IR 05000483/1977011
| ML20011A523 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/10/1978 |
| From: | Foster J, Gallagher E, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20011A456 | List:
|
| References | |
| 50-483-77-11-01, 50-483-77-11-1, NUDOCS 8110130512 | |
| Download: ML20011A523 (26) | |
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U.S. NUCLEAR REGULATORY COMMIS:.20N OFFICE OF INSPEC ICN AND ENFORCE."NT RECION III Report No. 50-483/77-11 Docket No. 50-483 License No. CPPR-139 Licensee:
Union Elec:ric Company
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P. O. Box 149 St. Louis, MO 63166
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Facility Na=e:
Callaway, Unit 1 Investigation At:
Callaway Site, Callaway County, MO
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Inves tiga: ion Condue:ed: Dece=ber 13-14, 18-22, 1977, and January 3-6, 1978
. K kk Investiga:ec:
.5 E. Foster
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Inspector:
E. J. Gallagher a /#
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L Approved by:
R. 1. Spessard, Chief O// C / /f Engineering Support See: ion 1 Inves t igation Su==ary Investigation on Dece ber 13-14, 18-22, 1977, and January 3-6, 1978 (Recor: No. 50-483/77-11)
Areas Inseected:
Special, announced investigation into allegations regarding deficiencies in quality control and i= proper concrete rsin-forcement; r;?iew of pertinent records, inspections of construe: ion ac:ivities, and in:erviews with personnel.
~he inves:igation involved 160 inspector-hours ensi:e by two NRC inspec: ors.
Re s u l,:s : Of :he areas inves:igated, three i:e=s of noncompliance
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were ' identified in :he area of quality con:rol (Findings section).
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INTRODUCT!ON The Callaway Uni: I nuclear power plant, licensed to the Union Elec:ric Cc=pany, is under construction in Callaway County, Missouri. Bechtel Power Corpora: ion is the Architect-Engineering firm for the plant, which is being constructed by Daniel International Corporation. Th e f acility will be :he firs: of a number of Standard Nuclear Uni: P owe r Plants, or SNUPPS units.
REASON FOR INVESTIGATION
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Following comple: ion of an earlier investiga:ica in:o allegations of i= proper prac: ices a: the Callaway construction site, representatives of NRC Region III (RIII) met with Individual
"A", on Dece=ber 13, 1977, to discuss the findings of that investigation.
Individual "A" indicated that he did not accept certain of :he NRC investigation fi?. dings (see IE Investigation Repor: No. 50-4S3/77-10), and provided addi:ional infor=ation relating to the allegations investigated. In addi: ion, Individual "A" made new allegations cor.cerning construction prac: ices at :he Callaway site.
Follewing receipt of this infor:ation, RIII re-exa=ined the findings of the previous investigatien in light of the new information provided, and initiated investigation into the addi:ional allegations received.
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SUMMARY OF FACTS on Oc:cber la,1977, Mr. E. F. Porter, of the St. Louis Post-Dispatch, contac:ed RIII.by telechene and indicatsd that he had received allega-tions concerning cons:ruction at the Callaway, Uni: 1 plan: from Individual
"A".
On Oc:ober 19, 1977, :vo RIII reactor construe: ion inspec: ors interviewed Individual "A" at his residence. Also present during :ha: interview were Mr. E. F. Porter and Ms. Kay Drey. A RIII Inves:igation Specialist, accompanied by two reactor construction inspectors conducted a subsequent in:erview a: Individual "A's" residence on October 28, 1977, to assure that all pertinent concerns had been iden:ified. During both of these in:erviews, Individual
"A" made sta:eeents alleging improper cens: rue: ion practices at th e Callaway si:e. Twelse specific allegatiens were derived from the s tatemen:s =ade by Individual
"A" during the interviews.
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On Nove=ber 19, 1977, Ms. Kay Drey contacted RIII and indicated that Individual "A" had =ade allegations concerning the adequacy of rein-force =en: in :he :hird lif t (a ten foot high circular section) of :he reactor contain=ent wall.
!cdividual
"A" was ag?in con: acted, and two additional allegations were ob:ained.
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These allegations were investigated by RIII personnel during visits to :he Callaway cons truction site on October 26-28. November 2-4, and 21-22, 1977, and the findings of that investigation are reported in IE Investigation Repor: No. 50-483/77-10. One item of noncompliance with NRC rrgulations, related to control of construction dr34ings, was develoaed as a result of that investigation.
On December 13, 1977, RIII personnel met with Individual "A" to dis-cuss the findings of the earlier investigation. After long discussions, RIII personnel =ade arrange =ents with the licensee to visit the Callaway-si:e with Individual "A", so that he could point out areas of his cen-cern. At the si:e, discussicas were held among Individual "A", licensee and contractor personnel, and the NRC represertatives.
During these discussions, Individual "A" made additional allegations regarding cons: rue: ion and provided clarifying information relative to allegations previously inves tigated.
The allegations were discussed with Individual "A" during the December 13,
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1977 evening meeting until early morning, and were again discussed with Individual "A" during the normal day shif t working period on December 14, 1977.
Two additional allegations were developed during the course of investigation.
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Representatives of RIII eisited the Callaway construction site during
Oecember 18-22, 1977, and conducted interviews, reviewed records, and were present during meetings between Individual "A", licensee and con-tractor representatives. Audio tape recerdings were made during two confidential interviews between Individual "A" and NRC representatives.
Audio tape recordings were also made during meetings where Individual
"A" discussed his allegations with NRC, Union Electric, and Daniel Inter-national representatives. A transcript of the recordings =ade during these meetings is at: ached as At:ach=ent A.
