ML20210B149
| ML20210B149 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/13/1984 |
| From: | Griffin H NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | Herr R NRC OFFICE OF INVESTIGATIONS (OI) |
| Shared Package | |
| ML20197F755 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8601270442 | |
| Download: ML20210B149 (74) | |
Text
_.
[
f"%
unnro sis Tts f
iy
,7 l g NUCLEAR REGULATORY COMMISSION
,f e s k, is.. !
OFFICE OF INVESTIGt.TIONS FIELD OFFICE. REGION IV
[' ' '
- "1$NNON. TExYs*MI *
,f M#
,g g August 13, 1984 g7 h/J
~
MEMORANDUM T0:
Richard K. Herr, Director Office of Investigations Field Office, Region IV 2M 10 FROM:
H. Brooks Griffin, Investigator NON Office of Investigations Field Office, Region IV
SUBJECT:
ALLEGATIONS FROM GOVERNMENT ACCOUNTABILITY PROJECT (GAP)
On August 10, 1984, the Region IV Office of Investigations Field Office received from the Comanche Peak Steam Electric Station (CPSES) TRT a GAP allegation related to a material false statement made by the CPSES plant management to the ASLB. This allegation was contained in a March 19, 1984 GAP letter to Mr. DeYoung with I&E.
OnAugust10,Ic84,thereportinginvestigatortelephonedBillieGardeatGAP) headquarters. Ms. Garde said this allegation referred to (Heyward Hutchinson's testimony before the CPSES ASLB Qir. Hutchinsoryhad been Interviewed by this' investigator on February 27, 1984, and a transcript of the interview was
~
provided to the ASLB. The events surrounding this incident were reported under Report of Inquiry No. Q4-84-014.!
The CPSES ASLB has already ruled on the CYGNA prenotification issue. No further investigation is anticipated.
cc:
D. Eisenhut, DL B. Hayes, O!
E. Gilbert, 01 f
J. Collins, RIV /
J. Youngblood, NRR S. Treby, ELD F0lA-85-59 8601270442 051212 G
w
Uf;11EC 51AiES OF *E.II.lEt, 1;U~LE AR F.!GULA10P.Y CO't';15510fi E E FDP.E T HE AT D* 1 C S Ar ET Y A';D L I E t t:51 hG B O Ar.D In the Matter of
)
TEXA5 UTIllTIES GEtiERATING COMPANY, Do:Let Nos.
50-445 and et a1
)
50-446
).
~~(Coman:he Peek Steam Electric Station, )
Units 1 and 2)
)
).
LIMITED APPEAP.AMCE STAT EMENT E
b 2
'.a My naat 1s s'
Citizens C15n-i'[of t,h4Jiovernment A:'countabilit, I ar. th he f
Project (GAP).
The Government Accountability Project is a project of the Institute for Policy Studies, Wasington, D.C.
The purpose of the program is to broaden the understanding of the vital role of public and corporate employees in preventing waste end corruption, to offer legal and strategic cour.sel to whistleblewers, it provide a unique legal education for law students, to bring meaningful and significant reform to the govertraent workplace, and to expose government action:
that are repressive, wateful or illegal, and that pose a threat to the health and safety cf the American public.
Presently, the Project provides a prograe. o-multi-level assist 6nce for government employees who report illegal, wasteful, o-improper actions by their agencies.
GAP regularly monitors governmental refor:r.:
offers expertise to Txecutive Branch of fices and agencies, and responds to requests by Congress and state legisletures for analysis of legislation to cake government more accountable to the public.
~
E_ w e w
, s.
- ;'.*. '. d i.
- : 0 L'.; i 1. v. ; *.. '. '
. 08 !!!!1t r;u.ir, c q 3 g,g ;
GAP's Citi2cns Clinic is a citi2cns trair.ing, consulting, and so:ial a,ctivist program for local " grassroots,' public interest, comunity, and chur:h groups.
This program is designed to assist and direct citizen involvemer.t. Its role is to provide a range of services to individuals or groups who begin to speak out about problems spawned by corpoEate or govern $ent ineptitude or malfea sa nce.
The Clinic's focus is on assisting citizens to effectively use their First Amendment rights to expose or address significant issues.
The Clinic addresses health and safety concerns, consu=er fraud, corporate
~
- rip-offs,* pollution, governm*Ih't mise 8kuctfabuse or inaction, and the abridg-r.ent of individual rights that of ten accompanies the struggle of citizens to redress their grie)ances.
I y,.n.,
In recent years, GAP has been approached by a growing number of witnesses from nuclear. power plants under constructicn across the nation.
In keeping with its objectives, both the GAP Whistleblower Review Panel and the Citizens Clinic Review Board have directed staff to pursue aggressively the comphints and problems thet nuclear workers bring forward.
GAP is not an "antbnuclear* organication.
Its ' objectives within the nuclear industry are the elimination of the government's misconduct and inaction the uncovering of facts that warrant closer scrutiny or regulatory action by the Kuclear Regulatory Commission (NRC), and nonitoring of how the liRC deals with significant information provided by nuclear "whistleblowers." This Clinic assumes that nuclear-related issues are critically important to the publ,ic safety, and acts upon evidence that the tiRC is doing an inadequate job regulating the nuclear industry that gover r.mer.t created, fluclear whistlet,h.cers I
the central figures in-our approach to nuc1 car-related work, are the vital
~'
' ' ' ' :, t ; : * ::.:.'.: i t ' : ' i.: t.'
N E l t u t t
- r t,U. * :J.:.1 7,7, 3 co:.ponents in the struggle for safe energy and making the public aware of den;eri o,r questionable conditions.
cap's involvement with Comanche Peak began a year ago when we learned of what happened to Mr. Charles Atchison at the Cerr.anche peak site.
The details of Mr. Atchison's firing were femiliar to us.
We have heard hundreds of similar horror stories from nuclear workers--from'managt: tent executives to document clerks--across the country.
What shocked us was the blatant disregard for Mr.
Atchison's rights by his employer, Brown & Root, and more specifically, the acti:
taken by the NRC staff to condone the company's wrongdoing and cover up its own flawed inspecticn.
In a letter which we filed with the Atomic Safety and 1.icensing: Appeal BoardN we protested the actions of the Regional 5taff Inspector.
Since that time, we have monitored both the liRC actions and those of Texas Utilities Generating Company (TUGCD) and Brown & Root at Co.anche Peak.
We have watched the fate of other workers who have also raised problems which they believed were a direct violation of approved construction procedures and 10 C.7.R. Part 50, Appendix B.
This Board is familiar with many of those workers and their allegatior.s of flawed construction, violated vendor inspection procedures, f r. adequate design quality assurance (Qt), inaccurate design documentation, and pressure from i
mar.agement supervisors to approve faulty work and participation in unauthorized work activities.
i This Board is also f amiliar with the type of trspections conducted into many of those allegations, and the continuous series of report conclusions that
0: l ' i '.11 : ! :.'d t. D M.*.'I re g :
that sun.arily dismiss or r.arrom the con: erns raised by the public " whistle-bl ow ers."
In revie ing these inspection reports over the pest year. GAP has con:1used that the entire regional inspection program is flawed.
We have proposed to Mr. P.ichard C. DeYoung, by separate letter today, that the Region !Y inspection program be subjected to a rigorous review by an internal team of auditors end Inspection and Enforcement officials from other regions.
We have found that Region IV is guilty of many of the generic defects GAP identified to the Congressional subcommittee of Investigations during a June 20, 1 933 hearing of the House Committee on Interior and Insular Affairs into the Investigation and Inspection Policies of the HP.C.
In short, Region IV is plagued with a quality assurance breakdown of its own inspections:
A.
