ML20215C646

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Forwards Summary of Ofc of Investigations Rept, Vogtle Nuclear Plant - Alleged Intimidation/Harassment of QC Welding Inspectors & Possible Falsification of QC Insp Records by Pullman Power Products,Inc
ML20215C646
Person / Time
Site: Vogtle, 05000000
Issue date: 09/09/1985
From: Uryc B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Scott E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20215C570 List:
References
FOIA-86-42 NUDOCS 8610100386
Download: ML20215C646 (8)
v • d • e


Text

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e UNITE 3 STATES

  1. g neseq'o, NUCLEAR REZULATCY COMMISSION

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REGION il o

3 101 MARIETTA STREET,N.W.

f ATLANTA, GEORGIA 30303 os.,...../

SEP 0 9 25 MEMORANDUM FOR:

E.

Scott, Record Assistant Office Services Section Administrative Management Branch Division of Resource Management and Administration T!!RU :

J. Lankford, Chief, Administrative Management Branch Division of Resource Management and Administration i

FROM:

B. Uryc, Investigation / Allegation Coordinator Enforcement and Investigation Coordination Staff

SUBJECT:

DOCUMENT TO BE PLACED IN PUBLIC DOCUMENT ROOM The enclosure is a summary of an investigation conducted by the Office of Investigations, Region II Field Office.

The subject of the investigation is "VOGTLE NUCLEAR PLANT - ALLEGED INTIMIDATION /

HARASSMENT OF QC WELDING INSPECTORS AND POSSIBLE FALSIFICATION OF QC INSPECTION RECORDS BY PULLMAN POWER PRODUCTS, INC."

You are re-quested to forward this document to the appropriate public document room.

The original of the enclosed document is being retained in the files of the Office of Investigations, NR,W ington, DC.

Bru o Uryc

Enclosure:

Cover Page and Summary, dated 10/26/83, 7 pages cc w/ enc:

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FILE ORIGINAL IN:

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EA FILE MAKE COPIES FOR:

bb REVIEWER REVIEWER

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AXELRAD TAYLOR VOLLMER VI LIEBERMAN(ELD)

JORDAN 9

PARTLOW GRIMES GAGLIARDO EISENHUT(NRR) '

CHAPELL(NMSS)

ZWOLINSKI(NRR)

R, BURNETT Thank you, Jane A. Axelrad, Director Enforcement Staff IF YOU HAVE C0ffiENTS, PLEASE CONTACT REVIEWER OR J. AXELRAD WITHIN FIVE DAYS IF AT ALL POSSIBLE.

SEP 121985 Georgia Power Company ATTN: Mr. R. J. Kelly Executive Vice President P. O. Box 4545 l

Atlanta, GA 30302 I

Gentlemen:

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SUBJECT:

PLACEMENT OF DOCUMENT IN PUBLIC DOCUMENT ROOM l

Enclosed is a sumary of an investigation conducted by the NRC Office of Investigations, Region II field office. The subject of the investigation is "Vogtle Nuclear Plant Alleged Intimidation /Harrassment of QC Welding Inspectors and Possible Falsification of QC Inspection Records by Pullman Power Products.

Inc." This Document has been placed in the Public Document Room and may be of use to you ir; preparing for the conference on September 25, 1985.

Sincerely, ORIGINAL SIGNED BY ALBERT F. GIBSON J. Nelson Grace Regional Administrator

Enclosure:

Cover page and sumary, dated 10/26/83, 7 pages cc w/ encl:

R. E. Conway, Senior Vice President Nuclear Power D. O. Foster, Vice President and General Manager Vogtle Project H. H. Gregory, III, General Manager, Vogtle Nuclear Construction G. Bockhold, Jr., Vogtle Plant Manager L. T. Gucwa, Chief Nuclear Engineer Ruble A. Thomas, i

Vice President-Licensing Vogtle Project cc w/ encl:

(Cont'd on page 2)

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4, Georgia Power Company 2

SEP 12 1985 cc w/ enc 1:

(Cont'd)

Ed Groover, Quality Assurance Site Manager C. W. Hayes, QA Manager J. T. Beckham, Vice President

& General Manager - Operations J. A. Bailey, Project Licensing Manager George F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge Bruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge Ernest L. Blake, Jr., Esq.

Shaw, Pittman, Potts and Trowbridge James E. Joiner, Troutman, Sanders, Lockerman and Ashmore James G. Ledbetter, Connissioner Department of Human Resources Charles H. Badger, Office of Planning and Budget, Management Review Division Deppish Kirkland, III, Counsel Office of the Consumer's Utility Council Douglas C. Teper, Georgians Against Nuclear Energy Laurie Fowler, Legal Environmental Assistance Foundation Tim Johnson, Executive Director Cducational Campaign for a Prosperous Georgia Morton B. Margulies, Esq., Chainnan Administrative Judge, Atomic Safety and Licensing Board Panel Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel Gustave A. Linenberger, Jr., Administrative Judge, Atomic Safety and Licensing Board Panel

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NUwoEAR CE2ULATORY COMMIS$13N uNrTE] str.Tas ENCLOSURE g

OFFICE OF INVEST 6 CATIONS FIELD OFFICE, REGION 11 g

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Date: October 26, 1983 REPORT OF INVESTIGATION i

TITLE:

V0GTLE NUCLEAR PLANT ALLEGED INTIMIDATION / HARASSMENT OF QC WELOING INSPECTORS AND POSSIBLE FALSIFICATION OF QC INSPECTION RECORDS BY PULLMAN POWER PRODUCTS, INC.

