ML20235A530

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Partial Response to FOIA Request for Documents Re SSER-22 (NUREG-0675) Concerning Operation of Facilities Which Provided Further Findings on Whistleblower Charges.Forwards App J Documents.Documents Also Available in PDR
ML20235A530
Person / Time
Site: Diablo Canyon  
Issue date: 09/21/1987
From: Grimsley D
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To: Devine T, Dixon C
GOVERNMENT ACCOUNTABILITY PROJECT
References
FOIA-84-744, RTR-NUREG-0675, RTR-NUREG-675 NUDOCS 8709230328
Download: ML20235A530 (2)
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{{#Wiki_filter:_ U.S. NUCLEAR REGULATORY COMMISSION Nac soiA neoutSt Nuuss4a siFc -7 d ga s e .g RespoNss rvet i M," RESPONSE TO FREEDOM OF b'"^' M '^"* O "

  • gs INFORMATION ACT (FOIA) REQUEST

\\ \\ SEP 211987 eseee s DOCKET NuMBERtSi t/r sMcebel RIOvESTER ft/Y1CL Y-PART 1.-RECORDS RELEASED OR NOT LOCATED (See checked boxes) No egency recore sub set to the request have been located. t No additional agency records sub set to the request have been located. t Agency records subtect to the request that are identifed in Appendix are already available for public inspecten and copying in the NRC Public Document Room, i 1717 H Street, N.W., Washington, DC. Agency records subject to the request that are identifed in Appendix are being made available for public inspecten and copying in the NRC Public Document Room,1717 H Street, N.W., Washington, DC, in a folder under this F04A number and requester name. The nonproprietary version of the proposells) that you agreed to accept in a telephone conversation with a member of my staff is now being made available for public inspecten and coying at the NRC Pubhc Document Room,1717 H Street, N W, Washington. DC, in a fo6 der under thrs FOIA number and requester name. Encioned is informaton on how you may obtain access to and the charges for copying records placed in the NRC Public Document Room,1717 H Street, N.W., Washington, DC. Agency records subsect to the request are enclosed. Any applicable char 0e for copes of the records proveed and payment procedures are noted in the comments section. Records subsect to the request have been referred to another Federal agencytes) for review arm direct response to you. In view of NRC's response to this request. no further action is being taken on appeal letter dated PART ll.A-lMORMATiON WITHHELD FROM PUBLIC DISCLOSURE Certain information in the requested records is being wrthheld from pubhc disclosure pursuant to the FOIA exemptions described in and for the reasons stated in Part 11, sec-tsons B, C, and D. Any rodeased portions of the documents for which only part of the record is being withheld are being made available for public inspecten and Copytng in the NRC Public Document Room,1717 H Street. N W., Washington, DC, in a folder under this FOIA number and requester name. Comments SIGN Atum s ECTOR. Divisi RULis ANp atCORDS s p Ia = - O a4 M,_ _ _ 1 x x y u W 9 8pga e70,a, 1 DIxoyg4,744 PDR NRC FORM 464 (Pset il to aos

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OVERNMENT ACCOUNTADlLITY PROJECT Uto for Pokcy Studies 1 Que Strebt. N W. Woshington. D.C. 20000 (202)234 9382 September 13, 1984 FREEDOM OF INFORMATK)N Director ACI REQUEST h Of fice of Administration f kQg % U.S. Nuclear Regulatory Commission Washington DC 20555 To Whoin It May Concern: Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. 5552, the Government Accountability Project (GAP) request copies of any and all agency records and information, including but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures,, instructions, files, graphs, engineering analyses, charts, maps, photo-graphs, agreements, handwritten notes, studies, data sheets, notebooks, books, tele-phone messages, computations, voice recordings. any other data compilations, interim and/or final reports, status reports, and any other records relevant t.m fnd/or generated in connection with the Safety Evaluation Report related to the operation of the Diablo Canyon Nuclear Power Plant, Unit 1 and 2, NUREG-0675, Suppictent No. 22, which provided the NRC Staff's further findings on whistleblower charges. We request that each responsive document be identified by the allegation - ;.aer(s) to which it may relate. -If any of the materials covered by this request has been destroyed and/or removed, please provide all surrounding documentation, including but not limited to a de-scription of the action (s) taken, relevant date(s), and justification (s) for the act ion (s). GAP request that fees be waived, because " findings information can be considered as primarily benefitting the general public," 5 U.S.C. 8552(a)(4)(A), GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through 1egal representation, advice, national conferences, films, pub-lications and public outreach, the project promotes whistleblowers as agents of government accountability. We are requesting the above information as part of an on-going monitoring project on the adequacy of the NRC's efforts to protect public safety, and health at nuclear power plants. For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portion of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is required under Vaughn v. Rosen(I), 484 F.2d. 820 (D.C. Cir.1973), cert, denied, 415 U.S. 977 (1974). 1 We look forward to your response to this request within ten days. Your truly 4 O NbkD l Thomas Devine Cr stal Dixon l Legal Director } Legal Intern

