ML102740526

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ROI, Case No. 4-2009-049
ML102740526
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 03/19/2010
From: Ferich J, Hannan M, Holland C
NRC/OI/RGN-I/FO, NRC/OI/RGN-III/FO, NRC/OI/RGN-IV/FO
To:
References
4-2009-049, FOIA/PA-2010-0245, RIV-2009-A-0067
Download: ML102740526 (3)


Text

Title: COLUMBIA GENERATING STATION FAILURE TO FOLLOW PROCEDURAL REQUIREMENTS DURING INSTALLATION OF PERMANENT PLATFORMS AND LADDERS Licensee: Case No.: 4-2009-049 Energy Northwest, Inc P.O. Box 968 Report Date: March 19, 2010 Richland, WA 99352 Control Office: O!:RIV Docket No(s): 05000397 Status: CLOSED Allegation No.: RIV-2009-A-0067 Reported by: Reviewed and Approved by:

J&e erich, Special Agent Crysta'D. Holland, Director Office of Investigations Office of Investigations Field Office, Region I Field Office, Region IV Participating Agent:

Mark Hannan, Special Agent Office of Investigations Field Office, Region III DO NOT DISSEMINATE, PLACE HE PUBLIC DOCUMENT ROOM OR DISCUSS THE CONTENTS OF IS EPORT OF INVESTIGATION OUTSIDE NRC WITHOUT AUTHORITY F THE PROVING OFFICIAL OF THIS REPORT. UNAUTHORIZE DISCLOSU MAY RESULT IN ADVERSE ADMINISTRATIVE ACTI AND/OR CRIM AL PROSECUTION.

OFFICIAL USE ONLY - 01 INVESTIGATIO INFORMATION

OFF ý US E 0 Y - 0 INVE ATIO IINFORMA SYNOPSIS This investigation was initiated by the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations (0I), Region IV (RIV) Field Office, Arlington, TX, on May 27, 2009, to determine if Energy Northwest (EN) and Williams Plant Services (WPS) personnel at Columbia Generating Station (CGS), Richland, Washington, willfully failed to follow procedural requirements during the installation of permanent platforms and ladders.

Based upon the evidence developed during the course of this investigation, 01 determined the allegation that EN or WPS personnel willfully failed to follow procedural requirements during the installation of permanent platforms and ladders at CGS was not substantiated..

NOT FOR PUBLIC DISCLO E WITHOUT APPROVAL OF FIELD OFFICE DIRECTOR, OF E F INVESTIGATIONS, REGION IV Case No. 4-2009-049 OFFICIAL ONLY- 01 INVESTIGAT N INFORMATION

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OFFICIj ONýL-0IN ýTIG ýIONINFO TýIN TABLE OF CONTENTS Page S YNO P S IS ............................................................................ ................................................... 1 TESTIMONIAL EVIDENCE ..................................................................................... 5 DOCUMENTARY EVIDENCE .................................................. ............................ 7 DETAILS OF INVESTIGATION .................................................................... 9......

A p p lic a b le R e g u la tio n s .................................................................................... 9 Purpose of Investig atio n ........................................................................ . . .. . .9 Ba c kg ro u n d ...................... I......................... I.................. 9 Coordination with Staff ........................................................................................... 10 Age nt's A na lysis ................................................................................................... . . 10 Conclusion ................................................... . 14 LIS T O F E X HIBITS ................................................................................................................. 15 NOT FOR PUBLIC DISCLO RE THOUT APPROVAL OF FIELD OFFICE DIRECTOR, OFFI F INVESTIGATIONS, REGION IV Case No. 4-2009-049 OFFIC USE ONLY - O INVESTIGATI INFORMATION

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TESTIMONIAL EVIDENCE Exhibit (b)(7)(C) Williams Plant Services (WPS),

Columbia Generating Station (COGS), Richland, Washington ......................................... 8 (b)(7)(C)

W PS , C GS ..................................................................... 5 (b)(7)(C ) w Ps , C G S ............................................ ................. 13 (b)(7)(c) ýW P S , CG S ................................................................