SUPPLEMENT:

50-424 CASE NUMBER:

2-83-005 C0h7ROL OFFICE:

01: Region 11 STATUS:

CLOSED REPORTING OFFICE:

OI: Region II PERIOD OF INVESTIGATION:

May 19 - July 9, 1983 REPORTING INVESTIGATOR:

444 R(ben H. Bu k Investigator Office of Investi tions Field Office, Region II REVIEWED BY:

E.'L5Williamsd,Ac[ingDirector g

OfficeofInvestiqtionsFieldOf.ce,RegionII lA4f Ybfbut1 i

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-v WilliamJ. Ward [ Director Division of Field Operations Office of Investigations U

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Roger } tuna,DeputyD e tor Of of Inve ati APPROVED BY:

M N B. Hayes, h torf Office of Investi atic6s f'

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This investigation was initiated to identify and document alleged intimidation and harassment of Pullman Power Products, Inc. (PPP) Quality Control (QC) welding inspectors by the company's construction management personnel.

PPP, head-quartered in Williamsport, PA, is under contract to install all piping and piping supports associated with the construction of the Alvin W. Vogtle Nuclear Plant (VNP), in Wdynesboro, GA, e licensed facility' of the Georgia Power Company.

Additionally, it was reported to the NRC that the intimidation and harassment experienced by the QC welding inspectors may have resulted in possible improprieties regarding inspection records prepared and maintained by these individuals.

The allegation pertaining to intimidation and harassment of QC welding inspectors by the Project Manager at the VNP was first reported to the Senior Resident Inspector (SRI), NRC at the facility. This initial allegation was substantiated by the SRI'during the subsequent interviews of four additional QC welding inspectors employed by PPP.

Additionally, a Confidential Source alleged vast PPP material storage problems, records improprieties and incidents of intimidation by the Project Manager and his construction superintendents.

The SRI obtained information that QC inspectors were being manipulated by the Project Manager through threats relating to adverse personnel actions affecting employment and l

salary matters. Additionally, the Project Manager allegedly interfered with the utilization o,f QC welding inspectors and attempted to influence the reassignments of inspectors whose work histories did not favor production and scheduling. An onsite incident of assault in August 1982 upon a QC welding inspector by a

~

'donstruction superintendent, both employees of PPP, was also reported to the SRI.

A review of pertinent regulatory documents, standards, procedures and contract requirements was conducted pursuant to the investigation.

It was disclosed that PPP committed to cooperate with the licensee to ensure QC standards for the VNP are enforced at all times.

Further, this review disclosed that the line of authority regarding administrative matters for the QA/QC manager at the field office site of PPP is through the Project Manager.

It was cetermined that PPP or l

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a subsidiary company was the subject of previous-inguiries regarding intimidation

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and harassment of QC inspectors at the Seabrock Nuclear Plant, Seabrook, New Hampshire and at the Diablo Canyon Nuclear Plant, Avila Beach, California.

A licensee initiated self evaluation in late 1982, utilizing Institute of Nuclear Power Operations (INPO) criteria, identified that the QA/QC administrative reporting to the Project Manager is an area of weakness in the PPP field organi-zation.

During the investigation, nineteen field level QC welding inspectors in PPP's field office at the VNP were interviewed Yegarding intimidation and harassment, interference by the Project Manager and inspection records improprieties.

Five of these individuals confirmed vast material storage deficiencies which are compounded by the overt refusals on the part of construction management to divert craft efforts to correct the problems.

These inspectors viewed the construction superintendent's negative attitude toward Storage Inspection Report deficiencies as a forr. of intimidation.

Some of these inspectors also related instances of interference and intervention into QC inspector assignment matters by construc-tion management to favor scheduling and the production effort.

All except one of the QC inspectors interviewed reported variously that the Project Manager has attempted to influence the utilization of, and decisions rendered by, inspectorsr ~

that the salary administration and other benefits fo'r QA/QC personnel controlled by the Project Manager is unfair and inequitable; that he arbitrarily adjusts -

recomended salary increases based upon subjective criteria; that he is frequently publicly non-supportive 'and negative towards the QC function; that he anc construction superintendents publicly chastise and embarass' inspectors and that he employs remarks which threaten job security as a means of intimidation

'lind harassment. The lone dissenting QC inspector was det'errtined to be a personal friend of the Project Manager and had been the recipient of preferential treat-l ment regarding a job assignment on site.

Those inspectors with knowledge of an onsite altercation, in August 1982, between a former PPP Construction Super-intendent and a QC Welding Inspector indicated that the superintendent disagreed t

with the inspector's perception of the non-conforming item being discussed.

One inspector reported an offsite altercation in December 1982 between a Construction Superintendent and a QC Inspector Supervisor during which the superintendent held an open knife on the QC supervisor.

