ML20090K049
| ML20090K049 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/13/1983 |
| From: | Zwissler L MANAGEMENT ANALYSIS CO. |
| To: | |
| References | |
| A-013, A-13, NUDOCS 8405230598 | |
| Download: ML20090K049 (51) | |
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSIOb 2l g
V Ci f",E 2 ) 03 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g
55.Nc '"
In the Matter of
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pp DUKE POWER COMPANY, et al. )
Docket Nos.
50-41
--)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
TESTIMONY OF LEWIS E. ZWISSLER 1
Q.
STATE YOUR NAME AND YOUR BUSINESS ADDRESS.
2 A.
My name is Lewis E.
Zwissler, and my business address is 3
Management Analysis Company, 11095 Torreyana Road, San Diego, I
4 California 92121.
5 Q.
DESCRIBE THE NATURE OF YOUR EMPLOYMENT.
6 A.
I am a Vice President of Management Analysis Company (MAC), and 7
I serve as a consultant in the areas of quality assurance, project 8
management, and research and development.
9 Q.
WOULD YOU DESCRIBE YOUR PROFESSIONAL EXPERIENCE AND 10 QUALIFICATIONS.
.l j
11 A.
I have set forth in detail my professional qualifications and 12 experience in a resume which is Attachment 1 to my testimony.
I i
13 have had over 40 years of experience in quality assurance, project 14 management, and research and development, including 20 years of 15 active management in quality assurance in the nuclear and aerospace
]
16 industries.
I have spent 8 1/2 years as Director of Quality i
17 Assurance for Argonne National Laboratory and served as QA 18 Manager on the Polaris, Titian III, Gemini and Apollo programs for 19 Aerojet General Corporation.
I have a Bachelor of Science degree 20 in Civil Engineering from Illinois Institute of Technology, a Master 21 of. Science degree in Applied Mechanics from Rutgers University, 8405230598 831013 PDR ADOCK 05000413 9
i 1
and I have completed - the academic requirements for a PhD in 2
Applied Mechanics.
I am a Registered Professional Engineer, a 3
Fellow in the American Society for Quality Control, and a Senior 4
Member of the American Nuclear Society.
i 5
Q.
WOULD YOU DESCRIBE YOUR EXPERIENCE IN MANAGEMENT
{
6 EVALUATIONS OF NUCLEAR POWER PLANT CONSTRUCTION 7
PROJECTS.
,y t
8 A.
I have been involved in consultation projects at seven nuclear 9
power plant construction projects.
At the South Texas Project, I 10 served as consultant to the architect-engineers, construction 11 company, and utility in developing a quality assurance corrective
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12 action program in response to an NRC Show Cause Order.
I have 4
i 13 also worked at the South Texas Project as Site Construction QA 14 Manager and later as Senior QA Consultant to the utility on the O
15 project.
I have worked as a consultant to a number of utilities on j
16 various aspects of quality assurance for operating reactors, and 17 construction projects.
18 I have participated as a member of a management diagnostic 19 team in the area of quality assurance and project management at f
20 Susquehanna and Wolf Creek.
I have served as a member of the 21 INPO Self Evaluation' Team at Marble Hill and as team leader for the 22 evaluation of the Midland construction project.
23 At Consumers Power Company, I reviewed the Operations QA 24 audit activity for the ' Big Rock, Palisades and Midland reactors and i
25 made recommendations concerning the implementation of their audit 26 program.
I have also served as Senior Consultant to the Midland 27 Project QA management,, participated in the Midland independent
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1 Biennial QA Management Audit, and worked as a consultant to the 2
site construction management to develop the construction completion 3
plan.
Finally, at the Callaway project, I was involved in a 4
management diagnostic project pertaining to evaluation of their 5
documentation program.
6 Q.
DESCRIBE THE CIRCUMSTANCES OF YOUR INITIAL EMPLOYMENT 7
BY DUKE, INCLUDING WHO CONTACTED YOU AND WHAT WAS 8
INITIALLY REQUESTED OF YOU.
9 A.
The Management Analysis Company office was contacted on January 10 21, 1982, by Mr.
J.
R.
Wells, who at that time was Corporate 11 Quality Assurance Manager for Duke.
I was assigned to work with 12 Duke on this matter.
13 I was advised that Duke management had become aware of a 14 number of concerns expressed by the welding inspectors at the 0
15 Catawba plant reg'arding the quality of the work.
I was advised 16 that Duke had undertaken an internal investigation of the concerns, 17 and as a result of this initial internal investigation, a Task Force 18 was established to investigate the concerns to assure that all i
19 quality requirements had been met and/or to recommend actions to i
20 resolve any open items.
21 It was my initial understanding that MAC was retained to 22 review the activities of the Task Force, and to provide an 23 independent, outside overview to assure that all reasonable actions 24 5.we being taken to assure the safe.y of the Catawba plant.
25 Q.
WHAT DID DUKE REQUEST YOU TO DO WITH RESPECT TO THE 26 WELDING INSPECTOR CONCERNS AND THE WORK OF THE 27 TECHNICAL TASK FORCE.
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A.
Duke appointed a Task Force to perform the initial investigation in 2
December 1981.
This Task Force is now referred to as Task Force i
3 I.
This Task Force concluded that the quality assurance and 4
quality control programs at Catawba were working and that there i
5 was no evidence to confirm that unacceptable craftsmanship or 6
unsafe conditions existed at the plant.
This initial Task Force did 7
report a lack of communication between the inspectors, the 8
supervisors, and quality assurance management.
9 After this initial Task Force made its report, Duke appointed 10 another Task Force, which is now referred as the Technical Task 11 Force, to investigate all of the concerns expressed by welding 12 inspectors to evaluate how they were previously addressed, i
13 including a reevaluation of the technical resolutions of all Non 14 Conforming Items Reports (NCI's) associated with the concerns, and l
15 to make recommendations of further corrective action that might be l
l 16 added.
l 17 Duke retained MAC to specifically review the approach and 18 methods used by the Technical Task Force to assure that it i
j-19 obtained a complete list of all of the concerns; to review the i
]
20 approach and methods used by the Technical Task Force to review 1
i 21 and determine resolution of the concerns; to review the 4
i 22 qualifications of those individuals involved in the review of these 23 resolutions to be sure these individuals were qualified to make these l-24 kinds of determinations; to audit the resolutions to ensure l
25 completeness and quality of work; to prepare a written report 26 covering the entire process and report independently to Duke's F
27 Management; and to be prepared, if necessary, to testify in the,
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licensing proceedings, or in any other forum, concerning my 2
opinion of the work performed by the Technical Task Force and i
3 those involved in resolution of the welding inspector concerns.
4 I performed the services requested by Duke and submitted my 5
report dated April 26, 1982, which is included in my testimony as 6.
7 Q.
WIIAT DID YOU DO AFTER YOU WERE RETAINED BY DUKE.
8 A.
I felt I needed to get familiar with the people involved at Duke, 1
9 and to fully understand the concerns that had been expressed.
10 Initially I met with Duke Management to discuss the status of the 11 matter, and the past actions taken to investigate the allegations. I
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12 met initially with Mr. Owen and Mr. Wells to discuss these matters.
13 Mr. Owen and Mr. Wells provided me with some background 14 information, which included the notes that had been prepared by I
15 Mr. Owen concerning the investigation of the concerns, the Gail 16 Addis memo to Mr. Owen which outlined the concerns, and the i
^
17 report issued by Task Force I.
I reviewed these documents to gain i
18 a thorough understanding of what had transpired prior to my 19 becoming involved in the matter.
