ML20136D990
| ML20136D990 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/27/1983 |
| From: | Treby S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Hayes B NRC OFFICE OF INVESTIGATIONS (OI) |
| Shared Package | |
| ML20136D916 | List: |
| References | |
| FOIA-84-779 NUDOCS 8511210403 | |
| Download: ML20136D990 (3) | |
Text
' U U S.'NRC U33 OCT 28 h g; 47 IITCE CF I.WESTCA?ig;$
October 27, 1983 0ADW!ARIEp"c' I
Note to:'
Ben B. Hayes
~
Director, Office of Investigations Fro.m.:
Stuart A. Treby Assistant Chief Hearing Counsel i
Office of the Executive Legal Director
SUBJECT:
' TELEPHONE CONFERENCE OF FRIDAY, OCTOBFR 21, 1983 IN COMANCHE PEAK On Friday, October 21, 1983, the Licensing Board convened a telephone j'
conference among the Board and parties to discuss alternative' ways of going forward with the evidentiary hearings in this proceeding.
In the course of the telephone conference, Mrs. Ellis, l
Tr. 9079-81.
the representative of CASE, made a critical conraent regarding the report of the deposition of Robert Messerley taken by the Office of Investiga-tions(01). Tr. 9098-9099. The Chafnnan of the Licensing Board 1
requested that I make sure that this section of the transcript was referred to 01 for its infomation. Tr. 9099.
Attached is a copy of the entire transcript for your informatior and, in accordance with the Licensing Board's request,1 direct your attendtion to pages 9098-9099.
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j Stuart A. Treby Assistcr.t Chief Hearing Counseli Attechcent: As stated
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l 8511210403 851101 f
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GARDE 84-779 PDR Qj L
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I witnesses 'nd potential witness testify before the Board.
a 2
Tnere are many of the people who were interviewed by the 3
office of Investigation which these individuals do not want 4
to remain anonymous.
They are anxious and willing to speak 5
to the Board and would like to be able to do that. There is 6
no need to await the findings of the Office of 7
Investigations in this regard because the people do not 8
" request anonymity.
9 JUDGE BLOCH:
I would in particular like the 10 reaction of the staff to that possibility, but please Il continu'e.
12 MS. ELLIS: Another thing that has arisen is that 13 one of the things that we were concerned with in the 14 investigation is that things were not handled in some ways 1
15 as we thought they should be. One of the things was brought 16 home in a particular investigation report which we received
- ncfYcrWJ 17 the week before the hearings.
It is Investigation Report i
18 83-27 under cover letter of September 29th.
19 In that particular report i t discusses some 20 allegations made by Robert Messerley.
This involved a 2!
deposition which was taken by the NRC Office of J
22 Investigations of.Mr. Messerley.. I personally was present 23 at that i nterview.
There is one point in particular that 1 23 just will taent.ico, but. there ate-several things about t.his 25 that the Board will probably be hearing f rora us in detail b
TAYLOE ASSOCIATES I
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regarding this particular report.
2 One of the things it states at one point is that 3
Mr. Messerley's allegations lacked specificity.
1 4
personally heard Mr. Messerley at the end of that interview g
79 5
ask if there isn't some way that they can go down to the 6
plant with the people from the investigation and show them I
where some of these things are.
The idea that a report 8
comes out now saying that his allegations lack specificity 4
9 is completely contrary to that and I see no reason for it 10 all, and, as I say, we will be pursuing that.
II JUDGE BLOCts:
Mr. Treby, could you please make 12 sure that that particular section of the transcript is 13 referred to 01 for its information?
14 MR. TREBY:
I will. I believe though that the 15 report tnat Ms. Ellis was just discussing with regard to M
Mr. Messerley was an inspection report.
II JUDGE BLOCti:
No, there is an attached report by 18 OI in support of the inspection report.
19 MR. TREBY:
I will make OI aware of this portion 20 of the transcript.
21 !-
MS. ELLIS:
Another possibility. would be fC r l
22 tnese witnesses or potential witnesses to take the Board or 21 the Board's consultants to the plant and show them some 24 specific instances.
23 JUDGE BLOCH:
You think.they could show us TAYLOE ASSOCIATES 16251 STREET. N.W. - SutTI 1004 WASHINGTOW, D.C.
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e TEXAS UTILITIES GENERATING CO.TIPANY 2001 BRYAN MWER DAL.LAS TEXAS 76201 R.J. GARY
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December 13, 1983 TXX-4087 John Collins Regional Administrator U.S. Nuclear Regulatory Comission Docket Nos.:
50-445 611 Ryan Plaza Dr. Suite 1000 50-446 Arlington, TX 76012 COMANCHE PEAK STEAM ELECTRIC STATION INVESTIGATIONS INTO ALLEGATIONS CILE N0.:
10066
Dear Mr. Collins:
In accordance with our agreement, enclosed please find a copy of the report of our investigation into allegations made by W. A.
Dunham and concerns expressed related to protective coatings.
