ML20210E856

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Discusses Pullman QC Inspector Allegations Received on 831223 Re QC Participation in Welder Qualification Process. Deficient Condition Notice Encl
ML20210E856
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 12/23/1983
From: Padovan M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), PACIFIC GAS & ELECTRIC CO.
To: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML16341D666 List: ... further results
References
FOIA-84-744 NUDOCS 8603310001
Download: ML20210E856 (14)
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January 2,1984 Mr. Mark Padovan Resident USNRC P. O. Box 369 Avila Beach, CA 93424 Ir

Dear Mr. Padovan:

f This letter is the information we discussed in my Dec. 23 jg phone conversation with you. I was a quality control inspector for e

Pullman Power Products, Diablo Canyon from July 25 to Dec.15 of 1983 During this time I worked in the rupture restraint and piping

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support programs performing visual, dimentional, and welding inspec-K tions in unit I and unit 2

  • Dates mentioned in this report before Dec. are approximate because all paperwork including personal notes, inspection logs and memos were confiscated by Pullman. Information copies of the doc-uments that I needed to properly make this report were flatly denied by Pullman.

However, should you find that this report has no legal standing without that data: could the NRC make those papers avail-able to me so that I may assemble a legal report?

The allegations in this report have serious consequences.

The inctdents are presented in a chronology to show how Pullman provided for evaluation of deviations presented by myself and others.

Sept 20

1. Deviation from the requirements of contract specification 8711.
2. Failure to notify purchaser (PG6E) of past and present devi-ations .
3. Failure to notify the' Commission as required by 10 C F R 21.21 b) l Addressed memo to Harold Karner, Pullmarts Q A manager, re-i garding PG&E's contract specification 8711, Sec.1, Para 7.10.1.

The contract stated that all GTAW shall be performed with a power supply equiped with 1) High frequency for arc initiation, 2) Rheostat for stepless control of current.

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.Iater on, in the afternoon, after observing more testing ~

with no QC participation I walked into the small office area and struck up a conversation with the production foreman, Art Savacou.

I asked Art where the QC inspector was at. Art replied they didn't have one at the moment but that he and Pat Watson had Ihn understanding." I thought that was pretty interesting so I asked Art if he was qualified as an inspector. Art replied no.

Dec. 9 m

1. Failure to provide for assurance that all prerequisites for bMk, 17. testing have been met, violation of 10 C FR 50, appendix B, criteria XI.

3 I learned this morning that the QC normally assigned to

%g U e welder qualification tests had quit on Dec. 7 at 09:00. Af-further observance of tests being performed with no QC inter-action, I checked the requirements of Pullman's Quality Assurance Manual and reviewed the stater 5ents in ASME,Sec III.

Wrote memo to Pat Watson, the area 10 leadman/ welding qualification supervisor, noting that Bill Bailey was gone and that I had observed an apparent lack of QC participation in the testing.

I reminded Pat that the QA Manual's paragraph KFP 15.2 specifically stated that a field inspector shall be assigned to the test shop and that ASME, Sec III, paragraph NA 3764.1 d would not allow a production foreman to determine the quality of production welders.

When Pat cane on his walk through the fab shop I handed him the memo. Pat after reading the memo would not accept it and walked off. Sometime later Pat returned and finally accepted the memo.

At approximately 14:00, Frank Lyautey and Chris Neary ap-peared and wanted to know what was going on. Frank is the as-sistant QA manager and Chris is Pullman's welding engineer from Williamsport, PA. I related the story and told Frank that I had 1

notified the proper person in the chain of command about the ap-

' parent discrepency. Frank explained that Bill Bailey had quit and that a new inspectg was scheduled to start in the welder qualifications on the 12 .

In the absence of either inspector, Pat Watson was performing duties as field inspector in the test shop.

I admitted to Frank that I had seen Pat Watson in the test bay twice on Thursday, the 8th, but that for the majority of the time I had noted no Frank assured me there 10

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was no problem and then Pat Watson joined us and he assured me the inspections had been performed. I asked Pat what his inten- .

sions were regarding the welders I had seen qualifying with no QC around. Pat said he had no requalification tests in mind be-cause there was no quality problem. Frank then asked me to join Chris Neary and add any comments I had to Chris' revision of Pullman's rupture restraint welding..