15 0 (b)(7)(C) W PS , CG S ........................................................... 7 (b)(7)(C)

(WPS, CG S ...................................... 10 (b)(7)(C ) IW P S , C GS ............................. ........................... . .. 14 (b)(7)(C)

(b)(7)(C)~W Energy Northwest COGS.......................................

PS CCGS.. .. .............................. ...... 14 9 (b)(7)(C) GS ... ...................... 11 (b)(7)(C)

W PS, C GS

.................................... ...... 16 (b)(7)(C)

CG S ......................................... 6 NOT FOR PUBLIC DISCLO UR ITHOUT APPROVAL OF FIELD OFFICE DIRECTOR, OFFI F INVESTIGATIONS, REGION IV Case No. 4-2009-049 5

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OFFICIA S0 NFO A ON DOCUMENTARY EVIDENCE Exhibit CGS Work Order details for N and an(b)(7)(C)

(b)(7)(C ) ý d a te d (b)(7)(C ) I................................................................................... 4 CGS ECP Internal Allegation Final Report, j(b)(7)(C) 1dated (b)(7)(C) ........................ 17

-7 Email from (b)(7)(CGS Work Or.der(b)(7)(c) date (7)(C) .............................................. 18 Energy Northwest (EN), CGS, Design Engineering Instruction, DES-2-2, dated O ctober 7, 2008 .................................. ............................................................. . . . 19 NOT FOR PUBLIC DISCLOS RE WIT UT APPROVAL OF FIELD OFFICE DIRECTOR, OFFICE VESTIGATIONS, REGION IV Case No. 4-2009-049 OFF USE ONLY - 01 INVESTIGATI INFORMATION

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OFFICIAL US Y - 01 INVE TONIFR IN DETAILS OF INVESTIGATION Applicable Requlations 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings (2009 Edition) 10 CFR 50 Appendix B, Criterion XVI, Corrective Action (2009 Edition) 10 CFR 50.5: Deliberate misconduct (2009 Edition)

Purpose of Investiqation This investigation was initiated by the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations (01), Region IV (RIV) Field Office, Arlington, TX, on May 27, 2009, to determine if Energy Northwest (EN) or Williams Plant Services (WPS) personnel at Columbia Generating Station (CGS), Richland, WA, willfully failed to follow procedural requirements during the installation of permanent platforms and ladders [Allegation No. RIV-2009-A-0067] (Exhibits 1-3).

Background

On April 29, 2009,1 (b)(7)(c) WPS, CGS, contacted the U.S. NRC, RIV, via email, to report concerns regarding EN and WPS employees circumventing procedural requirements during the installation of permanent platforms and ladders in the "2 over one" areas.

According to __)___c__] CGS work packages have precautions, limitations and prerequisites that require craft personnel and supervisors to contact the (b(7)( or field engineer for the work order if any problems or questions arose during the installation. 1(b)(7)(C) _advised that contrary to this requirement, during the installation of permanent platforms and ladders in the "2 over one" areas, the supervisor went direclv to an N desianer or implementation manager with their problems and failed to notifv te(b)(7)(c) )(7)(C) identified the pertinent CGS work order packages asi(b7(C)

On April 30, 2009, a RIV Allegation Review Board (ARB) met to discuss (b)(7)(C) allegation and determined that additional information was required from regarding his concern. On May 6, 2009,.(b)(7)(c) provided the RIV staff with requested additional information.

On May 26, 2009, the RIV ARB met to discuss ]b)(7)(c) concern and requested that Ol:RIV initiate an investigation to determine if EN and WPS personnel willfully failed to adhere to procedural requirements during the installation of the permanent platforms/ladders over the "2 over one" areas.

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OFFICIAL USE ONLY - 01 INVESTIGATION INFORMATION Coordination with Regional Staff Ol:RIV conferred with the RIV Allegations Coordination and Enforcement Staff at the outset of this investigation.

Allegation: Failure to Follow Procedural Requirements During the Installation of Permanent Platforms and Ladders Evidence Agent's Analysis This investigation was initiated to determine whether EN and WPS personnel willfully failed to adhere to procedural requirements during the installation of the permanent platforms/ladders over the "2 over one" areas at CGS.

