ML20136A806
See also: IR 05000445/1981004
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Docket No. 50-445/81-04
MAY 5
1981
50-446/81-04
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Texas Utilities Generating Company
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ATTN: Mr. R. J. Gary, Executive Vice
President and General Manager
2001 Bryan Tower
Dallas, Texas 75201
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Gentlemen:
This refers to the investigation conducted by Massrs. D. Driskill, R. Herr,
L. Martin, and R. Taylor of our staff on February 25-27 and March 9-13,
1981 at your facility in Glen Rose, Texas, concerning allegations that
QC supervision directed electrical QC inspectors to violate inspection
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procedures and to not perfom in-process inspections; that electrical QC
Department blueprints and are not always current; that electrical QC management
is sympathetic with production management; that some electrical QC inspectors
are not qualified; that electrical QC inspectors have accepted'nonconfaming
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terminations; and that pipe hanger packages are being divided at your
facility. The investigation and our findings are discussed in the enclosed
investigation report.
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Within the scope of this investigation, we found no instance where you
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failed to meet NRC requirements. We. note, however, that in our fincings
to Allegation No. 8 departmental policy had been established which was '
contrary to. one of your procedures. , Although we found no examples where the
procedure had been violated, you are requestad to take appropriate action
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to assure that departmental policies (written or unwritten) do not violate
hpproved procedures or other regulatory requirements.
In accordance with Section 2.790 of the Coinnission's " Rules of Practice,"
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Part 2, Title 10, Code of Federal Regulations, a copy of this letter together
with the enclosed investigation report will be placed in the Comission's
Public Document Room.
If this report contains any infomation that you
believe to be proprietary, it is necessary that you make a written application
to this office within 25 days of the date of this letter requesting that
such.infomation be withheld from public disclosure. Any such application
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must include a full statement of the reasens on the basis of which it is
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claimed.that the infomation is proprietary, and should be prepared so that
proprietary information identified in the application is contained in a
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separate part of the document. If we do not hear from you in this regard
within the specified period, the report wilU be placed in the Public Docu-
ment Room.
j
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GARDEB S-59
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Texas Utilities Generating Company
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Should you have any questions concerning this investigation, we will be
pleased .to discuss them with you.
Sincere)/nb4 lin
. ~44U1*7
G. L. Madsen, Chief
Reactor Project Branch
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Enclosure:
Investigation Report No. 50-44S/81-04
50-446/81-04
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bec to Repc9 duction Unit:
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STANDARDS DEVELOPMENT
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TEXAS DEPT. OF HEALTH RESOURCES
JUANITA ELLIS
GEOFFREY M. GAY
RICHARD W. LOWERRE, ESQ.
RICHARD FOUKE
W. Ward, EI
D. Thompson, EI
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U. S. NUCLEAR REGULATORY COPt1ISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Inv2stigation No. 50-445/81-04
50-446/81-04
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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:
us M
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D. D. Driskill, Investigator
Date
Investigation and Enforcement Staff
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K. Herr, Investigator
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Investigation and Enforcement Staff
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Inspectors:
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L. E. Marti , Reactor Inspector
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Projects
ction No. 3
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R. G. Taylor, Resident Reactor Inspector
Date
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F roje s Section No. 3
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Reviewed by:
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J.\\E. Gagl\\ardo, Director
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Investigatfon and Enforcement Staff
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Approved by:
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~. L. Madsen, Chief
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Reactor Projects Section
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Summary
Investigation on February 25-27 and March 9-13, 1981 (Report
. 50-445/81-04;
50-446/81-04)
Area Investigated:
Allegations were made that a Comanche eak Steam Electric
Station (CPSES) , Brown and Root, Inc. (B&R), Quality Conte 1 (QC) supervisor
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recent.dly_ told _ electrical OC inspectors Wviolate inspection procedures;
th.at_a QC supervisor told electric _al Q_C_ inspectors _not_toldo required in prog.eis,
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tions Ihat electrical QC Department blu~eprints are not always of the
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current r vision; that electrical QC management ie "tioht with the craft"
s['\\sdy.+n th.4r h.ina
y 7-+h +4r to oroduction manaoement needs: that some electricz-
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QC i_nspectors are inadequately qualified and have been helped to pass certifica-
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tion test; and that some electrical QC inspectors have " bought off" electrical
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terminations in nonconformance with drawings.