In its approach to whistleblowers, Reoion IV has:
1.
violated the confidentiality of whistleblowers, either directly or indirectly; 2.
narrowly defined issues raised by whistleblowers and fallec to tr.spect beyond hardware examples the witness was a ble to identify specifically; l
3.
failed to record interviews or take affidavits, particularly 1
on the most signficant issues being raised by whistleblowers; 4.
failed to include affidavits in the public reports when the statements cor.tradicted the NRC's party-line on the problems at nuclear plants; 5.
failed to keep pace with new whistlebli ser allegations in a timely manner;
- a- - ---
i ii ;;i g _C:::!
3, ;,, g E.
In its cooroach to utilitics. F.e: ion IV hes:
6.
conducted closed-door snectings with utility and contractor executives when investigating whistleblower allegations; 7.
provided advance warning to utilities about where and when Region IV was going to inspect, hardware; 8.
relied on industry's technical conclusions without disclosure of supporting data and calculations for evaluation of whistle-t blower allegations; 9.
offered advance, informal review of decisions to the targets of,
Revion IV investigations and inspections thereby permitting utilities to escape accountability through informal, of ten-
~
unenforced com.itments "not to do it again;" '
10.
reviewed and informally approved licensee practices before approved by corporate officials with QA responsibilities, thereby undercutting the employees who tried to carry out their duties objectively despite the pressure of ranagement urgings that "it's all right with Region IV, so why are you holding things u pT*
C.
In its acoroach to the public, the HP.C hes:
11.
attefr.pted, as a knee-jerk reaction, to discredit critics--whether whistleblowers, anti-nuclear organization:, or simply interested l
and concerned citizens--by questioning their motivations, patrio-l tism, integrity, and technical ccrr.petence to raise questions sheut public health and safety; 1
=*
=.e-.
... + +..
e
--v
__y
--_--.._..y..
r.-.,,----
--e-_._
......i.
- ..i L'.A*.:'.:!d Ci _i:U,1! T U.?.* i. GtJDI Fegt 6 12.
destroyed drafts of reports, significent tepe recordings, created secret files, failed to admit the existence of documents requested under the Freedom of ]nforrnatier. Act (FOIA), and given conflden-tiality to utility executives'in order to prevent the public from learning how inspection findings were covered up.
Unfortunately, the result of this regional QA breakdown has been to make th Board's job much more difficult.
Well-esteblished agency cese law prevents the Board from leaving cor. tested matters to the staff for resolution.
Therefore, the inadequate staff effort has changed this B'oard's role to much more than is the usual in operating license cases. We compliment this Board on its diligence and patience.
Today,.we have taken steps which we hope will imorove the situation which the Board has been faced with throughout this hearing.
We have filed a petition with the Cornissioners, pursuant to 10 C.F.R. 2.205, ' requesting the following:
1, Require a comprehensive management audit of TUGC0 officials by an independent management auditing firm to assess the cause of th'e continuing inability of TUGCC and its contractors to implement an acceptable design and construction program for the Comanche Paak site that meets the requirements of 10 C.F.R. 50, Appendix B.
2.
Require an independent design and construction verification pro-gram (IDVCP) to assess the integrity of the Comanche Peak site QA program.
3.
Suspend the Comanche Peak Construction Permit until the comple-tion of the special HRC inspection and IDVCP, and an analysis of
=
e.
-e m
.y.,.
m--
=.-- -,
e.
'.. '.. '. :.. : :..... :,... :.. M U i n t !! T i;'.i;. G.:.:'?
te et 7 the,results of those inspections which should. include public participation to determine the approprieteness of further audit or other requirements.
We have atteched a copy of that Petition tp this Statement for your review.
~
As you will note, part of our request is for an 3DYCP to be accomplished i-conjunction with the NRC special inspection team--hopefully during an ir=ediate stop Work Order.
We have compared the current TUGC0 proposal and its methodology with that of two other audits with which GAP has been directly involved.
TUGCO's proposa) falls far short of both., GAP suggests that the Board consider the following observations in its review of any proposal for a Comanche Peak audit:
1.
Independence and comoetence as outlined in the letter from Chairca Nunzio Palladino to Congressmen Dingell ~and Ottinger, February 1 1982 regarding the audit of the Diablo Canyon facility.
(This criteria has been further developed for situations parallel to Coman:he Peak at the William H. Zi= er Nuclear Power Plant and the.
Midland Huclear Power Plant.)
2.
Public particip!Fon in the develoteent of the mat _hedoloev.
Both i
Midland and Zimmer independer.t audits incorporated several sets of meetings with the utility, the HRC, the third-par'ty reviewers.
l and the public.
Those meetings produced a rigorous and healthy audit methodology and protocol, which are now setting the standart-for third-party audits at other plantr--unfortunately, only when the public demands it.
l l
[8 11L L !! i
- L'iii. C
- QI nye L 3.
Detailed methodoloey and orotocol which will prevent any opportur ity for skepticism or rc.jection of the results and conclusions of a third-party audit or the design and construction verification.
This must, at a minimum, include a comitment by the independent auditor to not engage in pre-notification of the utility, (or the NRC), about the specific components that will be inspected or the documents and design packa' es which will be reviewed.
- Further, g
the company must comit to strict adherence to the protocol to l
avoid any questions about the validity of the end product.
As an organization, we have participated in numerous similar ce'etings, colding and shaping methodologies for vendor audits,100 percent reinspections o QA implementation reviews, and other variations on that theme.
We have JessistQ the agency in the current program on special independent audits at five sites across the country.
We urge the Board to request the assistance of the NRC sta.
personnel who have developed a similar broad base of experience in these types of audits to provide technical assistance in the review of the audit proposal.
We also request the opportunity to sutenit our cements on the company's propost GAP has only begun a preliminary investigation.
We do not anticipate tha our own preliminary investigation will be finished for another.60 days.
We hav submittee to the Office of Investigation (01), affidavits from workers and for=
workers, who have concerns about the plant and its ultimate safety.
These wit-nesses have requested confidentiality.
Therefore, we refer the Board to the August,1983 Statement of Consideration which provides the established methods j.
by which this Board can receive access to the inforr.ation and affidavits which are sulnitted to the fiRC 01 office.
f ". ' I.. ~. i ' O iit.::*.;I *.t*.;.,t,.
(J I.1 L i 11 i 1 *.t.I T. C,:J qi Iep Cor.tnthe pea,L is a troubled project.
Our level of knowledge is lir.ited to" the f acts on the public record, embellished by the experiences of those wo with whom we have the opportunity to speak.
Many of these witnesses have an understandable apprehension of entering the operating license hearing es vitn They do not trust the regional IIRC personnel either.
We have explained to th witnesses that each organization--corporate, government, or volunteer *-is rad of good and bad people, of competent and incompetent professionals.
We belie that there is a comitment on the part of this Board to get to the exteni-end course of the problems.
We sincerely hope the Board succeeds.
Dated this 19th day of P, arch,1984.
~
l I
{
1/
- This letter was treated by the Appeals Board as en Amicus Curiae sr L
.i 1
i FOLDER NO.
78 Draft No.
Date COMANCHE PEAK ALLEGATION WORK PACKAGE MISCELLANEOUS Category 18 - Drug Abuse Allegation Numbers: AM-21 Statement of Allegation: Widespread drug abuse and management inattention to the problem.
I Reference Documents:
See source documents marked on attached pages from allegation list.
Source of Allegation: GAP - see enclosed allegation list Date Received: 3/84 The above information prepared by D. M. Hunnicutt 6/7/84 Name Date Group Leader Name Date Assigned Team Members Date Assigned Date Assigned Date Assigned Date Assigned F01A-85-59 3 m+
1 h
s COMANCHE PEAK OPEN ISSUE ACTION PLAN Task: Determine whether widespread drug abuse and/cr management inattention to a crug abuse problem exists.
i Ref. No.: AM-21 l
Characterization: Allegation that wide spread drug abuse and management inattention i
to the problem has been made.
l-Initial Assessment of Significance: There are no specifics available from GAP or others to guide the followup of this allegation. The allegation appears to be a " shotgun" approach that vill be difficult to confirm or deny.
