ML20198D602

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Partially Withheld Assessment of Allegtions AQ-6 & AQ-126 to Allegation Category Qa/Qc 7, QA Implementation Re Lack of Qa/Qc Independence from Production & Inspectors Performing Record Verification of Own Insp & Work
ML20198D602
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 8605230334
Download: ML20198D602 (4)
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1. Allegation Category: QA/QC 7, QA Implementation
2. Allegation Number: AQ-6 and AQ-126
13. Characterization: It is alleged that quality assurance / quality control

, (QA/QC) lacked independence from production (AQ-6), and that former craft persons and inspectors were assigned the responsibility of performing a record 1

verification of packages containing their own inspection or work between

[

-December 1983 and February 1984 (AQ-126). "

4. Assessment of Safety Significance
In assessing the allegation that QA/QC lacked independence from construction, the NRC Technical Review Team (TRT).

l first reviewed Texas Utilities Electric Company (TVEC) organization charts for the relationship between the construction, startup, and operations -

groups. The authority and duties of all group positions were described in the Final Safety Analysis Report (FSAR) and implementing procedures.

t The TRT learned from November 1983 organization charts and interviews that the construction activity was changed from management on a plant wide basis to a building management organization (BMO), which subdivided plant con-i struction responsibilities into four buildings: the reactor building; i electrical control and turbine building; auxiliary building; and safeguards and diesel generator building. Construction responsibilities included

' . planning and scheduling, documentation processing, engineering, and craft.

.QA/QC-personnel were assigned to provide quality services to each building, and reported directly to the project QA manager. The building manager and

the QA manager were at the same. reporting level to Comanche Peak Steam L Electric Station (CPSES) senior management.

The TRT verified that QA/QC perso1nel working with building organizations did indeed report direct to QA maiagement and not BM0 management. At the time of the TRT's evaluation, it was determined that QA/QC organization was independent from the influence of construction production and was in l compliance with 10 CFR Part 50, Appendix B, requirements for QA/QC organi-zational independence. The change of management on a plant wide basis to

, the BM0 did not affect quality personnel, who continued to report to the j same management as before; nor were their job assignments affected by the

change.
~ The TRT then reviewed the audiovisual orientations given to all new CPSES employees. Brown & Root (B&R) provides an orientation program for con-struction employees and TUEC provides an orientation program for all QA/QC
employees. Part of the B&R program consists of a slide presentation called

, " Quality Is Your Job," which was created in October 1983. The TRT was told by the' instructor that the presentation was prepared at the direction of

the vice president for Nuclear Operations as the result of an NRC commit-
ment. The presentation was given retroactively to all construction l personnel and included an explanation of the multiple levels of inspection required by the worker, foreman, QC, QA, and the NRC. All site workers j were expected to cooperate with inspectors and it was explained that

" bullying or harassment" of QC inspectors would not be tolerated. When TUEC's orientation first began, all new employees were shown the TUEC QA/QC film " Introduction to Quality Assurance and Quality Control," but j for the last 5 years it has been shown solely to the site QA/QC inspectors.

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s The TRT reviewed two of the six sections in the TUEC presentation, both of which made many references to the organizational independence of QA/QC from construction, as required by the regulations. There was a good presentation on the " Nature of QA/QC Inspectors," which placed special emphasis.on the establishment of good workin'g relationships with craft personnel and avoiding personal disagreements and conflicts with con-struction personnel.

