ML20210E774

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Bostron-Bergen/Meddco Metals Allegations Investigation Interim Rept
ML20210E774
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 01/25/1984
From:
CYGNA ENERGY SERVICES, PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML16341D666 List: ... further results
References
FOIA-84-744 NUDOCS 8603280165
Download: ML20210E774 (32)
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8603280165 960123 l PDR FOIA '

. DEVINE84-744 PDR

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BOSTROAMBERGEN/MEDDCO METALS ALLEGATIONS INVESTIGATION NTERIM REPORT Dated Jonoory 25,1984 By 6

Pocific Gas and Electric Company 77 Beale Street l

San Francisco, CA 94117 I

i and Cygno Energy Services 101 California Street San Francisco, CA 94117

TABLE OF CONTENTS Section Pace l.0 PURPOSE I .

2.0 BACKGROUND

2 i 3.0 SCOPE AND METHODOLOGY 5 4.0 INVESTIGATION STATUS 10 5.0

SUMMARY

26 i

i Pacific Gas and Electric Company I 8( L a Bostrom-Bergen/Meddco Metals Allegations investigation muuuuummuumul Interim Report Dated January 25,1984 f

l.0 PLAtPOSE This report is submitted to the U.S. Nuclear Regulatory Cor.vnission (NRC), Region V to provide tfw status of the Pacific Gos and Electric Company (PGond) investigation of the ellegations mode by former employees of Bostrom-Bergen/Meddco Metals, a miscel-leeous structural steel fabricator to the Diablo Conyon Nuclear Power Plant. This report fulfills the commitment mode to the NRC Stoff during the January 16, 1984 meeting between PGondE ond the NRC, at the NRC Reg!on V offices.

Section 2.0, "Bockground", of this report delineotes PGondE's understanding of the allegations plus the objectives of thePGondE investigation into such allegations. Section 3.0, " Scope and Methodology", oddresses the scope of the allegation investigation and the methods utilized to satisfy the investigation objectives. The report concludes with Section 4.0, " investigation Status", and Section 5.0, " Summary", which discuss the status of the allegations investigation along with PGondE's preliminary position relative to the perceived impact on the quality of materials supplied to the Diablo Conyon Nuclear Power Plant by Bostrom-Bergen/Meddco Metals.

I Pacific Gos and Electric Company L% [ j g a Bostrom-Bergen/MedC:o Metals Allegations investigation

- imm interim Report Dated .Awsory 25,1984

l I

i 2.0 BACKGROUPO in December,1983, ABC News in Son Francisco broadcasted allegations regarding quality proctices utilized by a structural steel fabricator, t$ostrom-Bergen and its subsidiary I Meddco Metals, who supplied miscellaneous structural items cnd components to the Diablo Canyon Nuclear Power Plant. These allegations, as understood by PGondE this date, are os follows:

2.1 Allegations related to the time period January 1981 throvoh Jonvory 1983 2.1.1 A former Bostrom-Bergen inspector alleges to have documented inspections which he never performed.

2.2 Alleoations related to the time period 1979 through 1980 2.2.1- Bostrom-Bergen qualified welders are alleged to have questionable qualifications in that welders did not maintain their qualification by continuous welding during six-month periods.

2.2.2 Ports are alleged to have been assembled by a manufacturer other than Bostrom-Bergen.

2.2.3 The adequacy of some inspections performed by Bostrom-Bergen inspectors are alleged to be questionable due to poor conditions for inspections such as inoccessibility and poor lighting.

2.2.4 Bostrom-Bergen personnel performing quality-related octivities are alleged to have received no Quality Assuronen Program training.

2.2.5 Bostrom-Bergen fabricated components found to be discrepont and/or domoged are alleged to have been shipped.

Pacific Gas and Electric Company 2 A (tj g a Bostrom-Bergen/Meddco Metals Allegations investigation mi Interim Report Dated January 25,1984

2.2.6 Bostrom-Bergen quality proctices are allegedly suspect due to monogement pressure to meet schedules.

2.3 Alleactions related to the time period 1977 throuch 1979 of Meddco Metals 2.3.1 Bostrom-Bergen/Meddco Metals Certified Material Test Reports " ore

. olleged to have been altered.

2.3.2 Material heat certification numbers are alleged to have been ground of f and new numbers stamped in their ploce.

2.3.3 Material piece mark identification numbers are alleged to have been ground off and n'ew numbers stomped in their place.

2.3.4 Red " Reject Togs" were token from materials, reploced with " Accept Togs," and the materials placed boek into the system.

2.3.5 Foreign-produced material purchased by Meddco Metals is alleged to have been inappropriately used as domestically produced.

2.3.6 A shop worker scraped point off of an occepted item and found the word

" BAD" on it.