j. pu f. 1 ~ ~ To: Hon. Victor Gillilsky,' Commissioner United States Nuclear Regulatory Commission 1717 H Street Washington, D.C. 20555 From: Harold Hudson - Former.Rullman Power hroduccs Quality Assurance Inspector, Quality Control Inspector, Quality . Assurance Program Internal Auditor and Lead Auditor. l Date: 1-12-84

Subject:

Report #3 - Quality Assurance Discrepancies Associaten With Pullman Power Products Internal Audit #103 At The Diablo Canyon Nuclear-Plant. W Pullman Power Products' Internal Audit #101, performed on 1-18-82, identified significant conditions adverse to quality whicn were not promptly corrected and resulted in corrective action which was not adequate. 1. Pullman Power Products' Internal Audit #101, Audit Action Request #1 findings hrve not had adequate correct ~ ive action implemented. A. Five NDE Procedures were identified on I.A. #101 as not having evidence that the special processes were controlled and accomplished using qualified picocedurer or that qualification records were maintained to document and acaure quality of material and work. There are nc Procedure Qualification Records docu-menting Procedure Qualification Tests for thro, five NDE procedures., The five NDE procedures are: 1. ESD 234 - UT Inspection Groove Welas AWE-D2.U6, 2 ASME Section VIII and Section V. Used to examinc full penetration groove welds on Pipe Rupture Restraints prior to July 1979. 2. ESD 243 - UT Examination of Safety Yoke Rods on 3707 RAX 6-21 Safety Valves. 3. ESD 246 - Magnetic Particle Procedure / Dry /Continu-ous Coil - B31.7. UseCunkown.- ' ~ - 4. ESD 247 - Magnetic Particle Procedure / Dry / Contin-uous Coil - B31.1. Used to examine crack repair welds on Feedwater Nozzles to Unit # 1 Steam G r-erators. 3. ESD 270 - Liquid Penetrant Examination Procedt re. Use unkown. Y z&s rt o u , q) $./ Af Y ~ fklE-N

s 'g =;.. I B. Two Ultrasonic.. Material Thi.ckness Measuring.. Procedures were identified as not having evidence that the special pro' cesses were controlled and accomplished using qualified procedures or that qualification records:werel maintained to-document and assure quality of material and work. There:are no Pro-cedure Qualificati'on Records documenting Procedure ~ Qualification' Tests. These'prodedures are: 1. ESD.236'- UT Thickness Measurement of Boundary-Valves. j See 2.P.P. Unsched'uled Internal Audit #34 and H. Hudson's Report #2 to NRC Commissioner V. Gilinsky, dated'l-2-84. 2. ESD 244 - UT Thickness Gauge' Procedure. This procedure widely used by fullman. It was determined in'.I.A. #101 by Pullman QA/QC Manager' H. Karner that these two ultrasonic proced-ures were not nondestructive testing procedures but were used to measure material. thickness and therefore did not require'" Proc.edure Qualification Records" (Procedure Qualification. Tests). This was not a valid determination. All special processes, not just welding, heat treating and nondestructive test-ing, are to be controlled and accomplished. using qualified procedures (Procedure Qualification Tests). The determination that ESD 236 and ESD 244 were not nondestructive testing procedures does not exclude the procedures from qualification requirements for special processes. It is alleged that QA/QC Manager H. Karner's determination that ESD 236 and ESD 244-did not require Procedure Qualification Records J covers up a serious breach in the Quality Assurance requirements for special processes as required by 10CFR50 App, B IX and XVII and PG&E C.S. #8711 Section 4.3.23 and 4.3.29. No corrective action has been initiated by P.P.P. concerning use of ESD 236 and ESD 244 without Procedure Qualification Records. 1 l l C.L ESD 234, ESD 246 and ESD 247 NDE Procedures had Procedure Qualification Tests performed as corrective action to I.A. #101, A.A.R. #1-(see attached PQR's). 3 These PQR's are after the fact qualifications of these J procedures. The actual use of these procedures were j not controlled and accomplished using qualified procedures. It should be noted that the PQR's for these procedures do not have approval signatures of either P.P.P. or PG&E Management authorities. The only signatures l 1 b _-_ _ _ _ _ _ _ - - - - --d

./ '[' 3 \\ on the_PQR.'s is...that.cf._the individuals _; conduct 1ng the qualification' tests. It.is, alleged that these PQR's have not been approved by the appropriate management authorities. l 2 ESD 270 did not have a Procedure Qualification Test performed.as part of the corrective a6 tion to I.A.

