IR 05000498/1980014
| ML19351D835 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/24/1980 |
| From: | Crossman W, Driskill D, Herr R, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351D810 | List: |
| References | |
| 50-498-80-14, 50-499-80-14, NUDOCS 8011200096 | |
| Download: ML19351D835 (14) | |
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g U. S. NI; CLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Investigation Report No. STN 50-498/80-14; 50-499/80-14 Docket No. STN 50-498 Licensee: Houston Lighting and Power Company Facility: South Texas Project, Units Nos. I and 2 Investigation at: Bay City, Matagorda County, Texas Investigation Conducted: June 5-6; June 18-20; June 24-26, 1980
Investigator:
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fff0 R. K. H(rr, Investigation Specialist Ddte/
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.ad,d O 24-t@.C Investigator:
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t D. D. W skill, Investig'7 tion Specialist Date
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Reviewed by:
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'. A. Crossman, Chidy, Projects S0ction, RC&ES Date
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Reviewed by:
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W.C.Seidle,tgief,RCSESBranch Date
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Summa ry Investigation on June 5-6; June 18-20; June 24-26, 1980 (Report No. 50-498/80-14; 50-499/80-14)
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l Area Investigated: Allegations that some Brown & Root (B&R) subcontract surveillance records were falsified, that B&R Quality Control inspectors were being intimidated, and that an unqualified person was promoted to a B&R supervisory position. This investigation involved 72 investigator-hours j
by two (2) NRC investigators.
Results Allegations that some subcontract surveillance records were falsified were confirmed.
Investigation of intimidation of QC inspectors and promotion of an unqualified person disclosed that these allegations have no merit.
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i INTRODUCTION i
The South Texas Nuclear Project (STP), Units 1 and 2, is currently under con-struction near the town of Bay City, Texas. Houston Lighting and Power Company (KL&P) is the construction permit holder, Brown & Root, Inc. (B&R) is the architect / engineer and construction firm.
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REASON FOR INVESTIGATION
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On May 6, 1980, the NRC Resident Reactor Inspector (RRI) at STP was contacted by Individual A, who alleged that B&R management personnel had altered con-struction records, changed draft nonconformance reports, promoted unqualified personnel, and are intimidating QC inspectors.
Individual A stated that he
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possessed, and would provide, documents which would substantiate some of his allegations.
SUMMARY OF FACTS On May 6, 1980, Individual A telephoned the RRI at S'iP and explained that he was calling for Individual B, who is employed at the STP site and who wishes to remain anonymous.
Individual A related the following, specific, allegations:
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That PDM Fabrication Check List (FCL), File No. AA18-4-8, Sequence 2.00,
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containing a " hold point," was not inspected as required and the record was falsified to indicate the inspection had been ccaducted, t
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That a draft Nonconformance Report (NCR) written by a QC inspector was rewritten in November 1979 by the Site QA manager and/or his staff and pertinent information was purposely deleted.
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That a QA subcontract surveillance inspector received and had entered in his personnel file a formal letter of warning concerning improper inspection practices. Records of this disciplinary action were allegedly removed from that record without proper authorization.
That an administrative assistant in the B&R Receiving Department is intimidating workers in that department by threatening to fire them, for little or no reason.
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That a secretary for B&R promoted to QA personnel supci. visor and is not qualified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- G. W. Oprea, Jr., Executive Vice President
- R. A. Frazer, QA Manager
- L. D. Wilson, QA Supervisor Present B&R Employees
- L. W. Zwissler, Project QA Manager Other Personnel Individuals A through 0
- Denotes those attending Exit Interview.
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Investigation of Allegations Allegation No. 1 That PDM Fabrication Check List (FCL), File No. AA18-4-8, Sequence 2.00, containing a " hold point," was not inspected as required and the record was falsified to indicate the inspection had been con-ducted.
Investigative Fincings On June 5,1980, Individual A was interviewed, along with Individual B, who had provided the initial allegations to Individual A.
Individual B stated that on November 12, 1979, Individual D admitted having signed off and dating the " hold point" as on "11-10-79" on Pittsburgh-Des Moines Steel Company (PDM) Fabrication Check List (FCL), File No. AA18-4-8 (a traveler), hereinafter identified as Document 1, on November 11, 1979, without having conducted the required surveillance inspection.
Individual B stated that on November 12, 1979, Individual D confronted the subcontract surveillance QC inspector (Individual C) who was on duty at STP on November 10, 1979, and told Individual C to include his " hold point" inspection on Individual C's B&R Mechanical Subcontract Surveillance Activities Report (daily activity report) for November 10, 1979.