In December 1983, PGondE quality assurance initiated on investigation of the Bostrom-Bergen/Meddco Metals allegations. The objectives of the ongoing investigation are to:

l l e Determine the validity of each of the allegations.

e Determine the impact on , quality of safety related systems, structures and l

components.

l Pacific Gas and Electric Company 3 L Ljk a Bostrom-Bergen/Meddco Metals Allegations Investigation interim Report Dated January 25,1984 i

l

e Based on the dwe, initiate and implement actions regarding suspect Bostrom-Bergen/Meddco Metals materials supplied to the Diablo Canyon Power Plant.

e Prepare a final report to the Nuclear Regulatory Comminion (NRC) summarizing the results of the review.

l i

i I

I Pacific Gas and Electric Company 4 L i j$ 3 Bostrom-Bergen/Meddco Metals Allegations Investigation Interim Report Dated .lonoory 25,1984 l

3.0 SCOPE APO METHODOLOGY This section describes the scope and' methodology for performing the investigation of allegations mode regarding the quality of items fabricated by Bostrom-Bergen/Meddco Metals. This investigation comprises three major activities under the following heodings:

. e Criteria Development e investigation Performance e Final Report The details are os follows:

3.1 Criterio Development Investigation criterio developed in the form of either procedures, instructions, checklists and/or review matrices for the performance of the allegation investigation. These ,

criterio delineote the specific methods for the performance, documentation and reporting of the investigation.

3.2 - Investigation Performance An investigation performed to determine the validity of eoch of the respective allegations mode. This investigation, os a minimum, includes a review of the following:

e PGondE Procurement Documents e Bostrom-Bergen/Meddco , Metals Quality Assurance / Control Program Documents e Nonconformance Control Documents e Certified Material and Test Laboratory Test Reports e Bostrom-Bergen/Meddco Metals Purchase Orders and Vendor Control Pacific Gos and Electric Company 5 L8 [ J k a Bostrom-Bergen/Meddco Metals Allegations investigation unummmmmum Interim Report Dated .lonvary 25,1984

e Welder Qualifications e Inspector Qualifications e Personnel Training e' Audit Records e Shipping and Receiving Records e inspection Records .

e interviews Once complete, the results of each of the above individual investigations will be inte-grated to establish a basis for forming a conclusion as to the validity of each of the

- allegations addressed in Section 2.0.

Eoch of the above categories is described in more detail as follows:

3.2.1 PGondE Procurement Document Review Review the PGondE specifications generated and issued to Bostrom-Bergen/Meddco Metals to a) determine whether oppropriate quality requirements had been specified for the items procured by or for PGondE during the 1976-1982 time period l

l b) form the basis of reviewing the Bostrom-Bergen/Meddco Metals Quality Assurance / Control Progrom documents.

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3.2.2 Quality Progrom Review Review each respective Bostrord-Bergen/Meddco Metals quality assurance / control program document to determine whether the contractually specified quality requirements have been oppropriately incorporated. Special emphasis will be

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concentrated on the systems / controls governing the topics of the specific ollegations.

Pacific Gas and Electric Company 6

% [. ;g a Bostrom-Bergen/Meddco Metals Allegations Investigation interim Report Dated January 25,1984

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3.2.3 Nonconformance Control . ,

Review Bostrom-Bergen/Meddco Metals generated documents and identify instances where discrepancies are noted. Once identified, perform o forther review i to determine what dispositions of the discrepancies have occurred. Specific documents to be included, as a minimum, in this review are:

Receipt inspection documentation e

e Inspection reporis e Shop traveller packages e Nonconformance reports e Hold Tog Logs l e Mill / Test Lab Test Reports 3.2.4 Test Reports

i

! Review all Certified Material Test Reports / Test Lab Test Reports to identify any instances where alterations are suspect. Once identified, develop a sample of the originals to be requested from the parent material manufacturer, material supplier and/or test laboratory for comparison.

3.2.5 Purchase Orders / Vendor Control I

Review Bostrom/Bergen purchase orders and vendor control documents to identify l

l the scope of subcontractor activities. Once identified, review vendor control documentation to determine that oppropriate controls have been exercised.

3.2.6 Welder Qualifications ,

Review welder qualification records for welders performing work on Diablo Conyon materials along with their respective employment records to determine:

Pacific Gas and Electric Company 7

% {. g 3 Bostrom-Bergen/Meddco Metals Allegations Investigation muuuuuuuuuuuun interim Report Dated January 25,1984

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o. whether welders were properly qualified in occordohe,with specified code requirements
b. whether welders continuity was mcintained in accordonce with specified code requirements.

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3.2.7 Inspector Qualifications

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Review inspector qualification records to determine if oppropriate inspector qIuolifications were established and maintained.

