ML20198D314

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Assessment of Allegation AQ-137 to Allegation Category Qa/Qc 3, Records Re Alteration of ASME N-5 Welding Records & Documents While Welder or Inspector Whose Signature Altered Not Onsite
ML20198D314
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V, Winczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230217
Download: ML20198D314 (2)


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1.

Allegation Category: QA/QC 3, Records

2. Allegation Number: AQ-137
3. Characterization: It is alleged that ASME N-5 welding records and docu-ments were altered while they were in the permanent plant records vault, and that such alteration could be determined because the welder or inspec-tor whose signature was altered was not onsite on the day these documents were signed.
4. Assessment of Safety Significance: Since the alleger could not supply the date or specifics of the alterations, the NRC Technical Review Team (TRT) selected a sample of documentation packages from 26 N-5 systems and re-viewed weld data cards (WDCs) for the field welds completed in each sub-system. The period covered by these documentation packages was from March 1978 to October 1983. From these WDCs, the TRT determined the specific dates on which welders, quality control (QC) inspectors, and Authorized Nuclear Inspectors (ANIS) performed safety system field welds and inspec-tions. The TRT found no evidence of physical altering on any of the WDCs selected.

For each WDC, the TRT recorded the weld symbols of the welders who had performed the field welds, the names of the QC inspectors who had inspected the welds, and the names of the ANIS who had completed hold point inspec-tions on the welds. The TRT then cross-referenced each weld symbol with a specific welder's name and badge number.

The TRT next obtained the badge numbers for the QC inspectors and to access personnel payroll records to determine if these employees were on site on the date the WDC entry was made. The TRT reviewed 194 entries made by welders on the WDCs. Payroll records showed that all of the welders investigated were on site on the dates that were taken from the WDCs, and the welder entries were accurate.

The TRT found that each ANI inspector entered his shift activities in a bound record book entitled, "Special Inspection Services Daily Inspection Record," as required by the Hartford Steam Boiler Inspection and Insurance Co. The TRT determined that this record provided satisfactory evidence of when an ANI was present at the construction site during the 5 year period under consideration. In the samples of WDCs reviewed, 47 inspections were performed by the ANIS. Numerous entries posted in the record book indicated that in all cases the ANI who signed the WDC was on site. However, the TRT noted that five of the inspection activities listed on the WDCs were omitted from the record book. This appeared to be an administrative omission.

The TRT reviewed 99 entries on the WDCs which were made by QC inspectors.

The TRT verified that all inspectors were onsite for the dates documented i

by the WDCs, with the exception of one inspector, a temporary employee from the Brown & Root Houston office. The record of the Houston employee confirmed that he was on site that week; however, their records are kept weekly not daily.

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5.

Conclusions:

The TRT concludes that since none of WDCs appeared to be altered and the attendance records of the individuals sampled revealed no discrepancies, the allegation that ASME N-5 welding records and documen-tation were altered while in the permanent plant record vault is not sub-stantiated. Accordingly, this allegation has no generic implications.

In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of the allegation and the TRT's conclusion. No major items of disagreement and no new concerns or allegations were identified.

6. Actions Required:
7. Attachments: None.

Reference Documents:

1. Brown & Root Procedure, CP-QAP-12.1, Rev. II, "ASME Section III Installation, Verification, and N-5 Certification."
2. Brown & Root Persennel Payroll / Time Records.
3. B&W Welder Qualification Records.
4. B&W Quality Control Inspector Records.
5. A-5 Interview, dated August 2, 1984, page 18
6. A-5 Closecut Interview, dated December 10, 1984, pages 35 through 73.
8. This statement was preparea by: dl V. Wenczel u

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Date TRT Technical Reviewer Reviewed by: Itata E [0 h 6 H. Livermore Date Group Leader Approved by:

V. Noonan Date Project Director 0-104