Another allegation was received
stiting-that pipe hanger packages are being divided making final QA reviews
inadequate.
This investigation involved 154 investigator / inspector man-hours
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by two NRC investigators and two NRC inspectors.
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.Results:
Personal interview of the source and numerous interviews of electrical
QC personnel disclosed no instances wherein the QC Supervisor allegedly instructec
electrical QC inspectors to violate procedures or not to conduct required in-
process inspections.
Interviews disclosed that the electrical QC Department
blueprints are only rarely found not to be of the current revision and no
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extended delay or nonconformances relating to blueprints, were identified.
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Numerous interviews of electrical QC inspectors disclosed a unanimous opinion
that they. possess independence in conducting their duties without pressures
from either QC or production management.
In depth investigations of qualifica-
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tions of some electrical QC inspectors identified none who were unqualified
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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 interviews identified no instances wherein electrical
terminations were intentionally " bought off" in nonconformance with drawings.
Investigation disclosed that pipe hanger packages were formerly 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 prohibiting QC inspectors from obtaining NCR numbers in order to insure
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
Architect / Engineer.
REASON FOR INVESTIGATION
On January 23, 1981, Individuals 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.
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SUMMARY OF FACTS
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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 Commission, at which time the following safety-related
concerns were identified:
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1.
A QC Supervisor has repeatedly told electrical QC inspectors to
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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.
2.
A QC Supervisor instructed. electrical QC inspectors not to do
in process inspections, but only to inspect completed work, which
is contrary to procedures.
3.
Field copies of blueprints used by the electrical QC department
for inspections are not always of the current revision.
4.
Electrical QC management is " tight with the craft" as a result of
their being sympathetic to production management.
5.
Some ainctrical QC personnel are inadequately qualified; were
helped to pass certification tests and their experience requirements
were " pencil whipped."
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6.
Electrical tequinations were being made and " bought off" by some
electrical QC personnel,'in nonconformance with drawings.
7.
Construction and inspection records relating to some pipe hangers
are being sepc te 31y maintained resulting in their final QA review
being inadeque .:..
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1.
Persons Contacted
Licensee Employees
J. Hawkins, Project QA, Manager, TUGC0
- R. Tolson, Site QA Manager, TUGC0
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- D.
Chapman, QA Manager, TUGC0
- J. Ainsworth, QE Supervisor, TUGC0
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Other Persons Contacted
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Individuals A thru X
- Denotes those attending exit interview.
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2.
Investigation'of Allegations
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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
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in the trees," which was interpreted to mean don't reject on looks alone.
Investigative Findings
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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
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instances when Individual C explicitly told him or another electrical QC
inspector to violate a specific procedure.
Interview of Electrical QC Inspectors
Between February 25, 1981 and March 12, 1981, Individuals D thru K were
individually interviewed concerning various aspects of their employment
as B&R electrical QC inspectors.
Individual D recalled one instance
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wherein an electrical QC Supervisor, Individual C, stated "I know what
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 beins questioned
concerning inspection of~ cable separations.
Individual [ also maded
that electrical caose seoaration has presenred a long term problem and
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that about three months ago their requirement to accumF6t cable
se g ations, as suitable or otherwise, was deleted from the electr_ica1
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QC inspection form and an alternate avenue of documentino unsuitable
he sMission of "naet'
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hrannrts">when cable separat19.D. were the_ on1.y area of noncomp ian
Individual 0 was unabTe to ide6tTfi any other -occacions when he believed "~-
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that Individual C had instructed or inferred that a CPSES procedure be
violated. When interviewed Individuals E, F, G, H, I and J, each stated
tnat Individual C's comments regarding " flowers in the trees" and " don't
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reject on looks alone" were interpreted to mean the inspectors responsi-
bility is to ensure the quality of the specific task conforms with procedur
and that the individual inspectors should not impose his/her own subjective
criteria, regarding 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 electr'icai yt, insp.ec_t5rs were
' either direct _ly_or_ny__unerence~directetrto violate any procedure or limit
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t,he quality of their respectivelnspection duties.
