ML19257C423
| ML19257C423 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1979 |
| From: | Agee J, Hale C, Herr R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19257C419 | List: |
| References | |
| REF-QA-99900224 99900224-79-2, NUDOCS 8001290096 | |
| Download: ML19257C423 (14) | |
Text
J U.S. NUCLEAR REGUL TORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900224/79-02 Company:
Bailey Controls Company 29801 Euclid Avenue Wickliffe, Ohio 44')92 Investigation Conducted:
November 6-8, 1979 Inspectors:
7(.A/.Tj M y fr/7/79 R.H.Brickley,P[incipalInspector Da t.e Program Evaluation Section Vendor Inspection Branch W d 57<-
lL/7f71 J. Fjf Agee ftontractor Inspector Date ComponentsSection II Vendor Inspection Branch Investigator: W. h/, S M k b f
,2/7/79 p R. K. Herr, Invest'igator Date G
D
['2~7~7 Approved by:
C. J. Qtt3T, Chief Date Program Evaluation Section Vendor Inspection Branch Summary Investigation on November 6-8, 1979 (Report No. 99900224/79-02)
Areas Investigated:
Special investigation of allegations concerning e.g.
falsification of inspection records, use of unqualified inspectors, in-spector training, inadequate inspection samples and source inspections.
The investigation involved sixty-three hours on site by two (2) NRC inspectors and one h7C investigator.
Results: None of the atlegations could be substantiated. There were no deviations or unresolved items identified.
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2 INTRODUCTION The Bailey Controls Company, a subsidiary of the Babcock & Wilcox Company, designs and manufactures electrical and electronic instrumentation, controls, control systems, computers, and data acquisition systems for major industries including the commercial nuclear power industry.
REASON FOR INVESTIGATION On August 22, 1979, the President's Commission on the accident at Three Mile Island received letters from individuals alleging improper quality control practices at Bailey Coatrols Company.
Additional documentation from one of the individuals to this commission appeared to corroborate his allegations.
On October 25, 1979, the chairman of the President's Commission referred the allegations to the Office of Inspection and Enforcement for investigation.
SUMMARY
OF FACTd On November 6-8, 1979, a team from the Region IV Office of Inspection and Enforcement conducted an investigation into these allegations which concerned falsification of inspection records, use of unqualified inspectors, inspector training, inadequate inspection samples, source inspection, failure data reports, waiving of inspections, certification of inspections, stockroom audits, and system checkout.
CONCLUSIONS None of the allegations could be substantiated.
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DETAILS SECTION A.
Persons Contacted Individual A, Alleger Individuals C through I, Hourly Inspection Personnel Individuals J through M, Salaried Inspection Personnel
- V.
C. catalano, Manager, Quality Control J. D. Courtwright, Contract Engineer R. P. D'Amico, QA Information Analysist
- G. M. Kohl, Director, Quality Assurance J. W. Ferencic, Contract Quality Engineer W. L. Hinkel, QC Engineer
- H.
Howe, Audit Coordinator D. E. Nelson, Contract Quality Engineer
- Denotes attendance at the exit interview.
B.
Investigation Details The allegations and resultant investigative findings are stated below:
1.
Allegation No. 1 Individual A alleged that salaried personnel are inspecting the nuclear hardware that is being shipped out; however the items are not actually inspected but merely stamped as such.
Investigation Findings The local union at Bailey Controls Company (BCC) was on strike from May 31, 1979 until approximately two (2) weeks prior to this inves-tigation. During this period unique inspection stamps were issued to thirty seven (37) salaried personnel for use in assigned inspection activities throughout the plant. The issuance of these stamps was found to have been authorized by Bulletin No. 1, dated January 4,1979, to BCC Instruction No. 1764-01-01 (Inspection, Test, and Calibration Stamps).
Interviews with individuals J through M revealed that none admitted receiving any type of pressure and/or harassment to stamp orders without inspecting them, all denied any knowledge of any inspector stamping orders without the proper inspection, and all maintained that nuclear related items are given special attention to assure that all items are inspected properly.
An examination of Manufacturing Order (MO) No. 531635 for nuclear pressure transmitters (Purchase Order No. 023825/26LJ) verified that, during the manufacturing assembly, each of the transmitters was in-spected and stamped at each inspection station including final inspec-tion.