20 I also met with other Duke personnel, including Mr. Wayne j
21 Henry and Mr. Larry Davison, as well as the members of the i
22 Technical Task Force. These initial meetings were primarily to meet i
1
]
23 with the personnel involved and to get acquainted with the
)
l 24 organizational structure and personnel at Duke.
I also reviewed 1
25 the statement of concerns expressed by each welding inspector as a 26 part of this effort to get familiar with what had transpired.
i 1
Q.
WHAT DID YOU DO AFTER YOU WERE FAMILIAR WITH THE i
2 BACKGROUND INFORMATION.
3 A.
After becoming familiar with the background information, I
i 4
interviewed the-Task Force members and reviewed their l
5 qualifications and experience to determine if they were qualified to 6-participate as Task Force members.
The overall objective of this 7
Technical Task Force was to assure that all concerns and allegations 8
voiced by welding inspectors regarding quality of work were 9
collected and reviewed to assure that the technical resolutions 1
10 questioned.by the inspectors were indeed valid, and that there was i
11 no adverse impact on the safety of the Catawba plant.
It was very 12 important that the Task Force members be qualified to do the job 13 requested of them.
14 Q.
DID YOU REACH ANY CONCLUSIONS CONCERNING THE f
15 EXPERIENCE AND QUALIFICATIONS OF THE' TASK FORCE J
16 MEMBERS. TO PERFORM THE WORK REQUIRED BY THE TASK i
17 FORCE.
1
- 18 A.
Yes.
I determined with respect to each Task Force member that he i
19 was qualified to carry out the work of the Technical Task Force by j
20 virtue of his education and experience.
Along this same line, I f
21 interviewed 12 quality assurance personnel and 14 management and
)
22 construction personnel in an effort to determine the degree of 1
j 23 Duke's sincerity in conducting the Task Force review.
Based on i
24 thess interviews, I concluded that the Task Force effort was being 25 taken seriously by all Duke personnel who were involved, and that 26 there was a clear commitment' to ' quality that went beyond the 27 requirements to assure a safe plant. The only factor identified that-l I 1 i.
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might influence the acceptability or cast doubt on the objectivity of l
2 the results of the Technical Task Force investigation was the prior 3
involvement of Task Force members in the resolution of some of the 4
stated concerns.
This was remedied by appointing a new Chairman i
5 of the Technical Task Force and initiating a completely independent 6
review of each resolution to confirm or deny the initial finding by 7
the Task Force.
8 Q.
MR. ZWISSLER, WE HAVE TALKED ABOUT YOUR EFFORTS TO j
9-BECOME FAMILIAR WITH-THE BACKGROUND, AND YOUR EFFORTS 10 TO ASSESS THE-QUALIFICATIONS OF THE TASK FORCE MEMBERS 11 AND THE SINCERITY OF THE TASK FORCE EFFORT, WHAT WAS 4
12 THE NEXT PHASE OF YOUR EVALUATION.
13 A.
The Technical Task Force had established a plan for evaluating the i
14 welding inspector concerns, which has been described, by Mr.
I 15 Cobb, Chairman of the Technical Task Force.
My purpose was to 1
j 16 make an independent evaluation of the quality of the work of the t
17 Task Force.
In order to evaluate their work, I reviewed the l
l 18 written concerns expressed by the welding inspectors; reviewed the I
19 Technical Evaluation-Individual Concerns form prepared for each I
I 20 concern; evaluated the technical adequacy statement and reasons; l
21 and performed a
detailed technical evaluation of the l
l 22 recommendations.
This review included reference to various quality i
l 23 -
assurance and construction procedures and the QA manual cited in i
24 the concern or the evaluation to ensure that the Task Force 25 proceeded based on valid interpretations of these procedures.
)
26 During this phase of my work, I worked directly with' the 27 Task Force members, reviewed each set of completed documentation
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and commented on the quality of their evaluation, particularly in 2
the areas of technical adequacy and reasons, and in the area of 3
recommendations.
In situations where additional work was required 4
or where I felt that the recommendations failed to completely 5
address the actions needed to resolve the concerns, I made 6
comments directly to the Task Force members.
This kind of 7
interface with the Task Force members permitted me to evaluate 8
their attitude, persistence, and desire to determine the actual or 9
potential impact of the welding inspector concerns on the safety of 10 the plant.
11 Q.
WHAT CONCLUSIONS DID YOU REACH DURING THIS TECHNICAL 12 EVALUATION PHASE OF YOUR WORK.
13 A.
I concluded that the Technical Task Force was dedicated to 14 evaluating each concern to assure that each of these concerns
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15 voiced by the inspectors was reviewed, and that the technical 16 resolutions were valid, and that there was no adverse impact on the l
17 safety of the Catawba plant.
It is my opinion that the Task Force 18 members performed their technical evaluations in a professional and i
19 technically competent manner to satisfy all NRC and Duke QA i
20 program requirements. I believe that the technical evaluation phase 21 was conducted in an objective and unbiased manner. There was an 22 independent review of prior resolutions of NCIs associated with the 23 concerns, which was followed by a second independent review to 24 assure the objectivity of the final Task Force determinations.
25 Q.
EXPLAIN WHAT YOU MEAN WHEN YOU SAY THAT THERE WAS A 26 SECOND INDEPENDENT REVIEW TO ASSURE THE OBJECTIVITY OF 27 THE FINAL TASK FORCE DETERMINATIONS.
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4 1
A.
Each individual concern was assigned to Task Force members who 2
were not involved in the prior resolution of the NCI associated with 3
the concern, for review to assure that the previous technical 4
resolution was acceptable, or prescribe actions to be taken to 5
achieve an acceptable resolution.
The documented result of this l
1 i
6 review was then assigned for a second, independent review by j
7 another Task Force member who was not involved in the earlier i
}
8 resolution, or in some cases, review by other persons who provided 9
technical support to the Task Force.
The second independent j
10 review was to assure the Task Force determinations were objective l
11 and accurate.
i 12 Q.
THE TECHNICAL TASK FORCE ISSUED A FINAL REPORT WHICH I
13 HAS BEEN DESCRIBED BY MR. COBB.
DID YOU PERFORM ANY j
14 EVALUATION RELATING TO THIS FINAL REPORT.
O 15 A.
Yes.
I reviewed the specific and programmatic recommendations 16 included in the Task Force report to assure that the summaries 17 were valid.
I concluded that the Task Force results were an
)
18 accurate portrayal of their evaluations; that the Task Force 19 recommendations were derived from their analysis of these results l
20 and that the recommendations adequately addressed the specific and i
i 21 programmatic actions to resolve the concerns expressed by the l
j 22 welding inspectors; and that the general recommendations should 23 improve the day-to-day work environment for the welding l
24 inspectors.
25 Q.. WHAT WAS THE NEXT PHASE OF YOUR ' REVIEW OF THE
)
l 26 TECHNICAL TASK FORCE EFFORTS.
27 A.
The next phase of my work was an evaluation of the Duke l
28
. management's ~ review of the Task Force report, results and
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recommendations.
The Task Force met with members of Duke 2
management to review the report.
Duke management reviewed the 3
Task Force activities, results and recommendations, and immediately 4
undertook a program to complete the corrective actions identified by 5
the Task Force.
A management implementation plan was prepared 6
and a coordinator was appointed to be responsible for the corrective 7
action plan and activities and for follow-up to assure ecmpletion of 8
the corrective action plans.
This Management Implementation Plan i
i 9
was reviewed and approved by the department heads in Quality 10 Assurance, Construction and Design Engineering.
11 Q.
DID YOU REACH ANY CONCLUSIONS CONCERNING THE 1
12 ADEQUACY OF THE MANAGEMENT IMPLEMENTATION PLAN.
13 A.
Yes.