3.2.8 Personnel Training Review Bostrom-Bergen personnel training records to determine whether individuals performing activities impncileg quality received appropriate trainhg. ,

3.2.9 Audit Reports 9

Review oudits performed at Bostrom-Bergen/Meddco Metals and evoluote the

chronological effectiveness of their quality assurance programs with respect to l ' deficiencies identified including the effectiveness of corrective actions.

l l

3.2.10 Shipping and Receiving Records '..

Review Bostrom-Bergen/Meddco Metals shipping records and Diablo Canyon jobsite receiving records to determine if items received were free of defect and, if not, that appropriate dispositioning occurred.

inspection Records

! 3.2.1 I Review Bostrom-Bergen/Meddco . Metals inspection documentation to determine if appropriate inspections were performed, and if identi!ied discrepancies were satisfactorily resolved.

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Pacific Gas and Electric Company 8 L ( )L A Bostrom-Bergen/Meddco Metals Allegations investigation is Interim Report Dated January 25,1984

3.2.12 Interviews interview the individuals who are known to have mode allegations to verify PGondE's understanding of these allegations and to discuss the findings.

3.3 Final Report .

As~ the investigation progresses, documentation will be generated and organized for inclusion into o final report. The final report will oddress each allegation and will include os a minimum: ,

e investigation methodology e Detailed results including impact on safety-related Diablo Canyon Power Plant systems, structures, and components

! e Completed checklists and/or matrices generated during the investigation l

i r

Pacific Gas and Electric Company -

9 4[ jg i Bostrom-Bergen/Meddco Meto!s Allegations investigation m . Interim Report Dated January 25,1984 l

4.0 NVESTIGATION STATUS Following is o detailed status summary of the allegations investigation conducted to date:

m .\ \

4.1 Allegatiom "A former inspector of Bostrom-Bergen olleges to have documeryted inspections which he never perforrned."

4.1.1 Status The investigation team reviewed all inspection records generated of Bostrom-I Bergen for Diablo Canyon work during the inspector's employment (Jonvory 17, 1981 through January 13, 1983). The review culminated in a complete listing of all inspections performed by the former inspector which was submitted to the General Construction Department at the Diablo Canyon jobsite. General Construction located all the materici inspected by the former inspector. All material was found to be insto!!ed in non-sofety related systems.

'In addition, a review of the inspector's qualification records indicated that the inspector did, in fact, have appropriate training and qualifications to perform

' proper inspections. Further, in the course of the investigation, Bostrom-Bergen l

provided to the investigators offidavits by the former inspector's co-workers and supervisor attesting to the forrner inspector's conscientious discharge of duties.

l l

4.1.2 Tentative Conclusion Based on the facts presented to date, it is concluded that the safety related systems, structures, and components in the Diablo Canyon Power Plant have not l

been impacted. Remaining activities include the continued investigation into the validity of the allegation includirig the possible re-inspection of certain non-sofety related rruterials inspected by the former inspector.

Pacific Gas and Electric Company 10 A{ g i . Bostrom-Bergen/Meddco Metals Allegations Investigation les Interim Report Dated Jonvary 25,1984 l

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4.2 Allegatiam '90stroargen qualified welders are oileged to have questionable qualification in that welders did not maintain their qualification by continuous welding during six-month periods."

4.2.1 Status The investigation tearn is performing a review to determine 'the odequocy of qualifications of welders who worked on Diablo Canyon Power Plant materials at

' Bostrom-Bergen/Meddco Metals. The review to-date encompasses the fallowing:

o. Identify oil 'the welders who performed welding on the Diablo Canyon project during the period of 1977 through 1980.
b. Review employment records of the welders identified as having performed welding to determine their dates of employment,
c. Verify the odequocy of welder qualification documentation meeting the requirements of AWS-DI.I.

Through review of Bostrom-Bergen/Meddco Metals production travellers and

' welding records, eighteen welders (twelve from Bostrom-Bergen and six from Meddco Metals) have been identified as having welded on Didato Canyon materials, to date. A review of the twelve Bostrom-Bergen welders' employment records indicate that ten have never had employment lapses in excess of five months. The remaining two welders did have lapses of employment in excess of six months, but signed offidavits by each welder, os contained in the welder qualification files, attest to the fact that each bod maintained welder continuity through other employment. Further, o review of the octual qualification records of all twelve welders indicated that these welders were hired and utilized based on welder qualifications from previous employers in lieu of training and testing by Bostrom-Bergen. -

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Pacific Gas and Electric Company iI

%( 6.4 Bostrom-Bergen/Meddco Metals Allegations investigation

, Interim Report Dated January 25,1984 l

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The above condition had been previously identified by Brown & Root Audit No.B369-5 of Bostrom-Bergen, which culminated in a 10CFR50.55e reported to the t@tC on December 4,1979 by Houston Lighting and Power Company. A follow-up inspection was performed by the NRC and reported in NRC inspection Report No. 9990726/80-01, which indicated that satisfoetory actions had been i

taken by Bostrom-Bergen regarding welder qualification and continuity. No deviations or unresolved items were identified.

l i

Remaining actions include the continuing review of Meddco Metals welder qualifications; verification of the two Bostrom-Bergen welder employment during their absence from Bostrom-Bergen, and verification that welder quollfication was consistent with the requirements of AWS-DI.I.

l 4.2.2 Tentative Conclusion 1 l l

It can be tentatively concluded that although welder qualification was not documented to the degree necessary to fully satisfy all the requirements of AW5-Ol.1, sufficient evidence exists to provide assurance that welders were in fact qualified. This is consistent with resolution of the 10CFR50.55e identified by Houston Lighting and Power Company and followed-up by the NRC. However,

  • further investigation continues to, as a rninimum:
a. Review the remaining two welders qualification records at Bostrom-Bergen.
b. Review the six Meddco Metals welders qualification records.

