discussed questions which were worded ambiguously and if, as a
result of the discussion, the individual wished to change his answer he was allowed to do so.
He said that he sometimes examined an indi-
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vidual orally about some questions and if this elicited some additional information from the individual, it was added to his answer on the test paper.
The Training Coordinator said that, at about the time he discovered
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the tests were being stored in an unlocked file cabinet, he heard an
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individual say the vendor surveillance test was easy because there were only ton true-false questions; two answers were true and the rest were false. He said the QC Manager's Secretary heard this remark.
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During 4 brief interview with the Secretary, however, she said she had
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I no recollection of hearing that statement being made by anyone. The Training Coordinator said that after he heard the remark he checked the test and found that it was true. He then brought the fact to the l
attention of the QC Manager and indicated to him the test should be l
revised.
The Training Coordinator declined to provide a signed statement l
regarding any of the above information.
Regarding the QC Manager's alleged knowledge of testing activities, as indicated above, the Training Coordinator and other individuals
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said that in about early March 1981 the QC Manager was made aware l
that the vendor surveillance test was inadequate. At about the same time, the Training Coordinator made him aware that the inspectors'
tests were accessible in an unlocked file cabinet.
In addition, one individual said that he had informed the QC Manager in mid-March 1981 that the test answers were available to the inspectors. On more than i
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one occasion during February and March 1981 a lead inspector had pointed out to the QC Hanager that the electrical QC inspectors were not qualified to perform the inspections. The lead inspectorsaid, on the other hand, the QC Manager was aware that they had passed the Level I test and therefore, had to know that something was wrong.
During an interview on June 11, 1981, the QC Manager said h-was employed as a Senior QA Engineer at the Clinton site on abou, June 30, 1980, and at the end of November 1980 he became the BA QC mnnager.
He also advised that the individual who was the Level III Electrical QC Engineer at the time he became QC Manager was transferred to Engineering in January 1981 and left the site about two months later.
The QC manager said it was his recollection that the Training Coor-dinator made him aware of the tests being in an unlocked cabinet in mid-April 1981. He said he took them and locked them up in his office.
The QC Manager said prior to the beginning of 1981 there had not been much electrical QC inspection work done. He said that there had been no pressure to hire and certify electrical QC inspectors. At that time he began staffing up in anticipation of increased workload in that area.
The QC Manager said that with the exception of one individual he had never scheduled a test for inspectors or instructed anyone to take a test and he did not know when personnel took certification tests until their qualification package was given to him.
He said his signature on the examination record in the Personnel Qualification file merely indicates that he saw those scores on the test papers. He said he does not grade or otherwise examine the test papers. He said he was-not aware that copies of the electrical QC tests were available to inspection personnel in the plant until mid-April 1981.
Regarding the execution of a waiver for certification of an individual who does not meet the ANSI N45.2.6 education and experience require-ments, he said he relies on input from his lead men regarding the individual's ability and the amount of on-the-job training he has received. He stated that although these certifications of Level I electrical inspectors are not limited, some inspectors are qualified to perform some types of inspections, others are not.
The lead men are advised as to which inspectors are to be assigned to specific types of inspections.
It was subsequently determined through an interview with a lead inspector that this is not done in a formal or-written manner. The QC Manager cited the example of one inspector who was not permitted to inspcct and accept any hardware. During a subsequent interview, however, a lead inspector advised that he had been instructed to give that inapactor some travelers which would involve the inspection of hardware.
Regarding the statement that he was aware test questions and answers were reviewed with personnel prior to their taking the test, the QC Manager denied any such knowledge.
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The QC Manager declined to provide a signed statement regarding sny of the above.