Source: Miscellaneous Category 18 - Drug Abuse 4
Aporoach to Resolution:
1.
Discuss any specifics with the alleger (either directly or through OI-based in Region IV). Discuss specifics with CPSES plant security and drug councilor or medical personnel at CPSES. Discuss allegation with plant management.
2.
Review drug abatement program with licensee management, drug councilor, and medical personnel at CPSES.
3.
Review procedures, NRC requirements, and licensee commitments for adequacy.
Were requirements and other commitments met?
4.
. Discuss adequacy of procedures with personnel involved with drug program.
Examine potential or identified problems that are/or could be associated with inadequate procedures identified during interviews.
5.
Review sample of drug control procedures for adequacy.
6.
Refer any examples of wrongdoing or significant deficiencies to TRT manager.
7.
. Evaluate allegations for generic / safety implications.
8.
- Report'on results of review / evaluation of allegations.
Related Open Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
from the tracking system open item list.
(Region IV identify and add to this work package.)
2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional
[
inspection while the inspector is familiar with the areas, i
l l
1
Status:
Review Lead:
Support:
4 t
Estimated Resources:
Estimated Completion:
CLOSURE:
Reviewed by:
i
'l i
l J
t e
1 4
I k
[
t l
[
{
4 I
c
MISCELLANEOUS ALLEGATION REVIEW CATEGORIES -
j Category Est. Mandays Allegation Package Assigned Schedule to.
Subject to Complete Nos.
Prepared' to Open Close Remarks 17.
Material false AM-20 statement (plant
'E management to ASLB) j 18.
Drug Abuse AM-21 19.
e 19 O
I w
c
=y sc e
se af j i;= is E'
- g. [
wr I
=0 te
!: 1 I
$1
.1:i-II 3
E! I 8
J wE e
= "L
=I "9 :-z... 3-3 5..
E
.i
.=-
g 15 1.
E
!b,
=.,-:.
-= -a
_a g g _,
a 11 g8.
- I'!
IE 1
3
% j!!
%I f
(.
Ig.-
s==
- =
g N1
=
-1 g
E'
=
B li
=
E I
L L
I s
s i
l C
-19
-19 l
3=in 3 =1s
=
e u
s 2
I 12
- .l!
a3 fi}1s. li
-=Il 1
543 3
"8 st 3:
3 a
j5 I
2 1
!. i U 8-
- s. I ljy 1", i.:-*))1Alis' 3
i-l"}
I ge i.s14 i
8 21.= -'. v :s a;,:j
= ::
3
-I E 41 2-.4.
a 23
=
s
=
a a
e
=
8 8
8 2Rl 8 8
8 8
Y)
I l
1 t
l l
c
,r
..-e
.--.-n~
COP.i ANCHE DEAi S~E A*.i ELE".T;iC STAT:CN Et AS JL.fiES GEMaats*G Co NONCONFC A.'.tANCE 4E?CET.NC A)
N SV 0/84L)
STavC?.s E STS E'A it t w C C*.t F ;'.E N !
aG : Nu 5ES
..,C A T.CN
- Esin" v sin N,C m
us.f
/N
/. d b.)
/[
g
. NONCCNFC8 MING CCNCittCN D a.s. to ME ftPn, s AMscu1 Of 0.A /OC Ofsco a n A L iy:
For.Su. spic son of tnHs,C brass iaiUL1 ' /krannins 5
GC/al Pan c +1uns tar G o. n Lit.2 of A n Y I rtn i3 mf In.wicrtb ce Riuit ia.sd JU Q R/GC A c. sonnet e
w do HAW L?frA trethin Ak-d AR A A(kts-Atlitte ti El eHAc &L Btcomt.s inds tr.<w sti att.
El O i A'u tl.. TNA.S /.s la Geri:*1'tC llC k.
I
/
d O
mEv saAa
- EFi:ENCE CCC'.; MENT CA?Z
^
j
&:)h0f r
^
Cg al'/IEW. ApeaCVAL.
3 O l ACTICN ACCaESSEE E,*
NT
_1 s
i Ot3PC5ITICN:
l AEAcak AEpain v5E AS is SC8A8 t
c.1 !
Ei
=:
25' Z9 1
0 -
l
. I ENG. AEVIEWi AppmCVAL i
.A ?E.
i e
I DATE.
i W
C : CispCsi?iCN VEmiF6CATICN & CLC5i;5E.
., A TE -
i i
. CCMMENTS.
l
Invertiration Su= ary:
Investiration Durinr the Period April 5. 1979, throuch May 7. 1979 (Report No.
50-445/79-09: 50-446/79-09)
Special, announced investigation concerning alletations by Areas Inspected:
former R. W. Hunt employees whose statements of inspection and testing impro-priaties appeared in the Fort Worth Star-Telegram on April 4, 5, 6 and 8,1979.
ctor-hoera by five NRC The investigation involved one hundred forty-inspectors.No items of noncompliance or deviations vptyidentified. -
Results:
e 9
l f
e 9
A M-n t U$ERNMENT ACCOUNIADILITY PROJECT hs: rate f: Pokey Studies 5 90 Gse Stree:. N.W.. weshingten. D C. 20039 (202)2x C0 March 19,1984 Mr. Richard C. DeYoung Director. Inspection and Inforcement 1
U.S. Nuclear Regulatory Comission Washington, D.C.
20555
Dear Mr. DeYoung:
In the past several weeks, the Government Accountability Project (GAP) has had intensive dealings with whistleblowers in the Region IV area.
These workers and former workers come principly from two nuclear plant sites under construction--
Comanche Peak and Waterford.
Although our findings, at this point, cannot even be categorized as " preliminary" at either location, we have been extremely disturbed by evidence of historical lack of oversight at both sites.
Further, we are disturbed that the posture of the agency throughout the licensing hearings, and in its daily operation, reflects such a blatant and biased
- pro-utility, regardless of the facts,"
attitude.
}
Today, we have filed a request, pursuant to 10 C.F.R. 2.206, regarding the Comanche Peak site.
In that request, we have asked the Comission for the following immediate actions:
i 1.
Require a comprehensive management audit of the Texas Utilities and Generating Company (TUGCO) officials by an independent management auditing firm to assess the c'ause of the continuing inability of TUGC0 and its contractors to implement an acceptable design and con-struction program for the Comanche Peak site that meets the require-ments of 10 C.F.R. 50, Appendix B.
l 2.
Require an independent design and construction verification program (IDVCP) to essess the integrity of the Comanche Peak site quality assurance (QA) program.
3.
Suspend the Comanche Peak Construction Perr.it until the completion of the special NRC inspection and IDVCP, and an analysis of the results of those inspections which should include public participation, to determine the appropriateness of further audit or other requirements.
1 We sincerely believe that the only way to get the Comanche Peak site under inmediate control, and avoid arty further destruction of documentation, and equally important.
4 I
to restore the confidence of the workforce in the NRC, is for you to issue an i
issnedtate Stop Work Order on the site.
Finally, we believe that an appointment of a separate inspection team made up on Comission employees from the Office of Nuclear Reactor Regulation (NRR) and other regions is necessary to do an adequate and unbiase:i probe into the extent of the QA design and hardware deficiencies at the Comanche Peak site.
3Jkmrn26h i
he s*-'w--'
w.w 3,,.-e-,- w - -.-_.