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c. Review any other, odditional qualification records of welders who may have welded on Diablo Canyon Power Plant materials.

Pacific Gas and Electric Cer,g,ceiy 12 d(;g a Bostrom-Bergen/Meddco Metals Allegations investigation ummummummumi Interim Report Dated January 25,1984

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4.3 Allegation

Parts are alleged to have been assembled by a manufacturer other than Bostrom-Bergen" 4.3.1 ' Status The investigation team is in the process of reviewing all Didio Canyon Power Plant records generated by Bostronergen, specifically their purchase orders and vendor control documents for sub-contractors. At this point, substantial evidence exists indicating that Meddco Metals, a wholly-owned subsidiary of Bostrom-

! Bergen during the allegation time frame, did in fact perform a large portion of fabrication /assembsy on behalf of Bostrom-Bergen. Further, evidence exists to substantiate that adequate procedures were in place at the Meddco Metals facility in the performance of fabrication / assembly operations.

4.3.2 Tentative Conclusion No' improprieties have been identified to-date to indicate the improper use of i outside manufacturing / assembly facilities for the perforrnonce of assembly operations. Further investigation is necessary to reach a final conclusion.

t ,t. 9 4.4

  • Allegation: "The odequacy of some inspections performed by Bostrom-Bergen

(

inspectors are alleged to be questionste due to poor condities for inspections such as inaccessibility and poor lighting."

4.4.1 Status The investigation team has reviewed approximately 30% of all inspection documentation including traveller packages and inspector records. In addition, inspector qualification records kve been reviewed indicating that of least eight of eleven have received appropriate training. Investigation of remaining inspector documentation, Diablo Canyon jobsite receipt inspection records, and inspector qualifications continues.

l Pacific Gas and Electric Company 13 i d( ~

g i Bostrom-Bergen/Meddco Metals Allegations investigation Interim Report Dated January 25,1984 l

L .- . - . - . - . - . _ _ - . - . _ . - . - _ _ _ _ . _ __ _ _ _ _ _ _ _ _ _ _ _

4.4.2 Tentofive Conclusion-At this time, evidence exists indicating that odequate and appropriate inspections have been performed. Further, sufficient tools were available to Bostrom-Bergen inspectors to perform proper inspections such as flashlights, mirrors, etc. There is no reason to currently believe that the quality of_ inspections performed' by Bostrom-Bergen inspectors, other than the allegation discussed in Porograph 4.1, above, has been compromised.

a.o 1

4.5 Allegation

'Sostrom-Bergen personnel performing quality-related octivities are alleged to have received no Quality Assurance Program training."

4.5.1 Status l

l 1

The investigation team has initiated the investigatior;into personnel training and qualifications. This investigation to date has shown that documentation of OA

[

I training for production personnel is locking, indicating that formal QA training at Bostrom-Bergen was not performed. Bostrom-Bergen monogement and on ex-

. Inspector stated that training was in fact given, but of the type given by production supervisors and day-to-day interaction with inspection personnel. To ossess the overall impoet on end product quality, the investigation team has initiated the review of inspector training since inspection is the direct check and balance on proper process control and product quality. At this time, eleven inspection personnel training files have been reviewed indicating that eight have received appropriate training. In addition to the above, and in support of Bostrom-Bergen personnel knowledge of quality proctices, inspections have been performed by PGondE of Bostrom-Bergen materials. In fact, of 47 detail field l Inspections found to-date, all inspections indicats acceptance of Bostrom-Bergen materials. Specifically,35 of the 47 inspections included inspection of the welds.

Pacific Gas and Electric Company 14 d( 6 A Bostrom-Bergen/Meddco Metals Allegations investigation i

numammum Interim Report Dated January 25,1984 l

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The investigation continues to assess the adequacy of the training given to the remaining personnel.

~ 4.5.2 ' Tentative Conclusion it con be concluded to-dote that formal Quality Assurance Progrom training was ,

not given to production personnel, as alleged by on ex-mechonic/ fitter at Bostrom-Bergen. However, investigation into this allegation in addition to the '

others hos revealed that systematic controls did exist, that thus for inspections were performed by trained inspectors, that production was appropriately controlled vio o traveller control system (sequenced production), that there were some field inspections performed by PGondE which found Bostrom-Bergen materials to be acceptoble, and therefore, it con be concluded that end product quality hos not been impacted due to lock of formal production personnel training. Further investigation is continuing to substantially provide a final conclusion on end-product quality.

