IR 05000445/1981004
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Investigation No. 50-445/81-04 50-446/81-04 Docket Nos. 50-445; 50-446 Licensee: ' Texas Utilities Generating Company Facility:
Comanche Peak, Units 1 and 2 Investigation at:
Glen Rose, Somervell, County, Texas Investigation conducted:
February 25-27 and March 9-13, 1981 Investigators:
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't -?. t -9 0. D. Oriskill, Investigator
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Oate Investigation and Enforcement Staff
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R.' K. Herr, Investigator Date
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Investigation and Enforcement Staff Inspectors:
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L. E. Marti, Reactor Inspector
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R. G. Taylor, Resident Reactor Inspector Date rajects Section No. 3
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U II J. \\E. Gagl \\a: co, Director Date'
Investigatfon and Enforcement Staff Approved by:
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G. L. Madsen, Chief Oate Reactor ProjectsSection I
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PDR Fogg CARDE8 5-59 ppg
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Summary
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Investigation on February 25-27 and March 9-13, 1981 (Report No. 50-445/81-04; 50-446/81-04)
Area Investicated:
Allegations were made that a Comanche Peak Steam Electric Station (CPSES) Brown and Root, Inc. (B&R), Quality Control (QC) supervisor repeatedly told electrical QC inspectorJ_lo_ violate inspection _ procedures.;_
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that a QC supervisor told ele 3IFaTQC inspectors not _to. do. required in process inspections; that electrical QC Department blueprints are not always of the current revision; that electrical QC management is " tight with the craft" due to their being sympathetic to production management needs; that some electrical QC inspectors are inadequately qualified and have been helped to pass certifica-tion test; and thaLseme_21 ectr.ical_0C jnspectors-have " bought..of f." e.lectric'ai tarminations in censenfocmance with drawings.
Another allegation was received stating that pipe hanger packages are being divided making final QA reviews inadequate.
This investigation involved 154 investigator / inspector man-hours by two NRC investigators and two NRC inspectors.
Results:
Personal interview of the source and numerous interviews of electrical QC personnel disclosed no instances wherein.the.QC_ Supervisor al_legedly in,structed
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electrical QC inspectors to violate _ procedures or not to conduct required in-
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process ins ~eEE ons.
A Interifiew's disclosed that the' electrical QC Department
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blueprinta are only rarely found not to be of the current revision and no extended delay or nonconformances relating to blueprints, were identified.
Numerous interviews of electrical QC inspectors disclosed a unanimous opinion that they possess independence in conducting their duties without pressures from either CC or production management.
In depth investigations of qualifica-
tions of.some electrical QC inspectors identified none who were unqualified for their position; however, examination of the certification tests for one electrical QC inspector disclosed that the electrical Quality Engineer con-ducting the examination had deleted several incorrectly answered questions from the test, which resulted in a passing grade for the inspector vice a failing grade.
Numerous interview 1sentified no instances wherein electrical terminations were intentionaily " bought oTf" in nonconformance with drawings.
Iivestiga'tTon disclosed th M iFe hanger packages were former17 divided and filed separately; however, the packages have recently been combined eliminating the admitted inconvenience factor in their final QA review.
During this investigation it was identified and confirmed that a member of QC management was crohibiting QC inspectors from obtaining NCR numbers in order to ins.ure that all NCRs were brought to him for approval prior to being issued.
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INTRODUCTION Comanche Peak Steam Electric Station Units 1 and 2 are under construction in Somervell County, Texas near the town of Glen Rose, Texas.
Texas Utilities Generating Company (TUGCO) is the construction permit holder with Brown and Root Incorporated as the constructor and Gibbs and Hill Incorporated (G&H) as the Archi tect/ Engineer.
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REASON FOR INVESTIGATION On January 23, 1981, Irdividuals A'and B were interviewed by a member of the NRC Region IV staff regarding their expressed concerns relating to-alleged procedural violations in the B&R electrical QC Department at CPSES and relating to review of pipe hanger packages at CPSES.
V SUMMARY OF FACTS On January 23, 1981, Individuals A and B were interviewed by Mr. R. E. Hall, Chief, Systems and Technical Section, Engineering Inspection Branch, Region IV, Nuclear Regulatory Commissicn, at which time the following safety related concerns were identified:
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A QC Supervisor has repeatedly told electrical QC inspectors to violate inspection procedures and once stated " don't worry about the ficwers in the trees," which was interpreted to mean don't reject on looks alone.
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A QC Supervisor instructed electrical QC inspectors not to do in process inspections, but only to inspect completed work, which is contrary to procedures.
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Field copies of blueprints used by the electrical QC department for inspections are not always of the current revision, g gj 4'.
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Electrical QC management is " tight with the craft" as a result of their being sympathetic to production management.
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Some electrical QC personnel are inadequately qualified;'were helped to pass certification tests and their experience. requirements were " pencil whipped."
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Electrical terminations were being made and " bought off" by some i
electrical QC personnel, in nonconformance with drawings.
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Construction and inspection records relating to some pipe hangers are being separately maintained resulting in their final QA review being inadequate.
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Persons Contacted Licensee Emoloyees
r J. Hawkins, Project QA Manager, TUGC0
- R. Tolson, Site QA Manager, TUGC0
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Chapman, QA Manager, TUGC0
- J. Ainsworth, QE supervisor, TUGC0 Other Persons Contacted Individuals A thru X t
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Investigation of Allegations g g g -[,
Allegations No. 1 A QC Supervisor has repeatedly told electrical QC inspectors to violate.
inspection procedures and once stated " don't worry about the flowers
in the trees," which was interpreted to mean don't reject on looks alone.
Investigative Findings On February 24, 1981, Individual A was interviewed.
Individual A stated it was his opinion that an electrical QC Supervisor, Individual C, en-courages electrical QC inspectors to overlook certain safety related aspects of their inspections.
Individual A recalled one occasion'when Individual C made statements to the effect of " don't reject on looks alone" and " don't worry about the flowers in the trees," which Individual. A stated he interpreted to mean the inspectors should not find fault with the work they were inspecting. Individual A was unable to provide any specific instances when Individual C explicitly told him or another electrical QC-inspector to violate a specific procedure.
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Interview of Electrical QC Insoectors Between February 25, 1981 and March 12, 1981,. Individuals 0 thru K were individually interviewed concerning various aspects of their employment
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as B&R electrical QC inspectors.
Individual 0 recalled one instance I
wherein an electrical QC Supervisor, Individual C, stated "I know what r
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the procedure calls for'and I'm telling you to do it this way."
Individual D stated this comment was made when Indivudal C was being questioned t
concerning inspection of cable _segme=Hmm,.-
Individual 0 also added
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that electrical cable separation Mas presented a long term problem and
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I that about three months ago hheir requirement to document cablei L
separafions,_as_s.uitable or-otherwhe_,gs geytTeTfrom the Mc_trical
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qC_.jnspection_ form and an alternate avenue of documenting. unsuitable-cable separations was init.i_ted in order to avoid-'the submiss' ion of " unsatisfactory a
inspection reports" when cable separation were the only area of noncompliance.
