ML19271E462

Board Notification 84-110:forwards 840522 Final Investigation Rept Re Incident W/Electrical Inspectors Referred to as T-shirt Incident

ML19271E462
Person / Time
Site:	Comanche Peak
Issue date:	05/25/1984
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Bloch P, Jordan W, Mccollom W Atomic Safety and Licensing Board Panel
Shared Package
ML19271E463	List: ML19271E462 ML20091E077
References
TASK-AS, TASK-BN84-110 BN-84-110, NUDOCS 8405300021
Download: ML19271E462 (2)

Text

{{#Wiki_filter:] CENTRAL FILES ONLY 1mY 25 W Docket Nos.: 50-445 and 50-446 MEMORANDUM FOR: The Atomic Safety and Licensing Board for Comanche Peak, Units 1 and 2 (P. Bloch, W. Jordan, W. McCollom) FROM: Darrell G. Eisenhut, Director Division of Licensing

SUBJECT:

BOARD NOTIFICATION - TEXAS UTILITIES GENERATING COMPANY TRANSMITTAL 0F A FINAL INVESTIGATION REPORT - INCIDENT WITH ELECTRICAL INSPECTORS AT COMANCHE PEAK STEAM ELECTRIC STATION (B0ARD NOTIFICATION N0. 84-lld This Notification is provided in accordance with NRC procedures regarding Board Notifications. Enclosed for your information and use is a copy of a Texas Utilities Generating Company transmittal ef a final investigation report dated May 22, 1984. This investigation report dated May 15, 1984 identifies issues surrounding an incident that occurred at the Comanche Peak Steam Electric Station with electrical inspectors on March 8, 1984, referred to as the "T-shirt incident". The parties to the proceeding are being informed by copy of this memorandum. Originni GiFnca by Darrell G Darrell G. Eisenhut,iirector Division of Licensing

Enclosure:

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o DISTRIBUTION LIST FOR BOARD NOTIFICATIDN Comanche Peak Units 1&2 Docket Nos. 50-445/446 ACRS Members - Peter B. Bloch, Esq. Dr. Robert C. Axtmann Mr. Jchn T. Collins Mr. Myer. Bender Mr. James E. Cummins Dr. Max W. Carbon Mrs. Juanita Ellis Mr. Jesse C. Ebersole Billie Pirner Garde Mr. Harold Etherington Ellen Ginsberg, Esq. Dr. William Kerr Herbert Grossman, Esq. Dr. Harold W. Lewis Renea Hicks, Esq. Dr. J. Carson Mark Dr. W. Reed Johnson Mr. William M. Mathis ~ Dr. Walter H. Jordan Dr. Dade W. Moeller ' Dr. Kenr.eth A. McCollom Dr. David Okrent Thomes S. Moore, Esq. Dr. Milton S. Plesset Nicholas S. Reynolds, Esq. Mr. Jeremiah J. Ray Alan S. Rosenthal, Esq. Dr. Paul r.. Shewmon Mr. Lanny Alan Sinkin Dr. Chester P. Siess Mr. Michael D. Spence Mr. David A. Ward Robert A. Wooldridce, Esq. Mr. Homer C. Schmidt Mr. H. R. Rock Atomic Safety and Licensing Eoard Panel Atomic Safety and Licensing ~ Appeal Panel Docketing and Service Section Document Management Branch Mr. A. T. Parker Westinghouse Electric Corporation David J. Preister B. R. Clements William A. Burchette, Esq. Mr. Pigott Mrs. Nancy H. Williams e _1_

TEXAS UTILITIES GENERATING COMPANY N KYWAY TOWEP

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..h';!.hii."i.".!.5,._. May 22, 1 m Mr. John T. Collins U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012

Dear Mr. Collins:

Enclosed is a copy of our 1inal report dated May 15, 1984, regarding issues surrounding the T-shirt incident" of March 8, 1984. I believe this report, together with its attachments, accurately reflects the serioustiess with wt.ich senior management views such matters and the level of effort we put into their investigation and resolution. Should you have any questions, please advise. Very truly yours, f m.A / MA BRC:In Enclosure cc: Darrell G. Eisenhut w/ attachment Dupe. ,94e6ewoft-- 0 n,m,On o, rw, cm,m, wcr,,,c c,_.,

TEXAS UT!LITIES GENERATING COMPAN[ TUQ-2134 OFFICE MEMOR ANDUM To D. N. Chapman cien nose, T.uu May 22. 1984 Transmittal of Final Report on Issues Resulting subject From Interviews with Electrical Inspectors This will formally transmit the subject report dated May 15, 1984. The report concludes that there was no intent on the part of the inspectors ~ to convey any concerns or any message that would reflect adversely on an inspector's objectivity. Accordingly no repercussions and/or disciplinary actions have been or will be taken. Of the six inspectors that I interviewed on March 9, 1984, two are still working in Unit No. 1 Safeguards Building; one ii working in the Unit 1 Control Building; two have lef t of their~ own accord; and one is working in Unit 2. All reassignments have been made due to decreased activity in the Unit 1 Safeguards Building and a need for additional resources in the other areas. We will continue our efforts to promote free expression of concerns without fear of retribution and to maintain a strong and effective QA/QC program at CPSES. y . Vega TUGC0 Site QA Manager AV/bil cc: M. D. Spence B. R. Clements 9 0 'N

