ML20198D529

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Partially Withheld Assessment of Allegation AQ-70 to Category Qa/Qc 6, QC Insp Re Craft Personnel Making Unauthorized Design Changes by Writing Travelers Which Allowed Use of Incompleted Design Package in Field
ML20198D529
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Curry T, Livermore H
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230317
Download: ML20198D529 (5)
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Text

1. Allegation Category: QA/QC 6, QC Inspection

2. Allegation Number: AQ-70
3. Characterization: It is alleged that craf t personnel made unauthorizeql design changes by wri+1ng " travelers" which allowed them to use an incom-plete design package in the field. Specific travelers were not identified.
4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) evaluated Brown & Root (B&R) procedure CP-CPM 6.3, " Preparation, Approval and Control of Operation Travelers," and found that it complied with the requirements of 10 CFR Part 50, Appendix B, Criterion V. Operation travelers may be initiated by the appropriate construction superintendent or engineer, and require QA/QC review and approval. Travelers are used at-Comanche Peak Steam Electric Station (CPSES) to control construction activities affecting quality. The operation traveler is used to identify the applicable part, component, system, design documents, operation description, sequence of operations, inspection and test requirements, and the required QC/ANI (auth-orized nuclear inspector) hold points. The traveler also provides for required approval and craft personnel sign-off that work was completed and QC indication of inspection and test status. The CP-CPM-6.3 procedure has been implemented at CPSES.

The TRT also reviewed B&R procedure DCP-3, "CPSES Document Control Program,"

and verified that release of documents for use with travelers was autho-rized by revision 14, dated August 18, 1982. Documents releastd for use with travelers must bear the control stamp "This document shali be used only in conjunction with operation traveler # .

This requirement is consistent with CP-CPM 6.3, which requires use of this same control stamp on documents released for traveler use.

The TRT interviewed personnel in the paper flow group (PFG) and QA/QC and craft personnel supervisors regarding use of the required contre 1 stamps on design documents. All personnel indicated that the required control stamps were placed on design documents and that only contro11N drawings were used in traveler packages. Since the alleger did not .dentify spe-cific travelers, the TRT selected 12 traveler packages fom the PFG (for work in progress) that were reviewed for required appros.als, completeness, and application of the required control stamps on design documents. All

packages reviewed had the required approval, were complete, and contained the required control stamps.
5. Conclusion and Staff Positions: The TRT concludes that the allegation

-that craft personnel were making unauthorized design changes by writing travelers could not be substantiated based on the review of documents, procedures, and records and on personnel interviews. Travelers were used for their intended purpose, i.e., to describe work to be done and to pro-vide a means of documenting completed work and the status of inspections and tests. The TRT could find no instances of a traveler being initiated by craft personnel.

A copy of the results of this assessment was transmitted by letter to the alleger.

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  1. 505230317-860512 3 0-207 I FOIA a-,

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7. Attachments: None.

Reference Documents:

1.

Construction operation travelers 8904/7898, 8904/5634A, 8904/4366, 8904/3588, 8904/6606A, 8904/6626A, 8904/8410, 8904/7772, 8904/0151, 8904/3398, 8904/0447, and 8904/6334.

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8. This statement prepared by: _ #~ & f,fM
7. Curry, TRT /

Technical Reviewer Reviewed by:

dl/4c/2 f-Herbert Livermore, d-Date 7- h' Group Leader Approved by:

Vincent Noonan, Date Project Director 0-208

with an area newspaper: the supervisor's comments had resulted in an article in the area newspaper (reference 7), which also served to publicize

, the phrase. Interviews conducted by the NRC resident inspector indicated that the T-shirts were worn with the general attitude of a joke (refer-l ence 12), which was also indicated in interviews conducted by the TRT. QA management restricted the eight inspectors to a room after they reported to work and searched their work stations without obtaining their consent.

The memo cited in Reference 23 also refers to QC inspectors performing

" destructive testing." The TRT considers " destructing testing" to be excessive pulling on wires or conduit to see if they come loose. Testi-many filed by TUEC identified two items -- a loose wire and a loose flexi-ble conduit -- that were thought possibly to have been destructively tested, but that was never confirmed by TUEC (Reference 18). Also, testimony filed by Region IV personnel (Reference 21) indicated that a significant inspec-tion effort conducted independently by Region IV inspectors did not reveal any items that could have been considered as destructively tested. Inspec-tion by the TRT also revealed no evidence of destructive testing.

TUEC conducted their own investigation of this incident, and published the results in report TUQ-2074.1, dated March 15, 1984, which concludes in part:

The inv,estigation clearly indicates that the T-shirts were worn in a spirit of levity, with no intent to convey messages or concerns. A greater number of inspectors had worn the shirts previously without incident. The investigation clearly indi-cates there was an unwarranted over-reaction on the part of management towards the wearing of the T-shirts on Thursday March 8, 1984. This over-reaction in itself gave this inci-dent inordinate and inappropriate attention.