Indivigual nm up_able to identify any other occasions when he believed that Individual C had instructed or i nf a r"ed tbAta_.QSU pr.p.c.edute._be C' lated.
When intersiewed_. Individuals 4,-F,-GrHTI and J,~each stated
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that; Individtb;_s-c6.ments_regarding " flowers in the trees" and " don't reject on-looks alone'Lwere interpreted to mean the inspectors responsi-ja bility is to ensure the. quality _.of _the, specif.ic task conforms with procedures'
andTn'at the individuaLinspectors -should_not_ impose his/her own subjective crit _eria._r.egarding. appearance,.on task. they inspect.
Individual K
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stated he had not given consideration to the specific comments, made by Individual C, and did not know what they meant.
None of the foregoing individuals supported a contention that the electrical QC inspectors were either directly or by inference directed to violate any procedure or limit the quality of their respective inspection duties.
Interview of Former Electrical QC Insoectors On March 9, 1981 and March 11, 1981, Individuals L and M, respectively, were individually interviewed.
Both Indiviudals L and M stated that they interpreted Individual C's comment regarding " flowers in the trees" to mean that their inspection responsibility was limited to the safety-related aspects and adequacy of the task being inspected.
Neither Individuals L or M recalled an instance wherein they were instructed to disregard compliance with CPSES procedures.
. Interview of Electrical OC Suoervisors On March 12, 1981, Individuals C and N, both electrical QC supervisory personnel.were individually interviewed.
Individual N stated Individual C's comments regarding " flowers in the trees" meant inspection should con-centrate on the safety-related functions of items being inscected and not nonsafety related aspects of the system or components which was not a part of the respective inspectors responsibility to inspect.
Individual N stated no comments made by Individual C should have been interpreted to mean a procedure should be violated.
When questioned cor.cerning his alleged past statements " don't reject on looks alone" and " don't worry about the flowers in the trees," Individual C corrected the latter to " don't worry about the flowers and the trees."
He stated these comments were directed to some electrical QC inspectors who were frequently finding nonsafety-related problems in areas of their inspections.
Individual C stated that he was not aware there had been any misinterpretation of his statements and said "perhaps I didn' t choose my words carefully enough." He said he had meant, by these statements, that inspectors should not apply their personal standards to a condition in order to reject it, if, in fact, it meets the required specifications.
Individual C also stated he frequently made comments to inspectors
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such as "you're not designing this place" when their criticism of an item took them outside the scope of their inspection responsibility.
Individual C stated he never knowingly instructed anyone to violate a CPSES procedure../
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Allegation No. 2-
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A QC Supervisor instructed an electrical QC inspector not to do in process
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inspections, but only to inspect completed work, which is contrary to pro-cedures.
Investicative Findinos
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On February 24, 1981, Individual A was interviewed and stated it was his opinion that Individual C discouraged electrical QC inspectors from
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performing the procedurally required in-process inspections.
Individual A stated that a rumor exists within the electrical QC Department that one QC inspector was fired for doing "too many in process inspections" and other QC inspectors are now using that as an excuse for not doing in process inspections.
Individual A could provide no information relating to specific instances wherein the Supervisors told inspectors not to do in process inspections.
Individual A further stated that Individual J was known to
rarely cohduct in process inspections and had been heard to say "they take too long and they are boring."
Individual A stated CPSES procedures require each inspector to conduct'a minimum of 10 in process inspections per day.
Individual A stated that Individual J had probably never con-ducted 10 in process inspections in a single day.
Interviews of Electrical QC Insoectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were individually interviewed.
Individuals 0, E, F, G, H, I and K each stated they regularly performed in process inspections during the course of their duties.
Individual 4 related that in process inspections are "too time consuming and they are boring."
Individual J admitted avoiding in process inspections whenever possible, but stated in recent weeks everyone conducting termination insoections has been getting to do a lot of in process work.
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Indivicuals_0 thru K uniformly stated that they had never been instructed by Supervisors, not to conduct in process inspections nor had Supervisors ever discouraged their conducting in process inspections.
Individual G related that his understanding of CPSES procedures required that the electrical QC Department conduct a total of 10 in process inspections per day; however, there was no requirement for a specific inspector to conduct any required number of in process inspections.
Interviews of Former OC Insoectors On March 9, 1981 and Marcn 11, 1981, Individuals L and M respectively, were individually interviewed.
Both stated that when formerly employed in the electrical QC Department they each regularly performed in process
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inspections and neither recalled having.ever been discouraged from, or instructed not to do in process inspections.
Individual L explained that during 1980 the electrical QC Department had many more terminations inspectors than now employed, due to the larger quantit_y_of_tenminations being done.
Individual L stated some of tnese Ynspectors did numerous'
in proc ~ess inspections during each week day while other inspectors were
" lazy" and did very few, if any, in process inspections.
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stated that he believed this disparity in total individual productivity, as well as with in process inspections conducted, created some resentment towards several of the less motivated inspectors.
Individual M also related that some termination inspectors, whom he did not identify, were
" lazy."
Interview of Electrical Craft Supervisor On March 10, 1981, Individual 0, an electrical craft supervisor, was inter-viewed.
Individual 0 stated some termination QC inspectors had worked closely with the electrical termination department and had conducted numerous in process inspections of work performed by his personnel.
He stated other QC inspectors were not particularly responsive to the needs of his personnel and that he had heard criticism regarding some QC inspectors who would, on many occasions, make excuses or refuse to conduct in process inspections.
Individual 0 stated he never heard nor had any indication that electrical QC Supervisors had instructed their personnel not to conduct in process inspections.
Interviews of Brown and Root (B&R) Electricians
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On March 9, 1981, Individuals P and Q were individually interviewed con-cerning their knowledge of in process electrical QC inspections.
Individual P stated most electrical QC personnel are not reluctant to conduct in process inspections.
Individual P identified Individual J as having refused, on numerous occasions, to conduct in process inspections stating "it is boring."
Individual Q also identified Individual J as the only electrical oQC inspector he knew who avoided or refused to conduct in process inspections.
Neither P or Q were aware of any facts which would indicate electrical QC inspectors had been instructed not to conduct in process inspections.
Interviews of Electrical OC Suoervisors On March 12, 1981, Individuals C and N were individually interviewed.
Individual C stated that the electrical QC Department is required by procedure.to conduct a total of 10 in process inspections each day.
Individual C stated tne purpose of the in process inspection is to sample the sork of various electrical deparment craftsman to ensure they are doing the work properly.
Individual C stated that during the past year the electrical QC Department has far exceeded the required number of in process inspections daily.
Individual N also stated the
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number of.in process inspections conducted each day is more than adequate to determine that work is being done properly.
Both Individuals C and
N stated they have never told inspectors not to conduct in process inspections nor have they ever discouraged the inspectors from conducting
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in process inspections.