ANSI N45.2.6, Qualifications of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants, Section 1.4, Definitions, states:
" Certification (Personnel) - The action of determining, verifying, or attesting in writing to the qualifications of personnel." Section 2.2, Certification, states:
"Each person who verifies conformance of work activities to quality requirements shall be certified by his employer as being qualified to perform his assigned work." Section 2.2.4, Certificate of Qualification, states:
"The qualifications of personnel shall be documented in an appropriate form. The certificate shall include the following information:
(1) Employer's name (2) Person being certified (3) Activity qualified to perform (4) Level of capability (5) Effective period of certification I
(6) Signature of Employer's Designated Representative (7) Basis used for certification" Baldwin Associates Quality Control Training / Qualification Manual, Section 2.0, Purpose, states: "This manual has been prepared to estab-lish that the appropriate Quality Control personnel are indoctrinated, trained (when applicable), and certified for their respective levels in accordance with the applicable Code and regulations." Section 3.0, Definitions, defines certification as " written and documented testi-mony of qualifications." Section 5.0, Levels of Certification, states, in part:
" Certification Levels I, II, and III shall be in accordance with the intent of ANSI N45.2.6..." It further states, in part:
"In any case, when the requirements are waived it shall be documented by an explanatory letter of waiver approved by the Manager of Quality and Technical Services." Section 5.2, Levels I & II, states in Para-graph c:
" Level I and II, Quality Control Inspectors may be qualified on past experience, but shall not be certified until the applicable IcVel of written or oral examination is satisfactorily completed."
Of 17 Personnel Qualification files of electrical QC inspectors reviewed, 10 contained a waiver of the education / experience requirement for certification as a Level I Electrical Inspector and 3 contained a waiver of the education / experience requirement for Level II Electrical Inspector.
These waivers were "... based on satisfactory on-the-job training experience, education and demonstrated knowledge (examination)."
One Level I and three Level II certificates showed education / experience as one of the bases for certification; the others did not.
In all cases, the certificates in those files for Level I and II electrical inspectors show one of the bases for certification was examination.
Information obtained through interviews, indicates that the validity of the examinations of at least 13 of the 17 individuals was question-able. One of the individuals had not been certified. The licensee was therefore in noncompliance with 10 CFR Part 50, Appendix B, Criterion II
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In that activities affecting quality (inspections) were performed by individuals whora certifications of qualifications to perform the inspections were invalid or questionable (50-461/81-15-01).
l As indicated earlier in this report a program of retesting BA QC inspectors was undertaken because of questions that arose on April 24, 1981. The retesting was conducted by BA and monitored by a committee composed of three IPC personnel and one individual from Power Systems with D. G. Tucker, IPC Compliance Supervisor, acting as team leader.
Prior to the retest a two or three hour refresher course was offered with attendance being left to the option of the inspectors. Six of seventeen electrical inspectors, seven of seventeen piping / mechanical and three soils inspectors attended a refresher session. Fifty-six personnel were tested on May 2, 1981, and seven were tested on May 4, 1981. One inspector, who was on vacation during the retesting period, submitted his resignation to accept other employment upon his return to work on May 11, 1981.
Banks of 50 questions for each test wera developed by the Training Coordinator and discipline supervisors. Each test was composed of about 25 questions selected at random from the appropriate bank. A new test was composed in the same manner for those who took the test on May 4, 1981.
Of the 56 that took the test on May 2, five scored below the passing grade of 80%. TVo of those five were electrical inspectors whose scores were between 75 and 80 percent. Those individuals were further tested orally and upgraded to 80 percent. One electrical inspector, who scored less than 80 percent on May 2, 1981, had received an up-setting phone call from his home just before the test.
He was given a different written test on May 4, 1981, and scored above 80 percent.
Two others, one electrical inspector and one material control inspec-tor, were given an oral retest consisting of a random selection of questions from the respective banks and both scored above 80 percent.
All personnel interviewed indicated that, in their opinion, the retesting was conducted satisfactorily. The committee reported in a
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memorandum dated May 4, 1981, that all examinations, oral and written, l
refresher sessions and grading of examination papers were observed at all times by a member of the committee.
Item No. 2 Nonconformance Reports initiated by QC inspectors are j
discarded.
At least six of the current and former BA QC inspectors interviewed expressed concern that Nonconformance Reports (NCR) prepared by inspec-tors may have been discarded before they were assigned a serial number and, therefore, no record was retained of the conditions inspectors regarded as nonconforming. Exampics of this concern were provided to the NRC and are individually addressed in Items 7, 8, 10, 11, 12, 13, and 16.
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Finding Regarding the seven above, four were found to have been entered into the NCR system (10, 11, 12, and 16).
In one instance, NCRs had been destroyed, but the matter was documented by Field Change Requests (7).
In a second instance, the licensee did not consider a housekeeping problem to be an appropriate subject for an NCR (13) and in the third instance, the drafted NCR did not adequately describe the problem (8).
