ML19343D400

Transcript of Testimony on Alleged Incidents of Document Falsification.Related Correspondence

ML19343D400
Person / Time
Site:	South Texas
Issue date:	04/27/1981
From:	Logan T, Mckay W HOUSTON LIGHTING & POWER CO.
To:
References
ISSUANCES-OL, NUDOCS 8105040411
Download: ML19343D400 (13)

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.Whg 0 UNITED STATES OF AMERICA y 1 NUCLEAR REGULATORY COMMISSION /' h h( c 2

3, f' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD o

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5 6l 7t 3l TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET g.

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0: OF MR. W. STEPHEN MCKAY 3; MR. TIMOTHY K. LOGAN 4!

5! ON 7 ALLEGED INCIDENTS OF DOCUMENT FALSIFICATION

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} BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3

L 3 In the Matter of: $

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! HOUSTON LIGHTING & POWER S Docket Nos. 50-4980L 4

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(! TESTIMONY OF W. STEPHEN McKAY AND TIMOTHY K. LOGAN 2i ON ALLEGED INCIDENTS OF DOCUMENT FALSIFICATION 3i 3 ,

Q. 1 Please state your names.

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A. 1 W. Stephen McKay (WSM) and Timothy K. Logan (TKL).

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Q. 2 Mr. McKay and Mr. Logan, by whom are you employed?

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Ll What is your current position?

2l A. 2 (WSM): Pittsburgh Testing Laboratory (PTL) . I 3

g am Corporate Manager for Quality Assurance (QA) in the 5i g: Pittsburgh Home Office of PTL.

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(TKL): Houston Lighting & Power Company (HL&P). I am 3

Project QA Supervisor on HL&P's W. A. Parish Unit #8 Project, 3l L a coal fired power plant, under construction at Thompsons, 2:

3, i Texas.

I' 3 Q. 3 Please describe your professional qualifications.

i 7j A. 3 (WSM, TKL): These are set forth in our earlier 3i testimony on the placement and compaction of backfill at

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3! STP.

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Q. 4 What is the purpose of your testimony?

1 Tl A. (WSM, TKL): The purpose of our testimony is to 3l

)[ addres tervenors' Contention 2, regarding alleged falsifi-

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( cations - 'roject records.

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j Q. 5 are you familiar with the circumstances surround-f ing the falsification of certain concrete aggregate test 3i reports by a PTL Technician in January 1977, which was the

.7 I Il subject of NRC I&E Report Nos. 77-03 and 77-05?

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]l A. 5 (WSM, TKL): Yes.

Ll 2l Q. 6 Mr. McKay, please explain your role relative to PTL's handling of the matter.

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A. 6 (WSM): In January 1977, when the falsification 31 7I occurred, I was the senior member of the PTL QA Group in the 3i 3! Pittsburgh Home Office. It occurred in the PTL concrete 3i L! aggregate laboratory located at the STP site. Since August 3l 1976, I have been in charge of all PTL quality 3: :tivities on 4!

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,i STP, and in particular, at the time of the incident, I was the senior PTL management representative responsible for 3

assuring that the matter was immediately responded to, and 3.

fully and adequately investigated and resolved.

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2; Q. 7 Mr. McKay and Mr. Logan, please describe the 4l falsification and explain how it was identified.

5 g A. 7 (WSM, TKL): The falsification involved a PTL 7'

3 Level I Technician who was performing tests on sand, also 3

referred to as " fine aggregate," used in the production of 3

1 concrete at STP. l 1

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3, 41 5l The tests, which are performed on a daily basis during 6

7 concrete " batching" (the combining of components, including 8

cement, water, sand and stone aggregates, to produce concrete),

9) 10 ! are designed for the identification of possible excessive 11 k 12 l organic impurities which may be present in the fine aggregate 13 '

14 ' material, for proper particle distribution, and for excessive 15 ;

