ML20029E576
| ML20029E576 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Millstone File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 03/03/1994 |
| From: | Gavensky R NORTHEAST UTILITIES |
| To: | NRC |
| Shared Package | |
| ML20029E566 | List: |
| References | |
| 2.206, NUDOCS 9405190119 | |
| Download: ML20029E576 (10) | |
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MARCH 3.1994 CODE OF FEDERAL REGULATION 2.206 REQUEST FOR ACTION To:
The Director of the NRC From:
Ronald Gavensky Quality Control Specialist Northeast Utilities I am on a permanent / partial medical disability leave from Northeast Utilities.
My field of expertise is evaluating spare parts for use in Safety Related Systems.
I have over 30 years experience in this field 16 of which Js in the nuclear field.
I have a vast knowledge in the manufacturing phase of these parts I evaluate, therefore, I have been trained to recognize visually, manufacturing defects.
I have worked for Northeast Utilities at both Conn. nuclear plants, Conn. Yankee Atomic, and Millstone Nuclear Power ( Northeast Nuclear Energy Co,) for a total of 16 years.
i I was originally hired as a contractor at Conn. Yankee l
for an outage, but was later asked to stay on by the maintenance dept.
While working the outage, I had developed a reputation as being a very sharp visual observer and straight shooter.
I wrote a lot of Non Conformances for finding visual discrepancies, and I spent my casual time roaming around the Safety Related Systems, writing any conditions I found unacceptable. The maintenance supervisor recognized my talent, and asked my to stay on after the i
outage because he couldn't trust QC, He explained, he was getting a lot of defective parts in the plant from receiving inspection.
These parts were GREEN TAGGED, which meant they were inspected and accepted for use.
I was hired as a contractor to research the entire warehouse.
I was to look at all the parts, QA and NON-QA, and evaluate them visually for conformance to the purchase order.
I found parts still packed in the original container unopened, but GREEN TAGGED.
I found cracked parts, bent parts, mismachined parts, all GREEN TAGGFD.
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The QC receipt inspector, the only receipt inspector, informed me he was worried about my findings.
He explained, he had no experience in receipt inspection.
I asked then how could he sign for the acceptance of the parts.
He said he called the department wanting the parts and simply asked them "is this the parts you ordered," sign here.
They signed for the inspection.
I then told him I needed to borrow some calibrated tools, so that I can report dimensionally the Non Conforming conditions I found.
He informed me there were no tools period.
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2 I have sericus concerns, that Northeast Utilities has been operating their facilities, with people who are unskilled and inexperienced in the field of receipt inspection, therefore violating 10 CFR 50 Appendix B.
I believe this could lead to serious problems in the future.
1.
By this letter, I am requesting that the License of q,t o 6 '
Northeast Utilities, be temporarily revoked, until after p cF4 A
such time a investigation into my allegations be made by
[yf your department.
In addressing each concern with specific's and example, I wish to emphasis, the seriousness of my concerns.
The lack of NRC findings in the Procurement Quality Control area, leaves a lot of doubts, in one's mind.
Without experts like others and myself, blowing the whisle, this country would have a lot more problems than it could handle.
There isn't enough protection for us.
I know people who won't come forward, because they saw what happened to me and my family.
The utilities have millions to fight, I now have nothing.
j 1.
Northeast Utilities violated 10 CFR 50 Appendix B.
The violations are as follows:
1.A Section I Organization Secti.on I, state in part The quality assurance functions, are those of (a) assuring that an appropriate quality assurance is established and effectively executed.
a.1.
FACT:
Conn Yankee Atomic, did not have the skilled personnel, nor the necessary tools-or equipment to perform a adequate receipt inspection, until 1990.
a.2 FACT:
Millstone Nuclear Power, could not have had a properly executed receipt inspection department, until 1989, but even at that time, unskilled inspectors, were performing skill required tasks.
Section I goes on to state in part:
(b) verifying, such as checking, auditing, and inspection, that activities affecting the safety related functions have been correctly performed."
a.3 FACT:
Category One parts or Safety Related parts, could not have been verified as to the purchase order requirements at receipt inspection, until early 1990's, when the tools were made available, such as material analyser, e
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i and various measuring devices.
In addition the lack of a skilled, mechanical lead person in the field of receipt inspection, prevented the objective of verifying the parts were inspected correctly.
Section I continues in part: " The persons and organization performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions."
a.4 FACT: In my grievance to management about my work performance evaluation, I mentioned a number of times to my supervisor, that I observed unethical and incorrect methods of receipt inspections, and as the only perso,n in the department with 30 years experience in the mechanical quality control field, I requested that since I was the most experienced in the department, I requested I be assigned to oversee the others doing mechanical receipt inspections.
My supervisor refused, he said it would cause animosity between the troops."
I grieved that decision all the way up to the Director of Quality Mr. Donald Nordquist.
On February 11, 1991, I received a Memo (copy attached) from Mr. Nordquist, addressing my concerns, as to how my fellow workers were performing receipt inspections.
Specifically in the memo, Mr. Nordquist said It is not your role to oversee the work of others in your group.
This has been pointed out to you several times."