My discussion with Chris covered his intensions to:

1. Restrict application of WPS 7/8 to the original joint design shown in the PQR. (Note that there is no joint shown in the PQR but only a reference to sheet 2 of 10 ?)

2.Use of prequalified procedures for all other applications.

After examination of Chris' notes I brought up the point that he intended to use the same eight or nine prequalified joint designs they had been using before but that he was still grouping them all under one procedure number, AWS 1.1. I said this could be con-fusing and that it did not appear to satisfy the requirement of a written procedure for each procedure. For instance, how can a single bevel corner joint have the same written procedure and num-ber as a double V butt weld that requires back grinding and welder access from both sides ?

I reminded Chris that under AWS Joint design is considered an essential variable. Chris did not see that this was a problem.

Dec . 12 I reviewed the events leading up to the confrontation on the 9

and determined that there still existed some doubt as to wether the qualification tests had been performed properly. Frank Lyautey and Pat Watson had personally assured me that there was no prob-lem, vet, they had not willingly showed me evidence of the in-spection records. In my own mind several questions remained to be answered:

l I 1. Why had I observed the qualification tests being per-formed with no QC including Pat Watson present?

2.Why did Art Savacou the production foreman who had ap-peared to be running the show refer to an " understanding" j with Pat Watson.

3. Did Harold Karner know of the problems I had witnessed in the test shop.

f 11

T I refered to the QA Manual and found instructions that said the QA manager was to be informed of problems affecting s quality. I initiated DCN 1/1640-021 that told of what I had ob- ,

auj- Me.3 served and that it appeared Pullman was perfonning work outside '

' the scope of its own QA Manual. The Deficient Condition Notice hla/d required an engineers signature to be submitted so I asked Mike, the area 10 engineer, to cosign the DCN.

Mike declined to sign the DCN because it showed no hard evidence of a hold point being passed. Mike did say, how- 8 ever, that if I did provide evidence then he would sign the DCN.

Dec .13

1. Failure to provide inspector access to records showing that a function pertaining to quality was adequately per-formed, in violation of 10 CFR 50, a p p e nd ix B, cri-teria I.

After informing RR engtneer Dale Warren that I would not accept their previous performance of a stich weld observed on the construction of square beams, I decided that I would inspect the records of the test shop during the time of Bill Bailey's ab-sence.

I went to the test bay and explained to Art Savacou that I had reason to doubt that the welder qualification test surviel-lance inspections i.e. materials, process, position, fitup, root-pass, WPS parameter verification, final visual, bend tests had been performed.

Art refused me access to the records saying that only his -

direct supervision could look at the records. I informed Art that by doing so he was denying a QC inspector the right to inspect records . Art's reply was "what are they going to do- put me in jail? "

I left the test bay and contacted Pat Watson asking to see his records for Dec. 7,8,69 concerning welder qualifications.

After some discussion Pat showed me what he had, the records showed a summary of the welders who had qualified, who passed, who failed. I told Pat 'that this was just a summary and that the records did not show wether the required inspections had been performed. Upon leaving, I reminded Pat that I was still waiting for a written response to the memo.

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I raws scri E M ch ') o 4 nJ ap Lum 8 C46 STEVEN LOCKERT - 1/16/84 0

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s u KIRSH: The date is January 16, 1983, the time is 7:02 pm.

This is an interview of Mr. Steve Lockert, a concerned citizen.

Individuals present are Dennis Kirsh, NRC, John Clewett of Government Accountability Project, and Steven Lockert, the concerned citizen. In order to make it more readily apparent to 3

the transcriber who is talking,'my name is Dennis Kirsh and the other two individuals will identify themselves for your information.

+ LOCKERT : My name is Stc,e Lockert.

CLEWETT: And my name i John Clewett, f rom G.A.P.

KIRSH: Okay, with those formalities over with, let's begin with other additional information you have to give me, Mr.

'f Lockert.

CLEWETT: Okay, well I guess the main thing that we are hoping to do, or to start with at least, is to ao through ...

KIRSH: This is Mr. Clewett, speaking.