Very truly yours, RJG:In Enclosure NRC Region IV (0 + 1 copy) cc:
Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Comission Washington, DC 20555
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5 TEXAS UTILITIES GENERATING COMPANY QTO-46:
OFFICE MEMORANDUM October 25. 1983 Dallas, Texa, _
D.N. Chapman To_
INVESTIGATION INTO ALLEGATIONS MADE BY W. A. DUNHA AND CONCERNS EXPRESSED RELATED TO PROTECTIVE C Subjeet 19, 1983, to D.N.
In accordance with B.R. Clements' memo dated September Chapman, an investigation was conducted into allegations made Bill Dunham, in filing Fonn B-3 (1282), Initial Claim for Benefits, with the Texas Employment Commission, indicated in part, Andy Dunham.
for identifyin; quality problems..."
The first part The investigation was basically a two part investigation.
included discussions with Bill Dunham, with other d
24, 1983; and persons present at the QC Coatings Inspectors on August The purpose of these discussions was to 26, 1983.
determine if Bill Dunham had been dismissed for identifying quality probl counseling session on August The details of the first part of the investigation are included in Attachmen The allegation that Bill Dunham was tenninated for identifying quality A.
problems was refuted.
The second part of the investigation followed up on matters initially broug up during the first part of the investigation.
The rest of the coatings QC inspectors, both day and night shifts, were a In addition, Mr. Harry Williams, the former Coatings QC In addition, T1JSI interviewed.
Supervisor, was also contacted at his present job. Engine supports engineering decisions was examined.
These Basically, six technical concerns were voiced during the investigation.
The technical concerns were itens are detailed in Attachment B, Part 1.
discussed with TUSI Engineering and with the Principal Corrosion Engine The Gibbs & Hill Specification AS-31, " Protective Coatings," was l
Industry standards referenced in the G&M specification, and site Ebasco.
l procedures for coatings application and inspections wsre also reviewed reviewed.
The validity of each of the technical concerns was evaluated in light of specification requirements and requirements in refe l
i and where deemed necessary, Design Basis Accident (DBA) testing reports examined to further assess the validity of engineering conclusions.
Dn the basis of the above, the technical concerns expressed by the inspect were found to be unwarranted.
QTQ-481 10/25/83 Page 2 The allegations of harassment, intimidation, and threats were investiga These t
The results of this investigation are detailed in Attachment B Part 2.Also, t phrases had varied meaning to different inspectors.
wre seen differently among the inspectors, and perceptions varied fr These discussions were highly subjective.
occurrences to improper actions.
In summary, inspectors working under the previous coating QC Supe Mr. Williams, Harry Williams, perceived less than total support from He stated inspectors were right but could not support an inspector when wrong.
liefs that that these disagreements came about primarily because of inspector be However, better procedures reflect unacceptable technical practices.
supervisory practices at times of disagreements would hav
- ble, vocal and articulate, group of inspectors who appear technically knowled the adverse morale effect.
and so have a disproportionate amount of influence with incidents resulted in inspection omissions which constitute a safety conce Coatings QC force.
It is recommended that a procedure be established on site, by which cr appeal an inspector's decision, that prevents the atmosphere of co This procedure that arises when craft and QC supervisors become inv between the inspectors and their supervision.
These are Management actions relevant to previous allegations were reviewed detailed in Attachment B, Part 3.
properly covered the scope of the allegations made at that time and i
management actions taken as a result of those investigations were ap in addressing the problems identified at that time.
l Inspectors' concerns related to the Protective Coatings Program at C The investigation concluded evaluated and detailed in Attachment B Part 4.
be that the use of the IR UNSAT instead of the NCR for activities reworked to meet engineering requirements is co I.
B.the IR to address missed hold points.
In addition, inspectors expressed a programmatic concern that there are provisions by which inspectors can express technica a policy decision must be made to define the extent to which inspector f eedback.
technical questions are to be answered, especially if other disciplines a i nvolved.
l
---J
e QTQ-481 10/25/83 Page 3 I
Another concern related to the program is that there are no provisions for The engineering recertification of coatings application personnel.
specification and referenced industry standards do not specif recertification.
Any areas found deficient will be handled in accordance with 31, 1983.
-approved procedures.
During the investigation, two management items that are significantly affectin The These are detailed in Attachment B, Part 5.
inspectors were noted. inspectors state that they have been working six 1 They Inspectors state state they have been on this schedule since May of 1983.
There their proficiency, objectivity, al ertness, and tempers are suffering.
This item was brought to the imnediate attention of site management.
The second item is one of a perceived canpensation disparity between Ebasco a l
B&R inspectors note that all Coating QC Supervisors B&R inspection personnel.They state the client does not want B&R Coatings QC are Ebasco personnel.In addition, they state that Ebasco personnel get sick leave, Supervi sors.
They state paid holidays, per diem, and regular salary, while they do not.They state it has that this is the most significant item affecting morale.
surfaced in Coatings but is festering in other areas, including Electrical and This item was brought to the immediate attention of Mechanical disciplines.
TUGCo site and Dallas QA management.
First, some I have two additional observations which are of concern.
inspectors interviewed appear so hostile that I believe they are adversely affecting the Protective Coatings QC Group in performing its assignment.