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Allegation No. 3
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Field copies of blueprints used by electrical QC departments for inspections
are not always of the current revision.
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Investigative Findings
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On February 25, 1981, Individual A was interviewed.
Individual A stated.
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that during the course of the last year, on several occasions, blueprints
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obtained from the electrical QC Department, for_ use_during inspections, have not been of the current _r.evision.
Individual A stated this problem never
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resulted in an inspection being done improperly.
Individual A was unable-
to identify any specific date or blueprint associated with this problem nor was Individual A able to identify any other inspectors who were aware of this problem.
Interview of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals 0 thru K were individually interviewed.
Individuals.E, F, H and J related they had
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never identified a blueprint, they were using for-inspection purposes, as being out-of-date.
Individual 0 stated he had, on several occasions, i.
identified blueprints as being out-of-date; however, the problem was quickly resolved.
In_diyvidu W G. T I and K'_. indicated _they had identified bl_ueprints as beino not af the_ current.revisio.n on sevJral occas.ionsa nd
it had created no problem for them during the course of their inspections,
as the proper blueprint was readily accessible.
None of these inspectors i
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indicated that a problem with blueprints leads to a QC inspection being
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improperly done.
Interview of Electrical QC Suoervisors
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On March, 12, 1981, Indivudals C and N were individually interviewed.
Individual C stated that during a shcrt period in 1980 the electrical QC Department had received revised blueprints approximately one day later than the electrical craft department due to hand delivery.
Individual C stated that upon notifying the B&R Document Control Center of this problem it was. quickly resolved.
Individual C stated he was aware of no problem, created for the QC inspectors by out-of-date blueprints, aside from the inconvenience of having to obtain a current revision.
Individual N stated that on rare occasions.the electrical QC Departe:ent does not have the current revision of a particular blupprint. He stated this problem is always resolved quickly and to his knowledge has never created
'an inspection problem Individual N additionally stated that an audit of
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the electrical QC Department blueprints.is conducted every three months and rarely is any pr'oblem ever identified.
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Allegation No. 4 Electrical QC. management is " tight with the craft" as a result of their being sympathetic to production management.
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Investigative Findings
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On February 24, 1981,- Individual A was interviewed.
Individual A stated that
it was his impression that Individual C is overly sympathetic to the needs
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of production management and that this may contribute to a compromise of i
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Quality Control inspections at CPSES.
Individual A related, as an example
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of this, a frecuentiv_.ancountered-1980 problem relating to separation requirements'~for safety related cables _ going to the CPSE5 control room.
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Iddivioual A stated _QC-inspectors had been required _to prepare two separate
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inspection-reports regardi.ng some cab _leLon_witish_.the requTPed separation had not been met.
Individual A stated that when QC inspectionr 5f' tables
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were conducted and all aspects were found to be acceptable, with the
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exception of separation, two reports would have to be precared.
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would document the inspection acceptability of the cables and/or te7minations
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and a separate report _would be prepared documenting that the required separa-tion had noc o mat.
Individual A stated this was obviously being done to
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1pEeclud a separation aspect being the basis for an unsatisfactory (
inspection report for the cable as a whole.
Individual A; stated that he felt this policy was the result of an informal ag'reement between Individual C ;
and production management.
Individual A was unable to cite any additional l
examples of Individual C being' sympathetic to production management needs.
Individual A agreed that, insomuch as tha unsatisfactory separation con-ditions were documented and must tie _ad_ dressed, no further safety relatec~
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problems are likely to occur.
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Interview of Electrical.0C Insoectors-
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Between. February 25, 1981 and March 12, 1981, Incividuals 0 thru K were
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individually interviewed concerning their independence as QC inspectors e
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and the possibility t' hat quality may be compromised due to management
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being sympathetic to production needs or requests.
Individual D related
that on several occasions he has overheard members of his Department, i
whose identities he was unable to recall, relate instances wherein Individual C had told them to ease off on some inspections to avoid conflict with the craft.
Individual 0 stated he had no personal knowledge of this having occurred.
Individual D stated he felt totally independent
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in conducting Quality Control inspections and believed he was supported by QC management to the fullest extent in his decisi.ons.
Individuals E
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thru K clso stated they felt totally independent in their Quality Control
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evaluaticos and believed they had the full support of.other Supervisors
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with regard to decisions-they made.
None of these Individuals recalled f
having ever personally 'been asked to " ease off on inspections" ner did
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they believe that electrical QC Supervisors are sympathetic to the needs j
of production management.when quality might be adversely affected e
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Interviews of Electrical QC Suoervisors I
On March 12, 1981, Individuals C and N were individually interviewed.
Individual C stated his Supervisors allow him the independence and latitude to manage his Department as it should be.
Individual C stated he maintained
.a good relationship with Craft Supervisors however, his primary goal is to ensure that -the Quality Control objectives at CPSES are achieved.
Both Individuals C and N stated they were totally independent from craft pressures and that they had never'been pressured by their own Supervisors or production management to compromise Quality Control standards.
(Investigators Note:
While conducting the foregoing facets of this investigation a possible noncompliance with CPSES procedures was identified, relating to NCRs, within the electrical QC Department.
Invest concerning this matter are contained in this repo'rt.)% 7 p,,gat
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g,p Allegation No. 5 Some electrical QC personnel are inadequately qualified; were helped to
past the Certification Tests and their experience requirements were
" pencil whipped."
Irivestigative Findings
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On February 24, 1981, Individual A was interviewed.
Individual A stated
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.that several persons working as QC inspectors in the area of electrical
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j termination were not qualified for their positions when they began working
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as QC inspectors.
These persons were identified as Individuals H, I and J.
Individual A stated nnna af the.1.had prior electrical or construction expertence, LGfore the experience portion of their applications must have oeen " pencil whipped."
hF'fi d_to-document them as_having a (
cer nin degree of arperience.J Individual.A related that Individual I has-worked hard and would probably now be qualified, due to the experience level achieved.
Individual A related having heard that Individual J got i
hired as a QC inspector due to Individual's C being a close friend of Individual J's brother.
Individual A stated numerous other persons employed as electrical QC inspectors and also some electrical craftsman concurred j
in the aforementioned evaluations of Individuals H, I and J.
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Interviews of Electrical QC Insoectors Between February 25, 1981 and March 12, 1981, Individuals 0, E, F, G and K were individually interviewed.
Individual 0 identified Individuals I and J as being_only =rcinalyaualif_ igd for their duties as QC inspectors.
IndividuarD stated that Individuals I and J'seemed to make no effort to improve their ability and due to their having apparently gained the favor of their Supervisors (Individuals C and N) they can usually be
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found sitting in the office talking.
Individuals E and F stated they felt all persons working as electrical QC inspectors are qualified for their jobs.
Individual G stated Individual H was qualified and works hard.
Individual G related having never worked with Individuals I and J, but stated some inspectors, whom he refused to identify, are " lazy."
