TXX-4087, Forwards Rept Re Investigation Into Allegations Made by Wa Dunham & Concerns Related to Protective Coatings.Related Documents Encl
| ML20087B046 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/13/1983 |
| From: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20087B027 | List: |
| References | |
| FOIA-84-2 TXX-4087, NUDOCS 8403080335 | |
| Download: ML20087B046 (22) | |
Text
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l TEXAS UTILITIES GENERATING CO.ilPANY 3001 SRYAN TOWER DAh TE.\\ AF 78201
".h..'.' [.b.*.'l' December 13, 1983 TXX-4087 John Collins Regional Administrator U.S. Nuclear Regulatory Comission 611 Ryan Plaza Dr. Suite 1000 Docket Nos.:
50-445 50-446 Arlington, TX 76012 COMANCHE PEAK STEAM ELECTRIC STATION INVESTIGATIONS INTO ALLEGATIONS l
FILE NO.:
10066
Dear Mr. Collins:
In accordance with our agreement, enclosed please find a copy of the report of our investigation into allegations made by W. A.
Dunham and concerns expressed related to protective coatings.
Very truly yours, l
e RJG:In Enclosure NRC Region IV (0 + 1 copy) cc:
Director, Inspection & Enforcement (15 copies)
U.S. Nuclear Regulatory Comission Washington, DC 20555
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8403000335 040120 P
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TEXAS UTILITIES GENERATING COMPANY I
. 0T0-481 0FFICE MEMORANDUM October 25. 1983 Danu, Teme.
T.
D.N. Chapman INVESTIGATION INTO ALLEGATIONS MADE BY W.A. DUNHAM AND CONCERN 5 EXPRESSED RELATED TO PROTECTIVE COATINGS Subjee 19, 1983, to D.N.
In accordance with B.R. Clements' memo dated September Chapman, an investigation was conducted into allegations made by William Bill Dunham, in filing Fom B-3 (1282), Initial Claim for Benefits, with the Texas Employment Commission, indicated in part, "I was fired Andy Dunham.
for identifying quality problems..."
The first part The investigation was basically a two part investigation.
included discussions with Bill Dunham, with other inspectors he suggested I talk to, with persons attending a meeting between the Corrosion Engineers and and persons preser.t at the QC Coatings Inspectors on August 24, 1983; The purpose of these discussions was to 26, 1983.
counseling session on August detemine if Bill Dunham had been dismissed for identifying quality problems.
The details of the first part of the investigation are included in Attachment The allegation that Bill Dunham was teminated for identifying quality A.
problems was refuted.
The second part of the investigation followed up on matters initially brought up during the first part of the investigation.
The rest of the coatings QC inspectors, both day and night shifts, were also In addition, Mr. Harry Williams, the former Coatings QC interviewed.
In addition, TUSI Supervisor, was also contacted at his present job. Engineering pe supports engineering decisions was examined.
These Basically, six technical concerns were voiced during the investigation.
The technical concerns were itens are detailed in Attachment B Part 1.
discussed with TUSI Engineering and with the Principal Corrosion Engineer for The Gibbs & Hill Specification AS-31, " Protective Coatings," was Industry standards referenced in the G&M specification, and site Ebasco.
procedures for coatings application and inspections were also reviewed.
reviewed.
The validity of each of the technical concerns was evaluated in light of specification requirements and requirements in referenced and where deemed necessary, Design Basis Accident (DBA) testing reports were examined to further assess the validity of engineering conclusions.
On the basis of the above, the technical concerns expressed by the inspectors were found to be unwarranted.
QTQ-431 10/25/83 Page 2 The allegations of harassment, intimidation, and threats were investig These The results of this investigation are deta-11ed in Attachment B, Part 2.Also phrases had varied meaning to different inspectors.
were seen differently among the inspectors, and perceptions varied fr These discussions were highly subjective.
occurrences to improper actions.
In summary, inspectors working under the previous coating QC Supe Mr. Williams, Harry Williams, perceived less than total support from h He stated inspectors were right but could not support an inspector when wrong.
that these disagreements came about primarily because of inspector However, better procedures reflect unacceptable technical practices.
supervisory practices at times of disagreements would have helpe Morale problems are worsened by a small, but very vocal and articulate, group of inspectors who appear technically know the adverse morale effect.
and 40 have a disproportionate amount of influence within incidents resulted in inspection omissions which constitute a safety concer Coatings QC force.
It is recommended that a procedure be establish This procedure that arises when craft and QC supervisors become invo between the inspectors and their supervision.
These are Management actions relevant to previous allegations were reviewed detailed in Attachment B. Part 3.
properly covered the scope of the allegations made at that time and t management actions taken as a result of those investigations were ap in addressing the problems identified at that time.
