ML20101Q513
| ML20101Q513 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/26/1982 |
| From: | Foster J, Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20101Q435 | List: |
| References | |
| FOIA-91-187 3-82-025, 3-82-25, NUDOCS 9207140313 | |
| Download: ML20101Q513 (5) | |
Text
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- f Reauj,'o UNITED ST'ATES rN NUCLEAR REGULATORY COMMISSION c
_DIQCLOSE-nI-
- REGION 111 Con n8 id ity Of o
799 POOSEVELT RO AD OLEN E LLYN,lLLINOIS 60137 :
Confi iAl 5 CS Office of Investigations
. REPORT OF INQUIRY November 26,-1982
SUBJECT:
ALLEGED IMPROPER / UNAUTHORIZED DESTRUCTION-OF ZACK COMPANY RECORDS AT THE CLINTON NUCLEAR POWER STATION _(OI NO. 3-82-025)
Background Information-On November 15, 1982',-the Office of Investigations, Region III, received ~
the-following information.from Herbert H. Livermore, Region III Senior Resident Inspector at-the Clinton Nuclear Power Station:
Baldwin-Associates' Quality A*surance' Auditors had found Zack Company-
_(the HVAC contractor) employees shredding Zack Company records at the Clinton site on-November ?.2, 1982. Baldwin;Asso'ciates believed the records.
-pertained to construction quality and should be retained, not destroyed.
i-They confiscated the documents pending -destruction and the bags of already L
shredded papers.
Baldwin' Associates also had the Zack Company's Clinton Quality Contro1' Manager,_ Gary A. Moseby, removed from_the: site, as they believed Moseby had ordered the destruction of the documents (Attachment 1).
On November 15,.1982, Baldwin Associates met with the management of.the Zack Company (Christine Zack DeZutel, Zack Company President; David Calkins, Zack'_s'Clinton Projec* Manager; and Mark Skates,- Zack's Quality Assurance Manager). The Zack _ Company _ contended the records being destroyed were superseded ~and/or-duplicates of Engineering Change Notices (ECN), Field Change Requests (FCR), Field Interference' Notices:(FIN), and Nonconformance-Reports (NCR). - The Zack _ Company.submitited that their-procedure CB-FQCP-T,;-
1 Procedure for Site Document Control (Attachment.2), permitted the~destruc-.
tion of those documents', and the Zack: Company _was. logging the records 1 destroyed _(Attachment 3)i Baldwin Associates notified the Zack Company that they would be conducting an investigation.into this-matter.
The Zack: Company, through Livermore, requested an NRClinvestigation':of-this incident.(they stated'such an-investigation would' clear them of' impropriety)~.
Interview 'of Illinois' Power Vice President On November-16, 1982, D. P. Hall,' Illinois Power Company's'Vice President-
- for Quality Assurance, was interviewed.- Hall was informed the purpose of-1 this inquiry was to learn the details of the matter and; the planned -course of action in order to. protect the interests of-the NRC.
Further, this in-i quiry was = not being conducted in = response to the= Zack Company? s request for an investigation. Hall: advised Illinois Power was following the investiga- :&f DO.71 DISCEo y Centa s ident y og-
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Report of Inquiry Zack Company Records at Clinton g v
tion being conducted by Jim Findley, Baldwin Associates Quality Assurance Manager.
Hall further advised Illinois Power was allowing Baldwin Associates the lead in the investigation as the Zack Company was a subcontractor to Baldwin Associates and not under direct contract to Illinois Power.
Interview of Baldwin Associates QA Manager on November 16, 1982, J. E. Findley, Baldwin Arsociates' Manager of Quality and Techni a l Services, provided the following information:
On November 12, 1982, Findley held a meeting with various members of the Baldwin Associates' staff to discuss their planned assumption of the site quality control f unction f rom the Zack Company.
This meeting was inter-rupted by three Baldwin Associates Auditors (Marsha Sumner, Jim Moffatt and John Kent) who had been at the Zack Company's trailers to conduct a vendor audit. The auditors reported they had observed several boxes of documents about to be shredded by Zack Company employees.
The boxes appeared te contain FINS.
Members of the Baldwin Associates quality assurance staff and site security went to the Zack Company trailers and found the Zack Company was in the process of shredding HVAC records.
Baldwin Associates ittpounded the records, removed Mosby from the site, and denied entry to the trailers by Zack Company employees. Also, the Baldwin Associates' staff learned the tack Company's shredder was not listed with Baldwin Associates as a piece of equipment authorized for use at the Clinton site.
', Attachment 4 pertains to the actions of the 3aldwin Associates' staff on November 12, 1982.)
The Baldwin Associates' qual.ity assurance staff conducted an immediate inspection of the records about to be destroyed and they appeared to be of the type required to be retained. Baldwin Associates guarded the records over the weekend and on November 15, 1982, began a complete inventory of the seven cartons of records.
Findley advised Baldwin Associates is inventorying all of the documents that had been identified by the Zack Company for destruction. 'Upon completion of that inventory, Baldwin Associates would compare the inventoried documents and the Zack Company's list of already destroyed records with the permanent g
records on file.
The purpose of the comparison is to determine if all of v
the information from the destroyed /to be destroyed documents was on file in permanently retained records.
(Attachment 5 is Baldwir Associates' Zack Plan of Action.)