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4 Although salaried personnel of BCC were performing inspection func-tions during the period of the strike, the allegation that the items are not actually inspected but merely stamped as such, could not be substantiated.
2.
Allegation No. 2 Individual A alleged that NRC inspectors merely look at the paperwork and never talk to the person who is identified on the paperwork to determine if that person actually inspected the item. If they did talk to the identified inspector they would find that the inspector may not have inspected the item.
Investigation Finding An NRC inspection consists of several elements i.e. examination of procedures and representative records, interviews with personnel and observations by the inspector.
The performance of each of these elements depends on the area of the inspection, activity being con-ducted at the time of the it pection, and the inspectors expertise in that activity.
Discussions with BCC representatives indicated that they had been present during past inspections when the NRC inspector interviewed inspection / shop personnel. Furthennore, interviews with individuals C through I revealed no instance where they or any other individual had used an inspection stamp without inspecting the item as required.
They all maintained that nuclear related items are given special attention to assure that all items are inspected properly.
The allegation could not be substantiated.
3.
Allegation No. 3 Individual A alleged that a Shipping Order identified as P-614638 is stamped inspected by No. 123 on April 10, 1979, and that No. 123 did not inspect the shipping order.
Investigation Findings An interview with the individual assigned inspection stamp No.123 re-vealed that his stamp signified that the quantities of the listed pro-ducts were contained in the shipment.
It did not signify that he had performed all of the required inspections. He further stated that he did not and would not affix his stamp unless he personnaly per-formed the required inspection.
The allegation could not be substantiated.
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5 4.
Allegation No. 4 Individual A alleged that, to prevent backlog problems, inspectors are made to pass (stamp as inspected) all incoming material without inspec-tion, or at most one piece.
This includes items concerned with nuclear power. Receiving inspection records are being kept falsely as to the amount being inspected and inprocess inspections are handled the same way.
Investigation Findings Interviews with individuals C through I revealed that none admitted receiving any type of pressure and/or harassment to pass (stamp as inspected) any material without inspection and all indicated that they would not succumb to such pressure and/or harassment. All of these individuals denied any knowledge of any inspector stamping orders without the proper inspection and maintained that nuclear related items are given special attention to assure all items are inspected properly.
The examination of BCC records revealed that in September 1978 the Manager, Quality Control issued two (2) memos to Receiving Inspection authorizing two (2) QC Engineers to waive inspection on selected purchase order items with known history of quality, catalog items etc.
An interview with one of the engineers authorized to waive inspections revealed that he had waived or reduced inspection require-ments only twice and these were non-nuclear items. He stated that at all other times they followed Military Standard 105D or the special inspection requirements for nuclear items.
Thirteen (13) Receiving Inspection History Cards were examined by the inspector.
In all cases the total number of items received, the total number inspected, total number defective, total number rejected, and the inspector's stamp were found to be on the card.
In all cases where an item was found defective the entire lot had been rejected.
In addition Manufacturing Order (MO) No. 531635 for Purchase Order 023825/26LJ (Nuclear Pressure Transmitters) was examined which re-vealed that during the manufacturing assembly of the transmitters each transmitter was inspected and stamped at each inspection station, including final inspection.
The allegation could not be substantiated.
5.
Allegation No. 5 Individual A alleged that, at the outgoing end (shipping), inspectors are made to stamp certificates of compliance which they indeed have never inspected.
If they do not do this they are threatened that they will be replaced by someone who will.
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6 Investigation Findings Interviews with individuals C through I revealed that none admitted receiving any type of pressure and/or harrassment to paso (stamp as inspected) any material without pection and all indicated that they would not succumb to su fressure and/or harassment.
Note: Also see Investigation Findings for Allegation No. 3.
The allegation could not be substantiated.
6.
Allegation No. 6 Individual B alleged that controls shipped to nuclear power plants, including the Three Mile Island reactor, may not have received proper inspection before leaving this plant.
In addition, it appears that the company may have falsified inspection records and misled the Nuclear Regulatory Commission (NRC) about the inspection program.
Investigation Findings The results of interviews with individuals C through I are reported under the Investigation Findings paragraph of Allegation No. 4 and those with individuals J through M under Allegation No. 1.