Confidential interviews were also held with ironworkers and Quality Control personnel.
During January 3-6, 1978, RIII representatives visited the Callaway site to continue the investigation.
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The investigation findings indicate that Individual "A" was correc:,
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or partially correct, in =any of his observations of construction activities at the Callaway site.
However, the NRC's evaluation of the
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investigation findings, with the possible exception of some of the embedaancs (a =at:er identified previorsly by the NRC), is that :he structural integri:y of :he enntainment ouilding is not impaired.
Not-withstanding the above, three it ems of noncompliance with NRC require =ents, and other mat:ers requiring licensee a::ention were the investigacion.
identified during
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The allegations and a brief su==ary of the investigation findings follow.
1.
At :ero degrees azi=uth, sheathing for the horizontal tendons improperly positioned.
was Finding: The placing of horizontal tendon sheaths was per=itted to deviate frc= the design drawings in certain locations. This deviation was reviewed snd approved by Bechtel power Corporation and was covered by a Design Change v tice (DCN).
o Items of nonce =pliance: None.
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2.
At 340 degrees azi=uth, vertical reinforce =ent bars were =oved so tha t the concrete cover for the bars was inadequate. Th e supperting bars for the horizontal tendon sheathing also had inadequate concrete cover.
Finding: Concrete cover was less than that required by NRC interpretation of the concrete cover require =~ents, but within the cencrete cover require =ents as interpreted by the licensee and contractors. This =atter remains under review by the NRC staff, and will be resolved by the sixth lift of the reactor
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containment wall.
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lte=s of nonec=pliance: None, pending resolution.
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3.
Identifying tags were switched on twelve #18 reinforce =ent bars, which are sixty feet long.
These bars were then =isplaced in the third lif t of the reactor containment yall.
Finding:
Reinforcement bars were i= properly placed in the third lift, as charged, but vere later re=oved and then placed in their proper location. No conclusive evidence was develeped that identi-fying tags were switched or destroyed.
Ite=s of nonce =pliance: None.
At fif teen degrees azi=uth, six horizontal reinforce =ent bars were cold bent.
Ftading:
The hori: ental reinforce =ent bars were sprung into place
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in an acceptable =anner, per the disposition of a Nonconfor=ance Report (NCR).
Ite=s of nonce =pliance: None.
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Quali:y Control personnel falsified cadwelding records.
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Finding: The investigation determined that the proper idectifying did sta=p had been applied to the cadwelds. However, the = tamp was not applied by :he individual who perfor=ed the cadwelds.
In that
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- he proper die sta=p was affixed, the NRC legal steff has deter =ined that this did not cons:i:ute falsification.
Items of nonce =pliance: Failure to have the cadweld insoection cr;teria match :he cadwelc production require =ents.
The cadweld inspec: ton criteria did not includa verifying :ha: the cadweld wen s:amped wi:5 an identifying stamp en the cadweld s~.eeve.
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6.
I: was planned :o cover up i= properly placed reinforce =ent bars in a control roca wall peur.
Finding: The N?C investigation was unable te confir= or disprove
- he 211ega: ion. The control room wall pour was delayed when.it was found that some of the reinforcement bars in the wall vere in-correctly placed. The pour was delayed so that,an engineering review could be =ade of the rebar placenent. The engineering review allowed the use of the reinforce =ent bars as placed.
Ite=s of nonce =pliance: None.
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7.
Shear bars were generally no.t placed according to the construction N-drawings.
Identifying :ags were switched to allow the use of the incorree: shear bars.
Finding: Overleng:h shear bars were, in fact, placed in so=e areas of the third lif t of the reactor contain=ent wall. According to 3echtel power Corporation this =atter was reviewed by 3echtel and found acoeptable. This ac: ion was not properly documented as a nonconfor:ance. The s:ructural considerations were subsequently reviewed by 3echtel and the NRC and vere found to be acceptable.
Individual "A" later indicated that tags had not been switched, and no evidence was found to indicate that identifying tags had been swi:ched or destroyed.
Ite=s of nonce =pliance: Failure to docu=en: the identification and engineering approval for the existence of overlength shear bars in :he third lif: of :he reac:or con:ain=ent wall.
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3.
A nonconfor=ing concrete e= bed was not controlled properly, and was almost placed in a wall before it was knew = : hat it was unacceptable.
Finding: A ncnconforming e= bed was found to have been properly inspec:ed and controlled.
I e=s of noncompliance: None.
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pliance was developed due to an NRC inspection. The inspection identified one instance where reinforcement bars were spaced one half inch beyond allowed spacing tolerances.
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CONCLUSIONS 3ased on the findings of the total investigation, including : hose con-tained herein, :he following conclusions have been dravn:
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1.
The structural adequacy of the con:ainment, with the possible exception of some of the e_tbed=ents, !s not in question. Tne adequacy of the e= bed =ents will be de: ermined by the NRC and reported in future inspection raports.
2.
Although certain weaknesres in Quality Assurance and Quality Con:rol were identified, the Quali:j Control and Quality Assurance programs of the lictnsee and cont:4c:or are basically sound.
3.
Although the allegations were determined not to affect the structural adequacy of the containment, the identification of t'
allegations over a period of several months has led the NRC to i
i=plement a program of augmented inspections t; assure that the s
Quality progra=s of the licensee will be more effective when
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further safety-related work is undertaken.