  1. 101, A.A.R. #1.

QA/QC Manager H. Karner determined that ESD 270 used'similar penetrant materials and examination methods as-ESD 210 - Liquid Penetrant Procedure ( ANSI - B31.7) and that ESD 210 had Pro-cedure Qualification Records which demonstrated the I ability to detect the specified discontinuities. QA/QC Manager. H. Karner directed that ESD 270 be revised to incorporate the PQR's of ESD 210 as the corrective action to be taken (see I. A. #101, A. A.R

  1. 1 Corrective Action Taken).

The use of ESD 210 PQR's does not provide a proven demonstration of ESD 270's ability to' identify discontinuities. ESD 210 and ESD'270 must have some differences or there would beeno need for two procedures. It is alleged that -QA/QC Manager *r H. Karner's directive to use ESD 210 PQR's for ESD 270 does not provide proper or adequate corrective action to the Audit finding and that'ESD 270's: lack of proper PQR is still a condition adverse to quality. No investigation was performed to determine where ESD 270 was used. 3. ESD 241 did not have a Procedure Qualification Test i performed as corrective action to the Audit finding. ~ A Procedure Qualification Record was suppose to be prepared per A.A.R. #1 Corrective Action Taken but this corrective action was never implemented and A.A.R. #1 was closed out and approved by the QA/QC Manager without the PQR being generated. The bases for this action was a memo prepared by i Internal Auditor J. G yler, dated 1-13-83 (see l attachment to A.A.R.

1) that stated: "There is a j

pending DR involving SD 241 This is a special g procedure createdsto supplement PG&E and manufacturers ] examinations. PPP has accomplished this per instruct-J ions from PG&E. It is evident that a nonconformance does not exist and a DR is not necessary. A written response indicating this will be considered basis for closing this portion of AAR". QA/QC Manager H. Karner indicated on AAR #1 that this memo by I.A. j J. Guyler would be uses to close out that portion ] of AAR #1. i i 1

q 4 o. s +. 7. . _InternaLAuditor J. Guyler's statement, that "it is evidenidas' A n6iidodf 6fshhod"dbs~e '~ hot exist and1a DR'is not necessary" is'not a. valid statement..It is alleged that:I.A. J. Guyler and'QA/QC Manager H. Karner have-covered: up serious breaches in the: Quality " Assurance Program and are in noncondormadce.to 100FR50 App..B IVI and PG&E C.S.=#8711'Section-4. 3.28 requirements that'~all conditions adverse to. quality'are-to1promptly. identified, reported -and corrected. It should be noted that during a. conference- 'to formulated a revised; response to..AAR#1' on 9-14-82, attended by"QA/QC Manager H. Karner, NDE Leadman P. Dawson'and I.A. H. Hudson, it was agreed'thatia: Discrepancy Report would be; s'ent $onPG&E identifying that the're was.no _ PQR*fortthe: procedure and'that the'UT examinatio of2the Yoke: Rods?*as perfbrme's prior'to ESD 241_being issuedeby M.W. Kellogg -(Pullman). and approved Eor implementation by PG&E (see attached Interoffice Correspondence of 9-15 to.I.A. #101, AAR#11 File). -QA/QC. Manager H. Karner later reneged' on' this agreement when' he approved.I.A.JJ./Guyler's memo and approved the closing of AAR#1.. QA/QC Manaher H. : Karner Las covered up significant QA discrepancies.in the use of ESD 241 by refusing to forward the proposed DR to PG&E. The proposed Discrepancy Report, dated 11-3-82, prepared by H. Hudson, identified.the following discrepancies (see proposed DR attached to I.A.