Tf)0-2674.1 ~ TEXAS' UTILITIES GENERATING COMPANY OFFICE MEM OR ANDU M To D & ChapmajL. Glen Rose. Tex,, May 15, 1984 s@ int._.[._' Final Report on Issues Resulting 4 Trom Interviews with Electrical Inspectors This will documert. actions taken as a result of interviews with six (b) electrical inspecto n who, on March 8, 1984, wore T-shirts with th9 phrase "I'm it,~the bdsiness of picking nits". Upon receiving e reportrof this, TUGCO site management decided to locate them in separate. quarters.tc p otect them from potential adverse reaction by other site personnel acc to-have them conveniently available for i r,te rvi e ws. The inspectors were advised that these shirts reflected adversely on their professier.alism and objectivity as inspectors. Concurrent hith this action,.the inspector's work stations were examined to obtain and, secure compuy property that might be coinpromised if iisciplinary acticns were taken. -The items secured included copies of Non-Confcnnnce Reports (NCR's) and Inspection Reports (IR's), and criginal IR's, Master Data Base Work Packages, controlled and "information" drawings, and misc!11aneous not m and notebooks. The n]nellenects nous and notebooks were returned to the inspectors tbs next' day. Imediately after, or the same day, an NRC representative confiscated t a remaining documents. The following week, we requested tec NRC representative to-Xerox the original documents in their possession anc rcturn the oricinals. to us so that we could proceed with our work. The NRC rsresentathe compliet with our request. The inspectors subsequently were interviewed separately by Mr. Boyce GHer on March' 8 ard 9,1964; and by,Msrk Welch and myself on March 9, 1984. Mr. Boyce Gricr's report.is. included as Attachment A. Durf rg thess meetings saveral coment; and concerns were voiced. Additional' interviews.with sixteen Electrical QC Inspectors were condi,cted to ebtain as. muck infomstion as possible in areas of concern. The following salipt" points' Were made during the meetings with different degrees of concurryace among the inspectors interviewed: 1. The f rispectersJst!.ed 'a strong displeasure at the publicity that ha6 oecn. jf ven t'o thir wearing of the T-shirts. They attributed a phone cell to c.>newscacer to one person whom they described as'"bsing. int 6111 ent but with very little common sense". The 9

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person sho allegesny called the newspaper was also described &3 NWing coined the pnrase, and they stated there whs no connection between this phrase and any other previous incident at Comanche Nak..The An30ectors stated there was no intent to convey a jrsssage cPconcern by wearing these T-shirts. They further pointed / ' outathat;ipor:oximstely twenty (20) inspectors had worn these shirts'triprevious Monday and that "nobody made a big deal about it". ~ f g g \\N , g 1> f

2. They stated that up to about a week before then, there was " finger pointing" going on between building management personnel and QC. They believed QC was being described as uncooperative and causing unnecessary delays. They stated that the main reasons for de dtl?ys were inadequate inspection packages provided by the Paper Flow Group and the craft turning in work for inspection prematurely to obtain progress credit. They did note, however, an improvement in the inspection pa:kages since the program was initially implemented as part of the Building Organization Concept. 3. Some inspectors voiced a concern with respect to inspection procedures. They believed that procedures have been changed too frequently and that changes have been in the direction of relaxing requirements. 4. A concern was voiced over cable terminations. They stated their inspections were identifying problems with lighting terminations and had heard rumors that inspection procedures were being changed to delete such inspections. 5. Some inspectors voiced a disagreement with "use-as-is" dispositions on Non-Conformance Reports (NCR's), principally because of the number of such dispositions. Management's commitment to quality was questioned because a "use-as-is" disposition did not require craft to build it per the original requirement. Two examples were cited. The two NCR's are included as Attachments B and C. 6. Concerns were voiced on documentation. Some inspectors were experiencing problems with incomplete document packages and with duplicate packages with different numbers for the same component. Several inspectors indicated that retrieving Insacction Reports (IR's) has been a problem. During our meeting, the following points were established: 1. TUGC0 Management has been and remains totally commited to a safe and reliable plant in full compliance with all applicable requirements. 2. TUGC0 Management has been and remains totally dedicated to a ' strong and effective Quality Assurance / Quality Control program at Comanche Peak. 3. There was a need to place more emphasis on communicating information to inspectors, especially when inspection procedures are revised such that inspections are reduced in scope or deleted. The reasons for these actions, such as equipment declassification; alternate inspection programs; or inspection or test provisions (such as prerequisite or preoperational tests) during other project phases, should be communicated. Such communication was also necessary on certain NCR's dispositioned "use-as-is"

