ML20136A882
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
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2001 Bryan Tower
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Dallas, Texas 75201
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Gentlemen:
This refers to the investigation conducted by Messrs. 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
procedures and to not perform 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 nonconforming
teminations; and that pipe hanger packages are being divided at your
facility. The investigation and our findings are discussed in the enclosed
investigation report.
Within the scope of this investigation, we found no instance where you
failed to meet NRC requirements. We note, however, that in our findings
to Allegation No. 8 departmental policy had been established which was
contrary to one of your procedures. Although we found no examples where the
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procedure had been violated, you are requested to take appropriate action
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to assure that departmental policies (written or unwritten) do not violate
approved procedures or other regulatory requirements.
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In accordance with Section 2.790 of the Commission'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 Consiission's
Public Document Room. If this report contains any information 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 information be withheld from public disclosure. Any such application
must include a full statement of the reasons on the basis of which it is
4
claimed that the infomation is proprietary, and should be prepared so that
proprietary infomation identified in the application is contained in a
seu rate part of the document. If we do not hear frem you in this regard
within the specified period, the report will be placed in the Public Docu-
ment Room.
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8601020340 851113
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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 1g g g
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G. L. Madsen, Chief
Reactor Project Branch
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Enclosure:
Investigation Report No. 50-445/81-04
50-446/81-04'
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bec to Repo9 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 COMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Investigation No. 50-445/81-04'
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50-446/81-04-
Docket Nos. 50-445; 50-446
Licensee: Texas Utilities Generating Company
Facility: Comanche Peak, Units 1 and 2
Investigation at: Glen Rose, Somervell, County, Texas
Investigation conducted:
February 25-27 and March 9-13, 1981
Investigators:
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D. D. Driskill, Investigator
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Investigation and Enforcement Staff
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R.'
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
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F rojects 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:
G. L. Madsen, Chief
Date
Reactor Projects Section
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Summary
Investigation on February 25-27 and March 9-13,1981 (Report No. 50-445/81-04;
50-446/81-04)
Area Investigated:
Allegations were made that a Comanche Peak Steam Electric
Station (CPSES). Brown and Root, Inc. (B&R), Quality Control (QC) supervisor
repeatedly told electrical QC inspectors to violate inspection procedures;
that a QC supervisor told electrical QC inspectors not to do required in process
inspections; that electrical QC Department blueprints are not always of the
current revision; that electrical QC management is " tight with the craft"
due to their being sympathetic to production management needs; that some electrical
QC inspectors are inadequately qualified and have been helped to pass certifica-
tion test; and that some 61ectrical QC inspectors have " bought off" electrical
terminations in nonconforman e with drawings. Another allegation was received
stating that pipe hanger packages are being divided making final QA reviews
inadequate. This investigation involved 154 investigator / inspector man-hours
by two NRC investigators and two NRC inspectors.
Results:
Personal interview of the source and numerous interviews of electrical
QC pePionnel disclosed no instances wherein the QC Supervisor allegedly instructed
electrical QC inspectors to violate procedures or not to conduct required in-
prcceo, inspections.
Interviews disclosed that the electrical QC Department
blueprints are only rarely found not to be of the current revision and no
extended delay or nonconformances relating to blueprints,'were identified.
Numerous interviews of electrical QC inspectors disclosed a unanimous opinion
that they possess independence in conducting their duties without pressu'res
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from either QC or production management.
In depth investigations of qualifica-
tions of some electrical QC inspectors identified none who were unqualified
for their position; however, examination of the certification tests for one
electrical QC inspector disclosed that the electrical Quality Engineer con-
ducting the examination had deleted several incorrectly answered questions
from the test, which resulted in a passing grade for the inspector vice a
failing grade.
Numerous 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
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filed separate-ly; however, the packages heve recently been combined eliminating
the admitted inconvenience factor in thei- final QA review.
During this
investigation it was . identified and confirmed that a member of QC management
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was prohibiting QC inspectors from obtaining NCR numbers in order to insure
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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
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Somervell County, Texas near the town of Glen Rose, Texas.
