ML20214Q590

Comments on Util Policy Re Employee Rights to Representation During Interview W/Nrc.Free Atty Svcs Provided During Interview

ML20214Q590
Person / Time
Site:	Comanche Peak
Issue date:	10/31/1984
From:	Griffin H NRC OFFICE OF INVESTIGATIONS (OI)
To:	Herr R NRC OFFICE OF INVESTIGATIONS (OI)
Shared Package
ML20214Q578	List: ML20214Q575 ML20214Q581 ML20214Q585 ML20214Q590
References
FOIA-86-180, FOIA-86-A-61 NUDOCS 8609260181
Download: ML20214Q590 (15)

Text

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UNITED ST ATES 5e . y$

' Y NUCLEAR REGULATORY COMMISSION '

N f-)/ oFrict oF INVESTIGATIONS FIELD OFFICE. REGION IV U.S. NEG Rg A DR . S,Ug UN

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3 NOV -5 PHepte%r 31, 1984 OT 'yS. CLOS

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MEMORANDUM FOR: Richard K. Herr ~ '

d H. Brooks Griffin FROM:

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SUBJECT:

TEXAS UTILITIES' POLICY REGARDING EMPLOYEES' RIGHTS TO REPRESENTATIGN DURING AN INTERVIEW WITH NRC INVESTIG On October 11, 1984, this rcporting investigator was in the process of interviewing TUGCO, Ebasco, and Brown & Root witnesses during the course of an NRC investigation into potential falsification This of QCinvestigation documents and related to intimidation.of a QC inspector (4-84-039). Following the interview transfer canal liner plates for Unit II at the CPSES.

of a millwright superintendent, an interview was requested with an Ebasco Services Incorporated employee who in March 1983 was a night shift A supervisor for TUGCO.that he had the right to have a representative The present with him d interview with 01, and said the utility had offered him a free attorney.

Ebasco amployee said he had accepted the utility's offer and had requested The an attorney, but said he was not acare when an attorney would be available.

ir.tcr.iew was suspended.

The reporting investigator questioned Anthony Vega, the TUGC0 QC manager,During the regarding the availability of counsel for the Ebasco employee.

course of the discussion, Vega explained that it was TUGCO's policy to offer the services of a free attorney during an interview with an investigator.

This investigator pointed out to Vega that it was the NRC's policy that a potential interviewee was entitled to a personal represen .

TUGC0 attorney. V6ga said it was TUGC0's interpretation of the NRC policyVeg I that the representative should be an attorney.to his subordinates that when N employees, the employees would be advised of their right to have aVega said the representative present with them during the interview.

employees were also advised that TUGC0 would provide and pay for the attorney.

This reporting investigator asked Vega whether attorneys were available on site, and Vega indicated that the applicant's attorneys were officed in Washington, D.C. Vega said arrangements would have to be made to haveVega an attorney present at the CPSES for those who desired representation.

. suggested that 01 furnish him with a list of all employees to be interviewed in advance so the applicant could advise them of their rights and they desired representation. ,

to 01. .

g2g1 860922 CARDE86-A-61 PDR

EGARDING f~

.?EXAI UTILITIES POLI

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• TMPLOYEES' RIGHTS TO REPRESENTATION DURING AN INTERVIEW WITH NRC INVESTIGATORS Page 2 The following week on October 16 and 17, 1984, this reporter interviewed three employees in the course of this investigation who had refused representation.

On October 17, 1984, this reporter spoke with Bruce Downey, a TUGC0 attorney from Washington, who had arrived at the CPSES a day early to debrief those interviewees requesting representation. Downey expressed annoyance over the fact that the subject of OI's investigation had already been explored by the ASLB, the TRT and TUGCO, and that the GAP version had been reported in the newspapers. Downey said he believed it was unfair to have the various divisions of the NRC (I&E, NRR, Region IV, and 01) separately question the same employees on the same subject. This reporter explained to Downey the needs of 01, and the distinction oetween an investigation and an inspection.

On October 18, 1984, three site employees were interviewed by this investigator with Downey acting as their representative. At the conclusion of the interviews Downey indicated that future interviews of site employees requesting representation would have to be scheduled in advance with his law firm to assure a representative would be present. Downey asked what time frame this investigator considered acceptable for arranging an interview.