Based on my discussions with Duke management officials, and 14 my ongoing evaluation of the Task Force efforts, I concluded that 15 the Management Implementation Plan was adequate to resolve the j
16 concerns expressed by the welding inspectors; that successful 17 completion of the Management Implementation Plan would 18 satisfactorily resolve the technical concerns related to plant safety; i
19 and, that successful completion of the Plan's provisions addressing 20 general and programmatic recommendations should improve the 21 day-to-day work environment for welding inspectors at Catawba.
22 Q.
WHEN DID YOU ARRIVE AT THESE CONCLUSIONS CONCERNING i
23 THE ADEQUACY OF THE MANAGEMENT IMPLEMENTATION PLAN.
24 A.
During April of 1982.
4 25 Q.
HAVE YOU PERFORMED ANY OTHER EVALUATIONS TO DETERMINE 26 WHETHER THE MANAGEMENT IMPLEMENTATION PLAN WAS 27 SUCCESSFULLY IMPLEMENTED.
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A.
Yes.
During August of 1982, I performed an audit of the 2
documentation supporting the completed corrective actions 3
implementing the Management Implementation Plan.
The purpose of 4
the review was to determine if there was any generic type problems 5
in the implementation of the Plan, correction of which could lead to 6
a more complete set of corrective actions.
My review was not j
7 considered a complete and exhaustive analysis of the total 8
implementation results.
Recommendations to improve the 9
documentation supporting completion of corrective actions were 10 made, such as:
Duke should clearly document the action taken, or l
11 if none, provide valid reasons; document the content of all training 12 given; evaluate effectiveness of actions taken; review new 13 procedures and changes to assure adequacy; and review the 14 specific technical resolutions to assure that every item is J
15 addressed.
Within the context of my review of the Task Force j
16 effort and the documented resolutions of the concerns expressed by 17 the welding inspectors, every concern that was expressed was 4
18 adequately resolved from a technical standpoint, and in my opinion, 4
j 19 no residual quality related problems remain in the construction of l
j 20 the plant.
21 I submitted a letter report of findings and recommendations 22 resulting from this review to Duke Power Company on August 24, 23 1982.
That report is attached to my testimony as Attachment 3.
24 Q.
MR.
- ZWISSLER, THE CONCERNS EXPRESSED BY WELDING I
25 INSPECTORS WERE INITIALLY CHARACTERIZED AS CONCERNS 26 AFFECTING THE QUALITY OF THE WORK OR THE SAFETY OF THE 27 CATAWBA PLANT.
DID THE CONCERNS EXPRESSED AFFECT THE O\\
28 QUALITY OR SAFETY OF THE CATAWBA PLANT.
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1 A.
Based on my review of the concerns expressed by the welding 2
inspectors, my interviews with Duke personnel, and my evaluation 3
of the thorough and objective work of the Technical Task Force, I 4
would not agree with the characterization that the welding 5
inspectors expressed concerns which indicated that there are 6
safety-related or quality problems at Catawba.
However, I do 7
agree with the assessment of Task Force I that there was a serious 8
problem involving lack of communication between the inspectors, 9
their supervisors, and QA management. I believe that this problem 10 could have potentially reduced the effectiveness of the QA program 11 had steps not been taken to address the concerns.
12 Q.
HOW WOULD YOU DESCRIBE THE PRIMARY CONCERN OF THE 13 WELDING INSPECTORS.
l h 14 A.
The primary concern of the inspectors was that they did not have a
15 the support of their supervision and management.
The concerns 16 expressed were related to failure to follow procedures; minor 17 violations of procedures which were excused or accepted and not 18 documented as NCI's; and that resolution of NCI's did not address 19 failure to follow procedures, but did address technical acceptance of 20 work actually done.
The real concern was that inspectors were 21 required to identify failure to follow procedures and when they did i
22 this, a technical evaluation by their supervisors accepted the work, i
23 but nothing was done to correct the generic problem of violations of 24 procedures.
The technical evaluations indicated there were no l
25 residual quality problems, however, aggressive action was not being 26 taken to " call the craft to task" for minor variations from 27 procedures.
This led to the allegations by the inspectors that 28 management was not supporting them.
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In addition, the inspectors did not understand their role in 2
the resolution of nonconforming items.
They questioned the 3
acceptance of work where they did not understand or agree with 4
the resolution of the NCI, particularly where there were departures 5
from construction and quality assurance procedures.
6 Q.
DID THESE DEPARTURES FROM PROCEDURE EVIDENCE A FAILURE 7
TO FOLLOW QA AND QC PROCEDURES AND THEREFORE 8
INDICATED A BREAKDOWN IN THE QA PROGRAM AT CATAWBA.
9 A.
I agree with the findings of both task forces that the QA program i
10 at Catawba was
- working, and that there are no residual 11 safety-related problems identified by the welding inspector i
12 concerns.
The expression of the concerns by welding inspectors 13 demonstreted that the quality assurance program was wcrking. The 14 welding inspectors identified construction deficiencies or procedure 15 variations which were corrected or a valid technical resolution of 16 the nonconformance was made.
The problem identified by the 17 concerns of the inspectors was in the manner of resolution of 18 nonconformances.
The rationale or justift:ation for resolution of 19 NCI's was not communicated to the inspectors.
The inspectors felt 20 very strongly that their job wa6 to require strict adherence to 21 procedures, and that their management failed to take aggressive i
22 action against the identified craft violators. The point at issue was 23 not failure of the QA system to identify departures from 24 procedures.
This was done properly by the inspectors.
The 25 concerns revealed that the inspectors perceived that aggressive 26 action was not being taken to reduce the number of occurrences.
O O __
i 1
In my view, the welding inspectors perceived that they did not 2
receive the proper support from QA management because in their 3
view, QA was not insisting on compliance with procedures and these 4
noncompliance were not addressed in the corrective actions called 5
for in the resolutions of NCI's.
6 7
8 9
I hereby certify that I have read and understand this document, and 10 believe it to be my true, accurate and complete estimony.
11
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15 16 17 Sworn to and subscribed before me 18 this.11AL day of September,1993.
OFFICIAL SEAL 19
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LEWIS E. ZWISSLER i
PROFES$10NAL QUALIFICATIONS 4
Mr. Zwissier has had over 40 years experience in quality soeurence, project management, l
j and resserch and development. He has over 20 years active management of quality
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assurance in the energy and aerospace fields, including 81/2 years as Direator of Quality j
Assurance for Argonne National Laboratory and se GA Manager on the Poterie, Titan !!!,
i Gemini and Apollo Programe for Aerojet General Corporations. He held responsible management positions in testing, manufacturing, project management, and engineering i
i resserch and development. He has acted as a consultant during his industrial experience and with MAC.
l i
EXPERIENCE l
4
}
1980 - Present MANAGEMENT ANALYSIS COMPANY j
Vice President - Participated in management evaluations of mejor j
nucteer power plant construction projects. Served as consultant to i
j A/E, constructor and utility in developing QA corrective action i
propame to lift NRC show cause order on nuclear plant construc-l 1
tion project. Served as site construction QA manager and later as j
j eenior QA consultant to utility on project. Acted as consultant to j
utilities on various espects of GA for operating reactors. Served -
j l
both as team leader and team member for INPO self evaluations of i
j construction projects. Performed consulting services for utility in j
GA and construction site management.