4. There was a need to romote more feedback and discussion, not r only within QA and QC, but with the Engineering and Quality Engineering function. On March 16, 1984, I was assigned to Comanche Peak as TUGC0 Site QA Manager. Concurrently, Quality Engineering was organized also reporting to the Manager, Quality Assurance in Dallas. During meetings at the site on March 16, 1984, with QA and QC supervision, TUGC0's commitments to a safe and reliable plant; to a strong and effective QA/QC organization; to free and open communication at all levels in QA/QC; to an emphasis on QA/QC procedures that assure design commitments are being met; were communicated, Subsequent to that meeting, I issued a letter logged TUQ-1982 dated March 22, 1984, entitled "QA Policy" that reaffirms these commitments. A copy of that letter is incluoed as Attachment D. Since that letter, I have held meetings with every element of QA and QC organization here on site. TUGC0 top management, including Mr. M. D. Spence and Mr. B. R. Clements, have attended some of these meetings with ma. A memo to file dated April 30, 1984, reflecting top management involvement, is included as Attachment E. In regard to the " finger-pointing", the QC inspectors cited inadequate inspection packages and premature submittal of work for inspection as reasons for delays. The Inspectors stated that they had seen significant improvement in the quality of the cackages, attributing the initial problems to " growing pains" with the Paper Flow Groups under the Building Management Concept. However, I have directed that a surveillance be conducted in these areas of concern. A copy of this directive is included as Attachment F. In addition to the above surveillance a task force (the CPSES Monitors Team) has been commissioned by the Assistant Project General Manager and myself to perform an oversight function on the entire records processing activity at Comanche Peak. The Paper Flow Group in each Building Task Force would be included within the inspection scope of the CPSES Monitors Team. The document commissioning this effort is included as Attachment G. This on-going effort will continue to assure QA records are being processed in an efficient and correct manner. In regard to premature submittal of work for inspection, this matter had already been identified by our trending program. A Corrective Action Request (CAR), logged TUQ-1955, designated CAR-036, dated March 1,1984, was issued requiring corrective action in four areas where a problem with " failure to assure work is completed correctly prior to a request for inspection" was idstified. The Corrective Action Request is included as Attachment H.

The concern on cable terminations has been addressed. On January 24, 1984, we verbally informed the NRC of a deficiency regarding cable terminations. On March 29, 1984, a final report was submitted in accordance with 10 CFR 50.55(e), describing actions taken. Supporting documentation is on record at CPSES. Terminations used in junction boxes for po,wer and :ontrol cable for lE applications are qualified in accordance with IEEE 323-1974. The report has been reviewed and approved as meeting all requirements. Contrary to the rumors, Revision 16 to the procedure, which was issued on March 12, 1934 and remains in effect as of this date, continues to provide for removal of the covers of Class 1E power and control junction boxes, and for inspections. In regard to the lighting terminations, the inspectors were ady' sed that lighting fixtures are not Class 1E. Concerns related to failure of the lighting fixture terminations in the open-circuit and short-circuit mode were discussed with the inspectors involved. Engineering documentation addressing both failure modes was reviewed with them and discussed at length. The inspectors were satisfied that the integrity of the Class lE power and distribution systems is not compromised. The investigation clearly indicates that the T-shirts were worn in a spirit of levity, with no intent to convey messages or concerns. A greater number of inspectors had worn the shirts previously without incident. The investigation clearly indicates there was an unwarranted over-reaction on the part of management towards the wearing of the T-shirts on Thursday, March 8, 1984. This over-reaction in itself gave this incident inordinate and inappropriate attention. Our efforts to encourage QA/QC personnel to voice their concerns is continuing. We continue to emphasize an open-door policy without fear of retribution. Mr. Boyce Grier is making every effort to provide greater visibility to his presence on site. We are continuing to place emphasis, during o.'r training meetings, on reasons for procedural changes and continue to encourage inquiries on dispositions of NCR's, or en any other area of concern. We believe our efforts are being successful. We continue to maintain a highly effective Quality Assu ance, Qual.ity Control and Quality Engineering organization at Comanche Peak. We believe that our combined efforts continue to assure that we are building a safe and reliable plant that is in full compliance with all applicable requirements. A. Vega TUGC0 Site QA Manager AV/bil cc: M. D. Spenc2 B. R. Clements

TEXAS UTil.lTIES GENERATING COMPANY ATTACHMENT A OFFICE MEMOR ANDUM R. G. Tolson cien no.e. Texu March 15, 1984 r. Subject Interviews of Electrical OC Inspectors Safeguards Building Task Force On March 8 and 9,1984, I conducted interviews of sixteen Electrical QC inspectors assigned to the Safeguards Buil' ding Task Force. A summe.ry of the results of the individual interviews is attached. The following is a summary of my analysis of the results in the principal areas discussed during the interviews. Procedures Three-fourths of the inspectors interviewed have concerns with respect to inspection procedures. They believe that procedures have been changed too frequently and that changes have been in the direction of relaxing requirements. '.t is their perception that requirements are being relaxed because inspectors have found too many problems that impact on schedule. They believe this is the reason that post construction inspections are being held up while the procedure is being revised. One inspector felt that inspectors should have more input into procedure changes and opportuni'y to comment on new procedures and proposed changes. Two inspectors had no problems with procedures and two were silent on the subject. Documentation Three-fourths of the inspectors interviewed have concerns about documentation. They were experiencing problems with incomplete document packages and with duplicate packages with different numbers for the same component. Several inspectors indicated that retrieving IR's has been a problen. Five of these inspectors believed that the situation with documentation is improving while two other inspectors said they saw no improvement. Three inspectors had no problems with documentation and one was silent on the subject. Training Three-fourths of the inspectors either have no problem with training or were silent on.the subject. The remaining one-fourth felt that training could be improved. For the training currently being conducted they complained about the instructors who only read a procedure and answered questions during a training session. One felt the training would be more helpful if tie instructors would discuss examples of inspection pmblems and describe how they were resolved. ~ ~ 9

