ML20197J489
| ML20197J489 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/17/1985 |
| From: | Griffin H, Hayes B, Herr R NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20197J483 | List: |
| References | |
| 4-84-025, 4-84-25, NUDOCS 8605200054 | |
| Download: ML20197J489 (10) | |
Text
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REPORT OF INVESTIGATION
Title:
COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED IMPROPRIETIES IN THE BROWN & ROOT, INC.
DOCUMENT CONTROL CENTER Licensee:
Case Number: 4-84-025 Texas Utilities Generating Company Report Date: MAY 171985 2001 Brian Tower Dallas, Texas 75201 Control Office: OI:RIV Docket No. 050-00445 Status: CLOSED Reported by:- -
Reviewed by:
Y-YM
-H'. ~ Brooks Griffin // -
Richard K. Herr Investigator, 01:RIV Director, 01:RIV Participating Personnel:
Appro by:
Thomas Ippolito NRR a
Del Norman, NRC Inspector, RIV
/
Richard H. Wessman, NRR
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/ s/
//
William H. Beach, Jr., Enforcement
' Beh B. H'ayesyD ' re or Roger A. Fortuna, Deputy Director 01 Office of Inve ti tions Connie Spagnoli, Secretary, OI WARNING e attached ocument/r rt has t been r viewed rsuant o O C.F.
5 2.790(a exemptio nor has y exemp teria been leted.
not d eminate or iscuss i contents utside C.
Tr t as "0FXICIAL 014 ONLY."
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The attached synopsis for 01 Case,4-84-025 has been approved for release by 01 and Region IV has completed-a 10 CFR 2.790(a) review.
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SYNOPSIS In April 1984, the NRC Region IV Office of Investigations initiated an investigation into document control allegations following a request by 4,
the Region IV Regional Administrator. Testimony was taken from two fonner Brown & Root, Inc. (B&R) document control employees at the Comanche Peak Steam Electric Station (CPSES) which contained allegations of suspected wrongdoing related to the improper release of documents, the improper alteration of the computer data base, and the willful circumvention of the established document control procedures.
j Forty-five present and former employees at the CPSES were interviewed j
regarding their knowledge of the allegations. During these interviews, new concerns were raised regarding potential violations of document control procedures or abuses of the document control system which are addressed in this report.
The allegations were divided into 13 categories which are addressed individually and are based on the testimony of employees having know-ledge of the allegations and a familiarity with the document control system at the time the alleged incidents occurred.
Investigator's Note: Not all 45 employees were questioned about all 13 allegations since the total number of allegations were assembled as the interviews progressed. The issues originally alleged were represented as examples of a breakdown in the document control system at the CPSES since the advent of the satellite concept which occurred during mid-1983.
i The following 13 allegations were purported to establish evidence of a willful breakdown in the document control system at the CPSES:
1.
Craft and Quality Control (QC) employees attempted to obtain individual documents or incomplete drawing packages in violation of procedures.
2.
Individual documents or incomplete drawing packages were released in violation of procedures as a result of verbal or written instructions by Document Control Center (DCC) supervisors to the i
DCC personnel.
1 3.
Improper deletions were made from the DCC data base, i
4.
Relevant design changes were removed from drawing packages by DCC clerks because of an incorrect or incomplete data base or because of improper supervisory instructions.
5.
Traveler requests were used by craft and QC employees to circumvent procedures requiring complete drawing packages.
l 6.
Paperflow (document control task forces for individual buildings) and QC groups possessed document control stamps in violation of procedures.
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7.
Satellite 307's manual electrical logs were copied and substituted in place of the DCC manual electrical logs to achieve "matchability" in advance of the July 1983 CYGNA audit.
Investigator's Note: Manual electrical logs have the entries made manually.
8.
Craft employees improperly returned satellite drawing packages to the paperflow groups and vice versa, resulting in lost documentation.
9.
Document control clerks requesting documents throughethe DCC phone bank were not notifying the DCC CRT (computer terminal) groep, which resulted in the documentation not being updated or revised.
- 10. Computer print-outs for the drawing packages in the paperflow groups were not updated on a regular basis or in a timely manner.
