ML20137J044
| ML20137J044 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/10/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17198A292 | List:
|
| References | |
| FOIA-85-59 50-445-78-07, 50-445-78-7, 50-446-78-07, 50-446-78-7, NUDOCS 8512020537 | |
| Download: ML20137J044 (10) | |
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B *4E/78-07 Appendix B.
NOTICE OF DEVIATION
&ased on the results of an NRC inspection conducted du'rtng -the, period April 11-21,1978, it appears that certain of your activities deviate mfrori..goestitments made in your Preliminary Safety Analysis Report as indicated below:
Paragraph 3.8.3.2.D states that concrete for the containment internal a.
structures will be tested (slug, air content, temperature) in accord-ance with ASPE-ACI-359.
This standard as modified by paragraph 7.3.b of Project Specification 2323-55-9, " Concrete." requires that samles of fresh concrete be tested at intervals of fifty cubic yards deposited.
Contrary to the above:
During a concrete placement involving two containment interior structures on April 11,1978, an initial test was performed but subsequent tests were not accomplished until two hundred-ninety (290) cubic yards of concrete had been deposited.
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1 U. S. NUCLEAR REGULATORY C0fF.ISS10N 0FFICE OF INSPECTION AND ENFORCEMENT REGICH IV Report No. 50-445/78-07; 50-446/78-07
. Docket No. 50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Cogany' 2001 Bryan Tower Dalles. Texas 75201 Facility Name:
Comanche Peak. Units 1 & 2, Inspection at:
Comanche. Peak Station and 2001 Bryan Tower. Dallas, Texas Inspection conducted: April 11-21, 1978 Inspectors:
'O f /d R. ~E. Taylor, Reactor Inspector Projects Section Date (Paragraphs'1. 2, 3, 6, 7. 8. g.10 & 11) 3/f0 sAe b r W. E. Foster. Contractor Inspector. Vendor Inspection Date Branch (Paragraphs 4 & 5) f L)
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JfA. Ward. Imes.tigation 5pecialist Date (Paragraph 7) other Accompesying Personnel:
E. L. Ross Co-op StvJent. Vendor Inspection Branch R. F. Naventi. NRR Project Manager
$. M. Kari. NRR. MIPC W. H. Lovelace. NRR. MIPC g/jg/7g Approved:
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aw-W. A. Crossman, Chief. Projects 5ection Dtte j
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inspec t1r<n Sumrary:
Ir.scection on April 11-21, 1978 (ReDort No. 50-445/78-07; 50 440/78-07)
Arees Inspected:
Routine, unannounced inspection of the implementstior, of 15 CFR Part 21 ~requirerents; storage of electrical coeponents; pipe f abri-cation activities; and vendor control activities.
Inv tions of improprieties in concrete testing activities,estigation of allega-and conc. rete test Also included was an announced examination of construction records.
,_,3ched.ule activities by NRR personnel.
The inspection involved one-hundred and two inspector-hours by two IE inspectors and one IE investigator.
Resvits:
Of the six areas inspected, no items of noncompliance or devia-tions were identified in five; one apparent deviation was found in one tres (failure to meet PSAR commitrants regarding frequency of testing of concrete - paragraph 8).
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DETAIL S 1.
Persons ' Contacted Principal Licensee Er ;1oyees
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- J. B. George. TUSI. project General Manager
""D.
N. Chapman. TUGCO, Quality Assurance Manager
"*R.
G. Tolson. TUGCO. Site Quality Assurance Supervisor
- "J.
V. Hawkins. TUGCO/G&H. Product Assurance
- * " D. E. Deviney. TUSI. QA Technician "J. T. Merritt. TUSI. Resident Manager
" A. Vega. TUGCO. Senior QA Engineer i
R. J. Gary. TUGCO. Executive Vice President l
R. Camp. TUGCO. Lead Startup Engineer l
E. G. Gibson. TUSI Project Engineer B. J. Murray. TUSI. Engineering Supervisor J. C. Kuykendall. TUGCO. General Superintendent 0.her Personnel "U. D. Douglas Brown & Root. Project Manager
- D. C. Frankum. Brown & Root. Assistant Project Manager Individual A. R. W. Hunt Laboratory Individual B. R. W. Hunt Laboratory M. O. Kirkland. Brown & Root. Project General Manager L. Hancock Brown & Root. Project Control Manager R. E. Walz. Gibbs & Hill. Scheduling Engineer
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The IE inspectors and invenigator also conteted and interviewed other licensee and contractor personnel.
- denotes those attendirig the exit interview on April 20, 1978.
" denotes those attending the exit interview on April 14, 1978.
- denotes those attending the exit 1.nterview-on April 21,19.8.
"" denotes those attending the exit interviews on April 20-21, 1978.
- denotes those attending the exit interviews on April 14 and 20,1978.
2.
Sito Tour The IE inspectors walked through various areas of the site to observe construction activities in progress and to inspect housekeeping and equipment storage.
No itses of noncorpliance or deviations wert identified.
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- 3. - ?!RC - Licensine Meeting The IE inspector attended meetings on April 18 and 19,1978, between representatives of the NRC and the licensee concerning the status of construction of the Comanche Peak Station. The purpose of the meetings was to obtain information to facilitate and ' support an independent staff estimate regarding the fuel load date for CPSES, IJnit No.1.
The licensee presented information regarding-status of engineering, procurement, start-
,vp planning, and a planned accelerated program to assure cornpletion of construction as scheduled.
The IstC personnel indicated that the licensee's scheduled fuel load date might well be attained if the construction acceleration is effective.
They indicated their intention to perfom another reviw in late 1978.
4.
Inspection of 10 CFR Part 21 The purpose of this area of the inspection was to ascertain that reasures had been established and implemented regarding 10 CFR Part 21.
This was accomplished by =eviewing Texas litt11 ties Generating Company Procedure entitled, " Safety-Related Defects and Noncompliance Pursuant to 10 CFR 21," dated December 20, 1977, various Brown and Root, Inc.
procedures and docenents and observation of the bulletin boards in the Administration Building and personnel entry / exit gates.
No items of noncompliance or deviations were identified.
5.
Receiot and Storace of Electrical Components The purpose of this area of the inspection was Wdetennine that hard-were had been received and stored in accordance with established speci-fications and procedures._,
This was accomplished by reviewing Gitibs;and Hill, Inc. specifications; CPSES Quality Assurance Plan and var,1ous Browh A Root, Inc. procedures and documents; and Westinghouse Nuclear Service Division (WNSD) Vol.1, dated March 1976, with attachment 205k and De Laval Procedure entitled,
" Preparation for Shipment and Reconnended Storage Procedure for Diesel /
Generator sets," dated October 24, 1977.
Further accomplishment was realized through observance of the storage of and review of the records relative to: a) containment spray pump motors; b) safety injection pump i
motors; c) diesel / generator set (engine only); d) termination rack;and ~
e) cocponent cooling water pump motor.
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3 W'ISD Vol.1. dated *1 arch 1976. witn attachment 205k recom. ends that motor winding tecperature be maintaiaed a few degrees above surrounding ll1 air tenperature as protection against condensation.
It further recocinends conthly measuring and recording of ambient air and winding temperatures.
i l The recorrendation for measuring and record 1'ng of.these temperatures had not been incorporated into Storage and Maintenance Requirements No.
33-1195-MEI-10-514. Rev. D. dated November 7.1977. for Safety Injection Ducip Motors.
i The manufacturer's procedure entitled
" Preparation for Shipment and Recossnended Storage Procedure for Diesel / Generator Sets." dated October 24, 1977, reconsnends sealing of all openings prior to shipment and during subsequent storage.
This reconsnandation had not been incorporated into Storage and Maintenance Requiresents No. 35-1195-MEI-10-511. Rev.1. dated November 4,1977. for Diesel Engine and Associated Parts. The IE inspector observed four (4) openings tn the engine-two (2) in the water cooling jacket and two (2) instrument lines.
These matters are considered unresolved items subject to further evaluation and inspection.
6.
Safety Related pipe Fabrication The IE inspector selected pipe spool AF-1-SB-08 (8Q3) as representative of a field shop fabricated spool and AF-1-SB-06-3 as representative of an off-site fabricated spool piece. The spools were fabricated to the requirements of Project Spec.ifications M-438, shop Fabrication of Piping in the Field." and M-43A. " Shop Fabrication of 71 ping 8" Nominal Diameter and Larger and Piping Material Supply Requirveents." respectively.
Both specifications reflect and. incorporate the requirements of ASME Section III to the Surser 1974 Addenda.
The pipe. spools selected will become part of the Unit No. I auxiliary feedwater system an( fall into subsection ND of the referenced code.
The IE inspector verified that all materials used met code and specification requirements, were welded by qualified welders to qualified weld procedures as determined froci certified material test reports, shop process documenta-tion and code data reports.
No items of noncompliance or deviations were identified.
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Investication of A11ecations of Concrete Test Records Falsifications An egioyee of the R. W. Hunt Comparp, the site concrete testing labora-tory, made allegations on April 14, 1978, that certain laboratory test records had been falsified. The licensee representative stated that the eriployee had initially made the allegation.to his laboratory supervisor who in turn notified the licensee.
The licensee notified the NRC project
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inspector who briefly interviewed the alleger (hereafter identified as i, F Individual A) on the afternoon of April 14, 1978.
The IE inspector r
'nssured Individual A that the NRC puld investigate his allegations and subsequently requested the licensee to take no action relative to the i
allegations until the NRC had an opportunity to investigate.
Individual A was interviewed by the NRC RIV investigator and the project inspector on three separate occasions during the period April 17-19, 1978.
The resulting allegations are surnarized as follows:
a.
Concrete test records for April 13, 1978, contained data which did not represent actual values of concrete slug measured.
Individual A stated that another laboratory employee (Individual 8) had con-sistently measured slug values in excess of the acceptance value
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but reported them to Individual A, who was acting as a data recorder, as having values that were acceptable.
Individual A stated that a Brown & Root employee (Individual E) could confim the allegation.
Individual A stated that his supervision directed him to enter the false data on the official test record and to sign the record.
b.
Individual A stated that another laboratory esployee (Individual C) had on April 11. 1978, not properly. conducted the slung tests and had also reported to Individual A, again acting as a data recorder,
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test data not representative of actual measured values.
Individual E was also to confirm this allegation.
Individual monts; i.e A stated-that laboratory tests required for small place-c.
,10 cubic yards of concrete or less, had not been actually accorplished by himself and' other eeployees of the labora-tory during the entire period of his suployment even though the records would show that,the tests had been accomplished.
d.
Individual A stated that he had been informed by yet another labora-tory employee (Individual D) that a laboratory level II tester had signed certain test reports covering tests accomplished on September 3 and 4,1977, when the level II person was not on site and could have no specific knowledge of the tests.
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5 Individual A stated that he had signed a pressure gauge calibration e.
record thet by lab:ratory procedures he was not qualified to certif.y.
f.
Individual A stated that he had on two separate occasions reported situations to his supervision tht should have resulted in issuance of Deficiency and Disposition Reports TDDR) to Brown and Root for engineering evaluation. He stated that on April 11,.1978, he had made a calculational error during slianp testing record keeping that allowed concrete in excess of specification requirements to be i
placed. This error was reported by him to his supervision who took no action to issue a DDR.
The IRC investigative team interviewed Individual E in regard to allega-tions a. and b.
Individual E stated that he could not actually see the slump seasurements made by laboratory personnel during their test work and relied completely on their verbal reports to him.
Individual E stated that he was not ware of any test not properly perfomed or re-corded.
Review of the alleged falsified test report failed to provide any meaningful inforeetion.
The investigator reviewed the personal log books of a number of laboratory personnel relative to allegation c. and could not substantiate the allega-tion even though Individual A stated that such a review would be revealing.
The investigation team interviewed a foriser laboratory foreman of testers who is currently espiered on site in another capacity by a different employer. This person stated that he had heard shop rumors of such activ-ities when he was foreman and had attempted to ascertain the validity of the rumor but had never found a tester not actually doing required test work.
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The investigativa team inte61ewed :ndividual Fregarding allegation d.
Individual D stated that he had heard the story from a former laboratory
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employee no longer ave 11abl.e for interview.
