ML20079J711

Affidavit of SL Hiatt Re Exam of Facility Quarterly QA Assessments & Trend Analysis Repts

ML20079J711
Person / Time
Site:	Perry
Issue date:	12/14/1982
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Shared Package
ML20079J701	List: ML20079J699 ML20079J711
References
NUDOCS 8212280324
Download: ML20079J711 (11)

Text

AFFIDAVIT I, Susan L. Hiatt, duly sworn depose and say that:

1. On November 17 and 18, 1982, I examined t h k lowing documents at the Perry Nuclear Power Plant: .

'82 EC 27 A'O:26 (a) Quarterly Assessment of QA Performance for:

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1st Quarter 1979 1st Quarter 1981 2nd Quarter 1979 2nd Quarter 1981 3rd Quarter 1979 3rd Quarter 1981 4th Quarter 1979 4th Quarter 1981 l 1st Quarter 1980 1st Quarter 1982 2nd Quarter 1980 2nd Quarter 1982  !

3rd Quarter 1980  ;

4th Quarter 1980 f (b) Trend Analysis Reports: [

t Pullman Power Products, July 1, 1981 to October 1, 1981  ;

hobert Irsay Co., January 18, 1980 Dick Corp., Decembcr 15, 1980 I National Engineering and Contracting Co., March 24, 1980 . [

t PBI Industries, February 1,1980 [

Ocneral Electric Installation and Service Engineering ,

Division, February 25, 1980 [

S & M Constructors, September 6, 1979 i i

National Engineering & ContractinE Co., September 6, 1979 United States Testing Co., September 5, 1979 National Mobile Concrete Corp., September 5, 1979 l National Engineering Contracting Co., Scptember 5, 1979 S & M Constructors, August 31, 1979 -

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Oliver B. Cannon & Son, Inc August 30, 1979 (NRs) i Oliver B. Cannon & Son, Inc., August 30, 1979 (ARs) l l

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~2-e United States Testing Co. , August 30, 1979 National Mobile Concrete Corp., August 30, 1979 S & M Constructors, July 18, 1979 Newport News Industrial Corp. of Ohio, February 28, 1979 Dick Corp., February 28, 1979 Great Lakes Construction Co., March 5, 1979 United States Testing Co., Feoruary 28, 1979 Oliver B. Cannon & Son, Inc,, February 28, 1979 Pittsburgh Bridge & Iron Industries, February 28, 1979 AR Trend Analysis SP-38/39, February 23, 1979 Wiss, Janney, Elstner, & Assoc.; hobert Irsay Co.;

heliance Truck Co., February 23, 1979 s & M Constructors, February 15, 1979 Ernst-Comstock, August 1978 to January 1979 National Engineering & Contracting Co., February 14, 1979 Johnson Controls, Inc., February.7, 1979 Pullman Power Products, February 7, 1979 National Mobile Concrete Corp., January 31, 1979 Nonconformance Trend Analysis, November 27, 1978 Great Lakes Construction Co., September 19, 1978 and August 7, 1978 Analysis of FVAs and ECNs, April 13, 1978 Nonconformance Trend Analysis, March 22, 1978 United Stat es Testing and National Mo'oile Concrete Corp. ,

January 31, 1978 Trend analysis of PBI/Kelley NRs, June 16, 1977 Great Lakes Construction, Nhs, March 3, 1977

2. The following representation of the contents of these documents is true and correct to the best of my knowledge and oelief.

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3. The Quarterly QA Assessment reports rated and briefly de-scribed the status, successes, and shortcomings of various QA-related areas of the Perry project, e.g., organization, program development, indoctrination and training, design and configuration control, control of vendors, control of contractors, document control, housekeeping, warehousin6s receiving inspection, start-up testing, nonconformance control, records management, audits, NRC inspections, and non-safety related quality. Each area was rated as either excellent, good, satisfactory, or action required. Later i reports (from 4th Quarter 1981) rated contractors on the same scale. At no time did CEI rate any of these areas, or the contractors, any lower than satisfactory (which is defined as adequate, but deficiencies, if not resolved, may result in adverse effects), even when siE nificant concern .

i was voiced over their adequacy.