- 11. Design changes critical to ongoing inspections and construction listed as "not to be incorporated" (NI) on the drawings were deleted from the open change logs and not included in the drawing packages.
- 12. After the FSE-159 (generic cable tray hanger drawing) drawings were placed in document control, they were not initially logged out, therefore, they were not updated or revised in the paperflow groups or in the field.
- 13. Site engineers introduced uncontrolled documents into the field in Start Work Authorization (SWA) packages.
i Following is a sumary of the results of the investigation into each of 1
the thirteen allegations (each summary is numbered to correspond with the allegation cited above):
1.
The former Satellite Operations Supervisor at the CPSES alleged that craft and QC personnel at the CPSES attempted to circumvent internal document control procedures (DCP-3) and obtained individual copies of documents rather than taking complete packages l
as required. This former supervisor alleged that craft and QC i
i personnel also made unauthorized copies of controlled documents to avoid checking out the packages on a daily basis. A confidential source alleged that craft personnel were taking office copies of control documents to the field for construction activities.
A total of 21 document control clerks and supervisors were j
interviewed regarding these allegations. Seventeen of those interviewed confirmed they had experienced pressure from craft and QC employees to release individual documents, and were aware that many craft employees sought to circumvent the document control procedures. All 21 employees interviewed testified they had not released individual documents in violation of procedure.
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4 The former DCC Supervisor, the Project Control Manager, and a document control clerk testified they had seen unauthorized copies of control documents in the field, but said these copies had been made by craft employees (not further identified) and not document control employees.
2.
The former Satellite Operations Supervisor and the confidential
,i source alleged that the DCC Supervisor had made exceptions to i
procedures and had authorized the release of individual documents i
through verbal and written instructions (memorandums) to satellite j
supervisors and clerks. A satellite clerk further alleged that i
after the former Satellite Operations Supervisor lost her position i
at the CPSES, the former DCC Supervisor verbally authorized the use of " reference only" copies, which were used by craft personnel to circumvent complete drawing package requirements.
A total of 24 document control clerks and supervisors were interviewed regarding these allegations.
Fifteen of the employees interviewed related knowledge of verbal and written authorizations (memorandums) for exceptions to procedure made by the DCC Supervisor. A DCC area supervisor said the use of " reference only" copies was greatly abused by the craft personnel to obtain individual documents. Seven DCC clerks and supervisors confirmed that numerous documents were obtained by craft personnel by requesting " reference only" copies.
Investigator's Note: All of the document control employees i
interviewed who testified that they had seen memorandums from document control supervisory personnel authorizing exceptions to procedures indicated that they did not have copies or know the location of copies of these netaorandums. Some of the i
employees testified that they had destroyed the memorandums within a few days after they had received them.
The former DCC Supervisor said he recalled authorizing the use of
" reference only" copies, but said he did not believe many documents were requested in this manner. This supervisor said he was not aware of craft and QC inspectors using these copies for construction or inspection purposes. This supervisor stated he regularly authorized exceptions to the complete package
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requirements of the document control procedures when reasonable explanations were provided to him by craft personnel.
4 The Project Control Manager stated he was aware the former DCC
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Supervisor had released individual design changes to craft superintendents, but said the former DCC Supervisor had the authority to do so if the superintendents provided him with an adequate explanation.
4 3.
The fonner Satellite Operations Supervisor alleged that design change information was improperly deleted from the computer to expedite the release of drawing packages.
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Twenty-five document control clerks and supervisors, who were interviewed regarding this allegation, testified that the only deletions made from the computer data base were to correct input errors. Three Texas Utilities Generating Company Nuclear Engineering (TNE) design change tracking group (DCTG) employees who were responsible for making additions and deletions to the computer data base testified that deletions were made from the data base to either correct errors or remove old revisions. Two of these DCTG employees expressed a belief that DCC personnel did not rely solely
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on the contents of the computer to determine what was to be contained in the drawing packages and said that they believed the clerks had other means of verifying the contents of the drawing packages. The DCTG clerk responsible for operating the computer testified that when she received telephone calls from DCC personnel on problems with the data base she would research the problem and make the appropriate changes in the data base.
