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i-UNITED STATES E
NUCLEAR REGULATORY COMMISSION
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i WASHINGTON, D, C. 20555 JUL 121985 HEMORANDUM FOR:
Vincent S. Noonan, Director Comanche Peak Project I
FRdM:
Chet Poslusny, Program Coordinator Comanche Peak Project
SUBJECT:
FEEDBACX INTERVIEW OF ALLEGERS, A-1. A-3, A-5 AND A-54 On[
the RT conducted a feedba k interview with A11egers A-1, A-3, A-5 and A-54 at The purpose of this meeting was to discuss e TRT eva'uation and conclusions concerning allegations in the quality assurance / quality control.
The TRT attendees were as follows:
V. Noonan, J. Zudans, J. Malonson, C. Hale, T. Curry, V. Wenczel, and V. Watson.
A previous feedback interview was. held That meeting was sumarized in a letter from. Poslusny to V. Noonan, date ' arch 13, 1985.
Tha following is a sumary 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.packa
, knowine that they contained deficient documentation. A-1 lhad no concern about the ANI's, only the quality engineers and e QC inspectors.s Discussion on this allegation was dropped.
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3.
A0-136 -- It was al.leged that the ANI's may not be qualified. A-1 M _,'}had no concern about the ANI's, only the quality i
engineeFs and some. inspectors.
Discussion was dropped.
I 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 nonnally followed (retaining originals and destroying all copies), and the allegers F0\\A-8 8607030386 860623 DE A-18 PDR s
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5.
LA - It was alleged that the Brown and Root QC inspectors were faTsifying 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.
AQ-45 -- It was alleged that between May 1982 and July 1984, permanent 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 permanent plant records and whether they required fireproof files.
7.
AQ-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 AQ-76 -- It was alleged changes to the N-5 program procedures for processing documents into and out of the vault, around 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 permitted to write NCR's except on the most serious problems.
Instead, they filled out problem sheets and sent them back to the inspectors.
9.
AQ-23, AQ-24, AQ-26, AQ-27, AQ-28, and AQ-108 -- These allegations concern qualifications of inspectors, 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. AQ-17 -- This allegation concerns duplication of paperwork on flange travelers. TRT verified this allegation.The problem was solved by
- 'ag the Paper Flow Group.
- 11. AQ-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 documentation.
- 12. AQ-130 -- It is alleged that valve discs may have been interchanged i
when the valves were disassembled for welding. The TRT substantiated.
this and several related incidents.
3 13.
AQ-55 -- It is alleged that fuel transfer canal liner documentation i
was falsified, radiography was not complete, and inspection travelers were improperly signed off.
It was not clear whether the equipment determination is made.was safety related, and the TRT will notify the allegers 142 travellers.
A-3 stated she was forced to falsify 112 to 14.
AQ-5, AQ-12, AQ-13, AQ-14, and AQ-ll5 -- It is alleged that lack of 4
material traceability for safety-related material and components has occurred.
which the TRT considers legal.The TRT found memoranda were used :
In the case of the ITT and MPS supports, the TRT found aA-5 an NCR.
i potential violation.
The allegers argued that using a memo for y
material upgrading prevented trending of the violation.
h to try to determine how much material had been upgraded by memo.TRT agreedJ 15.
AQ-40 -- It was alleged that heat numbers for safety-related
- 9 materials were improperly assigned in the field.
color codes being used to identify heat control numbers forThis is related to J$
instrumentation tubing.
The TRT found no violations.
The TRT was s
asked to determine if weld filler material used on safety-rela,ted,
%s non-ASME welds required traceabf11ty.
M 16.
AQ-77 and AQ-79 -- It was alleged that component parts, such as m
without fabrication instructions. eye-bolts which had been lost, and safet M
had existed, but was stopped.
The TRT confirmed this practice shift; the day shift still made these components without the prop I
4 documenta tion.
A-3 could identify plant areas where this had occurred.
i 17.
AQ-31 -- It was alleged that interoffice memos were used to t
disp 6sition IR's and make other changes, rather than NCR's.
found, in most cases where'IM's were used, that they were used The TRT properly, a,ttached to the NCR.
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18.