L. L b 4.6 Allegatiom "Bostrom-Bergen fabricated components found to be discrepont and/or domoged are alleged to have been shipped."

4.6.1 Status .

The investigation team has investigated approximately 30% of all shipping records l ,

and traveller packages for proper documentation of inspections with no indication of the shipment of discrepont materials. In addition, on investigation of oil the nonconformance reports (NCR's), the Hold Tog Log and the NCR Log hos been performed. One instance has been identified where discrepont material may have l been shipped to the site os indicated by' the evidence of the nonclosure of l NCR-2311-124 which identified material that was received having Rockwell Hordness test results which did not meet specification requirements.

Pacific Gas and Electric Company 15

6. 8 ( ) k A Bostrom-Bergen/Meddco Metals Allegations investigation

~+- lills Interim Report Dated January 25,1984

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4.6.2 Tentative Conclusion To-date, evidence exists indicating that, of the materials shipped,'only acceptable

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materials have been shipped to Diablo Conyon as indicated by the review of shipping records, which include inspection reports, traveller packages and material certification reports. Investigation is continuing to substantially conclude,the validity of this ollegation with special offention to the closure of NCR-23ll-124 discussed above. .

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4.7 Allegatiom 'Bostrom-Bergen quality practices are allegedly suspect due to monogement pressures to meet schedules."

4.7.1 Status To date, no information has been brought to the investigation team's attention to indicate inordinate monogement schedule pressures whicii could cause the  !

compromising of quality. Further, in discussions with Bostrom-Bergen monogement, it was stated that pressures were ploced only on those individuals whose performance was not satisfoctory.

I 4.7.2 Tentative Conclusion l

The investigation team has not seen evidence by review of documentation, and l discussion with Bostrom-Bergen personnel that monogement pressures of the Bostrom-Bergen facility were unreasonable which could cause suspect quality.

Further investigation will be conducted to develop a final conclusion.

Pacific Gas and Electric Company 16 g(( ; i a Bostrom-Bergen/Meddco Metals Allegations investigation summmmmmmmmmi interim Report Dated January 25,1984

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4.8 Allegatiom "Bostrom Bergen/Meddco Metals Certified Material Test Reports are alleged to have been altered." l 4.'8.I' Status i

The initial review has been performed on the Certified Material Test Reports (CMTR's) for materials pwhd by Bostrom-Bergen under Job No. 2311, the primary job number for the Diablo Canyon Project. These files contained

, proximately t il2 CMTR's for materials purchased between 1974 and 1982. Of these t il2 CMTR's, 321 CMTR's were in a condition which raised a question of otterations either in the form of cut and poste or hand markings over numerical

! information which was difficult to read due to the poor quality of the copies on file.

4 A secondary review has been performed on all files containing CMTR's for nuclear ,

! quality materials used on other Bostrom-Bergen jobs during this time period. This was done to generically review Bostrom-Bergen's CMTR -files since excess materials from one jd, may have been placed in stock, and later used on the

Diablo Canyon Project. At present, opproximately 3,000 CMTR's have been reviewed and 142 have been identified as being of questionste quality. This is in ciddition to the CMTR's in question above.

i

, To determine the validity of the allegation, o somple plon was developed based on MIL Standard 105D to determine on oppropriate sample of CMTR's to be requested from the material manufacturers for comparison. For the materials purchased for Job No. 2311, o random sample of 50 CMTR's was determined to be gpropriate, which once compared, will result in o 97% confidence factor that all CMTR's in i this population are occurate, if the comparison shows no improprieties. A rondom l

sample will be selected, from the generic CMTR files, on a simil'or basis and compared with copies obtained from the steel vendors.

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l Pacific Gas and Electric Company 17 4( 6 a Bostrom-Bergen/Meddco Metals Allegations investigation muuuuummmmul Interim Report Dated January 25,1984 4

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The initial sample of 50 CMTR's included materials from eight steel manufac-turers. The level of success in obtaining copies of test reports vorles greatly between the various vendors. Oregon Steel was contacted and immediately responded with eight of the nine CMTR's requested. Kaiser Steel was contacted with a request for six reports, and could not supply any of these due to the age of the reports, since Kaiser retains records for only six years. - A sample of five reports was requested from Bethlehem Stee!. Their quality controi department I

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will only release copies of CMTR's to the original purchaser of a product, and,only two of the five requests were purchased directly from Bethlehem by Bostrom -

Bergen; these two have been requested by Bostrom-Bergen, but the other three must be obtained from the steel supplier from which the steel was obtained.