4.
The former Satellite Operations Supervisor alleged that DCC clerks were required to follow the computer print-outs to determine the contents of drawing packages they released even if they knew the print-outs were wrong or incomplete.
The Satellite Operations Supervisor alleged that if the computer print-outs did not list relevant design documentation which was contained in drawing packages, the documentation was removed from the packages and destroyed. This former supervisor alleged that the computer data base was not complete and contained numerous errors which were identified by craft and QC employees. This former supervisor also alleged that during the changeover from manual logs to the computer i
relevant information was not entered into the computer from the manual logs. The confidential source also alleged instances in which design changes were contained in drawing packages but not luted on the computer.
Seventeen document control clerks and supervisors were interviewed regarding this allegation.
Thirteen of these DCC clerks and supervisors confirmed that they were required by their supervisors to remove design changes from packages if they were not listed on the computer, even if it appeared they corresponded with the drawing. A document control supervisor said there were no written procedures or guidelines that required the clerks to notify the DCTG group when errors were found in the computer data base.
The former DCC Supervisor said the clerks were under verbal instructions to notify the DCTG when they discovered computer input errors. This supervisor said he never instructed anyone to discard or destroy design changes contained in packages that were not listed on the computer, and said that to do so would constitute an 2,
offense resulting in termination.
The Project Control Manager stated that it was his understanding that design changes not listed on the computer were to be removed from the drawing packages, but said the clerks were also verbally instructed to call the DCTG for an explanation in these cases.
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5.
The former Satellite Operations Supervisor said a traveler system was initiated that authorized the DCC to release individual documents. This former supervisor alleged that these so-called
" travelers" were not real travelers but merely a piece of paper titled " traveler" that did not contain weld data cards or other information normally associated with travelers. The confidential source characterized these single sheets of paper titled " traveler" as a departure from the commitment to the concept of complete drawing packages. Two document control supervisors and one clerk alleged that craft employees obtained documents by telephoning traveler numbers to the satellites and picking up the documentation without presenting the traveler.
Eighteen present and formt, document control clerks and supervisors were interviewed regarding this allegation, and their testimony confirmed that individual documents were released through traveler requests. One of the supervisors stated that when the craft employees learned they could obtain documents by telephone, the number of documents requested using traveler numbers greatly increased. This same supervisor said thJ later when a supervisory decision was made to require craft to present a hard copy of the traveler to the document control clerks to obtain documentation, the number of requests using travelers decreased dramatically.
The former DCC Supervisor stated that the use of travelers had been in existence on site for years, and said that travelers used in Unit I were primarily related to backfit work. This supervisor said travelers could be requested by craft, Quality Control or engineering employees, but said that documents were not released unless the hard copies of the travelers were presented to the clerks.
The Project Control Manager stated that tr:velers were used in areas where complete drawings and all changes against drawings were not necessary. The manager said he was unaware of telephonic requests for documentation. The manager said that ongoing construction had QC " hold points" to ensure work was being performed properly.
6.
Allegations were made regarding document control stamps that were lost and/or in the possession of unauthorized personnel. A total of 22 site employees were interviewed regarding these concerns.
The former Satellite Operations Supervisor alleged that the former DCC Supervisor had given a quality review group a document control stamp in violation of site procedures for document control. Two supervisors in the quality review group, alleged to have been in possession of the control stamp, confirmed that the former DCC Supervisor had given them a control stamp which they had used to
" red stamp" the " black-stamped" copies that had been improperly released by the DCC. One of the quality review group supervisors said the stamp had been in his possession since that time and had not been used to stamp other drawings.
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'o When questioned about the alleged instance of a QC group b5ing in possession of a document control stamp, the former DCC Supervisor said he had no recollection of the incident. The Project Control Manager said that he heard a rumor about a QC group in possession of a control stamp, and said he investigated the rumor. The Project Control Manager said he had not been able to substantiate the allegation.