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3 Two current and one former QC supervisory personnel were interviewed and each substantiated the claims and perceptions of field inspectors regarding incidents and acts of QC negativism by construction managers, intimidation, harassment, adverse interference, verbal threats, embarassment and chastisement of these individuals by the Project Manager and his subordinates. All of these individuals indicated that production and scheduling appear to take precedence cver the quality functions, an attitude nurtured by the Project Manager and his-construction staff.

Authorized Nuclear Inspectors at the VNP also confirmed intimidation and harassment of QC welding inspectors by PPP construction manage-ment.

]nquiries were also conducted among the OC inspection personnel who allegedly engaged in visual inspection practices which were not in accordance with existing procedures or who signed inspection reports without assuring corrective actions had been completed.

One QC welding inspector admitted that he occasionally failed to conduct visual inspections within the distance requirements as specified in'PPP and ANSI /ASME procedures.

Except for this one procedural violation, all inspection personnel who were interviewed regarding record preparation and maintenance improprieties advised forthrightly that they had never signed or initialed an inspection document without first performing the actions in the manner prescribed by the applicable procedures.

Ten welders or pipcfitters employed by PPP were interviewed and, except for one reporting that a QC inspector had occasionally failed to visually inspect within the distance requirement set forth in the PPP and ASME procedures, none were aware of record 1mproprieties by QC welding inspectors.

The Project Manager and two construction superintendents were interviewed and all categorically denied any form of intentional intirridation and harassment of QC welding inspectors.

The Project Manager and one Superintendent admitted actions which could be interpreted as interference into matters which are purely QA/QC functions.

The Project Manager denied any improprieties regarding the adminis-tration of QA/QC personnel matters.

All claimed to be supportive of the QA/QC function but acknowledged that they had failed to do so openly in a public canner.

(

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Eight licensee management officials and QC ' inspection personnel at the VNP were it.terviewed regarding their knowledge of intimidation and harassment of QC welding inspectors employed by PPP.

No disclosures pertinent to the investi-gation were revealed during these,, interviews. Observations of PPP material storage areas tended to support remarks reported by QC inspectors regarding the g:neral disarray of materials and common utilization of these areas by several major contractors onsite.

A review of QC welding inspector salary data disclosed that there does not appear to be a specific correlation between the amounts of recent weekly increases received and longevity, related experience and education icvels of these individuals.

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UNITE 3 STATES

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  • 3 1585 Georgia Power Company ATTN: Mr. R. J. Kelly Executive Vice President P. O. Box 4545 Atlants, GA 30302 Gentlemen:

SUBJE'CT: PLACEMENT OF DOCUMENT IN PUBLIC DOCUMENT ROOM Enclosed is a sumary of an investigation conducted by the NRC Office of Investigations, Region II field office. The subject of the investigation is "Vogtle Nuclear Plant Alleged Intimidation /Harrassment of QC Welding I spectors and Possible Falsification of QC Inspection Records by Pullman Power Products, Inc.' This Document has been placed in the Public Document Room and may be of use to you in preparing for the conference on September 25, 1985.

Sincerely, O

P e

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J. Nelson Grace

.[

Regional Administrator l

Enclosure:

Ccver page and sumary, dated 10/26/83, 7 pages cc w/ encl:

I R. E. Conway, Senior Vice President.

Nuclear Power D.,O. Foster, Vice President and General Manager Vogtle Project H. H. Gregory, III, General Manager, Vogtle Nuclear Construction G. Bockhold, Jr., Vogtle '

l Plant Manager L. T. Gucwa, Chief i

l Nuclear Engineer Ruble A. Thomas, Vice President-Licensing Vogtit Project cc w/ enc 1:

(Cont'd on page 2) g e-n m n my c/

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,E Georgia Power Company 2

ggp 12 cc w/ encl:

(Cont'd)

Ed Groover, Quality Assurance Site Manager C. W. Hayes, QA Manager J. T. Beckham, Vice President

& General Manager - Operations J. A. Bailey, Project Licensing Manager George F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge Bruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge Ernest L. Blake, Jr., Esq.

Shaw, Pittman, Potts and Trowbridge James E. Joiner, Troutman, Sanders, a

Lockennan and Ashmore James G. Ledbetter, Commissioner Department of Human Resources Charles H. Badger, Office of Planning and Budget, Management Review Division Deppish Kirkland, III, Counsel Office of the Consumer's Utility Council Douglas C. Teper, Georg'ians Against Nuclear Energy Laurie Fowler, Legal Environmental Assistance Foundation

~ Tim Johnson, Executive Director Educational Campaign for a Prosperous Georgia Morton B. Margulies, Esq., Chainnan Administrative Judge, Atomic Safety i

and Licensing Board Panel Dr. Oscar H. Paris, Administrative Judge Atomic Safety and Licensing Board Panel Gustave A. Linenberger, Jr., Administrative Judge, Atomic Safety and Licensing Board l

Panel l

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UNff ED STATES ENCLOSilg NUCLEAR REOULATGRY COMMISSION OFFICE CF INVESTlGOT90NS FIELO OFFICE. CECloN II

  • In"EI.Es"o'nSi[E" Date: October 26, 1983-l REPORT OF INVESTIGATION V0GTLE NUCLEAR PLANT TITLE:

ALLEGE 0 INTIMIDATION / HARASSMENT OF QC WELOING INSPECTORS AND POSSIBLE FALSIFICATION 0{, QC INSPECTION RECORDS BY PULLMAN POWER PRODUCTS, INC.