1971 - 1980 ARGONPE NATIONAL LA8 ORATORY l
Quality Assurance Olvision Director - Director of quality eseurance j
^
octivities for Laboratory, including operation of Liquid Metal Cooled Fast Breeder Reactor et ideho Nuclear Engineering Laboratory. Developed and implemented QA proyem satisfying requirements of NRC and DOE quality programs covering design, procurement, construction, major modifications, operating l
3 reactors, resserch and development, testing and manufacturing, for j
i laborotory engaged in resserch end development of nuclear power l
l generation technology and basic resserch.
i 1966 1971 AEROZT OEFERAL CORPORATION, ELECTRO SYSTEMS la DIVISION Meneste. MK-44 Torpedo Operations - Directly responelble for all i
activit es required to operate highly technical program as separate, eutonomous burden conter within the Electronics Division. Sales volume on program was approximately $100 million per year.
j Number of people involved ranged from 500 to 2,MO.
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i Romume J L'ewie' E. Zwiseler Page Two j
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i Manecer of Manufacturina - Operatione included fabrication of l
machine componente, seeembly and testing of sophisticated electronic equipment, and ensembly of electro-optical mechanical devices. Mejor products were infrared sensing devices, underweter
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^ ti-submarine werfere devices, and othere. Supervised 400-800
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people.
ip 1958 - 1966 AEROXT GEERAL CORPORATION, SACRAMENTO PL ANT
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Meneoor. Quality Control - Overall functional responsibility for
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quality control in the secremento Plant. Directly responsible for i
l 1
j quality control activittee eenociated with manufacturing, testing l
and field support to all Liquid Rocket Motor Programs. Quality l
Control activity totaled approximet,ely 800 people.
j Menaaer. Relidlity and QC.Olvision - Responsible for manage-l 6,
ment of reliabi mty and quellty control activities required to support propulsion subsystem of Polarle program.
Division totaled j(
epprosimetely 620 peopf.o.,
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Associate Mansoor. Polarie Mem f acturine and Material Divielen -
Memponestie for management er the Polarse proeuctlon program, j'
inclueing. inert perte manufacturing, manufacturing engineering, production and meterial control, anoter processing, and final motor 4,
ensembly. Division totaled appronimetely 1,750 people.
ii,'
Head. Ak2 Lied Studies Desertment. Polarlo Enaineerine Olvleien =
l, MeeponeMe for initteting and completing resserch and development programe directed toward utill etion of new materiale and fabrice-l i
4 tion techniques in manufacture of Polarle rocket motor cesse and l
Inert componente.
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1956 - 1958 FORD MOTOR COMPANY
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Adminletration Meneger, Styling Olfleet Central Product Planning Officol and Staff Aseletant to the Executive Vice Preeldent, Car 1
and Truck Divisions.
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QEMRAL CLECTRIC C'OMPANY, AIRCRAFT GAS TWRSINE 19U - 1955 l,
DIVIStobl( AMCRAFT ACCESSORY TURBINE DCPARTMENT Q::::d throuherious seeignmente of manufacturing engineer, F siroject engineer, "c:;;; of Operatione Analysis report ng to
- d;*
, manager of division. Performed special seeignmente related to j
r component development, manufacturing studies to select product i
i lines, progrermlag, scheduling, coot control, and establishing l
l3 progedures, budgets and schedules.
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a S-j Resume - Lewis E. Zwissler 1
Page Three 1946 - 1952 M. W. KELLOGG COMPANY Production Design Engineer Special Project Department Responsione ior quamy proouction practices in original designs; 4
design changes, and development or use of new manufacturing methods. Department engaged in development of liquid propellant rocket engines and boosters, and solid propellant rocket cases.
Manager, RATO Fabrication Department - Fabricated Products Division - Responsible for pilot line and prototype production of ATO liquid rocket engines and booster rockets.
Division Head of Operating Division - Responsible for development testing for Special Projects Department and all fabrication, including subcontracted as well as internal development shop work; operation of high-speed rotating machinery testing, rocket test pits, inspection, coordination with design groups in layout design of new test stands, and estimating activities on new jobs.
.t945 - 1946 SELF-EMPLOYED l
Established Associated Consultants, with three other men.
Performed several small jobs in Chicago and Detroit areas.
1942 - 1945 ELLIOTT COMPANY i
t t Research Engineer, Research and Development Department k
Responsible for design, erection and operation of test stands for I
compressor and turbine machinery. Developed method of milling rotor for small Lyshdm compressors, and responsible for planning of research laboratory building for gas turbine development.
1941 - 1942 ARMOUR RESEARCH FOUNDATION Research Engineer in Applied Mechanics - Worked on analytical and i,
experimental investigations.
EDUCATION B.C., Civil Engineering - Armour Institute of Technology M.S., Applied Mechanics - Rutgers University Illinois Institute of Technology - Completed academic requirements for Ph.D. - did
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not complete thesis because of WW II.
REGISTRATIONS / CERTIFICATIONS l
Registered Professional Engineer, Illinois y
Certified Nuclear Auditor to ANSI 45.2.23 f.L
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PROFESSIONAL AFFILIATIONS t
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Member, Tau Beta Pi; Sigma Xi; Chi Epsilon honorary fraternities
!E Member, American Society for Quality Control, Fe!!ow Member, American Nuclear Society S
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TASK FORG EVALUATION WELDING INSPECTOR CONCERNS I
Prepared For:
J DUKE POWER COMPANY 422 South Church Street Charlotte, North Carolina 28242 4
e-J 26 April 1982 1
Prepared by:
Lewis E. Zwissler Vice President Management Analysis Company 11095 Torreyana Road San Diego, CA 92121 Project Number: MAC-82-F093 I
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EXECUTIVE
SUMMARY
Duke Power Company's (Duke) management became aware of a number of concerns regarding the quality of work expressed by the welding inspectors at the Catawba plant.
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Immediate action was taken to investigate the allegations to assure that the Catawba i
i plant would meet the Nuclear Regulatory Commission's (NRC) and Duke's quality requirements.
As a result of the initial findings, a Task Force was established to investigate all expressed concerns and to re-evaluate the technical resolutions to assure that all quality r
requirements had been met or to recommend actions to resolve any remaining open items.
Duke retained Management Analysis Company (MAC) to review the activities of the Task Force and provide an outside, independent overview to assure that all reasonable actions were being taken to assure the safety of the Catswba plant.
MAC'S CONCLUSIONS e
The Task Force members were technically qualified to perform their assigned task.
e The approach and methods used by the Task Force were adequate to assure a com-plete list of concerns and to provide technical resolutions for these expressed concerns.
The Task Force comp;eted the evaluation and prepared a report of the results and. _
e recommendations for corrective actions that meets or exceeds normal tecnnical and professional standards for completeness and quality of work.
i Successful completion of the recommended corrective actions will maintain safety i
e and improve the day-to-day work activities at Catawba.
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TABLE OF CONTENTS Page Section
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V 1.0 IN T R O DU C TION..........................................
2.0 INVESTIGATION SCOPE..................................
1 a
3.0 QUALIFICATIONS OF TASK FORCE MEMBERS 2
6 4.0 TASK FORCE OBJECTIVE.................................
5.0 TASK FORCE PROCEDURES AND METHODS 6
6.0 DATA COLLECTION AND REVIEW
7.0 TECHNICAL EVALUATION
Pace Appendices Appendix A TASK FORCE PLAN - CATAWBA WELDING INSPECTOR CONCERNS................................. A-1 Data Collection and Review............................... A-1 Technical Evaluation..................................... A-1 P
Results and Recommendations............................. A-2 Management Review / Implementation of Results.............. A-3 Inspector Feedback....................................... A-3 Final Report and Data Disposition.......................... A-3
'- - Technical Evaluation /
Individual Concern..................................... A-5 - Verification / Individual Concern............. :- A - 6 Appendix S LIST OF DUKE POWER COMPANY INTERVIEWEES.......... B-1 Appendix C CHECKLIST FOR INTERVIEWS
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1.0 INTRODUCTION
O Duke Power Company (Duke) was informed of a number of allegations and I
b inferences by several quality control inspections regarding the quality of work being performed at the Catawba Nuclear Station.