This investigator expressed the opinion that normally a postponement exceeding -

one week would place an unacceptable burden on the NRC.

k' '60 H. Brooks Griffin cc: Ted Gilbert, OI:HQ File O e 0

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4-84-039 REPORT OF INTERVIEW WITH Sam BELL On September 20, 1984, Sam BELL, a Brown & Root, Inc. (B&R) Quality 1 Control (QC) lead, working for the Texas Utilities Generating Company (TUGCO) at the Comanche Peak Steam Electric Station (CPSES), was j interviewed by NRC Investigator H. Brooks GRIFFIN. BELL said he was j presently working in QC operations and had been a B&R employee at CPSES for 7 years.

BELL was shown a copy of an inspection traveler for weld no. 595 for the spent fuel pool liner plates and asked to comment on his signature and initials on the traveler. Based on his review, BELL said he believed he must have received a chit to conduct the inspection on November 30, 1981.

BELL said this led him to conclude that he also perfonned the inspection on that date.

Investigator's Note: The existence of a chit representing the above-described inspection was a presumption on BELL's part since no such chit was in evidence with the traveler.

BELL said the word " sat" was already written in the space in Category 7 on the traveler when he received it. BELL said he presumed the word

" sat" had been written on the traveler by a millwright (not further identified). BELL said that based on his review of the traveler he would guess the millwright had written the word " sat" on January 11, 1982.

BELL concluded that he probably received and signed the traveler en January 11, 1982, and had changed the date on the traveler to correspond with a chit.

m n RELL examined page 2 of the traveler, he identified the recorded date, November 30, 1982, as his writing. CELL said he believed he must have been referencing a chit when he changed this date.

e i

EXHIBIT (4)

4-84-039 REPORT OF INTERVIEW WITH Billie Ray SNELLGROVE On October.25, 1984, Billie SNELLGROVE, a Texas Utilities Generating l Company (TUGCO) Quality Assurance (QA) technical inspector at the l Comanche Peak Steam Electric Station (CPSES), was interviewed by NRC 1 Investigator H. Brooks GRIFFIN at the CPSES. SNELLGROVE said he worked ,

for Brown & Root, Inc. (B&R), from February 1979 until October 1982 as a j pipe support Quality Control (QC) inspector before he took his present position with TUGCO.

SNELLGROVE was asked to review four B&R stainless steel inspection travelers which contained nondestructive examination (NDE) requests

(" chits") bearing his signature (welds numbered 207,210,235,and236).

SNELLGROVE said he recognized his signature on the chits, and said his signature on these chits represented QC inspections he had perfonned.

SNELLGROVE stated that based on his review of the NDE chits, he could not explain which inspection step each chit represented beyond the fact that they were for fit-up and cleanliness. SNELLGROVE said that millwrights had issued the chits, and they had also maintained the travelers.

SNELLGROVE said he recalled that these chits were used as " simplified check lists." SNELLGROVE said he had no other recollection or information regarding the travelers or the chits.

EXHIBIT (5)

4-84-039 REPORT OF INTERVIEW WITH DON V0GT On October 23, 1984, Don V0GT, a senior Quality Control (QC) inspector for Stone & Webster Engineering Corp. at the River Bend Station (RBS) in St. Francisville, Louisiana, was interviewed by NRC Investigator H. Brooks GRIFFIN. V0GT said that he had been employed at RBS for almost 4 years. V0GT said he had been previously employed as a Brown & Root, Inc. (B&R) QC inspector at the Comanche Peak Steam Electric Station (CPSES) from November 1975 until he took the QC position at RBS.

V0GT was shown a number of B&R stainless steel liner inspection travelers which contained documents with his signature. After. examining weld no. 93, V0GT said that the chit contained in the traveler was used as a QC sign off for the first hold point of fit-up and cleanliness. V0GT said that QC inspectors were told by their supervisors to reserve the Category 1 fit-up and cleanliness for the seam weld (inside weld). V0GT said that he remembered that the original chits were stapled to the five hold point inspection traveler used during that period. V0GT said that chits were not issued for each of the five hold points described on the inspection traveler. V0GT said that at that time the inspectors were required to sign off the inspection step on the traveler. V0GT said there was an exception in the case of the fit-up and cleanliness (step one) on the traveler which was reserved for the fit-up and cleanliness inspection made in preparation for the inside weld. V0GT also said that he recalled that construction clerks handled the inspection travelers and wrote most of the information on the left side of the traveler regarding welding information.

On examining the inspection traveler for weld no.104, V0GT stated that the inspectors had started using the eight-step inspection traveler and that this traveler showed he had signed Category 1 on the traveler and also the chit for fit-up and cleanliness. V0GT said that for a weld on plate to imbed there was no channel, so Categories 2-5 were marked "not ,

applicable." V0GT said he believed that step seven of this inspection  !

l traveler contained a date probably entered by a millwright clerk. V0GT I said he believed that following his signature, he lined through the date the clerk had placed on the traveler and had entered the actual date of his inspection when he initialed the traveler.