SUFPLEMENT:

50-424 CAshNUMBER:

2-83-005 CONTROL OFFICE:

01: Region II STATUS:

CLOSED REDORTING OFFICE:

OI: Region 11 PERIGD OF INVESTIGATION:

May 19 - July 9,1983 REPORTING INVESTIGATOR:

444 R[beYt k. Bu k Investigator OfficeofInvestigitionsFieldOffice,Regior.11 REVIEWED BY:

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William J. Ward;/iDirector 5

Division of Field Operations Office of Investigations

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-t is investigation was initiated to identify and document. alleged intimidation

','[dharassmentofPullmanPowerProducts,Inc.(PPP)QualityControl(QC) welding inspectors by the company's construction management personnel.

PPP, head-quartered.in Williamsport, PA, is under contract to install all piping and piping supports associated with the construction of the Alvin W. Vogtle Nuclear Plant

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I (VNP), in Wdynesboro, GA, a licensed facility of the Georgia Power Company.

Additionally, it was reported to the NRC that the intimidation and harassment s

experienced by the QC welding inspectors may have resulted in possible improprieties regarding inspection records prepared and maintained by these individuals.

s The allegation pertaining to intimidation and harassment of QC weldin'g inspectors by the Project Manager at the VNP was first reported to the Senior Resident Inspector (SRI), NRC at the f acility.

This initial allegation was substantiated by the SRI'during the subsequent interviews of four additional QC welding inspectors employed by PPP.

Additionally, a Confidential Source alleged vast PPP material storage problems, records improprieties and incidents of intimidation by the Project Manager and his construction superintendents.

The SRI obtained information that QC inspectors were being manipulated by the Project Manager through threats relating to adverse personnel actions affecting employment and salary matters. Additionally, the Project Manager allegedly interfered with the utilization of QC welding inspectors and attempted to influence the reassignments of inspectors whose work histories did not favor production and scheduling.

An onsite incident of assault in August 1982 upon a QC welding inspector by a

'donstruction superintendent, both emp'loyees of PPP, was also reported te the SRI.

A review of pertinent regulatory documents, stancards, procedures.anc contract requirements was conducted pursuant to the investigation.

It was disclosed that PPP committed to cooperate with the licensee to ensure QC standards for the VNP are enforced at all times.

Further, this review disclosed that the line of authority regarding administrative matters for the QA/QC manager at the field office site of PPP is through thp Project Manager. ~It was octerminec that PPP or

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2 a subsidiary company was the subject of previous inquiries pegarding intimidation and harassment of QC inspectors at the Seabrook Nuclear Plant, Seabrook,i New Ha pshire and at the Diablo Canyon Nuclear Plant, Avila Beach, California.

A licensee initiated self evaluation in late 1982, utilizing Institute of Nuclear Power Operations (INPO) criteria, identified that the QA/QC administrative reporting to the Project Manager is an area.of weakness in the PPP field organi-

'2ation.

Durings the investigation, nineteen field level.QC welding inspectors in PPP's 2

field office at the VNP were interviewed regarding intimidation and harassment, interference by the Project Manager and inspection records improprieties..Five

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of these individuals confirmed vast material storage deficiencies which are cor. pounded by the overt refusals on the part of construction managemen't to divert craft efforts to correct the problems.

These inspectors viewed the construction superintendent's negative attitude toward Storage Inspection Report deficiencies as a form of intimidation.

Some of these inspectors also related instances of interference and intervention into QC inspector assignment matters by construc-tien management to favor scheduling and the production effort.

All except one of the QC inspectors interviewed reported variously that the Project Manager has attempted to influence the utilization of, and decisions rendered by, inspectors;-

that the salary administration and other benefits for QA/QC personnel controlled by the. Project Manager is unfair and inequitable; that he arbitrarily adjusts i

rscommended salary increases based.upon subjective criteria; that he is fr quently publicly non-supportive and negative towards the QC function; that he and construction superintendents publicly chastise and embarass inspectors and that he employs remarks which threaten job security as a means of intimidation

'and harassment.

The lone dissenting QC inspecter was determined to be a personal 1

friend of the Project Manager and had been the recipient of preferential treat-ment regarding a job assignment on site.

Those inspectors with knowledge of an ensite altercation, in August 1982, between a former PPP Construction Super-intendent and a QC Welding Inspector indicated that the superintendent disagreed with the inspector's perception of the non-conforming item be'ing discussed.

One inspect'or reported.an offsite altercation in December 1982 between a Construction Superintendent and a QC Inspector! Supervisor during which the superintendent held an open knife on the QC supervisor.

3 "Two currsnt and one fonmer QC supervisory p2rsonnel were interviewed and

' substantiated the claims and percep~tions of field inspectors regarding i ncidents i

cnd acts of QC negativism by construction managers, intimidation, harassment advarse interference, verbal threats, embarassment' and chas'tisement of these individuals by the Project Manager and his subordinates.

All of these individuals indicated that production and scheduling appear to take precedence svar the quality functions,'an attitude nurtured by the Project Manager and his censtruction staff.

