ML20199H379
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION E
WASHINGTON, D. C. 20555 7,
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JUL 121985 MEMORANDUM FOR:
Vincent S. Noonan, Director Comanche Peak Project FROM:
Chet Poslusny, Program Coordinator Comanche Peak Project
SUBJECT:
FEEDBACK INTERVIEW 0F ALLEGERS, A-1, A-3, A-5 AND A-54 On December 10, 1984, the TRT conducted a feedback interview with A11egers A-1, A-3, A-5~ and A-54 at the Plantation Inn, Granbury, Texas. The purpose of this meeting was to discuss the TRT evaluation and conclusions t.oncerning allegations in the quality assurance / quality control.
1 The TRT attendees were as follows:
V. Noonan, J. Zudans, J. Malonson, C. Hale, T. Curry, V. Wenczal, and V. Watson.
A previous feedback interview was held on November 27, 1984, at Granbury. That meeting was sumarized in a-letter from C. Poslusny to. V. Noonan, dated March 13, 1985.
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i The following is a summary of each addressed allegation and the allegers' coments on each.
1.
AQ-19 -- It was alleged that the Document Control Center " control copy" stamps were used by the Paper Flow Group (PFG) and the Quality Control Department. The allegation refers ~to a special red stamp that was issued to Quality Assurance to identify current drawing copies.
It was returned to the Document Control Center.
The TRT felt this was a potential violation, and the allegers agreed.
The allegers identified six' stamps which had been used, and the TRT agreed to investigate them.
2.
A - It was alleged that the Authorized Nuclear Inspectors s) accepted flawed packages, knowing that they contained deficient documentation. A-1 stated she had no concern about the ANI's, only the quality engineers and some QC inspectors. Discussion on this allegation was dropped.
3.
AQ-136 -- It was alleged that the ANI's may not be qualified. A-1 stated she had no concern about the ANI's, only the quality i
engineers and some inspectors. Discussion was dropped.
4.
AQ-110 -- It was alleged that the document ' packages were destroyed by the Document Control Center prior to completion of Unit 1.
The TRT outlined the course of events normally followed (retaining originals and destroying all copies), and the allegers had no comment.
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A - It was alleged that the Brown and Root QC inspectors were a sifying records of piping and piping support hanger packages.
This allegation was not discussed further because neither the TRT nor the allegers had anything to add.
6.
A0-45 -- It was alleged that between May 1982 and July 1984, pennanent records were not stored in a fireproof vault. The allegers stated the records they referred to are permanent plant.
records which were removed from the vault for revision (this legally reverts them to documentation again) and were kept in files which were not controlled or fireproofed. There was considerable discussion and argument whether these were pennanent plant records and whether they required fireproof files.
7.
A0-49 and AQ-74 -- It was alleged that weld data cards were lost and hundreds of packages of permanent records were lost in the course of various moves. The TRT found a few cases, but record replacement was according to procedures. A-5 alleges the procedures for handling records were revised in order to cover up earlier violations. The allegers cited examples of this on weld data cards, but the TRT could not substantiate the allegations.
8.
AQ-75 and A0-76 -- It was alleged changes to the N-5 program procedures for processing documents into and out of the vault, around i
March 7,1984, made it impossible for the document reviewers to do their job. Also, management deleted an approved set of procedures for reviewing documents, which left the document controllers without review procedures. A-3 said they were not pennitted to write NCR's except on the most serious problems.
Instead, they filled out problem sheets and sent them back to the inspectors.
9.
A0-23, A0-24, A0-26, AQ-27, AQ-28, and'A0-108 -- These allegations concern qualifications of inspectory, cheating on examinations, incorrect training records,' and inadequate training of inspectors.
The TRT had verified some these concerns. The allegers named several individuals involved in this activity who had drug problems. Also, they mentioned inadequate training for DCC clerks in earlier periods.
Presently. -training and examination are required for them.
- 10. A0-17 -- This allegation concerns duplication of paperwork on flange j
travelers. TRT verified this allegation.The problem was solved by i
forming the Paper Flow Group.
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- 11. A0-43 -- It is alleged that craft workers were performing rework after QC signoff, by performing undocumented repairs. The TRT found some instances of rework, but all of them were covered by the proper j
documentation.
- 12. AQ-130 -- It is alleged that valve discs may have been interchanged when the valves were disassembled for welding. The TRT substantiated this and several related incidents.