The former Satellite Operations Supervisor also alleged that the auxiliary building task force paperflow group was in possession of a document control stamp which constituted a violation of procedure. A satellite clerk alleged she had seen an auxiliary building task force employee in possession of a document control r
stamp.
A satellite clerk who conducted audits in the auxiliary building task force (paper flow group) testified the allegation was untrue.
This clerk said the document control stamp in question had been in her possession during an audit.
The auxiliary building task force employee accused of being in possession of the document control sta'mp denied the allegation. A DCC area Supervisor who had been assigned to determine the validity of the allegation regarding the auxiliary building task force's possession of the control stamp stated she was unable to find any evidence to support the allegt.' ion.
The former DCC Supervisor said that he had interrogated the auxi. ary building task force employee alleged to have been in possession o.
the stamp but found no evidence to support the allegation.
A fonner DCC area supervisor alleged that the former Satellite Operations Supervisor lost a document control stamp in the safeguards building and had explained to the former DCC Supervisor that the stamp was left in a box and discarded by cleaning crews.
Investigator's Note: The former Satellite Operations Supervisor did not mention this incident in allegations related to the improper possession of document control stamps.
The Project Control Manager said he recalled an instance when a paperflow group employee found a document control stamp in the field and returned it to the satellite.
h 7.
The former Satellite Operations Supervisor alleged that prior to the July 1983 CYGNA audit the former DCC Supervisor instructed that satellite 307's manual electrical logs would be copied and substi-tuted for the DCC manual electrical logs to achieve "matchability" i
for the audit. This former supervisor further alleged that the I
original DCC logs were destroyed. This former supervisor also j
alleged that the backup design change cards which accompanied the manual logs were reproduced to match the substituted logs.
Fourteen document control clerks and supervisors were interviewed regarding these allegations. Nine document control clerks and f
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supervisors and the Project Control Manager confirmed that the satellite 307 manual electrical mgs were copied and substituted for the DCC manual electrical logs, and the original manual logs were destroyed. These employees indicated they understood the substitution was done in consideration of initial problems with the computer during the changeover from the manual logs to the computer, rather than in consideration of the CYGNA audit.
Five of the document control supervisors and clerks, including a j
clerk who participated in the reconstruction of the backup design I
change cards, confirmed that the cards had been reconstructed. The former DCC Supervisor confirmed he had decided to copy the j
satellite's logs and substitute them for the DCC logs. This former supervisor said the upcoming CYGNA audit may have been a consideration in his decision to substitute the logs, but said the l
substitution was mainly done in consideration of the computer problems. The former DCC Supervisor said he was unaware of the backup design change cards being reconstructed.
A satellite clerk alleged that the manual electrical logs had not been updated or maintained from the period of time the computer was first made operational until the time the manual logs were put back in use. A former satellite 307 supervisor testified that the manual electrical logs were maintained and updated during the period of time the computer was first put in use. This supervisor said he believed the manual logs were put back in use because problems developed in the initial use of the computer. The satellite 307 supervisor said the logs were accurate and up to date 1
when they were put back in use. The Project Control Manager said the manual electrical logs were revised and maintained during the time the computer was initially put in use.
8.
A satellite supervisor alleged that task force paperflow group clerks removed documents from satellite drawing packages and placed them in travelers in the task force paperflow groups, which resulted in documents missing from the satellite packages.
Seven document control employees were questioned about their j
knowledge regarding this allegation. A satellite supervisor and a j
satellite clerk confirmed they had encountered problems with craft h
and QC employees returning paperflow group documentation to satellites, which left the paperflow groups with missing g
documentation. Four of the seven employees interviewed, including the former DCC Supervisor and the Project Control Manager, i
testified that craft superintendents were required to furnish the i
former DCC Supervisor with tremorandums containing explanations when their employees lost documentation.
The above witnesses said this led to a decrease in the number of missing documents on site.
9.
A document control clerk alleged that when the task force paperflow groups were created there was a period of time when the DCC CRT group was not notified of acuments received through the DCC phone bank, and this resulted in these documents not being updated or revised, s
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Eight document control clerks and supervisors testified re'garding this allegation.
These employees confirmed that the CRT group had not been notified. These employees explained that there were no written procedures requiring that the CRT group be notified.