Authorized Nuclear Inspe'ctors at the VNP also confirmed

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intimidation and harassment of QC welding inspectors by FPP construction ma ment.

Inquiries were also conducted among the OC inspection personnel who allegedly engaged in visual inspection practices which were not in accordance with existin procedures or who signed inspection reports without assuring co.

4 rrective actions had been completed.

One QC welding inspector admitted that he occasionally failed to conduct visual inspections within the distance requirements as sp2cified ih'PPP and ANSI /ASME procedures.

Except for.this one procedural violation, all inspection personnel who were interviewed regarding record prcparation and maintenance improprieties advised forthrightly that they had n2ver signed or. initialed an inspection document without first performing the actions in the manner prescribed by the appl.icable procedures.

~ Ten welders or pipefitters employed by PPP were interviewed and, except for one reporting that a QC inspector had occasionally failed to visually inspect within the distance i requirement set forth in the PPP and ASME procedures

, none were aware of record improprieties by QC welding inspectors.

'he Prcject Manager and. two construction superintendents we e interviewed and all i

ategorically denied any form of intentional intinidation and harassment of QC l

elding inspectors.

The Project Manager and one Superintendent admitted actions hich could be interpreted as interference into matters which are purely QA/QC unctions.

The Project Manager denied any improprieties regarding the adminis-ration of QA/00 personnel matters.

All claimed to be supportive of the QA/QC

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anction but acknowledged that they had failed to do so openly in a public

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4 Eight licensee management officials and QC inspection personnel at the VNp were interviewed regarding their knowledge of intimidation and harassment of QC welding inspectors employed by PPP.

No disclosures pertinent to the investi-Observations of PPP material gation were revealed during these interviews.

storage areas tended to support remarks reported by QC inspectors regarding the grneral disarray of materials and common utilization of these areas by several cajor contractors onsite.

A review of QC welding inspector salary data disclosed that there does not appear to be a specific correlation between the amounts of receni, weekly increases received and lengevity, related experience and education' levels of these individuals.

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t JUL 171984 SED O

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Georgia Power Company ATTN:

Mr. R. J. Kelly Executive Vice President P. O. Box 4545 Atlanta, GA 30302 Gentlemen:

SUBJECT:

REPORT NOS. 50-424/84-16 AND 50-425/84-16 riN#4)

On May 14 - June 25, 1984, NRC inspected activities authorized by NRC Construction Permit Nos. CPPR-108 and CPPR-109 for your Vogtle facility.

At the conclusion of the inspection, the findings were discussed with those

, members of your staff identified in the enclosed inspection report.

A eas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.

Within the scope of the inspection, no violations or deviations were identified.

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In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures will be placed in the NRC Public Document Room unless you notify this office..

by telephone within 10 days of the date of this letter and submit written application to withhold information contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements

- of 2.790(b)(1).

Should you have any questions concerning this letter, please contact us.

i Sincerely,

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Hugh. Dance, Chief Reactor Projects Branch 2 Division of Reactor Projects

Enclosure:

Inspection Report Nos. 50-424/84.16 and 50-425/84-16 cc w/ enc 1:

D. O. Foster, Vice President and General Manager H. H. Gregory, III, Construction Project Manager G. Bockhold, Jr., Plant Manager E. D. Groover, QA Site Supervisor f-I b

3 d.

Proposed changes tc the Field Change Notice (FCN) and Action To Continue Work Program (ATCW).

This meeting was called to discuss the 1

proposed changes and revision 13 to Procedure DC-A-03 of the Field Procedure Manual.

It was agreed that the changes would be described in a letter to the Regional Office with reference to the Georgia Power Company letter of May 4, 1983, Log GN226 and the responding letter from j

NRC, Jene 2, 1983.

A meeting was held in Atlanta at.the Georgia Power Company Corporate e.

Offices.

The meeting was held to present the resultant findings from the investigation performed in April 1983, concerning alleged intimida-tion of Pullman Power Products inspectors. This meetings is described in more detail in Paragraph 8.

7.

Organizational Change Mr. C. E. Belflower, currently Hatch Q.A. Site Manager with 13 years experience at Plant Hatch, has been appointed as Vogtle Q.A. Site Manager for Operations.

In this position, Mr. Belflower will interface closely with all Project organizations in the development of policies, programs and procedures affecting the overall Quality Assurance Program for Nuclear Operations activities.

Mr. Belflower will report to C. W. Hayes,.Vogtle Q.A. Manager, along with Mr. E. D. Groover, Vogtle Q. A. Site Manager for Construction. This change was made effective June 18, 1984.

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Pullman Power Products Investigation l

A meeting was held on June 25, 1984, at Georgia Power Corporate Offices in Atlanta, Georgia, to present the results of the NRC investigation initiated to identify and document alleged intimidation and harassment of Pullman-Power Products Q.A. Inspectors.