A0-120 -- It was alleged that when Unit I was starting to be turned s
over, a number of NCR's were written, disposition of which was t
questionable.
They also said systems we' re turned over that were notTh 1984.
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! E complete.
d 19.
A0-116 -- It was alleged that Brown and Root procedure changes have resulted in manipulation of safety-related documentation and violations of manipulation. procedures.
TRT could find no evidence of 20.
A0-80 -- It was alleged that QA/QC inspectors were pressured by management and crafts to not write NCR's.
l According to the TRT, IR's were to be used whenever the repair used existing procedures for
- d rework.
Qwill turn that over. to the TFT.A-1 had been given an IR with a forged app i[
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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 coments.
- 22. AQ-55 and AQ-78 -- It was alleged that fuel transfer canal liner documentation was falsified.
(This is covered also by an 0I 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. A0-6, AQ-126, and AQ-132 -- It was alleged that:
(1) TUGCO's QA is not independent 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 conflicts of interest in these areas.
- 24. AQ-12f -- It was al5eged that site, library documents were not current, DCA's were not available when needed, and document changes were not always distributed. The allegers had several examples where
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up-to-date information was not available.
- 25. AOP-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 treeting. A-1 a ---agreed with most findings, but believes the supervisors ordering ~the procedure violations should have been disciplitted. A-54 agreed with A-l.
A-5 1
l had no coment.
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Chet Poslusny, Pr gram Coordinator Comanche Peak Project cc:
D. Eisenhut B. Hayes J. Youngblood L. Shao J. Calvo H. Livermore M. Kline Docket Files 50-445/446
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- 21. AQ-41 -- It was alleged that gauges u' sed to ca' librate 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 investigation.) A-3 stated it was falsified. A-1 said the documentation was not adequate to confinn 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, AQ-126, and AQ-132 -- It was alleged that:
(1) TUGCO's QA is not independent from TUGCO's construction, (2) former craftspersons and I
inspectors verified packages containing their own work, (3) auditors werenotindependentof.areasaudited,and(4)managementis suppressing audit findings. The allegers discussed several specific conflicts of interest in these areas.
- 24. AQ-127 -- It was alleged that site library documents 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 information 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.
l Conclusion -- The allegers stated they were m satisfied with this meeting than with the November meeting. A-1 agreed with most findings, but believes the supervisors ordering he procedure l
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 B. Hayes CPP j
J. Youngblood CPoslusny 4 4 /85:
L..Shao b
J. Calvo
[I H. Livermore M. Kline Docket Files 50-445/446 j
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UNITED STATES y(
~1 NUCLEAR REGULATORY CC'MMISSION b
.E WASWNG TON, D, C,20555 l,
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JUL 121985 MEMORANDUM FOR:
Vincent S. floonan, Director Comanche Peak Project FROM:
Chet Posiusny, Program Coordinator Comanche Peak Project
SUBJECT:
FEEDBACK INTERVIEW 0F ALLEGERS, A-1, A-3, A-5 AND A-54 m
On' W G X M _1: 7the TRT conducted a feedback interview with Allegers A-1, A-3, A-5 and A-54 at f&'ximMhuiMang The purpose of this meeting was to discuss tile TRT evaluation and conclusions concerning i
allegations in the quality assurance / quality control.
The TRT attendees were as follows:
V. Noonan, J. Zudans, J. Malonson, C. Hale, T. Curry, V. Wenczel, and V. Watson.
A previous feedback interview was held E F 7 %d_
a h_.),,lpThat I
meeting was summarized in a letter from C. Poslusny to V. Noonan, datedlarc'1 13, 1985.
i The following is a sumary of each addressed allegation and the allegers' b;
comments on each.
t 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 i
copies.
It was returned to the Document Control Center.
J The TRT felt this was a potential violation, and the allegers agreed.
l The allegers identified six' stamps which had been used, and the TRT agreed to investigate them.
7 l
2.
AQ-99 -- It was alleged that the Authorized Nuclear Inspectors (ANI's) accepted flawed. packages, knowino that they contained deficient documentation. A-1 f Q g d had no concern about the ANI's, only the quality engineers and'sMiie QC inspectors.
Discussion on this allegation was dropped.
3.