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Person Contacted Union Electric Cc:cany J. K. Bryan, Vice President, Nuclear D. W. Capone, Assistan? Manager, Nuclear Engineering
- M. I. Dcyte, Ceneral E.perintendent, Callaway Construction F. D. Field, Manager, Quality Assurance
- T. McFarland, Cons truction Supervisor
- R. L. Powert, Site Quality Assurance Cicup Leader
- D. F. Schnell, Manager, Nuclear Engineering 3. D Stecko, Assistant Engineer
- V. Weber, Manager, Nu lear Construction W. E. Ivanut, Supervisory Engineer, Nuclear Engineering
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Daniel International Corporation
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D. L. 3ettenhaussa, Civil Quality Control Supervisor T. 3erdeaux. Lead Area Civil Engineer
- J. R. 3ritt, Senior Area Engineer f-J. R. Cook, Project Mechanical Quality Control Engineer
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R. Construction Manager
- J. A. Holland, Project Quality Assurance Manager J. R. Lee, Civil Quality ontrol Inspector W. R. Loburk, Assistant Area Engineer W. Malisch, Civil Quali:7 Control Inspector M. McDaniel Audit Coordinacor E. Nelson, Reactor Building Area Engineer M. Osterhoff, Civil Engineer
- H. J. 5:arr Projec: Manager D. D. Whi:e, Reactor Building Area Superintendent j
3echtel ?cver Corporation
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l P. E. Divijak, Site Project Manager C. L. Miller, 7tvil Engineer
!. G. Pecrea, Civil Engineer t-W. Thomas, Civil Ergineer J. S. Whiteraf:. Civil Engineer
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Indivicuals Individuals "A" through "M" l
- Denotes those attending the site exi: briefings, i
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This investigation focused on several aspects.f the construction program conducted at the Callaway cons truct!.c? site. Principal areas of investigation included reinforce =ent steel placement, quality con-trol records, control of nonconforming items, and =aterial control.
1.
A11egatica A: :ero degrees a:i=uth, shea:hing for the horizontal tendons was i= properly posi:ioned.
Findings
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Indivi fual
"A" indica:ed that :he constructicn drawings for placing horisyttal tendon sheathing allowed a placing tolerance of one-half inch from the liner place, ari that, in se=e locations, the sheathing had been located two or :hree inches away frem the design location.
In reviewin; :he =atter, NRC inspectors foun'd that a Design Change Notice (DCN) had been issued by 3echtel Pever Corpora: ion concern-ing the placemen: of horizontal tendon sheathing. A DCN is an accepted method for = edifying a design which has been fernd to be
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deficient in some way.
The DCN (DCN C-0101-2-1) per=i::ed :he tet-don sheathing to be placed within a tolerance of as =uch as four inches from :he design location, in areas where the reae:or con-tai==ent vall was recessed, if required. Documen:s reviewed at the Callaway construe: ion site indicated that this DCN was received at the Callaway cons:ruction site on November 10, 1977, and was issued L,r construction useage on the following day.
Discussions with 3echtel Pever Corporation personnel indicated that the DCN had been prepared when the reactor rs.tain=en: vall tenden sheathing positioning was reviewed and found to be unworkable vi:h-ou: the addi:ional tole";nnee for some locations.
The NRC review showed : hat :he DCN was processed, reviewed, and approved in accord-ance with the Licensee's Quali:y Assurance Progra=.
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"A" indicated tha: he had not seen nor been advised of
the particular DCN.
O.dividual
"3", a General Foreman for the day l
shif:, also indicated : hat he had not been aware of -he DCN, bu:
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had followed :he orders of the Area Superintendent.
Ihe Reactor
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3uilding Area Superin:enden: s:a:ed that he ?.ad been aware of the DCN, i.-d had issued his ecostruction orders to the ironworkers based on the contents of the DC5.
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Individual "A" commented that the DCN covered cer:ain areas,
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and that outsice of those areas, the design location for the sheathing, within the original one-half inch placing tolerance, should be maintained. While this is correct, tendon sheathing is relatively rigid, and cannot be kinked. Therefore, a trans-ition area is allowed from where one placing tolerance is required to :he areas where :he other placing tolerance is required.
No items of noncompliance with NRC regulations were identified.
2.
allegation
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At 340 degrees a:i=uth, vertical reinforcement bars were moved so : hat :he concre:e cover for the bars was inadecua:e. The supporting bars for the horizontal tendon shea:hing also had inadequate concrete cover.
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Findings
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Individual "A" stated thcc some of the vertical reinforcement bars in the :hird lif t of the reactor containment vall had been moved outward a dis:ance of up to four inches, in some locations.
He indicated that this reposicioning of the bars had resulted ia a decrease in distance from :he concrete forms, and lessened e'
concrete cover for the bars in the finished wall.
Individual
"A" s tated that at the buttress at 41 degrees azimuth, concrete cover was insufficient, as the concrete cover in : hat area was
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less than one inch. He stated that he had not :aken any measure-
=ents of the concrete cover, but had =ade es:imates based on his observations of :he distances between :he reinforecment bars.end the concre te for=s. He also stated : hat the s=all bars used to support the horizontal tenden sheathing had inadequate concrete Cover.
Daniel International personnel indicated that the supporting i
bars for the horizontal sheathing (relatively small bars which i
support the shea:hing while concrete is being poured) are not safe:y-related i: ems, but are trea:ed as =ain reinforcecent as far as concrete coverage requiremen:s are concerned. This is a conservative approach, as applicable code requirements require less concrete cover for smaller si:es of reinforcement bars.
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A review of the requirements for concrete cove _ rage by NRC inspectors indica:ed tha: :he =ini=um cover requirements vary for different sections of :he contain=en: wall, depending on :he amount of cover specified for the area. The mini =u= concrete cover required for a 9-
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fla reinforcement bar, in the contain=ent vall, was found to be
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- vo inches.