Secondly, the refusal on the part of some inspectors to recognize Engineering decisions on technical matters, and their refusal to accept QA Management decisions such as the use of the IR in lieu of the NCR, constitutes insubordination and creates an unnanageable situation.-
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Antonio Vega AV/brd Attachment i
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ATTACHMENT A 1
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DETAILS:
In accordance with management directives, an investigation w Septenber 19, 1983 been " fired for identifying quality problems."
Prior to any discussions, Bill Dunham's personnel file was reviewed to obtain basis for further investigation.
DISCUSSION WITH W.A. DUNHAM:
Mr. Dunham was contacted and advised of the purpose of On September 20, 1983_Mr. Dunham's initial statement was that he wanted me know that he had previously reported his supervisor, Harry Williams, to the the investigation.
NRC; ard to Tom Brandt, Gordon Purdy, and Ron Tolson, for intimidating, harassing and threatening his inspectors.
certain inspectors to obtain details.
He stated that when he initially reported his concerns to Mr. Pur promised confidentiality.
He stated he Purdy was to request a transfer out of Protective Coatings therefore feels Mr. Purdy did not keep his promise -of confidentiality.
4 Mr. Dunham stated that on Tuesday (August 23,1983) he was advised that he i
26, 1983) as his day off. He came to work on l
could not have Friday (August Dunham stated Evert Friday, and at 4:00 p.m. went to Gordon Purdy's office.He stated none of these Mauser, "Curley" (Krisher) and Purdy were there.
He stated the meeting lasted persons were in his supervisory chain of command.
two minutes and that it was a " set up."
He stated that Harry Williams, his supervisor, was not present; that Williams i
He had missed that day because Williams knew that he (Dunham) was being fire further stated that he did not consider Purdy his supervisor.
l He stated that he I asked him about the meeting with the Corrosion Engineers.
I asked had raised his hand before speaking and that he had spoken the truth.He him what he had said in this me5 ting that was considered disruptive.
l He stated that he considered me an replied, "I'll tell you in court."He suggested I contact several inspectors fo adversary.
problems."
i DISCUSSIONS WITH CPSES SITE PERSONNEL:
In regard to this phase of the investigation Messrs. Evert Mauser, M.G.
"Curley" Krisher, C.T. Brandt, R.G. Tolson and the suggested QC Inspectors we i
~
In addition, Thos. Kelly, Principal Corrosion Engineer for interviewed.
EBASCO, was interviewed.
_ _ _ =... _ _ _ _. _ _. _ _, _ _... _ _ _ _ _. _, _. - _
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The substance of several key events was established as follows:
On Wednesday, August 24, 1983, a meeting was arranged between the Corrosion Engineers and the QC Inspectors for the purpose of discuss 1.
changes made to the procedures, their technical basis, and to answer any During this technical qut.stions that the QC Inspectors might have.
meeting, Mr. Dunham persisted in bringing up for discussion, non-tech In addition, Mr. Dunham was reported to have made gestures of hopelessness with his hands and ve supervisory problems.
the competence and integrity of the engineers.
Following this meeting, Curley Krisher, representing Tom Brandt at the In meeting, discussed with Mr. Dunham his behavior a 2.
Mr. Brandt adverse feelings about Mr. Dunham's conduct at the meeting.Mr. Tolso met with Mr. Tolson and Mr. Purdy.should be formally counsele Mr. Krisher Mr. Tolson directed that this be done as soon as possible.
was assigned the responsibility to prepare the counseling report, Mr. Tolson inquired as to the results of the 26, 1983, Mr. Tolson was advised that the counseling session On Friday, August Mr. Tolson advised Mr. Brandt and counseling session.
was scheduled for 4:00 p.m. that day.Mr. Purdy that their failure would render the three-day furlough ineffective.
the three-day furlough be eliminated and that Mr. Purdy limit his action Mr. Purdy acknowledged Mr. Tolson's directive to a counseling session.The counseling form was prepared on Friday, August 26, During the day on Friday, Mr. Brandt's secretary called Mr. Dunham and concurred.
to obtain his badge number, since it is required to be shown on the fonn.
1983.
Because Mr.
The counseling session took place in Mr. Purdy's office.
Purdy is the top B&R QA/QC representative on site, Mr. Purdy perso 3.
Mr. Mauser was conducts disciplinary meetings involving B&R employees.
representing Mr. Williams who had telephoned in sick with back p Mr. Krisher was representing Mr. Brandt.
Mr. Dunham handing to Mr. Dunham, a copy of the counseling report Mr. Purdy, saying either:
"(Expletive deleted) it -- you might as well walk me to the gate because I'm not going to change," or,
"(Expletive deleted) you guys -- you might as we gate.
gate." or, You might as well get my time and walk I' ve had it.
(Saying later, "No (expletive deleted) way -- this "No, damn way.
me to the gate."
ain't gonna (expletive deleted) work -- I don't have to take this shit.")
l
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Mr. Purdy made two more efforts at asking Mr. Dunham to settle dow These efforts were discuss what was perceived as an attitude problem.Mr. Purdy asked Mr. Dunham answered with similar comments by Mr. Dunham. After Mr. Dunham's response, if he was sure that "this is what you want."Mr. Purdy then entered a handwritten Mr. Purdy said, " Fine, let's go." summary of what transpired i report, a copy of which is attached as Attachment 1.