,,,.w
,m>
w%,,w-
---.ew.e,
---,rr-,,_m--.-r,r--
l
- P.-
{.,charc C. Debung 6.erch 15,159 1 -
As you any recall, GAP did an analysis of the generic defects and weaknesses in the NRC Inspection and Investigation Process which we presented to Congress in June,1g83.
i We have found that almost (11 of the defects we identified apply to Region IV. Sun-marized he'iow, those are:
A.
In its approach _ to whistleblowers. Reoion IV has:
1.
violated the confidentiality of whistleblowers, either directly or indirectly; 2.
narrowly defined issues raised by whistleblowers and failed to inspect beyond hardware examples the witness was able to identify specifically; 3.
failed to record interviews or take affidavits, particularly on the 4
most significant issues being raised by whistleblowers; l
4 failed to include affidavits in the public reports when the statements.
contradicted the NRC's party-line on the problems at nuclear plants; 5
failed to keep pace with new whistleblower allegations in a timely manner; B.
In its approach to utilities, Recion IV has:
6.
conducted closed-door meetings with utility and contractor: executives "
)
when investigating whistleblower allegations; 7.
provided advance warning to utilities about where and when Region !Y was going to inspect hardware; 8.
relied on industry's technical conclusions without disclosure of sup-porting data and calculations for evaluation of whistleblower allegations; g.
offered advance, informal review of decisions to the targets of Region IV investigations and inspections, thereby permitting utilities to escape accountability through informal, often-unenforced comitments "not to do it again;*
1 l
- 10. reviewed and informally approved licensee practices before approved by corporate officials with QA responsibilities thereby undercutting the l
employees who tried to carry out their duties objectively despite the pressure of management urgings that "it's all right with Region !Y, so why are you holding this up?
l l
1 C.
In its approach to the public, the NRC has:
1
- 11. attempted, as a knee-jerk reaction, to discredit critics--whether whistle.
blowers, anti-nuclear organizations, or simply interested and concerned citizens--by questioning their motivations, patriotism, integrity, and technical competence to raise questions about public health and safety;
- 12. destroyed drafts of reports, significant tape recordings, created secret i
files, failed to admit the existence of documents requested under the f
Freedom of Information Act (FO!A), and given confidentiality to utility i
executives in order to prevent the public f rom learning how inspectior.
findings were covered up.
We are aware that there are turrently internal investigations going on regarding the cctions of Region IV employees.
We believe that many of our witnesses have information which will be relevant to those investigations.
A copy of this letter has been given to that office.
We also respectfully suggest that you consider instituting your own review and audit of the regulatory policies being implemented i'n your Region IV office.
We believe that a rigorous audit and inspection by other regional inspection and enforcement personnel would provide you with insight into the cause and the extent of the problems in that region.
Pleese notify me immediately concerning your decisions regarding Comanche Peak. As you will note on Page 6 of the 2.206 request, the method by which GAP will handle the restTha of its investigation will depend on the agency's response.
to this matter.
Sincerely.
~
I S
O e
S e
e W
+ ~ ~ - - - - -,,, _ _ _ _
e,
.N, w,,'.:
.I r. s.'.. s a 1.:: :. :e :
- ..ey 5
- ..c:.e>
iCO: Cse 5:ree: N.V., vesNnct=n D.C 20337 (202)2h March 19,1954 Honorable Chairman Nunzio Palladino Monorable Victor Gilinsky Honorable James Asseltine Honorable Thomas Roberts Honorable Frederick Bernthal United States Ibclear Regula;ory Cc.tmission Washington, D.C.
20555 Re:
Petition pursuant to 10 C.F.R. 2.206 Comanche Peak
Dear Commissioners:
On behalf of the Citizens Association for Sound Energy (CASE) and numerous nuclear workers on the Comanche Peak Steam Electric Station,.tps Government A:countabili-Project (GAP) requests that the Nucleai Regulatory Cor=6ssion (MRC) take 1::::ediate action to protect the public health and safety of local Texas residents througr. the following actions:
W 1.
Require a comprehensive management audit of the Texas Utilities and Generating Company (TUGCO) officials by an independent management auditing firm to assess the cause of the continaing inability of TW:3 and its contractors te implement an acceptable design and constructica program for the* Comanche Peak site that meets the requ irements of 10 C.F.R. 50, Appendix 8.
2.
Require an independent design and construction verification prcgrar (I,','Cr to assess the integrity of the Ccmanche Peak sita 4ttality assurance (QA) program.
This should be acco=plished through a Director's Order for:
a.
An irenediate Step ork Order to hait the current destruction, mani pul a t f o r.,
and alleged f alsificaticn of docu-ents, b.
The assigrrnent of an !!RC special inspection taad# to deter. tine the extent of the problems with both the design doc:, ment.a t!on and the construction ceficiencies at tne plant. (This si.ould be 1/ ecause of historical and on-going :;ue:tions regarding the ability And t*:S B
willingness of the Regir,nal c:::cc: len Ar.r. Er.f* rcecent (!!) sta'f to efetcuvelj inspect and aucit pecale.n at tne "c.anche F edi. fa 41./. we s;:ccifically rec.tr :
that the special inspect. ion team te comprised of selected members of !;?.P. snd E
from other regions who have experier.ce in detero* nation of design /constructier.
problems at near-co=pleted facilities.
904 t-7c#-~
49
..1 V..r.!. M,
donc through an ir.,ediate inspection eudit of docunentation in both the perr.anent vau11 anc the field ' satellite
- stations.
coupled with the requested independent essessment of the hardware
~
on the site throuch matching docucentation to the *as-built
- con-dition of the plant.)
3.
Suspend the Con.anche Peak Construction Pernit until the completion of the special liRC inspection and IDVCP, and an analysis of the results of those inspections which should include public partici-pation, to detercine the appropriateness of further audit or other requi remen ts. 2,/
1.
BAtr. GROUND Coranche Peck is a two unit reactor under construction near Dallas, Texas.
It is being built by the electricity generating branch of the Texes Utilitie Electric Company (Texas Utilities Generating Company).
The prime contractor for the plant is Brown and Root (B&R), and there are numerous vendors and sub contractors engaged in the construction of the plant.
Tne architect enginee (AE) is Gibbs and Hill.
The request for a construction permit was filed in 1974, and ' construction actually began in late 1974.
The plant is now, according to TUGCO, in two stages of completion:
Unit 1 is allegedly 97 percent complete, and Unit 2 is allegedly 65 percent' complete.
Historically, Comanche Peak has had.its share 4,f regulatory difficulties.
However,'in the past two years, the inside s',ry of the Cocenche Peak plant has become widely known to the public af ter v.r. Charles Atchison, a~ former Quality Control (OC) Inspector, was fir ior revealing sa fety concerns eboel the vendor QC program.
As you a re a wa re, Mr. Atchison took his complaint 10-the Department of Labor under the provisions established by Section 19 of tr :
Energy Reorger.ization Act.
He won his case at every level of D.0.L., but th company refused to hire him back.
(Subsequently, he secured two cther ;tsit.
with nuclear industry subcontractors, and i.unediately lost his jobs because.
the " blacklisting" done by ESR.)
The Atchison case has become the test case the whistleblower protection act.
P.ecer.ily EER tool its a rcuments to the f Circuit Court of Appeals.
GAP recognized the icportance of this cese, nr.i filed an A.icus Curiae Brief explair.ing to the Court the importante of the whistleblower protection act as it plays a role in the day-te-day life of a nuclear power plant construction project.
Unfortunately for both the workforce and the public, Mr..Atchison's plight i-not an isolated incident.
Since his firin5, more workers have filed D.O.L.
cor. plaints against their employers at the Comanche peak site.
Some former workers have also volunteered to testify in the Operating License hearings.