The inspector also examined the records maintained by BCC on the Babcock & Wilcox (B&W) Purchase Order No. 07252VB dated August 5, 1978 for two (2) each of Part Nos. 6618196C1 (Converter, Pulse Spacing to Rectify Wave), 661894A2 (Converter Volt to Pulse Spacing),
and 6618192Al (Amplifier Assembly) for shipment to Three Miles Island-Unit 1.
These records consisted of the B&W purchase order, Certificate of Compliance Request (Form E1810-477), Certification No. AD11078, Invoice and Shipping Order No. P-614638, Certificate of Compliance dated April 10, 1979, and thirteen (13) Receiving Inspection History Cards for parts used in the manufacture assembly of the Amplifier Assembly. All documents appeared to meet the applicable instructions of the BCC Inspection Handbook.
The allegation could not be substantiated.
Note:
Individual B submitted a letter intended to support the allegations of Individual A.
7.
Allegation No. 7 Individual B alleged that approximately nine months ago (September 1978) the company stopped inspecting a random sample of parts pro-duced or purchased.
Instead, the company instructed inspectors to select only one piece, from the total produced, for inspection.
The change was made to eliminate backlogs in the parts to be inspected and to speed handling.
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7 Investigation Findings Interviews with individuals C through I revealed that all individuals maintained that nuclear related items are given special attention to assure that all items are inspected properly.
The examination of BCC records revealed that in September 1978 the Manager, Quality Control issued two (2) memos to Receiving Inspection authorizing two (2) QC Engineers to waive inspection on selected purchase order items with known history of quality, catalog items etc. An interview with one of the engineers authorized to waive inspections revealed that he had waived or reduced inspection require-ments only twice and these were for non-nuclear items.
lie stated that at all other times they followed Military Standard 105D or the special inspection requirements for nuclear items.
The examination of Receiving Inspection History Cards for thirteen types of the parts used in manufacturing assembly of the Amplifies Assembly for Three Mile Island-Unit 1 revealed several cases where one sample of a lot was inspected e.g. one out of 51,000 of Part No. 1942333 (Power Diode) on 4/22/78, one out of 30 of Part No.
6618188 (Heat Sink) on 11/21/78, one out of 5,000 of Part No.
1943207 (Transistor Socket) on 10/5/79, etc.
It should be noted that none of the receiving inspection records examined identified any of the parts as Commercial-Nuclear.
The examination of MO No. 531635 for nuclear pressure transmitters (PO No. 023825/26LJ) verified that, during the manufacturing assembly, each of the transmitters were inspected and stamped at each inspection station including final inspection.
Discussions with BCC management representatives revealed that the MIL STD-105D sampling plan was adapted by BCC per a management decision rather than by a nuclear customer requirement.
Additionally, all parts, other than special orders, obtained from BCC suppliers go to the stock room for issuance on both non-nuclear and nuclear M0s.
Those parts issued for nuclear M0s receive inspections per MIL STD-105D or the special inspection requirements for nuclear items as defined in the P0, MO, drawing, etc.
Although at times, only one piece of a lot is inspected for parts in receiving inspection, this allegation could not be substantiated for manufacturing, system checkout, or shipping order inspection. Note:
None of the records (P0s etc.) applicable to nuclear items required compliance with MIL STD-105D.
The allegation that the change in sample size was done to eliminate backlogs and to speed handling could not be substantiated.
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8.
Allegation No. 8 Individual B alleged that old system of inspecting was done according to the Military Standard 105 sampling plan which was specified by many customers and from what I understood is re-quired for parts to be used in nuclear operations.
Investigation Findings Discussions with ECC management representatives revealed that the Military Standard 105 sampling plan was adopted by BCC per a manage-ment decision rather than by a nuclear customer requirement. Further-more none of the nuclear related Pos examined by the inspectors in-voked this standard on BCC. Neither of the NRC inspectors had any knowledge of an NRC requirement to follow this standard.
The allegation could not be substantiated.
9.
Allegation No. 9 Individual B alleged that plant inspectors find the single piece inspection system so meaningless that even if the piece is flawed the entire batch is OK'd anyway.
Investigation Findings Interviews with individuals C through M did not reveal any instance in which a batch of parts was accepted when only one part was in-spected and found defective.