Interview of Former Electrical QC Inspectors
On March 9, 1981 and March 11, 1981, I'ndividuals 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 respo~nsibility 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 QC Supervisors
On March 12, 1981, Individuals C and N, both electrical QC supervisory
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personnel were individually interviewed.
Individual N stated Individual
C's comments regarding " flowers in the trees" meant insnectinn chnold_ con-
centrate'on the safety related functions or ita=e haina inenartad aad
Idtminsafety-related aspects of the system or ca=naaaa+e Jhich was
not a part_of tTe're_specT.ive inspectors responsibi.li.ty f.n 4 asnactv--
Inidvidual N stated no commests sade5y~Iiidividual C should have been
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interpreted to mean a procedure should be violated. When questioned
concerning 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
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C stated he never knowingly instructed anyone to violate a CPSES procedure. /
Allegation No. 2
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A QC Supervisor instructed an electrical QC inspector not to do in process
inspections, but only to inspect completed work, which is contrary to pro-
cedures.
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Investigative Findings
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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
performing the procedurally required in process inspections.
Individual A
stated that a rumor exists within the electrical QC Department that one QC
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inspector was fired for doing "too many in process inspections" and other
QC inspectors are now using that as an excuse for not doin'g 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 conduct 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 Inspectors
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Between February 25, 1981 and March 12, 1981, Individuals D thru K were
individually interviewed.
Individuals D, E, F, G, H, I and K each stated
they regularly performed in process inspections during the course of their
duties.
Individual J 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 conductinc
termination inspections has been getting to do a lot of in process work. -
Individuals D thru K uniformly stated that they had never been instructed
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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.
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Interviews of Former QC Inspectors
On March 9, 1981 and March 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
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that during 1980 the electrical QC Department had many more terminations
inspectors than now employed, due to the larger quantity of terminations
being done.
Individual L stated some of these inspectors did numerous
in process -inspections during each week day while other inspectors were
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" lazy" and did very few, if any, in process inspections.
Individual L
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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
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" lazy."
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Interview of Electrical Craft Supervisor
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On March 10, 1981, Individual 0, an electrical craft supervisor, was inter-
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viewed.
Individual 0 stated some termination QC inspectors had worked closely
with the electrical termination department and had conducted numerous
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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
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many occasions, make excuses or refuse to conduct in process inspections.
Individual 0 stated he never heard nor had any indication that electrical
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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-
carning their knowledge of in process electrical QC inspections.
Individual P stated most electrical QC personnel are not reluctant to
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conduct in process inspections.
Individual P identified Individual J
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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 QC inspector he knew who avoided or refused
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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
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conduct in process inspections.
Interviews of Electrical OC Supervisors
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On March 12, 1981, Individuals C and N were individually interviewed.
Individual C stated that the electrical QC Department is required by
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procedure to conduct a total of 10 in process inspections each day.
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Individual C stated the purpose of the in process inspection is to
sample the work 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
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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
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N stated they have never told inspectors not to conduct in process
inspections nor have they ever discouraged the inspectors from conducting
in process inspections.
- Allegation No. 3
Field copies of blueprints used by. electrical QC departments for inspections
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are not always of the currenc revision.
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Investigative Findings
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
obtained from the electrical QC Department, for use during inspections, have
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not been of the. current revision.
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
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this problem.
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Interview of Electrical QC Inspectors
Between February 25, 1981 and March 12, 1981, Individuals D thru K were
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individually interviewed.
Individuals E, F, H and J related they had
never identified a blueprint, they were using for inspection purposes,
as being out-of-date.
Individual D stated he had, on several occasions,
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identified blueprints as being out-of-date; however, the problem was
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quickly resolved.
Individuals G, I, L and K indicated they had identified
blueprints as being not of the current revision on several occasions and
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it had created no problem for them during the course of their inspections,
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as the proper . blueprint was readily accessible.