Duke's management immediately began to investigate the allegations to assure that the Catawba Plant met the Nuclear Regulatory Commission's (NRC) and Duke's quality requirements.
On December 4,1981, a Task Force was directed to investigate the allegations at Catawba, including the McGuire and Oconee Plants.
The Task Force concluded that the quality assurance (QA) and quality control (QC) programs at Catawba were workir.g and there was no evidence to confirm that unacceptable craftmansnip or unsafe conditions existed at the plant. It did report, however, a lack of communication between the inspectors, their supervisors and QA. This problem could have potentially reduced the effectiveness of the QA program, relative to welding inspection, if not firmly resolved (reference: Report by the Task Force on QC Inspection, Catawba Nuclear Station; December 29, 1981; Earl Hollen, Ted McMeekin, and Al Homesley).
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Subsequently, Duke appointed a Task Force to investigate all expressed concerns to assure that they were addressed and to re-evaluate the technical resolutions to assure they met NRC and Duke's quality requirements.
2.0 INVESTIGATION SCOPE Duke retained Management Analysis Company (MAC) to perform the following:
e Review the appror.ch and methods used by the Task Force to assure a complete list of concerns; e
Review the approach and methods usc
- by the Task Force to review and determine resolution of allegations; e
Review qualifications of those involved in the resolution; e
Audit resolutions to insure completeness and quality of work; e
Be prepared to report independently to Duke's President or Senior Vice President for Engineering and Construction; e
Prepare a written report covering the entire process; and v
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o B2 prep: red to t2stify, as nend2d, with rq;gtrd to his opinion of work performed by the Task Force and those involved in the resolution.
3.0 QUALIFICATIONS OF TASK FORCE MEMBERS
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3.1 LARRY COGGINS (Quality Assurance Engineer - Technical Support Group)
Education BS Materials Engineering, North Carolina State University,1970 Professional Activities Registered Professional Engineer, North Carolina i
Currently completing last semester for MBA, University of North Carolina.
e Experience e
Duke Power Company - nine years Quality Assurance Engineer Technical Support Group - one year Supervises five engineers and two QA specialists.
Quality Assurance - six months Review welding program, approval of procedures, technical review of
- (~N construction procedures, review and approval of welder qualifications; ASME Code Section IX.,
Design Engineering - seven-and-one-half years Specify and order materials and fabricated piping and penetrations. Field interpretation of ASME Code,Section III.
e Reynolds Metals - three years Materials Engineering and Operating Engineer Supervised four technicians and one secretary.
Conclusion Larry Coggins is qualified by virtue of his education and experience to perform as a member of the Task Force.
3.2 STEPl-EN VAN MALSSEN (Construction Staff Engineer)
Education e
BS Engineering Operations, North Carolina State University,1971 e
Numerous courses in welding, metallurgy, and management
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3029-2.
Professional Activities
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Member of Americta Welding Society
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e Member of American Nuclear Society s
Authorized Inspector - NBBPVI Level II Welding Inspector and Examiner (1979 - 1981) e Member, Utilities Advisory Committee, Welding Research Council e
e Alternate Representative - ASME Section III, Sub-committee on Nuclear Power Experience e
US Army - two years Cartographic Draftsman e
Kemper Insurance Company - two-and-one-half years Authorized Inspector, QA/QC Functions, Construction e
Duke Power Company - five-and-one-half years Construction Staff Engineer - one year Coordination of construction department welding program O
Coordination with QA, Engineering and construction site welding personnel McGuire Nuclear Station, Welding Welding Technical Support Supervisor - two-and-one-half years Lead Welding Engineer McGuire Nuclear Station, Construction Technical Specialist Welding - two years McGuire Nuclear Station, Construction Conclusion Stephen Van Maissen is qualified by virtue of his education and experience to function as a member of the Task Force.
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ma, 3.3 ROYG L. WILLIAMS p
Education
'J BS Engineering Physics, North Carolina State University,1961 Profesional Activities e
Member of American Welding Society e
Member of American Society of Mechanical Engineers t
e Member of ASME - B31.1 Code for Power Piping e
Member of ASME - B&PV Code Section I, Power Boilers Member of Piping Sub-Group, ASME Section I e
Registered Professional Engineer, North Carolina e
Experience Industrial Piping Division, ITT Grinnell - fourteen years e
Draftsman - two years
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Piping Engineer - six years N
Estimating, material ordering, construction in process and power piping Department Engineer - four years Supervised one engineer and three to four draftsmen, piping to ANSI 1331.7 and B31.1 nuclear applications Project Engineer - two years Supervised one engineer and two draftsmen, prepared orders for special material, interfaced with shop on fabrication, and with A/E, piping to ASME Section III and B31.1 e
Duke Power Company - nine years Analytical Engineer II (present position)
Supervised two to four engineers, prepared specifications for procurement and installation of piping for ASME Section 111 and 831.1; resolved non-conform:nce reports relating to materials and code problems; coordinated with other groups on code questions related to materials, fabricatio,n, examination and testing.
l Conclusion Royce Williams is qualified by virtue of his education and experience to function as a member of the Task Force.
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l 3.4 ALTON PARKS COBB, JR.
Education m
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e BSME North Carolina State University,1964 e
Graduate work - 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> to MS Engineering Mechanics Numerous company technical and management training courses e
e Professional Activities e
Eleven technical papers, author or co-author.
Experience e
Boeing Company - nine years Associate Engineer - five-and-one-half years Engineer - three years Senior Engineer - six months Structural Dynamics; load and stress analysis of aerospace structures s
Duke Power Company - nine years bi V
Assistant Design Engineer - three years Dynamic load; stress; seismic; and vibration analyses for nuclear power plant design.
Design Engineer - three years Supervisor of group responsible for special stress and vibration analyses and for managing consultant contracts engaged in piping analyses Senior Engineer - two-and-one-half years Group Head, Stress Analysis and Support Restraint Group Principal Engineer - six months Section Head, Civil Support Section Responsible for civil design for all operating stations.
Conclusion Parks Cobb is qualified to lead the Task Force by virtue of education, work and management experience.
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3.5 ROBERT W. McAULEY, JR.
Education i
e BSCE North Carolina State,1975
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MS Engineering (Structural), University of South Carolina,1981 e
Registered Professional Engineer, in North and South Carolina e
Professional Activities
)
e American Society of Civil Engineers Experience o
Duke Power Company - six years
- Supervisor, piping support design, Catawba Plant.
3
- Civil structures design
- Coordinating i.nd monitoring civil construction work Conclusion Robert McAuley, Jr. is quallfled to participate as a member of the Task Force by virtue of education and experience.
4.0 TASK FORCE OB.ECTIVE e
The Task Force objective was to assure that all concerns and allegations voiced by the inspectors regarding quality of work at Catawba were collected and reviewed to assure that the technical resolutions were valid and that no impact. _.
on the safety of the Catawba Plant existed.
5.0 TASK FORCE - PROCEDURES AND NETHODS The Task Force Plan is included as Appendix A. It is the purpose of this report to comment on the acceptability of the efforts conducted in each phase of the Plan.