CLEWETT: S'o rry, yeah, John Clewett ... make corrections on the copy of ~ the letter to Mr. Padawan of the NRC that we gave to you, Dennis, on I guess it would have been what, about a week ago

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or so, when we met with you, because at that point the dates were constructed from memory, so that the first thing we hooe to do is I to be able to correct that by reference to the documents that you

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, got from the Pullmsn Company.

j KIRSH: Okay. Can we go through this date correction very quickly, or is going to.take some time to go through the 7

Lockert/1-16 1 l(,0 .

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LOCKERT: I'm checking my notes. Yeah, let's make that an approximate date.

KIRSH: Okay, that's fine. Also, on page 9, December 8th date, on page 9. Mr. Lockert believes this date is correct.

Likewise, on page 10, the December 9th date, Mr. Lockert also 4

believes this date is correct. Page-il, the December 12th date, Mr. Lockert also believes this date is correct. Page 12, December 13th date, Mr. Lockert also believes this date is correct. Page 13, December 14th date, Mr. Lockert also believes this date is correct, and on page 13 also, the December 15th date. Mr. Lockert also believes this date is correct. In addition, Mr. Lockert supplied f rom his copies of the documents that I obtained from Pullman, a number of DCNs wherein the field engineers would not sign and accept these gggp Ng,3 k3 /w - DCNs. The DCN numbers are 1/1640-016, 013, 015, 020, 021 and 022. Okay, is that ... does that basically summarize what we had talked'about earlier while we wer'e off tape and we were going through your files, Steve?

LOCKERT: Yes it does.

CLEWETT: Steve, what do you think is the ef fect of the import of not being able to find some of these things in your dailies that you referred to you in your report?

LOCKERT: Oh, it's probably mostly my own ... for not havino a good enough record within my own notes that I was unable to find that. There are some pages missing here, but....

CLEWETT: From your dailies or from your....

Lockert/1-16 5

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, UNITED STATES OF AMERICA -

l BEFORE THE NUCLEAR REGULATORY C0f911SSION

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In the Matter of ) M pe4Ae*,ocskha l PACIFIC GAS AND ELECTRIC COMPANY Docket No. 50-2  % gev's.fe.ca.cu+ $

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(Dia'bl6 Canyon Nuclear Power Plant.

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j Pursuant to 10 CFR 2.206, on behalf of the San Luis Obispo Mothers for -

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!< Peace (Mothers) the Goverrnent Accountability Project of the Institute for Policy l

l Studies (GAP) petitions the Nuclear Regulatory Cocaission (NRC or Comission) to '

. defer any decision on whether to grant a low-power operating license to the Diablo Canyon Nuclear Power Plant (Diablo Canyon or DCPP) until' completion of -- l l . i (1) a comprehensive, third party reinspection program of all safety-related l construction in the plant, with full authority by the independent organization to  !

identify and impose corrective action. on any nonconfonning condition that deviates from 10 CFR 50. Appendix 8 - the Final Safety Analysis Report (FSAR) or plant specifications, through implementation of corrective action. ,

(2) an independent audit of design quality assurance, including the reliability of conclusions from remedial design verification programs imposed since 1981 such as the seismic design review;,

(3) development of a full factual record on Pacific Gas and Electric's (PG&E) character and competence to operate the Diablo Canyon nuclear power plant, including.

r (a) a management audit by an independent organization, and i

1 (b) publication of a report by the NRC Office of Investigations (01)  !

following a full investigation to determine the causes of construction and design +

E QA violations at Diablo Canyon, including issues such as harrassment and retaliation, ,

subordination of quality assurance to cost and scheduling concerns, destruction of l- records and false statements, and deliberate violations of the Atomic Energy Act; and . , _

- (4) a full program of public participation for the selection and oversight

.of independent organizations described in #1-3 above, including NRG review and approval of inde#ndent organizations. from nominations submitted b1either PG&E or any interested member:of the public, and creation of a public orersight comittee consisting of equal. representation by state and local representatfies and the -

intervenors with the authority to obtain all requested information and to conduct  ;

1egislative-style public oversight. hearings. -

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s the case for the procedure covering installation of pipe rupture restraint bolts, as a QC inspector learned in October 1983 den he inspected those bolts in Unit II. (Attachment 3, at p. . A9.)  :

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[ t 2 119. QA management did not take prompt action to inform inspktors of cha es in acceptance criteria. -The result is that an unknown number of inspections were conducted to the wrong standard. An example involves hardened steel washers. On November 8,1983 Mr. Lockert learned that the criteria had been-changed and promptly notified QA manager Karner. The result? As of December 15, 1983 the relevant engineering specification had not been changed, and the other inspectors still had not been notified of the new criteria.