Individ-ual B stated that PDM employee (Individual M) confirmed that the " hold point" had been passed by PDM welders on the late afternoon of November 10, 1979, and that Individual D had signed off the FCL " hold point" as inspected on November 11, 1979, witnout having actually conducted the inspection.
Individual B stated that Individual D's B&R time sheet
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reflected he worked from 10:00 a.m. to 10:30 a.m. on November 10, 1979, and therefore he could not have conducted the required inspection as indicated
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on Document 1.
Individual B stated that Individual J, a QC supervisor, had drafted a Nonconformance Report (NCR), hereinafter identified as Document 2, regarding the alleged falsification and backdating of the FCL and provided this along with a verbal report, to the B&R Site QA Manager (Individual E).
Individual B stated that Individual E had interviewed Individual C, Individual J, and interviewee regarding the allegation, however, Individual B stated no known personnel or disciplinary action was taken against Individual D for the alleged violation.
Individual B related that Individual D had, during the week of November 12, 1979, crossed out the date "11-10-79" on Document I and recorded his initials and the date "11-11-79."
Individual B provided Document 3, a copy which reflects Indi-vidual D's changing of Document 1.
In conclusion" Individual B claimed that
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Individual D has a documented history of improper inspection practices (Alle-gation No. 3 refers).
Interview of Individual C On June 18, 1980, Individual C was interviewed and stated that on November 12, i
1979, instructions were received from Individual D to list the " hold point" inspection, signed off on Document 1, on the November 10, 1979 daily activity report, hereinafter referred to as Document 4, prepared by the interviewee.
Individual C stated that Individual D admitted having backdated Document 1 on November 11, 1979, and I.ot conducting the required inspection.
Individual C stated that Individual N was present when the fit and tack procedure was accom-plished ou November 10, 1979.
Individual C stated Individual M confirmed that Individual D was not present when the work was done and that Individual D had signed it off on November 11, 1979, without having inspected the work.
Indi-vidual C stated that the department supervisor (Individual J) was apprised of these facts and had notified the Site QA manager (Individual E).
Individual C stated that Individual E had questioned Individual B, Individual J, and inter-viewee regarding their knowledge of the alleged records falsification.
Indi-vidual C advised that Individual E was apprised of all known facts related to the incident.
Individual C provided a written statement regarding the matter
(Document 11).
Interview of Individual I On June 19, 1980, Individual I was interviewed and stated Individual D was his current supervisor in the B&R Subcontract Surveillance Department.
Individual I stated he has worked with Individual D from March 1980 to present and has no knowledge relating to Individual D not conducting required inspections or falsifying inspection documents.
Interview of Individual J Cn June 19, 1980, Individual J was interviewed and stated that on November 12, 1979, Individuals B and C had reported to him that Individual D has falsified an
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inspection record (Document 1).
Individual J stated they had obtained a copy of.the document from Individual M.
Individual J stated he had reviewed the November 10, 1979 time sheet, which indicated Individual D was present at STP for only 30 minutes on the morning of November 10, 1979.
Individual J stated he provided this information verbally to the site QA Manager (Individual E) and the Assistant QA Manager (Individual N) and had also submitted'an NCR (Document 2) regarding the matter. He stated Individual D was interviewed by Individual N on that day and a meeting of supervisors was conducted later regarding the alleged falsification.
Individual J stated the meeting resulted in a decision that Individual E would investigate the allegation further.
Indi-vidual J also stated that Individual E indicated he would notify HL&P QA repre-sentatives of the allegation.
Individual J stated, Individual N had later commented to him that Individual D was cooperative and honest when questioned regarding the allegation and explained the backdating of the FCL as "a mistake." Individual J stated that Individual D had, at that time, been on a 30-day probation period because there was a ques-tion regarding his being physically able to perform his work, due to a previous illness and a question of his ability to submit written reports in a readable fashion.
Individual J remarked that, as Individual D's supervisor, he was to make the decision whether to keep Individual D on the job or terminate him at the end of the 30-day period, however, Individual J explained he was transferred to another department prior to the completion of the 30-day period.
Individual J added that he would not have recommended Individual D for continued employment had he been asked for an opinion or an evaluation by his Supervisor, Individual E.
Interview of Individuals K and L On June 19, 1980, Individuals K and L, both HL&P QA supervisors, were inter-
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viewed regarding their knowledge of the alleged falsification of PDM FCL No.