I have tried on several different occasions to identify quality problems within our own department, along with recommendations and solutions, but I wasn't allowed to, by either my supervisor, or the Director of Quality.
This is a direct violation of Section I of 10 CFR 50 Appendix B.
2.B Section II Quality Assurance Pr6 pram.
Section II states in part The program shall take into account the need for special controls processes, test equipment, tools, and skills to attain the required quality, and the need j
for verification of quality by inspection and test j
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2.b FACT:
Most tools a r.d test equipment were not available full time in the receipt inspection department, until the end of 1989-begging 1990, prior to that time, very few critical dimensions could be verified in the receipt inspection department.
Commercial grade material, seldom had any receipt inspection attributes identified.
2.c FACT:
As to the skills to obtain the required quality as relating strictly to procurement receipt inspection, the word skill must be defined.
The Random House Dictionary of The English Language, defines the word skill 3 ways.
H 1.
The ability, coming from one's knowledge, practice, aptitude, to do something well.
2.
Competent excellance in performance:
expertness, or special training.
3.
A craft, trade, or job requiring manual dexterity, or special training in which a person has competence and experience.
Webster's Ninth New Collegiate Dictionary, defines skill as:
1.
The ability to use one's knowledge effectively and readily in execution or performance.
2.
A learned power of doing something competently.
3.
A developed aptitude or ability
SUMMARY
Both sources are almost identical in meaning.
To have a skill, one must be knowledgeable in a particular field, and one must have special training in that field.
In addition, one must have enough experience in that field to be an expert.
In addition, the word skilled, is defined as:
of relating to, or requiring workers, or labor with skill and training in a particular occupation, craft, or trade.
It is my interpretation of the skill requirement mentioned above, the intent, as to its relationship to receiving inspection, is that quality control receipt inspectors must be skilled in receipt inspection prior to becoming receipt inspectors at Northeast Utilities, or be skilled in a related field, such as machining, mechanical shop inspection, or testing facilities.
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5 To further clarify my interpretation, the American National Standard N18.7-1976, of which Millstone Power is committed to in their Topical Report, states in part, under Para. 3.4.2 Requirements for the Onsite Operating organization.
The onsite operating organization shall include one or more individuals knowledgeable in the following fields----quality assurance.
Initial incumbents or replacements for members of the onsite operating organization and offsite technical support organizations shall have appropriate experience, training and retraining to assure the necessary competence is maintained in accordance with the provisions of American National Standard for Selection and Training of Nuclear Power Plant Personnel, N 18.1-1971.
It continues to say, if the person can't meet the qualification requirement of N 18.1, they must be qualified to N 45.2.6-1973, " except that the QA experience cited for Levels I,
II, and III should be interpreted to mean actual experience in carrying out the types of inspection, examination, or testing activity being performed."
FACT: At Conn. Yankee Atomic, the inspector performing receipt inspections, prior to 1980, had no experience or knowledge in the field of receipt inspection.
FACT:
At Millstone Nuclear Power, prior to 1983, none of the receipt inspectors or their Leads, were skilled in the field of receipt inspection, nor were they knowledgeable in the field.
At present there are only two skilled mechanical receipt inspectors.
FACT:
All the receipt inspectors are Level II to N45.2.6-1972, however most lack the actual experience in mechanical receipt inspection to be a receipt inspector as required by the standard Northeast Utilities is committed to.
3.C Section II continues to say " The program shall provide for indoctrination and training of pernonnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
1.c FACT: The only indoctrination and formal train-ing in receipt inspection was given by the training department, between 1991-1992, prior
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to that, indoctrination consisted of mostly read and sign.
Northeast Utilities had no training program for receipt inspecters.
Most of the receipt inspectors lacked the Knowledge of how to use measuring test equipment. They also didn't know how to perform a visual for damage inspection, which was a standard requirement in receipt inspection procedures, however the term has yet to be defined by N.U.
management.
although visual inspection is important, no training has ever been provided FACT: It is ironic, THE PERSON WilO TAUGilT AND TRAINED TIIE RECEIPT INSPECTION COURSE, WAS TAUGIIT HY TIIE RECEIPT INSPECTORS IIE TRAINED!
I am accusing the present Procurement Inspection Services supervisor and his manager of WIIITE WASIIING. "
They have performed perfunctor investigations.
Instead of admitting there was a problem, and fixing it, they hired outside people, to perform investigation. They j
spent thousands of manhours so that reports can be issued with positive results.
Then they
-l tell upper management nothing is wrong.
FACT:
The manager of procurement services, hired a two man team, to investigate my concerns, the team interviewed me to find out the particulars in more detail.
The team seemed to understand my concerns, and were sympathetic toward my concerns.
After the investigation by the team, the results were reported to the department as all is well.
After reading the report, I found that they after two weeks of investigating, did not look where I told them to.
They went around every-thing I said.
I called the NRC and reported my findings.
They investigated my complaint and reported that I was correct in my theory.
The teams report was not accurate.
The NRC reported to N.U.
management that the team who performed the investigation about my concerns, did not perform well. That their report, which my manager was happy with, was cursory in nature.
The NRC still holds this as a OPEN ITEM in their investigation.