Inspectors' concerns related to the Protective Coatings Program at CP The investigation concluded evaluated and detailed in Attachment B. Part 4.
that the use of the IR UNSAT instead of the NCR for activ reworked to meet engineering requirenents is con B.the IR to address missed hold points.
In addition, inspectors expressed a programmatic concern that there are no provisions by which inspectors can express technical c a policy decision must be made to define the extent to which inspector feedback.
technical questions are to be answered, especially if other disciplines are involved.
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QTQ-481 10/25/83 Page 3 Another concern related to the program is that there are no provisions for The engineering recertification of coatings application personnel.
specification and referenced industry standards do not specifically require However, this area will be audited during the week of October recertification.
31, 1983. Any areas found deficient will be handled in accordance with approved procedures.
i During the investigation, two management items that are significantly affecting These are detailed in Attachment B, Part 5.
The inspectors were noted.
They inspectors state that they have been working six 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> days per week.
state they have been on this schedule since May of 1983.
Ins;6 tors state There their proficiency, objectivity, alertness, and tempers are suffering.
appears to be an urgent need for additional Protective Coatings QC Inspectors.
This item was brought to the immediate attention of site and Dallas QA management.
The second item is one of a perceived compensation disparity between Ebasco and B&R inspectors note that eli Coating QC Supervisors i
B&R inspection personnel.They state the client does not want B&R Coatings QC t
are Ebasco personnel.
In addition, they state that Ebasco personnel get sick leave, Supervisors.
They state paid holidays, per diem, and regular salary, while they do not.They state it has that this is the most significant item affecting morale.
surfaced in Coatings but is festering in other areas, including Electrical and Mechanical disciplines.
This item was brought to the immediate attention of TUGCo site and Dallas QA management.
I have two additional observations which are of concern.
First, some inspectors interviewed appear so hostile that I believe they are adversely affecting the Protective Coatings QC Group in perfonning its assignment.
Secondly, the refusal on the part of some inspectors to recognize Engineering decisions on technical matters, and their refusal to accept QA Management decisions such as the use.of the IR in lieu of the NCR, constitutes insubordination and creates an unmanageaole situation.-
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Antonio Vega AV/brd Attachment
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ATTACINENT A 9
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DETAILS:
In accordance with management directives, an investigation was initiated on l
to investigate William A. Dunham's allegation that he had Septenber 19, 1983 been " fired for identifying quality problems."
Prior to any discussions Bill Dunham's personnel file was reviewed to obtain a basis for further investigation.
DISCUSSION WITH W.A. DUNHAM:
Mr. Dunham was contacted and advised of the purpose of On September 20, 1983Mr. Dunham's initial statement was that he wanted me to 4
the investigation.
know that he had previously reported his supervisor Harry Williams, to the NRC; and to Tom Brandt, Gordon Purdy, and Ron Tolson, for intimidating, harassing and threatening his inspectors.
He suggested that I interview certain inspectors to obtain details.
He stated that when he initially reported his concerns to Mr. Purdy, he was Mr. Dunham stated that his objective in going to Mr.
promised confidentiality.
He stated ha Purdy was to request a transfer out of Protective Coatings QC.w therefore feels Mr. Purdy did not keep his promise of confidentiality.
Mr. Dunham stated that on Tuesday (August 23, 1983) he was advised that he could not have Friday ( August 26,1983) as his day off. He came to work on Dunham stated Evert Friday, and at 4:00 p.m. went to Gordon Purdy's office.He stated none of these Mauser, "Curley" (Krisher) and Purdy were there.
He stated the meeting lasted persons were in his supenisory chain of command.
two minutes and that it was a " set up."
He stated that Harry Williams, his supervisor, was not present; that WilliamsHe had missed that day because Williams knew that he (Dunham) was being fired.
further stated that he did not consider Purdy his supervisor.
He stated that he I asked him about the meeting with the Corrosion Engineers.
I asked had raised his hand before speaking and that he had spoken the truth.
He him what he had said in this meeting that was considered disruptive.
~
He stated that he considered me an replied, "I'll tell you in court."He suggested I contact several inspectors.for adversary.
problems."
DISCUSSIONS WITH CPSES SITE PERSONNEL:
In regard to this phase of the investigation, Messrs. Evert Mauser, M.G.
"Curley" Krisher, C.T. Brandt, R.G. Tolson and the suggested QC Inspectors were In addition, Thos. Kelly, Principal Corrosion Engineer for interviewed.
EBASCO, was interviewed.