The largest number of test reports in the sample, twenty-six, are for steel produced by United States Steel Corporation (US Steel). US Steel was contacted, and their response was that they would not be able to supply the test reports due 1

to the elapsed time since their issuance. Their representative recommends that the individual suppliers be contacted to obtain copies of the CMTR's. US Steel l

! Supply was contacted for seventeen reports, and they are presently in the process of retrieving the documents; none have been received at present. The other nine

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items were purchased from several local suppliers, and on effort is in progress to contact and retrieve these reports.

Two steel mills, Pacific States Steel and Colt Industries, supplied one each of the reports in the sample, but both mills are no longer in existence, and it has not l

been possible to obtain verification of the reports. Several of the suppliers contacted are not able to supply copies of test reports due to the limitation of their record retention period. Additional reports will be selected for verification to maintain the sample size at fifty.

No effort has been expended in obtaining verification of the CMTR's in the sampling from the generic reports at the present time. ,

Pacific Gas and Electric Company 18

( Bostrom-Bergen/Meddco Metols Allegations investigation A{ g 4 gesammismael Interim Report Dated January 25,1984

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l 4.8.2 Tentative Conclusion I .

i At present, eight CMTR's from Oregon Steel have been received. These have been visually compared with the copies in Bostrom-8ergen's files and no alterations  ;

were found. The hand written markings on all these reports only serves to Improve the legibility of the copies on file. -

In addition, four CMTR's have been verified by comparison with other copies or i even originals, in Bostrom-Bergen's files that were filed under other heat numbers on the some report and had no hand merkings or evidence of cut and poste. These four showed no signs of otterations to the contents of the reports.

With gproximately 24% of the sample verified, no justification has been found to-I date for the allegation. Document retrieval is still in progress,'ond no definite conclusion con be drawn until the entire somple of fifty plus the sompte from the generic records have been verified.

n./ M i 4.9 Allegatiom " Material heat certification numbers are alleged to have been ground off and new numbers stamped in their place."

' 4.9.1 Status The investigation team has reviewed , proximately 30 % of Bostro n-Bergen/Meddco Metals documentation including all nonconformance reports and the entire hold tog log. At this time, substantial evidence exists indicating that l

heat numbers were ground off and re-marked. In addition, substantial evidence exists that whenever this was performed, it was performed under strictly controlled conditions in accordance with approved Quality Assurance procedures.

Examples identified to-date indicate two nonconformance reports requiring heat number changes, seven hold tag entries identify heat number or material discrepancies resulting in heat number changes, and eighteen correspondence Pacific Gas and Electric Company 19 L% { 6 4 Bostrom-SeiF/Meddco Metals Allegations investigation ammummusum interim Report Dated January 25,1984

sletters from Bostrom-Bergen vendors providing instructions to Bostrom-Bergen to correct / modify heat number stamping. Investigation is proceeding to determine whether heat number otteration improprieties occurred in the remaining 70% of

. Bostrom-Bergen/Meddco Metols documentation.

4.9.2 Tentative Conclusion Substantial evidence exists indicating that material heat ~ numbers were altered

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under strictly controlled conditions. Therefore, it is reasonste to conclude that the ollegation is factually correct but the implicofion that this was improper is incorrect. Further investigation continues to develop a final conclusion.

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. 4.10 Allegation: " Material piece mark identification numbers are alleged to have been ground of f and new numbers stomped in their ploce."

4.10.1 Status The investigation team is continuing its investigation into this allegation consistent with the investigation conducted as identified in Parograph 4.9, above.

i . 4.10.2 Tentative Conclusion No evidence exists to support the allegation. Continued investigation is being performed to determine the validity of this allegation.

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4.11 Allegation: " Red ' Reject Tags' were taken from materials, replaced with

' Accept Tags,' and the materials placed back into the system" l

! 4.ll.1 Status +

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! A review of the Quality Assuranc,e Manual for Bostrom-Bergen/Meddco Metals has i

been performed to verify that the requirements stated in the PGondE l Specification 8831R have been met. The section of the Bostrom-Bergen/Meddco i

l 20 j ( [ j , , Pacific Gas and Electric Company

, Bostrom-Bergen/Meddco Metals Allegations Investigation l ..

.m interim Report Dated January 25,1984

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Metals manuals reviewed were the sections which pertain to the control of nonconforming materiol; how they are handled; how they are segregated from acceptable material; how the nonconforming items are dispositioned; and who has '

the respansibility for dispositioning the nonconforming item. In addition, the section pertaining to corrective actions was reviewed to determine systematic requirements to prevent this nonconformance from recurring. ,

In review of the above manuals, nonconformance reports, internal audit reports, '

and the NCR Log, there is no reference to Hold Tags' being removed without proper outhorization by the gplicable QA personnel. Items con be removed from the holding area and fabricated as long as a Conditional Release is initiated per Section 15 of the QA manual. It should be noted that there is no mention in any of the applicable , manuals of a " Red Reject" tag being used at the Bostrom-Bergen/Meddco Metals plants during the years of concern.

t Through discussions with Bostrom-Bergen personnel, it is believed that the only tog used at the time that the individual making the allegation might be referring

- to was an " inspection aid" used for liquid penetrant testing of stainless steel bars for a nuclear power plant in Almarez, Spain. The tog, yellow in color, only indicated that a part did not pass inspection rather than the part being rejected.