He stated that as far as he knew the September 1977 date was opt correct and that sorretime in Deceeer 1977 was when he thought the incident occurred.
The investigator obtained the daily payroll records of all laboratory personnel for the first ten days of September 1977 and all of December 1977.
The level II person was present every day in the September peMod but was absent on Deceeer 4, 5.11 and 18 through 31.
The investigator reviewed all pertinent test records for the days involved and found no records vali-dated by the level II person.
The investigative team followed up on the allegation e. with the resuit that while the allegation was substantiated, there were no safety related The pressure gauge in question was calibrated by the Brown consequences.
& Root site calibration facility on August 15, 1977, in accordance with Brown & Root procedures with Brown & Root equiprent by Brown & Root personnel.
The calibration record was a R. W. Hunt form signed by Indivi-dual A do observed the test in accordance with R. W. Hunt procedures.
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These facts ware gathered during an interview with Brown & poc:
calibration facility personnel, including the facility superviscr.l' The final allegation, f., was unsubstantiated.
Individual A had statec that on two occasions he had reported problems to his supervision.
He was uncertain as to the time frame of the first instance but was specific on the second which was relative to tests on April 11.-19.78. The inves ti-gators were provided a-Deficiency and Disposition Report dated April 12
.J978, initiated by laboratory supervision reporting the exact substance of the allegation.
The site procedural system for processing DDRs indicate the DDR was originated and subsequently logged in by the Brcwn
& Root document control desk on April 12, 1978.
No item af noncompliance or deviations were identified directly associated with the allegations.
8.
Concrete Testino Activities During the investigation of allegations as outlined in paragraph 7, the IE inspector reviewed records of slump, air content and temperature testing of fresh concrete. The " Concrete Placement Report" and the batch plant delivery tickets revealed that on April 11,1978, one thousand and sixty (1060) cubic yards of Design Mix No.133 concrete was placed in three i
separate areas, two of which were safety related. The safety related place-monts comprised a total of four hundred-seventy (470) cubic yards.
Analysis of concrete acceptance test data indicated that while all twenty-two (22) required tests had been accomplished for the entire days batching, only five (5) tests had been accomplished on concrete placed in the safety related structures.
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The two safety related conerete placements wereYor containment interior walls and slabs which are addressed in paragraph 3.8.3.2.D of the PSAR.
The referenced paragraph. indicates that containment interior concrete work will be accomplished in accordance wi.th "ASME-ACI-359." The"ASME-ACI 359" doctment referred to requires the above tests. to be conducted for every one hundred-fifty ci&ic yards of concrete placed in the containment.
Project Specification 2323-15-9 modifies the ASE-ACI requirements by stating that tests will be conducted for every fifty cubic yards.
The Concrete Plgcement Report indicates that the initial test series was conducted on the concrete being placed that day, but no other test was conducted until two hundred-ninety (290) cubic yards had been placed.
This was pointed out to be a deviation from PSAR commitments.
! Tffn addition, a Deficiency and Dispositior! Report, dated February 13, 1978, described the situation as a detected pre-existing and tontinuing probler and provided corrective action.
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teec:- Cent < t.::: u t es It was brought to the IE inspecter's attentiori' that c'.e e-:s :< :,
liceesee's quality assurance prograr involvirg vencer c: : : 3::.. : t.
appeared to be treaking cowr..
Responsitib ty for vencer crt :- e;-
cor.ponents purchasec directly by the licer:ee had beca ceiega:e: ::
the architect / engineer. Gibbs & Hill. Inc. witn licensee pa-t'c :mim The IE inspector had previously been informed d the licensee tra: t.e celegated responsibility to Gibbs & rill was being directly asse et :)
the licensee's Quality Assurance Departrent.
The inspecter seie:te:
five purchase orders to review as follows:
a.
CP-0450 with General Electric b.
CP-0613 with Westinghouse c.
ES-24 with Forney Engineering d.
CP-0074 with Gulf & Western e.
CP-0082 with CVI-Pen malt Of the five orders inspected, the inspector verified that recuirec ree-award seveys had been conducted in each instance; but in three instances, the vender had not been placed on the approved vendor list.
Each of the five pre-award surveys resulted in quality assurance c2fi-ciencies in the vendor QA program requiring correction prior to initiating asty work or manufacturing work only. These hold points appea-ed clear i-
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the liewee documentation but did not appear in the purchase occ.ments issued to the vendors. Gibb1 & Hill purchasinWditor repcrts were found in a document package indicating that each vender had not initiatec work beyond a hold point except for CVI-Pennwalt, where Gibbs & Hill waived arty further audit ori February 23, 1977.
The vendor (CVI Pennwait) provided the licensee with a list of corrective actions in a letter catec March 28,1978, resulting from the initial prw-award audit conducte: in November 1976. The licensee, without Gibbs & Mill participation, concu::et an audit on April 10-11, 1978, finding that the corrective acticns had bee-implemented except in one instance and connunicated this directly te the vendor.
Discussions with licensee personnel revealed tnat tne 1::e see intends to perform all vendor control activities except for these situa:'c s where Gibbs & Hill has not concluded a previously initiated actic.
TP.e lic.nsee was not able to identify just what orders the exceptice at '3e:
to or what the magnitude of the exception was.
S/IE Inspection Report No. 9990524/75-01
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B It was clear th t the licensee and his architect / engineer have a cer'rel understanding of each party's responsibility, but no specific unher-standing on a purchase order by purchase order basis.
The IE inspector was informed that a definitive interface agreement was being generated to specifically define respensibilities.
This matter will be considered unresolved pending revtew of such ai.
agreement and verification of program effectiveness.
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Cnresolved Itses
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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable iters. items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are dis-cussed as indicated below:
Paragraph 5: Storage of Electrical Components Paragraph 9: Vendor Control Activities 11.
Exit Interview The IE inspector met with licensee representatives (denoted in paragrach
- 1) on April 14,1978 April 20,1978, and at the conclusion of the inspection on April 21. 1978. The inspector sunmarized the purpose and scope of the inspection and the findings.
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INSPECTION & ENFORCEMENT-STATl!TICAL DATA SU'PLEMENT
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GE N E R AL, INSTRUCTIONS - eL3 cst A Must et CNicute 70 smewJYPE os iNsomeat:oh s
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-(Al ITtne Of NONCOM.LiANCE CtTE L
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.11 171 l-Paragraph 3.8.3.2.D states that concrete for.the containment ^1nternal P ', '
structures will be tested (slump, air content, tebserature).in accord-I ance with ASE-ACI-359. This standard as modified by rcragraph 7.3.b no of Project Specification 2323-S5-9, " Concrete," requires'that sacples
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of fresh concrate be tested at intervals of fifty, cubic yards deposited.
is.
Contrary to the above:
pr.
During a concrete places: ant involving two containcent interior structures l
on April ll,1978, an initial test wasi perforred but subsequent tests were not accomplished until two hundred-ninety (290) cubic yards of j,,,
concrete had.been deposited.
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INSPECTION PLAN IE Inspection Report No.
50-445/78-07; 50-446/78-07 Licensee:
Texas Utilities' Generating Company Location:
Dallas. Texas Facility:
Comanche Peak Steam Electric (CPSES) Units 1 & 2 Type of Licensee:
W. PWR, 1159 me Type of Inspection:
Routine, unannounced Dates of Inspection:
April 11-21,1978 Dates of Previous Inspection:
March 20-24,1978 Inspectors:
Taylor. Foster
- Ross' and Ward SCOPE OF INSPECTION Taylor Foster Ward 470548 (only if placement activity occurs) 510538 099014 550568 51055B 49065 361008 490658 92206B 55083 307038
- - 550858 350208**
30702 099014 927068 947028 Ms. Ross will participate as trainee and provide assistance as requested.
- Mr. Foster & Ms. Ross will participate in inspection in period April 11-14 only.
- Visit to TUSI-Dallas on or about April 21. 1978.
Ms Ross will accompany inspection /investipation week of April 17. 1978.
Mr. Ward will conduct investigation of allagations week of April 17, 1978.
[N b
O Reactor Inspector Date M[-
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U. S.
C1. EAR REGUMTORY CGetISSION 1
OFFICE OF INSPECTION AND ENFORCEMEh"I REGION IV
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-- Report No. 50-445/79-09; 50-446/79-09,
Docket No. 50-445; 50-446 Category A2 Licensee: Teams Utilities Generating Ceepany 2001 Bryan Tower Dallas, Teams 75201 1
Facility Name:
Comanche Peak, Units 1 & 2 l
Investigation at: Nnche Peak Staam Electric Station, Clan Rose, Texas Investigatica Conducted: Apri 1979, thr h May 7, 1979 Inspectors:
[/ e -
$![ 79
- 1. C. StadaA"ector Inspec' tor, Projects Section Date' V
4 6/ch
% J. I. T(p;,a, heactor Tippecto'r, Engineering Support Dat'e Secti g.
W l2/W
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- 1. G. Taylor, Resident Reactor Inspector, Projects Section Date
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W. A. Croseman, Chief, Projects Section Date S
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- 1. E. Ball, Chief. Engineering Support Section D' ate 1
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Approved:
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W."A. Crossman, Chief Projects Sectice Date S
R. E. Esti, Chief, Engineering Support Section 6 ate /
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bN 4E39 CMt
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t e
o Investiaation Samarv:
j;nvestimation During the period April 5,1979, through May 7, 1979 tRepert s:;
14-445/79-09: W ia/79-09)
Areas laspected:
Special, announced investigation concorring' al.lega tions bv f ormer 1. W. Runt employees whose stataments of inspection and testing Lnp rc-
- ' prteties appeared in the Fort Worth Star-Telegram on April 4, 5, 6 and E. M 's.
The investigation involved one hundred forty-nine inspector-hours by five NR" inspectors.
Basalts:
No items of noncompliance or deviations were identified.
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DETR00UCT10ti u
2, are t$ tits 1.andGlen Po se of bol tion (CPSES),Tasas, na wn it
..s Steam Electric Sta and erville County, ny 'is the and Gibbs Comanche Peak erating'Compaconstructor struction in SomBoot, lac., as the Gen Tamas Utilities 118vESTICATION and eer.
r
-BreArchitect/Ragin REA30It FCE and test.ing um hic of concrete inapecof R. W tion 4, 5.
on Apriltigate employees ions Star-Telegram assigned to inve i
result of allegatstated by Worth ntial former personnel were asserted to beof the Fort As a s
alleged activitie articles 1 m IV inspection aswa ssess the FACTS Ra6 e eteres.
OF a
and to related stim SUte(ARY Star-Worth entitled, "
Fort evening at with a headlineand hrticles 4, 1979, the il Ca Medaeaday, Apra the fro t page it contained regarding concreteMr. M narticle allegationsion IV s article In this s
ande with Questioned."8, allegations result of the ssion an were s
vestigatio telephone discua ticlee, the Regof a
As Peak site.
r were ermin course estwrote theDuring the and saksequ vestigation detw or are spe j
who who en individuals reportervestigatio.
ssigned to the inarticles, th n
there prieties that war identi fifto in wed improprieties a
taspectors vie and te ting improand testing news of the IE s
re iew alleges that ag!
v inspectionin pection night shif s
alleged loyee Manage wa:
during the QA er R. W. Hunt empby the/
as follo i
and the forsman
/A form was toldafter he had comp allege tha 1
Ibyhimhe shelv that ployees the 7 him to doer 1. W. Bunt emsitting unuse a
down Two form the king appear d to be M lab, involved puttingresistance e
2 oc to was with wasd unsprung; t long-teraallegers by theRe trap rem ine
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i 3.
Several QC inspectors (unidentified) allege that shortcuts were taken on tests intelving stains of the aggregate and its moisture content. A g-g 4.
An umident.ified source alleges that truck drive'rw added excess water to the concrete in treasit.from the. batch plant. $(,-) q F.'
& fosser 1. V. Buat employee allages that (sometime between August 1976 and March 1977) he " flanked" same concreta for the Turbine Generator Building, but the concrete was placed anyway.
Other inspectors allege that Brown and i
Root construction employees made it difficult to do the concrete tests and somettans small pours were complated before the QC inspectors arrived to do the testa. AC 'LO 6.