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The substance of several key events was established as follows:
)
On Wednesday, August 24,1983, a meeting was arranged between the Corrosion Engineers and the QC Inspectors for the purpose of discussing 1.
changes made to the procedures, their technical basis, and to answer any During this technical questions that the QC Inspectors might have.
meeting, Mr. Dunham persisted in bringing up for discussion, non-technical In addition, Mr. Dunham was reported to have made supervisory problems.
gestures of hopelessness with his hands and verbal the competence and integrity of the engineers.
Following this meeting, Curley Krisher, representing Tom Brandt at the In meeting, discussed with Mr. Dunham h1s behavior at th 2.
Mr. Brandt adverse feelings about Mr. Dunham's conduct at the meeting.Mr. Tolso met with Mr. Tolson and Mr. Purdy.
should be fonnally counseled and given a three-day furlough without pay.
Mr. Krisher Mr. Tolson directed that this be done as soon as possible.
was assigned the responsibility to prepare the counseling report.
Mr. Tolson inquired as to the results of the 26, 1983, On Friday, August Mr. Tolson was advised that the counseling session counseling session.
Mr. Tolson advised Mr. Brandt and was scheduled for 4:00 p.m. that day.
Mr. Purdy that their failure to conduct the counseling session soonerMr. Tolson d would render the three-day furlough ineffective.
the three-day furlough be eliminated and that Mr. Purdy limit his action Mr. Purdy acknowledged Mr. Tolson's directive to a counseling session.The counseling form was prepared on Friday, August 26, and concurred.
During the day on Friday, Mr. Brandt's secretary called Mr. Dunham to obtain his badge number, since it is required to be shown on the form.
1983.
Because Mr.
The counseling session took place in Mr. Purdy's office.
Purdy is the top BAR QA/QC representative on site, Mr. Purdy personally 3.
Mr. Mauser was conducts disciplinary meetings involving B&R employees.
3 representing Mr. Williams who had telephoned in sick with back prob Mr. Krisher was representing Mr. Brandt.
Mr. Dunham handing to Mr. Dunham, a copy of the counseling report.
reviewed it briefly, apparently not reading it all, and threw it back to l
Mr. Purdy, saying either:
"(Expletive deleted) it -- you might as well walk me to the gate because I'm not going to change," or, i
"(Expletive deleted) you guys -- you might as well walk me to the I'm not going to change the way I am -- just walk me to the gate.
gate." or, You might as well get my time and walk I've had it.
"No, damn way.
(Saying later, "No (expletive deleted) way -- this me to the gate."
ain't gonna (expletive deleted) work -- I don't have to take this i
shit.")
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Mr. Purdy made two more efforts at asking Mr. Dunham to settle down a These efforts were discuss what was perceived as an attitude problem.Mr. Purdy asked Mr. Dunhan.
answered with similar cements by Mr. Dunham. After Mr. Dunham's response, if he was sure that "this is what you want."Mr. Purdy then entered a handwritten Mr. Purdy said, " Fine, let's go." summary of what transpired in t report, a copy of which is attached as Attachment 1.
Mr. Mauser accompanied Mr. Dunham to the QC trailer to personal belongings.Mr. Krisher accompanied Mr. Dunham to the time office at the QC trailer.
Mr. Dunham signed the where Mr. Dunham's brass and badge was picked up.This termination form is termination fom "(expletive deleted) Lie."
attached as Attachment 2.
On the basis of the above, I have concluded that Mr. Dunham was no Mr. Dunham's conduct and statements at the for identifying quality problems.
counseling session, in substance, constitute a request for v temination.
rejected by Mr. Dunham.
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EMPLOYNE'S NAME Bill CU'iHAM C955 DEPARTtE C OC BADGE KLMBEP.
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Co==r.mication Bill', you have on several occasions verbally expressed SUPEPNISOR'S STATDE3:a complete lack of confidence in tne project protective co The most recent ind the specific incident of was recorded and Production, program.
in the QC office on Wednesday 8/24/E3, during the open information er. change P.C. consultants and the Ouality inspectors.
and/or expressing scorn of and for the program was disruptive, by scof fing at, counter-productive and unproffessional.
The described attitudo and sc+ ianc raanat and will not be tolerated and any further demonstrations of this nature will result in disciplinary action.
Yes M No Did/Could this cresce a Po:er:ial Problen:
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ATTACHMENT B O
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e DETAILS:
1.
Technical Concerns During the course of the investigation, ir.spectors collectively brought up the following technical concerns:
The primer is then water cured for two Zinc primer is being applied.
(2) hours, and a top coat is applied immediately thereafter.
a.
According to some inspectors, this is too soon.
The " nickel" test (where a coin is used to test the curing status of the primer) should be used in conjunction with curing tables, taking b.
At CPSES the " nickel" test is account for humidity and temperatures.
used exclusively to test primer curing.