AA18-4-8.
Both stated they were unaware of the allegation.
Individual L stated, however, he had received an August 9, 1979 QA Internal Surveillance of B&R Quality Control Mechanical Subcontract Surveillances, SIS 19, report (hereinafter referred to as Document 5) which documented numerous omissions on B&R daily activity reports during April and May 1979.
This report documents Individual D's certifying that subcontractors had done "no work" on specific dates when subcontractor records indicate work actually was performed. The STP B&R Quality Assurance Department Corrective Action Request (CAR) prepared in response to that audit (hereinafter referred to as Document 6), initiated by Individual E, noted the audit disclosed " omission on the part of a cognizant surveillance specialist who claimed that he checkes "be operation on the day in question and that no surveillable activity was evtient at the time."
Also noted as a portion of the corrective action on the CAR was "give special counseling, and enter a warning in the file of the cognizant surveillance specialist." Both Individual K and Individual L stated they had been apprised of no other problems with Individual D's performance at STP.
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7 Interview of Individual D On June 19, 1980, Individual D was interviewed regarding his alleged back-dating and failure to inspect the " hold point" on PDM FCL File No. AA18-4-8.
Individual D stated that on November 11, 1979, he was approached by either Individual M or Individual 0 and asked to sign off the " hold point" which had been passed the previous day by PDM welders.
Individual D stated he was familiar with the high quality work done by PDM, therefore, he had signed off the " hold point," without having conducted any surveillance.
He also admitted having backdated the FCL to "11-10-79" (Dccument i refers) to corres-pond with the date the work was accomplished.
Individual D stated he was called into Individual N's office several days later and questioned concerning the " hold point" surveillance.
Individual D stated that he had lied to Indi-vidual N regarding the matter, when he told Individual N that "the fit and tack" had been completed on November 10, 1979, and that the root pass weld was approxi-mately one inch long and had not precluded his ability to adequately inspect the " fit and tack".
He said he' explained to Individual N that he had conducted the inspection on November 11, 1979, but had indicated on the FCL that the inspection was done on November 10, 1979, the date the work as actually done.
Individual D stated that Individual N had accepted his false explanation of what happened and had asked him (Individual D) to provide a letter to him stating the circumstances related to the incident.
Individual D stated the reason he had lied to Individual N was that he (Individual D) believed he would have been fired had he told the truth. When questioned regarding back-dating of the " hold point" Individual D stated he was instructed by Individual N to change the date of his inspection from "11-10-79" to "11-11-79" on Document 1.
Individual D described this change of date as a " late entry" correction to the document and reiterated that this action was ordered by Individual N.
Individual D stated he did not recall whether he documented the falsified Document 1 inspection on his November 11, 1979 daily activity report.
Indi-vidual D stated he has never falsified inspection reports at any other time.
Individual D provided a signed statement regarding these facts (Document 12).
Review of Records On June 19-20, 1980, a review of B&R subcontract records was conducted.
At this time FCL File No. AA18-4-2 was identified as apparently having been back-dated by Individual D.
This document, hereinafter referred to as Document 7, contained Individual D's initials and the date "11-10-79," adjacent a witness point.
November 10, 1979 is a date which Individual D previously admitted having not conducted any inspection activities.
Additionally, it was determined, via records, that Individual D's daily activity report for November 11, 1979, does not include any record of his inspection of the " hold point" (Document I refers) or the " witness point" I
(Document 7 refers). This activity report does identify other areas inspected on November 11, 1979. Lastly, Individual C's daily activity report, dated November 10, 1979 (previously identified as Document 4), was reviewed and found to contain notations that Individual D had conducted the " hold point" and
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" witness point" inspections, previously identified on Documents 1 and 7, on that date.
On June 24, 1980, a review of PDM QC records was conducted at STP.
PDM records confirmed that the work reported inspected by Individual D on his November 11, 1979 daily activity report was accomplished on that date. No records were found which would indicate additional instances of falsified or backdated inspection records.
Interview of Individual M On June 24, 1980, Individual M, a PDM QC inspector, was interviewed.
Individual M stated that the " hold point," listed on Document 1, was passed by PDM welders on November 10, 1979, and that no B&R QC inspectors were present.
Individual M stated that Indivr. dual 0, the PDM Lead QC inspector, apparently talked with Individual D, and that about noon, November 11, 1979, Individual D had come to their work location and signed off the " hold point."
Individual M stated that he does not know whether Individual D actually looked at the welding done on the previcus day, but that an inspection of the fit and tack procedure was impossible due to the root pass welding having been completed.