In his initial alleaation (b)(7)(C) reviusly identified to the NRC:RIV that CGS Work Orderi (b)(7)(C) were the work orders that were associated with the alleged violate ORI interview, (b)(7)(C) provided copies of CGS (b)(7)(C) . ~~~(b)(7)(C)idnfed0 5W r Work Orders (b)(7)(C) [inclusive an identified CGS Work Orders I _.J and (b)(7)(C) as the CGS work orders that were associated with the alleged violations (Exhibit 5, pp. 7-8, 17, 25, 28).

(b)(7)(C) testified that regarding CGS Work Order7c the workers in the field wanted to use a different bolt cand-aEieldLCha ge Request (FCR) was issued without initially providing fhin P'(lR tsh b ) C) b)(7)(C) it could be incorporated into the Work order.

lnoted that the FOR gies the the authority to chan e the work order so craft: personnel can do the work in accordance with the work package. ý(b)(7)(C) advised that once he was notified of the FCR he made the revision so the job could progress (Exhibit 5, pp. 8-12).

Regarding CGS Work Order (b)(7)(c) (b)(7)(C) advised that this job also involved a

-revision to th type of bolt that needed to be used ,nr,,fhc -z, nning of concrete for rebar.

i(b)(7)(C) stated that ass inn the staedtht he first wok work orderu j he received a FCR without first being consulted and that he should have been contacted in order to view the work site and provide his input (Exhibit 5, pp. 17-20).

Regarding CGS Work Ordei ) (b)(7)(C) i ed that he made a revision to the work order after the problem was identitled. [ noted that he should have been contacted when the issue was first identified, and been consulted as to what course of action should have been taken. Once the appropriate conclusion was determined the outcome of the decision was then incorporated into the work order and sent out to the field (Exhibit 5, pp. 25-27).

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OFFICIAL USE ONLY - 01 INVESTIGATION INFORMATION (b)(7)(C) related that CGS WIrkb7C)rJ- Jb)(7)(C),__ was being performed at the same time/location as CGS Work Orde(b......) As with the previous aforementioned CGS work orders, in this case a FCR was generated without first obtaining (b)(7)(C) input into the project (Exhibit 5, pp. 28 and 29).

(b)(7)(C) -stated he approached (b)(7)(C) rb- c CGS, to voice his crnncrn.- re-rding the work orders but was unsuccessful.( )(7 )(c J noted that he informed~b)(c) _of the need to contact himl (b)(7)(c) when isqi,,qh ar-b t (b)(7)(C) ddi-not have much to say. (*b)(7)(C) sup~ervis ordl(b)7)(c) ýthen contacted (b)(7)(C) I

_NVIPS, CGS, and advised him (_b)(7)(c) . of his~)(7)c) concerns but also was unsuccessful. After his contact with!l)7(c --

I(1contacted (b)(7)(c) CGS to voice his conc (b)(7)(C) was subsequently informed byl( ' Ltat some of the things that he(b)(7)(c) was awre nnt s laid off shortly thereafter an en contacted

[(b)(7)(C) CGS, to reoort his concern regarding the failure to follow the proh in the CGS work orders. (b)(7)(c) leventually received a voice message from (b)(7)(c).

indicating that he(b)(7)(c) found no one who knew or would admit that he(b)(7)(c) raised safety concerns. Ib)(7)(C) had no further contact with c (Exhibit 5, pp. 31-36).

"*c Thq DItRIV int.rvi*.w. n*f (b)(7)(c) 1CGS, l(b)(7)(C) C S aaPd(b)(7)(c)I (b)(7)(c) WPS, CGS, confirmed thal(b)(7)(C) approached each one to di s (b)(7)(C) dissatisfaction with the way work revisions were being completed. l(b)(7)(.)

related that w nges were being made in the field at the same timeý (b)(7)(C) received th (b(b)(7)(C C.ý dvised that work packages have caution Iii ed in the packages so craft wo Id not be make any decisions their ow((7)(C)

.on also indicated that qlthn, H(b)(7)(C) nrfrir th ,- rA,,Q k of a(b)(7)(C) (b)(7)(C)

(b)(7)(C) L(b)(7)(C) 11reported tha " was concerned because he was not being contacted immediately when an issue was discovered but contacted after the fact to revise the work order (Exhibit 6, p. 2 and p. 21; Exhibit 7, pp. 2, 7, 21; Exhibit 8, pp. 2, 7-8).