Texas Utilities
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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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St# MARY OF FACTS
On January 23, 1981, Individuals A and B were interviewed by Mr. R. E. Hall,
Chief, Systems and Technical Section, Engineering Inspection Branch, Region IV,
Nuclear Regulatory Commission, at which time the following safety-related
concerns were identified:
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1.
A QC Supervisor has repeatedly told electrical QC inspectcrs to
violate inspection procedures and once stated " don't worry about
the flowers in the trees," which was interpreted to mean don't
reject on looks alone.
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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.
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3.
Field copies of blueprints used by the electrical QC department
for inspections are not always of the current revision.
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4.
Electrical QC management is " tight with the craft" as a result of
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their being sympathetic to production management.
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5.
Some electrical QC personnel are inadequately qualified; were
helped to pass certification tests and their experience requirements
were " pencil whipped."
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6.
Electrical terminations were being made and " bought off" by some
electrical QC personnel, in nonconformance with drawings.
7.
Construction and inspection records relating to some pipe ha'ngers
are being separately maintained resulting in their final QA review
being inadequate.
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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
Other Persons Contacted
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Individuals A thru X
- Denotes those attending exit interview.
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2.
Investigation of Allegations
Allegations No.1
A QC Supervisor has repeatedly told electrical.QC inspectors to violate
inspection procedures and once stated " don't worry about the flowers
in the trees," which was interpreted to mean don't reject on looks alone.
Investigative Findings
On February 24, 1981, Individual A was interviewed.
Individual A stated
it was his opinion that an electrical QC Supervisor, Individual C, en-
courages electrical QC inspectors to overlook certain safety-related
aspects of their inspections.
Individual A recalled one occasion when
Individual C made statements to the effect of " don't reject on looks alone"
and " don't worry aoout 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. Indivi'!;.41 A was unable to provide any specific
instances when Individual C explicitly told him or another electrical QC
inspector to violate a specific procedure.
Interview of Electrical QC Inspectors
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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
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 being questioned
concerning inspection of cable separations.
Individual D also adde.d
that electrical cable separation has presented a long term problem and
that about three months ago their requirement to document cable
separations, as suitable or otherwise, was deleted from the electrical
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QC inspection form and an alternate avenue of documenting unsuitable cable
separations was initiated in order to avoid the submission of " unsatisfactory
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inspection reports" when cable separation were the only area of noncompliance.
Individual D was unable to identify any other occasions when he believed
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
that Individual C's comments regarding " flowers in the trees" and " don't
reject on looks alone" were interpreted to mean the inspectors responsi-
bility is to ensure the quality of the specific task conforms.with procedures
and that the individual inspectors should not impose his/her own subjective
criteria, regarding appearance, on. task they inspect.
Individual K
stated he had not given consideration to the specific comments, made by
Individual C, and did not know what they meant. None of the foregoing
individuals supported a contention that the electrical QC inspectors were
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either directly or by inference directed to violate any procedure or limit
the quality of their respective inspection duties.
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Interview of Former Electrical QC Inspectors
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On March 9, 1981 and March 11, 1981, Individuals L and M, respectively,
were individually interviewed.
Both Indiviudals L and M stated that they
interpreted Individual C's comment regarding " flowers in the , trees" to
mean that their inspection 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 Electrics 1 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 inspection should con-
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centrate on the safety-related functions of items being inspected and
not nonsafety-related aspects of the system or components which was
not a part of the respective inspectors responsibility to inspect.
Individual N stated no comments made by Individual C should have been
interpreted to mean a procedure should be violated. When questioned
.concerning his alleged past statements " don't reject on looks alone"
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and " don't worry about the flowers in the trees," Individual C
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corrected the latter to " don't worry about the flowers and the trees."
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He stated these comments were directed to some electrical QC inspectors
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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
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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.