None of these inspectors
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indicated that a' problem with blueprints leads to.a QC inspection being
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improperly done.
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Interview of Electrical QC Supervisors
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On March, 12, 1981, Indivudals C and N were individually interviewed.
Individual C stated that during a short period in 1980 the electrical QC
Department had received revised blueprints approximately one day later
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than the electrical craft department due to hand. delivery.
Individual C
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stated that upon notifying the B&R Document Control Center of this
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problem it was quickly resolved.
Individual C stated he was aware of no
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problem, created for the QC inspectors by out-of-date blueprints, aside
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from the inconvenience of having to obtain a current revision.
Individual
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N stated that on rare occasions the electrical QC Depa'rtment does not
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have the current revision of a particular blueprint. He stated this
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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 problem ever identified.
Allegation No. 4
Electrical QC management is " tight with the craft" as a result of their
being sympathetic to production management.
Investigative Findings
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
of production management and that this may contribute to a compromise of
Quality Control inspections at CPSES.
Individual A related, as an example
of this, a frequently encountered 1980 problem relating to separation
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requirements for safety-related cables going to the .CP.SES_sontrol room..
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_Indisidual A stated OC insnectors had been reauired to orecare two separate
e=h1==
aa which
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reauired separation
i_nspection reports reaardina ca==
had not been met.
Individual A stated that when QC inspections of cables
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 prepared.
One report
would document the inspection acceptability'of the cables and/or terminations
and a separate report would be prepared documenting that the required separa-
tion had not been met.
Individual A stated this was obviously being done to
preclude the 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 agreement between Individual C
and production management.
Individual A was unable to cite any additional
examples of Individual C being sympathetic to production mana;ement needs.
Individual A agreed that, insomuch as the unsatisfactory separation con-
.
-
ditions were documented and must be addressed, no further safety-related
problems are likely to occur.-
4
Interview of Electrical QC Inspectors
'
Between February 25, 1981 and March 12, 1981, Individuals D thru K were
individually interviewed concerning their independence as QC inspectors
t
and the possibility that quality may be compromised due to management
being sympathetic to production needs or requests.
Individual D related
'
that on several occasions he has overheard members of his Department,
'
whose identities he was unable to recall, relate instances wherein
i
Individual C had told them to ease off on some inspections to avoid
'
conflict with the craft.
Individual D stated he had no personal knowledge
of this having occurred.
Individual D stated he felt totally independent
in conducting Quality Control inspections and believed he was supported
by QC management to the fullest extent in his decisions.
Individuals E
thru K also stated they felt totally independent in their Quality Control
evaluations and believed they had the full support of other Supervisors
with regard to decisions they made.
None of these Individuals recalled
i
having ever personally been asked to " ease off on inspections" nor did
!
they believe that electrical QC Supervisors are sympathetic to the needs
'
of production management when quality might be adversely affected.
i
!
,
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.
Interviews of Electrical QC Supervisors
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 enst e that the Quality Control objectives at CPSES are achieved.
l
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
i
investigation a possible noncompliance with CPSES procedures was identified,
'
relating to NCRs, within the electrical QC Department.
Investigative finding
l
'
concerning this matter are contained in this report.)
'
Allegation No. 5-
l
Some electrical QC personnel are inadequately qualified; were helped to
past the Certification Tests and their experience requirements were
<
" pencil whipped."
'
,
Investigative Findings
j
i
On February 24, 1981, Individual A was interviewed.
Individual A stated
that several persons working as QC inspectors in the area of electrical
,
'
termination were not qualified for their positions when they began working
as QC inspectors. These persons were identified as Individuals H, I and
J.
Individual A stated none of them had prior electrical or construction
l
'
.
experience, therefore the experience portion of their applications must
l
have been " pencil whipped." (Falsified to document them as having a
certain degree of experience.) 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
>
4
l
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
l
in the aforementioned evaluations of Individuals H, I and J.
.
!
!
Interviews of Electrical QC Inspectors
!
Between February 25, 1981 and March 12, 1981, Individuals D, E, F, G and K
1
were individually interviewed.