A0-136 -- It was alleged that the ANI's may not be qualified. A-1
@WNhad no concern about the ANI's, only the quality 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 anddestroyingallcopies),andtheallege i
G SH7 a
~
2 5.
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.
AQ-45 -- It was alleged that between May 1982 and July 1984, permanent records were not stored in a fireproof vault. The allegers stated the records they referred to are permanent plant 3
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 permanent plant records i
and whether they required fireproof files.
7.
AQ-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 TLT could not substantiate the allegations.
l 8.
AQ-75 and A0-76 -- It was alleged changes to the N-5 program procedures for processing docua,ents into and out of the vault, around 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 permitted to write NCR's except on the most serious problems.
Instead, they filled out problem sheets and sent them back to the inspectors.
9.
AQ-23, A0-24, AQ-26, AQ-27, AQ-28, and AQ-108 -- These allegations concern qualifications of inspectors, cheating on examinations, incorrect training records,' and inadequate training of inspectors.
The TRT had verified some these concerns. The all'egers 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. AQ-17 -- This allegation concerns duplication of paperwork on flange travelers. TRT verified this allegation.The problem was solved by forming the Paper Flow Group.
- 11. AQ-43 -- It is alleged that craft workers were perfonning rework after QC signoff, by performing undocumented repairs. The TRT found some instances of rework, but all of them were covered by the proper 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.
3 13.
A0-55 -- It is alleged that fuel transfer canal liner documentation was falsified, radiography was not complete, and inspection travelers were improperly signed off.
It was not clear whether the equipment was safety related, and the TRT will notify the allegers af ter the determination is made.
142 travellers.
A-3 stated she was forced to falsify 112 to I
14.
A0-5, A0-12, AQ-13, AQ-14, and AQ-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 fiCR.
In the case of the ITT and MPS supports, the TRT found a potential violation.
The allegers argued that using a memo for material upgrading prevented trending of the violation.
TRT agreed 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 determine if weld filler material used on safety-related, non-ASME welds required traceability.
16.
A0-77 and A0-79 -- It was alleged that component parts, such as i
eye-baits which had been lost, and safety-related parts were made withcut fabrication instructions.
The TRT confimed this practice had existed, but was stopped.
A-3 said it stopped only on the night shift; the day shif t still made these components without the proper documenta tion.
A-3 could identify plant areas where this had occurred.
17.
A0-31 -- It was alleged that interoffice memos were used to disposition IR's and make other changes, rather than f1CR's.
The TRT found, in most cases where'IM's were used, that they were used properly, a,ttached to the flCR.
18.
A0-120 -- It was alleged that when Unit I was starting to be turned over, a number of fiCR's were written, disposition of which was questionable.
The allegers said the. critical time period was early 1984.
They also said sys.tems were turned over that were not ccmplete.
19.
A0-116 -- It was alleged that Brown and Root procedure changes have 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 craf ts to not write ffCR's.
According to the TRT, IR's were to be used whenever the repair used existing procedures for rework.
Q will turn that over to the TPT.A-1 had been given an IR with a forged approva r
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- 21. A0-41 -- 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 i
been covered with another alleger.
No one had any further cor=ents.
- 22. A0-55 and A0-78 -- It was alleged that fuel transfer canal liner documentation was falsified.
(This is covered also by an OI 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.
I 23.
A0-6, A0-126, and A0-132 -- It was alleged that:
(1) TUGC0's QA is not independent 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 conflicts of interest in these areas.
- 24. A0-127 -- It was alleged that site. library documents 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 information was not available.
- 25. A0P-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 mo.re sati_sfied with this meeting than with the November meeting. A-liem aagreed with most findings, but believes the supervisors ordering ~the procedure violations should have been disciplirted. A-54 agreed with A-1.
A-5 had no coment.
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g.vu,
Chet Poslusny, Pr / gram Coordinator Comanche Peak Project cc:
D. Eisenhut B. Hayes J. Youngblood L. Shao J. Calvo H. Livermore M. Kline Docket Files 50-445/446
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- 31. 12 1585 AQ-41 -- It was alleged that gauges used to calibrate lighting 21.
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 0I 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.
AQ-6, AQ-126, and AQ-132 -- It was alleged that:
(1) TUGCO's QA is not 23.
independent from TUGCO's construction, (2) former craftspersons and I
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 conflicts of interest in these areas.