In addition, the examination of inspec-tion records on nuclear related parts / products did not reveal any case in which a batch of parts was accepted when only one part was inspected and found defective.
The allegation could not be substantiated.
/
10.
Allegation No. 10 Individual B alleged that when backlogs build up, even single piece inspections are waived and entire batches of parts are stamped as OK.
Investigation Findings The examination of BCC records revealed that in September 1978 the Manager, Quality Control issued two (2) memos to Receiving Inspection authorizing two (2) QC Engineers "to waive inspection on selected pur-chase order items with known history of quality, catalog items etc."
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J An interview with one of the engineers authorized to waive inspections revealed that he had waived or reduced inspection requirements only twice and these were non-nuclear items.
He stated that at all other times they followed MIL STD 105D or the special requirements for nuclear items.
In addition, the examination of inspection records on nuclear related parts / products did not reveal any case where no in-spections were performed.
The allegation could not be substantiated.
11.
Allegation No. 11 Individual B alleged that when the Military Standard 105 inspection plan was abandoned, the company instituted a program sending inspec-tors to vendors from whom parts are purchased. Two inspectors travel to the vendors to make spot checks. However, the individual believed that two persons could not possibly cover all the vendors adequately.
Furthermore, there were criticisms of the level of training of these inspectors.
Investigation Findings An interview with one of the individuals assigned to vendor source inspection revealed that he felt that he has and could adequately cover all vendors assigned to him. He stated that all the vendors were in the Cleveland area and that many of the inspections involved several different parts at a single vendor.
The examination of the individual's resume and personnel records re-vealed that his level of education and experience exceeded those of non-salaried inspection personnel.
The allegation could not be substantiated.
12.
Allegation No. 12 Individual B alleged that when several of the source inspected parts were found to be flawed, these inspectors were told to stop checking parts received from vendors.
Investigation Findings Interviews with individuals C through I did not reveal any instance where items coming into receiving inspection were not inspected.
The inspector's examination of thirteen (13) Receiving Inspection History Cards for parts used in the Manufacture assembly of the 183'3t 210
J 10 amplifier for TMI-I did not reveal any instance where an inspection was not performed.
In addition it is common practice in industry to designate acceptance inspection as either prior to shipment from the supplier's plant, upon receipt at the buyer's plant, or a combin-ation of both types of inspection.
The allegation could not be substantiated.
13.
Allegation No. 13 Individual B alleged that in the Shipping Department, parts are often certified as inspected before being shipped and that certifications are made by persons who do not have the capacity to perform the in-spections themselves.
Investigation Findings An interview with an individual who signed a Certification of Com-pliance revealed that his signature indicates that he has reviewed the inspection records and/or the part and verified that all required inspection stamps are in place. The individual indicated that he had been assigned as an inspector shortly before the strike and had performed his duties under the direction / guidance of an experienced inspector.
The examination of the individuals' personnel records revealed that he had been employed by BCC for eleven (11) years in various shop positions.
lie was assigned as an inspector on March 12, 1979 and appeared to have the capacity (training and experience) comparable to others in his classification.
Parts are often certified as inspected before being shipped; however, this is common by acceptable practice in industry.
The allegation that certifications are made by persons who do not have the capacity to perform the inspections themselves could not be substantiated.
14.
Allegation No. 14 Individual B alleged that others knew of parts shipped to the Three Mile Island reactor which had been certified as inspected, but which in reality were not inspected.
Investigation Findings See Investigation Findings for Allegation No. 6.
The allegation could not be substantiated.
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Allegation No. 15 Individual B alltged that in the past, stock was randomly checked for a variety of purposes:
correct labeling, damage, proper packaging, etc.
However this program was stopped nine months ago.
Investigation Findings The inspector examined the records (Stockroom Audit Checklist) of thirty (30) stockroom audits conducted from January 1, 1978 through May 31, 1979, that included labeling, damage, packaging, etc. Twelve (12) of these audits were conducted between January and May 1979.
The allegation could not be substantiated.
16.
Allegation No. 16 Individual B alleged that when electrical failures were ncted in the systems the failures were suppose to be noted on a special form, which is reviewed by NRC inspectors. However this practice was not enforced until a new program was announced May 8, 1979.