The meeting was attended by the following people:

Licensee Employees R. E. Conway, Vice President, Eng. Construction Project Manager D. O. Foster, Vice President and General Manager, Vogtle Project P. D. Rice, General Manager of Q.A. and Radiological Health and Safety W. T. Nickerson, Manager,. General Plant Construction-Nuclear C. W. Hayes. Quality Assurance Manager R. W. McManus, Quality Control Manager-Construction Pullman Power Products B. L. Edwards, Project Manager, Construction I

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4 NRC H. C. Dance, Chief, Project Branch 2 A. R. Herdt, Chief, Engineering Branch V. W. Panciera, Chief, Project Section 28 J. J. Blake, Chief, Material & Processes Section B. Uryc, Investigative Coordinator E. H. Girard, Regional Inspector W. F. Sanders, Senior Resident Inspector J. F. Rogge, Project Engineer The meeting was started with a briefing presentation by Mr. Panciera describing the chronology of events starting in April 1983, until the present time.

Four (4) areas of concern were identified:

1.

Harassment and Intimidation 2.

Material and Storage Deficiencies 3.

Record and Procedure Improprieties 4.

Q.C. Deficiencies The four category groups were further defined and described as thirteen specific concerns which will require the following NRC action:

One unresolved item dealing with both harassment and independence concerns.

Eight Inspector Follow-up Items.

Three with no further review warranted.

At the conclusion of the presentation, Mr. Foster stated that the bulk of the information relative to corrective action was located at the construc-tion site and Georgia Power would address each item of concern in writing by letter within the next few weeks.

He stated that Georgia Power Company realized a problem existed in communicating to people at the site how

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certain corrective actions had been implemented.

Mr. C. Hayes was designated as the person responsible for getting the information together for further reviews of corrective actions.

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muk eiiin GIor7a Powsr C:r"carv Route 2. Box 299A Way escoro Gecrq a 3M30

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Teiecroce 404 '54 996 ? 6t 3360 4C4 W s'tJ 6t 3360 Jlli J A10 3 Georgia Power D. o. Foster v ce mes ce vee:eci

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vegre amect July 23,1984 United States Nuclear Regulatory Commission File:

X78G10 Office of Inspection and Enforcement Log:

GN-390 Region II - Suite 3100 102 Marietta Street Atlanta, Georgia 30303

Reference:

50-424/84-05, 50-425/84-05 Attention: Mr. H. C. Dance With reference to the items identified in your inspection report 424, 425/84-05, Georgia Power Company (GPC) wishes to submit the following possible intimidation of Pullman Power Products (PPP)gation and handling relative to the subject report and to our investi inspectors.

Immediately after being informed on June 24, 1983, of the NRC investigation of the above situation, GPC established a task force headed by Mr.

W. E.

Ehrensperger, a retired senior officer of GPC, to review and evaluate the PPP quality control and quality assurance program / organization giving due consideration to the above identified..

concerns.

This effort was conducted in a manner to avoid any conflicts with the related ongring NRC investigation and focused on the technical work process and QC procedures along with evaluation of salary y

administration and personnel practices of PPP.

The review of PPP's salary administration practices focused on three specific areas:

o-The rationale used in establishing salary increases, 4

5 2 o PPP's handling of certain disciplinary actions, and Qb job rotation practices among QC inspectors.

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Q The review detennined that PPP QC inspectors were well qualified Q

and knowledgeable, and found no evidence that PPP management had intentionally used. the salary administration program to intimidate inspectors.

No evidence of "short-cuts" was found nor was evidence that l

inspectors were being called on by their superiors to overlook problems.

M Although the question of intimidation was not specifically asked (again to avoid conflict with ongoing NRC activities), there was contiruous l

opportunity for inspector personnel to appraise the interviewers had such j

problems existed.

Task force recommendations were accepted by GPC and have been implemented by GPC and PPP.

On August 22, 1983, GPC informed the NRC of the results and response to the task force's review.

l In addition to the response to the task force's review and recomendations, GPC and PPP have expanded management attention to the l

PPP program to assure increased attention to the subject concerns and to the contractor's overall program.

This increased management involvement h]

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Page Two continues and has resulted in, but not limited to, the following management and/or program improvements:

Temporary assignment of the GPC Construction Project Manager full o

time to direct PPP activities Regular attendance of PPP executive management at Project Management o

Board Meetings to discuss related problems and program improvement o Replacement of a key PPP site manager o Restructuring the GPC surveillan'ce program to better monitor the quality of PPP's work, including the initiation of a verification program to verify the results of PPP's QC personnel o Frequent PPP corporate management visits and exits with GPC at Plant Vogtle including frequent site visits by the PPP corporate QA Director o Additions of PPP inspectors to better meet workload coupled with v

l a continuous monitoring program of the craft to inspector ratio o Establishment of lead PPP inspectors to give better support and y

supervision for inspectors

/ o Scheduling of regular site meetings between PPP employees and PPP management to discuss employee concerns and management actions

., o Employee information programs to explain the contents and requirements of " Whistle Blower" and labor laws o Correction efforts to improve identified PPP pay inequities including giving site department managers more input in relating performance to salary increases l'n an effort to evaluate the effectiveness of the above, a number of additional management assessments have been conducted and additional programs instigated with some specifics as follows:

In February, 1984, GPC conducted a survey of PPP QA and QC personnel o

consisting of thirty welding and hanger inspectors, eight lead inspectors and twelve QA engineers.

The PPP personnel interviewed-

.were asked specific questions concerning intimidations and dg b management pressure to accept poor quality work.