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FACT:
The same manager again hired a outside source, to-investigate my concerns _about unit III construction.
I accused Stone and Webster of having a poor receipt inspection department, when they were constructing unit III.
He hired the same team that did the inspections at receipt inspection from Stone &
Webster.
Where's the independence?
There is none.
My thoughts were, why should Stone &
Webster, shoot themselves in the foot?
Again hundreds of manhours were spent looking at old inspection reports, with the results tallied.
The results! ALLS WELL!
When I accused S&W of having a poor program
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in receipt inspection, I was referring to their unskilled people.
Anyone, can sign a piece of paper, attesting that it meets all requirements whoes to know once the part is installed or is put in stock.
My point is, I found many. bad parts accepted for use by S&W.
Many installed.
My manager again told the Director of Quality that the investigation showed very few problems that the paperwork was closely scrutinized, and that what I found was an isolated case.
The truth of the matter is I worried about the parts not the paperwork. Ageln were the people skilled receip inspectors?
That was never answered.
As for an isolated case !!!
I have written non conformances on S&W parts many times before.
Thank You Ronald Gavensky O>u.l faw-a 113c Wood Duck Circle Daytona' Beach FL 32119
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CONF I DENTI AL 0
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... s.mu.. iw February 11, 1991 TO:
R.
Gavensky
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6.
O.
Nordquist (Extension 5447)
SUBJECT:
GRIEVANCE MEETING NOTES The Step 2 meeting on your grievance was held in Berlin on Thursday,. February 7, 1991.
Attendees were yourself, D.
O.
Nordquist, D.
D.
- McCory, J.
N.
Coleman and M.
E.
Brown. - Grievance dated January 7, 1991 - Material presented by you at the Step 2 meeting, three pages dated December 1, 1990 The meeting started with your presentation of Attachment 2.
I then proposed that we seek areas of mutual agreement to which you agreed.
I started that process out by relating your Items 1 and 2 on Page 3 of Attachment 2 to the Performance Management Program (PMP) " General Competencies" which had been evaluated as "NI".
Your Item 1 noted an acknowledgment that you needed improvement in Planning and Organicing.
This relates directly to the PMP evaluation of "NI" in that Competency.
You also stated that feedback from the Myers-Briggs evaluation indicates a weakness in this area.
My feeling on this Competency is that three (3) data points, the PMP evalur. tion, your statement in Item 1 on Page 3 of Attachment 2 and the Myers-Briggs evaluation agree that this is an area that needs improvement.
I cannot support your position that a tendency for weakness in this area as noted through Myers-Briggs results justifies performance which does not meet expectations.
e Page 2 February 11, 1991 R.
Gavensky Your Item 2 on Page 3 acknowledges problems with " completeness".
This relates directly with "NI" PMP evaluations for Quality of Work and Written Communications.
The completion of documentation which supports the performance of quality activities such as Surveillance Reports and Receipt Inspections is a clear
, expectation of your job requirements.
We discussed several examples, at length, in which you noted a disagreement with your Supervisor's expectations, however, I believe you agree in principle that improvement -is needed in this area.
We discussed the Competency of Interpersonal Relations and its interrelationship with Teamwork.
They certainly can go hand-in-hand, however, they are distinct from the viewpoint that interpersonal relations deals specifically with your impact on others.
We discussed several examples of situations, both specific and generic, where it is not acceptable to allow a difference of i
opinion or disagreement to become emotional or non-professional.
1 key expectation of performance which must be This i sa understood.
Given a situation with potential conflict, whether you are technically or administrative 1y correct or not, if you react or cause other parties to act in a non-professional manner, you are not meeting expectations.
Additionally, your relationship with your peers and coworkers and your Supervisor's_expectatisna_mu be understood j.'t'is not your role to oversee the work of others r 'cifi50p.
This has been pointed out to you several times.
I have followed up as you requested with J.
Riley and a representative from G.
Closius' group relative to the concerns with your interaction on the Reactor vessel Studs on Millstone Unit 2.
The results of my discussion with John Riley and Gary Closius' representative indicate that you told John that you did not trust their (MP2 Maintenance) Engineering's ability to disposition the
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NCR on the Reactor Vessel Head Studs and that we (QSD) insist that NNECO Engineering be included.
John didn't agree with your position and was very taken back.
I also discussed the issue with Duncan McCory who agrees that he told you that this was a complex technical issue that would benefit from discipline input from NNECO or NUSCO Engineering.
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Page 3 February 11, 1991 R.
Gavensky This was not meant to instruct you to tell John that his staff was not competent to handle the NCR.
As a matter of fact, John had involved both NNECO and NUSCO Engineering.
Gary's representative felt that the issue was not handled in a professional manner.
Again, as discussed during the meeting, given a situation where differing technical views exist, your tendency is to handle the discussion in a non-professional manner.
John did agree that you are a good inspector and feels that your input is typically correct from a technical standpoint.
I would hope that the discussions during our meeting will help you understand that there are areas in your performance that do not measure up to expectation.
In summary, I must deny your grievance based on my conclusions that "NI" is the appropriate rating for your performance during this past year.
DON /dar