Individual D identified Individuals I
j
and J as being only marginaly qualified for their duties as QC inspectors.
l
Individual D stated that Individuals I and J seemed to make no effo.rt
to improve their ability and due to their having apparently gained the
!
favor of their Supervisors (Individuals C and N) they can usually be
l
1
i
4
!
.
-
-
.
-
, _ _ _ _ _
.
.
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.
.
.
.
11
,
-
.
.
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 QC Inspectors
'
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
,
only marginaly qualified as a QC inspector and was a very poor performer.
Individual L stated that electrical QC Supervisors displayed an obvious
'
..
favoritism towards Individuals H, I and J over other QC inspectors, which
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
are qualified, but. stated some (not identified) are " lazy."
,
l
Interview of B&R Electricians
1
On March 9,1981, Individals.P and Q, 8&R electricians, were individually
interviewed.
Individual P stated t' hat Individual'J was not adequately
j
qualified as a QC inspector.
Individual P related that on occasions
Individual J would ask questions about wcIrk being inspected which would
!
i
indicate a lack of knowledge regarding the field.
Individual-P stated that
j
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
i
Individual J may not be qualified as a QC inspector and related details
regarding occasions when Individual 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 deterrained that each met the required background
4
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.
It was noted that Individual J passed the certification exam for the
inspection of electrical terminations with a score of 84 percentile,
<
subsequent to the disqulification of two incorrectly answered questions.
.
.
l
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 would not
j
have passed this certification exam had these questions not been deleted
!
from the exam.
.
J
.
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12
.
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!"
Interview of B&R Quality Engineers
On March 12, 1981, Individuals 5 and T, B&R electrical Quality Engineers (QE)
i
were interviewed.
Each explained that a combination of on-the-job training
i
and classroom training are required of individuals prior to taking a
particular QA Certification Exam ~.
Individual S stated all certification
.
l
exams are administered by a QE, subsequent to which an oral exam is
!
administered.
Individual S stated that the QE, based on the results of
I
the oral exam, has the right to adjust, upward or downward, the score
I
of the written examination.
Individual S stated the certification
I
can be denied solely on the results of the oral exam.
Individual S stated;
I
however, that a person who displays a obvious 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
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.
J
~ Interviews 'of Individuals H, I and J
]
-
!
On March 11-12, 1981', Individuals H, I and J were each separately interviewed
!
by an NRC inspector (Electrical Specialist). and NRC investigator in an
l
effort to determine their respective qualifications.
The interviews
'
indicated that each possessed an adequate degree of familiarity with the
J
inspection procedures and techniques to perform the termination inspection
1
requirements.
Individuals H, I and J also indicated that they freely
exercise the prerogative of asking their Supervisors for the answers to
i
any questions that they encountered during the performance of inspections,
,
j
both technical and administrative. These interviews determined that QC
l
inspectors H, I and J were each qualified to conduct the QC inspections
i
in the area of electrical cable termination inspections or instructed by
i
site procedures. When specifically queried concerning the possiblity that
i
Individual C had influenced Individual J's employment in the QC Department
and influenced certification, Individual J related having no personal
knowledge to support such allegations and stated n'o personal relationship
existed with Individual C, aside from a professional one.
[
Interview of Electrical QC Supervisors
i
j
On March 12, 1981, Individuals C and N individually were interviewed. When
questioned'concerning the qualifications of Individuals H, I and J, as
j
electrical QC inspectors, Individuals C and N each stated they believed
those individuals to be qualified. Both. stated a belief that the training
program for QC inspectors was sufficient, but each added that more training
'
)
would be desirable.
Individual C stated that as an adjunct to the initial
i
training program, new electrical QC inspectors are encouraged to always'ask
questions of either Supervisors or more experienced Electrical QC inspectors
j
when they had questions concerning an area they were inspecting.
Both
i
!
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13
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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 Individuals 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
favoritism received by Individuals H, I and J, Individual C stated that
i
.