Mr. Mauser accompanied Mr. Dunham to the QC trailer t p2rsonal belongings.Mr. Krisher accompanied Mr. Dunham to the time office Mr. Dunham signed the at the QC trailer.
where Mr. Dunham's brass and badge was picked up.This temination form is temination fom, "(expletive deleted) Lie."
attached as Attachment 2.
On the basis of the above, I have concluded that Mr. Dunham w Mr. Dunham's conduct and statements at the for identifying quality problems.
counseling session, in substance, constitute a request fo termination.
. rejected by Mr. Dunham.
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BilT you have on several occasions verbally exoressed SUPERVISOR'S STATING 2:a complete lack of confidence in the project protective The most recent ind the specific incident of was recorded and Production, program.
in tne Q; of fice on Wednesday 6/24/E2, during the open information exchange between Your continued dor.ir.ance o' the meetin P.C. consultants and the Ouelity inspectors.
and/or expressing scorn of and for the program was disruptive, oy scoffing at, The described attitudo med = c+ 4 am
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counter-productive -and unproffessional.
be tolerated and any further demonstrations of this nature will result anc will not in disciplina ry action.
Yes X No Did/Ceuld this create a Po:e :ial Probic=:
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ATTACHMENT B I
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DETAILS:
1.
Technical Concerns During the course of the investigation, inspectors collectively brought i
the following technical concerns-The primer is then water cured for two Zine primer is being applied.
(2) hours, and a top coat is applied immediately thereafter.
a.
According to some inspectors, this is too soon.
The " nickel" test (where a coin is used to test the curing status of king the primer) should be used in conjunction with curing tables, taAt C b.
account for humidity and temperatures.
used exclusively to test primer curing.
The substrate profile on hangers is too slick for proper adherence c.
between it and the primer.
Instances have been identified where zine prim d.
(Design Basis Accident) tested.
Inspectors state Successive coats of zine primer are being applied.
that primer will adhere to substrate and to topcoat e.
itself.
primer thickness between successive applications.
Storage provisions, including compatibility among primer and topcoat batches manufactured during different time frames; and pot life f.
restrictions on zine primer.
Interviews with engineering personnel were conducted to assess the The results are as follows:
validity of these concerns.
In regard to water curing time of Carboline CZ-11 zinc primer, prior to topcoating, the following documents were reviewed:
a.
Gibbs & Hill Specification 2323-AS-31 Rev.1, March 15,1978, 1.
" Protective Coatings" ANSI N101.2, " Protective Coatings (Paints) for Light Water 2.
Nuclear Reactor Containment Facilities" ANSI N5.12, " Protective Coatings (Paints) for the Nuclear 3.
Industry" ANSI N101.4-1972, " Quality Assurance for Protective Coatings 4.
Applied to Nuclear Facilities" TUGCo Procedure QI-QP-11.4-5, " Inspection of Steel Substrate Primer Repair and Seal and Finish Coat Application and Repair" 5.
B&R Procedure CCP-30, " Coating Steel Substrates Inside Reactor 6.
Building and Radiation Areas."
The first four documents do not impose any QA requirements on testing for The document that addresses curing is B&R Procedure prime coat curing.
CCP-30, which is referenced by TUGCo' Inspection Procedure QI-QP-11.4-5 This procedure bears the approval signature of a TUSI Eng representative.
either curing time tables or, the following:
~,
" Carbo Zinc 11 is sufficiently cured for top coat when the coatings may be burnished rather than removed when rubbed with the flat This same portion of a smooth edged coin such as a nickel." p curing purposes may be as often as necessary to obtain proper cure.
This acceptance criteria is endorsed by the manufacturer, Carboline Company, in a Telex dated 1/23/80 which states, in part, " Carbo Zinc 4
sufficiently cured to topcoat when the film is able to burnish whenIn re scraped with a coin, rather than removed."
water spray, a Telex fran Carboline states, in part, " Force during of Carbo Zinc 11 by fine water spray or low pressure steam is acceptable prior to topcoating Carbo Zinc 11."
The documentation supports the following conclusion:
Forced water curing is an acceptable process that may be used as 1.
often as necessary to obtain proper cure.
Topcoat may be applied after proper primer coat cure has been The determination of cure can be based on curing 2.
obtained.
tables which require time, temperature and humidity measurements, j!t, physical testing of the coat for a burnish.
In regard to the use of the " nickel" test exclusively without I
concurrent use of the curing tables, item a. above adequately b.
There is adequate justification for addresses this concern.
exclusive use of the " nickel" test as a physical confinnation that proper curing has been obtained.
In regard to the concern that the profile on hangers is too slick for proper adherence between it and the primer, the following documents c.
were reviewed:
In GaH Specification 2323-AS-31. Rev.1, March 15,1978.
paragraph 4.2.a. it requires that the surface preparation of l
1 substrates conform to the applicable requirements of ANSI 101.2 and lists some exceptions.