Individual M stated that he recalled Individual D getting into trouble the following ween as a result of nis (Individual D) backdating of the FCL.
Individual M stated he thought Individual D's supervisors were also aware that he had not conducted the " hold point" inspectica, because one of the B&R QC inspectors had obtained a copy of the PDM FCL (Document 1) from the file in their office.
Individual M stated he vis never questioned by B&R supervisors concerning Individual D's failure to inspect the work and if he had been he would have stated the " hold point" inspec-tion was act conducted.
Interview of Individual N On June 25, 1980, Individual N was interviewed regarding the alleged falsifica-tion of Document 1 by Individual D.
He stated the initial allegation was pre-seated to Individual E and himself by Individual J on about November 12, 1979.
Individual N stated that Individual E had asked him to look into the allegation.
Individual N stated on November 12, 1979, he had called Individual D to his office and discussed the allegation.
Individual N stated that Individual D told him the " hold point" (listed on Document 1) was passed by PDM welders on
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November 10, 1979, however, he (Individual D) was contacted on the morning of November 11, 1979, at which time he had gone to their work location and con-ducted the required " hold point" inspection.
He said Individual D stated the root pass welding, which would have made appropriate inspection impossible,
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had not been completed and that his inspection had determined the fit and tack procedure was properly accomplished.
Individual N stated Individual D said he had, at that time, signed off the " hold point" (Document I refers) and backdated his signoff to "11-10-79" to coincide with the date the fit and tack was accomplished.
Individual N stated that Individual D appeared very sincere in his explanation
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and agreed he.had used poor judgement in backdating the " hold point" approva.
Furthermore, Individual N stated he had no reason to distrust Individual D because he had brought the matter to the attention of his subordinates early on Monday morning, November 12, 1979.
Individual N stated he had told Indi-vidual D to sake a " late entry" correction to Document i by correcting the date the inspection was done (Do%ument 3 refers).
Individual N stated he also asked Individual D to provide him a =emorandum explaining in deca 11 the sequence of events leading to the backdating of the " hold point" approval.
Individual N provided a copy of the =emorandum which was given to him by Individual D, hereinaf ter referred to as Document 8.
Individual N stated he was not aware of any probationary period regarding Individual D, nor was he aware of for=er disciplinary action in Individual D's personne] record. He stated if he had been aware of any derogatory per-sonnel action, regarding Individual D, be would have viewed the incident more critically.
Individual N stated he did not review Individual D's personnel records nor did he investigate the matter further.
He stated he later discussed tne matter with Individual E and they had agreed that Individual D's explanation was sufficient to resolve the allegation and that no further investigation would be necessary.
Finally, Individual N stated he believed that falsification of records was a serious violation of procedures, however, he felt Individual D's backdating the " hold point" approval was si= ply an error La judgement rather than inten-tional falsification.
Interview of Individual E on June 25, 1980, Individual E was interviewed regarding the alleged falsifica-tion of Document i by Individual D.
Individual E stated that on Nove=ber 12, 1979, Individual J told him that Individual D had not perfor=ed the required
" hold point" inspection and had falsified the 'ICL to indicate the inspection was performed on November 10, 1979.
Individual E stated that Individual J had also submitted a handwritten draft of an NCR, addressing PDM nonconformance with the required " hold point" and Individual D's falsification of Document 1.
Individual E stated he had discussed the allegation with Individuals 3 and C, who he stated were responsible for relating the initial allegation to Individual J.
Individual E stated that he and Individual N had discussed the allegation with Individual D who stated the inspection of the fit and tack was actually conducted on November 11, 1979, vice the documented November 10, 1979.
He stated Individual D had readily admitted the backdating of Docu=ent I and had clarified the circumstances relating to the passing of the " hold point" by PDM welders and his subsequent November 11, 1979 inspection.
Individual E stated that based on Individual D's explanation of the events, he believed there was no attempt on the part of Individual D to falsify records and that his bringing it the attentien of a subordinate indicated he did not attempt to conceal what he had don.
Indivstated that Individual D was told to correct the backdated Document 1 to the correct date of the " hold point" inspection (as Docu: at 3 refle. to provide a memorandum documenting the circumstances related to the L Individual E stated he believed that Individual D's explanation had s.orily resolved the allegation and no further investigation of the ma tte.de rta ken. Additionally, Individual E stated that EL&P QA personnel had nnotified of the allegation due to its successful resolution and in his o;t was an internal B&R personnel matter.