The TRT concurs with this assessment. As noted above, approximately 20 inspectors had worn the same T-shirt without incident on the preceeding Monday.

5. Conclusions and Staff positions: The TRT found no evidence that an organized disruption was intended by the eight electrical QC inspectors; therefore, the allegation of organized' disruption was not substantiated.

The TRT also found no evidence to substantiate the allegation of destruc-tive testing. It appears to the TRT that the T-shirts were worn primarily

. as a result of discussions with craft personnel that characterized the work of QC inspectors as " nit picking," plus previous publicity given to the phrase by an area newspaper. The incident resulted in unwarranted over reaction by management.

This issue was raised by TUEC management, who will receive a report of the results. Therefore, a closecut interview was not conducted.

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7. Attachments: None.

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i Reference Documents:

1. TUEC final report on issues resulting from interviews with the electrical inspectors, TUQ-2074.1, dated March 15, 1984.
2. Inspection reports:

El-004118 ET-1-004149

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El-004452 ET-1-004173 ET-1-0019966 ET-1-004175 '

E-10015178 ET-1-0044152 ET-1-0006098 ET-1-006134 El-004118 E-10015178 El-004121 EC-10026963 El-004124 EC-10026888 El-004115 EC-1-0026893 El-004440 EC-10026895 El-10002044 EC-10004782 El-0004452 EC-10004750 El-0004454 EC-10004717 ET-10003939 EC-10006133 ET-1-003941 ET-10006098 EC-10019075 EC-10019076 ET-10004175 EC-10019077 -ET-10004173 EC-10019446 ET-10003986 EC-10019409 ET-10003984 EC-10009622 ET-10002979 EC-10009603 EC-10021776 EC-10011898 EC-10021779 EC-10009037 EC-10021781 EC-10004691 ET-10021777 ET-10021782 ET-10002692 ET-10004149 EC-10004040 ET-10004152 EC-10004077 EC-10009624 EC-10004084 EC-10014328 ET-10004032 ET-10004041 -

3. TUEC Management 3/84 Allegation.
4. Deposition-of Mark Welch; July 16, 1984; (Tr. 53,000-264).
5. Deposition of Kenneth Whitehead; July 17, 1984; (Tr. 55,000-164, specifically TR 55,127).
6. Deposition of Jack Pitts; July 31, 1984; (Tr. 73,500-553).
7. Deposition of Ronald Tolson; July 10, 1984; (Tr. 40,546-562).
8. Deposition of B. R. Clements; July 10, 1984; (Tr. 40,096-105).
9. Deposition of Thomas Brandt; July 11, 1984; (Tr. 45,128-149).
10. Deposition of Boyce Grier; July 11, 1984; (Tr. 45,591-599).
11. Deposition of Gordon Purdy; July 10, 1984; (TR. 41,198-199).
12. Deposition of James Cummins; July 17, 1984; (Tr. 54,003-075, specifi-cally TR. 54,072).
13. Testimony of Michael Spence, Tr. 14,924-930 (9/10/84).
14. Testimony of Antonio Vega, Tr. 15,055-060; 15,191-193; 15,197-251; 15,278-416 (9/10/84).
15. Testimony of B. R. Clements, Tr. 15,418-428; 15,470-503; 15,514-521 (9/11/84).

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16. Testimony of Thomas Brandt, Tr. 16,107-133; 16,175-201 (9/13/84).
17. Testimony of Gordon Purdy; Tr. 16,358-373 (9/13/84).
18. Testimony of Ronald Tolson, Tr. 16,399-575 (9/14/84); Tr. 16,652-658 (9/18/84)- specifically, TR. 16,424 through 16,430 and TR. 16,542 through 16,546.
19. Testimony of Gregory Bennetzen, Tr. 17,745-934; 17,954-968 (9/20/84).
20. Testirnony of David Chapman, Tr. 17,969-18,301 (9/20/84).
21. Testimony of Doyle Hunnicutt, Tr. 18,515-669 (10/1/84) - specifically Tr. 18,561 through 18,570 and Tr. 18,633 through 18,640.
22. 01 Report 4-83-001 (24 August 1983).
23. Memorandum from P. Check to J. Collins, NRC, March 8,1984.

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8. This statement prepared by: x & M /, /o[As-D~Ctii .y, TRT 04te/

Technical Reviewe(r/

s Reviewed by: 46LE Herbert Livermore,

{#~7 <

Date Group Leader Approved by:

Vincent Noonan, Date Project Director 0-212

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