After reviewing the inspection traveler for weld no.115. V0GT said he believed he had written the date for step seven which had been lined through by somebody (not further identified.) V0GT said that he did not know who had crossed out his date and entered a new date on the form.

V0GT speculated that there may have been a welding filling material control (WFMC) for steps six and seven for the later date entered on the inspection traveler. V0GT speculated that someone may have changed the traveler to reflect the date the rework may have occurred.

V0GT reviewed inspection travelers for welds numbered 126, 129, and 144.

V0GT said that on weld no. 126, he had changed the date for step seven.

V0GT said he also changed the date on a QC inspection on a penetrant test signed off by an inspector named FRIAR (not further identified). V0GT I

EXHIBIT (7) p

4-84-039 speculated that if the WFMC was checked, he believed it would probably show that rework had been performed on October 25, 1979. V0GT speculated that welds numbered 129 and 144 may also have received rework.

After examining inspecti6n traveler for weld no.154, V0GT concluded that someone had changed his inspection date to November 2, 1979, and then had changed the date back to the original date he had written on the form.

V0GT said he had no explanation for why the document had been changed.

After examining weld inspection travelers for welds numbered 248 and 250 V0GT concluded that the chits represented sign off on the step one of the inspection traveler. Af ter reviewing inspection travelers for welds numbered 263, 285, and 287, V0GT concluded that his sign off on the chits represented the Category 1 fitness and cleanliness acceptance.

After examining the inspection traveler for weld no. 62, V0GT said he had no explanation as to why he had signed the Category 1 on this traveler and had not done so on the others. V0GT also said he had no explanation as to why there was no chit to accompany this traveler for step one.

After reviewing inspection travelers for welds numbered 595, 591, 589, and 588,, V0GT concluded that his signature on the chits represented step one.

After reviewing inspection traveler for weld no. 563, V0GT stated that his signature on step one led him to believe there had been a procedural change requiring the inspectors to start signing step one on the travelers. V0GT said that on the inspection traveler for weld no. 592, he had signed both the chit and the traveler for the same inspection step for fit-up and cleanliness.

V0GT reviewed inspection travelers for welds numbered 536A-549A and ccncluded that he had signed both the inspection traveler for fit-up and cleanliness (step one) and had also signed a chit for the same inspections. V0GT also reviewed inspection travelers for welds numbered 1823-1826 and confirmed that he had signed off for penetrant tests on these inspections.

After reviewing inspection travelers for welds numbered 1803-1808, V0GT  ;

said that he had conducted some of the inspections of the penetrant tests included in these inspection travelers. l When V0GT was questioned about the inconsistencies found in the above inspection travelers, he stated that in 1978 and 1979 many QC inspectors were terminated. V0GT said that because of these tepninations he was not surprised to find that a great deal of the paperwork was left incomplete.

V0GT said the travelers on which the dates had been changed following his signature were probably for rework completed by the craft personnel.

V0GT indicated there should have been another inspection following the rework if, in fact, that is what had occurred.

[

EXHIBIT (7)

i 1

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1. Allegation Category: QA/QC 6, QC Inspection t

2. Allegation Number

i AQ-55 and AQ-78

3. Characterization:

l It is alleged that fuel transfer canal liner documen-

{ tation was falsified, that required weld radiography was not completed and that offhold points on inspection travelers for the fuel building were l

signed improperly.

! 4.

I Assessment of Safety Significance:

The NRC Technical Review Team (TRT) learned that the liner consists of a series of 3/16-inch-thick stainless steel plates welded together and attached to the inside of a concrete structure within the fuel building.

Transfer tubes at either end of the canal connect to similar fuel pools inside the Unit 1 and 2 containment buildings, which are also referred to as reactor cavities. The method of construction required that all vertical liner plates first be preas-sembled; concrete was then poured around the outside cf the plates. The plates hold the also had studs plates welded to the back and embedded in.the concrete to in position.

The plates were first joined to a backup bar on the back side with a 1/4-inch spacer temporarily attached between the plates to maintain a weld gap. -

cavity, ing concrete and concrete was poured around the outside backfill Follow-of the liner.A the back side became inaccessible. The1/4-inch final (wa-spacer ter side) seam was mac, hine welded after removal of the .