  1. 101'):-

A. ESD 241 did not have a PQR as required by C.S. #8711 Section 4.3.23 and 4.3.29. B. The UT examinations of the Yoke Rods were performed prior to ESD 241 being issued by M.W. Kellogg and approved by PG&E. The. examinations wereaperformed between 12-17-T: 12-20-73. ESD 241 was issued on 12-26-7) and approved for construction by PG&E on 2-12-74. C. The PG&E Field Change Order directing M.W. Kellogg to perform the work required inspection per the Dresser Instruction and a PG&E Memo by J. Sale. The Sale Memo specified the part of the Dresser Instructic to be' used was paragraph 12, "Botts and

..l. 1. 9 s w :. . Studs-(Greater than 2 inch Diameter Up.to 4 inch' 71em~e~tTr )". Dres tr~# spa 52;166 aaragraph - 12 f1" states Hall?bolte and studs lshall be examined -prior to threading?. The yoke rods UT examined- .by.M~W.;K611oggTwere threaded.- The?examinati'on. of'these6threadediyoke rods is a_noneonformance toths1 requirements'oftheJDresserInstruction. Du, The "Reportiof.'. Ultrasonic: Examination" used to document lthe description:of equipment, procedure used p andsthe resultsEoftthe examination was not a form. referenced'in-ESD'241,18. It did not 'includefcertain' required'information. 1.- It did not include the surface or surfaces from whi'ch the' test.shall be performed as requi: sed Ty]ESB: 241 and the Dresser Instructic -

2., Itwdid.not' include a. description of the-calibration 3 1ock (size,' material and basic

. calibrutionere'flectors)>and calibration method ~as! required by,ESD 241 and the Dresser Instructi6n. ~' 30, The;.equipmenti. calibration frequencisreference e on:>the 1' Report 'of Ultrasonic Examination" were 'not as required by ESD 241 and-the Dresser i Instruction. It should have been noted that ESD 241 and the Dresser Instruction procedure: requirements for equipment for calibration frequency were for production runs and -not for individual rod examination. The two procedures did not meet the needs of the type examination being performed. E. The " Ultrasonic Examination Report", Appendix A, Form F-66, referenced in ESD 241 was not used to record the required information of ESD 241.15.3. F. There were differences between ESD 241-and the Dresser Instruction concerning information used to determine the reference point for. sensitivity j and criteria used to report questionable items. 4 1: G. PG&E Memo by J. Sale stated that "in addition to the UT inspection, a back up inspection should be performed with the dye penetrant technique to check the yoke rod ends for indications of crack-ing that might extend into thethreaded' area of j the yoke ends". 1. The Ultrasonic Status Reports indicate that no dye penetrant inspections were performed. ] k ~. j

6. i 2. ESD 241.17;l did not stipulate the same. A.#.. - ~reqt11NY&nTss ~tre PG&ETe~mo. ESD 2~4I.~1T1~ stated " Liquid' Penetrant o'r Magentic Particle will b'e tised ~on rods which aressuspected of containing discontinuities which'may. extend into 'threadedsareas or*to's'upport areas where UT* i tests indicate discontinuities with ' lengths in exc e s s' -of?.1" ~ 1dng". No Corredtive.Acti'on wasttaken on the audit. findings for ESD 241. fTh!e. proposed DR concerning ESD 241 QA discrepancies was not" approved by the QA/QC Manager and was' not~ forwarded tot PG&E ifor6 disposition. This is a nonconformance to 100FR50? App. B'XVI and PG&E C.S. s

  1. 8711 Sectio & 4p3)28lCbrrective' Action.

4. Only two ofutheiseven procedures. identified on I.A. # 101 not to haveEPQR'sDwereWidentified to 'PG&E on DiscrepancyEReports for their disposition. C..S. 8711.Section :4' 3".28 'and; C.S. # '8833XR Section 3.4.1210 require Contractor to assure that all conditions adverse to quality are promptly. identified, reported, and corrected. P.P.P. ~did'.not report alltthe conditions adverse to quality identified in I,A. #101 to PG&E. This is a~nonconformance to the C.S. requirements. 5. ESD 246 and ESD 247 were identified to PG&E on DR #4662 (see attached) as having no Procedure Qualification Records. DR #4662 identified that ESD 247 had been used to MT examine the inside diameterof Feedwater Nozzle welds to Steam Generators 1-land 1-4 during the repair l of cracked welds. PG&E accepted as issall work examined by ESD 247. Because DR #4662 did not identify any locations where ESD' 246 had be used no reference was made to accepting any work performed by ESD 246. During the Internal Audit investigation into the use of ESD 246 and ESD 247 I was' ordered by QA/QC Manager H. Karner to cease the investigation once it was known v where ESD 247 had been used. I was not allowed to l' continue the Audit investigation to determine where ESD 246 was used. This resulted in DR #4662 having limited information concarning the discrepancies being reported. There are two questionable Quality Assurance issues relst. to the useof ESD 247. A. ESB 247 specifies that it is a Magnetic Particle Procedure / Dry / Continuous Coil for B31.1 Code. C.~

  1. 8711 Section 2.2.1 specifies thht portions of the feedwater piping from the steam generators to the isolation valves are to be designed, fabricated, and erected per ASME Section I.