- 24. AQ-127 -- It was alleged that site library documents were not current,.DCA's were not available when needed, and document changes were not always distributed. The allegers had several examples where ll up-to-date information was not available.
AQP-2 -- It was alleged that a CMC related to pipe piece no. 48 was 25.
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 M jagreed with 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.
b f
I Chet Poslusny, Program Coordinator Comanche Peak Project cc:
D. Eisenhut q
CPP B. Hayes J. Youngblood CPoslusny L. Shao 4
/85:
J. Calvo
(
H. Livermore f
M. Kline Docket Files 50-445/446 y
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for6 ecord, this was intended as a 7:00 p.m.
inter-3~
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wyig,___(i@7N%3$@,dforhig-itMEM@&Fdforthepurpose 1
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- n of providing feedback regarding Technical Review Team assess-5 ment of concerns raised by h $,T',[d $ 3 $$ about the Comanche
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6 -
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Peak facility.
7 Parties present at this meeting are Bob Hubbard, Jim 8 l t
Malonson, Tom Curry, Charles Richards, John zudans, Vince 9
l Noonan, Herb Livermore, and Annette Vietti.
10 The items which we wanted to brief t
j 11 were AQW 29, AQP 2, AQ 55, AQ 78, AQ 80, AQE 41, 12 i
and AQW 30.
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did not. show up,[ $ 7($ gj g ck g gl and, therefore, are closing this meeting at 15 l
7:20 p.m.
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I Gu rnan Y IflTERVIEW FORMAT - FEEDBACK INTERVIEKS 1.
Cover Page i
Parties present.
c t.s FF hat.w.
- rm M As.op so4 vt( w q.N ca Et tom cu9R.T l
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Y*NOO 2.
Proceedings (on the record) 1 1
I "For the record, this is an inte.ty.iew of _ for the purpose of providing feedback regarding Tech [lical Review Team as::essment of certain concerns raised abcut the Comanche Peak facility.
"The location of this interview is "Present at this interview are (names /crganizaticns)"
"As agreed, this interview is being transcribed.
Describe mission of TRT "I wish to clarify details of your employment at Comanche Peak" (Obtain details of employment /qualificatiens eed AT
- a tA.
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"We s' oke with you on... anc have reviewed your statement (s) of...
p Turn over to Technical Reviewer...,
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I 2
3.
Conclusion of Proceedings "The results of our evaluation will be published.fn a SSER wnich w ll i
be available abcut January 1, 1785" "Where appropriate we will require corrective action by TUGCO."
"Do you have anything further you would like to add for the record?,
t "Have we adequately covered your concerns?
"Do you have additional concerns?"
"Have you given this statement to us today freely and voluntarily?"
... off the reccrd
-1 4
Administrative Guicance J
Ask if inoivicual wants cc;'y of transcript. advise them that ranscript will be part of public recere (except for confidentir.1 tources, or if they request confidentiality).
j 5.
Guidance Limit to topic of interest Ask:
Is this a new issue?
Have you prcvided this to NRC?
~....
_3_
Did you do it?
Did you see it?
Seek:
names, dates, locations, documents.
o Be courteous and considerate o
Be sure individual appreciates the importance cf his concern (s) and the staff / technical effort expended to review and evaluate.
o Be sure individual understands we will require corrective action and that we are dedicated to safety.
When presenting negative findings _fi.e., when allegations are found to be of no merit), do not tell jndividuals that they are "wrcr.g",
askiftheTRThaspossiblymisseohispoints....
+
0
Telecon with Alleger A-2 1/24/85 (1100 EST)
Attempt to discuss arrangements with Alleger A-2 for feedback interview were unsuccessful since A-2 was not at home.
Individual contacted informed me that Alleger A-2 would be home on the evening of 1/25/85.
I left a message that I would return my call at that time.
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Telecon with'A11eger A-2:
1/27/85 (1100 EST)
I called alleger A-2 to determine whether to meet with us af;er having talked to GAP.
Individual informed me that this was not a good time o meet with the TRT due to family problems.
I offered to send the alleger our findings in writing I
informed the allegar that the information would be sent n the near future.
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