Three different perseas (antidentified) allege that, during the placement g,. (,
of 6,600 cubic yards of concrete for the Unit 1 Containment Building foundation en February 21, 1976, some concreta was placed without testing.
7.
A former R. W. hast empisyee alleges that, during a placement in s.d-1977 in the conta1 assent unll, he failed a truck load of concrete with a slump 3
of 4-1/4" (4" maziam specified) and that the general foreman directed the lab technician to record a value of 4" on the cards. Ac * )
W Q.
We former 1. W. Bunt employees allege that concrete cylinder compression strength test results were falsified at the direction of the general g.1 i
faremma and laboratory manager.
9.
Sourtas (uniden.ified) have alleged that tests on concrete cylinder compres-sion tests were run purposely faster than altteed by MRC Regulations /NRC saacetamad senadards (BC Regulations or Standards act defined). 8QC-6 10.
he former R. v. Daat employees allege the recertification of inspectors (af tar the BC investigation of March,1977) was done "open book" with ensuere gives.
CWCLDSI WS 1.
A11asation so. I he stataamat by individual "A"1/ that aggregate tests were falsified by him and his forsana cannot be refuted. A review of the aggregate prequali-h.)
ficacian tests and of ta-process cancrete testing results indicates that the alleged testing impropriety would not have impacted on the quality of the cancreta.
(see Details, paragraph 2.s) 1/ Alphabetical identifications are used to protect the identity of allegers and others involved in the investigatiaa.
n.- - -.
.----.,.r.
n,.
2.
A11eastice No. 2 Based on the results of this investigativa effort, the allegation tha t the equipment used to run certai.n tests on aggregate had not been used cannot be substantiated.
(see Details, paragraph 2.B).
3,-
A11emation No. 3 j
although the allegaties can neither be substantiated nor refuted as with Allegation 1, the tests in question were of a monitoring nature and not estarial acceptance testa.
(see Details, paragraph 2.c) 4 A11eastion No. 4 This matter was the subject of an II citation as identified in II Inspection i
Report No. 50-445/75-10; 50-446/75-10, dated Auguat 7, 1975.
The allegation, 1
relative to safety related structure (s), cannot be substantiated.
(see Details, paragraph 2.d) 5.
Allenstion No. 5 This allagstion was saither substantiated nor refuted.
Although the falst-fication of test records on the part of individual "C" may have occurred, no tapact on the safety of the structures can be identified.
(see Details,
paragraph 2.e) 6.
Allenation No. 6 i
This allegation was refuted.
The base mat concrete placement was properly batched and adequataly tested.
Inspectice of the base mat was included in k,
@. C(.
f IE Inspection Reports No. 50-445/76-04; 50-446/76-04, dated April 20, 1976, and 50-445/76-06; 50-446/76-06, dated June 25, 1976.
(see Details, para-graph 2.f) 7.
Allenstion No. 7 There is no evidence that an improper inspection slump test occurred.
It is evident that a 1/4" discrepancy in a slump measurement would not impact on the quality of the concrete and is within acceptance tolerance.
(see Details, paragraph 2 3) 8.
Allenstion No. 8
- q The allegation by individuals "A" and "K" that concrete cylinder con:pression strength test results were falsified cannot be substantiated.
(see Details, paragraph 2.h) 9.
A11eastion No. 9 During interviews with individuals "F" and "M " the II inspectors were informed that the alleged " fast loading" during concrete cylinder cos:-
pression strength testing was observed being done in April 1976 and tha:
~5-
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_ _ _ _ - - ~,. _, - - - - - - - - - - -
corrective action was initiated by the R. W. Hunt labora t ory marage r.
It was determined that alleged " fast loading" was identified by a Bl.R QA inspector on January 24, 1977, and that corrective action was imple-meated.
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N results of the investigation indicate that no detrimental eff ects to safety related concrete resulted,and that the alleged improprieties were corrected in accordance with the QA/QC program requirements.
(see Details, paragraph 2.1) 10.
Allenation No. 10 h matter of qualification and certification of the R. W. Hunt Level I inspectors was a subjeet reviewed in detail during a March 1977 IE inves-
- tigation, h details regarding the resulting II noncompliance citation and subsequent licensee corrective actica are contained in the IE Inves-tagaties Report No. 50-445/77-02; 50-446/77-02, dated March 23, 1977, and related licensee correspondence, dated April 25, 1977.
N IE inspectors cannot verify the validity of the stated allegation regarding the racertification of inspectors af ter March 1977 beyond the oral statements given.
(see Details, paragraph 2.j) p j
i i
1 l
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DETAILS 1.
Perseas Contacted
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Princisal Licensee Employees
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B. R. Clements Vice President
- 1. G. Telsea, Site S Supervisor J. V. Esukins, Product Assurance @ Supervisor R. V. Fleck, startup @ Supervisor Ferner R. W. Bust Employees and one B&R Employee Individuals "A" through "0" i
2.
Investination - April 5. 1979. Throuah May 7. 1979 l
Q'3 a.
A11eastian No. 1
!adividual "A" alleges that aggregate tests were falsified in January 1976 by himself and his foreman.
Interview with Individual "A"
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Individual "A" states that while he was worH== tha =*cond shift he was i
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as to lat" the aggregate sEsrsion teatr. to eliminate the
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-1 tima cemaming ov-p.-
7 Interviews with libd1Mduals "B. " "E. " "C. " "I," "I,"
"J," "E, " "L,"
"N." and "0F These individuals azpressed no knowledge of the allegation.
Istarview with Individual "C"
Indivianal "C" expressed hearsay knowledge only.
He stated that he did not work in the aggregate laboratory.
Interview with ladividual "D"
ladividual "D" stated that he did not work in the aggregate laboratory and that he had never seen anyone falsify anything during employement
' with R. W. Bunt.
Interview with ladividual "F" Individual "F" stated that on occasion, during the evening shift, l
he saw procedural shortcuts being taken.
He reported the matter to 1.
the laboratory supervisor who subsequently took corrective action.
This action was to transfer the testing personnel involved to the day shift for closer s e rvision.
Interview with Individual "M" ladividual "M" stated that hm and individual "F" were transfered to i
the might shif t La April 1976, as a result of improper testing on the part of the individuals who proceeded then on that shift. Be further stated that it took them approximately twelve. hours to complete the values of testing which their predecessors completed la might hours.
En also stated that he was aware that the previous might crews would "geef-off a-let" and " play with homenade blow dart guns."
Investimation' Effort A review was conducted of independent testing results performed by Temas ladestries, the aggregate supplier, on aggregate supplied to the site between Jemmary and May 1976.
The Texas Industries Quality Centrol Department, North Central Texas Region, Bulk Materials laspection Reports for the following anterials were reviewed:
Material Source Tons 3/4" to No. 4 (4.75mmi)
Cleburne 36.5000 sieve gravel 3/4" to No. 4 h e lle 24,000 stave crushed stama
-l 1-1/2" to 3/4" Boonsville 24,000 crushed stane Maximum No. 4 sieve sand Claburne 40,000 The results of the above tests were reported as complying to the following specification requirements:
AS1M C136-76; Test for Steve or Screen Analysis of Fine and Cearse Aggregatas AS1M C142-71; Clay Luoys and Friable Particles In Aggregatas AS1M C117-76; Materials Finer Than No. 200 (75-um) Sieve in Minarsi Aggregates by Washing AS1M C127-77; Specific Grayity and Absorption of Coerse degregata
-s-5
l ASM C123-77; specific Gravity and Absorption of Fine Aggregate ASM C29-76; Unit Weight of Agghegate * -
ASM C40-73; Organic Impurities in Sands for Concrete The testing performed by Texas ladustries uns conducted for the purpose et material pregualification, whereas, the tests done by R. V. kat 4
dertag the might shift served to monitor the material for any deviation from the specificatica and to assure uniferaity. The qualification of the material was a shared responsibility between Texas Industries and i
L U. h at.
A semple would be takan from a stockpile and equally divided between the two campanies for independent evaluation. Material acceptance testing determiand the suitability of the aggregates and not the daily uniformity. The specific daily uniformity checks which are the embetance of the allegation are the moisture content and gradation l
de*===8==tions.
These checks served to assure uniformity of concrete batches and to infase the batch plant of any adjustaants which would be
- y la order to take into account moisture content variacions.
Fail m e to identify any substantial variation in material grading or asistare cantant, as a result of a failure to perfore the checks, would result la a variable workability which would be identified in the field test for Simp of Fortland Cement Concrete; ASM C143-74 A review of asaceaforenace reports 1assed during January and February 1976 did not disclose any asaceafornias slump gast results which would indicate non-unifees aggregate.
II Inspection Report No. 75-13 identiftad a recurring problan with aggre-gate gradation castrel during the period Juas 9,1975, through November 18, 1975. During this thee, twenty-five Deficiency and Disposition Reports (ms) were writtgi against aggregate which failad the gradation tests.
The Fort Berth Star-talegren articia dated dpril 4,1979, states that, "saan tests as the aand and gravel... continually failed to meet stand-ards... despite Breum & Root efforts to prod tant into correcting the difficulty." This stacament does not accurately represent the responsi-bilities shared between the two campanies.
It uns R. V. Sant's duty te merely test material and report the results.
Brown & goo was in charge of all other facets such as procurenest and corrective action.
The aswepaper articia also quotes from the It inspection report relative to the failure of the disposition of the DCta to address and provide assurance that the previously placed containment foundation base mat concrete uma of a unifera quality. This oversight on the part of Brown & Root uns the subject of an itan of noncompliance.
In response to the citatian, 10000 conducted a detailed review of the approximately 6,000 cubic yard placement ta esder to verify the uniformity of the cancrete. It uma determined that prior to the placeaant, thi materials.
h
which did not meet specification were either rejected or returned to the supplier where they were reproe,essed, rewashed and ratested prior to being returned to the site.
The aswspaper article states in reference to the response "In a January 15, 1976, latter to the MC, TUGCC said 'that the ' problems had been corrected." It should be peinted out that the " problems" were not with the quality of the aggregate er comernte, but r&ther with the failure of the established aesimistrative controls for Deficiency and Disposition geports to provide asasures for prompt corrective action to preclude repetition.
A subsequent NBC inspection Baport No. 76-03, involved a review of the measures for corrective action and found a substantial improvement in the rimaHaams of reporting 'and closecut of Deficiency and Disposition The taspection also involved review of compressive strength Reports.
tests for concrete placed during the period when out-of-specification The concrete strength test results aggregate gradation was identified.
An addi-were feed to be substantially above the required strength.
tianal terrective step which was laplemented tavolved improving the headling and landing procedures at the aggregate supplier's f acility.
.Conclusians The statensat by Individual "A" that aggregate tests were f alsified by klat and his "foremma" cannot he refuted.
It was determined through dimenssians with licensee representatives that the supposed "forensn" l
uns not, in fact, in any managemenat position, but rather a Level II inspector who uns in sharge of thn work.heessful efforts were made to locate and aantact the Laval II laspector during this investi-j garian.
During the interview with the allager, he stated that the " dry-labbing"
~
I Ihrough acaerred for the first three to four sqaks of his employment.
echer interviews, it was disclosed that this might shift crew had a reputation of lasity which soma falt aff acted the quality of the testing.
Corrective actica uma taken by L W. Bent to raschedule these night shif t i
.The debises testing was conducted in conjunction with other esplayees.
tests performed by ogpliers en the sm EPterialt which Served as pre-A review sf the aggregate prequalification tests geslifiestian tests.
and af in-process sancrete testing 1results gives confidence in the quality of the concreta auch that anty falsification of test results on impact the part of the allager womid not hs.ve had a significant adverse
.as the quality of the senerste.
4 b.
h =ti== Wo. 2 Individual "B" allages that the equipmunt used to test aggregatas was sarked by him and "A" with was and the equipaunt uns not used during three asachs in early 1976. The' test refarred to in the newspaper articia involved putting the aggregate in a sulfuric acid solution to Ref erence tast its leag-tets resistence to breaking down and cracking.
1 was also made to the test " stinking-up" the laboratory.