BA electrical QC inspection personnel stated that they had received oral instructions as recently as May 29 or 30, 1981, that they were to prepare NCRs in draft form. These would be reviewed by their lead man, a QC Electrical Engineer and the Level III Senior Electrical QC Engineer.
If all agreed that the matter was a nonconforming condition, a serial number would be obtained and a formal NCR would be prepared.
If, however, in the judgment of any of those reviewing the draft NCR, the matter was not suitable for handling by NCR, they had the pre-rogative of preventing it's being entered into the NCR system. The inspection personnel indicated they recognized the need for review and discussion to resolve questions of uncertainty about a given matter. They felt, however, that information concerning nonconforming conditions was being stifled since supervisors and/or management could take unilateral action to cancel a proposed NCR. They indicated that after they drafted an NCR, they are not in all caser informed as to whether it was processed or discarded. Unlike a NCR which is assi ned
a number and is subsequently voided on the basis that the matter does not constitute a nonconforming condition, discarded draft NCRs are not maintained as a matter of record.
During subsequent discussions with management, the licensee stated it was their opinion that supervisors and management personnel had the prerogative of determining whether a condition identified by an employee was or was not a nonconforming condition. This determination, in turn, governs whether the condition would be documented by a NCR.
This practice is not consistent with BA Project Procedures Manual, BAP 1.0, Nonconformances, Revision 6.
Paragraph 6.1.1 of this manual states:
"All Baldwin Associates personnel have the authority to ini-tiate a Nonconformance Report (NCR) when a nonconformance is suspected."
Paragraph 6.1.4 states:
" Quality Control / Technical Services inspector l
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(a) obtain a NCR number from the Project Engineering Document Coordinator." In addition, the practice is not consistent with the BA Quality Assurance Manual, Section 13.5, Requirements, which states:
"When an individual identifies a suspected nonconformance, the initiator shall document it on a Nonconformance Report, Exhibit 35.
The initiator shall request an NCR number from the Project Engineer who assigns the number from a log which he maintains." The licensee is therefore in noncompliance with 10 CFR Part 50, Appendix B, Criterion V, in that the procedures established to assure that conditions adverse to quality are identified and documented are not being followed (50-461/81-15-02).
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Item No. 3 A Level II lead inspector who does not have a certifi-cate to inspect concrete anchors has routinely reviewed travelers and signed inspection check sheets completed by inspectors.
Finding During an interview with the Level II lead inspector he stated that he had been routinely signing inspectors' completed concrete anchor inspection check sheets as the reviewer. He said it was his view that his signature attested to the fact that he had determined it was completely filled out.
He said he had not been certified as an inspector of concrete expansion anchors. During a review of QC Personnel Qualification files it was noted that, although several individuals' files contained Concrete Expansion Anchor Certificates, there was no evidence of his certification for such inspections.
BA Quality Control Training / Qualifications Manual,tahich was reviewed and approved on August 15, 1979, states, in part, that certification shall be in accordance with ANSI N45.2.6, and in Section 5.2, the manual states:
"The qualification examination for Level I and II personnel shall be developed to satisfy the requirements of the in-spectors' assigned tasks and responsibilities." ANSI N45.2.6 states in Section 3.2.2:
"A Level II person shall have experience and training in the performance of required inspections and tests and in the organization and evaluation of the results of the inspections and tests. He shall be capable of supervising or maintaining surveillance over the inspections and tests performed by others..."
A review of Form JV-550, Concrete Anchor Inspection Checklist showed that the information recorded thereon was largely by the use of check j
marks. Little, if any, technical knowledge was required by the individual reviewing the checklist.
I In view of all the above, the insp2ctor does not consider this particular matter to be an item of noncompliance.
Item No. 4 Inspections of the electrical fabrication shop have not been made on a daily basis as required by BA procedures.
TWo individuals stated that during May 1981 fabrication shop inspections were not performed during a two week period and that during the preceding l
month or more no inspections had been made.
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Civil / Structural and Piping / Mechanical Safety Related Reports, Forms i
JV-188, consecutively numbered from 3133 to 3334, covering the period from February 28 to June 10, 1981, were reviewed. These reports indicated that inspections were made of the electrical fabrication shop on February 5, 24, and 27, and March 2, 4, 6 and 9, 1981. These inspections are surveillance inspections which are conducted to assure
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activities are being carried on in accordance with approved procedures.
