IR 05000508/1980014
| ML20003E811 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 12/11/1980 |
| From: | Bishop T, Haist D, Haynes R, Joukoff P, Shackleton O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20003E794 | List: |
| References | |
| 50-508-80-14, 50-509-80-14, NUDOCS 8104100636 | |
| Download: ML20003E811 (10) | |
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50-508/80-14 I
Repor: !!o.
50-509/80-14 Docket !'o.
50-508 and 509
- .nense w. CPPR-154/155 safeguards creup 1.t een s e e :
Washington Public Pcwer Suoply System P. G. Sox 958 Richlanc, Wasnington 99352
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Washington Nuclear Projects Nos. 3 and 5 (WNP-3/5)
ractit:y ::a:e:
'JIP-3/5 Site. Ei::'a. Wasnington Inspec:ima at:
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hp st::er 25 - October 30, 1980 Inspecti:n ioncuc:22:
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2./k IIN <r[b Inspectors:
T. '.:. 5tsnco, sentor Resicent Inscector a:2 signec
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I/. ?. Falst, Reactor Inspector
' C 1:e dignec s e l (5. Aeelb 2 12/Wes 3. q. R ackle g n, Senior Investigator rate signed
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Appro ea. ;y:
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Paynes, KTfQ, ProJ cts Section Oate signed x.
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Eeac:cr Ccnstruc-icn and ':ngineering Suoport Branch t
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Inwsticaticn durine the cerice Secter.ber 25 - Octcber 30, 1980 (Recort Nos.
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50-508/cO-14 anc 50-509/80-14).
Areas In'.esticatac:.lonroutine, unannounced investigation by the resident inscector, regicncl based inspector, and regional based investigators of allecaticns regarding withholding of records from NRC inspection, directions to falsify quality records, and other a*eas under the site HVAC contractors area cf responsibility.
The investigation involved 190 manhours on site by two inspectors and two investigators.
Resul ts: One iten of nonccrpliance was identified during the investigation (failure to calibrate equiprent within specifie'd frequencies, paragraph 4.a).
RV Form 219 (2)
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CETA q 1.
Persens Centacted The inscectors and investigators centacted engineering, managecent, inspection and ccnstructicn eerscnnel of the organizations listed below.
Key perscnnel centacted include the folicwing:
a.
Washington Public Pcwer Sucolv System (WPPSS)
D. E. Dobsen, Project Manager
- J. C. Leckhart, Project GA Manager C. E. Trapp, Project Engineering Manager
- R. A. Davis, Sr. Project Quality Engineer R. Hicks, Sr., Project Ouality Engineer J. M. Walker, Sr., Quality Assurance Engineer b.
Ebacco Services Inc. (Ebarco)
- A. M. Cutrena, Caputy Project QA Manager
- L. F. Adams, Sr. Project Quality Engineer
- L. A. Bast, Project Quality Engineer T. F. Tully, Project Quality Engineer c.
'fallace/Surerior (W/s)
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W. Frost, Project Director J. Sandifer, Project Manager Additicnally, other meci:ers of the Wallace/ Superior staff were c::ntactec.
Cenotas these present at the management treeting of October 30, 1980.
- 2.
S'=ary cf Events The prire heating, ventilating, and air c:nditioning (HVAC) contractor en-site (Uallace/ Superior, contract Nc. 3240-232) had started safety related work activities in approximately April 1980. As of the date of this investigation this work had been limited to the installation cf 39 HVAC duct supports in the L' nit 3 reactor auxiliary building.
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In late August 1980 cr early September 1980 the licensee received allegatiens regarding the improper firing of a Wallace/ Superior employee. A licensee investigation into the allegaticns was initiated in mid-September 1980.
The Itcensee's findings had not been fully dccumented at the time this NC.C investigation was initiated (September 25,1980) but several significant probicts in the contractor's organizaticn had been identified by the license.
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-2-Cn Septerber 25, 1980 a contractor employee contacted the NRC and made two allegatiens regarding current activities. An NRC investigation was initiated imediately.
On Seotember 29, 1980 the licensee issued a stop work order to the contractor baseo uccn the findings of their investigation and preliminary results of the NRC investigation. On the sar.e day the licensee initiated an audit of the contractor's quality program.
Curing the course of the NRC investigation, additional allegations were ecde regarding the contractor's perfontance. These additional allegations att surrarized in paragraph 5 of this report and for the most aart were itrs that were creviously identified by the licensee's investigation er audit.