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oyv 3029-2 5.1 DATA COLLECTION AND REVIEW Oi 5.1.1 Duke's Activities e O Larry Davison, Quality Control Project Manager, met with the inspectors at Catawba on January 14, 1982. The inspectors were asked to submit a list of o-their safety concerns for review by the Task Force.
Mr. J. R. Wells was directed to retain an outside consultant to assure members of the Task Force were qualified and that the procedures and methods they utilized would achieve the desired objectives.
s-Subsequent to the appointment of J. R. Wells to the Institute for Nuclear Power Operations (INPO) February 8,1982, and the appointment of George Grier as Corporate Manager of Quality Assurance, Parks Cobb and George Grier met with the welding inspectors at Catawba and explained the activities of the Task Force. The inspectors were again encouraged to submit any and all concerns they had for review and resolution.
The Quality Assurance Department undertook the task of collecting the O
pertinent data and back-up information available for each concern expressed by the welding inspectors.
Where necessary, the inspectors and others were interviewed and the notebook records retained by the inspectors were examined.
5.1.2 MAC's Activities MAC interviewed 12 quality assurance personnel and 14 management and' -
construction personnel. The interviews were to determine the degree of Duke's sincerity in conducting the Task Force review. The names of the inte?viewees are listed in Appendix B.
The interviews were conducted using a checklist to,cbtain a complete review of factors influencing the individuals' participation in the Task Force activities.
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The checklist is attached as Appendi,. C.
5.1.2.1 Task Force Member Interviews The Task Force members are qualified to perform the task of collecting e
and reviewing the data and making the initial re-evaluation of the technical s
aspects of concerns identified by the welding inspectors.
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o Th2 Tcsk Forca msmb2rs prcp:r:d a pirn for th2ir retivitits and ware acquainted, in detail, with the task assigned to them.
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e There were no factors identified by the Task Force members that would constrain them from satisfactorily completing the investigation and resolution of the technical concerns related to safety and quality.
e In all cases, the individuals interviewed affirmed their personal belief that Duke was committed to meeting or exceeding all quality requirements of the NRC and Duke's Quality Assurance Program.
e There was agreement that the Task Force would be successful in completing its task.
The only factor identified as influencing the acceptability of the results of e
the investigation was the previous involvement of some of the Task Force members with resolutions of the stated concerns. This was immediately remedied by appointing a new chairman, Parks Cobb, and initiating a completely independent review of each resolution to confirm or deny the initial finding of the Task Force.
5.1.2.2 Interviews with Other Duke Personnel e
There was a general understanding that a problem existed, identified with the concerns expressed by the welding inspectors. The consensus was that the recent downgrading of welding inspectors classifications provided the motivation and the mechanism (Management Procedure Number 8030-0003, Involving Difference of Opinion) to draw attention to their situation.
The feeling was that the technical aspects would be handled by the Task e
Force.
e There was unanimous agreement that Duke was clearly committed to quality and went above and beyond the requirements to assure a safe plant.
The questions regarding support, upward and downward, were answered ' ~
e positively except for the welding inspectors. The inspectors felt that they did not have the support of their supervision and management.
They questioned the continued acceptance of work even though departures from construction and quality procedures occurred.
The day-to-day operations were regarded as satisfactory.
There were e
comments that the procedures were getting too long and complex due to the insistence that every possible contingency should be covered by a procedure. This was regarded by some as an undesirable trend.
The welding inspectors were very vocal regarding their perception that e
departure from procedures was being permitted, as evidenced by acceptance of work completed. They were willing to accept an engineering evaluation of the acceptability of work, but felt GA management was not supporting them. QA was not insisting on compliance with procedures and non-compliances were not addressed in the corrective actions called for in the resolutions of NCI reports.
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l A few of the welding inspection personnel felt that individuals making l
e decisions to accept work (called out by inspectors as non-conforming) were l
not as technically qualified as the inspectors.
Welding inspectors with O(/
many prior years of welding experience felt they were qualified to judge acceptability of work and their decisions should not be questioned.
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5.1.3 MAC's Conclusions e
The Task Force and Duke's management took action to inform the inspectors, particularly che welding inspectors, of the investigation and were urged to communicate any concerns to the Task Force for evaluation and resolution.
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it is MAC's conclusion that all reasonable efforts were made to provide the e
inspectors the opportunity _to make known any and all concerns which they may have with regard to actions or events that would impact the safety or acceptable quality of the construction work at the Catawba Nuclear Power Plant.
e it was unanimous that Duke was committed to producing quality work and went beyond the requirements of the NRC and Duke's own qualit'y program to insure a safe power plant.
e There were no factors or influences identified that would inhibit the Task 9-Force from completing their assignment.
5.2 TECHNICAL EVALUATION
5.2.1 Duke's Activities The activities of the Task Force were pursued in accordance with the plan.
There was specific effort expended to assure that the technical adequacy of the resolutions acdressed the acceptability of completed work with regard to safety and compliance with the QA program requirements. The results of these efforts,,
were to develop:
e General recommendations regarding policy and administrdtion of department activities.
e' Specif!c actions to correct identified technical deficiencies.
e Programmatic recommendations related to' improving procedures and practices in technical and administrative activities.
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5.2.2 MAC's Activities MAC reviewed each file folder for. the concerns identified to make an O
independent evaluation of the quality of the work of the Task Force. The review consisted of:
e Reading the concern expressed by the inspector.
e Complete review of the Technical Evaluation Individual Concern (Appendix A, Attachments I and II).
e Detailed evaluation of the technical adequacy statement and reasons.
e Detailed evaluation of the recommendations.
The review included reference to the various QA and construction procedures and the QA manual cited in the cancern and the evaluation to assure valid interpretations.
MAC worked directly with the Task Force during the technical evaluation phase by reviewing each completed file folder and commenting on the quality of the evaluation, particularly in the areas of " technical adequacy and reasons" and
" recommendations". In cases where additional work was needed or where it was v
felt that the recommendations failed to address completely the a'ctions needed to resolve the concern, comments were made directly to che Task Force. This method of operation permitted MAC to evaluate the attitude, persistence and desire of the Task Force members to determine the actual or potential impact on tne safety of the plant.
5.2.3
_MAC's Conclusions The Task Force was dedicated to evaluate every concern to assure that the e
quality of work at Catawba voiced by the inspectors was reviewed, that the technical resolutions were valid, and that no impact on the safety of the Catawba Plant remained.
e It is MAC's opinion that the Task Force performed their technical evaluations in a professional and technically adequate manner to satisfy all NRC and Duke QA program requirements.
The practice of performing an independent review of previous resolutions e
followed by a second independent review resulted in assuring that no bias existed in the final Task Force determinations.
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5.3 REST.A.TS abo RECOMNENDATIONS 5.3.1 Duke % Activities i (
The results and recommendations of the Task Force are given in " Final Report of Task Force Effort to Evaluate Technical Concerns of Catawba Welding Inspectors, Volume I - Task Force Program Summary", revision 1, dated March 30,1982.
The concerns were classified into nine generic technical areas.
The recommendations for specific and programmatic actions were tabulated for each generic area (Table I, Task Force Report).
In addition, two general recommendations were made to improve the procedures and practices at the department level.
1 The plan for feedback to the inspectors consisted of a general meeting to explain the Task Force results and recommendations to the inspector group.
Additionally, individual reviews were planned with the inspectors who had submitted concerns.
5.3.2 MAC's Activities The specific and programmati'c recommendations included in Table I (Task Force Report) were reviewed to assure that the summaries were valid. In as much as each file had been previously reviewed, no further review was con-sidered necessary.
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5.3.3 MAC's Conclusions The Task Force results were an accurate portrayal of their evaluations.