(b)(7)(C)  !CGS, advised that he wa cognizant engineer for CGS Work Orders)c Iand was familiar with the contents of the work orders. If an FCR was needed for any of the aforementioned work orders

() was the individual that generated it and the only individual that signed off/authorized FCRs pertaining to these work orders (Exhibit 9, pp. 2, 26, 28).

indicated that according to CGS Design Engineering Standard 2-2 (Exhibit 18) there are two processes that can be used to generate a FCR and they only differ in the amount of time that is involved. The traditional FCR goes through the entire approval process and then the work is completed where as the advanced FCR allows the cognizant engineer assigned to that particular project to evaluate what needs to be changed, perform the change, mark up [pen and NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF FIELD OFFICE DIRECTOR, OFFICE OF INVESTIGATIONS, REGION IV Case No. 4-2009-049

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OFFICIAL USE ONLY - 01 INVESTIGATION INFORMATION ink change] the effected documents and issue the documents to the appropriate personnel to include the assigned Planner (Exhibit 9, pp.8-12).

(b)7)c)elated that when it came down to providing technical opinions, regarding the four aforementioned work orders, he (b)(7)(c)ýwas the bottom line. In all cases, his work was reviewed by numerous levels of GS engineering personnel. In the case of(b-)(7)(C) he had to that no the technical best ofinput into the four his knowledca work order *role e(b7)(c) was to l(b)(7)(C) or revisions to the work- oides(b)(7)(C) d

  • _ ýnoted that it is optimal to provide the FCR to theb)(7)(c)/

the work plan can be made (Exhibit 9, pp.14-16).

b)....(C C OGS, advised thatlý Las a A*and part of hi ~)=7=c

  • job wast ____

, r(bi) (7)(C)

FCRs were received. (b(*u beca*me .irritated because on several occasions he

()was delayed in receiving the FCR to be incorporated into the work order and since it was during the outage there was pressure to stay on schedule. C ]testified that to the best of his knowledge there were always engineers in the field;(b)(7)(c) = was a b)(7)(c) and did not provide any technical advice (Exhibit 10, pp. 2, 9, 12-13, 16).

(b)(7)(C) = GIcS"; relate&1at part of his uies at (b)(7)(c)

(b)(7)(C) rovided no technical support to this oroiect and that his!i(b)(7)(C)

(b)(7)(c) job as a (b)(7)(C) was to prepare the (b)(7)(C)

(b)(7)(C) After an F R was isued b the engineer, those recommendations were reviewed at three engineering levels4 ')(7)(C) advised that there is a fast track FCR where the work doesn't stop and the FCR eventually find is wavothe DJanner-to-bejncorr ork order..AfteL eviewing CGS Work Orders (b)(7)(C)

(b)(7)() lwas questioned as to the meaning of the phrase appearing under the Limitations section of the work order, "Return Work Order to Planner for any changes other than editorial.

Contact field engineering/planning for problem resolution or clarification." (b)(7)(C) Itestified that this phrase relates to mundane or very minor changes in the field. If there are minor changes that do not require an FCR, the planner can make the revision. If the changes were more than just minor, an engineer is contacted and an FCR generated by the engineer (Exhibit 11, pp. 2 , 4 , 11-1 2 , 15 , 17-19, 21-23).