Plates out thatinch to 3/16 didornot handmaintain welding.a minimum gap of 3/16-inch required grinding g

3 years after the initial back side welds.The final seam weld was made as much as the seam welds were intended to be examined by dye penetrant testingAfter co ,

vacuum and dated box testing, and visual examination before the traveler was signed

The Final Safety Analysis Report (FSAR) for Comanche Peak includes a "Q" list components.

and (Table 17A-1), which identifies safety related structures, systems ,

assurance program in accordance with 10 CFR Part 50, Appendix quired.

The stainless steel pool liner is not specifically identified in that list as tion 2323-55-18, a "Q" (safety related) item; however, Gibbs & Hill Specifica-fuel pool liner, states that: Revision 3, dated April 6, 1979, paragraph . , 11 0 for the The contractor shall establish and implement a Quality Assurance

• Program which rigidly conforms to the applicable rules and standards as imposed by the Nuclear Regulatory Commission, 10 CFR 50, Appen-dix B, ANSI N45.2-1971, ANSI N45.2.9 (Draft 11, Rev. 0 - January 17, 1973), ANSI N45.2.10 (draft dated 1973), ANSI N45.2.11 (Draft 2, Rev.

2 - May 1973), ANSI N45.2.12 (Draft 3, Rev. 0 - May 2, 1973), ANSI N45.2.13 - NRC Extract (Draft dated May 31, 1973) and this specifi-cation.

fabrication, site erection,The program shall include pertinent aspects of procure storing and cleaning. inspection, testing, handling, shipping, Exhibit 17) 0-199

N i

The allegations refer to a period early in 1983, when the QC inspection responsibility for the liner plate welds was being transferred from ASME, Brown & Root (B&R), to non-ASME, Texas Utilities Electric Company (TVEC),

since the liner welds were not ASME-Code welds. In preparation for that transfer, B&R apparently noticed travelers that had missing QC signatures for hold points but that had been completed.

Part of the allegation was that a 8&R QC inspector was coerced into sign-ing 112 liner travelers that supposedly were inspected by another inspec-tor; that is, the other inspector had signed the inspection hold point some 5 years previously, filling out a chit documenting completion of the hold point, but not signing the traveler. The B&R QC inspector referenced the original chits as substantiation that the inspections had been com-pleted. According to the alleger, such sign off constituted falsification of the travelers since the chits did not contain adequate information to substantiate verification (signing) of traveler inspection hold points.

The TRT reviewed all inspection travelers for liners in the fuel building, plus selected travelers for the refueling cavity pool in the Unit 2 con-tainment building. The TRT located 47 inspection travelers related to c the Unit 2 refueling cavity liner, which were signed by two different in-spectors and for which hold point No. I had been signed-off out of se-quence (i.e., after later hold points had been signed off). A footnote was placed at the bottom of each traveler, stating: " Late entry per CP-QCI-2.11-ll, Para. 5, see Note. Refer NDE [ nondestructive examination]

chit attached documentation." The footnotes were signed by the inspectors and dated in early March 1983.

The TRT found the " chits" referred to in the traveler footnote attached to the travelers. Most of the chits were dated in late 1978. The d CP-QCI-2. ll-11, Para. 5, " Note" referred to states: "The QC Inspector shall use information on the NDE Report chits to epdate Attachment 4-A

[i.e., the inspection traveler] daily and subsequently forward the NDE request chits to the QA vault daily as a status indicator."

The TRT noted that there appeared to be confusion in implenentation of -

procedures related to stainless steel liner inspection, as indicated by t'he following:

a. TRT review of CP-QCI-2.ll-ll, " Welding Inspection and Fit-up of Stainless Steel Liners," showed that the correct number for this pro- , ,

cedure was CP-QCI-2.11-1, although pages in the procedure used either number. However, the TRT found that procedure CP-QCI-2.ll-1 had been deleted from the QC manual on January 10, 1979, by B&R interoffice memo IM-16606. This procedure,.was replaced by procedure  :

g QI-QAP-10.1-4.

The TRT found two procedures numbered QI-QAP-10.1-4: QI-QAP-10.1-4,

" Request for Requalification of Welders by ANI," Revision 0, dated i l August 24, 1978; Jnd QI-QAP-10.1-4, " Welding Inspection and Fitup of d. I Stainless Steel Liners," Revision 0, dated January 5,1979. The sec- I ond procedure was replaced by QI-QAP-11.1-4, " Welding Inspection of Stainless Steel Liners," Revision 0, dated December 26, 1979. This t

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, procedure was deleted from the QC manual on January 15, 1982, and was then reinstated without change on January 26, 1982.