Following imolecentation of sore corrective reasures, the licensee's step werk orcer was partially lifted on Cctober 13 and 14,1980. As of Octcher 30, 1980 the centractor's work activities were still limited pending ccepietion and verification of certain corrective measures.
3.
Initial Allecations to the NRC
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On Sectember 25, 1980, an individual care to the NRC an-site office and made two allasations regarding recent activities of the site HVAC contracter (Wallace/ Superior, contract tio. 3240-232). The allegations as understood by the MRC inspector, were as folicws:
a.
Cuality rccords were withheld to orevent an f;RC inscector from zaeino a cuality croblem.
On September 24, 1980 an NRC inspector requested the Wallace/ Superior ecuipment calibration log book.
It was alleged that irrediately before the log book was turned over to the NRC inspector, the Wallace/
Su:erior QC Supervisor removed six pages frcm the log, stating
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something to the effect of 'we wculdn't want the NRC to see these'.
The six pages identified equipment for which calibration was past due.
.b.
A centractor CC sucervisor directed the back-datino of quality records It was alleged that on September 25, 1980 the Wallace/ Superior QC Sucervisor verbally directed a QC Inspector to perform equipment calibrations and then back-date the records so that it would appear that calibration period had not yet lapsed.
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-3-The allegatiens were investigated by reviewing the documented requirements for calibration o" equiprent; interviewing individuals involved with the calibraticn aid associated record keeping activities; and examining pertinent qualit? records. A total of nine individuals were interviewed.
Eight of the persons interviewed were interviewed under oath. Two signed swcrn statemeni.s were taken.
4.
Firdincs on the Initial Allecations a.
Qualitv records were withheld to crevent a NRC inscector from e g a cuality croolem.
The allegaticn was substantiated.
Statement race under oath by person who removed the cuality records from the calibration log book anc tne signed sworn statement frem the individual who witnessec the removal substantiated the allegaticn.
Cn Secterter 25, 1980, examinaticn of the pages which had been removed identified that the calibraticn period had expired for five pieces of acuiptent which were in the field and available for use on safety-related and nonsafety-related HVAC systems. These five pieces of equicment were: portable welding rod ovens No. W/S 001, 004, 008, and C09; and welding machine No. W/S 006. Examination of the calibration-leg book indicated that the conthly log reviews (by the QA Manager, er his designee, for checking equipment calibration status) had not been signed-off since July 1,1980. The failure to accomplish ecuicment calibratiens and calibration. status reviews in accordance with acoroved precedures is centrary to the requirements of 10 CFR 50, Accendix B, Criterion XII. This is an apparent item of noncompliance (50-503/509/80-14-01).
The withholding of information with intent to mislead an NRC inspector
is of sericus concern. The findings from this aspect of the investigation l
have been submitted to NRC IE Headquarters for examinaticn and further i
action. Licensee corrective measures in this area are addressed l
in paragraphs 5 and 6 of this report.
5.
A centracter CC sucervisor directed the back-dating of quality recorcs.
The allegaticn was censidered to be unsubstantiated because of l
inconclusive evidence. The QC inspector stated that such direction had been given to him and there is circumstantial evidence to support
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his claim. However, the CC inspector's claim was not corroborated l
by a third person present during the conversation between the QC supervisor and the QC inspector.
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-4-The signed sworn statement taken from the inspector who allegedly received the directions to calibrate equipment and back-date the records and the QC supervisor's oral statement made under oath who allegedly gave the directions are inconclusive. The inspector stated that he definitely received such directions and the QC supervisor stated that he does not recall giving such directions and does not think that he would have done so. The supervisor further stated that he was in a state of "canic" at the time the directions were allegedly given. A third individual was reportedly present when the alleged directions were given.
In a sworn statement this individual stated that he does not recall that such directions were given, although he was occupied with other activities (reviewing time cards) at the time the alleged conversation took place.
The QC inscector stated that he was concerned about being put in a cosition wnere he felt he had to either break the rules (back-date documents) or refuse to folics his supervisor's instructions.
He stated that he discucsed this concern with his fellow inscectors and his foreman. NRC interviews with these individuals substantiated that such conversatloc.: were held. The ins ector further stated that he actually did back-date a few records, but then corrected them within an hour because he decided it was not proper. These back-cated records (two equipment calibration tags) were recovered frem a trash can and turned over to a NRC inspector.
5.