(b)(7)(C) f(b)(7)(C) re ported that he spoke toý 1n several occasions and informed him (b)(7)(c) Jthat he was not qualified to provide technical decisions; that it was the E-n-ngineers responsibility to make the final determination. Unfortunatel ( Ithought he should have been more involved in the technical decions and he (b)(7)(C) 11was informed that as (b()()Ehibit 11, pp.28-0)

OGS, advised that he was contacted by (b)(7)(c) Ion March 12, 2009, to report that ladders were installed irde andrx ri rpump house and (b)(7)(%C) (b)(7)(C)

A.2, eahadsrebar in the floor [CGS Work Orderýb7c informed by

, that per procedure, the floor where the suspected rebar was located needed to be NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF FIELD OFFICE DIRECTOR, OFFICE OF INVESTIGATIONS, REGION IV Case No. 4-2009-049 12 OFFICIAL USE ONLY -01 INVESTIGATION INFORMATION

OFFICIAL USE ONLY- 01 INVESTIGATION INFORMATION scanned in order to determine the exact location of h bar. According toi(b)(7)(C)

--- -- ]informed him (b)(7)(c) (tha(b)(7)(C) disagreed with(7C assessment and subsequently advised" (b)(7)(C)

_ r were not going to rescan the floor because it was too expensive (Exhibit 17). (b)(7)(c) noted that upon conducting the ECP investigation (Exhibit 16) he determined that a F R had been issued to change the way_

the ladder would be installed, which would not effect the integrity of the concrete. [(b)(7)(C) reported that it basically came down to a lack of communication betweeni(b)(7 )(c) Fand the supervisory staff. OnceL(b)( 7 )(c) -received the FCR the project was completed without issue (Exhibit 12, pp. 2, 6-8, 10-11).

(b)(7)(C) estified(b)(7 (b)(7)(c) was not qualified or have the abilit to rovide technical enegLineenno oinions and that his (b)(7)(c) role , F(b)(7)(c) to (b)(---c-i(b)(7)(c) (Ex It 2,pp 4 and 15).

P (('

\AIRc S S-ed he was familiar with CGS Work Orders(b)(7)(C) ý ()(7 - related that the(

to be contacted before an FCR is generated and that upon recei t of the FCR I(b)(7)(c) ]job would be to incorporate the F rk ori(n) -th-enotedthat "7c, [_ *Jvvas not an en d that he j use(ib)(7)(C) for technical advice because hel 7 )(c) was the engineer of record (Exhibit 13, pp. 2, 6, 10-12).

(b) tr)(C) advised that he was approache (b)(7)(c) on one occasion ertaining to e reaar in a concrete floor [Work Ordetscan b)(7)(C) (Ex ibit 4 (b)(7)(C) wanted a concrete floor re-scanned for rebar but (b)(7)(C) went t(b)(7)C oti ying (b(7() oget a technical solution. ccording to (b)()((c dtermined that a re-scan waS n cnecessary and (b)(7)(Cofw e decision when he received the FCR from indicating the course of action stated did not

  • n~H t' h*, r~~nt~ct- roarding a technical resolution; that (b)(7)(c) job was to add the (b)(7)(C) (Exhibit 13, pp.14-16).

(b)(7)(C) d t(b)(7)(C) h WPS, CGS, was contacted NR to0 schedule an rn interview.

(b)(7)(C) (b)(7)(C) was advised that ( had contacted the NRC to report a concern he c had regarding W and CGS circumventing procedural requirements durin the Inst In of lad latforms(b)(7)(C) ladvised he did not want anything to do witt*(7)f(c that helw(b)(7)(C- wasl(b)(7)(C) __for employment, and refused to provide any future contact information (Exhibit 14).

(b)(7)(C) WPS, cted to schedule an interview.

(b)(7)(c) in ormed Ol:RIV that spoke (b)(7)(C) his (b)(7)(c) concerns with orms and told (b)(7)(C) hat he (b)(7)(C) ou[d not support his (b)(7)(C) fictitious claims. (b)(7)(C) indicated that he worked in a similar position as (b)(7)(C) and considered all o wor performed to be above board and within procedural guidelines. (b)(7)(C) informed OI:RIV that he had nothing else to add and did not want to be contacted any further (Exhibit 15).