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Individual C also stated he frequently made comments to inspectrs
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such as "you're not designing this place" when their criticism of an item
took them outside the scope of their inspection responsibility.
Individual
C stated he never knowingly instructed anyone to violate a CPSES procedure. /
Allegation No. 2
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.
Investigative Fino;ncs
On February 24, 1981, Individual A was interviewed and stated it was his
opinion that Indiv.idual C discouraged electrical QC inspectors from
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performing the procedurally required in process inspections.
Individual A
stated that a rumor exists within the electrical QC Department that one QC
inspector was fired for doing "too many in process inspections" and other
QC inspectors are now using that as an excuse for not doing in process
inspections.
Individual A could provide no information relating to specific
instances wherein the Supervisors told inspectors not to do in process
inspections.
Individual A further stated that Individual J was known to
rarely 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 conducting
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
by Supervisors, not to conduct in process inspections nor had Supervisors
ever discouraged their conducting in process inspections.
Individual G
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reltted that his understanding of CPSES procedures required that the
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electrical QC Department conduct a total of 10 in process inspections per
day; however, there was no requirement for a specific inspector to conduct
any required number of in process inspections.
Interviews of Former 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
that during 1980 the electrical QC Department had many more terminations
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inspectors than now employed, due to the larger quantity of terminations
being done.
Individual L stated some of these inspectors did numerous
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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,
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as well as with in process inspections conducted, created some resentment
towards several of the less motivated inspectors.
Individual M also
related that some termination inspectors, whom he did not identify, were
" lazy."
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Interview of Electrical Craft Supervisor
On March 10, 1981, Individual 0, an electrical craft supervisor, was inter-
viewed.
Individual 0 stated some termination QC inspectors had worked closely
with the electrical termination department and had conducted numerous
in process inspections of work performed by his personnel. He stated other
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QC inspectors were not particularly responsive to the needs of his personnel
and that he had heard criticism regarding some QC inspectors who would, on
many occasions, make excuses or refuse to conduct in process inspections.
Individual 0 stated he never heard nor had any indication that electrical
QC Supervisors had instructed their personnel not to conduct in process
inspections.
Interviews of Brown and Root (B&R) Electricians
On March 9, 1981, Individuals P and Q were individually _ interviewed con-
cerning their knowledge of in process electrical QC inspection::
Individual P stated most electrical QC personnel are not reluctant to
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
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.
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Interviews of Electrical QC Supervisors
On March 12, 1981, Individuals C and N were individually interviewed.
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Individual C stated that the electrical QC Department is required by
procedure to conduct a total of 10 in process inspections each day.
Individual C stated 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
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the past year the electrical QC Department has far' exceeded the required
number of in process inspections daily.
Individual N also stated the
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number of in process inspections conducted each day is more than adequate
to determine that work is being done properly.
Both Individuals C and
N stated they have never told inspectors not to conduct in process
inspections nor have they ever discouraged the inspectors from conducting
in process inspections.
- Allegation No. 3
Field copies of blueprints used by electrical QC departments for inspections
are not always of the current revision.
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. Investigative Findinos
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
resulted in an inspection being done improperly.
Individual A was unable
to identify any specific date or blueprint associated with this problem nor
was Individual A able to identify any other inspectors who were aware of
this problem.
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Interview of Electrical QC Inspectors
Between February 25, 1981 and March 12, 1981, Individuals D thru K were
individually interviewed.
Individuals E, F, H and J related they had
never identified a. blueprint, they were using for inspection purposes,
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as being out-of-date.
Individual D stated he had, on several occasions,
identified blueprints as being out-of-date; however, the problem was
quickly resolved.
Individuals G, I,~L and K indicated they.had identified
blueprints as being not of the current revision on several occasions and
it had created no problem for them during the course of their inspections,
as the proper blueprint was readily accessible. None of these inspectors
indicated that a' problem with blueprints leads to a QC inspection being
improperly done.
Interview of Electrical QC Supervisors
On March, 12, 1981, Indivudals C and N were individually interviewed.