ATTACHMENT A - con't R. G. Tolson Page 2 March 15, 1984 NCR's None of the inspectors interviewed stated that they have any problem with issuing NCR's. One inspector did say that.he had had some problems in the past but none now. One-half of the inspectors stated that they often disagree with the disposition of NCR's, principally because they feel that - an excessive number are dispositioned "use-as-is". Management Two inspectors expressed concern because management did not seem to care about quality. Two other inspectors expressed the view that Area Management felt QC was overdoing inspections and causing delays in meeting schedules. Two other inspectors were concerned about pressure they perceived from management to meet turnover schedule, and one inspector felt the shutdown of inspections in the areas of post construction verification, separation and lighting was harassment by management. If you have questions or wish to discuss this matter further, please let me know. /B. Hforier BHG/bil Attachment cc: B. R. Clements D. N. Chapman ~ee d i

ATTACHMENT A - con't Summary of Interviews With Electrical QC Inspectors - Safeguards Task Force Inspector A Did pre-post construction inspections. Found many problems in first room - inspected. Room not ready for inspection. Followed procedure as written. Found 50-60% bad terminations. Noted evidence of rat damage to cables. Could not get SWA's to look at equipment. Only one SWA issued for pump motor. Training has been good. Documentation is a problem because of missing documents in folders. Three packages obtained today had nothing (DCA's, CMC's, IRN's) in folders. Feels situation with documentation is not improving. Has no problems with issuing NCR's when required. No problems with NCR dispositions. Inspector B Short time in Safeguards Task Force. Feels cooperation in Safeguards is not as good as in former group where everything went smooth. Regularly opened junction boxes during post construction insnections in former group. Training going good and has been helpful. Instructors mostly read orocedures and respond to questions. Should bring up more examples of inspection oroblems encountered and discuss resolution. Has no problems with issuing NCR's. No problems with dispositions. Inspector C Concerned about newspaper article and stateinent about damage being done during inspection. Concerned about Area Management statements that QC inspectors are " overdoing their job". Feels that inspection procedures are changed too fr equently. Believes terminal blocks which do not have lugs should not be used on safety equipment. Feels react ~on when anyone goes to the NRC is intimidation. Believes Safeguard Electrical QC group is feeling heat because they spoke up about problems. Has no problems issuing NCR's. Feels too many NCR's are dispositioned "t.se-as-is". Believes inspectors need more freedom to do their job. Suggested that interviews of inspectors be conducted routinely with random selection of inspectors to be interviewed. Feels craft personnel were back of lock-up of inspectors wearing t-shirts and search of their personal effects. Has been unable to find some IR's in vault.

ATTACHMENT A con't Inspector q Feels Safeguard QC group has too many agreements with construction and doesn't follow inspection procedures because of informal arrangements. Concerned about newspaper article and statement about damage being done by inspectors. Finds this statement directed toward entire group to be intimidating. During training some of the QE's just read procedures and sometines cannot respond to questions. Has problems with documentation packages with missing DCA's and IR's. Experience in the other A ea groups is much better and sees no improvement in Safeguards pFG. Turned three packages back this morning because they were incomplete. No problem with issuing NCR's. Feels too many NCR's are dispositioned "use-as-is". Feels shutdown of pCV, separation and lighting inspections by Safeguards group when other area groups are not shut down is harassment by QA/QC and craft management. Inspector E Has no problem with inspections but feels procet res are changed too frequently. Feels training is alright. Has problems with documentation and receiving incomplete packages from PFG. Has spent more than half day looking for documents. Feels situation with documentation is improving. Has no problems with issuing NCR's but feels too many are dispositioned "use-as-is". Believes procedure changes are in direction of relaxing inspection requirements. Concerned that management doesn't care about quality. Would like to feel that he did a good job in his inspections. Inspector F Has concerns about lighting terminations where cable slack is not as prescribed. Inspected three rooms and found problems with 90% of terminations in two rooms but no problems in third room. Variation in results apparently due to difference in workmanship. Feels training is going well. Has had problems with incomplete document packages and IR lists not complete. Has no problems with issuing NCR's. Feels QC works well with engineers to resolve NCR's and has no problems with disposition. Inspector G Inspections have found problems with lighting terminations,also with power and control terminations and conduit identification. Feels procedure is being changed because inspectors.have been looking too far. Understands Class lE lighting is not to be inspected. Concerned because evidence of rat damage has been observed. Feels push from Area Management to meet turnover schedule. Has no problems with issuing NCR's. Has no problems with document packaga.s.