BA Quality Control Instructions for Raceway Hanger / Support / Installation Inspection Instruction, Revision 1, dated March 3, 1981, states in
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Paragraph 3.3 that fabrication area monitoring will be documented on
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Form JV-188 and, inspections will be made daily for all arauu. The
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licensee is therefore in noncompliance with 10 CFR Part 50, Appendix'B, s
Criterien V, in that daily inspections ir. the fabrication area of activities affecting quality were not performed (50-461/81-15-03).
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Item No. 5 A NCR prepared regarding some equipment being supplied by Eberline had been improperly closed out.
An individual stated that six NCRs were prepared on the basis of an inspection at a vendor facility, Eberline, in December 1980. One of
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the NCRs stated that some wiring did not meet the fire resistance requirement. The NCR was subsequently closed by indicating the equipment could be used as is provided the wires were placed in conduit. There was no verification that the wiring had been placed in conduit before the NCE as closed.
Finding NCR No. 4055, dated February 9, 1981, concerning Eberline radiation monitoring equipment cable which did not meet K-Specification No. 2928,
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was reviewed. The stated disposition on this NCR was:
Use cable as is provided it is enclosed in conduit." The stated disposition is self conflicting since the term "use as is" means no changesis needed but it indicates the cable must be enclosed in conduit. The disposition was in the " rework" classification which is defined in BA Project Procedures Manual BAP 1.0, Section 3.3 as: "a disposition involving the process by which a nonconforming item is made to conform to a prior specified requirement by completion, machining, reassembling or other corrective means." BAP 1.0 states in Section 5.7:
" Reinspection is required for implemented " Rework" or " Repair" classifications. The reinspection criteria shall be documented on the NCR as required." NCR 4055 did not provide for a reinspection. This NCR was filed in the document vault as a closed NCR. The licensee had not determined through visual inspection or other means that the cable had been placed in conduit before the NCR was closed on April 27, 1981. A BA Supplier Qualifi-cation and Control Activity Report, No. C-20263-2, dated May 4, 1981, identifies this NCR as c previously unresolved matter and states that the NCR was closed. On June 19, 1981, the BA QC Manager stated that on about June 17, 1981, the NCR had been obtained from the document vault and that it was reopened.
The licensee is in noncompliance with 10 CFR Part 50, Appendix B,-
Criterion XV, in that NCR No. 4055 was dispositioned "use as is" and closed rather than being dispositioned " rework" and being reinspected before being closed (50-461/81-15-04).
To assess the generic aspects of this concern, fifty closed NCRs were selected at random for review.
No problems were identified regarding their disposition.
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Item No. 6 Conduit strap hanger anchor bolts had been inspected and accepted as having met the requirement with no conduit in place.
It was stated on June 2,1981, that a large number of such anchor bolts had been accepted as having passed the torque requirement. The traveler had been signed and the bolts had been sprayed with green paint which indicates QC acceptance.
It was stated that the bolts would have to be loosened for the installation of the conduit and be retorqued. No provision had been made for the reinspection of the bolts after they had been retorqued.
Finding IPC QA Surveillance Plan and Report, File N6. Q24-81(06-17)-L, for the surveillance period June 8-15, 1981, was reviewed. This report states:
"Through this surveillance, it was found that conduit strap hangers using concrete expansion anchors are being inspected and accepted prior to the installation of the conduit. This necessitates the removal of the torqued nuts on the anchors, with subsequent re-torqueing and reinspection. Although the mechanism for the original inspection appears to be adequately described in project procedures, this retorqueing and reinspection process is only vaguely described in the Quality Control Instruction for conduit inspection.
It is felt that the present guidance in the QCI is not adequate to assure that retorqued expansion anchors are adequately reinspected.
Surveillance finding C-112 has been initiated to track this problem."
QA surveillance finding C-112 was transmitted to BA on June 17, 1981, for corrective action with a response required by June 26, 1981.
During the exit meeting held on June 19, 1981, it was stated by a BA representative that a procedure was in effect to reinspect and retorque the anchors at the time the. conduit was installed. No procedure, however, was made available to the NRC that specifically addressed this problem.