4. Celi s ability to organize and control the Perry project QA program was frequently a point of concern. In the 1st quarter.1979 report, organization was regarded as "still- j unstable." It was also stated therein that "last sum =er's relocation (presumable to the PNPP site) resulted in recently discovered voids in document control." In the 2nd Quarter t 1979 report tne project organization was aEain characterized as "still unstable." Continual concern was expressed as to the large numoer of nonconformance reports (NRs) generated and the slow disposition of same. In the 3rd Quarter 1979 l

report, various problems in vendor documentation were de-l l

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serioed as " flexing the receipt nonconformance control system to the creaking point." In the 4th Quarter 1979 report it was stated that the " document control center vault records have oeen evaluated and extraneous materials were weeded out." In the 1st Quarter of 1981 a new method-ology was developed for documenting seismic clearance non-conformances; instead of using Nhs, a " Seismic Clearance Inspection / Evaluation Control Sheet" would be used. This was instituted in an attempt to reduce the large number of Nas being written. In the 3rd Quarter of 1981, the follow-up and close-out of NRs was still a point of concern. The Conditional Helease system was revamped because it has not provided " sufficient control of status." Gilbert Associates' QA records were rated as " marginally sufficient." By the 1st Quarter of 1982 1700 Seismic Clearance. Violations.had Deen written, ~ with no appreciable progress on their dis-psoition. In tnis same report the Program Development section .was descrioed as becoming unwieldy.

5. Large numbers of NRs were dispositioned "use-as-is":

July 1975 to March 1978 46%

March 1978 to Nov. 1978 28%

2nd Quarter 1980 64%

3rd Quarter 1980 40%

4tn Quarter 1980 42%

lat Quarter 1981 30%

2nd Quarter 1981 34%

3rd Quarter 1981 44%

-b-l 4th Quarter 1981 39%

CEI has a target of 50% "use-as-is" for NRs. In the quarterly reports the large number of "use-as-is" dis-positions is attributed to " minor problems" (2nd Quarter 1981) or " installation specifications being too restrictive" (3rd Quarter 1981). However, it is stated in tne March 22, 1978 Honconformance Trend Analysis tnat:

Dispositioning trends on nonconfonmance reports (scrap, rework, repair, and use-as-is) are some-what different than might be expected. The number of "use-as-is" exceeds the sum total of " scrap,"

" repair," and " rework." However, since affected contractors suggest the disposition of the NHs and civil / structural work dominates site activity at this stage, rework, repair, and scrap dispositions are considered to be difficult and undesirable by the contractor and Site Organization. "Use-as-is" proposals are therefore anticipated by QA and both Engineering and QA approve them. From a quality standpoint, .this analysis revealed evidence of general leniency on the parts of Engineering and QA. .

6. Contrary to~the assertions made by Staff and Applicants as to the NRC's augmented inspection program following the 1978 work stoppage, the 1981 quarterly reports indicate the following:

1st Quarter 1981: a " reduction in NHC inspection this quarter," due to tne " policies of the new ad-ministration." dowever, the Metalweld QA break-down was discovered in spite of this.

2nd Quarter 1981: NHC " inspection coverage remains at a lower level."

3rd Quarter 1981: CEI's good rating assigned to this area is a " reflection of the drastic reduction in NhC inspection coverage." During this quarter the hesident Inspector resigned. NRC coverage was considered by CEI to be comparable to 1977 levels.

This was not considered favorable due to a possible

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r negative impact on licensing.

4th Quarter 1981: The decline in rating in this area was ,

attributed to neavier NHC inspection this quarter, largely due to the L.K. Comstock investigation, which was prompted by allegations of workers (see 1st Quarter 1982 report).

7. Contrary to Applicants' statement that the coating con-tractor, Oliver B. Cannon & Son, was terminated "for convenience," the 3rd Quarter 1980 report states that the "other contractor (besides General Electric) on site with serious quality program problems, Oliver B. Cannon & Son, Inc., was terminated during this quarter and replaced as protective coating contractor oy Metalweld, Inc. . . .

tne transfer of coating responsibilities to Metalweld, Inc.

ends a long struggle to . provide an adequate Q4 program under O.B. Cannon." Curiously, none of the trend analysis reports defindd a negative trend for this contractor.

8. In the quarterly reports, several contractors are repeatedly cited as needing improvement:

General Electric: In the first 2 quarters of 1980, GE's -

QA program was described as." deteriorating," with regard to work on the PGCC and reactor safe end modifications. In the 2nd Quarter 1980 report,

" negative trends" were identified as to GE's serious i quality related problems.

In 1st Quarter 1979, NNIC  !

Newport News Industrial Corp.:

was characterized as having a " bad attitude." In the 2nd Quarter 1979 report, NNIC was rated as

" barely satisfactory." Their records management i

was described as being slow and full of errors, l

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j omissions, and mistakes. During the 3rd Quarter of 1979, NNIC was relieved of two equipment packages (which were awarded to GE) due to problems involving

,, quality mknagement and control of the work. In 4th Quarter 1980 and 1st Quarter 1981, NNIC's work on fuel pool penetrations was considered a problem.