ATTACHMENT A - con't inspector H Has had problems with interpretation of post construction inspection procedure. Procedure is being changed and feels problems are being resolved. Training will be conducted in revised procedure. Documentation has been a problem because of documents missing from packages. Feels situation is improving. Has no problem with issuing NCR's. Sometirnes does not agree with NCR disposition. Inspector 1 Concerned that inspection procedures are being changed to elim1nate removing of covers on junction boxes. Feels this may be compromising quality because inspections will be only a cosmetic look. Has problems with response from QE on questiens. No problems with documentation. No problems with issuing NCR's. Sometimes does not agree when disposition is "use-as-is". Inspector J Has no problems with inspection procedures. Feels training being conducted is good. Has had problem with incomplete document packages but feels situation is improving. Has no problems now with issuing NCR's but has had problems in the past. Feels disposition "use-as-is" is excessive. Has gone to supervisor, QE and engineer to resolve disagreements on disposition. Feels post construction. inspections are being limited. Concerned because QA management and Area Management don't seem to care about quality. Does not believe there is any way equipment is being damaged by inspection. Inspector K Concerned because of problems with procedures and shut down of inspections. Has no problems with training. Has problems with incomplete document packages. Inspector L Ha' found number of problems with lighting terminations during inspections. s Feels inspections now being limited. Understands inspection procedure is being changed. Believed now procedure will not find problems. Training now going on is reading procedures and responding to questions. No problems with documentation. No problems with issuing NCR's but some problems with dispositions. s

ATTACHMENT A - con't Inspector M Concerned because inspection procedures are being changed frequently. Some procedures have been changed 3-4 times since Task Force was rormed. One procedure was changed twice last week. Has found problem with documentation packages. Found four packeges concerning same cable tray with different numbers assigned to the packages. Also prpblem getting DCA's. Previously had own prints but now can't get print when someone else has it checked out. No problems issuing NCR's. Inspector N Understands post construction inspection procedure is being revised to relax requi rements. Concerned because of problems that have been identified with lighting terminations. Feels procedure requirement for STE or EE present when equipment is opened inhibits inspectors. Has no problems issuing NCR's. Feels electrical problems are not limited to the Safeguards Building. Training being conducted consists of instructor reading inspection procedures and answering questions. Feels documentation support is improving. Has had problem retrieving IR's. Concerned about promction policy. Feels his pay increase is overdue. Inspector 0 Feels inspection procedures are a problem. There is no system for inspectors to request changes in procedures or for comenting on new procedures. Believes there should be system for feedback from inspectors. Feels there is pressure on craft to meet turnover schedule resulting in conflicts between craft, Area Management and QC. Feels PFG was not ready for Task Force operation. Has had problems with duplicate documentation packages and with retrieving IR's. Two people are assigned to the records vault to correct problems. Has no problems issuing NCR's or with dispositions. Believes inspector training should be improved. Feels testing for certifications is not strict enough. Inspector P Has no problems with inspection procedures. Belietes Area Management feels that problems with delays are because of QC. Has no problems with training. Feels that. documentation problems are being resolved. Has had proolems retrieving' IR's. Has no problems issuing NCR's. Believes separation was not built-in in the Safeguards Building. Feels that construction training in separation criceria was lacking. n

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ATTACHMENT C COMANCHE PEAK STEAM cl ccvoir ev a t,m, tex 4S.'/TILITIEs .Q 0 O B O N J );~ # - o o o y9 ~ , GENERATJNG CO NONCONF( I UNIT ST RUCTU AE / SYS T E M IT E M / COM Potd E N T TAG /lD NUMBER LOCAflON OR ELEVA rlON RI A NO Trn. '55 C \\a-a1G 5r1 LKu a r b 00$_&( 0 l0 &.330 NONCONFORMING C'dNDITION Th< f\\w conj J for t 0 6 o 47'i9 i s imse boh or end s. T h ', 3 kodban i b a4 : E'id h d % s4 rad' ton o n. z / GL Y ' r.' k, c., 4 '. o n h e (. c. c.u q 2eporY S D 0 10'31 l' y i) e e g l oc d e.1 D, c.,, i G < <Je r bw%Sdbe F. O. b.O A-e ,n P C7 I - DO A Pnw.c3 m 44 +- h < eust ena d M<-D<>a 6,n. o., N So A s.A S f-o f d hw 3 cm p k'ed REFERENCE DOCUI.ENT. O f - O P )) 3 - 4 O l3 ngy ping REPORTED BY: DATE: E AA+ 5 k \\ i 5 184 OE REVIEW / APPROVAL: / OATE. / Cl / 16 IFV / V ACTION ADDRESSEE OEPARTMENT e h-) N '. / 0.* J-f*T~/? $ E/t*t Y /bh 97~- DISPOSITION: REWORK XYY REPAIR USE AS IS /Fk' SCRAP .) 'T t46 LOOS E N E 5 b O F TH E PLE.X A'T THC E Q 0 L P NE N'T" E N tb t % bv G. orvc V TIJ