As indicated above, this matter was not identified by the licensee prior to this investigation. The licensee appears to be in 1.oncom-pliance with 10 CFR Part 50, Appendix B, Criterion XIV, in that the quality program did not provide a procedure for assuring the rein-spection of retorqued expansion anchor bolts (50-461/81-15-05).
Item No. 7 Tko NCRs had been discarded which had been prepared regarding drawings which showed conflicting orientation of two pieces of switchgear. One drawing showed the switchgear facing one direction while another drawing showed it facing the opposite direction.
Finding It was determined from BA personnel that a QC inspector had prepared two NCRs relating to drawings which showed an incorrect orientation
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of two switchgear items, 480V Unit Sub "B" OAP06E and 480V Unit Sub "A" 0AP05E.
Before the two NCRs were assigned a number and entered into the system, an electrical engineer indicated he did not consider the drawing inconsistency significant enough to document on a NCR. The electrical engineer preferred to document the correct orientation on a traveler. The matter was brought to the attention of the BA Project Engineer who agreed a problem existed but that NCRs were not appro-priate. The BA Project Engineer' determined that a Field Change Request (FCR) should be initiated and promptly incorporated into the travelers.
The draft NCRs were held until the FCRs, No. 3158 and No. 8159, were initiated. The NCRs were then destroyed.
The FCRs resolved the problem; however, the BA Quality Assurance Manual, Section 13, Nonconformances, states: "When an individual identifies a suspected nonconformance, the initiator shall document it on a Noncon-formance Report, Exhibit 35.
The initiator shall request an NCR number from the Project Engineer who assigns the number from a log which he maintains." This is an example of the item of noncompliance described under Item 2.
Item No. 8 An NCR was discarded which related to traceable and nontraceable steel being intermingled.
Finding It was determined that NCR No. 4555 dated May 5, 1981, had been prepared and that it had been voided, not discarded. The NCR was voided on the basis that the condition described was not a noncon-formance. The NCR described the condition as follows:
"At 104 column and AC line a collection of steel and various other material is interfering with a complete inspection of all electrical hangers in the laydown area. The steel interfering with the electrical steel is from the other crofts.
This material was left there when the crafts completed their work."
During interviews with the QC inspector and his lead inspector they both indicated the inspector's actual concern was not accurately described by him on the NCR. They stated that safety related trace-abic steel was intermingled with nonsafety related steel which was a nonconforming condition.
QC supervisory personnel did not seek additional information from the inspector regarding the condition found but voided the NCR as it was written. The QC inspector and the lead inspector stated that, in any case, the condition was resolved satisfactorily.
Item No. 9 No torquing criteria have been provided to QC inspectors for the inspection of A-307 and A-325 anchor bolts.
It was also stated that 3/4" and 1" A-307 bolts on bus ducts on the 737' elevation of the Auxiliary Building had been overtorqued.
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Finding The BA Quality Control Instruction for Raceway Hanger / Support /Fabri-cation / Installation Inspection Instruction, Revision 1, dated March 3, 1981, was reviewed.
Paragraph 4.3 of this instruction does provide torque values for some sizes of A-307 and A-325 anchor bolts. However, no torquing requirements are specified for 3/4 inch and 1 inch bolts.
The QC inspectors who expressed this concern stated that these bolts are not being inspected or signed off pending the issuance of accept-ance criteria for them. The concern that A-307 bolts were overtorqued was not examined during this investigation and is therefore considered an unresolved item which will be evaluated during a future inspection (50-461/81-15-06).
Item No. 10 NCRs prepared in May 1981 regarding the presence of sharp edges on hanger assemblies may have been discarded.
Finding Copies of all NCRs are furnished to the NRC Senior Resident Inspector.
Among those received during the period of this investigation were a group of seven NCRs, Nos. 4540-4546, all dated May 5, 1981. These were noted as dealing with sharp projections on finger assemblies at various elevations. The recommended disposition was to " repair grind all sharp projections and galvanox." These NCRs had not yet been closed.
Item No. 11 An NCR which had been prepared in about mid-May regarding the failure to inspect concrete expansion anchors within 21 days may have been discarded.
Finding
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NCR No. 4677, dated May 20, 1981, was reviewed.
It identified some expansion anchors that did not " conform to the 21 days inspection l
limitation." The NCR had not been closed.
