ML17272A470
| ML17272A470 | |
| Person / Time | |
|---|---|
| Site: | Columbia, Washington Public Power Supply System  |
| Issue date: | 03/21/1979 |
| From: | Bishop T, Haynes R, Shackleton O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17272A467 | List: |
| References | |
| 50-397-79-03, 50-397-79-3, 50-460-79-04, 50-460-79-4, 50-513-79-04, NUDOCS 7906150079 | |
| Download: ML17272A470 (12) | |
See also: IR 05000397/1979003
Text
U. S.
ffUCLEAR REGULATO..Y COllfiISSIO."f
OFFICE
OF IflSPECTIOH AffD EHFORCEalEffT
50-397/79-03
50-460/79-04
Report
Np
50 513/79 04
BBB39
. 50-460
'ocket. tio.'0-513,
REGIOif V
License
Ho.
Safeg ards Group
Washington Public Power Supply System
P,. 0.
Box 968
Richland, llashington
99352
Niam
.
Washington Nuclear Project
Ho.
2
(WHP-2) 5 1/4
(WHP-1/4)
Investigation at:
WNP-2, and 1/4 Sites,
Benton County, Washington
Approved By:
Inueatiga~ti
nduct d:
February
1-2 and 14-15,
1979
I-pe.t.rs:
~i<!/
T.
.
isho
R
ctor Inspector
/
/
0. C. Shackleton,
Investigator
R. C. Haynes,
ref, Projects
Section,
Reactor
Construction
n
Engineering
Support
Branch
Z/
7p
Date Signe
ate Signe
Wj 7
Date Signed
Su+nary:
Investigati'on
on February 1-2 and 14-15,
1979 (Report Nos.
50-397/79-03,
an
Areas Investi ated:
Unannounced
investigation
by regional
based
personnel
of
reported
improper signoffs of procedures
under the jurisdiction of a subcontractor
performing work at the
WNP-2 and
WNP-1/4 sites;
types of documents
involved; nature
and reason for improper signoffs;
and licensee
stop work orders and,actions
taken
following issuance
of the stop work order.
The investigation involved 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />
onsite
by an
NRC inspector
and
an
NRC investigator.
Results:
Two items of noncompliance
were identified as
a result of the
1nvestlgation
(Infractions - failure to take effective corrective action in
response
to an audit finding, and failure to implement
an effective inspection
program,
see
Paragraph
5).
'g90615QO~
.
JE / Form 219 (2)
DETAILS
Princi al
Persons
Contacted
Princi al Licensee
Em lo ees
2.
- A. D. Kohler,
WNP-2 Project Manager
- J. C. Janus,
WNP-2 Construction
Manager
- M. E. Witherspoon,
gA Division Manager
- A. M. Sastry,
WNP-2 gA Manager
- T. J. Houchins,
WNP-1/4 gA Manager
Burns
8 Roe, Inc.
- R. C. Root,
WNP-2 Deputy Project Manager
- M. J. Parise,
WNP-2 Deputy gA Manager
- ~S'. Young, Senior
gA Engineer
Boeinq Construction
Com any
(BOECON)
D. Taylor,
gA Manager
The Waldin er Cor oration
(TWC)
G. Barber, Chief Project Manager
G. Wells, Project Manager
C. Boswell, Corporate
gA Manager
S. Loeffler, Site
gA Supervisor
P. Persell,
Corporate
gA Engineer
Industrial Heatin
and
Plumbin
Com an
(IHP)
E. Rasco,
Project Manager
D. King, gA Manager
- Denotes those present at exit interview on February 2, 1979.
- Denotes those present at exit interview on February 14, 1979.
Back round/Initial
NRC Notification
On January
31, 1979,
a representative
of the Washington Public Power
Supply System notified the
NRC
RV that
a quality audit at WNP-2 had
disclosed
possible
approval
signature irregularities
on quality re-
'lated work procedures.
The procedures
had been generated
to support
quality class
I pipe support fabrication for the Industrial Heating
and Plumbing
Company (IHP).
IHP is
a subcontractor
to the
WNP-2
prime
HVAC contractor,
The Waldinger Corporation
(ThC), and is in-
stalling seismic supports for roof drain, equipment drain, sanitary
'
4
I
-2-
drain,
and potable water piping systems.
While the piping systems
'hemselves
are not safety related,
the licensee
has established
that
the supports for these
systems,
within the Reactor Building, are
seismic class
I and quality class
I to provide protection for safety
related
systems
in that building.
Licensee representatives
reported
further, that
IHP had
been directed to stop all quality class
I work
at the
WNP-2 site.
An NRC inspector
and
an investigator
were dispatched
to the
WNP-2
site on February 1, 1979,
where it was determined that the following
sequence
of events
preceded
the identification of questionable
approval
signatures
on work procedures:
A Burns
5 Roe audit of TWC on August 4, 1978 (Audit No. 216-78-2),
established
that
TWC had failed to perform audits of its subcon-
tractorss
(which includes
IHP).