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 t'o their inexperinece, had required more
assistance of the Supervisors during recent months, which may have been
misunderstood, by some, as favoritism 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.
i
Allegation No. 6
-
Electrical terminations were being made and " bought off" by some
electrical QC personnel, in nonconformance with drawings.
'
'
,
Investigative Findinos
l
On February 24, 1981, Individual A was interviewed.
Individual A stated he
believed electrical terminations have been " bought off" (approved by-
l
inspectors) which are in nonconformance with drawings.
Individual A stated
~
this situation is specifically attributable to some electrical QC
inspectors being unqualified for their job, rather than any intentional
wrongdoing.
Individual A provided two examples of nonconforming con-
i
ditions which were approved by electrical QC inspectors (Individuals I and
J).
Individual A was unable to provide any additional information pertinen-
'
to the identification of nonconformances which have been approved by
l'
electrical QC inspectors.
'
Inspection of Alleged Nonconformina Conditions
!
On February 25, 1981, an inspection of the alleged nonconforming conditions
approved by Individual J, was conducted.
The inspection disclosed tha.t no
!
nonconformances existed' in the alleged component, at this time.
On
February 26, 1981, a review of the documentation relating to the allegedly
nonconforming conditions approved by Individual I was conducted.
The
review disclosed the work associated wit'. this inspection required only a
visual inspection after the work was com,,leted.
The documentation for this
,
j
work indicated that Individual I had visually observed and approved the wor
and additionally the work was also independently approved by one other
l
electrical QC inspector at another time.
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I
Interview of Electrical QC Inspectors
.
Between February 25, 1981 and March 12, 1981, Individuals D thru K were
individually interviewed.
Individual D stated he believed that allegations
'
made that electrical QC inspectors have " bought off" inspections would
j
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
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
K related having no personal knowledge of nonconformances being approved
'
by QC inspectors.
Individuals H and J each stated if they had approved
i
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 nonconfoming condition.
)
1
'
Interview of Brown & Root Electricians
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
4
inspections.
Neither Individuals P or Q was aware of any nonconformance
4
l
being intentionally approved.
Interview of Electrical QC Supervisors
l
On March 12, 1981, Individuals C and N were indiv'idually interviewed.
When questioned concerning electrical QC inspections being " bought off",
,
Individual N related that occurrences of nonconforming conditions being
j
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, when much electrical termination work was
1
,
being done and when a number of terminations inspectors were new on the
!
job, the likelihood of nonconforming conditions not being identified during
i
an inspection was much greater than now.
Individual N stated he frequently,
l
during that timeframe, reinspected work done by the less experienced
l
inspectors and, on occassions, did identify mistakes they had overlooked,
Individual N stated that termination inspectors were encouraged to contact
i
!
him when they had questions regarding a particular inspection, in order
to preclude errors being made.
Individual N stated he did not believe
l
any intentional approval of a nonconforming item had ever occurred.
1
Individual C also stated if errors were made during inspections and a
nonconforming condition was approved, it was due to the inexperience
i
of the respective inspector.
Individual C stated that the less experienced
1
I
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
'
l
'
l
,
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.
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. _ .
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.
,*
.,
15
-
,
. . _ . _
to the former training program, new inspectors were instructed to "ask
questions" of their supervisors when they did not understand the area
r
they were inspecting.
Individual C-stated this process made better
<
inspectors and helped ensure that mistakes were not made during
'
inspections.
f
Allegation No.-7
i
~
Construction and inspection records relating to some pipe hangers are being
separately maintained, resulting in their final QA review being inadequate.
'
i
)
Investigative Findings
'
!
{
On February 23, 1981, Individual B was' interviewed.
Individual 8 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.
Individual B stated that a new procedure was.
.
implemented which required each safety class hanger have NDE and
-
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
4
the hanger packages (containing all documents relating to the fabrication
4
!
and inspection of each hanger) in existence on April 1, 1980, were filed
j-
away and a new hanger package'was started for every hanger which was
!
not yet installed and QC approved. -Individual B pointed out that
5
the Documentation Review Group, now reviewing the fabrication and
4
- inspection history of each hanger, is only receiving the hanger packages
i
containing documentation prepared after April 1, 1980.