National Engineering & Contracting Co.: In the 1st Quarter 1980 report, it was stated that "overall, NECC's .

I quality performance is not good." The trend analyses performed for HECC revealed:

! (a) a neEative trend as to mislocated reinforcing l

steel and a fluctuating trend for "out-of-l plumb." heport dated November 27, 1978.

(o) negative trends in the areas of:.damge-of rebar, damage of embeds, and concrete cylinder. curing. ,

heport dated September 5, 1979.

(c) neEative trends in the areas of: concrete cylinder curing, slump average, voids and honeycomb, curing, mislocated rebar, rebar hooks bent, and missed. or mislocated embeds. Report dated March 24, 1960.

Metalweld, Inc.: Declining quality was detected in the 4th Quarter of 1980 and continued to be a problem throu6 h-out 1981. In the 4th Quarter 1981 report, Metalweld's

" negative trends continue."

U.S. Testing Co.: described in the 2nd Quarter 1979 report as having inadequate records.

S & M Constructors: In tne 2nd Quarter 1979 report, S & M

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was rated as "carely satisfactory." In the Feb.

15, 1979 Trend Analysis heport on S & M, most problems were attriouted to inadequate procedure.

l In the August 31, 1979 report, negative trends l were identified in the areas of concrete cylinder I

curing and concrete voids and honeycomb.

Johnson Controls: identified as a problem in the 2nd and 4th Quarters of 1980. The management of Johnson Controls was said to have exhibited a " continuing t

lack of quality consciousness and disregard for l

code requirements."

Pullman Power Products: considered a problem in the 2nd Quarter of 1980, throughout 1981, and 1982. In the 2nd Quarter 1981 report Pul? man was described as "still unsatisfactory." The Trend Analysis heport for Pullman (July 1, 1981 to October-1, 1981) states tnat "the expected improvement in quality performance following Pullman's_ response to CAR 0510 has not been made apparent by this trend analysis.

Both the number of documents reporting noncompliance and the relative siE nificance to quality of the items j reported indicate that further action is needed by Pullman to provide a viable quality progrms."

i areas of concern include documentation, welding, ,

craft and inspector training, supervision of con-struction activities, general carelessness, and the by-pass of hold points.

Interestingly, the 3rd Quarter 1981 report states

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a that a decrease in the number of NRs written that quarter is httributed to a slowdown of activities of Pullman, GF., and Newport News.

L.K. Comstock: considered a problem in 1981 and 1982.

9. Other specific deficiencies noted were:

1st quarter 1979: off-site warehouse facility in Fairport, OH was characterized as deficient in quality and environmental requirements.

2nd quarter 1979: in referring to 2 violations identified by tne NHC, the report stated that "the repetitive nature of these findinEs (concrete placement and storage and maintenance deficiencies) is ominous of QC program credibility. "

1st quarter 1980: in the warehousing area, the. cleanup of GE turbine parts is required. .

3rd Quarter 1980: in the warehousing area, 1500 dis-crepancies are found in comparing inventory to records. Serious deficiencies are found in the non-safety HVAC work; since the quality of work in inspected areas is unsatisfactory, there is suspicion that uninspected work is also unsatisfactory.

1st Quarter 1981: tne Corban yard piping was damaged by tho Lampson crane. Repairs to cracks in the turbine power complex and heater bay continued, but efforts are addressing symptoms and not the problems.

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A review of indoctrination and training from 1976 to 1980 revealed:

(a) improper installation of hanger supports; (b) violations of welding procedures; (c) improper installation of cable trays; (d) inadequate personnel qualifications.

2nd Quarter 1981: housekeeping, especially in the Unit.1 turbine building and reactor building, is identified as a major problem area. Concrete cracks and spalls are identified in the fuel transfer area of the fuel handling building. Numerous leaks are dis-covered in the Unit 1 main steam condenser.

3rd Quarter 1981: Sensitization of the suppression pool cladding was identified. Work continued in the warehousing area - cleaning and restoring- items (GE turbine parts) and cleaning burned-on poly-ethylene off a fire-damaged steam separator.

Housekeeping is still a problem, due largely to oil .

spills in the turbine building.

2nd Quarter 1982: It is.noted that supervisors are reluctant to pal ticipate in audits.

Trend Analysis of Great Lakes Construction Nhs, dated March 3, 1977: conditions identified include: rudwaste building wall and anchor bolts off location; control f

complex anchor oolts improperly spaced and located; concrete wass and sump liner off location.

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Susan L. Hiatt AYW Sworn to and subscribed before me this day of December, 1982.

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Notary Public l

, DANIEL D. WILT, Attemey NOTARY PUBLic . STATE OF OHl0 m commission has no experettee h Sasuna 147A3 L C.

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