The substrate profile on hangers is too slick for proper adherence c.
between it and the primer.
Instances have been identified where zine primer is being applied over Phenoline 305 topcoat and questions whether this has been DBA d.
(Design Basis Accident) tested.
Successive coats of zine primer are being applied.
Inspectors state r
that primer will adhere to substrate and to topcoat, but not to e.
itself. They cite this as a reason for delamination within the primer thickness between successive applications, Storage provisions, including compatibility among primer and topcoat f.
batches manufactured during different time frames; and pot life restrictions on zinc primer.
Interviews with engineering personnel were conducted to assess the validity of these concerns. The results are as follows:
In regard to water curing time of Carboline C2-11 zine primer, prior a.
to topcoating, the following documents were reviewed:
Gibbs & Hill Specification 2323-AS-31. Rev.1, March 15,1978, I
1.
l
" Protective Coatings" ANSI N101.2, " Protective Coatings (Paints) for Light Water 2.
Nuclear Reactor Containment Facilities" ANSI N5.12. " Protective Coatings (Paints) for the Nuclear 3.
Industry" ANSI N101.4-1972, " Quality Assurance for Protective Coatings 4.
Applied to Nuclear Facilities" TUGCo Procedure QI-QP-11.4-5, " Inspection of Steel Substrate 5.
Primer Repair and Seal and Finish Coat Application and Repair" B&R Procedure CCP-30. " Coating Steel Substrates Inside Reactor 6.
Building and Radiation Areas."
l
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The first four documents do not impose any QA requirenents on 2esting for The document that addresses curing is B&R Procedure CCP-30, which is referenced by TUGCo' Inspection Procedure Ql-QP-11.4 prime coat curing.
This procedure bears the approval signature of a TUSI Eng representative.
either curing time tables og the following:
" Carbo Zinc 11 is sufficiently cured for top coat when the coatings may be burnished rather than removed when rubbed with the flat This same portion of a smooth edged coin such as a nickel."
paragraph further states, in part, " Application o l
This acceptance criteria is endorsed by the manuf sufficiently cured to topcoat when the film is able to burnish whenIn re scrapet ith a coin, rather than renoved."
water spray, a Telex from Carboline states, in part, " Force during of Carbo Zinc 11 by fine water spray or low pressure steam is acceptable prior to topcoating Carbo Zinc 11."
2 The documentation supports the following conclusion:
7 Forced water curing is an acceptable process that may be used as 1.
often as necessary to obtain proper cure.
Topcoat may be applied after proper primer coat cure has been The detennination of cure can be based on curing 2.
obtained.
tables whien require time, temperature and humidity measurements, OR, physical testing of the coat for a burnish, In regard to the use of the " nickel" test exclusively without concurrent use of the curing tables, item a. above adequately b.
There is adequate justification for addresses this concern.
exclusive use of the " nickel" test as a physical confirmation that proper curing has been obtained.
In regard to the concern that the profile on hangers is too slick for proper adherence between it and the primer, the following documents c.
were reviewed:
In G&H Specification 2323-AS-31, Rev.1, March 15,1978.
p4ragraph 4.2.a. it requires that the surface preparation of 1.
substrates conform to the applicable requirenents of ANSI 101.2 and lists some exceptions.
ANSI N101.2 under Section 6.3.1, Carbon Steel, states, in part, "The surface shall be cleaned in accordance with SSPC-PS-10, 2.
'Near White Blast Cleaning'..."
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B&R Procedure CCP-30, Rev.11, dated 8/16/83 in para 4.1.
Preparation of Substrates and Coating Materials, states, in 3.
part, "The surface shall then be cleaned by blast, h SSPC-SP-10 'near white' blast cleaning."
It states, what constitutes compliance with this requirement.
" Typically, power tooling utilizing, but not limited to, 3-M Clean-N-Strip, 80 grit or coaster Flapper Wheels or sanding discs, roto-peans, etc., may be used to achieve surface cleanliness equal to SSPC-SP-10."
TUGCo Inspection Instruction QI-QP-11.4-1, Rev.14, dated 9/23/83, page 4 Section 3.2.2.c requires the inspection of 4.
anchor pattern depth at random locations using a Keane-Tator It Surface Profile Comparator, Model 373 or equivalent.
It further requries a minimum of 1.0 mils anchor pattern depth.
states, " Surfaces that have been power tooled with 3M Clean-N-Strip, 80 grit and coaster " flapper wheels," sanding discs, " roto peans" or equivalent, provide acceptable surface profile."