I Item No. 12 An NCR, No. 4045, relating to damaged and repaired cables in GE supplied control room equipment, may have been voided.
l Finding NCR No. 4045, dated February 10, 1981, which related to repair of l
cables supplied by General Electric, had not been voided. The recom-
mendation portion of the NCR states:
"Use as is - all cables supplied by GE/NED have been received with a P.Q.C.
All have gone through a l
continuity and high potential dielectric check as part of this
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manufacturing process." The NCR was closed out on April 30, 1981.
Item No. 13 When successive housekeeping reports did not result in action to improve conditions in the control room,
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a NCR was drafted but was not entered into the system.
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Finding Document vault file SI-A7-1.3 (Housekeeping Reports, Form JV-510)
was reviewed. Of 14 reports reviewed, 3 pertained to the Control Building and were dated January 30, February 17 and June 1, 1981.
It was noted that Housekeeping Reports are not formal documents and there is no requirement that action be taken and documented regarding the contents of these reports. BA management personnel stated that action was eventually taken to improve housekeeping conditions in the control room and that the use of a NCR was not appropriate for such matters.
10 CFR Part 50, Appendix B, Criterion II, however, requires, in part, that activities affecting quality shall be accomplished under suitably controlled conditions, such as adequate cleanness. During a visit to the control room on June 19, 1981, it was noted that house-keeping conditions there were satisfactory.
Since the condition had been corrected, a finding of noncompliance was not made.
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Item No. 14 Vendor documentation letters were prepared stating
all required documentation had been received from the electrical penetration vendor, Conax, but all documen-tation had not been received.
Finding This problem was identified during an NRC inspection conducted during the period February 9 - March 9,1981, (Report No. 50-461/81-05) and was listed as an unresolved item pending receipt and evaluation of the a
licensee's response. This matter therefore was not pursued further during this investigation.
Item No. 15 Installed electrical hangers were cut down without the required traveler authorizing this action.
Finding A review of NCRs showed that NCR Nos. 4267, 4270, and 4303, dated March 17, 18, and 24, 1981, respectively, documented that electrical hangers were removed and reinstalled without proper authorization.
This was also a finding in a BA Qi. Internal Audit Report, No. I-169.
A review of Corrective Action Report No. 064 established that correc-tive action was initiated.
In addition, the individual responsible was terminated from employment.
Item No. 16 An NCR prepared regarding bent and distorted tubular steel may not have been entered into the NCR system.
Finding Two NCRs were identified which related to deformed tube steel. NCR No. 4714, dated May 21, 1981, related to a slight bow in the center of some tube steel. The disposition of this NCR was to use as is.
NCR 4499, dated April 24, 1981, identified eleven assemblies having tube steel with waves in it.
The recommended disposition was to use
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as is.
The design organization's disposition block on this NCR states:
" Accept BA recommendation.
Based on inspection of hangers, this con-dition is normal distortion caused by welding the seams and handling of the tube steel. No strength is lost."
The tube steel, which is used as a part of the system for hanging cable, was visual}y examined by the NRC inspector and it appeared to be acceptable.
Item No. 17 Craft supervisors have instructed workers to pass inspection hold points.
Finding A review of the BA NCR log entries for NCR Nos. 4196-4791 showed that this problem had been identified and documented on four occasions during the previous two months. These NCRs and their respective dates were:
No. 4457 dated April 20, 1981 No. 4679 dated May 13, 1981 No. 4780 dated June 12, 1981 No. 4791 dated June 16, 1981 To determine whether action had been taken to prevent recurrence, additional information was obtained on January 6 and February 5, 1982.
It was determined that on July 21, 1981, BA QA initiated a Corrective Action Request, Number 071, regarding missed hold points. The problem cause was stated to be lack of proper indoctrination of craft per-sonnel in the latest project procedures regarding hold points.
In August 1981 training sessions were given to foremen, general foremen, superintendents, and engineers.
BA QA prepared two reports, S-503 and S-504, to document surveillance of training sessions held on August 27 and 28, 1981.
Both reports state the training on the subject of hold points was satisfactory. A BA QA trend analysis revealed two instances of hold point violations in September, three in October and one in November.
In a memorandum to file, dated January 29, 1982, the BA QA Manager stated the Corrective Action Request 071 was considered closed but that "QA will continue to scrutinize NCR's/DR's of this nature for any future ad. verse trends.