16 fine particle sizes. To perform the tests, the material is 17 i 16 i

washed through sieves, and the resulting sample must be oven toi dried to evaporate the water. ! The residue is then weighed 21 ! and the weight is recorded for each sample. This drying - 22 23 l takes about 24 hours. 24 i 25 ' On January 25, 1977, a PTL Level II Technician examining-26 i 27 j certain test worksheets in progress, which were being prepared 23 1 29 ' by the PTL Level I Technician involved, looked for actual 30 31 ; test samples referred to in the worksheets but was unable to 32 g find them. The PTL Level II Technician waited until January 27, 34 35 when the tests were to have been completed, and verified at 36 that time that test samples had never been prepared, despite 37 38 references in the worksheets indicating that tests had been 39 40 taken, producing acceptable results. 41 i 42 l Q. 8 Mr. McKay, what action was taken by PTL once the 43 '  : l l 44 l tests in question were concluded and the falsification was ) 45 l suspected? 46 i A. 8 (WSM): The PTL Level II Technician immediately 49 20 ; notified the PTL Site Manager and other PTL Supervisors of 51 } i I 1l 2F 3' 4 5I the incident on Thursday, January 27, 1977. The Level I 6 7 Technician was questioned by the PTL Site Manager the next  ; Ol day, Friday, January 28, and at that time the individual 9 10 admitted that the tests in question had not been performed. 11 12 The Technician also indicated that he had falsified records 13 , 14 i on a "few occasions" in the past, and said that the falsifi-15 , 16 , cations were the result of being "hard pressed for time." 17 i ig i The PTL Site Manager immediately called me at the PTL Home 9 }9 '0j Office in Pittsburgh and explained the situation. 2f f Q. 9 Mr. McKay and Mr. Logan, what did you do when you 23 first learned of the falsification? 24 25 , A. 9 (WSM): When the Site Manager called me Friday, 26 i 27 I January 28, and explained the falsification, I instructed 23 l 29 ! him to discharge the Level I Technician, which was done the 30 l 31 ; next working day, Monday, January 31. I further instructed 32 i 33 j the Site Manager to immediately re-sample and re-test the 33 36 j il stockpile from which the material in question was taken. Additionally, the PTL Site Manager was instructed to immedi-37 ! 38 ! ately notify the B&R Site QA Manager of the situation. 39 . 40 i (TKL): The B&R Site QA Manager notified HL&P QA of the 41 ' 42 l problem on January 31. HL&P QA notified the NRC on February 1,  ! 43 ' l 44 1977. I 45 46 ! Q. 10 Mr. McKay, after you gave these initial instruc-47 48 tions to your Site Manager, what were the next actions you

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                !          took?

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t 1 2 3 - 4l A. 10 (WSM): On Monday, January 31, I left the Home - 5 Office and went to the STP site to personally review and 8 9 discuss the incident with PTL Site Supervisors. I instructed 10 them to prepare a PTL Nonconformance Report in accordance with 11 12 PTL procedures, which was completed and filed on February 2, 13 ! 14 , 1977. I also reviewed the falsified test reports prepared 15 16 l by the Level I Technician together with PTL's reports on the 17 i gg ! re-sampled material. 19 l Q. 11 What were the results of the reports on the 20 I 21 re-sampled material? 22 i 23 ! A. 11 (WSM): No unacceptable or nonconforming test 24 ! 25 ' results were noted as a result of re-sampling the material 26 ! 27 l in question. 28 ! 29 l Q. 12 Mr. McKay and Mr. Logan, had the material in 30 i 31 ! question been previously tested prior to the tests which f were falsified by the PTL Technician? 33 A. 12 (WSM, TKL): Yes. Although not as a part of the 3a 36 ' Project QA program, the same material had already been 37 38 tested for compliance with the Project specifications regard-39 ! 40 ing gradation, fine particle size, and distribution on two 41 42 previous occasions: first, by the aggregate supplier, . 43 44 Thorstenberg Inc., prior to delivery to the site batch 40 l l 46 plant, and then again by the concrete supplier, Champion i 4 4 Inc., prior to use by the Concrete Batch plant. In both

 $9     I cases, the material in question was found to be in accordance
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51 , with the specifications. i i i l

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I i 1l l 2" 3f 4 5 Q. 13 Mr. Logan, did HL&P confirm that the material 6 7 was in accordance with specifications? OI A. 13 (TKL): Yes. HL&P QA reviewed all documentation 9l

  .0 l           generated by PTL and B&R concerning the incident, including
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  .2l            studies of test re. cults. Our review confirmed that all
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  .4            material was in accordance with the specifications.
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  .6l                 Q. 14   Mr. McKay, did you explain the falsification
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  ,g l           incident and the PTL management response to the incident to 9'I NRC Investigators?
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{- A. 14 (WSM): Yes. The NRC conducted an investigation 13! at the STP site beginning on February 2, 1977, which was 14 ; 15 ' later described in NRC I&E Report 77-03. The NRC interviewed 16 ! #

  !7l           me and members of PTL's Site Management as well as HL&P and 18 i 39 l           B&R employees who were familiar with the situation.      I fully 10!