ANSI N101.2 under Section 6.3.1, Carbon Steel, states, in part, "The surface shall be cleaned in accordance with SSPC-PS-10, 2.
' Hear White Blast Cleaning'..."
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B&R Procedure CCP-30, Rev.11, dated 8/16/83 in para 4.1, 3.
Preparation of Substrates and Coati's Materials, states, in part, "The surface shall then be cleaned by blast, hand, or 4
power tool operation to achieve a surface cleanliness equal to It further describes SSPC-SP-10 'near white' blast cleaning."
It states, what constitutes compliance vdth this requirement.
" Typically, power tooling utilizing, but not limited to, 3-M Clean-N-Strip, 80 grit er coaster Flapper Wheels or sanding discs. roto-peans, etc., may be used to achieve surface cleanliness equal to SSPC-SP-10."
TUGCo Inspection Instruction QI-QP-11.4-1, Rev.14, dated 4.
9/23/83, page 4, Section 3.2.2.c requires the inspection of anchor pattern depth at random locations using a Keane-Tator It Surface Profile Comparator, Model 373 or equivalent.
It further requries a minimum of 1.0 mils anchor pattern depth.
states, " Surfaces that have been power tooled with 3M Clean-N-Strip, 80 grit and coaster " flapper wheels," sanding discs " roto peans" or equivalent, provide accepta51e surface profile."
The above documents demonstrate that substrate profile requirenents, as specified by G&H Specification 2323-AS-31 and the referenced ANSI N101.2 document, are accurately reflected in site application In addition, DBA testing procedures and inspection procedures.
documents indicate that panels tested and primed with Carbo Zinc 11 have a surface preparation in accordance with SSPC-SP-10 with a 1 mil. (minimum) blast profile.
Accordingly, this concern is deemed to be udthout merit.
Instances have been identified (NCRs which have been dispositioned) d.
Has where zine prirer is being applied over Phenoline 305 topcoat.
In discussing this concern, Engineering this system been DBA tested?
indicates that this procedure was used on " spot" touchups only.
" Spot" or minor defects are defined as an area, either circular or linear, in which a 1/2" diameter circle could not be completely inscribed at any point along the entire length.
l A "Special Engineering Instruction" 35-1195-CEI-9, dated November 11, 1976, states, in part, " Area will be repaired with appropriate coatings, i.e., Phenoline 305 if damage does not extend to the primer; Carbo Zine 11 and Phenoline 305 if primer is damaged."
Subsequent Carboline documentation as recent as 9/30/83, reconfirms the acceptability of using Carbo Zinc 11 as a touchup of Phenoline The latest Telex states, "Should an excessive overlap exist, it 305.
Though we have no hard, fast rules can be renoved by hand sanding.
for overlap areas, a one to two inch overlap is not unrealistic."
Based on the coating manufacturer's expressed approvals of the repair process used and its application to minor repairs, the concern and stated need for DBA testing is deemed to be without merit.
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In regard to successive coats of zinc primer being applied, the t
l following documents were reviewed:
e.
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11/15/78, states, " Theoretically, carbo Carboline Telex, dated 1.
Zinc 11 may be recoated with itself an unlimited number of
.., We prefer that the original Carbo Zinc 11 prime coat times.
not be recoated with itself more than twice, and only if absolutely necessary..."
" Report on Irradiation, Decontamination and DBA Testing," dated 1
8/16/78, prepared by the Analytical Chenistry Division of Oak l
2.
l Ridge National Laboratory, tests acceptability per both ANSI The test documentation reflects that two N101.2 and N5.12.
successive coats of Carbo Zine 11 were tested under DBA conditions. Two separate samples were used. The coatings 1
remained intact without defects.
(
Accordingly, this concern was found to be without merit.
In regard to the storage concern related to compatibility of paint system component (primer and topcoat) batches manufactured during f.
He most different time periods, the engineer was interviewed.
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vigorously rejected the statement that. there was any restriction on use of component batches manufactured during different time periods.
He stated that in his experience, with three different nuclear plants and over seventeen (17) years of additional experience with these particular materials, the vendor has gone to great efforts to assure that both their customers and their inventory provides consistency j
among stock interchange.
In addition ANSI N101.2, " Protective Coatings (Paints) for Light i
i Water Nuclear Reactor Containment Facilities," supports the Engineer's position.
It states, "The coatings manufacturer shall maintain a quality assurance program and provide adequate l
documentation to show that the quality of a given coating system is j
reasonably identical to that of the coating system qualified under The coating system shall be requalified if there are this systen.
changes in formulation or manufacturing procedure which will alter l
the perfomance obtained from a previous test." Accordingly this concern is deemed to be without merit.
In regard to the storage concern related to pot life, the Engineer states pot life expiration is defined by the manufacturer as when the l
I material can no longer be applied successfully by nomal methods.
The Engineer states the actual pot life is a function of temperature, The same. applies to shelf life.
pressure, agitation, and thinning.
The Engineer states tne charts are provided as guides only.
1 In a letter dated October 27, i
The manufacturer concurs with this."The true pot life ends when the prod 1981, Carboline states:
l no longer sprayable.