Item No. 18 Heat numbers and/or Receipt Inspection Report (RIR)
numbers on riser hangers on the 781' elevation cannot be confirmed because they are covered by concrete or red paint.
It was also stated that the disposition of NCR 4117 (actually 4119),
which related to verification of hanger part heat and RIR numbers, was not satisfactory.
Finding Although it was not confirmed that heat numbers and/or RIR numbers were covered over, NCR 4119 addressed the problem of traceability of
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all hanger parts on the 781' elevation. A review of the disposition of this NCR was made by the NRC inspector and it was concluded to be satisfactory.
Item No. 19 There was no traceability maintained on shim plates used in electrical hanger installation.
Finding A previous NRC inspection, conducted during the period January 6 to February 2, 1981 (Report No. 50-461/81-03), resulted in a finding of noncompliance regarding the lack of traceability of steel plate material installed in some electrical hanger assemblies. The licen-see's response, dated June 1, 1981, to this noncompliance was that Procedure BAP 1.5, Material Identificttion, states that traceability of small miscellaneous structural steel material received in bulk containers, such as sheared filler plates, would be maintained until issued to the field for construction. The licensee also stated that this was consistent with other material installations of bulk com-modities and that unique piece traceability for sheared filler plate was impractical, not required, and would not provide a significant improvement in quality assurance. The licensee also stated that BA procedures had been revised as of March 30, 1981, to clarify trace-ability requirements for plate material. This response was considered adequate.
Item No. 20 Bolts securing cable pans to auxiliary plates require 400-500 foot pounds torque but no torque wrenches are available for use by inspectors which will measure these torque values.
Finding A licensee representative stated that torque wrenches capable of measuring 1000 foot-pounds are available on site.
These wrenches are normally used on bolts for structural steel. Further, a review of torque requirements for cable pan bolts showed that there are no torque values in the range of 400-500 foot pounds applicable to them.
Item No. 21 Some installed electrical hangers have surfaces which have not been covered by galvanox.
It was indicated that any surfaces that are exposed after an electrical hanger is installed are required to be touched up with galvanox.
Finding It was determined that the inspection check sheet for hangers contains an item requiring the inspector to check the adequacy of galvanox. The NRC Senior Resident Inspector advised that he receives a weekly hanger status report which includes the number of hangers inspected and rejected. This number is broken down to show the bases for rejection.
He advised he has noted that a lack of galvanox is routinely listed on
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these reports as a reason for some hanger rejections. No QC inspectors interviewed indicated they had accepted hangers having any areas unpro-tected by galvanox.
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(Investigator's Note: During a subsequent investigation, IE Report No. 50-461/82-02, the failure to apply galvanox was identified as an item of noncompliance.)
4.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during this investigation is discussed in Section 3, Item 9.
5.
Exit Meeting On June 19, 1981, an exit meeting was held with those IPC personnel identified in the Persons Contacted section of this report. During this meeting the allegations / concerns and the investigation findings regarding them were discussed.
6.
Enforcement Conference On August 6, 1981, an Enforcement Conference was held in the Region III offices to discuss the investigation findings. The meeting was attended by the following:
Licensee W. C. Gerstner, Excutive Vice President L. J. Koch, Vice President Region III A. B. Davis, Deputy Director R. L. Spessard, Director, Division of Resident and Project Inspection
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l R. C. Knop, Acting Chief, Projects Branch 1 (
F. W. Reimann, Acting Chief, Reactor Projects Section 1C i
H. M. Wescott, Projects Inspector, Division of Resident and Project Inspection H. H. Livermore, Senior Resident Inspector, Clinton Site G. A. Phillip, Investigator, Enforcement and Investigation Staff The licensee was advised that the investigation addressed 21 allega-l tions/ concerns received by Region III from several sources. Each item L
of noncompliance was discussed. Regarding the certifications of QA l
inspector qualifications which are considered invalid because of testing
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irregularities, the licensee was advised that consic.eration would be given to referral of the matter to the Department of Justice. The licensee outlined the actions planned to address the question of the adequacy of inspections performed by inspectors prior to their being i
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retested in May 1981. The licensee also described other. proposed actions regarding the noncompliances including changes in the issuance of Nonconformance Reports. The actions taken will be confirmed by the-licensee in his response to the noncompliances after they are trans-mitted to him in writing.
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