31 l explained the facts surrounding the falsification and the 12 ! g3 responsive action taken by PTL Management. 14 la. 1 Q. 15 Please describe the qualifications of the Level 16 17l I Technician in question and his previous involvement with I8 ! PTL work in connection with the STP. 19 l 10 A. 15 (WSM): The individual in question joined PTL in ill! L2 ; 1976, and after the required training and successful comple-13 i [4 ' tion of written examinations, was certified by PTL as a 15 Level I Technician in September 1976. Previously, the 16j 17 ' gg individual had worked for 1 1/2 years in another testing I9 30 : i laboratory in Shreveport, Louisiana, where he performed

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I i 1{ 2: 3 4 ^ soils, concrete and asphalt testing. The individual per-5 6l formed concrete aggregate testing for STP between October 7 8 1976 and the time of the falsification incident in January 9 10 1977, after which he was discharged. 11 12 Q. 16 What corrective action did PTL take after the 13 14 issuance of its Nonconformance Report on February 2, 19 *. '7 ? 15 16 , A. 16 (WSM): First, a thorough review was made of 111 17 i yg i previous test reports from October 1976 through January 9 1977, which were issued by the Level I Technician who had 21 l been terminated. In addition, a statistical evaluation was 22 l 23 ! performed using Standard Deviation and Coefficient of Varia-24 ! 25 : tion, which compared the results of tests by the Level I 26 27 ' Technician with similar tests by other PTL personnel, the 23 i 29 l concrete supplier, Champion, Inc., and the aggregate supplier, 30 ! 31 : Thorestenberg Inc. These investigations were completed March 17, 1977, and determined that no detectable trends or 3'23. 34 ! deviations existed in tests performed by the Level I Techni-35 I 36 ' cian. 37 38 Q. 17 Mr. Logan and Mr. Mc.Kay, what preventative 39 l 40 i measures did PTL take as a result of this incident? 41 l A. 17 (WSM, TKL): The PTL Site Manager conducted an 42 l 43 44 indoctrination of all PTL personnel assigned to STP reempha-s45 sizing the need for accuracy, completeness, and factual 46 i 4 l reporting of test results. Additionally, PTL set up a 49 formal personnel rotation so that one individual was not , 90 l  ! 51 l l l

1 2!- 3l 4l 5, consistently responsible for the performance of any one 6 series of tests. Additional supervision and surveillance by 7 0 PTL Supervisors were also initiated. Later, PTL decided to 9 10 replace the formal personnel rotation system with a syrtem 11 12 under which more qualified Level II personnel are used to 13 l 14 perform the aggregate testing. This revised system was 15 16 implemented after review and concurrence by B&R, HL&P and 17 i yg j the NRC. Under this system, reviews and multi-tiered super-1c jf { vision are performed, with all Level I Technicians under , 21 l supervision by a certified Level II Technician, and reports 22 23 i are reviewed by the Level II Technician and the Assictant 24 ! 25 ! Manager / Document Supervisor. Additionally, there is a 26 : 27 i review conducted by a B&R Quality Surveillance Inspector 28 i 29 { prior to final review and transmittal to the B&R QA Vault. 30 31 Finally, personnel with a higher degree of edu7ation and 32 ! I background experience have been assigned to the aggregate 33 33 section. 32 36 ' Q. 18 What actions did HL&P take? 37 38 A. 18 (TKL): HL&P increased routine daily monitoring 39 40 of PTL laboratory activities, with special emphasis on tests 41 1 42 { requiring time-consuming operations, such as drying in 43 , 44 l ovens. Farther, HL&P QA monitored the PTL personnel training 45 l and personnel rotation as described above. 46  ; 47 i 4g l Q. 19 Did PTL revise its QA Program as a result of the 49 falsification incident? 50 51 _g_

I li 2L 3 4 A. 19 (WSM, TKL): PTL's QA Program functioned as it 5 6 was designed to function. The situation was promptly identi-7 8 fied, immediately reported to the client, fully analyzed, 9 10 and subjected to the proper corrective action. Consequently, il i 12 other then the general preventative measures discussed in 13  ! 14 the previous answer, no other QA programmatic changes were 15 16 ' c nsidered necessary.