Review of Former OC Insoectors On March 9, 1981 and March 11, 1981, Individuals L and M were individually interviewed.
Individual L stated that Individuals H and I were pretty good workers and are probably qualified in all phases of the inspections they perform.
Individual L stated Individual J, at best, was probably C
only marginaly qualified as a QC inspector and was_a very poor performer. y
...q, Individual L stated that electrical QC Supervisors displayed an obvious
,r favoritism towards Individuals H, I and J over other QC inspectors, which n;'
would probably account for their doing less field work and spending more
time around the office.
Individual M stated a belief that all QC inspectors t -
are qualified, but stated some (not identified) are " lazy."
Interview of B&R Electricians On March 9,1981, Individais P and Q, B&R electricians, were individually interviewed.
Individual P stated that Individual J was not adequately qualified as a QC inspecter.
Individual P related that on occasions
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Individual J would ask questions about work being inspected which would indicate a lack of knowledge regarding the field.
Individual P stated that Individuals H and I also do not appear adequately knowledgeable regarding electrical QC work.
Individual P also identified Individual R as probably not being qualified and performing poorly.
Individual Q stated Individual J may not be qualified as a QC inspector and related details regarding. occasions when Indiv.idual J did not understand simple aspects of work to be inspected.
Individual Q related no knowledge regarding Individuals H and I being qualified as electrical QC inspectors.
Review of B&R QC Qualifications and Training Records On February 26, 1981 and March 12, 1981, CPSES requirements for QC inspectors qualifications and the training records for Individuals H, I,- J and R were reviewed.
It was determined that each met the required background qualifications and satisfactorily completed the required written and oral examinations and the required on-the-job training necessary for certi-fication as electrical QC inspectors.
CW1K It was noted that Individual J, passed the certification exam for the
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in_spLction of electrical terminations-with_a_Ege_pL84 oercentile, s6bsequent to the disqualtrication of two incorrectly answered questions.
Examination of other electrical terminations certification exams taken by other persons during a similar time frame disclosed the same questions had not been disqualified.
It was determined that Individual J vould not have passed this certification exam had these questions not been deleted from the exa.. --
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Interview of B&R Quality Engineers
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On March 12, 1981, Individuals 5 and T, B&R electrical Quality Engineers (QE)
were interviewed.
Each explained that a combination of nn-the-iob training
and classr.com_ training are required of individuah_.pr.ior to_taking a
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i particul.ar,QA Certification ExamMndi'v%ual 5 stated all certification exams are administered by a QE, subseque~nt to which an oral exam is administered.
Individual S stated that.the QE, based on the results of the oral exam, has the right to adjust, upward or downward, the score
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of the written examination.
Individual S stated the certification can be denied solely on the results of the oral exam.
Individual S stated;
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however, that a person who displays a4obvi~ous understanding of the material required for certification, but has not scored above the 80% required on
the exam, is usually required to take the examination again.
Individual S
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j stated the QE who administered the written and oral exam to Individual J was no longer employed at CPSES; therefore no reason could be provided for the disqualification of questions on the written exam of. Individual J.
Interviews of Individuals H, I and J On March 11-12, 1981, Individuals H, I and J were each separ,ately interviewed
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by an NRC inspector (Electrical Specialist) and NRC investigator in an effort to determine their respective qualifications.
The interviews
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i indicated that each possessed an adequate degree of familiarity with the l
inspection procedures 'and techniques to perform the termination inspection
requirements.
Individuals H, I and J also indicated that they freely exercise the prerogative of asking their Supervisors for the answers to
any questions that they encountered during the performance of inspections, both technical and administrative.
These interviews determined that QC inspectors H, I and J were each qualified to conduct the QC inspections
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_in the area of electrical cable termination inspections or instructed by i
site procedures.
When specifically queried concerning the possiblity that
. Individual C had influenced Individual J's employment in the QC Department and influenced certification, Individual J related having no personal
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knowledge to support such allegations and stated no personal relationship
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existed with Individual C, aside from a professional one.
Interview of Electrical QC Supervisors i
On March 12, 1981, Individuals C and N individually were interviewed.
When questioned concerning the qualifications of Individuals H, I and J, as electrical QC inspectors, Individuals C and N each stated they believed j
l those individuals to be qualified.
Both stated a belief that the,trainina _
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program for OC insn e tnes was sufficient, but each added that more training l
M be. desirable.
Individual C stated that as an adjunct to the initial
training program, new electrical QC inspectors are encouraged to always ask
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questions of either Supervisors or more experienced Electrical QC inspectors
when they had questions concerning an area they were inspecting.
Both i
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Individuals C and N stated that over a period of time this process can develop good inspectors.
When specifically questioned concerning Individuals H, I and J, both Ind % iduals C and N stated they believed the
training and experience had mutually been responsible for the better qualifications of those persons.
When questioned concerning the alleged
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favoritism received by Individuals H, I and J, Individual C stated that the attention received by these individuals during their training was apparently misunderstood as being favoritism.
Individual C stated that Individuals H, I and J, due to their inexperinece, had required more assistance of the Supervisors during'recent months, which may have been misunderstood, by some, as favorit'ista or special attention.
Lastly, Individual C stated he was a personal friend of Individual J's brother; however, this had in no way influenced' Individual J's receiving a job within the electrical QC department.
Furthermore, Individual C stated that he had not been responsible for hiring Individual J nor had Individual J's brother been aware that Individual J was being transfered to the electrical QC Department. h
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Allegation No. 6
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f3 Electrical terminations were being made and " bought off" by some
electrical QC personnel, in nonconformance with drawings.
Investigative Fitdings On February 24, 1981, Individual A was interviewe.d.
Individual A stated he t ali_ev.gd_alec.tr.ical_t.gtminations J! ave _b_e_en "boucht of f" (approved by inspectors) which are in nonconformance with drawings.- Individual A stated this situatina h en*H fi.caU,y_ a_ttributable to some electrical QC N
i_nspectors being unqualified for their iob, rather than any intehtional wrongdoing.
Inct71dualTp7ovided two examples _of nonconformino con-ditinns which were annroved by electrical QC inspectors (Individuals I and J).
Individual A was unable to provice any additional information pertinent to the identification of nonconformances which have been approved by electrical QC inspectors.
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p f f.h e [p P Insoection of Alleged Nonconforming Conditions
.;
vf.
On February 25, 1981, an inspection of the alleged ny forming conditions, approved by Individual J, was conducted.
The inso# tion disclosed that no conconformances_ existed in the alle-oed comnonen( at this\\ time.
On abruary 26, 1981, a. review of tba dnenmentation_ relatino 'to the allecedly
. n'dr.waiutming condi'tions approved by Individual I was condt)cted.
The review disclosed the work associated W n tnis inspection rAquired only a visual inspection after the work was completed.
The documentation for this work indicated that Individual-I had visually observed and approved the work and additionally the 'ork was also independently approved by one other w
electrical QC inspector at another time.