1: was indicated that this mini =um could be reduced by one-third, to give an absolute minimum concrete cover of one and one-third inenes. A review of the drawings for the buttress at 41 degrees azimuth indicated that the two-inch cover require-
=ent would be the mini =um cover requirement for : hat area, as the
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outside vertical reinforcement bars are #18 bars.
Discussions with Daniel Interna:ional Quality Control (QC)
inspectors, who ad inspected the concrete forms prior to concrete S
placement, indica:ed that they had not observed any areas where concret e coverage would be less than :he mini =um r equired by
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the specifica: ions. Representatives of Union Elec:ric and y
3echtel Fever Corporation had also =ade inspections of the reinforce =en: bar placement in the third lif t, and found i: to be ac:eptable.
In an effor: :o resolve the issue, Individual "A" was asked to delineate :vo areas of the reactor contain=ent vall where concrete cover problems could be located. A verbal request was then =ade to Union Electric representatives to have these two areas chipped down :o the depth of the mini =um required concrete cover for the a.eas, to verify that adequate concrete cover is present.
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Union Elec:ric officials indicated that they felt that there was no legiti=a:e reason for the reques:ed chipping, and that no action t'
would be :aken without a formal written reques froa the NRC. As the issue was not of safety significance, Union Electric was advised that a vritten reques t for the chipping would not be made.
The NRC inspectors, upon further review, did not accept :he interpreta: ion that the mini =um concre:e cover require =ent could be further reduced as was indica:ed. The requirements for concrete cover were discussed during a meetinF be:vesa NRC, Union Electric, 3echtel Power Corporation, and Daniel Interna-tional personnel on January 23, 1978. Sechtel Power Corporation personnel repeated that their interpretation of :he cover require-ments was that the evo-inch cover requirement can be reduced to an absolute miai=um of an inch and one third per a provision of the specifications which allevs a redue: ion of the specified cover by one-third. NRC personnel indicated that their interpre-cation of the requirement was that :he :vo-inch cover mini =um
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cannot be further reduced.
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FRC personnel ci:ed a draf: Code case coverir* the same subject, which had been submitted to the A=erican Concrete Institute Technical Coe=i::ee on Concrete Pressure Creponents for Nuclear Se rv ic e. The draf: Code case decision agrees with the NRC inter-pretation of the require =ents for minimum concrete cover.
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,,s-Union Electric representatives were informed that they would be
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expected to co= ply with the NRC interpretation of the cover requirem-nts. NRC representatives indicated that it would be accept tie if the cover requirements were fully met in the area of the sixth lift, utili:ing the fif th lif t as a transition area.
To su=mari:e, the 3echtel understanding of the cover require-ments was that a minimum cover of one er.d ene-third inch, for a #18 reinforcement bar, was acceptable for the third lif:.
Individual
"A" es timated that actual cover was approximately one and three-quar:ers inch, which is within the requirements as used at tha: time by Bechtel. As Union Electric has been
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advis ad to coeply with the NRC interpretation of the requirement, a two-inch minirca concrete cover will be required for the sixth and subsequent 3:f ts, utili:ing the fif:h lif t as a transition area. Union Electric is evaluacing this position.
Since the pour had been completed prior to the investigation, the NRC s:af f was unable to determine conclusively whether or not there was any noncompliance with NRC regulations associated with this allegation.
3.
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Identifying tags were switched on twelve #18 reinforcement bars,
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which are sixty feet long. These bars were then misplaced in the
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third lif: of the reactor contain=ent wall.
Findines A review of procedures indicated that site constructics procedures require tha: each bundle of reinforcement bars have one iden:ifying i
tag, or have more than one tag if the bundle contains readily dis-l tinguishable bars, of dif feren: types, in which case each bar type
=ust have a tag.
I Site procedures also require that the identifying tag for a bundle of reinforcement bars re=ain with any bars which are in the " pit" area adjacen: to the construction area itself. Site i
personnel stated that workers sometimes mark the ends of the reinforcemen: bars to assure that bars lifted :o the work platform do not become unidentifiable.
'Jhen a work shif t changes, the
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general fore =an and foremen for the shif t arrive at the jobsite early, so as :o learn from the departing shif: where they have been working, and what is the loca: ion of the reinforcement bars that they have been using.
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Through discussions with Individual "A" and a review of con-
struction drawings, it was found that the allegation concerned 414 reinforce =ent bars, bar marks C-1004 and C-1049, which are sixty fe*t in length, and identical in shape except for a four inch differente in radius. The differenes in the two bars is
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=inimal, and could not be 2e:ected ';y visual inspection of the bars. Both bars would be identical in their.tiffening capacity, so that an it.:erchange of the bars would not affect the integrity of the reactor contain=ent.
A review of cons:ructien blueprints (drawings R-0232-069 and R-
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0231-070) indicated :ha: nine C-1004 and seven C-1049 reinforce-bars were included in the third lift of the reictor con-men:
tain=ent vall.
Site ricords indicated that eight C-100* reinforce =ent bars were issued cor cons truction on Nove=ber 14, 1977, and five C-1049 b u s were issued on Nove=ber 15,1977, :he o:her bars in the see: ion having been ins:alled prior to the place =ent of concrete in the second lif t of the reactor containment vall. -The warehouse records for issue of the C-1004 and C-1049 reinforce =en: bars in-dicated that there would be one identifying tag on each bundle of bars.
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In accordance with site procedures, if less that. the entire
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bundle of bars were lif ted to the work platfor= for placement,
-le identifying tag for the bundle of bars would stay wi:h the remaining
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bars in the " pit" area.