The TRT also noted that, beginning with CP-QCI-2.11-1 and continuing through QI-QAP-11.1-4, paragraph 3.1.1, these procedures required fit-up and cleanliness verification of the inside seam welds after con-crete placement as a QC hold point. Similar requirements were noted in B&R procedure Revision 1. 35-1195-CCP-38, Revision 3, and in QI-QP-11.14-6, which states that there was no procedural requirement for verify cleanliness (Reference 23).

b.

Texas Utilities Generating Company (TUGCO) procedure QI-QP-11.14-6 references B&R procedure 35-1195-CCP-38 for instructions on issuance and distribution of the inspection traveler and chit. However, CCP-38 does not contain such instructions; indeed, even the intent of the TUGC0 procedure is not clear, since the traveler and chit do not receive " issuance" and " distribution" in the usual sense.

c.

The use of the chit was introduced in B&R specification CCP-38 in Revision 1, dated October 21, 1977, paragraph 3.4.2, which stated:

"The form shown in Figure 3 [i.e., the chit] shall be used in the above noted hold points as notification to QC to perform inspection."

The QC inspector signed the chit after the inspection, providing craf t personnel ing them with a record of completing the hold point and allow-to proceed.

The chit was apparently intended to be used as a construction document, not as a QC record to document completed inspections.

chit, was deleted on JanuaryProcedure 10, 1979. TheCP-QCI-2.11-1, which referenced u superseding procedures, QI-QAP-10.1-4 but and QI-QAP-11.1-4, stated in paragraph 3.1.1: contained no reference to the chit, The QC Inspector shall inspect the following items during fit-up and Linerwelding of liner Inspection material upon receipt of the Stainless Steel traveler.

followed.] [A list of items to be inspected The chit was replaced in CCP-38 on August 14, 1978 by the inspection traveler in Interim Change Notice (ICN) No. 2 for Revision 2, and was reintroduced in CCP-38 by ICN No. I for Revision 3, dated July 26, 1979, and in QI-QP-11.14-6, Revision 1, dated September 8, 1982, both of which indicated that the traveler was to be used to notify QC to perform inspections and that the chit was to be used to record in- -

spection results for hold points not included on the inspection traveler attachments,(e.g.,etc).

examination of plates after removal of temporary January 10, 1979, Apparently, the continued use of chits after tions was not in accordance with the above procedures.as a primary mea d.

There were frequent to specification CCP-38. changes in the inspection traveler form attached Initially, the form was issued as part of CCP-38 on August 14, 1978, and showed five weld inspection hold points.

The use of five hold points was inadequate for plate-to- i plate welds, in that two fitup and cleanliness inspections of the .

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same gap were appropriate, but the use of five hold points allowed for only ona sign off. The form was modified to include eight hold points, one of which was an additional gap fitup and cleanliness inspection, and was reissued on April 18, 1979. The form was also reissued with minor revisions on May 23, 1979, July 26, 1979, June 22, 1982 (decreased to seven hold points), and September 7, 1982 (in-creased to eight hold points).

The TRT found that welding of stainless steel liners for the refueling cavity in the Unit 2 containment building was also the subject of noncon-formance report (NCR) M83-00795, issued on March 17, 1983, which stated the following nonconforming conditions:

a. "A random review of stainless steel liner travelers for Reactor II cavity liner welds has found required fit-ups/ cleanliness  ;

inspections of inside (water side) welds cannot be verified as l being performed."

b. " Quality of welds indeterminate."

c. "See attached sheet for welds randomly reviewed."

d. "Five hold tags applied."

This NCR was dispositioned and closed on March 23, 1983. However, the NCR was reopened and issued as Revision 1 on March 29, 1983, for the stated ^

purpose of changing the nonconforming condition, i.e. , the words " random" and " randomly" were deleted. In the opinion of the TRT, deletion of those words limited the scope of the NCR to the welds listed on the NCR, which was not the meaning of the original NCR. It appeared to the TRT that this revision was issued to avoid the investigation that the original NCR would have required. No explanation was provided on the NCR for revising the description of the nonconforming condition, and there was no indication on the NCR of the inspector's concurrence with the changed description. (The TRT has reviewed TUEC's testimony filed before the Atomic Safety and Licensing Board on November 27, 1984, regarding this subject, and does not accept TUEC's explanation that the revision was simply a matter of g word changes.)