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Interview of Electrical ~QC Inspectors J
Between February 25, 1981 and March 12, 1981, Individuals D thru K were
,
individually interviewed.
Individual D stated he believed that allegations
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made that electrical QC inspectors have " bought off" inspections would probably more aptly _ relate to the qualifications of an individual inspector and his/her ability to identify a particular nonconformance.
Individual D
,
stated he has no knowledge of a nonconformance being knowingly approved by a i
!
electrical QC inspector.
Individual D stated he had personally reinspected
.'
the task which had.been visually inspected by Individual I (reported above),
and found the work to be in conformance with drawings.
Individuals E thru l
K related having no personal knowledge of nonconformances being approved by QC inspectors.
Individuals H and J each stated if they had approved a nonconforming condition in the past, it was done unintentionally.
Individuals H and J stated that such an occurrence would be the result of their not understanding all aspects of the work they were inspecting.
None
of the aforementioned inspectors recalled.having ever been asked to
approve a nonconforming condition.
,
l Interview of Brown & Root Electricians a
On March 9,1981, Individuals P and Q were individually interviewed regarding electrical QC inspections being " bought off" in an nonconforming condition
,
l-by electrical QC inspectors.
Both Individuals P and Q comments regarding.
'
inspections being " bought off" related directly to the qualifications of specific inspectors and the diligence with which.they conducted their
.
inspections.
Neither Individuals P or Q was aware of any nonconformance
,
being intentionally approved.
Interview of Electrical QC Suoervisors On March 12, 1981, Individuals C and N were individually interviewed.
When_ questioned concerning electrical QC inspections being " bought off",
Individual N related that occurrences of nonconforming conditions being
approved by an electrical QC inspector would probably be the result of the
'
respective inspector's inexperience.
Individual N stated that_during the summer and fall of 1980. whan_much electric _al termination work was
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being done and when a number of terminations inspectors were Kes on.the
~
job, the'ttielihood of nonconforming conditions not being identified during an inspection was much greater than now.
Individual N stated he frequently, during that timeframe, reinspected work done by the less experienced
.
inspectors and, on occassions, did identify mistakes they had overlooked.
-
'
Individual N stated that termination inspectors were encouraged to contact j
him when they had questions regarding a particular. inspection, in order
'
to preclude errors being made.
Individual N stated he did not believe j
any intentional approval of a nonconforming item had ever occurred, j
Individual C also stated if errors were made during inspections and a
'
nonconforming condition was approved, it was due to the. inexperience of the respective inspector.
Individual C stated that the less experienced inspectors were assigned less complex inspection task when they began
in order for them to gradually acquaint themselves with the inspection process and avoid errors.
Furthermore, he stated that, as an adjunct
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to the former training program, new inspectors were instructed to "ask
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questions" of their supervisors when they did not understand the area they were inspecting.
Individual C stated this process made better inspectors and helped ensure that mistakes were not made during inspections.
.
Allegation No. 7 Construction and inspection records relating to some pipe hangers.are being
-
'
uparately maintained, resulting in their final QA review being inadequate.
Investigative Findings
.
On February 23, 1981, Individual B was interviewed.
Individual B stated that prior to April 1,1980, procedures for the construction, installation and inspection of every pipe hanger was very rigorous and that each step in these processes was documented.
Individual B stated that on April 1,1980, the procedures for most of this inspection' and. documenta-tion were eliminated.
Individua' B stated that a new procedure was implemented which required each safety class han'ger have NOE ana mechanical inspections performed following its installation.
Individual B stated that the problem exists with regard to hangers'being fabricated prior to a April 1,1980, and which were completed subsequent to the initiation of.the new inspection procedure.
Individual B stated that the hanger packages (containing all documents relating to the fabrication and inspection of each hanger) in existence on April 1,1980, were filed away and a new hanger package was started for every hanger which was
.
not yet installed and QC approved.
Individual 8 pointed out that the Documentation Review Group, now reviewing the fabrication and inspection history of each hanger, is only receiving the hanger packages containing documentation prepared after. April 1,.19.80.
Individual B stated that this prevents a complete' review being' accomplished on hangers which were in the fabrication process on April 1,1980.
Individual B stated the Welding Engineering Department currently main-tains the old hanger packages for hangers which were being fabricated on April 1,1980, and they refused to give the old packages to the Documentation Review Group without a written request from the QA. Depart-Individual B stated this constitutes a violation of CPSES pro-ment.
cedures,.in that all documentation is not being incorporated into a final review package.
Interview of Documentation. Review Group Suoervisor On February 25, 1981, Individual U was interviewed regarding the review of hanger packages.
Individual U stated that since January 1989 numerous procedural changes havh occurred relating to fabrication and inspection of pipe hangers which has resulted in problems regarding a mutually agreeable consolidation of all records relating to the respective hanger packages.
Individual U stated that on September 1,1980, a major procedural change was implemented regarding the documentation format for both construction and QC preparation of structural hanger packages.
Individual U stated
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e
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that subsequent to September 1, 1980, h'e learned that hanger document.ation packages were being divided into two separate packages by the Welding Engineering Department.
He stated this division involved separation of old documentation (prepared prior to September 1, 1980), into a package that would be maintained by the Welding Engineering Department and another package
.
of documents prepared in accordance with the new procedural change (subsequent to September 1, 1980).
Individual U stated that subsequent to the installatic and inspection of'the hangers having two documentation packages, only the
,
i new package was being forwarded to the CPSES vault for final component review.
Individual U stated this separation of the packages did not always affect his final review and acceptability of a respective hanger.
He stated that i
when the old documentation was required to make a final determination of
acceptability, his group was required to submit a written request, through his Supervisor, to the Supervisor of the Welding Engineering Department in order to obtain the old hanger package.
Individual U stated that on every occasion his Department's requests for the old hanger packages were approved.
Individual U stated that approximately one month ago (early February,1981),
the Welding Engineering Department had agreed that upon notification that a new hanger package had been sent to the Documentation Review Group for review, they would send the old package-to also be reviewed.
Individual U stated that during the past week, according to information he had received, the Welding Engineering Department had sent several boxes of old hanger packages to the vault room for storage with the new hanger packages.
Individual U stated this would ensure availabilty of all documentation relating to hanger packages.
Individual U stated that the Welding Engineering Department had never refused to send a package for the reviews his group was conducting and no CPSES procedures or codes have been violated.
Lastly, he stated that had he ever been refused a hanger package, to complete his review, he would have refused to determine the acceptabilty of the
'
respective hanger.
g (,(5 Allecation No. 8 Electrical QC Supervisors require that nonconformance report (NCR) drafts be submitted to them and they are the only individuals within the electrical QC Department authorized to obtain an NCR number for the draft.
Investication Findings On March 11-12, 1981, Individuals H, I, J, L and M were interviewed individual ~
regarding matters associated with this allegation.
During tha interview of Indivudal M, he commented that the electrical QC Department policy regarding NCRs, is that the inspector prepares the draft and gives it to either Individual C or Individual N (electrical QC Supervisors) who are the only persons authorized to obtain an NCR number for the draft.