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ATTACHMENT D TUQ-1982 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMOR ANDUM w Site OA/DC Personnel Glen he, Texa. March 22. 1084 Subject GA Policy Effective March 16, 1984, I assumed the position of TUGC0 Site QA Manager at Comanche Peak. I ask for your support in carrying out the following policies and objectives: 1. TUGC0 Management has been and remains totally committed to a safe and reliable plant in full compliance with all applicable requirements. 2. TUGC0 Management is totally dedicated to a strong and effective Quality Assurance / Quality Control program at Comanche Peak. 3. TUGC0 Management strongly supports and encourages all QA/QC personnel to express quality related concerns. I wish to promote free discussion between inspectors, their " leads", QC supervisors and QA management. I wish to encourage the use of the Request for Infonnation and Clarification (RFIC) as a means to communicate questions on procedures and instructions. I also wish to point out the availability of Mr. Boyce Grier to listen to any of your concerns. While your first recourse on concerns should be to your supervision, if you are not satisfied with the response from supervision, or for any reason you prefer not to go to supervision, Mr. Grier is available. I maintain an "open-door" policy. Please feel free to visit with me at any time. I encourage you to voice your concerns without fear of retribution. We will make every effort to address your concerns in a complete manner. 4. Quality Engineering is being reorganized reporting directly to the TUGC0 Manager, Quality Assurance in Dallas. This provides an added measure of independence for that organization in order to assure that inspection procedures and instructions accurately reflect design requirements. Quality Engineering will also be working toward improving our program for training on inspection procedures and instructions. We intend to place more emphasis on systematically infoming the affected inspection forces of changes to inspection procedures and instructions, especially when changes appear to relax or delete procedural requirements. Our objective is to communicate reasons for the above changes, such as declassifications, alternate inspection programs or inspections or test provisions during other project phases such as preoperational testing. Our objective is to continue to promote a high degree of confidence that inspection procedures and instructions, which prescribe inspection work activities, accurately address design requirements.

ATTACHMENT D - con't 2-I again request your support so that together we can continue to work toward-a safe and reliable Comanche Peak Steam Electric Station. Thank you, A A. Vega TUGC0 Site QA Manager AV/bil d

TEXAS l'TILITIES GENERATING COMPANY ATTACHMENT E OrrlCE M EMOR ANDU M File April 30,1984 To .clen none, Texas subject Top Management Participation in ~ ~ ~ " ~ Site Meetings with QC Inspectors This will document Mr. Mike D. Spence's involvement in meetings with QC Inspectors at Comanche Peak S.E.S. These meetings included both informal meetings and formal training classes. The attendance rosters for the formal meetings are attached, Mr. Spence, as President of TUGCO, presented top management's priorities and commitments as they apply to Comanche Peak. The meetings between Site QA Management and the inspectors were undertaken to personally re-emphasize the QA policy elements documented in memorandum TUQ-1982, dated March 22, 1984, a copy of which is attached. Mr. Spence stated that Texas Utilities because of its size has many important priorities. However, Texas Utilities has no higher priority than constructing Comanche Peak correctly. Mr. Spence stated that Site QA Management's commitment to an open door policy and more informative communication is a reflection of his policies. As examples, he stated that inspectors have the right to ask for information and receive infonnation on use-as-is dispositions on NCR's. He supported the intent to inform inspectors of underlying reasons for changes to inspection procedures. Mr. Spence also emphasized TUGCO's responsibility for the safety of Comanche Peak. He stated his belief that this is a responsibility that TUGC0 has accepted and which it cannot delegate to any organization. He stated his belief that quality cannot be legislated; that it' must originate with top management support for quality. He further stated that quality cannot be inspected into the plant; that it must be built by the craftsman into the plant. He discussed the economics and the management support for " building it right the first time" as opposed to building it right on the second or third effort. Mr. Spence stated he saw Quality Assurance as an essential tool in assuring an effort is done correctly the first time. Mr. Spence then opened the meeting for questions, declaring an "open season on the President of TUGC0".

ATTACHMENT E - can't File Page 2 TUQ-2046A During this part of each meeting, the inspector's questions, concerns and comments were addressed. These ir.cluded: - The effect of security measures, in the permanent plant records vault, on inspector's accessibility to records. - The review of QA records by non-QA organization personnel. - Pessibility of across-the-board salary increases. - History / purpose of Component Modification Cards (CMC's). - Plans related to the completion of Unit 2. - Sources of financing for the project. - Status of the licensing process. - State of the nuclear industry, especially plans for new plants, in the present regulatory eavironment. ~ - Inquiries as to what TUGC0 is doing to present the positive aspects of Comanche Peak. I believe these meetings have made a significant contribution in improving communications with the inspection forces. A A /rC D A. Vega ~ TUGC0 Site Manager AV/bil cc: M. D. Spence B. R. Clements D. N. Chapman

ATTACHMENT E - con't TRAINING RECORD C0fMNCHE PEAK STEAM ELECTRIC STATION DATE: THE UNDERSIGNED ACKNOWLEDGE RECElPT OF SPECI ALIZED TRAINING IN: 5.T f f,i/. //- 7 % E g u y GIVEN BY: /( ~ 7 '/ _ / /7C/ 7~7 I.]Q1ST40CTOR) THIS DATE, AT C0t%NCHE PEAK PROJECT. PME 4 1SU NME (PRINTED) SIGNATURE l. hw (l.k],hr;h0s.J-n91A1 32 3 to 2. (pl ?5~~ ( eN l 37 D '. Tro ;t6 5 G T' D C vips p i ) ~ 'w/' E /% lk'. i/ b(d. >t?4 /y3 -c/ ~ 700 D.B. Dlonne A.6.D h- 'M" ek,5 - 9 2 - z. +o o it &l l *b IEh ) hdikki Nh f2 l((s /~ S'l- 02 T T t Yn n r. i c 191, u -cp1p Ecw GnsInhca Ql 0 -L.x.>, ll: ' a. t J. M 'Is & :- \\ j q a hm,:, iiM * .N ;* Ii i $ t. t