In particular, two former Comanche peat engineers, Mr. Mart k'alsh and P.r. Ja Doyle have participated in the Operating ticense f. earings on the subject of e
inadequate end flawed concept that was ecployed in the design and construt.i:
of the Comnche Peak facility.
This " iter t ive" des i ;n proces s is currer. '. c the subject of a major contention before the Atomic Sa fety end Licensir.g ' m (Board).
2/m.
..u,.
a _.,
,r...
, s. n 4, u _
c,....
...,v.
i In December,15E3, the Board issued an Order which found that the
- iterative
- design process was not accectable.
They have required TUGC0 te file a plan which would assure the Board that the plant "as built" could operate witno;t endangering the public health and safety.
Hearings on the various proposais for that review are on-going.
It is TUGC0's position that the CYGNA Corpora-tion, a company which performed an Independent Assessment Program (]AP) tr.rca-h the past eight months, should also be allowed to do an appraisal which woule alleviate the Board's concerns.
The intervenors, the Citizens Association for Sound Energy (CASE), reject that suggestion, on a variety of grounds.
These include the recent admission that CYGNA had pre-notified TUGC0 about the design packages it was going to review ar a final check on its appraisal, and i
its refusal of CYGNA to produce any engineers to explain the report conclusions Intervenors maintain CYGNA's review was neither independent nor adequate.
since the disclosure about CYGNA, GAP has been involved in reviewing the pechlems at the Comanche Peak site on.a full-time basis.
Our own preliminary investigation will take approximately another 60 days.
However, the infortatio:
that we have received to this point convinces us that the recuests for i=.ediat:
action by the Commission are the minimum necessary to begin to get the Comanche Peat site under regulatory control.
1
\\
II. LEGAL BASIS A.
Leoal Recuirements The law gives the Ccamission broad discretion tg revoke, suspend, or nocify l
the constructions permit of an GRC licensee.
42 U.S.C. 52236 states that:
A license or construction permit may be revoked, suspended, or modified in whcle or in part, for any material false statement in the application fer license or in the supplemental or other statement of fact required by the applicant; or because of conditions revealed by the application for license of statement of fact or any report, record, inspection, or other means whien would warrant the Cc= mission to refuse to grant a license on an original application; or'for failure te construft or Operate o facility in accordance with the terms of the construction permit of license or the technical specifications in the application; er for the violation of or failure to observe any of the terms and
-provisions of this chapter or of any regulation of the Commission.
Part 50.103 of Title 10 of the Code of Fedcral Regulations states the s:me criteria for the revocation, suspension, or modification of a construction permit.
The NRC has a mandatory duty to exercise this authority when necessary.
According to the decision in Natural Resources Defense Council vs. U.S. *;uclece Resulatory Co= mission, 523 F.2c 166 (2ncGir.197d), uncer tne Atonic Energy -T;." of 1954, tne NRC is required to determine that there will be adequate protecticr. c' tm health and safety of the public.
The issue of safety F.ust be resolved before tre Co ~.ission issues a construction otrmit.
f r1rt er C it i Ch. o f 12:4k *.'n!Iih..,.. :
Atomic Energy Com.ission, 515 F.2d 513, 524 (7tn'CiCTi?5).)
- 'wmv.-
c' re ^ en -w-
-wo,.w. wee-v,.
-,-,-,,w,,--,_.7,.,
_,,,,,,,,wm__m.,,,._,,p,%,,,,,,.,,,,,,,,
_..,_,,-,,._._.7_._
E.
Criteria to Exercise Dis:retton A: cording to 10 C.F.R. j?.206 the NRC "t'ay institute a pec:eeding to ::dify suspend, or revoke a license or for such other action as may be proper by serving on the licensee an order to show cause which will:
(1) allege the violations witn w 1:i the 1,icensee is charged, or the potentially hazardous conditions or other facts :eem!
, to be sufficient ground for the proposed action.'
As interpreted by the Prce: sed General 5:stement of Policy and Pro:edure fer Enforcement Action, published in t5e Federal Register, 4a Fed. Rec. 66754, Oct. 7.1980 (10 C.F.R. j2.202, 2.204), ss s pend-orders can be used to remove a threat to the pubile health and safety, the ccm on defense and security or the environment.
More specifically, suspension orders can be issued to stop facility constru-s tion when further work would preclude or significantly hinder the identification ar.3 correction of an impreperly constructed safety-related syste= or component; er if the licensee's quality assurance program implementation is not adequate and effe:tive to provide confiden:e that construction activities are being properly carried out.
More over, orders can be issued when the licensee has not responded adequately to other enforcement action or when the licensee interferes with the condu:t of an inspect ~ ion or investiga, tion or for any reason not mentioned above for which the license revocat-is legally authorized.
In order to help determine the significance of violations within this list, the Cc= mission established " severity categories" ranging from the most serious structural flaws (Severity I), to minor technicalities (Severity Yl). -
44 Fed. Reg. a t 66758-59.
GAP cites as pre:edent in this case the November 12, 1982 Show Cause Order issued by the Consission to the Cincinnati Gas and Electric Company regarding the Zimmer Nu: lear Power Plant._3/
In that case, the Comnrission ordered the utility to "show cause" why conste:
tion should not be halted.
At the time the Zimmer plant, similar to Comanche #aak,4 nearing completion when the discovery of numerous quality assurance problems ir. : 9-struction were brought to the attention of the agency by whistleblowers throu2h GAP.1 i
In this case, a similar situation has develcped with the recent discovery o-numerous construction and design quality assurance deficiencies at the site.
Also, similar to the Zimmer situation, is the Regional Inspection and Enfors ment staff's failure to identify the nature and extent of the QA breakdown thenugtou' the life of the plant.
C.
Soe:ific Bases for suspension The Co=r.ission clearly has both the duty and the discretion to suspent the f
Cor.an:he Peak Construction Permit at this time.
2/See Order to Show Cause and Order Immediately Suspending Construction, Cincir.nati Gas and Electric Cemoany, et al., (Zi.?ner Nuclear Power Plant), CLI 32-33.
{ November 12, 1932).
$/Id. at 1.
L
D. ir:
St ;:st se,e zi r. ntns, U3:0 h s censr.itrated en en.illingness
- srs t the einica ne:essary ect-itment to co ;1y with the laws anc pro:edares surrcunding the construction of nu: lear po-cr pl a nts.
Th'e Government Accountability Prcject (GAP) has been indirectly monitorin; the Coman:he Peak croject sin:e Jer.u: y, II 3, sh2n tit firing of :P.trias At:his:. i brou;ht t: sur attantien by :15 cad :). atchis:n.
Our initial review of the documents surrounding that incident, the inaceast '
of the NRC staff's resolution, and the staff and TUGCO's f ailure to recognize the seriousness of the underlying causes and results of company actions taken agsir.s Mr Atchison caused our initial concern.
In reccht weeks, our role at the Coman:he Fe!,
site has in:reased dramatically.
Former anc current workers have sought GAP's le;sil and investigative services in unprecedented numbers.
Incorporated in this Petiti:n.
is a sum =ary of the issues presented in affidavits which are being submitted to the NR;'s Office of Investigation (01).
Those affidavits represent only the first group of completed statements fr:
former and current workers who wish to make the HRC aware of serious construction er documentation deficiencies on the site.
However, because of the serious and i= media nature of the allegations that are contained in these affidavits, we have decice: tr it is critical we submit them to the agency as soon as possible to prevent further destruction or falsification of documents, harassment and intimidation, terminatior employees, and to insure that the NRC 01 investigators have every opportunity to tai necessary immediate action if our request for an immediate Stop Work Order is grante In the event: that such an order is granted, GAP cWamits to im=ediate and '
cooperation with the OI staff investigators and to supplying information, affidavit '
and sup/ porting documentation which we are provided with by the Comanche Peak work-force.2 In the event that a Stop Work Order is not granted i= mediately, we will :o tinue to supply the same information.