Individual N recalled that during November 1980, Individual C had stated an NCE prepared by Individual M related only to the " cosmetic" aspect of the item inspected and had directed it.be withdrawn, which it was.
Individual M stated this was the only occasion in which he ever had an NCR denied by I
a Supervisor.
Individual M did not recall any specific information regarding that NCR.
Interview of Individu.ls H, I, J and L disclosed they each were aware of the electrical QC Department policy designating
.
..
.
.
electrical QC Supervisors as the only persons, in that Department, authorized to obtain NCR numbers for NCR drafts.
None of these individuals recalled ever naving been denied the right to submit an NCR.
Interview o# NCR Coordinators
'
.
On March 11, 1981, Individual V, a TUGC0 NCR Coordinator was interviewed regarding electrical QC Department policy relating to obtaining of NCR numbers.
Individual V statso that in about September 1980, Individual C had directed that only he and Individual N be allowed to obtain NCR numbers for the electrical QC Department.
Individual V stated that no
electrical QC Department NCR, without Individual C or Individual N's
signature on it, had been processed, in accordance with this direction.
On March 12, 1981, Individual W, a S&R NCR Coordinator was interviewed.
Individual W stated that B&R NCR Coordinators office processes only civil and mechanical QC inspection department NCRs.
Individual W related having no association with the electrical QC Department or their NCRs.
Individual W stated that no agreements exist between the B&R NCR Coordinators office and civil or mechanical QC Supervisors.
Individual W stated however, that 99% of the NCRs issued from the B&R-NCR Coordinators Office, to the civil and mechanical QC Departments', are issued to Supervisors.
Interview of Electrical'OC Suoervisors On March 12, 1981, Individuals C and N were individually interviewed regarding their department policy relating to NCRs.
Individual N stated a policy exists in the electrical QC Department requiring electrical QC inspectors to provide an NCR draft to an electrical QC Supervisor (either Individual C or Individual N), for review and that the respective Supervisor is responsible for obtaining the NCR number from the NCR Coordinator.
Individual N statad that h: had-never "turnad dnwn a legitimate NCR; however, he stated that he had questioned the legitimacy of some and has required that a Field Deficionry Report (FOR)_he prenarod instead_qf an NCR on occ.asion."
Individual N stated this problem happens only occasionally (two or three times per month), and usually involves an inexperienced inspector.
Individual C, when interviewed, stated he was responsible for initiation of the policyytdrjng e.lectrical QC inspectors to have their NCR1_appr2Y3_d _by a Super, visor _because, juting.the_ ear.ly fal1,1980 he d
1_ earned snme elec*Mel QCJJg.e_ctors were_nhtairung_SCQnumbers for ec th_eir NCR drafts and never submitting the NCR.
Individual C~ stated he implemented the policy to asrare ocuounto0TTity of NCR numbers and to ensure each NCR submitted, by his department adequately explained and identified the problem found.
Individual C st&ted he was not aware his policy contradicted TUGC0 (CPSES1_Erocedure_No._CP.'.QF-16.0 (Revision 3),
dated July 9,'1930.
Individual C statid"he would rescind his policy and
~
ensure compliance with the site procedure.
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Interview of QA Mana'oer On March 13, 1981, Individual X was interviewed.
Individual X stated he was unaware the -site-NCR-procedure-was-notleina properly followed by the electrieni QC_Depar-tment.
Individual X stated he believed this was an isolated situation and that corrective action would be immediately taken to properly implement the' site NCR procedure.
Individual X, furthermore; stated
"I will make it clear how this procedure is to be interpreted and imple-mented" to all QC Departments."
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DESIGN CHANGE AUTHORIZATION
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SAFETY RELATED DOCUMENT:
YES XX NO 2.
ORIGINATOR: CPPE xx ORIGINAL DESIGNER 2323-El-0018-03
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COMPLETIONS I,1)
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JERRY HENSON-PROD. CONTROL (1)
Pete Bush OA (1)
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MAR 13 COMAl CHE PEAK STEAM ELECTRIC STATION
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DESIGN CHANGE AUTHORIZATION
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ggg g g g (WILL) (EILIXMOI) BE INCORPORATED IN DESIGN DOCUMENT OCA NO. 7,025 REV.13.
1.
SAFETY RELATED DOCUMENT:
XX YES N0 h
2.
ORIGINATOR: CPPE XX ORIGINAL CESIGNER
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DESCRIPTION:
-
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APPLICABLE 3REE/0WG/8hl63pgx1 See Page 2 REV.
B. OETAILS THIS REVISION VOIDS AND SUPERSEDES DCA 47,025 REV.12.
PROBLEM: Color code shown for Westinchouse orefab cables (16TW/PR) does not match color code desionated on drawings.
SOLUTION: Chance color code to read as oer Pace 3 of this DCA.
REV. 10:
' add drawino nurters on Pace 2 as noted.
DEV. 11 Adds drawina nichee en Dace 2 as no*ed.
NOT -
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WR 171994 fM T.014 r,TN.6Aton
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CRIGINATOR: /M/W2/a 46./. -
CATE h / /'l / 92.
B.
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DATE 3 - / 2 - h /
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DESIGN REVIEW PRIOR TO ISSUE:
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VENOCR RELATED CHANGE:
n NO YES:
P. O. NUMBER:
7.
STANDAR0 O!STRIBUTION:
Matt Haddadi EE (I)
ARMS (ORIGINAL)
(1) ' dark Welch CA (I)
CUALITY ENGINEERING (1)
9.D. Joyce EE (!)
DCTG FOR ORIG. OESIGN (1)
3.B. Crowell EE (I)
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APPENDIX
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U. S. NUCLEAR REGULATORY CC EISSION
REGION IV
NRC Inspection Report: 50-445/S3-24 50-446/83-15 Docket: 50-445 50-446 Ca tegory:
A2 Licensee:
Texas Utilities Generating Company (TUGCO)
2001 Bryan Tower Da llas, Texas,
75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At:
Comanche Peak, Units 1 and 2, Glen Rose, Texas Inspection Conducted: March through July 1983 Inspectors: 4
/7? / 45 - 8 S// k83 R. G. Taylor, Senior Resident inspector De te '
Construction (SRIC)
Approved:
[Y,
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8// <//83
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Reactor Project Section A Insoection Surmary Inscettion Conducted March throuch July 1983 (Recort 50 445/83-2: and S3 *c6/53-15)
Areas Insoected: Special inspections, announced and unannounced, related to allegations mace to various NRC persons including the Atomic Safety anc Licensing Board in their procedings regarding the operating license for Ccmanene Peak Station.
The inspections involved 449 inspector-hours by one NRC ins;:ector.
Results: Tne inspection confirmed the need to issue four violations initially ioentTiTed by the Construction Appraisal Team (CAT) (NRC Inspection Report 50-445/83-18; 50-446/33-12).