In conclusion, the inspectors' concerns relevant to storage are l
without merit.
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In conclusion, technical concerns expressed by the inspectors were discussed with engineering, investigated, ard were found to be unwarranted in light of the design specification, referenced standards, manufacturer's recommendations and DBA test documentation.
Harassment, Intimidation and Threats 2.
The entire subject of " harassment, intimidation and threats" as stated by Mr. Dunham, was dicussed with site QA/QC personnel including the protective coatings inspectors.
The discussions were particularly difficult because what people perceive as being harassment, intimidation or threats varied very sienificantly In addition, the three phrases were at times used among inspectors.
interchangeably to varying degrees.
In conducting thi investigation, questions were fomulated so as to attach In the broadest interpretation to " harassment, intimidation and threats."
the investigation questions to solicit even a broad the inspectors.
The results are summarized as follows:
One recurring general ecxnplaint was voiced involving the previous Coatings QC Supervisor (Mr. Harry Williams) and one " Lead" Coatings a.
Neither person is employed at CPSES at Inspector, Mr. Bob Wallace.Several specific instances of this general com the present.
were provided.
One instance es mentioned by several inspectors where they were admonished on the subject of " nitpicking" during a meeting called by b.
Mr. Willians.
One inspector stated he had been directed to accept primer cure on the basis of a " nickel test" perfomed on material still wet from c.
He stated this had occurred 10 to 12 times during the water curing.
last 18 months that he worked for Mr. Williams.
The details of the above items are discussed below, The most prevalent complaint was that in several instances, when an inspector rejected an item, the craft foreman would go to the craft a.
general foreman, who at times would also invlove the craft They would collectively get Mr. Williams, the superintendent.
Coatings QC Supervisor, and converge at the point of inspection with Some Different inspectors viewed this differently.
the inspector.
inspectors stated they saw this as part of their job and something Others saw that is expected and experienced on any construction job.
this either as harassment, intimidation, undue pressure or coercion Only one inspector was adversely influenced on to varying degrees.
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In this instance, the inspector was inspecting the one occasion.
The inspector noted two areas of weld topcoat on the polar crane.
spatter over the topcoat that the inspector felt needed to be knocked The craft called for Mr. Williams who off prior to final acceptance.Mr. Williams agreed that one area needed to be cle was off site.
However, he disagreed that the off and retouched and this was done.This area was not cleaned off second area was weld spatter.
The area where weld remained inspector signed off the inspection.
From a was described by the inspector as "the size of a quarter."
safety standpoint, the remaining spatter bears no significance.
Mr. Harry O. Williams was contacted at his current place of Mr. Williams stated that some inspectors felt that QC employment.
was being overrun by the craft because engineering was approving He stated that some inspectors insisted on evaluating Accordingly, some cha nges.
procedures and changes, which is not their job. inspect Mr. Williams stated that if the inspector was i
their procedures.
However, if he was not correct, he would support the inspector.
correct he would not support him.
The " nitpicking" meeting resulted from an inspection of the skimmer pump room floor and the adjacent heat exchanger room floor (Elevation b.
The inspectors identified overspray, embedded 808' R.B. #1).
particles and pinholes.
The craft forenan and the general foreman contacted Bob Wallace, Coating QC Lead at that time, who called Harry Mr. Wallace, who was also a certified inspector, Mr.
Willi ams.
Williams, and later Mr. Brandt, the Coating Level III, disagreed with the validity of the overspray, and embedded particles deficiency.
Messrs. Wallace, Williams and Brandt attributed the appearance of overspray and enbedded particles to the 115 surfacer used below the However, they noted some pinholes that constituted an coati ng.
unacceptable condition which had not been identified by the inspectors even though they had spent approximately 12 manhours (2 Mr.
persons working 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) to inspect a 10 ft. x 12 f t. room.
Williams stated that on the following day he assembled the inspectors and that the rooms in question were examined physically.
Mr.
Williams stated that he and Mr. Wallace used the examples of apparent overspray and particle embedment as examples of " nitpicking," and pointed out that while doing do, some rejectable pinholes accepted.
exanine these same areas for valid rejectable conditions, such as pinholes, and if he found any, he would pull their certifications.
This is the only incident that could be construed to be a threat.
Although there appears to be some justification for the supervisory action, it would have been appropriate to have discussed theseThe matters with only the inspectors involved in the inspection.
1 manner in which this natter was handled is indicative of poor supervisory practice.
Otherwise, the incident is a moot point, in that since then the floors were sanded, recoated and reinspected.
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One inspector stated he had been directed to conduct " nickel tests" He stated that c.
on material that was still wet from water curing.
this occurred 10 to 12 times during the last 16 to 18 months that Mr.