From this de-scription, it was assumed that the test referred to was the Test for potential Reactivity of Aggresstes (Chemical Method), Asm C289-71 1
(1976), but from the laterviews it has becoma evident that the test i
alluded to in the allegation could only have beein the test for Light-weight pieces in Aggregate ASM C123-69 (1975).
n.-
Findians Interview with ladividual "A" Individual "A" stated that the person la charge of the chemistry lab rarely did his work and that he was of the opinion that this person was falsifying test results.
He also stated that the equipment whieb was marhad with was was kept in a storage room.
Individual "A" was unable to identify the equipment involved from photographs of all possible equipment tavolved La the various tests which were shown to his by the IE inspectors.
Interview with ladividual "B" The interviewee stated that equipment used to perf orm the Test for So mdassa of Aggregates by Use of Sodium Sulfate. ASM C88-76, was mased for several anoths.
Be remembered the had odor ande by the test.
Be stated that he asked the chemist about not r - ing the test and was told that he didn't of ten run the test because the results always ese est the same.
Es stated that the particular tast gave off a bad ador which anda the test myopy&ar.
Zaterviews with Individual "C". "G." "E." "1." "J." "E," "L,"
and "F' Thess individuals expressed no knowledge of the allegation.
Interview with ladividual "D" i
Individual "D" believes that the alleger uns only trying to make trouble for R. W. Bust staca he heard the allager remark that he would l
"get this company ame usy or the other." Individual "D" did not sub-i stantista the specific allegation.
l Interview with ladividual "E" Individual "E" doesn't know of the stated aggregate test.
He could saly aliada to the organic impurities test which he believes was esaducted properly.
M. -
i l'aterview with Individual "T" ladividual "F" was in charge of the -test for potential reactivity of aggregates.
Se stated that this test was 'the subject of considerable technical discussion due to the different techniques used by many laboratories. Es further stated that the test was subsequently elim-
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insted due to the recommendations of Erlin Rime Associates.
Interview with Individus1 "N" ladividual "M" was of the opinion that the only test that smened excessively was the Test for Lightweight Pieces in Aggregates, Asm C123-49 (1975).
Be further stated that if this were the test alluded to, than he uns of the opinion that the anegation could be true considering the persons in charge of it at the time.
Interview with Individual "W" Individesi "N" stated that the test described in the newspaper articia was the test for Potential Reactivity of Aggresstes (Chemical Nethed), ASTN C289-71 (1976).
Be based this on the fact that this test involved putting the aggregate in a sulfuric acid solution.
He further stated that this test was performed at the Chicago of fice of R. W. Bast until the s e r of 1976.
It was individual "N's" opinion that the test which easMM ;g the lab was the Test fer Lightweight Pieces f a Aggregate, ASM C123-69. (1975). When questioned about the Test for Soundaeas of Aggregates by Use of Sodium Sulfate, ASIM
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CSS-76, he stated thtt this test did noNu at an.
Investinaties Effort The II inspectors conducted the interviews with perscnaal in an ef fort to clarify the allegaties with respect to the test involved.
A tour of R. W. Eat laboratory was aise conducted in order to view the equip-ammt and discuss its usage with the cognizant licasse representative.
The newspaper articia described the test which used the equipment that was marked with una as a test which "stuak-up" the lab and it involved patting the aggregate in a sulfuric acid solution to test its long-tens resistaace to breaking down and cracking.
The test involving selfwie acid was identified as the test f or Potential Esectivitiy of Aggregates (Chemical Method), ASTM C289-71 (1976). A study conducted by the licensee's quality assurance staff of potential reactivity test reports generated by the R. W. Hunt was addressed la the Buelaar Regulatory Commission laspection Reports No.
78-09 and 78-U.
The study was conducted as a result of a comment ande by a laboratory employee that he was not surprised that a failing
- i
{l test was the first one to appear in three years since he felt tha t the person in charge of the test had been f alsif ying the results.
The NRC inspectors determined that the cause of the test failures was the result of a continuing irregular weight loss as a twoul; of heating the platinua dishes used in the dissolved silica portion of the test.
An independent Savestigation performed by Erlia Eine Associata.s subsequently determined
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that the aggregates in question were acceptable for use.
Individual "B" stated that the equipment used to perform the sodium sulfate test of aggregate was unused for several months.
This test determines the resistance of aggregates to disintegration by, saturated solutions of sodium sulf ate which do not cause a bad odor to be given off when the test is run.
It can, therefore, only be assumed that the allager was mistakes in addressing the test f or soundness in sodium sulfate.
the test for Organic Impurities in sands for Concrete AS'Di C40-73, uses a reference standmed color solution made out of potassium dichro-mate and sulfuric acid. The solution does not come fato contact with the aggregate and is kept in a closed container.
h oe facts exclude the possibility of this test as being the one in question.
The test which was determined to have the potential to smell excessively or "stisk.g" the lab is the test for Lightweight Pieces in Aggregate.
A31M C123-49 (1975). This test uses a mixture of carbon tetracholoride and 1,1, 2, 2 - tetrabramoothans ykich are highly toxic, both by absorp-tism through the skin and inhalation.
Note No. 1 of the Astm standard is a cautionary statannat which states tht these chemicals should be used sely la a hood.
During a tour of the lab, the IE inspectors viewed
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the hoed and discussed its usage with the chemist who acknowledged com-pliance with the cauttanary statement.
C4peclas_ies Based as these findings and as the fact that the test for potential reactivity was conducted in the Chicago office of E. W. Eust prior to Jaly 1976, which is one esoth af ter the alleging individual "B" was dismissed, the allegation with respect to the potential reactivity test cannot be substantiated.
p c.
Allenation no. 3 s
According to the Fort Worth Star-Telegram article, several unidentified
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quality control inspectors allege that shortcuts were taken on tests involving sising of the aggregate and its moisture content.
-1}-
1
h laterview with ladividual "A"
Xadividual "A" effirmed.the allegation, however[ he could not address
.,e.1fie usatifyias re rds.
n.-
laterviews with ladividuals '"B. " "F " "G," "E." "I. " "K." "L."
"R." and "F" These 1adividuals empressed me knowledge about & allegation.
Interview with ladividual "C"
!adividual "C" aapressed hearsay knavledge only.
Interview with ladividual "D"
Eadividual "D" empressed me knowledge of the allegation. Be went on to state that he seald met understand why anyone would falsify a grada-tien er a asistare test seasidering the simplicity of the tests.
Estarview with Individosi "3"
!adividual "E" hase mething of the allegation but he suggested that seas sentesten en the part of the teaters was due to the fact that i
udben as aggregate test failed, the stockpils would be reblended and the test stat agata. -es stated that thia =ues in accordance with the spesificatism although it weald appear to be a shortcut to an unaware P
perses.
Interview with Individual '11" -
1adiviemal 'W" stated that he was suare of ame procedural shortcut taken i
Sa the remessi of amtstare. Es stated that he performed the test using a het plata to remove the esisture from the aggregata as opposed to using the time-eemsuming even mathed as regaired by the R. W. Eust procedure.
1 Se further stated that the level 11 inspector in charge of the aggregate i
testing (the mens Imvel 11 taspector identified ta Allegation No.1 and the "istaar iallsw employes" referred to la paragraph 6 of the Nuciasr Segalatory Casalissian Raspection Report Es. 78-09) had warned his not to get amusht estas the het plata. Se also stated that this Level II inspector would essasianally adjust test results if they were borderline
)
fa h.
l Investiasties Effort Amfttaa 1 and 3 were treated.as beias essentially the sees due to the lack of a defiattive time ireas.
The reierence to the Level II taspector has been the subject of previous NRC inspections (78-09 and 78-11). Aasrissa Estianal Standard ANSI N45.2.6-1973, " Qualifications.
A
of laspecties, Eneminaties, and Testing Personnel for the Construction phase of Ihnelear power plaats," establishes minious levels of capabil-I ity for pre, ject factions. A qualified Inval 1 inspector is authorized to taplement specific taspection and test procedures while the reporting of the taspection and test results any only be acc~omplished by a level II inspector.
CoatluS1GRS Although the allegaties caemot be refuted, it appears, as with Allegation mm.1, that the tests ta questies were of a monitoring nature and not estarial acceptaase tests. The matter is deemed not to have an impact en the qualitJ et the sencreta.
The one precedural shortcut which could be identified involved the use of a het plate as appened to the even required by ASM C136-76, " Sieve er screen Analyets of Fins and Cearse Aggregates." This standard requires drytag of the semple la en even to a coastaat weight at a temperaenre of 230*F. Through conversations with cognisant TUGC0 per-esmal, it uns lasraad that tests for information purposes only wars also re se the anterial. These tests served as a preliminary indicator et asterial geslity and employed the hot plate as a means of expediting the results.
The anterial acceptance tests would be subsequently run la ceafeemense with the ABM standard.
Considering that the important pe&at in the drytag of the asterial was the requirement for constant weight, it is alikely that the age of the het plate would give signi-flamatly difforent results had the even heem used. This philosophy was taserpeasted la the engineertas approvaPts the request for use of the het plate en tests for informaties.
As a result of this approval, the e
alleged ehertant uns en.,z.ted 1ste the L V. Bat tese for inf or-astia.
It is act considered detrt===rm1 to obtaisias test results for tafernstian peepeces. As with A11agatica No.1, ao impact as the quality si the esserete can hs identified.-
i d.
A11assgies Ee. 4 Sewcas allege that despite earlier company assurances to the IIRC, j
truck drivers added emeess water to the concrete in transit from the i
batch plant to the peer site.
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M satar,1 e with zadt,$d-i "A." "F." "E. " and 'h"
' These ladividsals empressed hearsay kaawledge saly.
i Inte:Wees with ladividuals "B." "G." "I." and "It" These ladividaals empressed no knowledge of the allegation.
l I l l
1
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a Interview with ladividual "C" ladividual "C" stated that he new trsch drivers add water at the point of placement.
Be further stated that the'pIscenes s favolved a Unit 1
==at====t interior pedestal placement, a Unit 2 containment well plaeament, and a placement is the Unit 2 Turbine-Generator Building.
1starview with Individual "D"
!adividual "D" stated that the truck drivers did not care what the slump uma and, therefore, he saw no reason for them to add unter.
Be also stated that they would alunys clean their trucks out immediately af ter they would he emptied so that no residue would be lef c.
Interview with ladividual "E" Radividual "E" aapressed no specific latowledge of the allegation but he did state that he doubted the accuracy and intent of the allegers because if the allagstian unre true, anly the truck driver would be aware since it suppeeedly escurred la transit.
t M w$th ledividual "E" Individual 'T' called the allegatieup " pure acasense." Be stated that the trucks were chechad for simp at the point of placement.
laterview with ladividual "J" Individual "J" stated that he could sat understand how they could do it or uhy they would unat te.
Interview with ladividaal "L" Individual "L" stated that he had heard of ase lastance ubers a driver uns sought adding unter to his miser at the point of placement.
Be stated that the truck uns rejected and the driver dismissed.
Estarview with ladividual "0" Zadividual "O" stated that the addition of unter to the sizers by the drivers was samouhat of a standard praedere for the "401 mix."
Be 1
said they did it to unah est the minars.
1svestiastise Sifort the EE Inspection Esport No. 75-10, dated assust 7,1975, cited sia Imada af treasit sia samerate for the Unit 1 hase est that had unter added to them withmet approved supervision and signature of the testint i
l 1
i laboratory representative.
The corrective steps which were takan to avoid further moscampliance included; a concrete placement trainint course for construction personnel utiich asPhasised the necessity for a test lab representative to verify all batch tickets, assignment of additional tear lab persomaal en large placements to ensure that water would met be taproperly added, and taitiation of first line inspection of concrete truck dischstges by Brown & Root Civil Engineering to ensure esaferusase with specificattaa and procedure requirements. Subsequent l
to the taitiaties of these corrective steps, two additional instances l
uhare unter uns added were identified and documented in two Deficiency and Dispositian Reports.
The first Lastance involved the addition of ten gallons and the second, eight gallmas.
The provisions of the batch plaat procedure required that the water usage aster be set back to aero for each load.
The batch plant tickets include a provision for additional water which is called " water temper."
Ceasequently, any water added subsequent to batching is indicated on the usage aster.