However, we will proceed according tc G;P's normal (and unfortunately slower) procedures of presenting the agency only form:li:
affidavits and sworn statements under grants of confidentiality.
Further, GAP recognizes that the burden of proving the need for the re:ues relief is ours.
We have balanced that need, with the concern over a timely suc-is; to the agency of information of immediate releven:e to the OI investigators.
- is e fore, in deference to the latter, we request that.the Commission allow GAP to su;
- 1 this request at a later date, not to exceed 60 deys, at the completion of GAP's preliminary investigation into the Co..anche Pest project.
III. SUMM*RY OF ISSUES RAISED IN AFFIDA'.*ITS SU3MITTED TO THE NRC OFFICE OF INVESTICATION The following list is a summary of the issues raised in the affidavits s ab.itt-today to the NRC's Office of Investigation.
These affidavits have been submitte:
b/ s the Co= mission is well aware, gap investigators negotiate scperately.".
A each witness the terms and conditiens under whic:. ne/she will provide infor. s:::n :
us and, in turn, to the NRC.
See generally, Consumers Power Company (Midlanc plant Units 1 and 2), Docket Numbers 50-329/330 Ont0'.
v------
e
>N e---
).'
the Oire: tor. Mr.- 5cn Hayes.
We expe:t tha t the af fidavits. a nd subsecuer. 0: a r.d investigations and inspe:tions will be revie-ed by the Commission and/or the circ:.:
in making the determination whether or not to gra nt both the trnmediate relief s;.,gr.t this matter. as well as the suspension of the constructior, permit until su:h tt=e as '
the Com.ission is able to determine the extent cf the problems at the Comanche peax i
faci,lity and the appropriate solutions.
i We feel a need to communicate a sense of urgency to the Comission in regard tc the deterioration of conditions on-site at Comanche Peak.
Within the past few ment -
several major " players" in the QA*and documentation breakdown have resigned or lef t the site. fir. Ron Tolson, the QA Project Manager, and Mr. Frank Strand, a Ds:'.:sen-Control management official, are no longer in the positions of authority after abre; j
and unexpected staff changes.
Our sources indicate that documents are' being altered and shuttled around in a wholesale manner as the company scrambles to erase traces of falsification, sis-matching, and other problems with documentation.
The sue: nary list follows:
1.
Assignment of heat numbers in the field to materials used in safety-related construction, l
2.
Back-fitting of allegedly final components ready for turnover.
l 3.
Downgrading safety-relatell material to non-safety-related to avoid ANI review (material is actually still in a safety-related systen).
4 Improper use of inter-office memos (IOM) to disposition non-confor=sn:e reports, or make changes that would be otherwise unauthorized.
5 Lack of material traceability for numerous, hardware components.
6.
Lack of proper QC inspector training, and evidence of widespread j
cheating on QC tests.
7.
Institutionalized lack of independen:e of the QA/QC functicn from 1
production.
8.
Use of un:entro11ed drawings and other design documentation to ir.spect and build the plant.
l 9.
Lack of vendor document control.
10.
Undocumented repairs (" bootlegging"), af ter the final QC signoff.
11.
Harassment and intimidation of QC inspectors.
12.
Falsification of safety-related do:umentation.
13.
Failure to follow blueorints followed by "as-built" program to legitimize the practice.
14 Pre-notification to areas and of documentation to be inspected by auct:
j teams, and by the NRC.
i
l 15.
Tete 11y out-of-control docu-entation.
16 Failure to protect perr.anent records in fire-proof valuts.
17.
Upgrading ncn-safety-related material to sa fety-related through the use of informal inter-office memos. and other unacceptable procedures.
- 18. Material false statements by plant management to the Atomic Safety and Licensing Board.
19.
Unauthorized issuance and use of the " controlled" starps by the DC Department used to indicate valid inspections of safety-related materials.
20 Inadequate staffing of document control offices, making it in.possible to keep up with the demands of craft and QC.
21.
Intentional cover-up of known de'f tetencies in the document control -
system.
22 Inadequate and unreliable documentations of design changes and drawings.
23.
Lack of control of safety-related drawing documentation by allowing craft to obtain portions of document packages instead of the complete packege, as required,by procedure.
24 Widespread drug abuse and management inattention to the prob 1b.
~
25.
Alteration of final design drawings.
26 Failure in the cleanliness inspection program for component maintenance IV.
CONCLUSION i
By separate lettee, we have provided the Director. Mr. Richard C. DeYoung, wi h t
copy of this recuest and esked for his immediate response to those items identified in this letter.
The affidavits will be supplied to 01, and we have provided copies of this request to the Atomic Safety and Licensing Board with a
(
Limited Appearance Statement filed today.
We look forward to completing our ewn preliminary investigation and providing furthe:
information to the Commission.
I Sincerely.
1
_. _ - _ ~ - - -,
\\
- t..
~ :..
- i... u. s.;
. - i.,:
executives in order to prevent the public frc: learning how inspection findings were covered up.
We are aware that there are turrently internal investigations geing on regarding the actions of Region IV employees.
We believe that many of our witnesses have informatio which will be relevant to those investigations.
A copy of this letter has been given to that of fice.
We also respectfully suggest that you consider instituting your own review and audit of the regulatory policies being implemented fn your Region IV office.
We believe tha' a rigorous audit and inspection by other regional inspection and enforcement personnel:
would provide you with insight into the cause and the extent of the problems in that region.
Please notify me icrnediately concerning your decisions reg"arding Comanche Peak.
As yo will note on Page 6 of the 2.206 request, the method by which GAP will handle the rest' of its investigation will depend on the agency's response.
Thank you for your attenti-to this matter.
Sincerely.
~
Citizens C nic i
.e 3.. 4 6,.....
,.. m.
j
.,_._--,,-,.-,w--------e---
- - * - - - ~ - - - " - - -
Ut;!!ID STA1:5 DF Av.IF.lCA NUCLE AR F.EGULATDP.Y CD't';15510A EEFORE THE ATDF.1C SArrTY A'iD LICEt:51NG BOARD In the Matter of
)
TEXAS UTILITIES GENERATING COMPANY.
Docket Hos.
50-445 and et al 50-446 (Coman:he Peak Steam Electric Station. )
Units 1 and 2)
)
).
L1HITEDAPPEdRANCESTATEMENT E
My name is I en the hhe CitiEens Cliiiic' of t Government Ac' countability' Project (GAP).
The Government A: countability Project is a project of the Institute for Policy Studies, Wasington, D.C.
The purpose of the pt ogram is to broaden the understanding of the vital role of public and corporate employees in preventing waste and corruption, to offer legal and strategic counsel to whistlebicwers, to provide a unique legal education for law students, to bring meaningful and significant refonn to the government workplace, and to expose government a:tions that are repressive, wateful or illegal, and that pose a threat to the health and safety of the American public.
Presently, the Project provides a program of multi-level assistance for government employees who report illegal, wasteful, or improper actions by their agencies.
GAP regularly monitors governmental refor:r.s, '
offers expertise to Executive Branch offices and agencies, and responds to requests by Congress and state legislatures for analysis of legis1'ation to make countable to the public.
< g $(f d.
[
r m
~
3
~
O
., ;'.;'. i: 1.: : i t.: :J.;; m.* ; s. t.T
' ' O: E!Ltli r*EhiE C*?.OI De ge 2 GAP's Citizens Clinic is a citi2 ens training, consulting, and so:tal a,ctivist program for local " grassroots.* public interest, community, and chur:h groups.