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- 13. A0-55 -- It is alleged that fuel transfer canal liner documentation was. falsified, radiography was not complete, and inspection travelers 4
were improperly signed off.
It was not clear whether the equipment i
was safety related, and the TRT will notify the allegers after the determination is made. A-3 stated she was forced to falsify 112 to 142 travellers.
- 14. AQ-5, A0-12, A0-13, AQ-14, and A0-115 -- It is alleged that lack of material traceability for safety-related material and components has occurred. The TRT found memoranda were.used for upgrading material, which the TRT considers legal. A-5 felt it should be done by using an NCR.. In the case of the ITT and MPS supports, the TRT found a i
potential violation. The allegers argued that using a memo for material upgrading prevented trending of the violation. TRT agreed i
-to try to determine how much material had been upgraded by memo.
- 15. A0-40 -- It was alleged that. heat numbers for safety-related materials _were improperly assigned in the field. This is related to color codes being used to identify heat control numbers for instrumentation tubing. The TRT found no violations. The TRT was asked to detennine if weld filler material used on safety-rela lted,
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non-ASME welds. required traceability.
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- 16. A0-77 and A0-79 -- It was alleged that component parts, such as eye-bolts which had been lost, and safety-related parts were made
- without fabrication' instructions. The TRT confirmed this practice had existed, but was stopped. A-3 said it stopped only on the night shtft; the day shif t still made these components without the proper documentation. A-3 could identify plant areas where this had occurred.
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- 17. AQ-31 -- It was alleged that interoffice memos were used to disposition IR's and make other changes, rather than NCR's. The TRT I
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found, in most cases where'IM's were used, that they were used properly, attached to the NCR.
- 18. AQ-120 -- It was alleged that when Unit 1 was starting to be turned 2
over, a number of NCR's were written, disposition of which was questionable. The allegers said the critical time period was early 1984. They also said systems were turned over that were not complete.
- 19. A0-116 -- It was alleged that Brown and Root procedure changes have i
resulted in manipulation of safety-related documentation and violations of procedures. TRT could find no evidence of manipulation.
- 20. A0-80 -- It was alleged that QA/QC inspectors were pressured by management and crafts to not write NCR's. According to the TRT, IR's were to be used whenever the repair used existing procedures for rework. A-1 had been given an IR with a forged approval signature.
j She will turn that over to the TRT.
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- 21. AQ-41 -- It was alleged that gauges used to calibrate lighting restraint cable installation tools were worn, which resulted in incorrect installation and issuance of an NCR. This allegation had been covered with another alleger. No one had any further comments.
- 22. AQ-55 and AQ-78 -- It was alleged that fuel transfer canal liner documentation was falsified.
(This is covered also by an OI i
investigation.) A-3 stated it was falsified. A-1 said the documentation was not adequate to confirm hold point no. 1.
A-5 wanted to know if anyone from the TRT had looked at the radiographic film. The TRT had looked at the film, but had not evaluated them.
The TRT selected the film that they reviewed; it was not preselected.
- 23. AQ-6, A0-126..and AQ-132 -- It was alle ed that:
(1) TUGCO's QA is not indepencent-from TUGCO's construction, 2) former craftspersons and inspectors verified packages containing their own work, (3) auditors were not independent of areas audited, and (4) management is suppressing audit findings. The allegers discussed several specific 1 __
confifets of interest in these areas.
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- 24. ' AQ-127 -- It was alleged that site library tfocuments were not current, DCA's were not available when needed, and document changes were not always distributed. The allegers had several examples where up-to-date infonnation was not available.
25 AQP-2 -- It was alleged that a CMC related to pipe piece no. 48 was missing;.it was perhaps lost deliberately so unauthorized work could not be traced. The TRT found a potential violation.
Conclusion -- The allegers stated they were more satisfied with this meeting than with the November meeting. A-1 said she agreed with
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most findings,. but believes the supervisors ordering the procedure violations should have been disciplined. A-54 agreed with A-1.
A-5 had no comment.
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i Chet Poslusny, Program Coordinator j
Comanche Peak Project cc:
D. Eisenhut j
B. Hayes CPP j
J. Youngblood CPoslusny L. Shao 44/85 J. Calvo I'
i H. Livermore M. Kline l
Docket Files 50-445/446 i