Additional Allegations During the course of the flRC investigation each individual contacted was asked about pcssible problems in other areas. The following items were allsged to be areas where oblems were believed to exist or did exist.
f a.
A OC sucervisor improperly comoleted training / indoctrination records for GC inscectors.
Finding: The statement was correct and was previously identified by ne licensee's investigation. The licensee had identified that the training records for two QC inspectors had been signed off as
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corrplete, when, in fact, the training had not been accomplished.
Statements taken by the NRC from the QC Supervisor indicated that he had generatcd the training record document, including the signature indicating completion but had become side tracked and never actually l
administered the required 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of training for the two inspectors.
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b.
An inscector was iecrecerly terminated for cerforming his inscection l
duties.
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-5 Finding: Terminatinn of this inspector was the subject of a previous licensee investigaticn and is presently under investigation by
' the U. S. Department of Labor, c.
The CC Sucervisor directed inscectors to discard " records" identifying a cuaiity orcolem.
Finding: The allegaticn was not substantiated, since the " records" involved (stubs from " ACCEPT" tags) were not ouality records required to be retained, and the existence of the quality problem (item 5.d, below) was doctxented by the tags themselves and was idertified by the previous licensee investigation.
d.
Uncualified individuals cerformed inscections.
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Findinc: The staterent was correct and was the subject of a previous licensee investigation. Two trainee inspectors whose erployment has been terminated had performed scme inspections of shop activities, primarily of non-safety related materials. Those few safety-related items that may have oeen inspected by the trainees were reinspected by certified inspectors.
e.
A construction manager has attemoted to intimidate OC personnel Findinc: The statement was enrrect and was previously addressed ar.c c:rrected by contra.e r management. The allegation involved verbal ccnfrontatione Fet.een QC personnel and the contractor's c:nstruction canager. oontractor management subsequently replaced the constructicn manager, f.
Senior management acolied improcer oressure on the OA/QC organization.
Findinc: The allegation was not substantiated. Sworn statements tar.en from contractor CA/QC personnel and senior management do not incicate any improper pressure being applied to the QA/QC organization j
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The OA manager shared living quarters with the construction manager l
(an accarent conflict of interest).
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Finding: The allegaticn of a conflict of interest was not substantiated.
Personnel interviews indicated that the construction manager, on occasion, shared the living quarters of the QA manager who resided closer to the site since the construction manager's residence was
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in the Seattle area, approximately 100 miles frca the site. There
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was no information obtained from sworn statements which would indicate i
a conflict of interest arose frcm this situation. The construction manager has since been replaced.
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Incoming materials have not been orocerly controlled.
Finding: The statement was correct and was the subject of a previous licensee audit. The concern of improper control related to the lack of a receiving hold area and the shipment of materials from the contractor's shop in Utah without complete paper work.- There was no indicatien from the interviews that indicate unsatisfactory safety-related raterials were allowed to be installed due to this lack of control. The contractor has since been required to establish appropriate receiving areas and assure adequate documentation is transmitted with the shipments.
1.
Construction eersennel have a disregard for cuality control.
Findina: The allegation was not substantiated. The incidents icentified as exemplifying the disregard have ceen the subject of a previous licensee investigation. NRC interviews with contractor personnel do not indicate a " disregard" for quality control although there were instances wnere, it appears, that construction personnel were not fully cognizant of quality requirements. The contractor has conducted foreman training to correct this situation.
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Peor cuality material has been received from the contractor's Utah shoo.
Finding: The statement was correct but was recognized by the contractor ano unsatisfactory material conditions have been documented, and proper acticns taken to correct the unsatisfactory conditions.
k.
Due to the ocar cuality of materials received from the contractor's Utan snoo it is one eerson's opinion that the inscectors at the Utan snoo are being forced to accept inferior welds.
Findino: The allegation was not substantiated by the investigation at WNP-3/5.
There was nothing identified during the investigation that would indicate coercion of QC personnel at the Utah facility. No interviews were concucted of W/S personnel at their Utah facility.
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1.
The CC training and certification program is inadequate.
Finding: The statement was correct and was previously identified by tne licensee's investigation. Deficiencies in the QC training and certification program have also been identified in the licensee's audit of the contractor. Corrective actions in this area have been implemented, and all previously accepted safety-related items have been independently inspected by qualified licensee personnel.
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ficnconformance recorts are rewritten by QC/0A suoervisors and staff and are not returned to the original authors for review.