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The Task Force recommendations were derived from their analysis of the results egd adequately addressed the specific and programmatic actions to resolve the concerns expressed by the welding inspectors.
. The two general recommendations should improve the day-to-day work a
e activities.
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l 5.4 MANAGEENT REVIEW /It@LEMENTATION OF RESULTS l
5.4.1 Duke's Activities l
The Task Force met with members of Duke's management to review their activities, results and recommendations on March 23,1982. Those present were W. H. Owen, R. L. Dick, R. B. Priory,
'e'. L. Bradley, A. P. Cobb Jr., L. M.
Coggins, S. H. Van Maissen, G. Grier and L. E. Zwissler (MAC).
The consensus was that the Task Force Report, Volume I, was acceptable with respect to documenting the Task Force activities and recommendations. The Task Force stated their intent to prepare a management implementation plan and include that in a revision to the Task Force Summary Report (Volume I).
7 W. L. Bradley was identified as the individual responsible for coordinating the corrective action plan and activities. He was also responsible for follow-up to assure completion of the action plans.
5.4.2 MAC's Activities The MAC representative attended the management review meeting and partici-pated in the discussions.
5.4.3 MAC's Conclusions e
Responsible members of Duke's management performed an adequate review of the Task Force activities, results and recommendationns.
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o Duke immediately undertook a program to complete, as necessary, the corrective actions identified by the Task Force.
5.5 MANAGEENT IMPLEENTATION PLAN 5.5.1 Ouke's Activities A management implementation plan was prepared and incluoed as Section 9.0 of the Task Force Report.
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W. L. Bradisy (Corporcts Gunlity Assur:nca Dspartment) wcs Essign2d Es tha implementation coordinator to assure that the recommended actions were planned, completed and document.ed.
The plan for resolving the general and programmatic recommendations was structured by identifying objectives which corrective action programs should meet to correct the problems.
The completion of the implementation plans are'to be reviewed and approved by the department heads of Quality Assurance, Construction and Engineering.
4 5.5.2 MAC's Activities The Task Force Report Summary, Volume I, Revision I was reviewed in its entirety.
5.5.3 MAC's Conclusions The management implementation plan is adequate to resolve the stated e
concerns of the welding inspectors at the Catawba plant.
Successful completion of the management implementation plan will resolve e
satisfactorily the technical concerns related to plant safety.
Successful completion of plans addressing general and programmatic re-e commendations should improve the day-to-day work activities at Catawba.
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APPENDIX A j
TASK FORCE PLAN - CATAWBA WELDING INSPECTOR CONCERNS O
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I.
DATA COLLECTION AND REVIEW (2/10/82)
A.
Identify inspector concerns.
1.
Obtain copy of statement of each concern submitted originally.
2.
Obtain statement of any additional concerns (1/29/82 letter).
B.
List, index, and classify all concerns.
C.
Establish file for each technical concern.
D.
Establish file for each generic area of technical concern.
E.
Review each technical concern for sufficient information.
ez 1.
Conduct additional interviews with inspectors as needed.
2.
Collect data from within and outside Task Force as needed.
i II. TECHNICAL EVALUATION (2/24/82)
A.
Divide and assign technical concerns to Task Force members based on expertise.
B.
Perform technical evaluation.
1.
Develop response to concern.
l a.
State Task Force concurrence that concern is valid (or not) based on available, substantiating information and give reason (s).
b.
Cite any violations of Design, Construction, or QA Procedures that have or could occur as result of concern (regardless of answer to item a).
c.
State if item or generic area of concern is technically adequate at' -
present, based on items a. and b. above and other pertinent data available. State reason (s).
2.
Cite recommendations (if any) for additional review, program or procedure changes, hardware changes, etc. as judged appropriate to fix existing inadequacies, prevent problems in the future, and/or prevent concerns in the future.
l C.
Document technical evaluation on form Technical Evaluation - Individual Concern (Attachment 1).
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Document stttsm:nt of conc;rn (pcrrphrtsad) Cnd Etttch a copy of tha hindwrittIn concvrn C.s obtcined from th2 originItor.
,m 2.
Document technical response and recommendations.
(VI 3.
Attach any pertinent information used in the technical evaluation.
4.
Sign and date the form after evaluation is complete.
D.
Verify technical evaluation by independent review by another qualified member of the Task Force or a qualified person outside the Task Force.
1.
Review the documented technical evaluation.
2.
Make determination as to technical accuracy and completeness of evaluation.
3.
Perform separate data collection, fact-finding, and analysis as necessary.
l E.
Document verification on form Verification - Individual Concern (Attachment II) 1.
Document any separate data collection, fact-finding, and analysis conducted.
2.
Document pertinent comments or items that contributed to verification to indicate general process used, as deemed appropriate.
3.
Sign and date the form after verification is complete.
n F.
Where two members of the Task Force were previcusly involved in basis of the concern (such as NCI resolution), only one may participate in the evaluation and verification process.
G.
When necessary, expertise outside the Task Force and Duke Power in general shall be used to provide complete and accurate evaluation and verification of concerns.
III. RESULTS AND RECOMNENDATIONS (2/24/82)
A.
Develop statistical summary of responses to technical concerns.
1.
Number of concerns with concurrences versus non-concurrences.
2.
Number of concerns involving design or constrdction requirement violations (actual, potential, none).
3.
Number of concerns involving technical inadequacies (actual, potential, none).
B.
Compile recommendations by generic area; note the number of occurrences of each recommendation.
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C.
Devslop ov:;r:Il recommenditions.
1.
Technical recommendations related to concerns.
2.
Recommended plan for feedback of Task Force effort to inspectors.
IV. MANAGEhENT REVIEW /IMPLENENTATION OF RESULTS (3/4/82)
A.
Develop draft reports.
1.
Volume 1 - Task Force Program Summary 2.
Volume II - Technical Evaluation and Verifications - Individual Concerns B.
Review technical recommendations and obtain management - implementation plan.
C.
Review plan for feedback to inspectors and obtain management input on implementation.
D.
Incorporate management implementation plan for Task Force recommendations into Volume I report.
V.
INSPECTOR FEEDBACK (3/11/82)
A.
Conduct presentation of Task Force Program to inspectors as a group.
1.
Review overall Task Force effort.
2.
Review results of technical evaluations (summary).
3.
Review technical recommendations and management implementation plan.
4.
Document questions, answers, and comments.
B.
Review evaluation of each technical concern with originating inspector in separate discussion.
Include others in discussion, as appropriate, such as inspector's supervisor, other Task Force members.
Document pertintent comments.
C.
Summarize results of group and int.svidual discussions.
VI. FINAL REPORT AND DATA DISPOSITION (3/18/82)
A.
Finalize and publish report to management.
1.
Incorporate inspector feedback results in Volume I.
2.
Print and distribute reports (Velume I and II).
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1
8.
Close out files of individual conesrns tnd gsnaric tree.s of concern.
1.
Collect fila material in bindsr(s).
5 2.
Transmit to file with Final Report originals.
C.
Conduct review with Nuclear Regulatory Commission.
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Attachtnent i O
TECHNICAL EVALUATION - INDIVIDUAL CONCERN STATEMENT OF CONCERN FILE NO.
(Parachrase Concern and/or attach clipping of copy of original version as P
obtained from inspector; include statements as necessary to clarify stated con ce rn. )
TECHNICAL RESPONSE CONCURRENCE STATEMENT AND REASON (S):
(State if concern is or was substantiated by specific physical evidence, such as paperwork, in-place item or procedure, etc. and cite such evidence.)