The TRT learned that Revision 2 of the NCR was issued on August 13, 1984, for the stated purpose of deleting weld No. 1225 from the NCR. This was an additional change in the description of the nonconforming condition, ,

and also was made without explanation and with the signature of someone other than the original inspectors. This NCR was dispositioned as follows:

Subject welds are seam welds utilized to provide leak tightness of the liner. Acceptability of welds shall be based on vacuum ,

box and hydrostatic tests.

The TRT also reviewed NRC RIV Inspection Report 79-15, dated June 21, 1979, related to welding of the pool liners, in which the insp'ector concluded:

0-202

I g-The resident inspector. .has oecome reasonably sure that there

were difficulties encountered by the welders with water, moisture,

, j and in some instances with concrete on the weld surfaces, and that in some instances, the welds may not be completely sound inter-nally.

(, These welds, however, serve no strength purpose and need only be smooth and leak free, factors which are established by visual inspection, dye penetrant, and by vacuum box tests of the joint after it is complete.

y has no safety significance. The allegation, while prcbably true, j.

, Review of the stainless steel liner by the TRT mechanical and piping group is documented in Mechanical and Piping, Category 43. As indicated in that assessment, the liner is not safety-related, and the liner welds are con-sidered to be acceptable.

4

'tf The TRT then reviewed that part of the allegation re,garding the improper W sign-off of inspection travelers, including review'of material supplied

+ by the intervenors (References 14 and 16).

The TRT found certain recur-af ringcategories.

six irregularities in the inspection travelers which were grouped into

,'.7 The categories listed in References 14 and 16 were not Q,. -

specifically addressed by the TRT, because the TRT reviewed the travelers independently in forming their conclusions. In some instances, the items F# -

t identified in References 14 and 16 are similar to items noted by the TRT; h in other instances, the items did not appear to the TRT to be significant.

g ;; The following examples are typical, but not inclusive, of the irregulari-ties noted for liners in the fuel building (unless otherwise noted):

e Y ' a.

Travelers for Weld Nos.

h sg i were signed by a QC inspector on 12-4-81.595, 591, However, the 588,

" SAT"and 589, Dw dy [ preceeding the signature does not match the inspector's signa-g, ture on penetrant testing inspection forms attached to the trav-elers.

ng j It appeared to the TRT that sobeone entered " SAT" and cg g nature. on the travelers, then obtained the QC inspector's sig-the date i This inspector confirmed during an interview that this

( had occurred, and the TRT discovered a number of travelers in which " SAT" signature (e.g.,was written weld Nos. for Hold Point No. 5 with no inspector's 6, 15, 19, 34, 36, and 61 for Unit 2).

ki f( Also, Step 5 of the traveler for Weld No. 580, Dwg. WFB00831, had a signature and date of 8-5-81; then the date was changed to g4 li Weld Nos. and was initialed and dated "7-2-80." The traveler for "7-2-80" i

567, 568, 572, and 583 were similarly modified.

a The same type of corrections were noted on some NDE examination 9l

• j y

records (See travelers for weld numbers 60, 70, 104, 114, 126, 129, 144, and 580 for the fuel building). It appears to the TRT that dates were also pre-entered on some NDE examination records; however, the practice of pre entering the scheduled date was apparently required.

discontinued because of the number of corrections I

f b.

The traveler plete for Weld No. 564, Dwg. WFB00831, was signed as com-on "7-29-81."

l However, in reviewing the traveler before i

I

} 0-203

i -

t a

transmittal to the B&R QA files, the inspector apparently noted !L that vacuum box testing had not been completed. The vacuum box  ?- #

testing was performed on "8-26-81," then the signoff date for T weld completion was changed to "8-26-81," and the traveler was g .1 receipt stamped by 8&R QA files as "8-27-80 [ sic]." The TRT I '

noted similar occurrences on travelers for Weld Nos. 584 through !g 586, 558 through 563, and for 565 and 592. j $.!?NQ

c. The procedure numbers for the vacuum box and leak tests were  :/O v' s:

changed during construction of the liners; however, the numbers lJ on the inspection forms were not changed. Since the form was not i Mri; changed, the inspector was required to write in the correct pro- iQ cedure numbers, as shown on travelers for Weld Nos. 568 through 571, and for 573 and 575, dated July 2, 1980 and August 10, 1981.