No evidenc~e was provided.

In fact, the individuals stated. that they had definitely not accepted poor quality due to management pressure.

Certain individuals did state that they have experienced pressure to produce but again stated that they had not performed less than quality work due to the stated perceived production pressure.

o A follow-up review of PPP's salary administration program was

Page Three conducted by GPC corporate personnel in June,1984.

This review

  • verified the positive findings of the original salary administration review and established that PPP has continued to ensure that salary adjustments are equitable and noncoercive.

i The GPC QA department conducted an assessment of the PPP quality hp in June, 1984, with the assessment being directed at h p [ p program verification of recommended actions and commitments for enhancement 0

of the PPP neganization and programs.

o GPC has strengthened its surveillance program of site contractors work by reinspection and verification of selected inspectors work.

We are currently formalizing our documentation of GPC's surveillances and verification actions.

o GPC realized that improving contractor management and increasing GPC involvement in activities would not by itself provide employees the necessary freedom to discuss their concerns.

Therefore, in

December, 1983, GPC implemented our Quality Concerns Program.

This program provides all employees of GPC and its contractors associated with the Vogtle Project a system to express their concerns about quality and/or safety problems and have them resolved.

This program assures that all concerns will be treated confidentially and that the submitter's identity is protected.

The details of this program have been presented to all site personnel and presented off-site to major contractors' home office personnel.

The Quality Concerns Program provides all Vogtle 4

employees, including PPP QC personnel, not only the freedom but obligation to express concerns of harrassment or intimidation.

o PPP has initiated its own internal Quality Concerns program.

Th'i s

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program is patterned after the program developed by GPC and is

\\y., Q A administered by a full-time program coordinator employed by the c

This coordinator functions in a staff relationship g; p [ / contractor.

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gy with the contractor's organization at Plant Vogtle and has direct

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line responsibility to PPP corporate offices in Williamsport, Pennsylvania.

The PPP program has been implemented and is currently in place.

The program is monitored and reviewed by the GPC Quality Concerns Coordinator and all concerns involving issues having l

potential safety significance are.either deferred to GPC for investigation and resolution or are jointly processed by GPC and PPP.

o In order to ensure.that no form of harrassment or retaliation takes place in the future, PPP has committed to the development and implementation of a comprehensive training program for all levels of supervision.

The training program is being designed to ensure that all supervisors are fully aware of the legal g

G prohibitions regarding retaliation for statutorially-protected g

y activity.

The training sessions will also emphasize the supervisor's role in encouraging employees to perform quality work and to bring quality questions and concerns to the attentio'n of management or the Quality Concerns Program.

Page Four o In. a related sense, GPC formed a task force under our Quality Concerns Program in December,1983, to investigate a quality concern by a PPP employee who had been reprimanded for not performing the required amount of nondestructive examinations (NDE).

The task force interviewed all available PPP NDE technicians, observed work practices and reviewed documentation. The review was conducted of work assigned and completed with no evidence that production pressures were degrading quality control actions.

All persons interviewed felt that production was not stressed to the point that quality was sacrificdd.

In addition to the above, specific discussion and response pertaining to the open items listad in Inspection Report 424, 425/84-05 is as follows:

Unresolved Item 84-05-01, " Insufficient Organizational Freedom / Control of Services through Effective Audits GPC had a program and continues to have a program to assure that contractors comply with the requirements of 10 CFR 50, Appendix B.

The PPP QA Program was reviewed and the independence of the PPP QA/QC organization complies with 10 CFR 50, Appendix 8.

There is no requirement in Appendix B

that disallows the contractor's QC organization from reporting administratively to the Project Manager, the highest level of contractor management on site.

GPC did take action in December, 1982, to have PPP revise their program to require the PPP QA audit function to report to the Corporate QA office.

This was done to strengthen PPP's program and bring it in line with GPC policy.

Checking for harassment of QC inspectors was never included as a specific checklist item or mentioned in QA audit reports.

Audit reports did address quality of work and implementation of QA prograins.

Although we found no evidence of inspector intimidation, GPC recognized that conditions did exist such that employees at times may have seemed intimidated.

The actions outlined in the second paragraph of this letter were taken to relieve this situation.

GPC has initiated an annual assessment audit program to assess l

the effectiveness of on-site e.ontractors' QA programs including the independence of QA/QC inspect. to prevent harassment or intimidation.

GPC has also implemented the Quu tty Concerns program mentioned earlier l

to allow employees including int'ectors a path to upper management if they. feel harassed-or intimidated.

GPC has conducted audits, surveillances, verification reviews ar.d assessments of PPP's program and site activities.

There has never been any indication of any substandard or poor qu'ality work performed by PPP which can be attributed, in any ay, to retaliation, harassment, intimidation or lack of independence of the inspector.

Inspector Follow-Up Item 84-05-09, " Clarification of Engineering and Procedural Requirements" The concern of QC inspectors being pressured or receiving

i Page Five interference from their own QC management was reviewed by the Piping k f Quality Improvement task force.

The task force found no evidence of "short cuts" being taken or inspectors being called on to overlook g G (F O D[r k

problems.

Frequently, there are questions about procedures and specificaticas.