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-
i
tains the old hanger packages for hangers which were being fabricated
l
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-
ment.
Individual B stated this constitutes a violation of CPSES pro-
cedures, in that all documentation is not being incorporated into a
final review package.
!
Interview of Documentati:n Review Group Supervisor
4
On February 25, 1981, Individual U was interviewed regarding the review of
,
hanger packages.
Individual U stated that since January 1980 numerous
'
procedur'al changes have 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
!
.
i
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,
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. _ . . . .
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'
.
16
.
..
___
,
l
that subsequent to September 1,1980, he learned that ' hanger documentation
'
l
packages were being divided into two separate packages by the Welding
Engineering Department.
fie 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 insta11atio
and inspection of the hangers having two documentation packages, only the
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
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
i
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 hav'e 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
-
i
respective hanger.
Allegation No. 8
Electrical QC Supervisors require that nonconformance report (NCR) drafts
be submitted to them and they are the only individuals within the electrical
4
QC Department authorized to obtain an NCR number for the draft.
l
Investigation Findings
On March 11-12, 1981, Individuals H, I, J, L and M were interviewed individua~
regarding matters associated with this allegation.
During the 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.
Iridividual N recalled that during November 1980,' Individual C had stated an N
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
a Supervisor.
Individual M did not recall any specific information
regarding that NCR.
Interview of Individuals H, I, J and L disclosed
they each were aware of the electrical QC Department policy designating
!
l
!
4
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_ . . _ . . . .
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17
-
.
1
l
<
electrical QC Supervisors as the only persons, in that Department, authorizec
to obtain NCR numbers fer NCR drafts. None of these individuals recalled
1
ever having been denied the right to submit an NCR.
,
i
Interview of 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 stated 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 directior
.
)
_
On March 12, 1981, Individual W, a B&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
4
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 i
'
stated however, that 99% of the NCRs issued from the B&R NCR Coordinators
'
Office, t'o the civil and mechanical QC Departments, are issued to Supervisor
a
i
Intarview of Electrical QC Supervisors
!
On March 12, 1983, individuals C and N were individually interviewed
regarding their department po11cy 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 stated that he had never " turned down a legitimate NCR;
however, he stated that he had questioned the legitimacy of some and has
required that a Field Deficiency Report (FDR) be prepared instead of an
i
NCR on occasion."
Individual N stated this probl,em happens only occasionall
(two or three times per month), and usually. involves an inexperienced
.
.
inspector.
Individual C, when interviewed, stated he was responsible for
j
initiation of the policy requiring electrical QC inspectors to have their
NCRs approvad by a Supervisor because, during the early fall,1980, he
learned some electrical QC inspectors were obtaining NCR numbers for
their NCR drafts and never submitting the NCR.
Individual C stated he
implemented the policy to assure accountability of NCR numbers and to
ensure each NCR submitted, by his department adequately explained and
i
identified the problem found.
Individual C stated he was not awtfe his
)
policy. contradicted TUGC0 (CPSES) Procedure No. CP-QP-16.0 (Revision 3),
dated July 9,1980.
Individual C stated he would rescind his policy and
ensure compliance with the site procedure.
1
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.
- 18
Interview of QA Manager
On March 13, 1981, Individual X was interviewed.
Individual X stated he
was unaware the site NCR procedure was not being properly followed by
the electrical QC Department.
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; statec
"I will make it clear how this procedure is to be interpreted and imple-
mented" to all QC Departments."
.
.
- e
9
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II Investigation Report No'.
50-445/81-04; 50-446/81-04
Licenses:
Texas Utilities Generating Company
location:
Glen Rose, Texas
Facility:
Comanche Peak, Units 1 & 2
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Type of Licensee:
W, PWR, 1150 MWe
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Type of Investigation:
Allegations regarding electrical problems
Dates of Investigation: February 25-27, 1981
-
Dates of Previous Inspection:
February 23-25, 1981
.
f M 464 W nvestigators:
DDDriskill
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SCOPE OF INVESTICATION
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M44 W / W p46666/
Investigator
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Approved
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