Interviews were held wi:h all available second shift ironworkers who were involved in :.
alleged incident. Frem their state =ents, the alleged reinforce =ent bar =isplace=ent took place on the night of Nove=ber 14, 1977. The crew fore =an's Daily Ti=e c.rd for the night indicated that sixteen =an-hours (eight nen working :wo hours each) were expended to " lay out and ins:alling hori:en:a1 bars".
No particular area or elevation for this work was noted en the ti=e card.
Second shift l
irenworkers, with minor variations, indicated :ba:
at the start of their shift on the night of Nove=ber 14, 1977, l
the C-1004 bars were already on the work platform, nes: the area where they were to be installed, which was area 2A.
The ironworker
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crew was i
to work in area IA, and install C-1049 reinforce =ent bars in that area, but could not loca:e the C-1049 ba:. The workers
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- hen used rollers :o =ove the C-1004 reinfores=en: bars :o the 1A
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area, and began installing the bars in place =anually.
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Interviews wi:h Individual "A" and Individual
"C",
.he crew
Foreman, indica:ed that :he Daniel International Superintendent had ordered the workers to ins:all the C-1004 reinforcement bars in the incorrect location, and throw the identifying tags away.
Individual "C" made a vei: ten statement to this ef f ect, but noted in his statement that he had not removed any tags.
(Exhibit I)
Individual "D",
the Daniel Internatienal Superintendent, stated that the crew had not been sure which reinforcement bar was on the work platform, as the bars were not tagged, tnd he fel: : hat the
'ronworkers were looking for an excuse for not doing any work on -
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reinforcement bar placement. He s:ated that he and Individuals
"A" and "C" had decided : hat the bars were the correct bars to be "
installed, and he had ordered that they be installed.
Individual
"D" made a written statement to the effect that he had not ordered any worker to switch identifying tags on reinforce =ent bars.
(Exhibit II)
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Interviews with ironworkers indicated that before the shif t finished work en November 14, 1977, the C-1004 reinforcement bars were taken down from :he incorrect area of the reactor containment wall and re-erected in the correct location. The ironworkers interviewed
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no:ed that they had to hurry and get some of the bars placed in
- he correc: area so that they could show that some work had been i
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done during their shift. Two ironworkers made writ:en statements to the effect that the reinforcement bars had been taken down and erected in the proper location en the reactor containment wall.
Typed transcripts of these statements are at: ached :o this report as Exhibit III and IV.
No items of noncompliance with SRC regulations were identified.
Allegation At fifteen degrees acimu:h. six horizontal reinforcement bars were cold bent.
Findines Through discussions with ndividual "A" and with Daniel International pcisonnel, i: was found that Nonconfor=ance Repor: (NCR) #1042 deals
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wi:h the six horizontal bars in question..The report indicates
- hat during construction of the first lift of the reactor containmen:
vall, i: was found that :he bends on a particular reinforcement bar had been detailed incorree:1y. To install the reinf orcement bars and saintain the necessary clearances and concrete cover, it was necessary to spring the ends of the bars into place.
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A review of NCR #1042 indicated :ha: the report was initiated on Augus: 3, 1977, and the recommended action of springing :he bars into place was aoproved on August 17, 1977.
RIII reoresenta:ives calculated that the ends of the reinforcement bars were =oved in a relatively s=all arc, springing the bars into place without permanently de forming them.
Individual "A" indicated that he was unaware of the NCR, and stated that he felt :ha: the bars were da= aged by pulling them into position as indicated by the disposition of the NCR.
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No items of noncompliance with NRC regulations were identified.
5.
Allegation Quality Control personnel falsified cadwelding records.
Findings
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A review of the si:e cadweld produccion procedures indicated that a cadweld is required to be sta= ped wi:h an identifring sta=o which indica:es which cadwelder =ade the cadweld, the
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splice number, and :le cadweld nu=ber.
A tve par: cadweld identification tag, each half of which includes the ss=e infer =ation,
and in addi: ion, :he da:e spliced, sleeve lot nu=ber, and pewder lot nu=ber, is clso at: ached to :he cadweld. One half of the two part :ag is used to genera:e the as-buil: cadweld drawing, and the other half of the :ag is re=oved by the QC inspector when the cadweld is e..spected.
Acceptable cadwelds are sprayed with white paint, and the infor=a:icn on the half of the tag re=oved by :he QC inspec:or is recorded in the Daily Cadweld Inspection Repor:.
It was observed by the NRC inspectors : hat the cadweld inspec: ion procedure did not include checking for the cadweld identification sta=p as an inspection criteria.
Documents reviewed and state =en:s received during the NRC review indicated that Individual "E", a Civil QC inspector, while
=aking a double-check of.he cadwelds on Cadweld As-Buil: drawing CAD-2003 (reactor build.c ), on :he night of Septe=ber 20, 1977, fo2nd :ve cadwelds, in serara:e locations, one of which lacked a cadweld identification sta=p, and one which had an illegible
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letter as par: of :he stamp. He stated that' b5th cadwelds had been sprayed with white paint, indica:ing that they had previously been inspected by a QC inspector and found acceptable.
By comparing :he informa: ion on :he As-Suilt cadweld drawing with the Daily Cadweld Inspection Repor: per:aining to the cadwelds,
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the QC inspector s:ated that he could logically deter =ine the corree: identification for the two cadwelds. He indicated that he felt the ca; welds $.s auld have an identification sta=p, as the cadweld production procedure called for the stamp, even though the cadwelds had been properly inspected and would soon be. encased in concrete.