The above documents demonstrate that substrate pr N101.2 document, are accurately reflected in site application In addition, DBA testing procedures and inspection procedures.
documents indicate that panels tested and primed with Carbo Zinc 11 have a surface preparation in accordance with SSPC-SP-10 with a 1 mil. (minimta) blast profile.
be without merit.
Instances have been identified (NCRs which have been dispositioned)
Has where zine primer is being applied over Phenoline 305 topcoat.In discu d.
this system been DBA tested? indicates that this procedure was used o
" Spot" or minor defects are defined as an area, either circular or linear, in which a 1/2" diameter circle could not be completely inscribed at any point along the entire length.
35-1195-CEI-9, dated Novenber 11, A "Special Engineering Instruction" 1976, states, in part, " Area will be repaired with appropriate coatings, i.e., Phenoline 305 if damage does not extend to the primer; Carbo Zinc 11 and Phenoline 305 if primer is damaged."
Subsequent Carboline documentation as recent as 9/30/83, reconfims the acceptability of using Carbo Zinc 11 as a touchup o 305.
Though we have no hard, fast rules can be removed by hand sanding.
for overlap areas, a one to two inch overlap is not unrealistic."
Based on the coating manufacturer's expressed approvals of the repair process used and its application to minor repairs, the concern and stated need for CBA testing is deemed to be without merit.
-_ __ - - =
In regard to successive coats of zine primer being applied, 9.he j
l e.
following documents were reviewed:
Carboline Telex, dated 11/15/78, states, " Theoretically, Carbo 1.
Zine 11 may be recoated with itself an unlimited number of
... We prefer that the original Carbo Zine 11 prime coat times.
not be recoated with itself more than twice, and only if absolutely necessary..."
/
" Report on Irradiation, Decontamination and DBA Testing," dated 2.
8/16/78, prepared by the Analytical Chanistry Division of Oak Ridge National Laboratory, tests acceptability per both ANSI The test documentation reflects that two N101.2 and N5.12.
successive coats of Carbo Zinc 11 were tested under DBA conditions. Two separate samples were used. The coatings remained intact without defects.
Accordingly, this concern was found to be without merit.
In regard to the storage concern related to compatibility of paint f.
systen component (primer and topcoat) batches manufactured during different time periods, the engineer was interviewed. He most vigorously rejected the statenent that there was any restriction on use of component batches manufactured during different time periods.
He stated that in his experience, with three different nuclear plants and over sennteen (17) years of additional expertence with these particular materials, the vendor has gone to great efforts to assure that both their customers and their inventory provides consistency among stock interchange.
In addition, ANSI N101.2, " Protective Coatings (Paints) for Light Water Nuclear Reactor Contaimnent Facilities," supports the Engineer's position.
It states, "The coatings manufacturer shall maintain a quality a;.surance progran and provide adequate documentation to show that the quality of a given coating system is reasonably identical to that of the coating system qualified under The coating system shall be requalified if there are this systen.
changes in formulation or manufacturing procedure which will alter the performance obtained from a previous test."
Accordingly this concern is deemed to be without merit.
In regard to the storage concern related to pot life, the Engineer states not life expiration is defined by the manufacturer as when the material can no longer be applied successfully by normal methods.
The Engineer states the actual pot life is a function of temperature, pressure, agitation, and thinning. The same applies to shelf life.
The Engineer states the charts are provided as guides only.
The manufacturer concurs with this.
In a letter dated October 27, "The true pot life ends when the product is 1981, Carboline states:
no longer sprayable.
In conclusion, the inspectors' concerns relevant to storage are l
without serit.
l t
In conclusion, technical concerns expressed by the inspectors were discussed with engineering, investigated, and were found to be unwarranted in light of the design specification, referenced standards, manufacturer's j
recommendations and DBA test documentation.
2.
Harassment, intimidation and Threats The entire subject of " harassment, intimidation and threats" as stated by Mr. Dunham, was dicussed with site QA/QC personnel including the pretective coatings inspectors.
The discussions were particularly difficult because what people perceive as being harassment, intimidation or threats varied very significantly In addition, the three phrases were at times used among inspectors.
interchangeably to varying degrees.
In conducting the investigation, questions were formulated so as to attach In the broadest interpretation to " harassment, intimidation and threats."
addition, the phrases " undue pressure" and " coercion" were introduced into the investigation questions to solicit even a broader range of input from the inspectors.
The results are summarized as follows:
One recurring general complaint was voiced involving the previous a.
Coatings QC Supervisor (Mr. Harry Williams) and one " Lead" Coatings Inspector, Mr. Bob Wallace.
Neither person is employed at CPSES at the present.
Several specific instances of this general complaint were provided.
One instance was mentioned by several inspectors where they were b.
admonished on the subject of " nitpicking" during a meeting called by Mrc Willians.