Coatlusione As a result of the corrective action taitiated in response to the II citaties (Bayert No. 75-10) and is consideration of the requirement for serstag of the unter meter and the provision for additional water temper, the ellagatism sammet be substantiated.
This conclusion is also based e.a tL: interviews with persenaal sad as the lack of specific information as the part of the allegers. The refer e to the "401 mix" was act seasidered to be relevant to the quest 16a of safety because it was deter-anmad that this mis uma saly used for tilt-g wall construction for the
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administration and unrehouse buildings, which are not safety related.
a.
m-ties me. 5 Individual "F' allages that he "fiskad" a land (one truck) of hoacrate for a slab in the Ttsrbine-Gemarator Building, but that it was still placed.
IAR$$EEf.
Interviews with Individuals "F." "C. " "E. " "I " "E. " "L." "M. "
and "Ir' These individuals expressed no kasvledge concerning the allegation.
Interviews with ladividuals "A" and "B"
!adividuals "A" and "B" expressed hearsay knowledse only.
$sterviewwithIndividual"C" Individual "C" claims that, "this sett of thing happended on a retular basis." Be alluded to a placement in the haectar Building durint which he vitasseed escaral mauccessful attempts by his co-worker (there were two inspectors at each test station) to rue en air contet test.
Ac-
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sording to "C." his fa11=e employee was incogetaat.
Be also made reierence to a placement la the asiatemance building whorein he rejecteo two trucks ier bevias enceeded the time in transit limit. Eis concern was that the trucha were already is the process of discharging when he arrived at the placement.
ladividual "C" also stated that he had falsi-fied same test reem1ts sa a ten cubic yard placement ta the cooling water intaba structare (a asa-safety related structure). Be said that l
while the first air eestant and simp tests were performed and found to be acceptable, the sessed est of tests were set performed.
"C" also stated that during a three ambic yard placement of patch concrete in the yuel Baadling w1 Mag, he falsified the test records for the air eentent, slap and temperature determinations.
He also claimed to have knowladge of falsified records for a placesset in a west wall of the Turbine-Generater Buildias.
Interview with ladividual "D" Individsal "D" had me kneuledge of the allegaties but he did relate to airemetaaees surrounding the placenent is the maintemance. building ubish uma referred to by ladividual "C."
to stated that there was some j
esaarete left ever from a esfety related plasement and that it was sent
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to the maintenance be11 dias ubish is a heafety related structure.
Be alas stated that eben "C" arrived only shout three cubic yards had been poured out. The rest of the eenerata une rejected and never placed i
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=e.edag t. "o.-
1sterview with ladivideal "I" Individual "I" ctated that ha how methias of the allegation, but that he een1d set understand it since the inspectors all had the authority I
to step any placement.
1 Interview with Individeal "0" ladividual "0" stated that the placement involved was a small, approxi-notely tem subic yard, elab La the Turbine-Generator Building (non-safety related). Be alae stated that appromiantely three quarters of the load had been placed by the time he get there.
i Investiasties Effert i
We direct investigative effort-eas made to address the allegation due to the ase-enfety related eategory of the Turbine-Generator Building.
The statements made by "C" sencerning the Reactor Building, the cooling 1
e
water intaka structure, and the Fuel Bandling Building were inspe::ed in an effort to assess their veracity and impact on safety.
Tne qualifiestions of the co-worker referred to by "C" were reviewed and found to be in order.
The statement by "Ct' that he had f alsified the second set of test results for a placement in tfie cooling water intake structure cannot be refuted.
The same is true for his statement con-
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carning the Fuel Bandling Building.
Conclusions Although the f alsification of test records en the part of individual "C" any have occurred, no impact on the saf ety of the structures can be identified.
Ihis determination is based on the minuscule amount of concrete involved and on the following facts: the strength of the concrete in the Intake Structure was determined by concrete cylinder compression strength testing to meet specifications; the field tests for slump and air content met specification; the uniformity of batching assures similarity of properties;'end the patch job in the Fuel Bandling Building ref erred to by individua'l "C" above was not of a structural nature but rather f4114=-
of a void.
The placements in the Turbine-Generator Building and the Maintenance Building are not safety related and as such do not impact on the safety of the plant.
f.
Allenstion No. 6 According to the Fort Worth Star-Telegram article, three dif f erent un-identified persons allege that during the Unit 1 Containment Buildina base mat placement on February 21.1976p.'.'some concrete was placed without testing."
Findinas Interview with Individual "A" Individual "A" stated he had heard hearsay about a void in the contain-ment base mat.
_ Interview with individual "B" Individual "B" was of the opinion that the Unit 1 base mat was placed so f ast that all of the required concrete tests were not performed.
Be could not identify nor substantiate the omission of specific tests.
Interview with Individual "C" Individual "C" stated that he heard rumors about the lack of testing during this placement but that he was not employed by R. W. Hunt at the time of the placement.
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Interview with Individual "D" ladividual "D" stated that he was not. aware of any test omissions.
Be also stated that R. W. Bunt had recruited.and certified inspectors from Mason-Johnston Associates and from Brown & Root prior to the base est placement in anticipation of the need for a sufficient number of testias personnel to cover the three.12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shif ts which were required for the placement.
Interviews with Individuals "E." "1." "J." "K." and "L" These individuals stated that the placement in point occurred prior to their employement with 1. W. Eust.
Interview with Individual "F" ladividual "F" stated that he was aware of hearsay about the placement hains too fast; but that he had no knowledge of any tests being omitted.
Interviews with Individuals "G." "E." "M." "N." and "O" These individuals stated that they had no knowledge of the allegation.
Investination Effort I
A review was conducted of batch tickets and test records f or the subject placessat. It uma determined that 6,600 cubic yards of concrete were placed using two design sizas. The rev&sno.of the batch tickets assured the uniformity of batching e ita the review of the cog ressive strength test results gave confideoca in the integrity of the base mat.
The i
specification la facce at the time, along with the draf t version of l
ACI 359, required that. slump.-air content, temperature and cylinders be taken every one-bedred yards. This upuid require a set of sixty-six i
test resulta.
Sixty-seven QC test records were identified and, in all cases, the results were found to antisfy the specification requirements.
i Conclusions 1
The base syst concrete placement was adequately, tested and properly hatched.I' The allagstion uns refuted.
g.
A11eastion No. 7_
Individus1 "E" alleges that during a placement of concrete in the Omit Bo. 1 contaimment wall in mid-1977, he failed a load of concrete with a simp of 4-1/4" ineham (4 inches anzia m specified) and that a foremas directed a lab technician to record a value of 4 inches on the card.
J/IE laspecdos Aaports No. 50-445/76-04; 50-446/76-04, dated April 20, 1976, and 50-445/76-06; 50-446/76-06, dated June 25, 1976..
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Findians Interviews with Individuals "A." "B." "C." "E," "C," "J," "L,"
"M." and "0"
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These individualis aupress'ad no knowledge of the allegation.
d Interview with ladividual "D Individual "D" stated that during this placement, there were three pump stations and sia concrete taspectors involved. Be said that the slump averaging asthed of Gibbs & Sill Specification SS-9 uns being used and
)
that this mothed allowed them ta go to a 5 inch slump if allowed by the eler maatter's calculation of the running average cf ten results. Be l
feels that the allager was act amare or capable of tse calculation in-volved. Be also said that the specification calls for the. recording of data to the amarest quarter inch which he feels also contributed to "K's" confusion. As for the statement that he directed a lab technician to record a vales of four inches, he emphatically denied it.
Interview with ladividual "F" Individual "F" stated that there uns a strong dislika betven the two tadividuals involved ("D" & "E").
Istarview with Individual "E" Individus1 "E" ans of-the opinion that "RLuas not aware of the slump averaging process.
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ja gryjew with ladividual "1"
!adividual "1" stated that "E" was'esually la ths lab and that if he us in the fiald during that piammmaar it was because of a shortage of in-spectors. Because of this, he thiaka "E" was not very knowledgeable h et simp averasias.
Interview witb !adividual "E" l
!adividaal "E" suced that he was misquoted in the Fort Worth Star-i Telegram articia with respect to the disposition of the excessive slump.
l Es said he was at a simp testing station along with the principal tester l
"C." and "M".uns the sim p aseitor.
Be stated that "D" was also present.
What happened, ascertAng to "E," una that they had built up some safety margia (assent unse's kasus) and that he subsequently heard "M" say that i
there was as margia when a sim p test result uns 4-1/4 inches.
He stated i
that, esatsary to what una stated la tua aswspaper, he did not know what uns to be done about it at the tias, but that he subsequently saw the card with 4 inches recorded.
Be ses.ted that the testing of cylinders uns his asia duty and that he uns at the simp station as a backup.
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Interview with Individual "N" Individual "N'" stated that although 'he we,s the simp monitor, he does not remember this particular instance.
Es eisplained that they were sperating with simp averaging and that one man at one test station could not know what the average was due to the fact that there were three stations. Se also stated that'"K" was usually in the lab which could be the reason "K" did not fully understand the averaging techni-gua and, therefore, could possibly be mistahan.
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Isvestimaties Effort A review was conducted of Gibbs & Bill Specification 2323-55-9 Revision 4.
Section 5.2 states, "A tolerance of up to 1 inch above the indicated annimum shall be allowed for individual batches provided the average of I
all batches tested or the most recent ten batches tested, whichever is feuer, does not excess the easianan limit, i.e., 4 inches. Whenever the amasured si g escends the indicated anzia m by more than 1/4 inch, succenaive batches or truck lands as deposited shall be asasured until the slaup is within the maximum limit."
A review of slump test resulta ist the period identified included the esiculation of the running average.
Ihis investigation disclosed that all the simp test results f all within the values allowed and that the differenca of 1/4" for the test in question would not have altered the acceptability of the concrete.
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Comaidaring the fact that the alleged discrepancy involved only a quarter of am inch,'and the fact that a review of the records indicated that this small amount did not' influence the r - 4== average.
It is the II inspector's determination that 'tha allegation is not an influence en the quality of the cancrete, even if it were true.
Since the concrete la gematian was being pumped, a reduction of simp would h expected to occur through the pipelias. This factor alame would reduce the reported slump to a value under four inches.
This allegation is determined to be fasignificaat relative to the quality of the concrete placed.
h.
A11asstion No. S geb Individuals "A" and "E" allege that cylinder compression test results were falsified by directions frem the R. W. Bunt laboratory annager and individual "D."
mOF
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Intervier with ladividual "J" It was individual "J's" opinion that-We allegation was " stupid" because the 1. W. Eust laboratory manager was a. smart aan who wouldn't cut corners.
Ma stated that the amasser was conscientious but not a leader, which led to personnel problaas.
Interview with ladividual T Individual "E" stated that he believed be was misquoted in the newspaper article. Se stated that he had no knowledge of any falsification as was stated ta the aswepaper. Es said that sons field-cured cylinders were found by the seestruction group and that he went to pick them up.
He moticed that,they were. overdue (passed the 28-day test interval).
He also stated that he didn't know what kind of paper was turned in on the cylinders. When asked by the IE inspector whether he knew that field-cured cylinders do not necessarily have to be brokan, "K" answered, "yes."
Interview with Individual "u" Individual "W" stated that the allegation could only be possible if the persons who did the test were the omas who falsified the results.
"N" also stated that "D" did not review the test results. He stated that lavel 11 inspectors were the amas who would sign the reports i
aftar review.
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Interview with ladividual "0" M
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i Zadividual "F' stated that "E" was responsible for the cylinder breaks l
antil sons taspectors complaiand because they also wanted to test cylinders. Se said that Level'1 Anspectors subsequently broke cylinders en a rotating assignment basis.
Investiaation Effort j
A review of the statistical analysis of concrete cylinder breaks for
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all of Class I concrete placed to date was conducted.
The statistical standard deviaties of the results indicates that concrete of uniform stremath and quality has been produced throughout the overall con-struction peri:d. It was identified in the II Investigation Report No. 77-02, that individual "A" conducted cylinder 28-day compressive strength tests daring the period September 3, 1976, through November 17, 1976 (see Allegatisa No. 9 as a related iten).
Individual "K" denied any knowledge of falsification of test records.