TWC reported at that time that
an audit of IHP would be performed in September
1978.
The audit
completion date
was subsequently
postponed
by TMC to January
2,
1979.
The audit,
however,
was not accomplished
by that date.
On January
23, 1979, allegations
were made to the Project
gA
organization regarding
the quality activities being performed
by IHP at MNP-2. It was alleged that the former
gC supervisor's
stamp
was being used for backdating
records
and that
gC inspec-
tors were being asked to make entries
on records that had already
been completed,
On January
31, 1979, the licensee
issued
a letter
(No. MNP2MC-216-F-79-129) to
Tl<C directing them to perform an
audit of IHP within five working days.
The audit was initiated
on January
31, 1979.
Due to the existence of the allegations,.a
Project
OA representative
participated in the audit.
On January
31,
1979, the audit identified three
IHP work procedures
containing
questionable
approval
signatures.
Specifically,
IHP procedures
P-121
(entitled
"Weld Identification System" } and
P-133 (entitled
"guality
System Audits") were found to have approval
signatures
of one individual which appeared different from other signatures
in the records for that
same individual.
IHP procedure
P-118
(entitled
"NDT (Visual Inspection)" ) was found to have revision
1
approval
signatures
cut out and taped to revision
2 of the proce-
dure to signify approval of revision 2.
Upon identification of
these conditions,
TMC immediately issued
a stop work order to
IHP.
Licensee representatives
notified the
NRC of the apparent
irregularities the
same day.
IHP is also
a subcontractor
at the MNP-1/4 site.
Accordingly, on
February 2, 1979,
IHP was directed to stop all quality class
I
work on that site.
-3-
3.
Licensee Action at the
WNP-2 Site
~
~
~
On February 1, 1979, clarifying instructions
were issued
regarding the
stop work order at MNP-2
(TMC letter No. SC-708).
The instructions
established
that all quality class
I IHP records
would be under the
control of TMC and that access
to the files would be
by authorization
only.
A records
review team
was established
composed of WPPSS/B&R
gA personnel
and
TMC personnel.
The-review team examined all of the
records,
drawings,
and procedures
(pertaining to IHP quality class I
work) for signature inconsistencies
and other documentation
problems.
In addition,
each of the
IHP gC personnel
and the former
IHP gC super-
visor were interviewed.
The review'as
concluded
on February 5, 1979,
and identified several
documentation
problems;
these
were:
use of the previous
gC super-
visor s signature
stamp after his termination, missing signatures;
use of "white-out" for correction; corrections
not initialed, and
printed: or typed
names in lieu of signatures
or stamps,
in addition
to the three improper document signoffs initially identified.
The
documentation
deficiencies
were recorded
on
TMC audit finding 'reports.
In addition to document reviews, the licensee
and
TMC conducted inter-
views with currently employed
and previously employed
IHP gC personnel.
During an interview with the former .IHP supervisor,
he reportedly
stated that:
(a)
he
had probably cut out and taped
approval
signatures
in
Procedure
P-118;
(b)
he could have written the questionable
approval
signature
on procedure
P-121;
(c)
he may have applied the signatures
because
of the urgency
of the work and in the interest of getting the job done;
he
also noted that
he had written the original documents.
and was,
therefore,
thoroughly knowledgeable of their acceptability;
and
(d)
he
had provided his signature
stamp to IHP for use after his
termination to authenticate
some inspections
he
had performed,
but not yet documented;
he indicated that notes
were retained
in IHP which identified the various inspections
he had per-
formed, but not documented.
The
TMC interviews with other"IHP
gC personnel
reportedly established
that:
l,
f j
(a)
inspectors
and clerks
had
been directed to use inspection
stamps'nd
signature
stamps of personnel
other than themselves
(the
former gC supervisor);
(b)
(c)
inspections
had
been
conducted to criteria more lenient than
specified in the approved
program;
weld rod traceability,
as
documented
on rod withdrawal slips,
was not valid; and
(d)
that nonconforming conditions were not properly dispositioned.
On February 7, 1979, the contractor
directed
IHP to:
retype,
review
and resubmit for approval
each of the procedures
which contained
ques-
tionable signatures;
instruct all personnel
in the method of properly
completing records; reinspect all work in progress
or previously com-
pleted which was affected
by questionable
documentation
or revised
inspection criteria;
and take immediate action to correct the
improper directions given to
gC personnel.
By February 12, 1979, the retraining of IHP personnel
had
been
'ompleted
and appropriate
procedure corrections
had
been
made to
permit resumption of quality class
I work.
Two
TWC gC personnel
were assigned
to
IHP to provide additional
assurance
of quality
work.
In addition,
TllC initiated
a comprehensive
audit of IHP
to assess
the adequacy of IHP in areas
which may not have been
examined during the investigation.
This audit was scheduled
to be
completed
on February
16, 1979.