Individual "E" gene cated a =e=o indicating the above sequence, which is attached as Exhibi: V.
S:2:e=en:s received indicated that on the night in question, Individual
"E" had Individual
"F", a fellov QC inspec:or,
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go to the second shif t Superintendent and reques that an ironverker go to the reactor building to sta=p some cadwelds.
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Individual "F" stated that he acco=panied the ironworkers to the reac:or building e: *rance, then went about his own inspections.
Interviews with the two ironworkers involved in the incident, Individuals
"G" and "H",
indicated that, Individual "E" shoved them the cadwelds to be =arked, and told them the identification sta=p which should be applied to each cadweld.
Individual "G" stated that he had to return to the ironworker's shed to obtait, a letter sta=p, as the letters :o be sta= ped
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were not those assigned to him.
Individual
"G" indicated
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that he did not apply his own let:er stamps to the cadweld, s_
but could not definately recall the letters or nu=bers of
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the sta=ps applied to the cadwelds.
L' hen asked if "AR or
"3E, the letters indicated on the As-Built cadweld drawing, could be the let:ers applied, he inc:cated tha: :he 1e::ers sounded right, but he could not positively recall.
Individual
"G" also stated that he had been asked to sta=p c:her cadwelds on other occasions, and had sta= ped several other cadwelds on : hose occasions. He indicated : hat he had not fel: that what he had done was impreper.
Discus sions with Individual "E" indicated tha: this was not a singular instance, and he sca:ed that he was aware that other QC inspectors had occasionally followed the same procedure.
Individual "D" provided a vri::en state =ent indica:ing tha: he was aware of seven cadwelds his ironworkers had sta= ped when the identifying numbeca were illegiole.
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(Exhibit VI)
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Individual
"A" stated that he had not gone with the iron-workers who had sta= ped the cadwelds, nor witnessed the s ta= ping of :he cadwelds. He indicated that he believed-15-
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that the men had been marking cadwelds with their own
identification letters, to falsely indicate that they had performed the cadwelds. When the sequence of events as found were discussed with Individual "A", he indicated that he otill felt that the procedure was not " legitimate", and constituted falsification.
The ques tion of whether the procedu re constituted falsification was explored in detail by the NRC.
It was felt th at there was no motivatien for the falsification cf the cadweld identi-fication sta=p, as the QC inspector could have allowed the cad-weld to remain unstamped and be covered with concrete. The
meched of marking the cadweld, involving several QC inspectors and several iron workers, did not indicate that there was any attempt to conceal the procedure. Also, the QC inspecto'r involved in the incident did not attempt to conceal what had been done, but gave details of what had occurred, and produced documents to substantiate his statements.
It was noted that the end result of the procedure outlined would be that a properly inspseted and identified cadweld would b'e encased in concrete as a part of the plant. It was concluded that the actions taken did not constitute falsification.
A review of the cadwelding procedures indicated that the marking
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of the cadwelds with an identification stamp was included
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in the cadweld production procedures, but inspection for the sta=p had not been made a requirement or hold point in the cadweld QC inspeccion procedure. This deficiency may have contributed to the incidents described above, by allowing a cadweld to be inspected without verifying ;*at the identifying sta=p had been made, and indicates a failure by the licensee to have an adequate cadweld inspection procedure.
This is an item of noncompliance with NRC regulations in that it is i
contrary to 10 CTK 50, Appendix 3, Criterion V, which indicateA, in part, th a t " Activities affecting quality shall be pteseribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions."
The licensee, by copy of a memo dated January 5,1973 (PQC-1437), advised the RIII representatives that the cadweld QC inspection procedure would be amended to include a requirement
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for verifying that the cadweld has been -properly stamped with an identifying stamp.
It was indicated that the amended procedure would require that if the identifying stamp is not present, and the cadwelder who made the cadweld could not be located to sta=p the cadweld, then the esdweld will be rej ec ter' md replaced.
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This corrective ac:icn is acceptable, and no response to this
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i:e= of concompliance ia required.
6.
Alleestion It was plannad to cover up i= properly placed reinforcement bars in a control roem vall pour.
Findings A check of the s:stus of :he indica:ed wall (placemen: 2C361'402)
was made, and it was found that a nonconfor:ance report (NCR*2-
17S -C) had been generated agains: the vall, delaying concrete placement pending disposition of the NCR. The vall 'eas inspected by RIII personnel, who obse'ved the nonconforming reinforcement bar placement which was the subject of :he NCR.
In addi:icn. a weld on i nelsen stud a:tached to a concre:e embed it :he vall appeared questionable to the RIII inspec:or.
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The disposition of the NCR, to 2se the reinforcement bars as pisced, was reviewed by the RIII representatives when i: was received at rhe site, and vis found to be acceptable. The
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nelson stud.:.ase veld was questioned by the KIII inspe;ter was tes:ed, by bending it to fifteen degrees, tad was also found to f
be acceptable. Af ter the review of the NCR rad the weld tes:,
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the RIII representatives indicated to the licensee that they had no reason to regaes: that the placement of concrete be delayed. and concrete was ;) aced.
Individual "A" indicated that the corcrete placemen: crev va,
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in place and concrete placement for :he vall was about to proceed when he showed the Civil QC inspec:or the location of
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- he nonconforming reinforcement har placement.