The former DCC Supervisor and the Project Control Manager said the notification was the responsibility of the former Satellite Operations Supervisor based on verbal instructions she had received from the former DCC Supervisor. The former DCC Supervisor and the Project Control Manager said the notification problem had only 3
existed in the Satellite Operations Supervisor's satellite (306).
l These two supervisors stated that although there was no written 4
procedure requiring the Satellite Operations Supervisor to notify
.l the CRT group, her failure to notify the CRT was part of the reason for her termination, o
- 10. Two former satellite supervisors alleged that until the latter part
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of April 1984 task force drawing packages were not updated in a timely manner and were not complete. The supervisors further alleged that the task force clerks did not compare the computer print-outs with the contents of the package, which could have resulted in construction performed with drawings out of revision and missing design changes against the drawings.
A document control clerk, whose responsibility was to update the computer print-outs in the field, explained that she wrote new design change numbers on the computer print-outs contained in the task force paperflow group drawing packages when new changes were issued.
This clerk said the computer print-out itself was infrequently changed.
The former DCC Supervisor said he believed the computer print-outs were replaced every time.a new design change drawing was issued by the DCC. The Project Control Manager stated that new design change numbers were written on the bottom of the print-outs when changes were added to the packages.
Four document control employees testified new computer print-outs were formerly added to the drawing packages on an infrequent basis, but said they were now
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replaced on a weekly basis.
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- 11. A document control clerk stated that in May 1984 design changes "not to be incorporated" (NI) on drawings were deleted from the open design change logs, which resulted in relevant design changes missing from drawing packages that were critical to ongoing i
construction and QC inspections.
Six employees were interviewed regarding this allegation. Five employees said the removal of these "NI" changes led to immediate confusion and problems with craft employees who needed these 1
changes to conduct their work. The Project Control Manager said 1
the removal of these NI changes had led to NCRs being written on
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missing design changes. This manager said that if an inspector realized he needed a change he could request the additional i
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4 documentation on a traveler. This manager said the craft $nd OC employees were responsible for making sure they had all the documentation they needed for their work.
Investigator's Note: This investigation did not identify specific instances where the removal of the NI changes resulted in deficient work. However, there was concern among some of the employees interviewed that placing this responsibility back on individual employees could result in faulty workmanship.
- 12. The former Satellite Operations Supervisor alleged that at the time i
she lost her job at the CPSES, 12,000-13,000 FSE-159 cable tray hanger drawings were improperly introduced into the document control system. This former supervisor alleged that these cable tray hangers had not been QC inspected, and said these documents were being obtained for backfit inspections through the use of illegitimate documents inappropriately titled " travelers" (supra).
A document control clerk responsible for updating and revising FSE-159 drawings also alleged that initially there was no check-out logs for these cable tray hanger drawings.
The clerk alleged she could not find these drawings in the field to revise and update them.
Ten site employees interviewed said they were aware of the allegations regarding FSE-159 drawings, but said they were unaware of any problems related to their inclusion in the document control system. A site engineer testified that the cable tray hangers depicted by the FSE-159 drawing involved in safety systems had already been QC inspected.
This same engineer said a supervisory decision was made to include these drawings in the document control system so they could be distributed by the satellites. The former DCC Supervisor confirmed there were some initial problems with the " logging out" of the FSE-159 drawings, but said he did not believe this problem lasted very long. The Project Control Manager denied knowledge of this problem.
- 13. A document control clerk alleged she had seen two QC inspectors in possession of unauthorized, uncontrolled component modification cards (CMCs) in the field. Another document control clerk alleged that she had obsersed " black-stamped" xerox copies of design changes in SWA packages.
Eleven site employees were questioned about their knowledge of these allegations. Nine of these employees confirmed they were aware of instances when uncontrolled documents had been released to the field by engineers in SWAs. The former DCC Supervisor stated that when he had discovered such violations of the document control procedures, it was his policy to request that the responsible employee be terminated. The Project Control Manager said he was unaware of this problem, but said it would be an offense which would result in termination of the offending employee.
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