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fl Conclusion It was determined that the allegation by individuals "A" and "K" that coacrete cylinder compressive test results*were_ falsified cannot be substantiated.
."A" does not admit doing it and "K" deniss it.
The review of test result statistics did not disclose any apparent variation
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in the uniformity of the concrete produced to date.
If any falsification did occur on tbs part of "A," it was possible only during an approximate 6 month period of tias. The miformity of the concrete produced along with concurrent testing by other personnel derogates its significance.
p the Connache peak facility concrete batch plant and adjacent concrete 1sSerotory are located approximately one thousand yards f rom the plant cesplan. The batch plant consista of a standard, autcasteh -200 cubic yard per hour unit and a standard 100 cubic yard per hour backup unit.
Both units are certified to the National Ready Mix Concrete Association i
(M MCA) requirements.
On-sita OA/QC docenatation reflect that NRMCA j
racertifications, QC inspectieres, and. B&R QA/QC monthly survaillance checks have been conducted as required since May 1975.
On-site records indicate that approziantely 478,000 cubic yards of j
concreta have been placed to date at the Comanche Peak facility. An estimated 52,000 cubic yards remain to be placed.
During this investigation, the II inspectors conducted a random sampling l
review of batch plant product 1 ;. grintout tickets for the period March 1975 through December 1978 and found no deviations from the batching talarences and desigr epecifications.
Mis, not only confirms prior NRC inspectism findings, but adds significantly to the conclusions drawn.
1.
411eastion Bo. 9 - -
antamatified sources have alleged'that-tests on concrete cylinder com-j pressian testa were run purposely faster than allowed by NRC Regulations /
MC sometimmad standards (Eagulations or Standards not defined).
l pia 41 ass Interview with Individual "A" Zadividual "A" substantiates the allegation. Be stated that he saw quite a few that were does rapidly.
Be also said it occurred during one entire Satisrday seraias.
It was set performed in front of the R. W. Hunt manager er when a Q& inspector uns around.
Interview with ladividiusi "B" We specific haowledge of tacident..
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Intnrview with Individual "C" Individual "C" stated that he falsif-ted records when the work load was heavy.
He stated that he uns supposed to f ast load to 50% of expected break strength based on previous breaks but he fast loaded the test
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machias until breaks occurred.
He could not identify a specific instance or time period.
Interview with Individual "D" ladividual "D" said be never saw it happen.
He stated that they were making 2-30 day epares, if 28-day break passed, the spares were never used and were thrown out.
laterview with ladividual "F' Individual "E" heard rumors but nothing specific.
He alluded to a personality ceaflict between 541 QA/QC manager and t., W. Hunt QC ananger.
Interview with Individual "F" Individual "G" stated that a B&R QA inspector observed individual "A"
landing cylinders to 75% of espected break strength and wrote a noncon-formance report.
Individual "F" also stated that in April 1976, the L U. Eust replaced the might sh!f t Level II inspector because of rumors regarding feat leading activities i,, individual "A."
g Ingerview with ladividual "G" Individual "G" stated that the problem was identified by an internal audit and was documented in a'Nonconfornance Report (NCR) which he affared to locate in a docuamat search.
Interview with Individual "E" Individual "I" would not express any knowledge of allegation or such activity.
Jacerview with Individual "I" ladividual "I" una act suare of any such activity.
He knew that B&R Q& chechad load rates every three months.
He stated that a chart is ia plain view above machine giving load rate test results.
II Interview with Individual "J"
Individual "J" could not arpress any knowledge of such an allegatim Ee stated that a chart above the machine gave the. loading ra t e to use Interview with Individual "K" ladividual "K" stated that he was aware that fast loading occurred in the early stages of construction but tha t f as t loading was never done to 100% of the expected break.ing load.
He stated that B4E QA identified the activity and it never occurred again.
He f urther stated tha t cylinder strength test results were never f alsified.
Interview with Individual "L" Individual "L" stated that he did not believe it happened.
Interview with Individual "N" Ladividual "N" stated that allegation is true.
He observed individuals "A" and "B" fast loading cylinders to 80-95% of the expected br sking laad.
Individual "M" further stated that he and individual "F" were transferred to the night shif t in April 1976 by R. W. Hunt management as a result of rumors of " goof-off" activities going on during the previous nights.
Interview with Individual "N" Individual "N" stated that f ast leading was possible, but only done by
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the individuals claiming to have falsified records.
InterviewwithIndividual"0"j' Zadividual "0" stated that fast loading was done.
He said that the individuals doing it thought it was a big joka to see cylinders explode.
Fast leading was done when large number of breaks were required in one i
day.
Be further stated that he had no knowledge of test results being l
falsified.
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Investination Effort (1)
The II inspector obtained a copy of the B&R Nonconformance Report (NCR) (DDR No. C-473 R-1) dated January 24, 1977, and observed that the deficiency states in part. "It var observed tnt approx 1-mately 3/4 of the laed was applied to the concrete co gressive strength test cyliador at the higher rate of inacing rather tnac to just the first half of the anticipated load.",
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w Attached to the DDR are R. W. Hunt reports fo. HOP-2h85 through 21598 f or concrete test cylinders af f ected by this victatroc.
It is stated in the disposition of the DR that, "Although the cited procedure was violated, the deficiency occurred while testic; 90-day cylinders which were made for engineering inf er:r.ation only.
In comparison. with the 28 and 56-day test results, the test results of the 90-day cylindets are consistent with what might be expected
'in strength sdnN An engineering concurrence by the Architece-Engineer with the disposition of this matter is attached to the'DDR memo, dated Feburary 14, 1977.
a, e
The IE inspector also determined by a records review that the overspeed loading involved 28 cylinders broken at 90-days on a Wednesday, January 19, 1977, by individual "A " a principal N
\\
alleger.
(2) As a comparable review, the inspectors conducted a random sampling review of the computer ptintout batch plant production tickets f or the period March 1#75 through October 1976.
There were no devia-tions from the batchfag colerances and design specifications.
s
\\
s (3) An additional comparable review was conducted of the BER " concrete testing data annagement records" which.provides the statistical analysis of concrete cylinder compression strength tests prescribed by AC 214. The statistical analysis, reflecting 8,264 concrete cylinder breaks-of safety related Wencrete placed during the period March 1975 to Jesuary J977, are within the acceptance standards i
prescribed by MI 318 vlth average compressign strengths exceeding j
50N psi at'26-day 'versus the =4ni== 4000 psf. at 28-day.
Conclusions l
(1)
It was determined that the alleged " fast loading'" during concrete cylinderfconspression strength testing was identified by a B4R QA inspector January 24, 1977, and that corrective action was imple-I mented. '
i N
l l
(2) There are no other is.cidents that epuld be,epecifically identified l
by the allegers or by the IE inspectors.
y (3) The Q&/QC testing records and employment records of allegers indicate that the " fast loading" could only have occurred during a limited time.
(On the order of three months)
(4) The 561 DDR C-473-R-1, dated January 24, 1977, indicates that no detrimental effects to safety related concrete resulted when
" fast loading" did occur.
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- l (5)
Cylinder compression strength tests were conducted by more than seven different 1. W. Euat Level I inspectcrs, on a rotating job assignment basis, during the par,iod March 1975 through March 1978.
Since there were no wide variazias in. test data recorded by other Laval I inspectors, the consistent batching records and the high concrete strengths ' achieved, the fast 1#== vould not have an adverse impact an.the safaty of the atrueturas.
A11emation No.10 j.
Tneo formar R. W. Eust employees allege that racertification of inspectors af ter the March 1977 IEC investigation was "open book" awa=4 nations and answers were given during the test.
Findians Interview with Individual "A" ladividual "A" supported b allegation and also stated that when he first reported to work he did not possess the mini== education and emperiesca for his job as defined by the R. W. Bunt procedures.
_1_starview with Individual "B"_
this individual empreseed no knowledge of the allegation.
Estarview with ladividual "C" m
ladividus1 "C" stated that he failed Letal I soils test and that he was subsequently given answers (orally) by the laboratory managar and taak test over usias. notes he took.
Be also stated that to obtain his recartification (after March 1977) he needed only to have a supervisor sign the recartificatica form.
Istarview with ladividual "D" Es did not administer any of the written or practical tests. He stated he was amare of one man being caught cheating and the man was terminated. Be thought the ineidaat was comical because the answers were wroes anyumy.
Istarview with ladividual "E" ladiv14 mal "E" stated that to his knowledge b====intions were run correctly and above board.
,}sterview with ladividual "F" l
ladividual "F" stated that he sa involved in administering tests and that he never permitted cheating nor open book====inations.
He further stated that he doubts the validity of the allegation.
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Interview with ?.ndividual "C"
Individual "G" stated he had no knowledge of the allegation.
He was aware methods of certification were changed.in, March 1977.
Interview with" Individual "H" Ladividual "E" stated that 'if the allegation did occur he never was asare of it.
Be further stated *. hat the portion of the teet involving concrete aim design was, cad properly had to be, an open book tes..
1sterview with Individual "I" ladividual "1" stated that he never took an open book===ination.
He was saly told what material to study in preparation for the examination.
Interview with Individual "J"
i Individual "J" stated that he doubted the allegation.
Someone was always l asaltorias the emmainations.
Interview with Individual "E"
Ladividual "K" stated that he never witnessed an open book examination.
Es fwther stated that usaminations were given correctly, especially i
af ter March 1977, because B&R S monitored the amaninations.
He felt that the forty hour study program
- was inadequate in view of the inexpe-rience of personnel hired.
= - -
laterview with Individual "L" Individual "L" stated he was never given a test lika that alleged.
He farther stated that he has takaa 'eas test three times and hasn't passed yet.
Interview with Individual "W"_
Individual "M" stated that he doubted the allegation.
Be further stated that his first certif tsation was with answers given; however, recertifi-eations were, and are, given correctly as most gained enough experience and knowledge that it is not necessary to give answers.
Interview with Individual "W"
Individual "N" stated that he gave examinations and never permitted, aor hed he observed open book answers being given or used.
1 30-
,_.,_...m.,_
i interview with ladividual "0"
!adividual "0" stated that he never *ook a test that was honest. He further stated that the laboratory manarsr' told. him not to worry, he veeld never lose his job if he failed sa emanination.
~
Investimaties Effort No specific investigative effort was pursued.
gwiens (1) The matter of qualifications and cartification of the R. W. Hunt Level I inspectors was a subject reviewed in detail during the March 1977 3 investigation.
The details regarding the resulting n asaccepliance citation and subsequent licensee corrective action are cantataed la the II Investigation Report No. 50-445/77-02; 50-446/77-02, dated unrch 23, 1977.
(2) The II inspecters cosmet verify the validity of the stated 3
allegataan beyond the oral statements given.
3.
General Comments Impressed by Interviamers Istarviews with Individuals "A" and "C"
~
Individual "A" stated that he esaid not comment en the quality of the concrete with respect to the safety' et the plant stacF1st was not an engineer.
He
~
also stated that he ese same concreta which, "I wouldn't use in my patio."
Individual C" alae stated that he uma met en engineer and, therefore, not goals.fied to caement as the safety'of,the plant.
Intervices with Individuals "B." "D." "E." "F." "G." "E." "I," "J " "K,"
"L."
'it. " "B." and "tr' Individual "B" stated that he had no concers regarding the safety of the eencreta but merely had 1standed to point out the poor management on the part of L W. Bunt.
Individual "D" believen that the concreta is of high quality and he has no esmeera for the safety of the plaat.
Individual "E" empressed no cancern with the safety of the plant.
Individual "F" believes that the camereta is of high quality and that no safety concera esists. Es haMaves most of the allegations are a result of disgruntled employees.
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1 d.
Essentially au principals interviewed, including the named individuals in the news article, stated that their specific intent was to relate an sapressed dislika for R. W. Hunt, site management.
With the exception of one individual, au principals interviewed, s.
including the named individuals in the news article, stated that the, had no intent to question the plant saf sty or overall quality of the concrete structures.
f.
It appears that. the alleged inspection improprieties involved only a f ew individuals of the approximately thirty-five inspectors engaged in identical or similar concrete inspection activities within the same time fraan.
3 As can be derived from the details section of this report, the alleged inspection improprieties that had the potential of impacting on the quality of the concrete were acknowledged by only three R. W. Hunt level I inspectors with limited responsibility and assignments.