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ATTACHMENT E - can't TRAINING REC'. ERD COMANO1E PEAK STEAM f.LECTRIC STATION DATE: / THE UNDERSIGNED ACKNOWLEDGE RECEIPT OF SPECIALIZED TRAINING IN: OD cOf // f~ [W TcM Y / !F/D. E"rr 7evj!NSTRUCTOR) THIS DATE, AT CDMANCHE PEAK PRdJECT. GIVEN BY: NAME (PRINTED) SIGPMTmE MDGE 4 .SSN hal M:lla<- YWidf d>P94 %t G4pG z.js HA?3oy % Y = .5L 00 % % D - b'C - 96 0% l~ea H. 5-E E.M 2$ Ho oni s48.n-oso/ $$ tao -. d.c,c., o _ h,$s.fh"$Au* 6!M SN-& FNU MLOp VP'?O 96/~ 77-ff 3 o D x vz o x.2 i n.c o c s f f f / ( ( ( (- ~ \\ \\ \\ \\ 1 \\ S X / \\ / I i / ) ( ( .\\ / \\ \\ ) \\ W/Y/JN/bR 5 IteTauCTf(S'SiGSATURE gy,y/' HomS OF TRAINING: YI8N2 i Tine: D O A l' /A:DS~Aff'

ATTACHMENT E - con't TRAltiltG RECORD COf%NCHE PEAK STEAM ELECTRIC STATION ~ DATE: THE LNDERSIGNED ACKtOblEDGE RECEIPT OF SPECIALIZED TRAINItG IN: 0/2 /f Y Y YC V- ~ ~~ GIVEN BY: [/ b/2/ W DX (IrlSTRUCTOR) THIS DA, AT CDMANCHE PEAK FR6 JECT. EADGE # ISi NAME (PRINTED) 91Gr@TtRE 50HNAW LMfu YS2 y'Al J J ]nn.0 so-9a ses 9r-sus o V 4' . n o // 0.br ()f /kg 1 do-47 Ye/- 79'- od) 4 2001E Ni ~ hic I2EN felcl u D ucht tbM T. 9 %') - % LI*(1~A G 0 9 ~ JAn1cs J e hlc,rd 0% Mi E //4

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7U0-1982 TEXAS UTILITIES GENERATING CO31PANY ATTACHMENT E - con't Of f!CE MEMOR ANDUM To Mte DA/DC Personnel G W no. Teu. March ?? 1984 0A Policy , Subject Effective March 16, 1984, I assumed the position of TUGC0 Site QA Manager at Comanche Peak. I ask for your support in carrying out the following policies and objectives: 1. TUGC0 Management has been and remains totally committed to a safe and reliable plant in full compliance with all applicable requirements. 2. TUGC0 Management is totally dedicated to a strong and effective Quality Assurance / Quality Control program at Comanche Peak. 3. TUGC0 Hanagement strongly supports and encourages all QA/QC personnel to express quality related concerns. I wish to promote free discussion between inspectors, their " leads", QC supervisors and QA management. I wish to encourage the use of the Request for Infomation and Clarification (RFIC) as a means to comunicate questions on procedures and instructions. I also wish to point out the availability of Mr. Boyce Grier to listen to any of your concerns. While your first trecourse on concerns should be to your supervision, if you are not satisfied with the response from supervision, or for any reason you prefer not to go to supervision, dr. Grier is available. I maintain an "open-door" policy. Please feel free to visit with me at any time. I encourage you to voice your concerns without fear of retribution. We will make every effort to address your concerns in a complete manner. 4. Quality Engineering is being reorganized reporting directly to the TUGC0 Manager, Quality Assurance in Dallas. This provides an added measure of independence for that organization in order to assure that inspection procedures and instructions acc.urately reflect design requirements. Quality Engineering will also be working toward improving our program for training on inspection procedures and instructions. We intend to place more emphasis on systematically infoming the affected inspection forces of changes to inspection procedures and instructions, es.pecially when changes appear to relax or delete procedural requirements. Our objective is to comunicate reasons for the above changes, such as declassifications, alternate inspection programs or inspections or test provisions during other project phases such as preoperational testing. Our objective is to continue to promote a high degree of confidence that inspection procedures and instructions, which prescribe inspection work activities, accurately address design requirements. I 8

ATTACHMENT E - con't 2 I again request your support so that together we can continue to work toward a safe and reliable Comanche Peak Steam Electric Station. Thank you, ,f /d#y J A. Vega TUGC0 Site QA Manager AV/bil ~ ( 4 e