These involved the areas of HVAC, Ecuipment Installation, Document Control, and Storage of Eoui; ment.
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.Regarding the matter of the possibility of some undefined problem with the boot fabric, the BISCO site manager stated that his company has been e'ngaged in a law suit with the supplier of the fabric but only in regard to the per-
formance of the fabric in one application which is understood to involve the l,
tearing of the fabric after being punctured.
It is understood that the puncturing has occurred when a gel type radiation seal hardens under radia-
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Since the specific design involved is not scheduled for use at CPSES, tion.
the allegation has no technical merit.
Regarding the matter of possible sep.aration of the radiation seal angregate
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caterial from the carrier material, the SRIC can only conclude that the al-
,
The BISCO test legation is potentially correct but without apparent merit.
reports indicate that the seals involved met the engineers specification, j
Tne separation of the aggregate (powdered lead) from the carrier (a silicone
material) would appear to be process sensitive in that if they are not well j
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mixed, pockets of lead might form with resulting pockets of silicone without sufficient lead.
Since the specification and the BISCO procedures require l
l careful control and monitoring of the mixing process, the SRIC can only con-j clude that these measures are effective in production operations as they were
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in preparation of the test samples,
f 15. Electrical Cable Solicing The SRIC became aware that the Comanche Peak project electrical engineer l
had authorized the splicing of safety-related and auxiliary electrical Since l
cables within several control panels during the inspection period..
the licensee has comitted in FSAR Section 8.1 to comply with IEEE 420,
,
" Trial-Use Guide for Class IE Control Switchboards for Nuclear Fower Gener-
ating Stations," which forbids splicing of wiring in such panels, the SRIC i
!
The licen-judged that the licensee was deviating from these commitments.
see engineer indicated that he interpreted the IEEE standard to prohibit
'
such splicing only between the cabinet terminal boards and the cabinet l
devices and did not orchibit such splicing in the field run cables attach-The engineer stated that action had been ing to the terminal boards.
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initiated with the NRC Office of Nuclear Reactor Regulation to clarify tnc
issue in the FSAR.
The SRIC confinned that such action had been initiated
'
by a telephone conversation with the NRR Licensing Program Manager for Comanche Peak.
Pending action by NRR, this matter will be considered as an l
unresolved matter.
f 16. Unresolved Items Unresolved items are matters about which more information is required in l
order to ascerta'.n whether they are acceptable items, items of non-l compliance, or deviations.
i One such item, disclosed during the inspection, is discussed in paragrach 15
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This item is identified as " Splicing of Electrical Cables in above.
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Cabinets."
(8324-01)
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FOLDER NO.
Oraft No.
Date CCMANCHE PEAK ALLEGATION WORK PACKAGE i
ELECTRICAL Category I-Improperly Installed Electrical Components
X ~ h + w,, C.r~.kz
,a t.:t i s
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Allegation Numbers:
E-13 AC ' A
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AC-6 Statement of Allegation: Electrical allegations - construction concerns.
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Group I-Electrical component installation deficiencies AE-13, AE-14, AE-16, AE-17.
Group II Electrical separation criteria
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AE-15.
Reference Documents:
Refer to CP allegations chart and statement of allegations from source documents attached.
P ?^-"
9-ia, rd 02 2^
L Source of Allegation: Refer to CP allegations chart attached
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Date Received: 1979 - 1983 The above information prepared by D. M. Hunnicutt 6/6/84 Name Date (
Group Leader Date Assignec l
Name
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Team Members l
Date Assigned
Date Assigned
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Date Assigned i
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Fate Assigned
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- FOLDER NO.
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Oraft No.
Date
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i COMANCHE PEAX ALLEGATION WORK PACKAGE h tLTe.
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93/CC Category 34'- Inadequate Inspection And Certification i
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Allegation Numcers:
ACW-15, ACW-16, A0W-17. AQW-18, A0W-19, AQW-27, ACE-7,
{pgyk
A06-12] A08-2, A0-38, AQ 39, AQ-50, A00-7, A00 t i
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Statement of Allegation:
Inadequate or improper certification of the i
qualifications of QC personnel.
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Reference Occuments:
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See source documents marked on attached pages from allegation list.
t Source of Allegation: Various
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Date Received: Various
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The above information prepared by R. G. Taylor 6/8/84 l
Name Date
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Group Leader i.
Name Date Assigned
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j Team Members
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Date Assigned
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Cate Assigned
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Date Ar,1gnec
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Fo14-9Pi
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COMANCHE PEAK OPEN ISSUE ACTION PLAN
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Task:
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l Ref. No.:
AQW-15, AQW-16, AQW-17, AQW-18, AQW-19, AQW-27, [, AQE-1
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AQB-2, AQ-38, AQ-39, AQ-50, AQO-7, AQO-14 J
l Characteri:ation: Inadequate and/or improper certification of the qualifications l
of QC personnel.
Initial Assessment of Significance: Possibly indicative of a general breakdown j
in the QA prcgram.
Source: Various
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j Aporoach to Resolution:
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1.
Review procedures, codes / standards, design requirements, NRC requirements, and licensee commitments for adequacy at time work was performed; were i
j codes / standards, FSAR, contractor requirements, and other commitments met?
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2.
Discuss adequacy of procedures with personnel involved. Examine installation, as appropriate, that is associated with any inadequate procedures identified.
3.
Refer any examp'.es of wrongdoing or significant deficiencies to TRT manager.
Evaluate allegations for generic / safety implications.
5.
Report on results of revtew/ evaluation cf allegations.
j Related Ooen Issues
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j Review activities necessary to close or partially close related items,.either j
based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
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Status:
Review lead:
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Succort:
Estimated Resources,:
Estimated comoletion:
CLOSURE:
Reviewed by:
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FOLDER NO.
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j CCMANCHE PEAK ALLEGATION WORK PACKAGE htOh}
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4 mig Category Jf"- QC Inspector (or Supervisor) Qualification / Training
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Allegation Numbers: AQW-1. ACW-2, A0W-3 AQW-4, ACW-5, ACW-6, ACW-7, ACW-11,
,
AQC-9, AQO-27 /AQE-8,) AQ-23, AQ-24, AQ-26, AQ-27, AQ-28,
,
AQ-29, AQ-63 (/
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Statement of Allegation: Various concerns related to welding / training and general
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qualification / training program, including:
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a.
Improper weld practices g.
Lack of QC training and ung' alified u
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b.
Nonqualified welders OC inspectors
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c.
Weld inspectors not qualified h.
Supervisory personnel not qualified d.
Inexperienced personnel 1.
Electrical inspectors not qualified
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Vendor welds inspected by J.
00L desposition of Dunham i
unqualified inspector k.
Recertification of inspectors with q
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Training inadequate answers given i
Reference Documents:
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See source documents marked on attached pages from allegation list.