(Id., at p. A9).

I. Generic breakdown-in disclosure system for QA violations.

On June 24, 1983 the NRC staff' issued a Notice of Violation to PG&E for taking almost five months to notify the NRC through issuance of a Nonconformance Report (NCR) that an inspection had found ten welds whose quality could not be verified as required. Under contract specifications, the condition should have been reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The staff routinely could issue similar Notices of Violation, because the practice was routine. "Through a gauntlet of interim reports and required approvals, the Pull _ man QA program is structured to inherently block or delay disclosure to the NRC of nonconforming conditions. When internal disclosures survived j

the formal institutional roadblocks, managers took another approach: " void" l the reports and throw them in the trash. In most cases this was unnecessary, I .

because training for reporting violations was deficient. Not all pspectors were even informed of their right to issue NCR's, or where the forms are located.

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i 120. Inspectors wishing to issue a Nonconformance Report cust navigate o convoluted mze of interim reports and appmvals*that inherently delay _

First, the inspector must file a " Discrepant fondition closure to the NRC. T' -

PG&E does not see the report, which remins within! r: Pullman's Notig " (DCN).

An inspector cannot even issue the report without crhization at that stage.

l also obtaining the signature of a lead an, and often an engineer from the '

n 3 Mr. Karner can void this report or order corrective pmduction department. Once .

action such as rework without sending it to PG&E for dispositioning.

A DR finally received by PG&E, the DCN is called a Discrepancy Report (DR). C becomes a None'onformance Report only when PG&E decides to sen d

i Under these circumstances, both organizational freedom for QC inspectors

4. at prompt disclosure '.of violations to the NRC are impossible. (Attachmen
p. 6)

I 1 21 .

Pullman failed to adequately train its QC inspectors to report The lecture portion of the program does not include prepar-QA violations.

One veteran inspector still,onsite reports that until the ation of DCN's.

NRC came to interview workers in January 1984 he didn't even know He added that "we never have been told, orally had the right to prepare NCR's.

Report..., nor or in writing, about how to fill out a Non-Confonnance /si@

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would I have any idea where to get a blank from an NCR."(Id..at p. 8.

construction personnel do not even have access to the 122. G&

They formal nonconformance reporting system, outside the QA department. h I

canhot issue Nuclear Plant Problem Reports (NPPR), which can even Only employees in the Nuclear hlant Operations qk the Nuclear Regulatory Comission. i-Other employees must be content to report (NPO) department can issue NPPR's.

affidavit of John Cooper and (See_ January 23, 1983

. violations through memos.

exhibits, enclosed as Attactnent 6 at p. 20.)

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y 123. Management during 1978 instructed control technicians not to

/ . .

/ write NPPR's without prior approval- from a foreman, according to notes from a shop log. (Attachment 6. Exhibit 12.) h!.

r 1 124. PG&E management arbitrarily swept problems under the rug by viiding NPPR's without- explanation, as occurred in at least eight cases identified on February 23, 1979 in theJhop log. In other instances during 1978 and 1979, Mr. Cooper reports that NPPR's simply ~ disappeared."

125. In other cases management ordered construction personnel not to write problem reports without prior approval. On July 13, 1978 Mr. Cooper's foreman imposed this prohibition. (Id., at p. 24.)

J. Generic breakdown in organizational freedom for QC personnel to conduct inspections Quality control inspectors must have the freedom to identify quality problems without restrictions. At Diablo Canyon the Pullman QA management attempted to keep inspectors ignorant and on a tight leash. QA managers denied access to relevant professional codQ and standards, and also restricted the movements of inspectors known for identifying problems.

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