Individual E explained he issueonformance Report No. S-M 1357A (Document 9) to PDM for bypassing a holi When ed concerning the relationship of the November 12, 1979 allegation to thormal warning and probationary period, related to Individual D's work I Individual E stated that he did not feel that this incident had violavidual D's probation nor did it in any way relate to the past formai received by Individual D.
He further stated he had not believed the fening Individual D received was a serious matter and that if he had discos discrepancies which predicated it (Documents 5 and 6 refers),
vice B&R audit personnel, a much more informal action would have been utiliasolve it.
In-response to questions concerning Individual D's signine witness point, dated "11-10-79", contained on Document 7, Indivitated he had no knowledge of this document.
Individual E additatated he had not reviewed the B&R daily activity reports for Novest, 1979, nor had he questioned any PDM personnel to substantiate infortovided by Individual D.
Lastly, Individual E stated that he beliesintentional falsification of inspection recordt was a serious violat&R policy, which would warrant the termination of the involved indivi Reintef Individuals B and C On Jur80, Individuals B and C were reinterviewed concerning their being questiIndividual E on November 12, 1979, about Document 1.
Individual B statIndividual E was told by interviewee, early on the day of November 12, 1979,;e known details of the falsification of Document I and that Indi-vidualersonally aware of the falsification.
Indiviand C each related that subsequently they were both questioned togettdividual E, later on November 12, 1979, at which time he asked them iad "a personal vendetta" against Individual D.
Both agreed that, Individual E's demeanor and tone of voice that they each felt threathis questics.
They stated they ha. answered "no."
Individual B statIndividual E then asked them "are yvu implying there was a falsif and if so, that this is serious business," referring to tneir commecDocument 1.
Both agreed they were intimidated by the manner in whiquestion was asked and Individuals B and C agreed they mutually avoideing the question by stating that they wanted a transfer to anothement.
Individuals B and C emphasized that it was their conten-tion they answered "yes" to the question, that their employment with
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B&R would have been endangered.
'4 hen queried concerning their request for transfer to other departments, Individual B indicated the request was approved and a transfer was received and Individual C stated that a work-related medical problem resulted in termination of B&R employment soon thereafter.
Reinterview of Individual D On June 26, 1980, Individual D was reinterviewed concerning the possible falsi-fication of a witness point on PDM FCL AA18-4-2 (Document 7).
Individual D stated that his initials on Document 7 were not placed there indicating his approval of the witness point, but were placed on the document to void the witness point. He stated that PDM welders had passed the witness point on November 10, 1979, without having a B&R QC inspector present.
He stated this fact was brought to his attention on the morning of November 11, 1979, at which time he voided the witness point and backdated the voiding procedure to "11-10-79."
He stated this action took place at the same time he signed off the hold point on Document 1.
Individual D stated the passing of the hold point (Document 1) and the witness point (Document 7) by PDM welders each warranted the issuance of a Corrective Action Report (CAR), however, he failed to document these violations.
Individual D stated that on November 12, 1979, he had told his subordinate, Individual C, who had worked on November 10, 1979, to note his inspection of the hold point (Document I refers) and the voiding of the witness point (Document 7 refers) on their November 10, 1979 Daily Activity Report, which was done.
Individual D stated he had not been questioned by his supervisors regarding the voided witness point nor had he mentioned it to them.
Individual D provided a second signed statement relating these facts (Document 13).
Summary of Individual D's Admissions
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Individual D admitted in his two signed written statements that he:
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Falsified Document 1 by not inspecting the " hold point" and claiming he had inspected it by executing his initials and date adjacent to the hold point.
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Falsified Document 7 by backdating the waiver of the witness point.
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Failed to report his total work activity on Document 10.
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Attempted to enlist a subordinate to falsify a document (Document 4) to cover his original falsification.
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Failed to write NCR's on Documents 1 and 7 when PDM bypassed the hold point and witness point.
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-12 The matter discussed above concerning the by p&ssing of a hold point has been remanded to the Construction Branch, Region IV, for enforcement considerations.
Allegation No. 2 That a draft Nonconformance Report (NCR) by a QC inspections specialist ~
was rewritten in November 1979 by the Site QA manager and/or his staff and pertinent information was purposely deleted.