The inspector stated that he Harry Williams was his supervisor.
initially tried to document this on the IR and by attaching a 3-part He stated Mr.
memo that stated that an item was acceptable "per HW."
j Williams would destroy the 3-part memo and bring the IR and ask that The inspector emphasized this was primer work done in it be redone.
the shop and that he could provide no specifics on the irs involved.
l Mr. Williams was questioned on this matter.
i Mr. Williams stated that on one occasion only, the craft had been l:
drying off panels used for painter certifications.He asked toe inspector Some areas were wet, but nickel tests were not run on these.Mr. Williams stated that he I
to run a nickel test on dried areas.
asked the inspector to enter his (Harry Williams') initials on the l
inspection certifications because they were only for painter certs,Mr. Willia i
not anything that would be used at the site.
j denies he ever ordered the inspector to run a " nickel test" on wet He stated that this would be a direct violation of i
material.
procedure and the test would fail. The inspector indicated there was no third party involvement. and so it is difficult to resolve i
conclusively such contradicting statements.
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BAR Procedure CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas." and TUGCo Inspection Procedure l
QI-QP-11.4-5, which address application, curing and inspection of
}
primer, do not require the primer surface to be dried after waterIn ad l
j cure prior to testing for burnish.
Coating Level III state that performing the nickel test on a surface i
The water does wet from water cure does not detract from the test.
i not prevent a horizontal force to be applied on the coating to test i
its adhesion to the substrate.
I Although this item could not be proven conclusively either way, there No further action is i
is no technical basis for safety concern.
l deemed necessary.
e In summary, the allegations of harassment, intim.idation and threats were j
thoroughly investigated.
Several conclusions can be drawn.
i Inspectors working under Mr. Willians perceived less than total 1.
I Some inspectors' stated belief that procedures support from him.
l reflect unacceptable technical practices have brought about occasional confrontations where at times QC supervision disagreed These situations had a greater morale effect with the inspector.
because a small, but very vocal and articulate group of inspectors who appear knowledgeable on the technical aspects of-protective i
coatings, have had a disproportionate amount of adverse influence within the Protective Coatings QC force.
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that constitutes a safety concern.
The inspectors spoke favorably of their present supervision.
However, there is a small number of inspectors that essentially 3
refuses to recognize and support the fact that Engineering, not QC meet design requirements a'nd what acceptance c by the inspectors.
Prevkous Management Investigations 3.
As a result of Mr. Dunham's previous discussion with QC supervision and management, two previous investigations were conducted.
This investigation One of the investigations was conducted by Mr. Brandt.Mr. Brandt interviewed was conducted during the first week in July,1983.
eleven (11) coatings inspectors, including two that Mr. Dunham stated Mr. Dunham made two allegations.
The could substantiate his allegations.
first allegation, that Mr. Williams had publicly reprimanded Mr. Dunham, was not substantiated.
The second allegation, that Mr. Williams, who was not a certified inspector, had instructed Mr. Dunham on how to perfonn a " nickel" test, No direct changes were made as a result of the was substantiated.
Mr. Brandt conducted a general meeting with Cnatings QC i nvestigation.
The inspectors raised only one personnel to discuss the NCR/IR program.Mr. Brandt also invited inspectors tc question and that was answered.come in any time to discuss any d have originated with him.
Mr. Brandt stated he and Mr. R.G. Tolson, TUGCo Site QA Supervisor, had previously tried to remove Mr. Williams from a supervisory role but were restrained by QA Management in Dallas.
Mr. R.G. Tolson, as a result of his visit with Mr. Dunham, after Mr.
Dunham's visit with Mr. Purdy, directed Mr. B.C. Scott, the Non-ASME QA Supervisor, to conduct interviews to ascertain problems and arrive at Mr. Scott interviewed Mr. W1.lliams and Mr. Dunham.
corrective actions.
The first issue was that Mr. Scott concluded there were two major issues.
Mr. Williams sided with Construction and did not provide adequate feedback The second issue was that inspectors wanted to issue NCRs l
to his people.
instead of "Unsat irs."
Mr.
Mr. Scott stated that Mr. Dunham did not have any other problens.
Dunham stated the biggest problem was with Harry and Harry's way of doing things.
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Mr. Scott was awar.e of the plans for a general meeting with inspectors to discuss the PCR/IR program and curtailed the interviews and reported his conclusions to Mr. Tolson.
Subsequently, Mr. Tolson visited informally with Mr. Dunham at a barbeque held to bring the craft and inspectors Mr Tolson stated that Mr. Dunham never mentioned closer together.
" harassment" or intimidation, but Mr. Dunham did mention that he didn't care for Mr. Williams.
Mr. Tolson stated that during the last 1-1/2 to 2 years he was under a restraint from QA Management in Dallas in regard to Mr. Williams.
Mr.
Tolson stated that at that time he wanted to reassign Mr. Williams out of a supervisory role but was restrained.
Mr. D.N. Chapman, TUGCo Manager QA was interviewed.
Mr. Chapman stated that approximately a year ago, Mr. Tolson reported to him that Mr.
Williams had shortconings as a supervisor. Mr. Chapman stated Mr. Tolson described the weaknesses as communication difficulties and a general lack of supervisory strengths. Mr. Tolson reported that he had looked into statements made at the licensing hearings regarding suppression of NCRs and that it was his conclusion that Mr. Williams was not harassing his people; that Mr. Williams was trying to do an earnest day's work as a supervisor. Mr. Chapman stated there was a general agreement between him and Mr. Tolson, that since Mr. Williams primary strengths were in civil / structural areas which were winding down, Mr. Tolson should contact Mr. Williams' enployer, DUCI, and arrange for an orderly transition to another project. Mr. Chapman stated the plan was to phase out Mr.