I Th. OC inspector involved in :he incident indica:ed : hat he had not comple:ed his fir.a1 Civil QC inspection of the vall when he was approached by Individual "A" and :cid of noncenfoiming reinforcemen: bar plac<tment around a door frame. The QC inspector indicated that he had s1 ready obser~ed that the reinforcement bar place =ent was particily incorrect on one side of the d.or frame, and was on his way to review his construction dravi.tgs when Individual "A" advised him that the reinforcement was
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incorrec: on both sides of the door frame, which he i= mediately verified by inspee: ion. The OC inspector sta:ed : hat he then generated :he nonconformance report which delayed concrete place =ent.
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Individual
"I", the Civil QC inspector involved in the incident, sta:ed that final Civil QC inspections are always mede immedia:ely before concrete is placed, to preclude the possibility that' r in-forcement bars could be moved prior to concrete placement. He noted that it is not unusual for this final rispection to reveal problems which require delaying concrete placement.
No items of noncompliance wi: 3 NRC regulations were identified.
7.
Allegation
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Shear bars were generally not placee according to the construction drawing 9.
Identifying tags were switched to allos the use of the incorrect shear bars.
Findings Discussions with Individual "A" indicac2d that identifying tags had not ac:ually been switched on the shear bars, but that shear bars of improper length hcd been placed in the' third life of the
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reactor con:ain=ent wall.
Individual
"A" stated that, in seme cases, shear bars which were approximately five and a half inches overlent:h were utili:ed in areas of the reactor conetinmen: vall.
Through discussiens, it was found : hat overleng:h shear b;rs had
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been placJd in ehe third section of the reactor containment vall, in :he area of he electrical penetrations, and possibly other locations. Daniel Intwrnational personnel stated that Daniel Civil QC inspec: ors had identified the presence of the long shear bsts, and had consulted with a Bechtel Power Corporation engineer, who had advised them that the shear bars were acceptable, even though ove rle ng:h. Telephone contact wi:h :he Pechtel engineer verified that he had observed t e shear bars and sdvised that they were acceptable.
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3echtel Power Corporation representatives indicated that the place =ent of shear bars is 2: the discretion of the client, as long as :he
" design in:ent" of their placement is met.
3y copy of memo 3LSI-5384, Bechtel advised : hat the design document for the reactor containment vall, 3echtel Topical Report 3C-TCP-5A, in paragraph CC-3532.1, allevs :he placement of a shear bar wi:hou: :he hook of the bar being in contact wi:h principal reinforcement. This design docu=ent does allew the use of overlength shear bars, and
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3echtel has incorporated a clarifying note to the construction drawings :o this effect by Design Change Notice C-0003-10-5.
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- 'hile the use of the overlength shear bars is permitr+d by the
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design document, the placerent of overlength shear bars was
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no: in accordance with the 6;ostruction drawings for the third
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lift of the reactor containmen, wall, and therefore should l
have been documented as a nonceaformance and dispositioned as such. This is an item of nanJo=pliance with NRC regulations, as it is contrary te 10 CFR 50, Appendix 3, Criterica XV, which i
s:a:es, in part, that " Nonconforming items shall ta reviewed j
and accepted, rejected, repaired or reworked in accordance wi:h i
documented procedures."
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Allegation i
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A nonconforming concrete embed was rot controlled properly..and
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was almost placed in a vall before a: was known tha: it was i
unacceptable.
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Findings
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j RIII personnel accompanied Individual "A" to the location of i
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the embed, and found : hat the embed did not have a " hold" tag, i
al: hough a small portion of a hold tag was found attached to
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the embed. Visual inspection of the embed gave no indication
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that it was unacceptable.
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Through discussiens with Individual
"A", the day shif t Assis:an Ironworker Superintendent, and QC personnel, it was found that two e= beds hsd been heat-straigh:ened at the ironverker fabrica-
- icn s.op without an approved senconfor=anct report.
This con-dicion was ob,erved by CC inspectors, an NCR (NCR#2-1592-C-A) was generated, anf " hold" tags were placed on the embeds. The dis-posi: ion of the NCR was to use the embeds "as is", since the pro-
cedure used to strai;h:en the embed was acceptable, and the degree
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of embed place warpage was within the allowable colerance li=its.
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The " hold" cags were removed from :he embeds following :he dis-position of the NCR, but :he day shift Assistant Superintendent i
was not adviaed that t!.s " hold" tags were removed from the embeds.
Frem statements received, Individual "A" and other ironworkers j
were in :54 process of placing :he embed in the plan: when the day shif t Assistan: Superintendent noticed tha: the place
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which they were placing was one of vo embeds.which had been on
" hold".
The Assistan: Superintendent then ordered the crev to place :he embed to one side, and indicatad his belief that i:
l was a nonconforming e= bed.
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Following discovery of the above sequence of events. Individual
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"A" and the Assistan: Superintendent oere informed that th e embed was acceptable.
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No items of noncompliance with NRC regulations were identified.
OTHER FINDI!!GS Ouring the investiga: ion, on January 4, 1979, an inspection was made of the reinforce =ent bars in the four:h lif: of the reactor
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con taimaen: vall. Several discrepancies were noted during :he
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inspection, and the RIII inspector requested copies of any NCR's per:ain!c.g :o the lift. A1: hough all discrepancies vere not covered by NCF't. it was no:ed that work remained to be done in s. <s vtl areas of the containmen: vall section, and final Civil QL in:pections had nor been performed.
During the inspec: ion conducted of tag fourth lif: of the containment wall. it was noted that some sections of reinforcement bars appeared
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to b= spaced more widely than allowed by applicable codes. A review of tne reiniorcement placing drawings indicated that the reinforcement bars had been placed as per the drawings, and wi:hin the cpplicable pl ace =ent :elerances, with ene exception.