In assessing the allegation of former craft personnel and inspectors per-forming verifications of their own records, TRT reviewed four B&R and two TUEC procedures on personnel training and one procedure on verification activities of QA records. These procedures did not provide any preventive measures or precautions that record reviewers avoid the potential conflict of. interest alleged. The training requirements for record reviewers prior to spring of 1984 included attendance at the QA/QC orientation class, re-view of the applicable procedures, and a general reading list, which included 10 CFR Part 50, Appendix B, and ANSI N45.2. Criterion X of 10 CFR Part 50, Appendix B, states that inspections shall be performed by indivi-duals other than those who performed the activity being inspected. This criterion also would apply to record verification. B&R management could not provide any documentation in the training given to record reviewers that stated they should not review their own work, nor were record review-ers required to sign statements disqualifying themselves when they were assigned work with such a potential for conflict of interest. Subsequent to spring of 1984, the new position of verification inspector was created and qualified per B&W CP-QAP-12.1 and TUGC0 CP-QP-2.2A.

In interviews with B&R management, the TRT learned that the record review group was made up of former craft personnel and QC inspectors who were transferred into this group when construction work was slow. This fact was confirmed by the B&R organization chart (dated April 15, 1984) of the "N-5/ Hydro" group, B&R QA management acknowledged that it was a violation of 10 CFR Part 50, Appendix B, Critation X for craft personnel to inspect their own work, but stated that there were no specific requirements which prevented inspectors from verifying the contents of records which contained the results of their own inspections. B&R acknowledged that there were instances in the past where this situation had occurred, but they could identify no specific instance of this practice. The TRT interviewed the Authorized Nuclear Inspectors (ANIS) who stated that when they found in-spectors verifying their own work at Unit 1, they returned the packages to B&R for reverification by another person. The TRT attempted to identify instances of this type of potential conflict of interest, but was unable -

to do so. The TRT reviewed all 66 field weld data card packages trans-mitted by the N-5 group to the permanent plant records vault from November 1, 1983, to March 31, 1984. The TRT could identify no specific instance where the document reviewer was the same person as the QC inspector, welder, or weld filler metal issuer. J The TRT also selected 92 pipe hanger record packages, one from each N-5 group, transmitted to the permanent plant records vault from December 1, 1983, to February 29, 1984. Each package contained one to six weld data j cards (the average was three). The TRT could find no instance where the  !

document re.. ewer was the same individual as the craft person or the QC inspector.

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5. Conclusion and Staff Positions: The TRT concludes that the allegation that QC lacked organization independence from construction could not be substantiated by the reviews and interviews conducted.

Based on interviews with ANIS and with B&R management, who were directly responsible for creating the record review group, the TRT substantiated the allegation of the potential for inspectors reviewing records of their own work, although specific examples were not found. The situation was created by B&R QA management's interpretation that 10 CFR Part 50, Appen-dix B, Criterion X was not violated. The TRT questions the effectiveness of a QA program when inspectors are placed in compromising positions in j which falsification of records could occur.

On December 10, 1984, the results and conclusions of the TRT's assessment of these allegations were presented to the allegers. No new a'llegations or concerns were presented at this meeting.

7. Attachments: None.

N Reference Documents:

1. TUGC0 procedures: CP-QP-2.1, Rev. 16.

CP-QP-2.2A, Rev. O.

CP-QA-2.2, Rev. 2.

CP-QA-2.3, Rev. 4.

CP-QP-3.0, Rev. 15.

2. Brown & Root procedures: CP-QAP-2.1, Rev. 11.

CP-QAP-2.1.5, Rev. 6.

CP-QAP-12.1, Rev. 11.

CP-QAP-18.1, Rev. 3.

3. AQ-6: A-5 letter, March 7, 1984; A-1 interview, August 1, 1984, pages 61 through 66; A-3 interview, pages 93 through 100; A-1 and A-3, statement, undated AQ-126: A-1 testimony, August 1, 1984, pp. 61 through 66.
4. Close-out interview.with A-1, A-3, and A-5 December 10, 1984, p. 173.
5. 10 CFR 50, Appendix B, "QA Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."

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8. This statement prepared by:

V. Wenczel,gRT '

6f(f4/ ((

Date Technical Reviewer

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Reviewed by:

., H. Livermore, CWuM d~ 7 \ b Date Group Leader i

Approved by:,

V. Noonan, Date Project Director 5

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