Williams over a period of time.
Mr. Chapman stated that Mr. Tolson subsequently advised him that he had contacted DUCI and advised them to start looking for a new assigreent for Mr. Williams.
It is the conclusion of this investigation that Mr. Brandt and Mr. Tolson conducted their own investigation to address matters as they perceived them at that time.
In addition, Mr. Chapman, similarily addressed the netter of Mr. Williams' reassignment consistent with the facts presented to him. The insistence for an orderly phasing out of a person's service, in light of decreasing activities in his primary area of expertise, is consistent with good management practice. At the time this decision was made, the present situation had not materialized, since Mr. Tolson, Scott and Brandt's investigations had not yet occurred.
4.
Procrammatic Concerns Inspectors expressed the following programmatic concerns in the area of protective coatings:
Some inspectors expressed concerns over the use of the IR UNSAT a.
instead of an NCR.
Inspectors state an IR UKSAT can be resolved without Engineering review and input.
rage oss
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This concern was investigated.
It was determined that an NCR is required when a deficiency is such that it cannot be reworked to In this bring it into compliance with Engineering requirements.
case, Engineering resolution to either use-as-is or alter the requirement, is necessary. However, if the deficient condition can be brought up to Engineeri ng requirement by rework, the use of the IR This concern UNSAT is entirely consistent with 10CFR50 Appendix B.
It should be noted that on September is deemed to be without merit.
QC management on site had a general meeting with coatings 29, 1983, There is inspectors to discuss this philosophy and answer questions.
a resistance on the part of some inspectors to accept this perfectly acceptable practice.
Some inspectors stated that the program does not define how to b.
resolve instances.Aere surface preparation hold points are not observed.
This concern was investigated. TUGCo Inspection Procedure QI-QP-11.4-1, " Inspection of Steel Substrate Surface Preparation and Primer Application," Section 3.5 states that inspections required by Section 3.1 through 3.4 shall be documented on an IR.
(Section 3.1 through 3.4 include surface preparation.)
Section 3.5 further requires that a reject tag be applied to an UNSAT area together with Section 3.7, "Nonconformances," states that the inspection report.
non-confoming conditions shall be reported on an IR in accordance with CP-Qp-18.0. Accordingly, an inspector who is asked to perfom an inspection subsequent to Item 7 (inspection of surface preparation) on the Inspection Report in Attachment 2 of the subject procedure, and notices a lack of QC signoff on the previous steps, should identify this on the IR itself. However, since there is confusion on this item, there appears to be a need for further indoctrination and training of inspectors on this subject.
Inspectors state that there is no method by which inspectors can c.
express technical concerns and have them reviewed by appropriate persons or organizations.
This iten was discussed at the several levels of QC supervision.
QC supervisors stated a willingness to accompany inspectors to visits Evidence of with Engineering or higher levels of QA/QC management.
this was seen, in particular the meeting that was set up between the i
Coatings QC Inspectors and the Corrosion Engineers.
That meeting, however, was apparently not productive in that non-technical subjects 4
were persistently brought up by Mr. Dunham for discussion.
There appears to be a need for management involvement in deciding to what extent inspectors' questions should be answered, especially if electrical, mechanical, and structural disciplines are to be handled i
accordingly. The TUGCo " hotline" might be considered as a means by which inspectors can voice their questions.
~S Inspectors state that there are no provisions for recertificatio As a result of this concern, the d.
coatings application personnel.
Engineering specification and referenced industry in accordance with the coating applicators' qualification proce reviewed.
It is Recertification, however, is not specifically required.
Construction Management's position that a recertification Construction Management states that irs are reviewed Trends are brought to not required.
on an ongoing basis ard trended by foremen.the app the perfomance of his people.
Any deficiencies observed This area will be audited by TUGCo QA.will be reporte d
procedures.
Management Items _.
5.
During the course of the investigation, several items of manage significance were voiced.
The Coatings QC Inspectors state they have been working day, six days a week for months.
a.
inside containnents, the number of inspectors h Inspectors state accordi ngly.
effect on proficiency, alertness, and objectivity.This creates a feeling that schedule pressures af fect craft tempers.
of hostility that gives rise to a feeling of harassment or intimidation.
Several Some B&R inspectors complained of a conpensation disparity.
inspectors stated that Ebasco personnel hold the QC supe b.
get sick leave, get paid holidays, per diem, and a regular s They state it is apparent that the client does not wish to hav They state they do not get sick leave, paid holidays, Some inspectors stated supervisors.
i per diem, and are paid on an hourly basis.
that the compensation discrepancy is the most significant item They state that the af fecting morale among B&R QC inspectors.
results are evident in coatings but that the sa disciplines.
Some inspectors complained that they did not have adequa They stated that it would be helpful if c.
to do their QC paperwork.
f acilities that are well-lighted and away from unnecessary interruptions, are provided to perform their paperwork.
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