This program is designed to assist and direct citizen involvement. Its role is to provide a range of services to individuals or groups who begin to speak out about problems spawned by corporate or government ineptitude or mal feasance.
The Clinic's focus is on assisting citizens to effectively use their First Amendment rights to expose or address significant issues.
The Clinic addresses health and safety concerns, consumer fraud, corporate
" rip-offs,* pollution, governmeh mis *c~o'n"PEI" abuse or inaction, and the abridg-ment of individual rights that of ten accompanies the struggle of citizens to redress their grietances, 4( c In recent years, GAP has been approached by a growing number of witnesses from nuclear. power plants under construction across the nation.
In keeping with its objectives, both the GAP Whistleblower Review Panel and the Citizens Clinic Review Board have directed staff to pursue aggressively the complaints and problams that nuclear workers bring forward.
GAP is not an " anti-nuclear" organication.
Its objectives within the nuclear industry are the elimination of the government's misconduct and inaction..
the uncovering of facts that warrant closer scrutiny or regulatory action by the Nuclear Regulatory Commission (NRC), and monitoring of how the f.RC deals with significant information provided by nuclear "whistleblowers."
This Clinic assumes that nuclear-related issues are critically important to the public safety, and acts upon evidence that the flRC is doing an inadegaate job regulating the nuclear industry that govce nment created.
Nuclear whistlet*:sers.
the central figures in our approach to nuc1 car-related work, are the vital e
eo e oo.
m
.a e
..me.,
e < en
-a
= =.
~
b 5
ti b.
Page 3
.\\.
components in the struggle for safe energy and making the public awre of dan o,r questionable conditions.
GAP's involvement with Comanche Peak began a year ago when we learned of t
what happened to) at t.he Comanche Peak site.
The details of firing were familiar to us.
We have heard hundreds of similar horror stories from nuclear workers--from* management executives to document i
i clerks--across the country, what shocked us was the blatant disregard for i
l rights by his employer, Brown & Root, and more specifically, the actic taken by the NRC staff to condone the company's wrongdoing and cover up its ow flawed inspection.
In a letter which we filed with the Atomic Safety and 1.icensing Appeal BoardU we protested the actions of the Regional Staff Inspector.
Since that time, we have monitored both the NRC actions and those of Texas Utilities Generating Company (TUGCO) and Brown & Root at Comanche Peak.
We have watched the fate of other workers who have also raised proble:6s which they believed w a direct violation of approved construction procedures and 10 C.F.R. Part 50 Appendix 8.
4 This Board is familiar with many of these workers and thef allegations of flawed construction, violated vendor inspection pencedures, inadequate desi quality assurance (QA), inaccurate design doeur.entation, and pressure from mar.agement supervisors to approve faulty work and participation in unauthorized work activities.
f This 8:ard is also familiar with the type of irspections conducted into many of those allegations, and the continuous series of report cone'lusions that i
y
-,m-
,-._---,_,,.--,,-,-,,..,-y___._----,
. h: F $[:1 *! *.!i iakS*
Fege that sums.arily dismiss or r. arrow the con:arns raised by the public " whistle-bl owers. "
In reviewing these inspection reports over the past year, GAP has conc 19 sed that the entire regional inspection program is flawed.
We have propesec to Mr. Richard C. DeYoung, by separate letter today, that the Region !Y inspectior pro 2 ram be subjected to a rigorous review by an internal team of auditors and Inspection and Enforcement officials from other regions.
We have found that Regior. IV is guilty of many of the generic defects GAP identified to the Congressional Subcommittee of Investigations during a June 20, 1 983 hearing of th House Committee on Interior and Insular Affairs into the Investigation and Inspection Policies of the NP.C.
In short, Region !Y is plagued with a quality assurance breakdown of its own inspections:
A.
In its accroach to whistleblowers. Recion !v has:
1.
violated the confidentiality of whistleblowers, either directly or indirectly; 2.
narrowly defined issues raised by whistleblowers and failed to inspect beyond hardware examplet the witness was able to identify specifically; 3.
failed to reccrd interviews or take affidavits, particularly 4
on the most signficant issues being raised by whistleblowers; 4
failed to include affidavits in the public reports when the statements contradicted the NRC's party-line on the problems at nuclear plants; 5.
failed to keep pace with new whistleble ser allegations in a timely manner;
, li l'.'. i ?::*.i:_'M i F4;c i B.
In its encroach to viilities. Recion IV has:
conducted closed-door meetings with utility and contractor 6.
executives when investigating whistleblower allegations; 7.
provided advance warning to utilities about where and when Region IV was going to inspect hardware; 8.
relied on industry's technical conclusions without disclosure of supporting data and caleviations for evaluation of whistle-blower allegations; 9.
offered advance, infonnal review of decisions to the targets of Revien IV investigations and inspections, thereby permitting utilities to escape accountability through informal, often-unenforced commitments "not to do it again;"
10.
reviewed and informally approved licensee practices before approved by corporate officials with QA, responsibilities, thereby undercutting the employees who tried to carry out their duties objectively despite the pressure of management urgings that
~
"it's all right with Region IV, so why are you holding things up?"
e C.
In its amoroach to the public, the fiRC has:
11.
atta.v.pted, as a knee-jerk reaction, to discredit critics--whether whistleblowers, anti-nuclear organizations, or simply interested i
and concerned citizens--by questioning their motivations. patrio-tism, integrity, and technical ccmpetence to raise questions shcut public health and safety; 4
9 m e e e e e s.
w e
m ese m =
m pe
3 k Nd1h -lh.*.[Gdbf.....
~
bge 6 4
12.
destroyed drafts of reports, significant tape recordings created secret files. failed to admit the existence of documents requestes under the Freedom of Information Act (FOIA), and given confiden-
)
tiality to utility executives in order to prevent the public from learning how inspection findings were covered up.
Unfortunately, the result of this regional QA breakdown has been to m Board's job auch mort difficult.
Well-established agency case law prevents the Board from leaving contested matters to the staff for resolution.
Therefore, the inadequate staff effort has changed this Board's role to much more than usual in operating license cases.
We compliment this Board on its diligence and patience.
Today, W have taken steps which we hope will improve the situation wh the Board has been faced with throughout this hearing.
We have filed a petition with the Cornissioners, pursuant to 10 C.F.R. 2.206, requesting the f 1.
Require a comprehensive =anagement audit of TUGC0 officials by an independent management auditing firm to assess the cause of the continuing inability of TUGCC and its contractors to implement an acceptable design and construction program for the Comancht peak site that meats the requirements of 10 C.F.R. 50, Appendix B.
2.
Require an independent design and construction verification pro.
gram (IDVCP) to assess the integrity of the Comanche Peak site
)
QA program.
3.
Suspend the Comanche Peak Construction Permit until the comple. {
tion of the special NPC insoection at inVfD l
- -d 1
'd F. ; '. H I : ':. t.:.
,,,, CT E!:.t !! F * :'.?1. GU.??
tape 7 the,results of those inspections' which should include public participation te determine the appropriateness of further audit or other requirements.
We have attached a copy of that Petition tp this Statement, for your review.
As you will note, part of our request is for an IDVCP to be accomp'tished i conjunction with the 'NRC special inspection team--hopefully, during an tier.ediatt Stop Work Order.
We have compared the current TUGC0 proposal and its methodology with that of two other audits with which GAP has been directly involved.
TUGCO's proposa) falls far short of both.
GAP suggests that the Board consider the following observations in its review of any proposal for a Comanche Peak audit:
1.
Indeoendence and comoetence as outlined in the letter from chainu Munzio Palla,dino to Congressmen Dingell and Ottinger, February 1, 1982, regarding the auctit of the Diablo Canyon facility.
(This criteria has been further developed for situations parallel to l
Comanche Peak at the William H. Zi=er Nuclear Power Flant and the l
Midland Nuclear Power Plant.)