Findinc: The statement was correct and was previously identified by =e licensee's audit. MRC interviews with involved personnel indicate that the original reports were reviewed, grammatical corrections made, and then typed to inarove the quality of the final report.
Individual inspectors interviewed indicated that there were no instances where the substance of their recorts had been changed.
The contractor has since taken action which assures the original report is not changed without the originator's knowledge.
n.
A walder was imcrocerly cualified in that calvanizine was rarroved ren.ne steel cerare nt s cua nncation test was cerrormeo.
Findina: The allegation was not substantiated.
Investigation of the aileged incident disclosed that the activity involved an attempt to qualify a welding procedure rather than a welder. The personnel involved reported that test welds were made with galvanizing on
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and off the steel to assess the welding procedure and that this
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par'.icular procedure was ultimately discarded and a new procedure developed.
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Welders do not possess the skills and finesse needed for AWS welding.
Findina: The allegation was not substantiated. Visual inspection of accroximately 100 completed AWS structural welds did not indicate a lack of welder skill or finesse.
p.
0A ranager allcwed certain activities which were in violation of
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crocacures.
Findino: The statement was true and was previously identified l
by :22 licensee's investigation and audit. Three instances were identified as situaticns where activities were allcwed (by the CA "anager) to proceed and which were contrary to procedure requirements.
These conditicns were: (1) liquid penetrant nendestructive testing was acccmplished without having an approved procedure for qualifying the condestructive examiners; (2) a QC trainee (the QA manager's
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sen) was allowed to sign ACCEPT tags; (3) a hold area was not established for inccming materials. NRC investigation into these areas indicate that, at the time these situations occurred, the ranager did not recognize them to be violations of quality requirements, and felt that in no case did the situations result in a deterioration in
l oroduct quality. The conditions indicate a lack of familiarity with procedures and/or rigorous application of quality requirements which may, in part, be attributed to the individual's lack of previous nuclear experience. The contractor and licensee have taken action t
I to assess the quality impact of each of the conditions identified, and a new Quality Assurance manager, with significant previous nuclear experience, has been assigned, l
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The CA manaoer has a ocar ouality attitude.
Finding: This allegation is addressed in 5.p, above.
6.
Additienal Licensee and Contractor Actions In addition to the licensee investigation and audit and audit follow-uos the licensee has accorolished a 100% reinspection of all completed safety-related work performed by the contractor. The cuality documentation associated with this work has also been examined. While these activities did identify certain discrepancies, they were not major in nature.
Those problems that were identified were documented and are being properly resolved. As an additional measure the contractor has contracted the services of Energy, Inc., to perform an indecendent assessment of the centractor's cuality program and recorr.end imorovements. Other actions taken by the contractor include the assignment of'Mr. W. E. Frost (member of the Board of Directors and past president of the Sam P. Wallace Company)
as the Project Director, and the replacement of the QC supervisor and site CA manager.
7.
Examination of Ccmoleted Work As stated previously, the contractor's completed safety-related work is
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limited to 39 HVAC duct supports which have been installed in the Unit 3 reactor auxiliary building. The NRC inspector examined the weld quality en 20 of the 39 supports. Scme discrepancies (undercut, marginal weld size) were identified but these conditions had been previously documented by the licensee's reinspection program and were also used as examples in tne reinstruction of contractor GC inspectors.
During the investigation it was determined that the contractor intends to make use of friction clamping devices for securing certain HVAC ducting.
The inspector requestad that the seismic qualification data for these devices be made available if they are to be used in safety-related applications
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(50-508/509/80-14-02). Licensee representatives agreed to investigate l
this mattar.
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_ Licensee Perfcrmance While it is recognized that the licensee's quality program ultimately identified many of the programatic deficiencies which were discovered during the investigations and supplemental audit it is not clear why these problems did not come to light during any of the three audits -
and approxirately 70 surveillances previously perfonned on the contractor.
Licensee representatives stated that this area will be examined and appropriate action will be taken. This item will be examined further during a subsequent inspection (50-508-509/80-14-03).
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The effectiveness of licensee's and contractor's measures will be examined in conjunction with the routine inspection of HVAC activities.
9.
Manacerent Meetings The inscectors and investigators met with licensee and contractor management at various times during the investigation, with a final meeting on October 30, 1520. Those individuals present at the October 30, 1980 meeting are noted in paragraph 1.
During the meetings the findings, including the item of noncompliance noted in paragraph 4.a. were discussed, t
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