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()(7)(C) (b)IWPS. CGS. testified that he was familiar with CGS Work Orders b (Exhibit 4) .(b)(7)(C) Istated that pertaining to the aforementioned work orders, under Limitations, Section 2.1, where it states, "Return work order to planning for any changes other than editorial", and Section 2.2, "Contact Field Engineer/Planner for problem resolution of clarification", regarding Section 2.1, if there was anythn otherithan minor changes the work order needed to be returned to the planner for revision.E noted regarding Section 2.2, if a problem was encountered in the field an engineer should be consulted. (b)(7)(c) ladvised that(b)-(7)(G) as not an engineer and that7cas assigned as the project engineer to the previously cited work orders (Exhibit 16, pp. 5, 12-14).

(b)(7)(C) reported tha b)(7)(C) was a (b)(7)(C) ýha (b)(7)(C) at CGS.

advised that he was approached by (b)(7)(C) ino the to conduct an additional scan for rebar [(Exhibit 4) CGS Work Order No (b)(7(c) 1(b)(7)(c) indicated that (b)(7)(C) d-AtoDzrvide engineering advice, [regarding the aforementioned work order],

even thoucll(b)(7)(C) __

(b)(7)(C) _as not an engineer and those duties did no~(b)(7)(C)__ (ba(7itin his

-jo-bdecription. As the assigned engineer tQ oject was contacted

-To determine ifian additional scan for rebar was needed an 7 )(C) indicated that it was not necessary (Exhibit 16, pp. 7, 16-20).

In summary, this investigation found no evidence to support that EN and WPS personnel willfully failed to follow procedural requirements during the installation of permanent platforms 1(b)(7)(C) CGS. Although input from all employees should be considered, it appeared that

!as over zealous in his desire to be constantly consulted regarding the structural nte ty of the platforms and ladders when changes to the work packages needed to be made.

l(b)(7)(c) Itestimony clearly stated that he was the "bottom line" when it came to engineering decisions being made. ' regarding

' the platforms/ladders - and after i~~~(ýb)(7)c e- the decisions,

  • )( (cthey were subseauently reviewed by several engineers for accuracy., )(c) noted thatt I(7(C was ab *and as such, provided no technia " "put.Fý()C w r --de e( ()

Conclusion Based upon the evidence developed during the course of this investigation, 01 determined the allegation that EN or WPS personnel willfully failed to follow procedural requirements during the installation of permanent platforms and ladders at CGS was not substantiated.

NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF FIELD OFFICE DIRECTOR, OFFICE OF INVESTIGATIONS, REGION IV Case No. 4-2009-049 14 OFFICIAL USE ONLY- 01 INVESTIGATION INFORMATION

OFFICIAL USE ONLY- 01 INVESTIGATION INFORMATION LIST OF EXHIBITS Exhibit No. Description 1 Investigation Status Record, dated May 27, 2009 (1 page).

2 Allegation Review Board Meeting Minutes, dated May 26, 2009 (2 pages).

3 Branch Evaluation Plan & Recommendation, dated May 26, 2009 (7 pages).

4 CGS Work Order Details, date (b)(7)(C) (13 pages).

(b)(7)(C) 5 Transcript of Interview with dated June 30, 2009 (44 pages).

6 Transcript of Interview with" dated June 30, 2009 (32 pages).

(b)(7)(C) 7 Transcript of Interview wit" dated June 30, 2009 (29 pages).

(b)(7)(C) 8 Transcript of Interview wt dtdJune 30, 2009 (19 pages).

9 Transcript of Interview with (b)(7)(c) ated August 25, 2009 (40 pages).

10 Transcript of Interview with dated August 25, 2009 (31 pages).

11 Transcript of Interview witý(b)(7)(C) dated August 25, 2009 (40 pages).

(b)(7)(C) 12 Transcript of Interview wit dated August 26, 2009 (43 pages).

(b)(7)(C) 13 Transcript of Interview wit dated September 28, 2009 (31 pages).

14 Report of Interview witli- dated June 19, 2009 (1 page).

(b)(7)(C) 15 . Report of Interview witl . dated August 4, 2009 (1 page).

16 Transcript of Interview with (b)(7)(C) dated October 10, 2009 (46 pages).

17 CGS ECP Internal Investigation N dated (4 pages).

18 Emails fro O(b)(7)(c) dated February 24, 2009 (3 pages).

19 CGS Design Engineering Instruction, DES-2-2. dated October 7, 2008 (21 pages).

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