TEXAS UTILITIES GENERATING COMPANY ATTACHMENT F Of flCE MEMOR ANDUM ("' To C. H. Welch - cien na a. Teu. March 21, 1984 _ subject Inspector Interviews 4 CONFIDENTIAL 4 Concerns have been expressed related to document packages and duplicate packages with different numbers for the same components, presented to inspectors for their use in conducting inspections. A concern has also been expressed on the retrieveability of IR's. The problem appears to have been observed during the establishemnt of work packages related to the integrated building management system. An improvement has been noted in some instances. Please arrange for a surveillance of this activity and advise me by March 23, 1984, of your schedule for conducting this surveillance. (1 . f-orc" ARbga.. / TUGC0 Sit 5 QA Manager AV/bil ~ cc: B. R. Clements D. N. Chapman B. H. Grier I ~[ I ~l

/ TEXAS UTILITIES GENERATING COMPAN Y OTTICE ME MOR A NDUM Distribution Glen nm, Tua,_ tiarch 30. 1984 7. subject COMANCHE PEAK STEAM ELECTRIC STATION The CPSES Monitors Team is established as a management oversight group under my direction. Its purpose is to monitor records processing acti-vities as they relate to construction and startup activities. Initially, efforts will concentrate on records necessary to complete construction within security boundary of Unit 1 and common. The scope will incluae all of the departments cited on the attached flow diagram between the points labeled DCC and PPRV/B0P Vaults. Activity reports and recommenda-tio.s will be made on a regular basis to me and the management of the groups affected. This team is being chartered as a result of an already successful moni-toring effort in DCC and requests made by several building managers. It supplements the existing QA internal audit program. / f, T. ) ferri t, Jr. At t. Proj ct Genere ianager W Vega / '~ TUGC0 Site QA Manager JTH:AV: pew cc: B. J. Murray G. B. Crane F. L. Powers J. A. Dittmar R. D. Gentry H. A. Hutchinson C. Boyd C. Welch C. Osborne L. M. Richman L. D. Platt j

t Af tACW(316. tem't J.T. MERRITT STAFFADVISOR L RIO1 MAN MONITORS GROUP r - L. D. PLATT, LEAD -J. R MENARD 3 - L. H. ROSSON J. SWAIN N - D. CAllCUTT i (. I. l: - H-9 f t i

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8 GENERATM RECORDS PROCES3pg ACTIVITIES SUPPORTRS ) gy AND TRACKING R ECORDS I (COMSTRUCTIONI l REPO I Ry REPOstTORY I CONSTRUCTION (CONSTRUCTION I (OPCRATIONSI RECORDS REPOSITORY * { t OPERATIONSI 4 g I - Aux ELDS TF 3, ~ 300 SATELLITE ~ - CONTROL BLDG. TI ~ ~ 304 SATELLITE - ~ ~ ASE - SOS SATELLITE - ) ~ M M - 30T SAfELLITE - f l CENTER yay ENGINEEResG N (DCC) - 304 3ATELLITE - . ENGINEERING www qqw RECORD WAULT-VEM00RS ~0A /QCl0E [ppgy) N ~ gragygp VBOP VAULT G EN P MT RECORO VAULT-l MS PACKAGE REVIEW ~ i 4 1r t,0PERATIONS y 5 PERMANENT PLANT V VAULT oRAw McS l # M INCLUDES RECOROS l GENERADON g , * *

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'[ TEXAS UTILITIES GENERATING COMPANY ATTACHMENT H TU0-1955 OFFICE MEMOR A ND UM To J. T Merritt cien no,,, Tem, March 1,1984 subice Corrective Action Request (CAR-036) Control of Deficiencies RE: Corrective Action Report Fourth Quarter 1983 (Attachment) A review of the fourth quarter trend report indicates that the percentage of inspection reports documenting deficiencies is unsatisfactory in several areas and appears to warrant corrective action. The following shows the type of work in.ipected, the percentage of inspection reports documenting deficiencies, the mi.jor deficiency trend categories, and, based on discussions with inspection supervisors, the apparent causes for the deficiencies: 1. Electrical Cables showed an unsat rate of 14%. The major orend category was work incomplete /not per requirements. This trend appears to be caused by a failure to assure the work is completed correctly rarior to a request for inspection. 2. Electrical work other than cables and terminations (E) showed an unsat rate of 12.8%. The major trend category was work incomp'.ete/ not per requirements. This trend appears to be caused by a failure to' assure work is completed correctly prior to a request for i nt pection. 3. Miscellaneous Structural Steel (MS) showed an unsat rate of 14.2%. The major trend category is fabrication errors due to misdrilled holes, improper dimensions, and/or improper material. The apparent causes appear to be a lack of clear fabrication requirements and failure to assure work is completed correctiv prior to a request for inspection. 4. Protective Cortings (PC) showed an unsat rate of 34.4%. The major trend category is inadequate surface preparation. The apparent cause is a failure to assure work is completed correctly prior to a request for inspection. Pleas.e provide a written responsa to this office on or before March 16, 1984, describing the action you have taken or intend to take to correct these matters and prevent recurrence and your estimated date for completion of corrective action. ./ R. 3.' Tolson TUSCO Site QA Supervisor RGT/3CS/GWP/ GAS /pr Attachment cc: J. D. Hicks MN.Chjapy .}}