Investigation Finding The inspector verified that during systems checkout faulty components are identified on a data failure report form and submitted to the QA information analyst who compiles several types of data failure reports to determine the need to initiate long term test and analysis pro 3 rams on specific parts, modules or systems.
NRC inspectors may or may not inspect the reports on their routine announced inspections. NRC inspection of the failure data reports would be conducted at the discretion of the NRC inspector on a random selective basis to fulfill the inspector's inspection plan but would not be conducted for the convenience of the company inspected.
The inspector verified the data failure analysis program was initiated in July 1974 and continued until May 1979. All the records of this data are available for review upon request.
Completion of this data was discontinued during the Company strike from May to November 1979.
Accumulation of data for the systems failure data reports was resumed following the strike in early November 1979.
Electronic failures are noted on a special form. The allegation that this practice was not enforced until May 8, 1979 could not be substan-tiated.
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12 17.
Allegation No. 17 Individual B alleged that as individual modules are assembled into complete control panels, they are checked to see if the systems work.
Little is known about problems here since it is done by salaried personnel.
Investigation Finding The inspector found that it is standard accepted practice for systems to be checked by salaried personnel and faulty components reported to QA via a failure data report.
The allegation could not be substantiated.
18.
Allegation No. 18 Individual B alleged that it is routine for " complete" panels to be checked before completely assembled and shipped to the customer.
Missing modules are shipped later for installation, commonly without receiving inspection prior to leaving the plant. Moreover, replace-ment parts never receive this checkout at the plant.
Investigation Finding In the investigation it was determined that on nuclear safety related systems customer approved system specifications, description and checkout procedures and QA Documentation Manuals are used exclusively throughout the system checkout.
Each test is accepted based on con-formance to the customer approved system description and specification.
All failures are evaluated upon discovery and retested as required.
All discrepancies including module failures and customer equipment failures and all additions and deletions are documented in the System Log Book per Program Management Instructions. Discrepant modules are repaired or redesigned and replaced before system checkout is approved.
It is mandatory that replacement parts (modules) receive multiple inspections and stamps before release from manufacturing, therefore any replacement modules are inspected before used in the systems.
No nuclear safety related systems are shipped with missing modules.
The allegation could not be substantiated.
19.
Allegation No. 19 Individual B alleged that personnel were concerned about the lack of an ongoing training program for inspectors, which is required to maintain licensing by the NRC.
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13 Investigation Findings It should be noted that neither BCC nor their inspectors are licensed by the NRC; however, interviews with individuals C through M did not reveal any concerns about inspector training.
The examination of personnel training records on these individuals revealed that they had received on-the-job training at various times covering several topics e.g.
Shop Math, Metrology, Use of Inspection Equipment, etc.
In addition some people had attended courses at the local college under the Babcock & Wilcox (BCC is a subsidiary of B&W) educational refund plan. This plan applies to all BCC personnel both salaried and hourly.
The allegation could not be substantiated.
20.
Alegation No. 20 Individual B alleged that some inspection programs which are normally not done are reinstituted when the NRC inspector is in the plant, then promptly abandoned again.
Investigation Findings Interviews with individuals C through I did not reveal any instance where an inspection activity was instituted because of an NRC or customer inspection of BCC.
All individuals indicated that they had no advance knowledge of an NRC inspection including the present inves-tigation.
The allegation could not be substantiateo.
C.
Exit Interview 1.
Individual A An interview was held with Individual A on November 7, 1979. The Individual was informed of the results of the investigation thus far and was requested to provide objective evidence and/or clarification of the allegations. The Individual could not provide any objective evidence and it appeared, from the response to our questions, that the allegations were based on opinion and/or discussions with other persons.
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14 2.
BCC Management An exit interview was held with management representatives on November 8, 1979.
In addition to those individuals indicated by an asterisk in para-graph A, those in attendance were:
L. A. Blyth, Manager, QA Lab., BCC M. A. Keyes, Vice President, Engineering, BCC J. A. Pittman, Acting President, BCC R. Wachniak, Director of Quality, Babcock & Wilcox The inspector summarized the scope and findings of the investigation.
Management comments were generally for clarification only, or acknow-ledgment of the statements by the inspector.
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