The MT Examination Records attached to DR #4662 (see attached) indicate

r 2z:z:a,: z;x.=;;ux:.:', . ;_w O L' L j l. 1 y ~ Lthe_. Ache.p+Aea ~ NMada_,to.be_ASME. Seetion_-I.-This, raises!!ithe;.4u'esti'onDean a_331.1 Code MT procedure. be ussdit'oW.~exaniine >ASME Section I piping and obtain results $hich?are/ reliable. ~ -B. The MT: Examination Records attached to DR# 4662 are da'ted 10-19a77 4 d 10-20-77 and'the'MT's were perforniedlby) D.R'.DGeske. The M.W. Kellogg.(Pullman) Personne1' Testing Record for D.R. Geske (seenttached). inaicated:heswas.cer.tified a' Level II MT<on 8-23-76 with ' aic omp^osit'engrade for 198%. But the Testing ~ Recorddunde29.sEz'aimins.ti6n' Grades in Percent 'does. not record 1anynecores coretne General, specific, e PracticaD Exami~natibneL JIt is not' understood by this . writer 'howf si'.'compositfgrad6,of 98% could.:be obtained when there,are-nonrecorde.d'percental*' scores for the, General,1 Specific', and* Practical Examination. Both the SNT-TCal&'and*M.W.JKellogg ESD 235.(NDE Personne1' Qualification andT Certification Procedure). require s General,iSpecificf arid" Practical' examinations to qualify for Level gI!MT,. The Personne1' Testing Record'for D.'R.~Geske.does not provide-the necessary information to werify:?that Geske.was properly qualifie as a Leve1MII'MT.Technican. J The NRC should. investigate these11ssues to assure that1 there.are no QA discrepancies associated with the use of ESD 247 and the examinations of the Feedwater Nozzles to Steam Generators. ESD 246 and ESD 247 had Procedure Qualification Tests performed on 11-9-82. The. Corrective Action Response to.=I.A. #101, AAR#L,' by M. MacCrae (see attached) states."As both ESD',246 and ESD 247 have been' withdrawn' from uses and thesequipment listed in both procedures-is no-longer available for use, the equipment used for these PQR's"was the Magnafiux Model P-90 for the coil technique onlye. iThe Proc.edure Qualification Test was performed:1ssingidifferent equipment than specified in the' original' procedures. that P-90 puts out lessaamper.The Response does indicate 3 age than the equipment listed in ESD 246 and ESD 247 and that acceptable results were obtained. But a questionsis raised. Is.it acceptable to' qualify MT procedures after the fact using different equipment than listed in the_ procedures? This is an item of concern that the NRC should investigate. 6. The most important issue to raised by.this report and ARR#1 findings is can NDE procedures be qualified after they have been used?' 100FR50 App. B IX and PG&E C.S. # 8711.4.23 and C.S.. #8833XR.3.4.128 require special processes to.be; controlled..andanocomplished using qualifiec procedures. The sevezi proc'edures' identified in I. A. #101 were used without being qualified bf Procedure Qualificati< test and are'nonconformances to the above requirements.

8, ' i s

  • e l

l This 'is a:ma;)or breakdown in the PPP Quality Ass 8rance-Program., In-my-opinion 3-the-use-of - - l i' unqualified procedurss puts the work-examined into a' questi'onableK1 status. The NRC should j investigate this'.i'ssue'to assure that thereare { n'o. conditions existing which would adversely I affect quality #end tend-to cause. failures or { malfunctions 'in the work' examined by' these procedures. { 2. The Internal. Audit #101,wAAR#1 findings were not promptly corrected as ' required +by3100PR50 App.B XVI and PG&E C.S.

  1. 8711.4.3.28 and C.S.i#8833XRMT4.1210 requirements.