Records are in evidence that the three Inval I inspectors were involved only during short time durations, as compared to the total 182,041 cubic yards placed.
la addition, correlation of production and test records do not reflect a measurable deficiency with regard to the concrete strength, serviceability or safety of the structurer.
h.
The type of tests involved la the alleged improprietins were of a routina, first level, concrete production / placement acuitoring f unction, as distinguished from that of qualification-final acceptance tests.
~
1.
With few exceptions, as identified in paragraph 2 of the report, the alleged impropriaties had been previously identified by Brown & Root QL/qc, R. W. Bunt.QC, TUSI QA mad MC inspections.
Corrective action had been implemented sad recorded as evidenced by QA/QC inspection documentation.
5.
Additional Assertions During the investigation, the IE inspectors were informed of the alleged useofmarijuana,tacq on site sala, during the job tenure of four R. W. Emat individuala. % a ddition, it was alleged that " dice games" we l a a commes activity in one of the R. W. Eunt facilities.
NRC inspectors had no previous kasvledge of such activities; however, information regarding the see and sale of marijuana was provided to the licensee's corporate man-agement during a meeting between RIV representatives and Mr. B. R. Clements in the TDGC0 offices an Thursday April 26, 1979.
There was no evidence that the above activities had a direct impact on safety related structures and/or l
seaponsats and these activities had not been observed by Region IV inspectors daring previous site visits.
3/During the period October 1975 through January 1976.
-,-,---_..--,.-._.__,,_-,--.--__,,r,.m_,
l 6.
_ Referenced MRC Reporte Because of the congruity of matters being ' investigated, the II investigation Reports No. 50-445/77-02; W 446/77-02, dated Miirth 23.,1977, and 78-07, dated May 10, 1978, are by. reference, an integral part of this report.
In addition, the feumwing II Inspection Reports and corresponding licensee replies are teferenced for additional inforantion regarding II concrete inspection activites:
IE Inspection Report W445/75-06; 50-446/75-06, dated April 28, 1975 n Inspection Report W 445/75-07; W 446/75-07, dated June u, 1975 3 Inspection Report W445/75-09; 50-446/75-09, dated July 14, 1975 3 Inspection Report W445/75-10; 50-446/75-10, dated August 7, 1975 II t ; ntion Report 50-445/75-u; 50-446/75-H, dated August 28, 1975 n laspection Report 50-445/75-12; 50-446/75-12, dated october 1,1975 n Inspection Report 50-445/75-13; 50-446/75-13, dated December 12, 1975 n Inspection Report WA45/76-03; 50-446/76-03, dated April 1, 1976 n Inspection Report 50-445/76-06;. 5446/WO4, dated April 20, 1976 IE Inspection Report %445/WO5; W44F/75-05, dated May 26, 1976 n Inspection Raport 50-445/ W O6; W 446/76-06, dated June 25, 1976 n Inspection Report 50-445/76-07;.50-446/76-07, dated August 3, 1976 II Inspection Report W 445/ W O8; W 446/76-08, dated August 19, 1976 II Inspection Report W445/W10; W446/W10, dated October 14, 1976 IE Y- ;= tion Report W445/Wu; W446/WM, dated November 2,1977 II laspection Report 50-445/W12; 50-446/W12, dated Jan:ary 3,1977 It Inspection Report W 445/77-03i W 446/77-03, dated March 31, 1977 n Inspection Report W 445/77-04; W 446/77-04, dated May 17, 1977 n laspection Report W445/77-06; 50-446/77-06, dated May 27, 1977 II Inspection Report W 445/77-07, W 446/77-07, dated July 7, 1977 IE Inspectica Report 50-445/77-09; 50-446/77-09, dated September 6, 1977 34-
.w--,-
n.,
n Inspection Report W45/77-10; W46/77-10, dated october 18, 1977 n laspectica Report W 4 5/77-u; 50-4 6/,77-n, dated lievember 2, 1977 n laspectica 8 sport W45/78-01; bu6/78-01, dated January 30, 1978 M Inspection Report 50- 4 1/78-09; 50- 4 6/78-09, dated June 6, 1978 n taspection Report W45/78-n; S46/78-u, dated June 29, 1978 m laspection taport SMS/78-13; 50-46/78-13, dated september 18, 1978 n Inspection Report 50-45/78-16; 50-u6/78-16, dated November 17, 1978 4
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Individual "C" believes that it was done, but could not be specific atent uhe did it er when it uns deas.
keesview with Radividuna "p" hiividual "W" stated that he had mething to do with the toeting of ey11adees. En amid ha uns in the field all of the time. Es also stated that a Escal II tampacter uns suppened to be supervisias'the level I taspectess while they uste breaking the cylinders and that "K" was the pereen ta sharga of the ey11ader break earts.
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useo disastisfied utch their unges which-led to a let of grumblias.
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u Individent "B" does est believe it'uomId unster to the lab amasser if a erlinear passes er failed and, therefore, does not believe that aspect of the allagassam.
Interview with 1sesvidual "r Individual "B" does est balieve "D" had anythias to do with the cylinder treaks. e Es stated that "E" uns the only person la charge of tbs cylinder
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A.M.c. (Stewa-t) latt Investigation tesort 79-09 ciscusse:
allegations appearing in the Fort Wor.h Star Telegrp :n April 4, 5, 6 and 8, 1979, concerning concrete ins:e::icn and testing activities.
It was alleged that:
(1) Aggregate tests were falsified.
(1) Equipment used to test aggregate was unusse.
(3) Shortcuts were taken on tests involving sizing of agg.egate and moisture content.
(4) Truck drivers added excessive water to :.ucks in transit.
l SWij (5)
Concrete for tuttine building ;1..emen: =as re;e::ee,
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'g but placed anyway.
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,.%y ,l ; y. . ; /.4, y., b. v,. -. A truck lead of concrete was places in a containtreet r -' (7) building well'with a slues of di" (4" mariinCm I r specified). b A.YhT!N;o >..
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y y: s.gg Concrete cylinder comorassion strength test results' .j/ldN, N..n. (8) + c were falsified at the direction of gene-al fofeu n
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~~yr and laboratory manager. e i Concrete cylinder compression te.sts were run (g) purposely faster than allowed. r (10) tecertification of R. W. Hunt inspectors we-e done open book
- with answers given.
The investigation of the ten allegations appearing in :na news media was completed on May 7, 1979, and documented Eight of the allegations mRC Investigation Ret, ort 79-07. could not be substantiated, but a detailed investigation of all aspects of these allegaticins determined that even if the practices in question had occur-et, thert.cuid be Cae ne tasset on the quality of' concrete production. The other allega:icn remaining allegation was refuted. n was substantiated, but the practice involved Mac see 17 si n@- *u-;-Q' fp' -- J - previgusly ide.itifi'ed and Corrected.
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-m;m .,, ;. h e;. .y + ' ?lO ~ T requires the concletion of the 8th grade ;1cs 2 yea-s of emoerience as a minimum recutrement. i wM' AN 4 f '3?NhY) The Applicants respoeded ic MefincingsinftNaseve IRC Investigation Report 77-02 by lettee dded
- ES".Nik April 25.1977, (letter TIX 2303) whe-etn :ney statec
} that two Level I inspectors =see ter.ccra-iij em:,e: from safety-related activites pending a rev e. s' personnel records; all training and certifica: en L records would be audited by SAR and upcatec as neces-t stry; work performed by the Levei ! inspectors in ( question was found to be within specification ~ requirements; S&R assigned a full time ons te ci<i' i OC enginee-to work full time with R. W. Mun: :e.: the SSR QA Manager directed R. W. Munt Co. by Te::e-to report imediately all test failures. The R. W. Munt Co. Procedu-os STCM 5.2, was revised A.: ee'*e:: the tequirearits of the ASME Code. The response was accepted, sveject to ve-ifica:ica. by Region IV letter dated May 11, 1977 i U"s.%W > .t. (Taylar) HRC Inspection Ra' port 75-07 eiscussac an n .E allegatie. that certain cone-ete labora::ry test recer:s d + The investigation 'cund no ev h tMa: 4 .ece falsified.
- . m woulff substantiate toe allegation, ex
- e:: in one. Case.
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37 The one substantiatec allegation relatec to the :a' t a-l tion Of a 3ressure' gauge by 45 indi vicual w"C wii "C* aroperly certified. ~he test, however..was ':unc :: have been properly Deedormed by a competer.: co -s :P. we.c was not, however, certified. 4.26.c. (Stewarti NRC :nvestigat'on Ae: ort 79-09 c s:ussa: allegations appearing in the Fort Werth Star Te'eg s :n April 4, 5, 6, and 8,1979, cencer9f ng concrete inspec:ic-and testing activities. It was allegec that: (1) Agg agate tests were falsified. (2) Equipment used to test aggregate was unusec. (31 Shortcuts were taken on tests involving s::ing :' egg.egate and acisture content. (4) Truck drivers added excessive water to ucts '- transi t. (5) Concrete for turbine building s'acemea: -as e;e::e:. but placed anyway. '6' Concrete 'er 'Jnt t '. ::ata - e-: :ase a: -as :'t:e: without testing.
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- n accitser :: :n. cut ne 4-s: ::t:-s :es:- :e: a::.e. : : :e N#C sta " ::ne.c: investiga ' ens s' ae;a: : s :'
- r::~ e: e-in :: 5 ac t:9 act <
- ty irv: <ts; :: : ete' A.25.
Yes, in addition to the routine ins:ec:<ees ces:-icee a::.e. a nuntee of investigations have beta c:acacted :' al' e: ' y:- oc rieties in :enst%ction ac*.i<ities *n.;'v'ag ::r: ete. 0.25. Please aescribe the nature of the a'.lega:4 ens ' ves-4ga:e: a-: -e investiga 'en 'indings. A.26.a. (Stewart) NRC *nvestigation Re: ort 77 2 cis:.sses a-allegation of the fa'sificatien of c:nc ete air entrainment test rec:rcs e:c-te by :ne *:;iica-:s. findings reflect that the 4. W. Hu-t ins:e:::e :9a ge n-air entrainment test recced to read 4.0% rat *e- : e9 -e actual test reading cf 3.9*..
- 1:s had 'tt e ee.:.
any, on the approximately 10 cabic yards of c:rc-e:e
- Iaced 4 C there was na evice9ce to inci:ste :- ' a' inte-t er malice.
Howeve, du 4 ag ime ::u-se :' : e investiga 'on. two 1te"Is c' -cec 49 e a c - e Oe. t-tien =tae 'de9:i#iec Oy t9e NE~ i 5:e":: s.
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,z s 1 (1) The R. W. Hunt Co. had a Level I inspector _ per#orm y / .. t_.:.. + t,: Concrete Cylinder CCf"Cression break tests e96 ~ ; c.;; w. + :, ig 499Pe94te sieve analysts without eviceeca of _gycg demonstrated proficiency and approvai in acc rdance
- WS: **
with R. W. Mont Co. procedure requirements. In addition, the sinimum information -ecuired t: ac ea-6 on the certificate of qualifications for ons :e Level I and II inspectors, with regard to de en-strated proficiency, was not apparent. (2) The R. W. Munt Co. field reoresentatives had not s- ~ tamediately reported verbally to Brown & Rect Oc. aa. employee's alleted falsification of test records, although the matter %ad been identified in a hanc-written memo, dated January 20. 1977, and was cen-tained in the individual's personnel recoro foleer. The R. W. Nort Co. procedures Manual requires that moncompliance matters shall be immediately repertec, first verbally, and immediately therea'ter, in a report fem directly to the B&R QA Manage. l 2 i 5..y p:5 ' h h [49I (3) The R. W. Nunt Co.. had in thet e manuai, w; ate: the tuo (2) year experience requirect for 44h,ratory . j .s penonnel, contra y to tMe PSES
- Sat ::mitment ::
the ASPE 5ect'en **.*, : vis on : :ce..* :- L___,__._ ~ ~ ~
,f a : o. requires the comcietion of the 8th gra:e :'.;,s 2 fea-s of emperience.as a mini:n.m recutremeat. The Applicants res;cnced :: :Me 'incings *n tre a::.e NRC Investiga fon teocet 77-02 by le::er dated April 25,1977, (lette-71x 2303) ne-etn :sey state: that two Levet ! *nsoectors weet tem:cea d'y -ee:ver from safety-related activites sencing a rev:ew O' personnel records; all training and cert' fica:fcn records would be audited 3y B&R and uncated as neces-sary; work performed by the Level I inspectors ia ~ question was found t6 be within specification requirements; S&R assigned a full time onsite civil OC enginee-to = ort full time with 4. W. Wn: :o.: the SSR QA Manager directed R. W. Hunt Co. iay lette-to report 1smediately all test faffures. The t. W. Hunt Co'. procedu-os STCM 5.2, was revised I.o reect the requirects Of the ASME Codr.. The response was accepted, sutfect :: <e-tf':a:::a. by Region !Y letter dated May !!, 1977 A.26.n. (Taylor) NRC Inspection tecer 78-07 c'scussee se allegation that certain conc ete laborat:ey tes: *ec:r:s were 'a'sified. % e invest' gat':n ':u,e 9e eviceace :*a: would sunstantiate tre si'egati:n, em:e:: 'm :re :sse. e --,--,---_,,-.--._,-.,-,-m ---,,-,-,,,,,n,_--
1 (w 37 * ~ The one substartiated allegation re'a' ic :ne :a:'tra- / ti0n of a pressure'gaugt by aa i n d ' v ' d's t wnc a'as ".c: 3 root'If cer*if'ec.