Typically a part that did not pass inspection had only surface abnormalities that l

could be removed by buffing and/or grinding in occordance with approved l

procedures. Bostrom-Bergen personnel stated that the Hold Tog Log for this j

I project (Almarez) indicated that this system was actively used and some parts were rejected and signed of f as dispositioned (scrapped) by responsible inspectors.

4.11.2 Tentative Conclusion It is tentatively concluded that bdequate systematic controls were evident within the Bostrom-Bergen/Meddco Metals quality program. Further, substantial evidence exists indicating that nonconformances were reodily identified and controlled. Further investigation is necessary to provide a final conclusion as to the validity of this allegation.

I 21 Pacific Gas and Electric Company 6.M L a Bostrom-Bergen/Meddco Metals Allegations investigation Interim Report Dated January 25,1984

4.12 Allegation: " Foreign produced material purchased by Meddco Metals is alleged to have been inappropriately used as domestically produced."

4.12.1 Status The investigation team is in the process of reviewing project documentation to determine if there is evidence to substantiate the use of foreign material in' lieu of domestic material. A review of what is currently believed to be all of the i

Diablo Canyon project certified material test reports incidates that only domestic material was purchased by Bostrom-Bergen/Meddco Metals. In fact, one nonconformance report (NCR 2311-118) was issued to identify on instance where Japanese-produced steel was inodvertently used for fabrication of Disio Canyon materials. In this instance, the material was dispositioned reject and downgraded l to non-nuclear sofety related. It should be further noted that substantial evidence has been presented to date indicating that the nonconformance control system

implemented by Bostrom-S.w./Meddco Metals via the use of " Hold" togs and t "Nonconformance Reports" odequately identified suspect material (refer to Paragraph 4.11, above).

4.12.2 Tentative Conclusion ,

Evidence exists to indicate that only proper (domestic) steel was utilized by 4 .

Meddco Metals, and that the quality system in place was sufficient to control the inadvertent use of improper materials. Investigation continues to reach a final l

conclusion regarding the validity of this allegation.

1 Pocific Gas and Electric Company 22

%{ g i Bostrom-BergeVMeddco Metals Allegations investigation muumuuuuumme Interim Report Defed January 25,1984 i

q 3. V 4.13 Allegation "A shop worker serged point off of an accepted item and found the word ' BAD' on it."

4.'13.1 Status 1

The team's investigation of this allegation is proceeding in accordance wittr the investigative gproach outlined in Paragraphs 4.9,4.10 and 4.11, above. Tete, there-is no evidence which confirms this ollegation. The investigation team is in the process of abtaining further clarification of this allegation from the individual stating the allegation. .

4.13.2 Tentative Conclusion As previously discussed, substantial evidence exists indicating that systematic controls were in place for the control of non-conformances. Further investigation is required to determine the validity of this allegation.

4 4.14 Other issues 4.14.1 Charpy Test Reports i During the course of the allegation investigation regarding certified material test i reports / material test laboratory reports, the investigation teorn identified some material test laboratory test reports which contained Chorpy impoet test results i lower than that specified in the governing specifications. Investigation into this j issue reveoied the following:

4.14.1.1 The questionsle Charpy impact test reports were isolated to miscellaneous A36 steel procured by Bostrom-Bergen.

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4.14.1.2 The locations of Bostrom-Bergen/Meddco Metals supplied

! material have been identified of the Diablo Canyon Power Plant.

Pocific Gas and Electric Company 23 6.4 ( k a Bostrom-Bergen/Meddco Metals Allegations investigation summmmmmmel Interim Report Dated January 25,1984

Engineering has performed an evaluation of Charpy 4.14.1.3 requirements for the Didio Canyon Power Plant. ,

This evolvation determined that the requirements for Charpy impoet testing were provided in the specifications and design drowings for Class I structural steel construction as follows: The specifications (8831, 883lR, 8833, 8833X, and 8833XR) required Charpy impact tests for selected structural steel included in the original contract scope. Subsequently, as the plant design evolved, the scope of work under these specifications increased to include additional structural steel.

The Charpy requirements for this odditional work were defined by either referring to the original specificottons or by modifying requirements by notes on the design drawings, e.g.,"Charpy tests for information only".