It is alleged that'QA/QC; Manager J.'Karner deliberately procrastinated on these-findings.to avoid identifying these discrepancies to PG&Efand9u11 man Corporate. Management and because he was undble-to' formulate a proper corrective action.- It is alleged' that Pullman Corporate Director of Quality, Assurance.;A.,4Eck,. failed to expedite corrective 2 action!oiic,6theiwds' made~ aware that the onAsite QA/QC Manager waslnot'providing a prompt response to AAR#1 finding. Internal Audit #101.;was performed on 1-18-82 AAR#1 findings weke..not'.formhlizediuntil 3-22-82,due to additional investi'gati'orijfequested 'by the QA/QC Manager. AAR#1 findings were acknowledged by QA/QC' Manager H. Karner on 3-23-82.. Corrective' Action Taken response was due on 4-5-82 and?was.Treebived:nnd' approved. Bero.re the follow'up audit to-assure activities complisd with approved corrective action, QA/QC Manager H. Karner requested AAR#1 back so that a revised response could be ~ prepared duetto addition findinga being identified. The additional findingy.was that ESD 241 had been used. It had been decided under the original response that this procedure had never been used. AAR#1,would not be returned to my possession for a foll'ow up audit until C g, /- 3-22-83. Prompt /correctivemaction was not implemented for the findings of'AAR#1Cas required by 10CFR 50 App. B J' XVI and PG&E C.S.'#8711'and #8833XR. I would spend the next year-tryinggto get QA/QC Manager H. Karner to provide a revised corrective action response so that AAR#1 findings could be closed out. Following is a narrative of action takenhby me to try to get a revised corrective action response from the QA/QC Manager. A. On 5-18-82 I send a PPP Message (see attached) to the QA/QC' Manager requesting he provide an immediate revised response and return it to me. B. On numerous occasions I verbally request the QA/QC Manager for a revised corrective action response.

,~ a i-g .~. , f'*. 7 [ I ~ O. On 6-1442 an > Interoffice ! Correspondence (see. attached: ' ds ~#eWd ~t'5^A.:. sck,7CbryoTEte~~DireTtcentfluality~ ~ ~~ w withoutlPQR's)lating that an.AAR"(NDE procedures.; directed;to Assurance,.:st per ESD :263. wasi;tof,be, responded to :in 10. calendar days, wasLtaking weeksTfor a response, b .D. On-7-6-82).anLU6 scheduled, Internal. Audit :# 31 '(see attachd-)Was'.l'pe'rfbrmediand taddressedito A. Eck, e Corpoiate @irector mfdQA.7 The Ginsche'duled:.- audit t i was performed 3o.~idsitlfygitotMan'agementlpersonnel'a deficienoffin'hthe71Epiement'a'ti6nlof eorfec~tivelaction .to Internal %tidi't3 poi,t'sI,$The Mudit efinding was that - the yf/QC.Wansi eklyasl$ot' promptly. implementing, correotive'actioh3 diftieknal: Audit-Report; findings. xs m sw.w ~ 1. A response" fro'm:1.s'$ck,.. dated.7-16-82 (see attached did :notladdr'esalth61is' sue ~of. Corrective. Action notibein M mp1'ementedFin1a.' timely manner.

Instead, A.(EcMreprimande;d?'mKfor incorrect. application of'ESDr263~.~(UsIJA;:U#31 was not responded to by the "Directortof:lQA.

i It apj>earsd?;.that?the LD1:dector.of. QA was more concerne'dWithhth6.,fsoYo'alled.finproper application of ESD'263 MInternalTAudit Procedure)'than with gettingdc'orrectiveTaction 'iinplementedito an Internal / Audit' finding that~ NDE procedures 'did not have'Precedure Qualification. Records. It should be'noted thattA. Eck's reprimand directed me to assign resolution of no formal PQR's for NDE procedures to the responsibe NDE Supervisor. 2. On 7-22-82,'QA/QC Manager H. Karner conducted a meeting'with me at'which time A.Eck's reprimand was discussed and Mr. Karner laid out ground rules for future Internal Audits. It should be noted that no mention was made as to when a r'evised corrective action response would be forth coming. (see attached). t-E. On 7-28-82 I send an Interoffice Correspondence (see attached) to QA/QC Manager H..Karner asking what Corrective Action is being takentto resolve audit wanted me to r'ea$1 findings for AAR Also I asked Mr. Karner if he ddress AAR#1 to the NDE Supervisor per A. Eck's directions. Mr. Karner verbal response-was no that he would provide a resolution to AAR#1 findings. At this time I recommended that the AAR#1 l findings be identified in a Discrepancy Report to L PG&E for review. In addition, I stated that sub-sequent investigation of ESD 236 - UT Thickness Measurement of Boundary Valves may be required to have a PQR. l l