One inspector stated he had been directed to accept primer cure on c.
the basis of a " nickel test" performed on material still wet from water curing. He stated this had occurred 10 to 12 times during the last 18 months that he worked for Mr. Williams.
The details of the above items are discussed below.
The most prevalent complaint was that in several instances, when an a.
inspector rejected an item, the craft foreman would go to the craft general foreman, who at times would also invlove the craft They would collectively get Mr. Williams, the superintendent.
Coatings QC Supervisor, and converge at the point of inspection with Different inspectors viewed this differently.
Some the inspector.
inspectors stated they saw this as part of their job and something that is expected ano experienced on any construction job. Others saw this either as harassment, intimidation, undue pressure or coercion to varying degrees. Only one inspector was adversely influenced on i
l
In this instance, the inspector was inspecting the The inspector noted two areas of weld one occasion.
topcoat on the polar crane.
spatter over the topcoat that the inspector felt needed to be kno off prior to final acceptance.Mr. Williams agreed that one area needed to be cleaned was off site.
However, he disagreed that the off and retouched and this was done.This area was not cleaned off and th second area was weld spatter.
The area where weld remained inspector signed off the inspection.
From a was described by the inspector as "the size of a quarter."
safety standpoint, the remaining spatter bears no significance.
Mr. Harry O. Williams was contacted at his current place ofM was being overrun by the craft because engineering was approving employment.
He stated that some inspectors insisted on evaluating Accordingly, some changes.
procedures and changes, which is not their job. inspectors Mr. Williams stated that if the inspector was their procedures.
However, if he was not correct, he would support the inspector.
correct he would not support him.
The " nitpicking" meeting resulted from an inspection of the skimmer pump ruom floor and the adjacent heat exchanger room floor (Elevation b.
The inspectors identified overspray, enbedded 808' R.B. #1).
The craft foreman and the general foreman particles and pinholes. contacted Bob Wallace, Coating QC Lead at that tim Mr. Wallace, who was also a certified inspector, Mr.
Williams, and later Mr. Brandt, the Coating Level III, disagreed with Williams.
the validity of the overspray, and embedded particles de overspray and embedded particles to the 115 surfacer used below the However, they noted some pinholes that constituted an coati ng.
unacceptable condition which had not been identified by the inspectors even though they had spent approximately 12 manhours (2 Mr.
persons working 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) to inspect a 10 ft. x 12 ft room. Wil Mr.
and that the roans in question were examined physically.
Williams stated that he and Mr. Wallace used the examples of apparent overspray and particle embedment as examples of " nitpicking," and pointed out that while doing do, some rejectable pinholes h accepted.
examine these same areas for valid rejectable conditions, such as pinholes, and if he found any, he would pull their certifications.
This is the only incident that could be construed to be a threat.
Although there appears to be some justification for the supervisory action, it would have been appropriate to have discussed these The matters with only the inspectors involved in the inspection.
manner in which this matter was handled is indicative of poor supervisory practice.
Otherwise, the incident is a moot point, in that since then the floors were sanded, recoated and reinspected.
...a..
m nis i ed
One inspector stated he had been directed to conduct " nickel tests" He stated that c.
on material that was still wet from water curing.
this occurred 10 to 12 times during the last 16 to 18 months that Mr.
The inspector stated that he Harry Williams was his supervisor.
initially tried to document this on the IR and by attaching a 3-part He stated Mr.
memo that stated that an item was acceptable "per HW."
Williams would destroy the 3-part memo and bring the IR and ask that The inspector emphasized this was primer work done in it be redone.
the shop and that he could pro /ide no specifics on the irs involved.
Mr. Williams was questioned on this matter.
Mr. Williams stated that on one occasion only, the craft had been t
Some areas were drying off panels used for painter certifications.He asked the inspector wet, but nickel tests were not run on these.Mr. Williams stated that he to run a nickel test on dried areas.
asked the inspector to enter his (Harry Williams') initials on the inspection certifications because they were only for painter certs,Mr. Will not anything that would be used at the site.
denies he ever ordered the inspector to run a " nickel test" on wet He stated that this would be a direct violation of l
material.
procedure and the test would fail. The inspector indicated there was no third party involvement, and so it is difficult to resolve conclusively such contradicting statements.
B&R Procedure CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," and TUGCo Inspection Proceoure QI-QP-11.4-5, which address application, curing and inspection of primer, do not require the primer surface to be dried after waterIn add cure prior to testing for burnish.
Coating Level III state that perfoming the nickel test on a surface The water does wet from water cure does not detract from the test.
not prevent a horizontal force to be applied on the coating to test j
its adhesion to the substrate.