W and signed by another inspector. However, travelers for Weld l139

+FA-Nos. 536A through 544A and 546A through 549A, with the same in-  !*_k.-

spector's signature, were dated in November and December of 1981. }*- TN.-

_._ and did not have the procedure numbers corrected. The procedure l numbers were corrected and dated separately in December 1981 and i, 5 January 1982, a few days before the travelers were received and i M. .

date-stamped by the B&R QA files. 3

d. Inspection travelers, 58, 60, 114, 115, 126, 129, and 144 had 5

the signoff dates changed without explanation, including, in

+

-yJ A tot, some instances, changes to first party inspector dates on the  ; _ :- -

of Se; NDE sheet. the ft i

]

e. In comparing weld rod issue dates with inspection signoff dates , 4 Three for 23 travelers, the TRT located one traveler (No. 62 for 2 which Unit 1) in which weld rods were issued on October 3, 1978, but m Ff.. y' graphy the fit-up and cleanliness inspection hold point was signed off -pP throug on December 14, 1978. . F.y. showed

. ,'. that t

f. The TRT also noted that inspection travelers typically had tne ' --

assess.

welding information completed on the left side of the form to identify the welder, weld filler material log, procedure, and The fue the hold point against which weld rod had been issued. However. leak te some travelers for welds that had welding performed and inspec~ .c tion hold points signed off did not have information as to

• elf 5,f- Q er, weld filler material log, procedure, or hold point (e.g.. y was not welds 410 through 540 for Unit 2). It is difficult to determ " the res what the requirements were for completing the lef t side of tF# r y,g, The pri traveler form, since the procedures that reference the form, '~g sign of identifyrequirementsforQCinspectorstosignoffholdpoi"Q 3 clude t but do not indicate how the left side of the form is to be use-- Apparen or if it is required to be used. ,.

inadequ

c . signed ,

g. In testimony filed on November 27, 1984, p. 21,041, TUEC state, 3.

that for the inspector to correctly sign hold point 1 as a 13 ,

IDEC re; entry, there must be verification that both inspections (105 4 . Wright c andoutside)havebeencompletedforaplate-toplateweld;],

This I

[datefor two chits, or one chit plus one personal inspection. tion of demonstrated by Unit 2 traveler No. 261,forwhtchholdpo'Nl,.

n 0-204

14 ,

n.

3ted - was signeo on "3-3:83," and which has two chits attached, one dated "9-28-78," the other dated "10-19-81." However, Unit 2 r c traveler Nos. 248, 250, 263, 331, 334, 335, 338, 341, and 346, wg M which were also signed on hold point 1 on 3-3-83 as a late entry,

'T -.; have only one chit attached, which substantiated the initial iro ( utside) inspection. The inside weld was completed in 1981 and/

2 or 1982, as indicated by weld filler material logs; therefore, a e , second cleanliness inspection before welding could not have been accomplished by the inspector on March 3, 1983. Additionally, bers' ' :

as these travelers have an NCR (M83-00795, dated March 17, 1983) p [ attached which states that the documentation required to support ough -

completion of inspection for the inside weld is not available.

Final sign-off of the traveler was completed after the NCR was dispositioned.

1981g 4 Based on the above, the TRT concludes that these ld in nSl travelers were signed off improperly, i.e. , without substantia-tion or personal inspection of the inside weld. The TRT does 1981 not consider this improper sign off to b'e falsification, as

! dure' . stated by the alleger, because of an apparent absence of an iaN intent to deceive. -The note entered by the inspectors on the and travelers indicated they were signing hold point 1 with sone reservation, and NCR M83-00795 further identified the lack of idnM ; i adequate documentation.

ery i

M,j A of total of 5,022 September inspection travelers related te the liners were issued as 14, 1984.

ie M ,j Of these, 1,209 were for Unit 1; 2,612 were for the fuel building; and 1,201 were for Unit 2.

te p Three lift gates in the fuel building fuel transfer canal had gate supports utf[f  ?. j!

which were welded to the liner. B&R specification CCP-38 required radio-offP 8 graphy for these Welds (Nos.

through 1826). Di e TRT located the 1759 through 1772; 1803 through 1808; and 1823

;j radiograph records. These records showed acceptance of all the above welds. Therefore, the TRT concluded j' that the required radiography inspection was completed. (This subject is b

3 assessed Mechanical and Piping, Category 41, allegation AQW-79.)

1 The fuel building fuel pool was filled and the liner was satisfactorily se ( leak tested on March 22, 1983 by Test No. XSF-055.

!1 4 5.

- Conclusion and Staff Positions: The allegation that required radiography 11 was not completed is not substantiated, since the TRT found records showing the results of radiography of those welds for which radiography was required.

ie ,

T j) The primary sign-off subject of this allegation was the falsification or improper of records i.e., inspection travelers.

i "

The TRT could not con' ed

- l clude that the irregularities noted constituted falsification, per se.

r Apparently, these irregularities occurred because of poor practices and inadequate inspection forms. Some travelers also appeared to have been "l signed off improperly.

i - TUEC representatives indicated that it was common practice for the mill-wright department to write " SAT" and, in some instances, the scheduled  !