Findley stated he would keep the NRC informed of the progress of the Baldwin Associates' investigation of this matter, b
In dC7 h NbE Cbntaint idensitT CI cenfidentiL1,CW YC2
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DO[NOT DISC [0Sh Co;thinsildictityOf confid;ntiil;pturc3 Report of Inquiry Zack Company Records at Clinton November 26, 1982 Observations by NRC personnel On November 16, 1982, the NRC Senior Resident Inspector and 01:RIII Investi-gator Weil inspected two cartons of records identified by Sumner and Kent as records slated for destruction by the Zack Company.
The two cartons appear-ed to contain xerox copies of ECRs, ECNs, and FINS.
A few original documents in the form of transmittal slips were found. Neither Sumner nor Kent could answer if the boxes contained inspection records.
Both replied the Zack Company Document Control clerks claimed to have listed the inspection records destroyed; therefore, both assumed the cartons could contain inspection records.
While inspecting a record folder designated Diesel Generator Building-702',
a Zack Company " Shop Traveler" (Attachment 6) was found.
This traveler (SF-5541. Drawing No, M14-1063-1) contained original writing under the " Quality Assurance" heading on the line beginning " Welder I.D."
"O.C. was writtea after the Welder 1.D. heading.
"J.M. 2-21-82, Companion 1 OK" was entered after " Inspector /Date." These writings were in ink, the drawing and accom-panying design information on Shop Traveler SF-5541 were prepared from carbon paper.
Shop Traveler SF-5541 was compared to " Field" Traveler SF-5541 (Attachment 7) on file at the Zack Company's site quality control office..The Field Traveler drawing and accompanying design information were prepared from carbon paper similar in appearance to that information on the Shop Traveler.
Under the Quality Assurance headit.g, the information on the line beginning " Welder I.D."
was written in ink.
- 1he " Welder I.D." and the " Inspector /Date" had the same information as on the Shor Traveler (Welder I.D. was "0.C." and the Inspec-tor /Date was "J.M. 2-21-81."
However, the remaining information written in ink on that line was different.
The Field Traveler had "16 welds acc dim ok";
however the Shop Traveler had " companion ). OK" on-that same line.
Findley was given the Shop Traveler SF-5541 and requested to resolve the apparent discrepancy between the Shop and Field Travelers. Also, Findley was informed the Baldwin Associates' comparison of the documents to be destroyed to the-permanent file records would have to be quite detailed in order te insure all information had been transferred to the permanent files.
Findley acknowledge the necessary for a detailed comparison of the documents.
Actions Planned by OI RIII The Baldwin Associates Plan of Action was reviewed in detail with Findley.
Baldwin Associates' plan covered the necessary aspects of document inventory and comparison to permanent records to assure all pertinent information had been transferred to the official files.
Baldwin Associates and Illinois Power were advised to proceed with the investigation as outlined and to keep the NRC apprised of their findings.
Laldwin Associates
- investigation will be monitored by the NRC Senior Resident Inspector and the Of fice of Investi-j gations, Region III.
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Zack Company Records.at Clinton l November 26,.1982 MM E arles H. Weil, Investigator APPROVED BY:
// /M
~.mes E. Foster, Acting Directof #-
Office of Investigations, Region III Attachments:.
1.
Zack Company ltr, dtd 11/3/82 Moseby to Washburn/J. DeZutel-2.
Zack Company Procedure CB-FQCP-7,.
Rev. 8,_ Site Document Control 3.
Zack Company listing of destroyed documents 4.' Baldwin Associates' Memo of Events dtd 11/12/82 5.
Ltr dtd 11/15/82, Findley to Hall :
Zack Plan of Action 6.
Zack Company Shop Traveler.SF-5541 7.
Zack Company Field' Traveler SF-5541~.
A y
- cc w/ attachments:
p W. J. Ward, 01:HQ James G. Keppler,. RIII
.R.
C. Knop, RIII D. W. Hayes, RIII H. H. Livermore,-RIII R. D. Lanksbury, RIII R. M. Burton, OI:RIII:
R. J. Strasma, RIII'
.Cohtainshput 7 Of i
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" thel ZACK i coe
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. CUSTOM METAL FADRICATidN 4AM.1H005.82
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November 3. 1982 To:
Marcia '.lashbern,- D.C. Supervisor /J. De7ute!, Encutive Vice Pres.N from:
C. Moseby, Q.C. Mst.
Marcia:
Please pull in all ECN, TECN and TCR books from the field! This includes all historical files.
e Hy copies vill to on'the shelf behind my desh, and will be marked "ref erence only".
- Since the hanger drawings will come in from Sargent and 1.uidy with outstanding docuents incorporated, and our Traveler Control Croup vill double check these drawings, any additional inforr.ation required v111' coae fron Sarger.t and Lundy on a FECN, and become a part of the Job Plan Treveler.
In additio:., all our new procedures (FQCP's and TCP's), will not allo.c any outstanding (iles of this type, and vcold result in subsequent stop work's and shut downs.
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C.-A. Moseby, Q. C. Hgr.
I Cocuruan:f,6fL-ZACK/CUNTO' CAM:ai
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cc: J. NZutel D. Peters-J. Peoples ld.
H. Skates D. Boyd D. Calkinn a
R. L' singer J. Neuhoff D. Jenniges C. Bracken ATTACHMEh'T ON'E
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