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Individual C stated that during a short period in 1980 the electrical QC
Department had received revised blueprints approximately one day later
than the electrical craft department due to hand delivery.
Individual C
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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
problem, created for the QC inspectors by out-of-date blueprints, aside
from the inconvenience of having to obtain a current revision.
Individual
N stated that on rare occasions the electrical QC Department does not
have the current revision of a particular blueprint. He stated this
problem is always resolved quickly and to his knowledge has never created
an inspection problem.
Individual N additionally stated that an audit of
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the electrical QC Department blueprints is conducted every three months
and rarely is any problem ever identified.
Allegation No. 4
Electrical QC management is " tight witn 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 procuction 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
requirements for safety-related cables going.to the CPSES control room.
"ndividual A stated OC insnactors had been recuired to creoare two separate
inspection reports reaardina <ama r=h1==
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which +ha ceauired separation
had not been met.
Individual A stated that when QC inspections of cables
were conducted and all aspects were found to be acceptable, with thc
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 management needs.
Individual A agreed that, insomuch as the unsatisfactory separation con-
ditions were documented and must be addressed, no further safety-related
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problems are likely to occur.
Interview of Electrical OC Inspectors
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Between February 25, 1981 and March 12, 1981, Individuals D thru K were
individually interviewed concerning their independence as QC inspectors
and the possibility that quality may be compromised due to management
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being sympathetic to production needs or requests.
Individual D related
that on several occasions he has overheard esrabers of his Department,
whose identities he was unable to recall,- relate instances wherein
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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
having ever persor, ally been asked to " ease off on inspections" nor did
they believe that electrical QC Supervisors are sympathetic to the needs
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of production management when quality might be adversely affected.
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Interviews of Electrical QC Supervisors
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On March 12, 1981, Individuals C and N were individually interviewed.
Individual C stated his Supervisors allow him the independence and latitude
to manage his Department as it should be.
Individual C stated he maintained
a good relationship with Craft Supervisors however, his primary goal
is to ensure that the Quality Control objectives at CPSES are achieved.
Both Individuals C and N stated they were totally independent from craft
pressures and that they had never been pressured by their own Supervisors
or production management to compromise Quality Control standards.
(Investigators Note: While conducting the foregoing facets of this
investigation a possible noncompliance with CPSES procedures was identified,
relating to NCRs, within the electrical QC Department.
Investigative findings
_
concerning this matter are contained in this report.)
Allegation No. 5
Some electrical QC personnel are inadequately qualified; were helped to
past the Certification Tests and their experience requirements were
" pencil whipped."
l
,
Investicative Findinos
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
experience, therefore the experience portion of their applications must
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
'
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
.
in the aforementioned evaluations of Individuals H, I and J.
Interviews of Electrical OC Inspectors
Between February 25, 1981 and March 12, 1981, Individuals D, E, F, G and K
were individually interviewed.
Individual D identified Individuals I
and J as being only marginaly qualified for their duties as QC inspectors.
Individual D stated that Individuals I and J seemed to make no effort
to improve their ability and due to their having apparently gained the
'
favor of their Supervisors (Individuals C and N) they can usually be
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found sitting in the office talking.
Individuals E and F stated they felt
all persons working as electrical QC inspectors are qualified for their jobs.
Individual G stated Individual H was qualified and works hard.
Indi.vidual G
related having never worked with Individuals I and J, but stated some
inspectors, whom he refused to identify, are " lazy."
Review of Fomer 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
_
1avoritism 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."
Interview of B&R Electricians
On March 9, 1981, Individals P and Q, B&R electricians, were individually
interviewed.
Individual P stated that Individual J was not adequately
qualified as a QC inspector.
Individual P related that on occasions
Individual J would ask questions about work being inspected which would
indicate a lack of knowledge regarding the field.
Individual P stated that
Individuals H and I also do not appear adequately knowledgeable regarding
electrical QC work.