.]'};? .~10l

a.,

w ';, 'W F. On 9-15.82Mp$$paredian' Int'eroffice Correspondence ~ ~ ~ V6 7."AMIO1,1. AARF1TF116;-and"T6-~the QI/QUTMahaset' 'd.noumHtthg. aMonfererice1 held "to formulate a revised ~ re s ponse Tt oiAAR7/1. ( s e e ?. attache d ). The following actionEwassagreedJon>by;the-QA/QC Manager, NDE Supervis'orlandithe Internal Auditor._

1. - ESD(23Motild$ ave;fa Procedure Qualific& tion Test

' p'effornied. Lidsnljbc. 41dioul'd6be?r tryiiigf$h'at?.th,ep.orted :.on <a DR to'!PG&E. 2. ESD ere^was2no'PQR ahddthat the UT ?eYAMWatiozie:psreEperformed. prior 'to ESD 241 being{iasued2byTblidgg?sndapprovedbyPG&E. 3. ESDF246iand?ESD;247pwould have. additional invest-igati'oni.brf6fmsdabsfoie a decision; as to correct-ive action /would be<made. 4. ESk 270'woulddlav% incorporated into,'its proced- .urs-the TQRF.of E'SDT210 5. ESD' 236 w'ouldibe: withdrawn from use and again . the QA/QC[;Manpgefditated< he felt no PQR / required. G4, On 10-13-82iaii-Inhero'ffice. Dorre.ap~ondence '(seesaistache was-send:to the.iQA/QC; Manager requesting af" Revised Written Response to AAR#1, I.A.'#101". It'was stated in this IOC that?PG&E C.S. #8711 and #8833XR required all! condi:tions adverse to quality to be promptly corrected. H. .On 11-3-82 a proposed Discrepancy Report concerning ESD 241 was prepared'by2me in compliance to the 9-14-82 conference to formulate a revised response to AAR#1. (see attached) 1. This proposed DRewas reviewed by QA/QC Manager H. Karner'andhhe wrote comments concerning the DR (see attached), 2 The proposed DR was reviewed by M. MacCrae and he wrote comments concerning'the DR (see attached) 3. On 11-22-83 I send an Interoffice Correspondence to QA/QC Manager -(see attached) responding to Karner's and MacCrae's comments of the. proposed DR. It should be noted that subsequently QA/QC Manager H. Karner would refusetto submit the DR to PG&E identifying ESD 241 discrepancies. m 4 w_____..__.__

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  • A y;.7 p

p-p v.x M*,, c c :- - I; On-1-1-2-83-a-PPP-Message-(seefttached) was, send._ to QA/.QC< Manager H. Karner requesting he provide revised corrective.act' ion.to 'AAR#1. At'this time.the9QA/QC.0Mahagerswas isformeds.hejwas in J t non' onformance 'to >100PR50' App'. 6B XVI and PG&E C.S. c

  1. 8711)Sdet'io( s3):281:addT#8833XR Section33.4.1210.

~ ggf .my ' f y ' On :1-211-83 Nj.m. nd0 s e r O f f i^c's C o r r e s p o n d'e n c e,( s e e L J. attachsd)).wasisdddhoMheZQA/qCHManager?. indicating that' Corpord,tV:lAuditGTITPleS3.,t AARF10 had? identified that'ths'reinited"nsmb'zvof;fInternal Audits lfor 1982.- J e . had notLb'eerdd16seafoutPaddithatra revised'c'orrective aotionErespo.~ns'e,Was Tussded f. or iAR#1. .m. ~. .a- .p. ..F m,1H -It should be notei14t51stigA/QCsManager,dny. Karner did not provide any' resp 6nses?to7anyAofAthe>a correspondences requesting airevise'di,'6orrectitseactios. It is alleged that QA/QC Manager EL"KarnerTdelibe'rhtaly procrastinated in providing a reiris6d16brrectipeCaction to.AAR#1 to avoid I ' identifying theseldi'screpanoiessto'PG&E; add Pullman Corporate Management andi bscause he t.wascunableMo 'formulateJ a, proper. corrective? action.3 ! t/isValleged;thap QA/QC Manager H. Karner deliberat~ely 1'slatedslO.0FR50 App /B XVI and*PG&E C.S.

  1. 8711 SectionT4.3T2 szfd@8'833XRESention3.4 1210' require-ments that ' cosditiohs$adverseftoiquhll1.ty.be.; promptly id entifie-

-reported and 16rrected C It\\1s' alleged that Pullman Corporate Director of.Quali'ty":.16s'urance.i.. Ak Eckjfailed to expedite corrective action.:ence henwas.made aware that the'onsite QA/QC Manager was not providing a prompt response to AAR#1 findings. l

3. On 1-28-83 QA/QC Manager H. Karner and myself had a violent verbal confrontation concerning AAR#1 and anothert. issue.