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The ex:eption was noted to be at approxi=ately 229 degrees azimuth, where :vo #11 reinforcement bars at either side of electrical penetra-tion E-225 were found :o be twen:y-six and one-half inches apart. This spacing viola:es the =aximum reinforcement spacing, including spacing tolerance, by one half inch. This ir an item of noncompliance with NRC regulations in that the licensee failed to identify the nonceaform-ing condition. as required by 10 CFR 50, Appendix 3, Criterion XV.
Cri:erion XV states, in par:, that " Nonconforming items shall be reviewed and accepted, rejec:ed, repaired or reworked in accordance with doc"=ented procedures."
Subsequen: :o the inspection by :he RIII personnel, the licensee inspected :he area questioned by the NRC inspec:or, and agreed that
- he spacing of the reinforcemen: bars exceeded applicable tolerances.
A NCR was gecerated concerning :he spacing of the reinforcement bars (NCR 2-1901-C-A), which reco= mends that the bars be deflected to obtain :he required spacing for the upper see: ions of the containment
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wall.
The half inch spacing error is not viewed at significan:, and
- here is no questica regarding the s';ructural integri:y of the contai= ment wall. Complete inspection of the fourth lif t of the containmen: vall was pos:poned, and will be documen:ed in a subsequent inspection report.
A::ach=ents:
1.
A::achten: A
2.
Exhibits I :hrough 7I
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I Individual "C", make the following written statement to James Foster. who has identified himself to me as an Investigation specialist of t.hc NRC.
I understand that I do not have to make a statement and that it =ay be used by the NRC.
I installed five or six C-1004 reinforcement bars instead of C-1049 reinforcement bars in the third lift reactor containment wall. This was done because my =en could not locate C-1049 rebar, and Individual
"3" old me to place the C-1004 bars in the pour. He said that he
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voc'd cake :Ne responsibility. He also asked me to remove the identifying tags en the bars. I did not remove the tags.
The wrong size shear bars were also used and when we ran out of short size bars, both Individual "A" and Individual "D" cold me to have =y men put in the longer size shear bars.
These shear bars, were placed in area 31 and 32 of the third lif t reactor containment wall.
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I have read this written statement consisting of two pages, and it is accurate.
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Individual
"C" 12/21/77
- itness:
James E. Foster 12/21/77
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Exhibit I
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To whom it =ay concern:
I have never instructed an Ironworker General Foreman, Foreman, or Ironworkar :o switch :ags on rebars this Callaway Plant.
Thanks,
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I.1dividual "D"
'di:ne s s :
Indiv'.i al "M"
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o Exhibi: II
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d I. Individual "K", hereby make the following voluntary statements to
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C. C. '.*illiams, identified to me as an inspector with the U. S.
i Nuclear Regulatory Commission.
Between Novehber 10, 1977, and Thanksgiving day, an error in rebar
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installation location occured. The =isinstalled rebar was in quad-rant No. 1-A.
The rebar was corrected.
I observed that the rebar was removed from this (the wrong) location.
I was involved in the installation of this rebar. I later observed that this error had been corrected.
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I have read the ccements %d statement on this page and conclude that it is a true repre' entation of the facts as I know them.
Individual "K" 1/12/78
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o Exhibit III
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January 12, 1978 I, Individ'etl
"L", hereby make the following voluntary statements to C. C. '*111iams identific' to me as an inspector with U. S. Nuclear Regulatory Commission:
About 2 weeks '..~;-e Thanksgiving (1977) I helped inscall rebar which was later dete rmined to be at the wrong location. This rebar installed in the area of quadrant 1A of the containment vall.
was
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3e next shift I verked, I saw that the rebar had been removed from this (vrong) location. As I recall, I helped install different (cerrect) rebar in this same area.
I also helped in the installa-tion of the removed rebar, in the correct location.
I have read the com=ents and statements on this (1) page and conclude that it is a true represenettion of the facts, as I knee them.
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Individual "L"
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Exhibit IV I
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INT E R.O F FIC E COM M U NIC ATIO N
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Feem 3 4 99 (Rev. 4 75)
To:
D. C. Wilson (26)
DATE:
December 19, 1977
PQC-1404
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FROh:
Individual "I'(2 6)
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SUBJECT:
Stamping of Cadweld Sleeves vaile verifying Cadweld.As-Built CAD-2003 on Seocember 20, 1977'
it was found that sn I.D..a ts not stamped on one of the six sleeves in area 66.
By comparing the As-Built (see page 1,
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attachment A) with the Daily Cadweld Inspection Report (see page 1 & 2, attachment B) the missing I.D. was establishet Also one of the cadweld sleeves in either section 22 or 2'3 (see page 2, attachment A) did not have a legible 1,et.e.r, as the die was not rolled, to conform to the cadweld sleeve, as it was struck.
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We requested that the missing I.D. be stamped and the ille ible
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letter be re-stamped.
We observed the stamping of the cad eld (..
2 eves and verified the correct I.D's by visual inspection.
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bdividual ".L"
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Civil QC Inspector (S tructural)
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Tile:
A37.10-08 & 13
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cci W. G. Westhoff (4)
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H. J. Starr (1)
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December 16, 1977 TO:
303 HILYER
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FROM:
Individual "3"
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Dear Mr. Hilyer,
This lettar is concerning the accusations Lade on falsifying Cadwelds on Second Shift.
I have no knowledge of any such happenings other than seven Cadwelds that the letters took but the numbers did not show clear.
QC asked the Foreman (Individual "C") to let a Cadwelder make the nu=bers more visible.
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Thank you,
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i Individual "D" Second Shift
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Assistant Rebar Superintendent
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Exhibit VI ks
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ATTACHMENT 3
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