These questions are answered in various ways:

verbally, written memo to individual, or written memo to all inspectors.

There is a concern with the handling of these answers, i.e.,

everyone is not always aware of the questions and answers.

Some people feel the questions and an,swers are changes to existing requirements.

All memos concerning clarifications of PPP procedures are now apprcved by either the QA/QC Manager or the appropriate Assistant QA/QC Manager.

In addition, GPC, BPC, and PPP has had meetings to resolve or clarify differences concerning specifications and drawings on hangers.

These meetings continue to be held as required to assure proper understanding of specifications and drawings.

Inspector Follow-Up Item 424, 425/83-05-02, " Unsatisfactory Piping Welds from the Pullman Fabrication Shop" This item was identified to the NRC as a potential 10 CFR 50.55 (e) item and GPC has conducted extensive evaluations of the quality of welding in pipe spools and corrected all discrepancies.

In addition, GPC increased shop surveillance activity in the PPP shop to visually inspect 100% of the pipe welding.

Inspector Follow-Up Item 424, 425/84-05-08, " Control of Nonconfomance Reports" After identifying a problem with shop welds on pipe spools, GPC initiated inspection teams to reinspect the PPP fabrication shop welds.

PPP war aware of this and did not want to duplicate inspections or NCR's.

" Void" is an acceptable disposition on an NCR.

Also, clarifications and administrative corrections are made to NCR's by a QA engineer or a a QC supervisor.

Occasionally, QC inspectors verbally discuss problems with field engineers and during the engineer's review of the problem he decides to write an NCR.

When the engineer writes the NCR, he will list the inspector's name who asked the question in the space for QC Inspector."

PPP's present policy is to send a copy of the NCR to the listed inspector to keep them informed of voids, changes, or NCR's written by others.

A new form replacing the present NCR form, in the next revision of the NCR procedure, requires the individual writing the NCR to put his name as initiator.

Inspector Follow-Up Item 424, 425/84-05-03, " Storage and Protection Deficiencies" GPC has had an ongoing program to assure adequate storage and t

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Page Six 4

protection of material and equipment. As with all our ongoing programs, GPC continues to look for improvement.

GPC and PPP management are aware of the storage problems and are taking actions to resolve them by improving the coordination and cooperation among the organizations involved.

Individual GPC area managers have been assigned personal responsibility to maintain specific areas of the plant relative to housekeeping, which is a large part of the storage problem.

1 In addition, to further enhance storage conditions, PPP has initiated a new program to prioritize the resolution of storage deficiencies and has established a new superintendent with associated craft, who are only responsible for resolving storage discrepancies.

PPP Procedure XIII-5, Paragraph 6.2.4 requires PPP to protect flange surfaces during storage.

We are not aware of any violations of this requirement.

We are aware of two instances where acid or corrosive substances were spilled or used.

These are documented in NCR's and are available for review.

Inspector Follow-Up Item 424, 425/84-05-04, " Licensee Review of Charges of Fraudulent Welding Inspection Verification" A sampie of work of each individual was reinspected and except for one arc strike, no hardware discrepancies were identified.

Minor discrepancies (i.e.,

inspector initialed instead of signing process sheet, no procedure revision entered on certain lines, welding stencil entered on wrong line, etc.) were found to documentation and were corrected.

The inspectors were trained to prevent recurrence.

There was no evidence of any fraudulent sign-offs.

1 Inspector Follow-Up Item 424, 425/84-05-05,

" Adequacy of Training Program for Inspectors, Field Engineers, and Craft" This item was reviewed by the Piping Quality Improvement task l

and their recommendations have been implemented.

PPP has froce developed a comprehensive training program for QC, Field Engineering and craft personnel.

Inspector Follow-Up Item 424, 425/84-05-06,

" Control of Foreign Materials in Piping" PPP procedure requires all purge dams to be recorded on the process sheets as to type used and when installed.

Removal must be verified and indicated on the process sheet unless a water soluble material was used. QC personnel are now recording purge dams issued and returned instead of craft personnel.

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Page Eight Inspector Follo* Up Ites 424, 425/84-05-13 " Unqualified Welding Procedures" PPP has identified minor discrep'ancies in the application of qualified welding procedures.

These discrepancies have been identified in nonconformance reports and properly resolved.

Qualification records are available for PPP welding procedures and PPP has not performed work at Plant Vogtle with unqualified welding procedures.

GPC had developed, and has available on site, documentation packages addressing our response to each of the identified concerns. We are prepared to discuss our program enhancements and c'orrective actions in total detail during future inspections.

Yours truly,

/

t D. O. Foster,

DOF/js cc:

Victor J. Stello, Jr., Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C. 20555 Andy Martin Pullman Power Products P. O. Box 3308 Williamsport, PA 17701 R. J. Kelly R. E. Conway l

G. F. Head l

W. T. Nickerson D. N. MacLemore l

D. E. Dutton W. F. Sanders R. H. Pinson P. D. Rice R. A. Thomas J. A. Bailey

0. Batum G. Bockhold B. M. Guthrie E. D. Groover L. T. Gucwa M. Malcom H. H. Gregory J. T. Beckham J. L. Vota C. S. Ikca'l B. L. Edwards l

_ _ _ _ _.

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