DuringreviewofRuptureRestraintD$cumentationforinvest-igation of Unscheduled Internal: Audit #' 35.I identified three full penetration ~ welds that had NDE $y MT inst.e'ad of the C.S. required UT process. While preparing to report.these dis-crepancies, Mr. Karner confronted me,atymy desk'and wanted to know what I wasidoing..:Ilinformed^him that I had identified Rupture 9Re'straint"NDESdis6repancies.- Mr. Karner i then asked me -i'f/ I/haddesnyi11 rested (by<him to identify '.these problems. I' stated thatkhe>had4not'. directed me-to identify the problems. Mr. Karnsr.1.atFthis" point; began to scream and-shout at me that. I;was.nos16dger(therInternal Auditor- (I had ) ~ been replaced.but giv.pnjipermission to' conclude two. audits j in progress, oneiof1vhibh Nas"U.I.A. #35) and.that.I was only to do what he ' told me. <In effect, Karner was telling me'that I I as a QA/QC Inspector could:no longer identify discrepant / conditions unless~specifically order tofdo so by him. Mr. Karner screamed at me that if I did'this again he would get rid of me.

< ~ m.;g,.,3 p- .y Mit / e Karner then' accused me of(g6 igg to' unscheduled' audits to.gst.~ardunT i s,. Tov 117o%'tYe 7Emdit ch~e~cklist'.- He~ accused:me io'f eii erseM o4 quality..At-this point I screamed 4at' 's' s$ thhhbeen' sitting. on' AAR#1ief I. A. l#101Mfik ' T ' Aihd$p"ra.tNhs$s' '. Violating 100FR50 s s App /B:XVIl#dndl 'Ohnt 'etUrdquiremen.tsibf not ' prompt 1f*d6tf ~ ' ' verseStogidality. :QA/- .QC Manage W 5 tater,tha Uit.yas OK. for himttoq 1%t 'd20odtrac,ts'.PlHe repeated this - statsidenF a:rndrfalhoEstateduthatinne of the rs sousMylit audits doHeW as hs "fdidd3 ghnye~all'.'the> required.1982 vis,tigated' items not~on al checklis'tloisfrfs1Vadt? respon'ds'dito this by saying one reasonLw'ss?.thhtihs'h dybsyn" sitting on an' audit ( AAR#1, I. A,.L#1011). Tor a~f ye.ar. c - .7, face to face;"screa%hshtthis-time we.were toe to toe, I should pointzout mingThtsach other. Mr. Karner again ~ that I.was only. :to do what he told me toido't repeatjed;hterpr& tad :to mean that I twhi6U Ifi could not rideiftifyfQu'ality issui'ad'oesdiscrepancies unless.speci'fi'cally fo'rder' ed?to do 'so. This -conf 2iontation was'.witnessedtby numerous persons in ths QA/QCf0ffi6b'.~i' W G " ~ a ;. .' " vgy _ ,.g This confii.ontationipro^duced7two'significant' conditions adverse'tiju'alifyb" 4 1. As a QA/QC' ins ector Ikas oi'dered by the QA/QC Manager 'not?to id' ntify; QA discrepancies unless e specifically.orde~r'toido so{by the QA/QC Manager. If I did'I would;be'gotten rid of. This was an attempt to.intd.midatA'me;from identifying ~ discre' pant condi'tions.. This violates 100FR50 App. B I requirement thatspersonb performing quality assurance fune.tions.c hall hgtve sufficient ' authority s and organizati'on3 free' dom to. identify quality problems 2. The QA/QCiManager, stated.he'did not 4tave'to comply with 100FR50".Appr Brand CLS.i requirements to promptly sorrecticonditions? adverse to quality. This tis. a? base tvi.olatioh of. Quality Assurancer i requirements. /QA/QC" Manager H. Karner'has.demonstrat this disregard for this QAfrequirement in his lack of corrective action for I.A. #101, AAR#1 audit findings, in a timely manner. Internal Audit #101 identified significant Quality Assurance discrepancies in the 2 aTif'ir'ation2.of NDE;and: UT thic.kness meas-0 ~ uring_ procedure.s. Subsequen$17,;s'igMficantTQrdH5fshnci~es took place in the itoplemenQgicf)6oriiective notion toithe audit findings. The issuesfideht1*fied ih Mhis report and I.A. # 101 should be investigate ~d'by'the NECit @ assure that quality assurance has notabeen compromised.at the Diablo' Canyon Nuclear Plant. A- )}}

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