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Source of Allegation: Various - see enclosed allegations list
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Date Received: Various - 1979 - 84
4 The above information prepared by O. M. Hunnicutt 6/11/84 Name Date J
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Group Leader
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Date Assignec l
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Date Assigned
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Date Assigned
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P014-0T-69
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CCMA"CHE PEAK CPEN ISSUE ACTION h.AN i
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Task: Determine if inspectors, welders, supervisors are qualified. Review procedures and training requirements.
Ref. No.: AQW-1, AQW-7 AQW-3, AQW-4, AQW-5, AQW-6, AQW-7, AQW 41, ACC-9,
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AQO-27, E s, Q-23, AQ-24, AQ-26, AQ-27, AQ-28, AQ-29, AQ-63 Ch Cha racte.-i za ti on:
Various concerns involving procedures, training of personnel and inspections by unqualified personnel, and welding and other practices.
Initial Assessment of S*gnificance:
Initial disposition in IR reports for several of these allegations.
There appears to be enough specificity to warrant followup on these allegations. The allegation reizted to 00L (Department of Labor) on Dunnam should be treated separately from the facility training, uncualified personnel, and other general allegations.
Source: QA/QC Category 12 - QC inspector (or supervisor) qualification / training
.
Aeproach to Resolution:
1.
Review IR-09, IR 79-20, IR 79-11, IR 79-15, IR 79-12, IR 83-52, IR 82-11,
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and R 81-04 o determine if documentation adequately supports findings.
a 6 g,.
.l If not, aporopriate action to close allegation.
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2.
Review training and OJT procedures, in question, for adequacy. Were Yp ht training standards and/or FSAR commitments met?
)
3.
Olscuss adequacy of procedures with perseg:nel involved with welding and y
training. Discuss adequacy of other OJT welding procedures.
Examine weldments, as appropriate, that are associat.ed with any inadequate procedures or training activities identified during interviews.
Review sample of similar-type welding / training procedures for adequacy.
5.
Refer any examples of wrongdoing or significant deficiencies to TRT manager.
6.
Evaluate allegations for generic / safety implications.
7..
Report on results of review / evaluation of a14gations.
8.
001, on Dunham should be reviewed separately (contact TPT).
Related Ocen Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
from the tracking system open item list. \\(Region IV iden.ify ind add to this work package.)
2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional f
inspection while the inspector is familiar with the areas.
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3.
While performing physical inspections above, examine s rrounding systems, components, and structures for related apparent defects or indicators of faulty workmanship.
If workmen are still in the area of a physical inspection, interview them for any knowledge of other potential deficiencies.
5.
Complete portion of IE Module on welding and/or training if it relates to effort made on allegations.
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Status:
Review Lead:
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Estimated Resources:
Estimated Comoletion:
CLOSURE:
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Another example of the violation of regulations at CP 7 7 I.
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is in the practice of regularly using " butt splices" on both quality and non-ouality cables.
Eutt splicing is used on a routine basis at Comanche P e al: where cables are not long enough to reach their intended destinations.
(Butt
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splicing is a means of physically attaching a new length of N
cable to an existing length of cable using a crimp to secure the attachment.)
The problem with butt splicing is
.
that, if it is not properly done, the cables can separate posing a potential fire ha:ard.
This potential ha ard is heightened by the fact that the majority of the butt
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AFFIDAVIT OF
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splices are in bundles c-f cables and the ha:ard extends
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beyond the cable that has been spliced to the cables that
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surround it.
It is my understanding that butt splicing is specifically prohibited by the NRC.
I have confirmed this
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belief by contacting the NRC Region V Office.
In particular, it is my understanding that Regulatory Guide 1.75 specifies that cable' splices in raceways should be prohibited and further, that if such s p'l i c e s do exist, the
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1L resulting design should be justified by analysis and
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submitted as part of the FSAR.
However, at Comanche Peak, DCA 19264 and several other DCA's allow butt' splicing of (j quality cables.
At Comanche Peak not only do the butt T
splices exist, but in same cases no notation is made on design drawings that the splices exist.
As a result, there
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may be no record of where butt splices have been made.
It is my belief that it w'ill be necessary to reinspect all cables and conduits for butt splices since'no records tre kept of their existence or location.
.
I am particularly concerned about the practice of butt splicing because of its potential for starting fires, and because it is my experience that there are many fossil fuel
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AFFIOAVIT OF
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Annex 3 Conversation Record Allegation Numoer AG-21.
Time
%'00 PA1 Date 7-3/- VY Type Visit Conference X
Telephone Incoming 1 0utgoing
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Name of Person (s) Contacted or in Contact With You Organization
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Telegnene Number GAP Artre-ek "N *
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SUBJECT: yg e,,,,7,,
7,,,74,7. rns1 +tse+ee to cuetry THF stectPre M47df on 1Re 4-t Le++Tnov.
SUWARY: ;p g. gg,g,,,,e.4 7, y,g
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toHecn enstr stv Whtloses Mares sas MF-coHrrot poon.
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iYorpl Thu mrros c+M ee TAtHsreeAro rease g6eerrerne c+res.orY 13ro Goe<rtsew. esre+sa r j.
Name of Person Occumenting Conversation-l#/wg
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Sigrature A>ff - / /f) L
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Date 97-/-g y
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Name(s) of Other Persons Vho dere Present During Conversation kicHMD lll$$fArAW_
h.tg [4tyo I have reviewed the sumcary of the conversation with the individual (s) named below and agree that it accura *.ely represents the conversation.
Signature of Person Providing Infor nation N/A File: Allegation Work Package
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cc: Project Director I
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Group Leader J
Additional pages n.ay be attached as needed. Additional pages should be identified, signed, and dated.
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E Draft 2 - 8/3/84 i
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F AE-13/CP2 i
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. COMANCHE PEAK OPEN ISSUE ACTION PLAN j
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Task: Electrical 1 - Electrical Cable Termicotions o
$i Ref. No.:
AE-13, AE-16, AE-18, AE-22, AE-26, (AQE-7 Part), (AQE-8 Pgrt),
I f
AQE-12..WE-36, (AQE-37 Part), (AQE-39 Part), (A0E-46 Part).
Characterizatfan: Various allegations pertaining to electrical esble v
$
terminations, splices in panels, and related activities.
i i
Initial Assessment,of Significance. Possible safety-significant i
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Source: Various b
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I e
i Approach to Resolutions:
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h Become familiar with specific issues through review
-
of work packages and related source docu=ents.
E
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f Review FSAR and related site procedures to detarmine it
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installation / inspection requirements
,
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_2 Perform inspections of installed hardware (where appropriate)
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and reviews of applicable records (as necessary) to determine
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s ce=pliance with requirements and/or commitments.
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)
Review for safety-significance and/or generic implications (
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e and perform additional inspections and document reviews as
necessary.
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Related Open Issue Identification: None m
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li Status: Open i
Review Lead: Calvo
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Sucport: None i
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Estimated Resources:
12 man-days y
Si Estimated Completion: July, 31, 1984 h
I li CLOST;RE:
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Reviewed by:
TRT Leader
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