Individual P also identified Individual R as
probably not being qualified and perfoming poorly.
Individual Q stated
Individual J may not be qualified as a QC inspector and related detafis
-
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 determined that each met the required background
qualifications and satisfactorily completed the required written and oral
examinations and the required on-the-job training necessary for certi-
fication as electrical QC inspectors.
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 disqualification of two incorrectly answered questions.
Examination of other electrical terminations certification exams taken
by other persons during a similar time frame disclosed the same questions
4
had not been disqualified.
It was determined that Individual J would not
have passed this certification exam had these questions not been deleted
from the exam.
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Interview of B&R Quality Engineers
On March 12, 1981, Individuals 5 and T, B&R electrical Quality Engineers (QE)
were interviewed.
Each explained that a combination of on-the-job training
and classroom training are required of individuals prior to taking a
particular QA Certification Exam.
Individual 5 stated all certification
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
the oral exam, has the right to adjust, upward or downward, the score
of the written examination.
Individual S stated the certification
can be denied solely on the results of the oral exam.
Individual S stated;
,
however, that a person who displays a obvious understanding of the material
r
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.
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
effort to determine their respective qualifications. The interviews
indicated that each possessed an adequate degree of familiarity with the
inspection procedures and techniques to perform the termination inspection
requirements.
Individuals H, I and J also indicated that they freely
exercise the prerogative of asking their Supervisors for the answers to
ahy questions that they encountered during the performance of inspections,
both technical and administrative. These interviews determined that QC
inspectors H, I and J were each qualified to conduct the QC inspections
in the area of electrical cable termination inspections or instructed by
site procedures. When specifically queried concerning the possiblity that
Individual C had influenced Individual J's employment in the QC Department
'
and influenced certification, Individual J related having no personal
knowledge to suppart such allegations and stated n'o personal relationship
existed with Individual C, aside from a professional one.
i
Interview of Electrical QC Supervisors
.
On March 12, 1981, Individuals C and N individually were interviewed. When
!
questioned concerning the qualifications of Individuals H, I and J, as
!
electrical QC inspectors, Individuals C and N each stated they believed
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
training program, new electrical QC inspectors are encouraged to always ask
'
questions of either Supervisors or more experienced Electrical QC inspectors
when they 5ad questions concerning an area they were inspecting.
Both
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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 9 stated they believed the
training and experience haa mutually been responsible for the better
qualifications of those persons. When questioned concerning the alleget
favoritism received by Individuals H, I and J Individual C stated'that
the attention received by these individuals during their training was
apparently misunderstood as being favoritism.
Individual C stated that
Individuals H, I and J, due t'o their inexperinece, had required more
assistance of the Supervisors during recent months, which may nave 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, Indiviaual 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.
Allegation No.-6
Electrical terminations were being made and " bought off" by some
electrical QC personnel, in nonconformance with drawings.
.
Investigative Findings
.
On February 24, 1981, Individual A was interviewed.
Individual A stated he
believed electrical terminations have been " bought off" (approved by
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-
ditions which were approved by electrical QC ir.spectors (Individuals I and
J).
Individual A was unable to provide any additional information pertinent
to the identification of nonconformances which have been approved by
electrical QC inspectors.
Inspection of Alleged Nonconforming Conditions
On February 25, 1981, an inspection of the alleged nonconforming conditions,
approved by Individual J, was conducted.
The inspection disclosed that 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 with this inspection required only a
visual inspection after the work was completed. The documentation for this
work indicated that Individual I had visually observed and approved the work
and additionally the work was also independantly approved by one other
electrical QC inspector at another time.
.
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Interview of Electrical QC Inspectors
Between February 25, 1981 and March 12, 1981, Individuals 0 thru K were
individually interviewed.
Individual D stated he believed that allegations
'
made that electrical QC inspectors have " bought off" inspections would
probably more aptly relate to the qualifications of an individual inspector
and his/her ability to identify a particular nonconformance.