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yg Q. 20 Is HL&P QA satisfied as to the adequacy of PTL's 9 QA Program? b'0i 21 ! A. 20 (TKL): HL&P QA is satisfied that this incident 22 i 23 ! verified the adequacy of PTL's QA Program, because: 24 i I 25 1. The incident was promptly identified and was 26 27 accurately reported; 20 29 2. All details and possible ramifications were fully 30 l investigated and reported; and 37 32 3. Resolution was accomplished in a timely and effic-33 34 ient manner. 3m 36 The NRC I&E Reports also found no items of noncompliance 37 38 with regard to the incident. 39 40 Q. 21 Had the falsification not been detected, would 41 42 the aggregate in question have been subjected to additional 43 44 testing prior to its placement in the plant? 45 i A. 21 (WSM, TKL): Yes. The fine aggregate undergoes 46 4 prequalification testing at a frequency of once for each 200 4 49 tons used. The stockpiled material must pass this same test i 20 l 51 l t 1 2 3 4' Prior to its use for batching. The falsified test was a 5 6l daily test run primarily to assure that handling or some 7I 8 other operation has not changed the properties of the material 9 LO to the extent that it no longer qualifies. L1 12 After placement, cylinder tests are run to determine 13 14 the actual strength of the concrete. If strength was affect 3 15 ! 16 i by use of this material, these tests would show that effect. 17 l If the strength was too low, Engineering would evaluate the gg ; 19 ' Problem and repair or replacement would follow. 20 i 21 ! Q. 22 Mr. Logan, are you familiar with the situation 22 ! 23 described in the NRC's I&E Report 78-07 involving the inspec-24 i 25 ! tion of bolted beam to column connections? 26 ! 27 ! A. 22 (TKL): Yes. I investigated that situation at 28 1  ! 29 i the time it occurred and discussed it with the NRC investi-30 : 31 ! gator. 32 33 Q. 23 Did this situation involve the falsification of 34 inspection records? 35 36 ' A. 23 (TKL): No. This situation is not at all similar 37 38 to the PTL employee situation discussed previously. The 39 40 l problem identified by the NRC resulted from unclear procedures 41 > , 42 l and differences in the way individual QC Inspectors marked l 43 i 44 their inspection records. These problems were resolved by a 45 46 revision of the procedures to assure that all Inspectors 47 i The NRC never marked their records in a uniform fashion. 48 l 49 l 50 l 51 j a

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4 a cused anyone of falsification and closed out the incident 5 6 in I&E Report 78-11 following our procedure revision. 8I Q. 24 Please explain what happened in that situation. 9i LOl A. 24 (TKL): A specific vertical column in the Reactor L1 ! Containment Building (RCB), Unit 1, had four beams that L2 { L3 i 14 ' bolted to it at elevation - 2 feet. Each place where a beam 13 , L6 , j ined the column (a joint) was to be inspected to assure L7 I tg l that the bolts were tightened to the proper degree. The QC Inspectors carried copies of the drawings and marked them f9 l 21 with colored pens whenever they had in:pected a joint. The 22 23 ) confusion arose from the issue of whether each beam-to-column 24 : 25 i joint was a separate entity to be inspected or whether the 26 l 27 ! entire connection (four beam-to-column joints) was the 28 i inspection item. Some QC Inspectors would wait until they 29 30 , l 31 j had inspected all four joints before coloring the location 32 ' n the drawing. Other QC Inspectors inspected and marked 33 l 34 each of the four joints as a separate item. These latter 33 36 Inspectors usually placed one colored dot in the center of a 37 38 circle on the blueprint, which represented the column, to 39 40 indicate inspection of beam-to-colum web joints and placed 41 42 other colored dots elsewhere in the circle to indicate 43 44 inspection of the beam-to-column flange joints. 49 46 In this part cular case the connection had been partially 47 inspected, i.e. some, but not all, of the joints at that 4g 49 i 50 l 51

l i L-1 3 1 5i location had been inspected, and the connection was physically 5i 7j marked to indicate a partial inspection. The QC Inspector 3 9 doing the inspection was one of those who treated each joint 3 as a separate item and, thus, he had placed a colored dot cn 2 his inspection record indicating the inspection of beam-to-3' 4' column web joints. 5' 6, The NRC took the position that since our procedures did 74 gl not differentiate clearly between a connection and a joint, o. fl no colored dot should be placed on the inspection record 1 !

;!               until the entire connection (all four joints) had been s ,

e J inspected. Since this entire connection had not been inspected, 4' 5j NRC viewed the inspection record as inaccurate. 6 7 We agreed that a single system needed to be used by all S! 9l Inspectors in order to prevent misunderstanding of the 0! 1; completeness of the inspection. The procedure were revised 2i d i to provide a single inspection system, the QC Inspectors

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o were given new instructions and the previously inspected j 6! connections were reinspected. 7 8 - 9 0l 11 2; T. Hudson:07:G 3i 4l -5 61 7! 8l 9l 10 l Il I i l l

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