SPECIFIC CRITERIA VIOLATED OR MISUSED:
(Specifically list p-ocedures involved)
TECHNICAL ADEOUACY STATEMENT AND REASONS:
(State if in-place item, procedure, etc. is technically adecuate at present and state reason (s). )
OTHER COMMENTS:
(Note any additional data gathered, investigations made, etc. in support of eva luatien. )
RECOMMENDATIONS (State recomendations as deemed appropriate for int::ediate and future changes or activities to remedy or improve technical adequacy in area of concern, regard-less of oresent state of the concern.)
Os SIGN-OFF EVALUATION PERFORMED BY:
l DATE:
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Attachment II VERIFICATION - INDIVIDUAL CONCERN FILE NO.
(State any comments as desmed appropriat' to note logic used in verifying evaluation; document any additional data gathered, discussions held, or investigations perfomed.)
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SIGN-OFF DAL'JATION PERFORMED BY:
DATE:
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9 APPENDIX B DUKE POWER COMPANY INTERVIEWEES 4
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Task Force Members Principal Engineer Parks Cobb
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Larry Coggins Quality Assurance Engineer Construction Staff Engineer Steve Van Maissen Analytical Engineer II Royce Williams Quality Assurance Personne!
Quality Assurance Manager, Projects Larry Davison Project Quality Assurance Engineer Robert Morgan Rob Atkins Staff Quality Assurance Engineer, Welding /NDE Supervisor Welding Inspection Charles Baldwin Supervisor Quality Assurance Technical Welding /NDE Joe Shopshire
[
Richard Childers Lead Inspector, Welding Senior Welding Inspector Charley Farrell Beau Ross -
Supervisor, Technical Welding Inspector Welding Inspector John Rockholt Welding Inspector Richard Irby Welding Inspector Dennis Wright
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Welding Inspector John Bryant Construction Personnel Construction Project Manager John Rogers Senior Construction Engineer Sam Dressler Welding Support Group Dave Llewelbyn General Superintendent Charley Aycock 4
Mechanical Superintendent Ken Webber l
Bill Rogers General Superintendent, Welding i
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Construction Personnel (Continued)
General Foreman, Welding Billy Smith Foreman, Welding
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Herschel Brewer O
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Welder Ed B. Henlien Welder Wayne Garvin i.
Welder Keith Kirby Tom Mills -
Mechanical, Technical Support l'
Tom Robertson Construction, Technical Support Civil / Welding Vice President, Construction Robert Dick r
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O REVEW OF DOCUMENTATION OF COMPLETED CORRECTIVE ACTIONS RESLLTING FROM TASK FORCE EFFORTS TO EVALUATE TECHNICAL CONCERNS OF CATAWB A WELDING INwt.u ORS FOR DUKE POWER COMPANY August 18-19, 1982 Management Analysis Company Project Number: MAC-82-F093 O
sum
8087-2.
The documentation of completed actions taken to implement the " Management Imple-mentation Plan", Section 9.0, Final Report of Task Force Effort to Evaluate Technical Concerns of Catawba Welding Inspectors, Volume I - Task Force Program Summary, March 30,1982, was reviewed during the period by August 18 and 19,1982.
As a result of the evaluation, several recommendations are made. The detail findings are included in the balance of this report.
Recommendations 1.
The documentation supporting each action taken to answer a specific recommendation should clearly state what was done in a manner equivalent to answering a direct question relating to the recommended action (Finding 9.3.d).
The documentation should be such that under cross-examination by an attorney the supporting evidence is readily available. If a review was made and the decision was that no action was taken for valid reasons, it should be so stated and documented.
2.
Document the content of all training given to inspectors with particular emphasis on Welding Inspection Programmatic Recommendation #6 and NCIR Recommenda-1 tion #2. Document specific answers given in training to all actions recommended throughout the Programmatic Recommendations.
4 3.
Evaluate anticipated or demonstrated effectiveness of actions taken (Finding 9.3.d).
1 4.
Review new procedures and procedural changes to assure they are adequate to meet objectives (Finding 9.3.1 cnd 9.3.a.1, 2 and 3 and 9.3.d).
5.
Review specific techrical resolutions to assure every item is addressed (Finding Project Control #10 and Quality Assurance Procedure #4). This might occur as the result of answering the specific action concern, Table IX, without reference to the specific concern, Technical Evaluation Sheet R-63.
6.
Interview Duke personnel; including inspectors, craft and supervisors, to evaluate l
their perception of the success of the Task Force effort.
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Findings The review was a quick look to determine if there was any evidence of generic type O
problems whose corrections could lead to more complete and acceptable set of corrective actions. The findings which support the recommendations for improvement are detailed in this section. They should not be considered a complete and exhaustive review of the acceptability of the implementation of the Task Force recommendations but are indicative of arena where improvements can be made.
Findina 9.3.a.1,2 and 3 The Inspector Resource Procedure QA-007, establishes a method whereby inspectors may l
seek tschnical resolution of questions which they consider wrong or inadequate. There are no provisions for Duke management to assure that all submittals are resolved or the inspector informed that he has been given a final answer by Duke Quality Assurance and his next step is the Corporate Resource. That is, there is no tracking procedure to ensure that a concern is not lost in the system which could lead to an inspector perceiving that he had raised a quality question and Duke had not acted.
The responsibility is left to the inspector to pursue final resolution. It appears that Duke management should play an aggressive role to assure every reasonable action is taken to resolve concerns regarding quality Findina 9.3.d
" Process Control Recommendation 3 states; Review the adequacy of track-i ing methods for monitoring Process Control procedural and documentation problems. Review methods for feeding back results from such monitoring into procedures and personnel performance evaluations."
These two items were not specifically addressed in the response or resolution of Item 9.3.d.
In addition Item 9.3.d states:
"Put in place an appropiate discrepancy tracking and feedback program.
Including review sessions for non-NC1R discrepancies."
4 The first action is not addressed. The second item is answered by a memorandum from Sam Dressler setting up the meetings. Documentary evidence does not demonstrate that this is an effective method of satisfying the requirements stated in Dessler's memo.
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. 8087-2 Meeting schedules were not available to support quarterly schedule of meetings of same Also, based on quarterly schedule, the time lag between discovery of problem, groups.
reporting and resolution could take almost 6 months. This appears to be too long for a construction problem related to process control problems, The meeting minutes did not include the names of attendees so documentation of i
attendance by group leaders is not available.
QA was assigned responsibility for "taking notes and monitoring action items". There is no indication of a QA procedure for handling this or other indication of how this action will be implemented.
Findino 9.3.1 The resolution of Item 9.3.1 was accomplished by writing QA-107, Procedure for Issuing Temporary Changes to Procedures.
There are several apparent weaknesses in this i
procedure:
1.
Distribution of QA-107A is not required to all manual holders; hence, an individual manual may not be up to date.
2.
No requirement stated for time limit, invalidation or incorporation into GAP for a GA-107A.
3.
Accounting is related to those no longer in effect or incorporated in QAP, not those that are in effect; hence, no active list is available.
4.
No statement in QA-107 that " Memo to File"is not to be used in issue clarification or direction for procedural deficiences.
5.
No provision to review outstanding " Memos to File" for need to issue QA-107A's to formalize existing directions, i.e., see July 1,1982, memo to file, Method of Handling NCis returned to Design or QATS.
Findino Process Control #10 I
The specific action recommendations of Process Control #10, references concerns, J-5, i
R-13 and H1 which require hardness checks to be made on specific welds in question.
There is no documentation available in the file to indicate this action was taken.
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4-8087-2 I
Findino QA Procedures #4 -
l This specific action refers to concern R-63 which requires verfication of filler material
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j action was taken.
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