Licensee Action at the
WNP-1/4 Site
IHP is a subcontractor
to Boeing Construction
(Boecon) at the
llNP 1/4
site and
has responsibilities for installing drain piping, pipe sleeves,
concrete inserts
and restraints
in the general
service
and containment
buildings at
NNP 1/4.
The majority IHP work at >NP 1/4 is ultimately'-
buried in concrete
and is usually not available for inspection follow-
ing concrete
placement.
Therefore, to assure
work has
been properly
completed,
and to avoid the necessity to remove concrete for rework,
Boecon routinely performs
a records
review and inspection of IHP work
before concrete
placement.
Following the stop work order on February 2, 1979,
IHP's quality
assurance
records pertaining to
lJNP 1/4 work were secured
by Boecon.
The ensuing investigation
by licensee,
United Engineers
8 Constructors
(the construction manager),
and
Boecon personnel
included -a review
of IHP piping package
work documents
which have not been previously
acceptable
by UEKC,
a sampling of the document
packages
which have
been turned over to UE8C, and
a review of IHP work procedures.
The
investigation
was concluded
on February
5, 1979,
and revealed
pro-
blems of material
heat
number traceability, missing signatures,
use
of white-out for correcting paperwork,
typed or printed
names in
lieu of signatures,
inconsistencies
of procedure revisions,
and the
apparent
issuance of weld rod by non-inspection
personnel.
These
problems were identified in the work packages
which had not been
accepted
by UESC.
The review of records which were accepted
did
not identify any of the above noted problems.
As a result of the investigation,
IHP was directed to correct all
items affecting work in progress
(or future work) prior to embedment
'of the items, correct deficiencies relating to procedures,
and review
and correct all weld rod requisitions.
Based
on the corrective
actions
IHP was allowed to return to work on February 5, 1979.
To
assure
implementation of the corrective actions,
Boecon scheduled
a followup audit on February
16, 1979.
NRC Actions at WNP-2 and MNP-1/4 Sites
The
NRC inspector
and investigator were dispatched
to the sites to
determine the circumstances
surrounding the reported
improper docu-
ment signoffs and examine the actions
being taken
by the licensee.
This was accomplished
by conducting interviews with cognizant
IHP
employees
and
a former employee,
examining completed quality class
I
work packages,
reviewing selected
IHP work procedures,
inspecting
completed
IHP quality'class
I work, and examining documentation of
the licensee's
corrective action.
It was noted that
IHP quality class I work at the
MNP-2 site was just
beginning, with only eight class
I pipe supports
having
been installed.
On February 2, 1979, the inspector
and investigator
examined
seven of
the eigh't supports
and accompanying
record packages.
It was determined
from the examination
and personnel
interviews, that, in addition to
the problems identified by the licensee's
investigation,
the
IHP
quality inspection
program at the
MNP-2 site is not in compliance with
10 CFR 50 Appendix
B requirements.
This fact was evidenced
by one of
seven supports
(No. RD-405) being improperly installed, the inadequacy
of inspection reference material
(no means to verify proper shock arrestor
identification), and the use of an unapproved
inspection
procedure
(entitled "Procedure for Handling the Hanger Installation Inspection
Reports).
The failure to implement
an effective inspection
program
is an item of noncompliance.
(50-397/79-03/01)
The inspector also found that during an audit of TMC by the licensee
in August 1978, it was identified that
TMC had not performed audits of
its subcontractors
(IHP).
Also, as of January
31, 1979,
adequate
cor rec-
tive actions
had
been taken
on this audit finding.
Licensee representa-
tives explained that during this
same time period
TWC was experiencing
I
its own problems,
and did not have the resources
to address its own
problems
and meet its audit responsibilities
simultaneously.
The
licensee,, therefore,
did not press
the requirement for
TMC to perform
subcontractor
audits.
However, the inspector found that the licensee
did not provide actions to compensate for this reduction of quality
assurance
coverage.
The failure of the licensee
to take adequate
followup action in response
to their audit findings at the
HNP-2 site
is an item of noncompliance.
(50-397/79-03/02)
At the
MNP 1/4 site it was established
that each portion of IHP
work is accepted
by Boecon prior to embedment in concrete.
This
additional
check explains
why the "accepted"
record
packages
at
the WNP-1/4 site were free from deficiencies.
In addition, it was
determined that Boecon
had
been actively auditing
IHP activities at
the HNP-1/4 site in accordance
with the quality assurance
program
requirements.
No items of noncompliance or deviations
were identi-
fied at the WNP-1/4 site.
The effectiveness
of the licensee's
followup actions at the
>JNP-2
and MNP-1/4 sites will be evaluated
during subsequent
routine
inspections.
(50-460/79-04/01)
6.
Mana ement Discussions
The pertinent details of the investigation were reviewed with
licensee
management
representatives
on February
2 and 14,
1979,
as indicated in Paragraph
1 of this report.
I-
t
1
'