- he
- e s t, hcwe v e r, wa s 'c'.r c 10 have beta pecperly per#:r ed by a c e:eter.t :e-s:n r.:
was not, however, certifisc. A.26.c. (Stewart; NRC Invas :ga 'en te:ce: 79-09 c sc;ssec allegations appearing in the Fort Worth Star Te'eg-te. :n April 4, 5, 6, and 8,1979, concerning concrete inspe::'cr and testing activities. It was alleged tha : (1) Aggregate tests were falsified. (2) Equipment used to test aggregate was unusec. (3) Shortcuts were taken on tests involving si:ing :f agg.egate and meisture content. (4) Truck drivers added ex:essive water to : ;cks 'a transit. (5) Concrete for tursine building piacema:.as *e;e::ec, but placed anyway. l$' Cencrete d:r Ur. ; *. ::a a - ea-tase-a .45 : a:e: wtthout testing. ~ ~~ C /52 l I
I 7 -M- / (7) A truck load of concrete was placed in a centainme-: building well*with a slump of ai" '4" max E m specifiedi. (8) Concrete cylinder compression strength test results were falsified at the direction of general foye.an a and laboratory manage. (g) Concrete cylinder compression tests were run purposely faster than allowed. (10) Recertification of R. W. Hunt ins:ectors we e dene ' spen took" with answers given. The investigation of the ten allegations appearing in Me news media was completed on May 7, 1979, and documentee in IEC Investigation Report 79-07. Eight of the allegations could not be substantiated, but a detailed investigation of all aspects of these allegations dete- 'ned inat eve-if the practices in question had occurred, the-e wculd be no impact on the quality of conc-ete 3r: duction. One remaining allegation was refuted. The stne aMegatten ws substantiated, but the practice invc1<ed hac bee-previously identiffed and corrected. m
MAR 2 31977 In Reply AeSerTo: RIV Docket Nos. 50-445/Rpt. 77-02 0-446/Rpt. 77-Texas Utilities Generating Company ATTN: Mr. R. L. Gary Executive Vice President <h and General Manager 2001 Bryan Tower [$)l Dallas, Texas 75201 Gentlemeo: This refers to the investigation conducted by.fr. R. C. Stewart, and other members of our staff during the period March 1-4. 1977, of activities authorized by *.1tC Construction Permit No. CPPR-126 and 127 for the Comanche Peak facility, Units he.1 and 2. and to the discussion of our findings with you and other members of your staff at the conclusion of the investiga-tion. Areas examined during the investigation and our findings are discussed in the enclosed investigation report. Within these areas, the investi-gation consisted of selective examination of procedures and representative records. interviews with personnel, and observations by the inspectors. During the investigation it was found that certain activities under your license apoear to be in noncompliance with Appendix 8 to 10 CFR 50 of the 181C Regulations. "f)uality Assurance Criteria for Nuclear Power Plants." The items of noncompliance and references to the pertinent re<:uirwents are identified in Section I.A. of the summary of the enclosed report. One new unresolved item is identified in Section II of the sumary of the enclosed report. This notice is sent to you pursuant to the provisions of Section 2.201 of the :stC's " Rules of Practice," Part 2. Title 10. Code of Federal Regu-lations. Section 2.201 requires you to submit to this office, within 30 days of your receipt of this notice, a written statement or explanation in reply including: (1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. /, A1Y _A.__ h /# ..b -= RC5tewart:jo WACrossman WCSeidle WEvetter AEH411 3/23/77 / 3_/sJ/77 ___ 3/s-3/27_ 3/@77 3/q/77 / . u., men, e.
gg 0 31977 Texas Utilities Generating Co. ~ During the inspection. it was also found that cartain of your activities appeared to deviate from commitments in the PSAR. This item and references to the pertinent consitaants are identified in Section I.B. of the summary of the enciesed report. In your reply. please include your comments con-corning this iten. a description of any steps that have been or will be taken to correct it. a description of any steps that have been or will be tahme to prevent recurrence, and the date all corrective actions or pre-ventive measures were er will he completed. In accordance with Section 2.7g0 of the NRC's " Rules of Practice," Part
- 2. Title 10. Code of Federal lations, a copy of this letter and the encleoed investigation report 11 he placed in the HRC's Public Document Room.
If the report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 30 days of the data of this letter, requesting that such inforuetten he withheld from public disclosure. The application meet include a full statement of the reasons udty it is claimed that the infhvuatten is proprietary. The application should be prepared so that any proprietary infttfuntion identified is contained in an enclosure to the application, since the application without the enclosure will also be pleens in the public Document been. If we do not hear from you in this rd within the specified period, the rupert will be placed in the public t Amoa. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely. @ sW by .W. C. Seidle i W. C. Seidle, Chief Reactor Construction and Engineering Support Branch
Enclosure:
t IE Investigation Report Nos. 50-445/77-02 50-446/77-02 n/enciemure cc: Texas Utilities Generating Company l ATTN: Mr. M. C. Schmidt. Project Manager l 2001 Bryan Tower l Ballas Texas 75201 l l
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV REPORT OF INVESTIGATION IE Investigation Report Mos. 50-445/77-02 50-446/77-02
Subject:
Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 (Comanche Peak) Docket Numbers 50-445/446 CPPR-126 & 127
- nvestigation of licensee reported alleged falsification of concrete air entrainment test records.
Period of Investigation: March 1-4,1977 Investigators:
- rr 3/25/77 W. A. Crossman, Chief, Projects Section
. Date 3-w-?7 ,m m o R. C. 5tewart, Reactor Inspector Date L _,[ S. 2.3 ~77 J. I.,Tapia, Rea "4r[IAspepr' Intern Date ( / ,= Reviewed By: .7 - 2 J - 7 7 j a W. C. 5eid14) Chief, Reactor Construction Date and Engineering Support Branch l c Y
REASON FOR INVESTIGATION On February 25, 1977, the Texas Utilities Generating Company (TUGCD) QA Manager notified the NRC Region IV staff by telepnone of an incident involving an alleged falsification of concrete air entrainment test records. SCOPE OF INVESTIGATION To review the circumstances surrounding the reported falsification of records, interview involved personnel, assess the intent, safety and generic implications. CONCLUSIONS The following are the significant findings evolvec 'com the investigation by the RIV inspectors: 1. The placement of approximately 10 cubic yards of cancrete containing 3.9% air entrainment rather than 4.0% air entrain-ment, had little effect, if any, on the structural soundness, or quality of the concrete placed. 2. Interviews held with the licensee representatives by the IE inspectors, and the detailed review of the applicable record documents, support the IE Region IV staff position that the incident appears to be an isolated occurrence cypounded by an error in judgment initiated by the subject employee. 3. During the cours's of the investigation, two items of noncompliance, l one deviation, and one unresolved matter wert identified by the IE inspectors. These items are related to quality assurance pro-l grasmatic matters and not directly associated with the alleged falsification. The items are identified in the following Sumary of Facts. 4. There was no evidence revealed that would indicate criminal intent or malice. e 2-n.
/ SUP94ARY OF FACTS I. Enforcement Action A. Items of Noncomoliance 1. Violations None 2. Infractions 77-02/A.2.1 Procedural Infraction - Certification / Documentation of Inspectors 10 CFR 50, Appendix 8, Criterion V, states in part: " Activities affecting quality... shall be accomplished in accordance with these instructions, procedures, or drawings." Section 7.3 of the R. W. Hunt's Skills Training Certification Manual 5.2, Revision dated May 1975, which implements Cri'e-ion V, requires a Certificate of Qualification to be given to qualiried personnel. The minimum information required to appear on the certificate is to include: ... (c) activity qualified to perform... (g) basis used for certification." Section 5.2 of the R. W. Hunt Manual. requires a practical examination in which the candidate for certification should have demonstrated proficiency in performing specific practical tests on one or more samples approved by the Level III Examiner. The satisfaction of this requirement is 'requircd to be documented on the Certificate of Qualification by Section 7.3(c) of the R. W. Hunt Manual. Contrary to the above: Items (c) and (g) of Section 7.3 do not appear on any of the Certificates of Qualification, reviewed by the inspector, which l were issued to the on-site Level I and II Inspectors. The R. W. Hunt Co. has permitted a Level I Inspector to perform concrete cylinder compression break tests and aggregate sieve analysis without evidence of demonstrated proficiency and i approval in accordance with the above R. W. Hunt Co. procedure requirements. (Details D.3. ) l
I A f teld notebook, currently contained in the B&R QA Occeen. cc,,._, vault, is stated to be a copy of the disposed of notetoca. ~ ~ ' w in the exception of the three torn out pages. It was stated by the RWH manager that the three torn out pages contained tre n : 4: test data reflecting 3.9% A/E. 2. The inspectors reviewed the personnel folder of the " Level I Inspector" and observed that the employee was hired by RWH on January 12, 1976, and terminated M e 7-8; 1977. It was also noted that the " Level ! Inspector" was certified as a concrete inspector on January 19, 1976, 7 days after being hired; however, the employees application record indicates that he had no orevious experience in concrete testing / inspection, nor does his record indicate graduation from high school. This matter has been identified as a deviation from ASME Section II:, Division 2 (Proposed) Code Requirements. 3. Subsequent review of the " Level I Inspector" training records and related inspection activity records revealed that the " Level : Inspector" had conducted cylinder compressive strength tests during the period September 3, 1976, through November 17, 1976; ASTM C-117 and C-136 Gradation tests, April 13, 1976, through April 21, 1976; and ASTM C-566 Moisture of Aggregates tests, April 21, 1976, without evidence of training as prescribed by RWH Procedure Requirements. This matter has been identified as an Item of Noncomoliance. 4. During the IE Inspectors' review of the B&R DDR C-488, dated February 11, 1977, and February 23, 1977, and the RWH DDR No. 0217, dated January 24, 1977, and February 14, 1977, it was apparent that the RWH manager did not imediately report the incident regarding the record falsifica. tion, inr writing, as required by the RWH QA Manual, Section 513.13. This matter has been identified as an Item of Noncompliance. 5. Specific documents directly relating to the alleged falsification were provided the IE inspector. These documents included the " Level I Inspectors" field notebook, Field Used-Acceptance Tes-Report Form (No identifying form No. ), " cylinder data card" (For-- HCP-1074) and the RWH, QA Permanent Record Report No. HCP-21697 ,(Form HCP-10). All documents were dated January 20, 1977. It was observed by the IE inspectors that the Field Used-Acceptance Test Report Form and the " cylinder data card" reflect concrete ai-entrainment as 3.9%, with the corresponding ~ identifying baten ticket No. 27354, truck No. 29, and representative of the iniF3' first 10 cubic yards batch. However, the corresponding ident -i. m batch ticket and truck number contained in the field noteccoi. - -}}