Although this item could not be proven conclusively either way, there No further action is is no technical basis for safety concern.
deemed necessary.
In summary, the allegations of harassment, intimidation and threats were tharoughly investigated. Several conclusions can be drawn.
Inspectors working under Mr. Williams perceived less than total 1.
Some inspectors' stated belief that procedures support fran him.
reflect unacceptable technical practices have brought about occasional confrontations where at times QC supervision disagreed These situations had a greater morale effect with the inspector.
because a small, but very vocal and articulate group of inspectors who appear knowledgeable on the technical aspects of protective i
coatings, have had a disproportionate amount of adverse influence l
within the Protective Coatings QC force.
i i
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None of the incidents identified resulted in any inspection omission 2.
that constitutes a safety concern.
The inspectors spoke favorably of their present supervision.
3.
However, there is a small number of inspectors that essentially refuses to recognize and support the fact that Engineering, not QC 1
inspectors, is responsible for determining what application practices meet design requirements and what acceptance criteria are to be used by the inspectors.
3.
Previous Management Investications As a result of Mr. Dunham's previous discussion with QC supervision and managuaent, two previous investigations were conducted.
This investigation One of the investigations was conducted by Mr. Brandt.Mr. Brandt interviewed was conducted during the first week in July,1983.
eleven (11) coatings inspectors, including two that Mr. Dunham stated Mr. Dunham made two allegations. The could substantiate his allegations.
first allegation, that Mr. Williams had publicly reprimanded Mr. Dunham, was not substantiated.
The second allegation, that Mr. Williams, who was not a certified inspector, had instructed Mr. Dunham on how to perform a " nickel" test, No direct changes were made as a result of the was substantiated.
Mr. Brandt conducted a general meeting with Coatings QC investigation.
The inspectors raised only one personnel to discuss the NCR/IR program.Mr. Brandt also invited inspectors to question and that was answered.
come in any time to discuss any directive issued by him or represented to have originated with him.
Mr. Brandt stated he and Mr. R.G. Tolson, TUGCo Site QA Supervisor, had previously tried to remove Mr. Williams from a supervisory role but were restrained by QA Management in Dallas.
Mr. R.G. Tolson, as a result of his visit with Mr. Dunham, after Mr.
Dunham's visit with Mr. Purdy, directed Mr. B.C. Scott, the Non-ASME QA Supervisor, to conduct interviews to ascertain problems and arrive at Mr. Scott interviewed Mr. Wi.111ams and Mr. Dunham.
corrective actions.
The first issue was that Mr. Scott concluded there were two major issues.
Mr. Williams sided with Construction and did not provide adequate feedback The second issue was that inspectors wanted to issue NCRs l
to his people.
instead of "Unsat irs."
i Mr.
Mr. Scott stated that Mr. Dunham did not have any other problems.
Dunham stated the biggest problem was with Harry and Farry's way of doing i
j things.
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9
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Mr. Scott was aware of the plans for a general meeting with inspectors to discuss the ER/IR program and curtailed the interviews and reported his Subsequently, Mr. Tolson visited infonnally conclusions to Mr. Tolson.
with Mr. Duaham at a barbeque held to bring the craft and inspectors Mr Tolson stated that Mr. Dunham never mentioned F
closer together.
" harassment" or intimidation, but Mr. Dunham did mention that he didn't care for Mr. Willians.
Mr. Tolson stated that during the last 1-1/2 to 2 years he was under a Mr.
restraint from QA Management in Dallas in regard to Mr. Williams.
Tolson stated that at that time he wanted to reassign Mr. Williams out of a supervisory role but was restrained.
Mr. Chapman stated Mr. D.N. Chapman, TUGCo Manager, QA was interviewed.
that approximately a year ago, Mr. Tolson reported to him that Mr.Mr. Chap Williams had shortcomings as a supervisor.
described the weaknesses as comunication difficulties and a general lack Mr. Tolson reported that he had looked into of supervisory strengths.
statements made at the licensing hearings regarding suppression of NCRs and that it was his conclusion that Mr. Williams was not harassing his people; that Mr. Williams was trying to do an earnest day's supervisor.
and Mr. Tolson, that since Mr. Williams primary strengths were in civil / structural areas which were winding down, Mr. Tolson should contact Mr. Williams' employer, OUCI, and arrange for an orderly transition to Mr. Chapman stated the plan was to phase out Mr.
another project.
Mr. Chapman stated that Mr. Tolson Williams over a period of time.
subsequently advised him that he had contacted DUCI and advised them to start looking for a new assignment for Mr. Williams.