Investigative Findings The June 5,1980 interview of Individual B disclosed that a draft NCR (previously identified as Document 2), reporting the November 10, 1979 passing of a " hold point" by PDM welders and the backdating of the PDM FCL by Individual D was submitted to Individual E by Individual J on November 12, 1979. Document 9, a December 3, 1979 B&R NCR, reflects that only one of the reported items of non-conformance listed on Document 2, concerning the passing of a " hold point,"
was addressed. Document 9 does not report the backdating nonconformance mentioned in Document 2.
During the June 25, 1980 interview of Individual E, he explained that subsequent-to his receipt of the draft NCR (Document 2), his-inquiries resulted in the determination that_the alleged backdating was actually a " misunderstanding" on the part of Individual D and was resolved with a "Iste entry" correction of the FCL -(Document 3).
He stated that he considered the matter of alleged backdating an internal RRR personnel matter and therefore omitted mention of this incident on the December 3,1979 formal NCR (Document 9).
Allegation No. 3 That Individual D, a QA subcontract surveillance inspector, received and had entered in his personnel file a formal letter of warning concerning improper inspection practices. Records of this disciplinary action -ere allegedly removed from that record, without proper authorization.
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Investigative Findings On June 18, 1980, a review of Individual D's B&R personnel folder disclosed a written warning to Individual D from his supervisor, for failure to conduct proper inspections. The warning stated Individual D was "to exercise strong care in making accurate and complete surveillance reports," in the future.
This warning references the findings of B&R internal audit SIS-19-F-1 (pre-viously identified as Document 5).
The warning was prepared 'in conformance with corrective action taken as reported in CAR 134 (previously identified as Document 6).
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Allegation No. 4 That an administrative assistant in the B&R Receiving Department, Individual F, is intimidating workers in that department by threatening to fire them, for little or no reason.
Investigative Findings This allegation was initially received from Individual A, reporting for Indi-vidual B.
Interview of Individual B disclosed that no threat or intimidation, on the part of Individual F, actually occurred.
Individual B explained the problems with Individual F could be more aptly identified as personality con-
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flicts with coworkers.
Allegation No. 5 That a secretary for B&R was promoted to QA personnel supervisor and is not qualified.
Investigative Findings On June 6, 1980, Individual B was interviewed and alleged that Individual G was promoted from a secretarial position within the B&R QA Department to B&R QA Personnel Supervisor, without being qualified for that position. On June 18, 1980, Individual H, who was formally the QA personnel supervisor was interviewed.
Individual H stated that when he held that position, his job classification (pay grade) had been Project Administrator II.
He stated that subsequent to his transfer from that position, the job classification was downgraded to Administrative Assistant II.
A review of Individual G's personnel record and the Administrative Assistant II job description disclosed that Individual G is qualified for that position.
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Captioned Documents The written statements and copies of all documents, identified herein, relating to these allegations are maintained in the NRC, Region IV, office. The following is a list of documents utilized in this report.
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DOCUMENT 1 - PDM FABRICATION CHECK LIST FILE NO. AA18-4-8 DOCUMENT 2 - HANDWRITTEN DRAFT OF NONCONFORMANCE REPORT.- UNDATED DOCUMENT 3 - PDM FABRICATION CHECK LIST FILE NO. AA18-4-8 AMENDED
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DOCUMENT 4 - B&R MECHANICAL SUBCONTRACT SURVEILLANCE ACTIVITIES REPOR FOR
PDM, DTD NOVEMBER 10, 1979 DOCUMENT 5 - QA INTERNAL SURVEILLANCE OF B&R QUALITY CONTROL OF MECHANICAL SUBCONTRACT SURVEILLANCES, SIS-19, DTD AUGUST 9, 1979 DOCUMENT 6 - B&R CORRECTIVE ACTION REPORT NO. S-134 DTD SEPTEMBER 24, 1979 DOCUMENT 7 - PDM FABRICATION CHECK LIST FILE NO. AA18-4-2
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DOCUMENT S - STATEMENT OF INDIVIDUAL "D" DTD NOVEMBER 19, 1979
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DOCUMENT 9 - B&R NONCONFORMANCE REPORT NO. S-M1357A
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DOCUMENT 10 - BER MECHANICAL SUBCONTRACT SURVEILLANCE ACTIVITIES REPORT FOR PDM DTD NOVEMBER 11, 1979-DOCUMENT 11 - STATE ENT OF INDIVIDUAL "C" DTD JUNE 18, 1980 l
DOCUMENT 12 - STATEMENT OF INDIVIDUAL "D" DTD JUNE 19, 1980 l
DOCUMENT 13 - STATEENT OF INDIVIDUAL "D" DTD JLTE 26, 1980
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