• -? I

~

date for inspection of the completed weld on the traveler, with the inten- l tion inspected.

and of obtaining the inspector's signature when the weld was completed f Welding priorities apparently were then rescheduled and the pre entered dates were correctcd when the traveler was signed.

0-205 l

. _ g 1

b The TRT concludes that there are record anomalies apparent in the liner 0 plate travelers which are not adequately explained on the face of the I travelers (e.g., dates changed), which violate procedures (e.g., failure I 8 to transfer sign-off from chits to travelers daily), and which employ in- -

adequate traveler). procedures (i.e., confusion over the use of the five-line i-It appears to the TRT that the QC documentation relating to the liner plate .

l welds did not meet the standards expected of an effective QA/QC program ^/

or the standards required by Gibbs & Hill specification 2323-55-18, and ,

10 CFR 50 Appendix 8.  ;>

The TRTwith meeting discussed theon the alleger results of the assessment of allegation AQ-78 in a December 10, 1984, as documented in the meetin; transcript, beginning on page 166.

also transmitted to the alleger. A letter containing these results was j .'.

fi gf held on March 5, 1985, to discuss the results of this assessment.A . ;-k- w meeting issues or concerns were identified. No new j+ E

. & 4, Reference Documents: ;y a.. .

1. <

[ ,.:

Logbook pages for radiography of Weld Nos.1759 through 1772, 1803 2.

through 1808, and 1823 through 1826. .

< ,, e l

Signoff sheet for Test XSF-055, dated March 22, 1983.

3.

4.

Fuel Building Spent Fuel Pool Liner Details, 23235-0831 through -0834 D ' y. .

Fuel Pool Liner - Fuel Building Weld Map, WF8-00831.

5. B&R Specification lT

6. 35-1195-CCP-38, " Stainless Steel Liner Erection." .k B&R Procedure CP-QCI-2.11-1, " Welding Inspection and Fit up of Stain- f  :

7. less Steel Liners," with IM-16606, dated January 10, 1979.

Office Memorandum TUQ-2340, " Stainless Steel Liner Travelers Unit II.

dated September 11, 1984. r9-

.g-

9. :2u

9. Starview with a11eger A-3, pp. 60 through 89.

Bostrom-Bergen drawing 2401. " 'E T

10.

11. Testimony of alleger A-4, March 7, 1984, pp. 18, 19, 20.  ;

12. Testimony G&H of alleger A-3, August 1, 1984, pp. 59,516 through 59,536.

Specification April 6, 1979. 2323-55-18, " Stainless Steel Liners," Rev. 3, 13.

14. Deposition by C. Thomas Brandt, August 16, 1984 (Tr. 45,239-355). -

"1984 CASE's Evidence of a Quality Control Breakdown," dated September F.

15. ,

16. Prefiled Testimony of C. Thomas Brandt, October 3, 1984 (Tr. 45,356-P h;

" CASE's Further Evidence of a Quality Control Breakdown in the Con-struction, Installation 3 ggjg Plate," dated November and Inspection of the Stainless Steel Liner 15, 1984.

17. Testimony of C. Thomas Brandt, Tr. 15,629-697 (9/12/84); 15,978-10. , ,,,

,' Y@f (9/13/84); 16,728-777 (9/18/84); 17,264-363 (9/19/84); 20,569-774 Q 18.

(11/26/84); 20,778-21,091 (11/27/84). y.g Deposition by alleger A-3, August 1, 1984 (Tr. 59,516-536, 59,640-6,. 0 49 and August 2, 1984 (Tr. 59,773-825). ig 19.

Deposition by Alleger A-1,' July 31,1984 (Tr. 54,596-617). ?Mff

20. Deposition by Dwight Woodyard, July 24,1984 (Tr. 56,561-566). M, 21.

22. Deposition by Ted Blixt, July 25, 1984 (Tr. 57,015-036). g.g Deposition by Robert Siever, July 25, 1984 (Tr. 58,024-056).

0-206  ; 9 4 fr

?

-a u-E@

'id 23 Prefiled Testimony of C. Thomas Brandt, October 16, 1984 (Tr. 45,373).

24 Transcript of TRT Interview, December 10, 1984 (beginning on page 166).

25. NRC letter, D. Eisenhut, NRC, to M. D. Spence, TUEC, dated January 8, 1985.

26. Liner inspection travelers as noted in text.

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