It is to be noted that the specifications' acceptance requirements for Class I steel structures and substructures designed to the AISC Code required material Chorpy test values as established by engineering. The requirements originally estab!!shed ,

for carbon steel were 15 foot-pounds average for three test specimens and 12 f l

foot-pounds minimum for o single specimen. This is consistent with Section Vill of the ASME Code. The test temperature was specified as a function of materials locotion in service. This specification requirement was wolved by engineering

. with a note on the design drawing ("for information only") as it became known in the industry that the code requirements were unnecessarily stringent when applied to structural steel and were, therefore, being relaxed when certain conditions were met. For example, as the ASME Code further evolved, Charpy impact testing is exempted by Section lit, Subsection if, of the ASME Code, if t l

a. The design temperature exceeds ASME NDT Temperature by 30'F f
b. The steel thickness is 5/8" or less, or
c. The calculated stress is compression or less than 6 ksi tension.

5 24 Pacific Gas and Electric C.vpsay Bostrom Bergen/Meddco Metals Allegations Investigation  ;

L { g a ,

muuuuuuuume Interim Report Dated .lanuary 25,1984 1

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A review oh the Bostrom-Bergen documentation has demonstrated that essentially oil material supplied meets the prescribed requirements of the specifications or

&awings. The current ASME, Section lit, provisions are satisfied, except possibly for some minor substructures in the fuel handling building where the specified Charpy requirements were not met. For this building, the service temperature is l

substantially above the NDT and the portions of this structure fabricated by Bostrom-Bergen are limited to secondary steel, such as platforms located within the building, and not primary structural elements. It is tentatively concluded that this issue does not impact plant safety. Further investigation is continuing to fully resolve this question for materials in the fuel handling building.

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25 Pacific Gas and Electric Company

[;g g Bostrom-Bergen/Meddco Metals Allegations investigation ammmmmmmmmmmm Interim Report Dated January 25,1984

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SUMMARY

l Based on our review to date, there is no reason to believe that the quality of items '

supplied by Bostrom Bergen to the Diablo Canyon Nuclear Power Plant hos bee compromised. This belief is supported by the following:

9 e- The allegation investigation results to date.

e PGonE's continued quality control surveillance activities of, and experience with the Bostrom-Bergen/Meddco Metals organizations and facilities during the offected period of the allegotions.

PGondE will continue this investigation to reach a conclusive finding on the valid each allegation. PGond is further committed to take those actions necessary to any condition found which compromises the quality of safety related systems, struc and cwt.penents of the Disio Canyon Power Plant.

26 Pacific Gas and Electric Company Bostrom-Bergen/Meddco Metals Allegations investigation 6,% ( .4 6 4 WWWilmImimimmt i nterim Report Dated January 25,1984 i

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g 'h-T 9 4 Task: Allegation or Concern No. 98 fvr [r ru I -- fI

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ATS No.: RV-83-A-0085 BN No.

Characterization ,

A vendor in the nuclear industry (Brand Industrial Services Company, (BISdO) is improperly installing penetration seals. They may be involved at Diablo Canyon.

Implied Significance to Plant Design, Construction, or Operations Improperly installed penetration seals may fail during accident conditions, resulting in a failure to contain or limit liquid or gaceous effluents to a room or section in the Auxiliary Building.

Assessment of Safety Significance This allegation was received in Region V on December 2, 1983 and subsequently investigated and resolved in SSER No. 21 (dated December, 1983). The staff concluded in SSER No. 21 that BISCO had never performed any work either as a contractor or as a subcontractor at,Diablo Canyon. Subsequent to the writing of SSER No. 21, BISCO contracted with PG&E to work on 179 safety-related pressure seals at the Diablo Canyon. site. BISCO completed their contracted work on February 1,1984 and is no longer onsite.

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To resolve the allegation that BISCO improperly installed penetration seals, the staff examined the BISCO Quality Assurance Manual (BQAM), the BISCO quality control procedures, records of employee qualification and

' certification, records of completed work, and examined a number of the BISCO installed penetration seals. ,

The staff's examination of the BISCO Quality Assurance Program indicated that the program complied with the requirements of 10 CFR 50, Appendix B and ANSI N45.2, and that quality control personnel were certified and qualified in accordance with the program requirements. Examination of ten BISCO installed penetration seals in the Unit 1 Auxiliary Building did not reveal any discrepancy from the licensee and/or the BISCO requirements.

The staff's inquiry into the extent of the licensee's QA/QC surveillance of BISCO's in process work revealed that no formal audit or surveillance had been performed. The licensee's explanation was that BISCO's work scope was so liiited, i.e. for a short period of time, that a formal audit was not scheduled. However, the licensee is in the process of performing a quality control inspection of 5% of BISCO's work to verify proper installation of the l

pressure seals.

! Staff Position ,

The staff concludes that this allegation does not represent a safety concern at Diablo Canyon. This conclusion is based on the staff's review of the BISCO's~ quality assurance program, quality control procedures implemented

4 during BISCO's work at Diablo Canyon, and the field examination of the BISCO installed penetration seals.

. ' Action Required The licensee's audit results of BISCO's work will be reviewed during the

-regularly scheduled NRC Inspection program. "

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