Individual D
stated he has no knowledge of a nonconformance being knowingly approved by a
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 eerk 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
a nonconforming condition in the past, it was done unintentionally.
-
Individuals H and J stated that such an occurrence would be the result of
their not understanding all aspects of the work they were inspecting.
None
of the aforementioned inspectors recalled having ever been asked to
approve a nonconforming condition.
Interview of Brown & Root Electricians
i
On March 9,1981, Individuals P and Q were individually interviewed regarding
electrical QC inspections being " bought off" in an nonconforming condition
l
by electrical QC inspectors. Both Individuals P and Q comments regarding
inspections being " bought off" related directly to the qualifications of
specific inspectors-and the diligence with which they conducted their
inspections. ~ Neither Individuals P or Q was aware of any nonconformance
being intentionally approved.
Interview of Electrical QC Supervisors
On March 12, 1981, Individuals C and N were individually interviewed.
When questioned concerning electrical QC inspections being " bought off",
Individual N related that occurrences of nonconforming conditions being
approved by an electrical QC inspector would probably be the result of the
respective inspector's inexperience.
Individual N stated that during
'
the summer and fall of 1980, when much electrical termination work was
being done and when a number of terminations inspectors were new on the
i
job, the likelihood of nonconforming conditions not being identified during
an inspection was much greater than now.
Individual N stated he frequently,
i
during that timeframe, reinspected work done-by the less experienced
inspectors and, on occassions, did identify mistakes they had overlooked.
Individual N stated that termination inspectors were encouraged to contact
him when they had questions regarding a particular inspection, in order
to preclude errors being made.
Individual N stated he did not believe
any intentional approval of a ' nonconforming item had ever occurred.
Individual C also stated if errors were made during inspections and a
j
nonconforming condition was approved, it was due-to the inexperience
of the respective inspector.
Individual C stated that the less experienced
'
inspectors were assigned less complex inspection task when they began
in order for them to gradually acquaint themselves with the inspection
process and avoid errors.
Furthermore, he . stated that, as an adjunct
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to the former training program, new inspectors were instructed to "ask
questions" of their supervisors when they did not uncerstand the area
they were inspecting.
Individual C stated this process made better
inspectors and helped ensure that mistakes were not made during
inspections.
Allegation No. 7
,
Construction and inspection records relating to some pipe hangers are being
separately maintained, resulting in their final QA review being inadequate.
Investigative Findings
'
On February 23, 1981, Individual B was interviewed.
Individual B stated
that prior to April 1,1980, procedures for the construction, installation
and inspection of every pipe hanger was very rigorous and that each
step in these processes was documented.
Individual B. stated that on
April 1,1980, the procedures for most of this inspection and documenta-
tion were eliminated.
Individual B stated that a new procedure was
implemented which required each safety class hanger have NDE and
mechanical irspections 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
i
initiation of the new inspection procedure.
Individual B stated that
the hanger packages (containing all documents relating to the fabrication
and inspection of each hanger) in existence on April 1,1980, were filed
away and a new hanger package was started for" every hanger which was
not yet installed and QC approved.
Individual B pointed out that
the Documentation Review Group, now reviewing the fabrication and
inspection history of each hanger, is only receiving the hanger packages
containing documentation prepared after April 1, 1980.
Individual B
stated that this prevents a complete review being accomplished
on hangers which were in the faorication process on April 1, 1980.
Individual B stated the Welding Engineering Department currently main-
tains the old hanger packages for hangers which were being fabricated
on April 1,1980, and they refused to give the old packages to the
,
.
Documentation Review Group without a written request from the QA Depart-
ment.
Individual B stateo this constitutes a violation of CPSES pro-
cedures, in that all documentation is not being incorporated into a
'
final review package.
,
'
Interview of Documentation Review Group Supervisor
On February 25, 1981, Individual U was interviewed regarding the review of
hanger packages.