It is the conclusion of this investigation that Mr. Brandt and Mr. Tolson conducted their own investigation to address matters as they perceived In addition, Mr. Chapman, similarily addressed the them at that time.
matter of Mr. Williams' reassignment consistent with the facts presented The insistence for an orderly phasing out of a person's service, l
to him.
in light of decreasing activities in his primary area of expertise, is At the time this decision was consistent with good manageraent practice.
made, the present situation had not materialized, since Mr. Tolson, Scott and Brandt's investigatians had not yet occurred.
i 4.
Programatic Concerns Inspectors expressed the following programmatic concerns in the area of protective coatings:
Some inspectors expressed concerns over the use of the IR UNSAT instead of an NCR.
Inspectors state an IR UNSAT can be resolved a.
without Engineering review and input.
I st
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9 q
This concern was irwestigatm'.
It was determined that an NCR is I
required when a deficiency is such that it cannot be reworked to l
bring it into compliance with Engineering requirements.
In this case Engineering resolution to either use-as-is or alter the t
However, if the deficient condition can requirenent, is necessary.
be brought up to Engineering requirement by rework, the use of the IR This concern UNSAT is entirely consistent with 10CFR50 Appendix B.
It should be noted that on September is deemed to be without serit.
QC management on site had a general meeting with coatings 29, 1983, There is inspectors to discuss this philosophy and answer questions.
a resistance on the part of some inspectors to accept this perfectly acceptable practice.
Some inspectors stated that the program does not define how to b.
resolve instances where surface preparation hold points are not observed.
TUGCo Inspection Procedure This concern was investigated.
QI-QP-11.4-1, ' Inspection of Steel Substrate Surface Preparation and J
Primer Application," Section 3.5 states that inspections required by Section 3.1 through 3.4 shall be documented on an IR.
(Section 3.1 through 3.4 include surface preparation.)
Section 3.5 further requires that a reject tag be applied to an UNSAT area together with Section 3.7, "Nonconformances," states that the inspection report.
non-conforming conditions shall be reported on an IR in accordance l
Accordingly, an inspector who is asked to perform with CP-QP-18.0.
)
an inspection subsequent to Item 7 (inspection of surface preparation) on the Inswetion Report in Attachment 2 of the subject procedure, and notices a lack of QC signoff on the previous steps, should identify this on the IR itself.
However, since there is confusion on this item, there appears to be a need for further indoctrination and training of inspectors on this subject.
Inspectors state that there is no method by which inspectors can c.
express technical concerns and have them reviewed by appropriate percons or organizations.
This iten was discussed at the several levels of QC supervision. QC r
supervisors stated a willingness to accompany inspectors to visits Evidence of with Engineering or higher levels of QA/QC management.
this was seen, in particular the meeting that was set up between the Coatings QC Inspectors and the Corrosion Engineers.
That meeting, however, was apparently not productive in that non-technical subjects were persistently brought up by Mr. Dunham for discussion.
There appears to be a need for management involvement in deciding to what extent inspectors' questions should be answered, especially if electrical, mechanical, and structural disciplines are to be handled accordingly. The TUGCo " hotline" might be considered as a means by which inspectors can voice their questions.
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l Inspectors state that there are no provisions for recertification of As a result of this concern, the d.
coatings application personnel.
Engineering specification and referenced industry standard in accordance with the coating applicators' qualification procedures.
reviewed.
It is Recertification, however, is not specifically required.
Construction Managenent's position that a recertification program is Construction Management states that irs are reviewed Trends are brought to not required.
on an ongoing basis and trended by forenen.the applicable f perfonnance of his people.
Any deficiencies observed This area will be audited by TUGCo QA.will be reported for reso procedures.
5.
Management Items During the course of the investigation, several items of management significance were voiced, The Coatings QC Inspectors state they have been working 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a.
day, six days a week for months.
inside containnents, the number of inspectors has not inc Inspectors state accordi ngly.
effect on proficiency, alertness, and objectivity.This creates a feeling that schedule pressures affect craft tempers.
l of hostility that gives rise to a feeling of harassment or intimidation.
Several Some B&R inspectors complained of a campensation disparity.
inspectors sta+.ed that Ebasco personnel hold the QC supervisory job b.
get sick leave, get paid holidays, per diem, and a regular salary.
They state it is apparent that the client does not wish to have B&R They state they do not get sick leave, paid holidays, Some inspectors stated supervisors.
per diem, and are paid on an hourly basis, l
that the compensation discrepancy is the most significant item They state that the affecting morale among B&R QC inspectors.
l results are evident in coatings but that the same prob disciplines.
Some inspectors complained that they did not have adequate facilities They stated that it would be helpful if c.
to do their QC paperwork.
f acilities that are well-lighted and away from unnecessary
~
interruptions, are. providsd to perfonn their paperwork.
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r a.
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