Individual U stated that since January 1980 numerous-
procedural 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
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that subsequent to September 1, 1980, he learned that hanger documentation
packages were being divided into two separate packages by the Welding
Engineering Department. He stated this division involved separation of
old documentation (prepared prior to September 1,1980), into a package that
would be maintained by the Welding Engineering Department and another package
of documents prepared in accordance with the new procedural change (subsequent
to September 1, 1980).
Individual U stated that subsequent to the insta11atior
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
stated that during the past week, according to information he had received,
the Welding Engineering Department had sent several boxes of old hanger
- packages to the vault room for storage with the new hanger packages.
Individual U stated this would ensure availabilty of all documentation
relating to hanger packages. Individual U stated that the Welding
Engineering Department had never refused to send a package for the reviews
his group was conducting and no CPSES procedures or codes have been violated.
Lastly, he stated that had he ever been refused a hanger package, to complete
his review, he would have refused to determine the acceptabilty of the
respective hanger.
p
Electrical QC Supervisors require that nonconformance report (NCR) drafts
be submitted to them and they are the only individuals within the electrical
QC Department authorized.to obtain an NCR number for the draft.
Investigation Findings
On March 11-12, 1981, Individuals H, I, J L and M were interviewed individual
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.
Individual N recalled that during November 1980, Individual C had stated an NC
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 awhre of the electrical QC Department policy designating
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17
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electrical QC Supervisors as the only persons, in that Department, authorized
to obtain NCR numbers for NCR drafts.
None of these individuals recalled
ever having been denied the right to submit an NCR.
Interview of NCR Coordinators
~
,
On March 11, 1981, Individual V, a TUGC0 NCR Coordinator was interviewed
i
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 direction.
'
_
On March 12, 1981, Individual W, a B&R NCR Coord'inator was interviewed.
Individual W stated that B&R NCR Coordinators office processes only
civil and mechanical QC inspection department NCRs.
Individual W
related having no association with the electrical QC Department or their
NCRs.
Individual W stated that no-agreements exist between the B&R
NCR Coordinators office and civil or mechanical QC Supervisors.
Individual W
stated however, that 99% of the NCRs issued from the B&R NCR Coordinators
Office, to the civil and mechanical QC Departments, are issued to Supervisors.
j
Interview of Electrical QC Supervisors
On March 12, 1981,. Individuals C and N were individually interviewed
regarding their department policy relating to NCRs.
Individual N stated
j
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;
1
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
NCR on occasion." Individual N stated this problem happens only occasionally
(two or three times per month), and usually involves an inexperienced
~
!
inspector.
Individual C, when interviewed, stated he was responsible for
initiation of the policy requiring electrical QC inspectors to have their
'
i
NCRs approved 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
i
implemented the policy to assure accountability of NCR numbers and to
j
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ensure each NCR submitted, by his department adequately explained and
,
'
identified the problem found.
Individual C' stated he was not aware his
l
policy contradicted TUGC0 (CPSES) Procedure No. CP-QP-16.0 (Revision 3),
j
dated July 9,1980.
Individual C stated he would rescind his policy and
ensure compliance with the site procedure.
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Interview of QA Manager
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In'ividual X stated he
On March 13, 1981, Individual X was interviewed.
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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; stated
"I will make it clear how this procedure is to be interpreted and imple-
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mented" to all QC Departments."
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WHENEVER ENTRIES ARE
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layraAiGATION pun
II Investigation Report No.
50-445/81-04; 50-446/81-04
.
Licensee:
Texas Utilities Generating Company
Location:
Glen Rose, Texas-
Facility:
Comanche Peak, Units 1 & 2
Type of Licensee:
W, PWR, 1150 MWe
_
Type of Investigation:
Allegations regarding electrical problems
Dates of Investigation: February 25-27, 1981
-
Dates of Previous Inspection:
February 23-25, 1981
f4441A) W nvestigators:
DDDriskill
I
.
SCOPE OF INVESTIGATION
099014B - investigate allegations regarding electrical problems
.
M4diff/t.d446666/
investigator
p e.
Approved
Dat
'
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.
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