2.
Public particicat*cn in the detelotv ent of the methodeleev. Both Midland and Zie:ner independent audits incorporated several sets of meetings with the utility, the NRC, the third-party reviewers, and the public.
Those meetings produced a rigorous and healthy audit methodology and protocol, which are now setting the standar:
for third-party audits at other plant!--unfortunately, only when the public demands it.
l
'. :.,,tr i nt!T P*:s!* G:'!!
Ft;c 5 '
3.
Detailed methodolooy and protocel which will prevent any opportun-ity for skepticism or rejection of the results and conclusions of a third-party audit or the design and construction verification.
This must, at a minimum, include a commitment by the independent auditor to not engage in pre-notification of the utility, (or the NRC), about the specific components that will be inspected or the s
documents and design packages which will be reviewed.
- Further, the company must commit to strict adherence to the protocol to avoid any questions about the validity of the end product.
As an organization, we have participated in numerous similar meetings, molding and shaping methodologies for vendor audits,100 percent reinspections.
QA implementation reviews, and other variations on that theme.
We have assiste3 the agency in the current program on special independent audits at five sites across the country.
We urge the Board to request the assistance of the NRC staff personnel who have developed a sir.ilar broad base of experience in these types of audits to provide ~ technical assistance in the review of the audit proposal.
We also request the opportunity to submit our comments on the company's propostis-GAP has only begun a preliminary investigation.
We do not anticipate that our own preliminary investigation will be finished for another 60 days.
We have submitted to the Office of Investigation (01), affidavits from workers and for=er workers, who have concerns about the plant and its ultimate safety.
These wit-nesses have requested confidentiality.
Therefore, we refer the Board to the August 1983, Statement of Consideration which provides the established methods 3
by which this Board can receive access to the inforr.ation and affidavits which are submitted to the HRC OI office.
e=
0* El t t f ! F 1 P.N E F. G * *.DI Coranche Pen,k is a troubled project.
Our level of knowledge is limited to' the facts on the public record, embellished by the experiences of those tio;kers with whom we have the opportunity to speak.
Many of these witnesses have an understandable apprehension of entering the operating liceMt hearing as witnesse!
They do not trust the regional NRC personnel either.
We have explained to these witnesses that each organization--corporate, government, or volunteer
- is made up of good and bad people, of competent and incompetent professionals. We believe that there is a comitment on the part of this Board to get to the extent and.the course of the problems.
We sincerely hope the Board succeeds.
Dated this 19th day of March,1984.
l MThis letter was treated by the Appeals Board as an Amicus Curiae ane not allowed into the record as *cn timely."
..._r_.
r n
c d
hECLIy5o TEXAS UTILITIES GENERATING COME4,NY OrrICE MEMOR ANDUM u M 984 7,
A. Vega cien no. r sub w _
COMANCHE PEAK STEAM ELECTRIC STATION NCR M-84-01840 The surface area involved in your memo TUO-2289 dated August 14, 1984 has been included in the Protective Coatings Exempt Log. Entry 651, a copy of which is attached.
Should you need any further information, please advise.
i' f
i
}/
/
it.\\Meft tt, &.
T.
Pro et Gene 1 Manager s
JTM:RGT: pew s
Attachment cc:
B. C. Scott F01A-85-59 3 3,g
y h
.D R
8 0
E D
~
4 e
osM g'g a$
a n
\\.
69
~
j Qb
.g
\\9 5
0 4 L 5h E
w e
Pl N g
3.
3 3
N
%w.
- th
^d 3
u w
N a a$ p(
=s j a
2 s
s e 31 b
d 4
9 r'
0 0
=
k h
U I
" d
.9[)
O-9
- G 43 3
s l
E
@J g (;
w j
W e
o g q ge dE v
w 6
u) a e
2 a
e h.igi33 1;6%9hjl)e q
b-p M5 ups a n a$I g
8 1 8 5 l}' D t i $
lj 3
s w
2 *$ g % g lg 9
e 5!!l!l$' sic)gg,f.g"$6ja d
9 r
MJpl{w!)h8bN1s 9 jji 3
t
+
4 A
a e..
1 M r9 gm q ).
t u ;e
@; u
~
3 9
ae 3-k@$k eh f5b hEN lb 4 4 bli
)
hdf.hhYjh~~ h'
% ' td.!4,!!h$$5[ih. f.
n.
uWf..1,
^
& p.4
-.. o
<tue42as..
TEXAS UTILITIES GENERATING COMPANT OTTICE MEMOR ANDUM To J. T. Merritt Glen twe. Texa.
August 14. 1984 Subjwt NCR M-84-01840 The subject drug related NCR has been dispositioned to reinspect a sample of inspections performed by the involved QC personnel.
One Protective Coating Inspector was engaged only in the inspection of steel substrate surfaces. In order to perform a verification of this Inspectors work a destructive test (adhesion test) must be performe 1.
In lieu of performing adhesion tests to verify these inspections acceptable Engineering approval is requested to place approximately 379.06 square feet of hanger surface areas on the exempt log.
Please advise the undersigned or B. C. Scott of your decision.
{
AV/BCS/bil
\\
k
Disposition of NOR M-84-01840 A reinspection has been conducted to determine if the QA/QC personnel addressed by this NCR had performed their assigned tasks in an acceptable manner.
QA/QC personnelinvolved are:
A)
A. Ambrose, SSN 189-44-2515, Electrical Inspector (Non-ASME)
B)
J. Long, SSN 449-33-2856, MechanicalInspector (Non-ASME)
C)
D. Riggs SSN 459-13-2276 Thermo-Lag, Hilti Bolt Inspector (Non-ASME)
D)
S. Valdez, SSN 416-84-6789, Protective Coatings Inspector (Non-/.SME)
E)
H. King. SSN 418-64-8617 Electrical Inspector (Non-ASME)
F)
J. Barrett, SSN 458-13-0429, Protective Coatings Inspector (Non-ASME);
Mechanical Inspector ( ASME)
G)
W. Bishop, SSN 441-42-4137, Mechanical Inspector, Quality Engineer (ASME)
H)
G. Willis, SSN 409-784-7059, Quality Engineer (Non-ASME)
A statistical sample plan with appropricte sample sizes and accept / reject criteria was developed from the requirements established in ANSI Z1.4 (MIL-STD-3 35D) under general inspection Level II, single, normal inspection with an Accep able Quality Level (AQL) of 4.0.
Sampling Plan Inspector No. Inspections Sample Size Accept Reject A
1284 125 0-10 11+
B 5116 200 0-14 13+
C 169 32 1-3 4+
D 70 13 0,1 2+
E 1068 80 0-7 3+
F 50 13 0,1 2+
If reinspection of the samples randomly selected had exceeded the reject level established,100 % of that individual's work would have been reinspected.
Individuals "F" and "G" involved in ASME inspections will not have a reverification inspection performed due to at least two (2) redundant inspections by other B6R inspection personnel and an independent inspection / verification by the Authorized Nuclear Inspection (ANI) agency representing he American Society of Mechanical Engineers (ASME). See attached memorant i from G. R. Purdy dated July 18, 1984 which describes.the redundant inspec sns by B6R and the ANI.
The Non-ASME activities of Individual "F" were not reinspected but were evaluated by Engineering and the areas he had inspected (approximately 379 square feet of hanger surfaces) were added to the exempt log. The exempt log identifies areas where protective coatings may not satisfy all QA/QC requirements but which would have no safety significance if they failed.
Individual "H"
was involved in Quality Enginee-ing activities, such as procedure / instruction preparation, that required second and third level review and/or approval of his work. Therefore, reverification was not performed.
The reverification inspections were performed by certified inspection personnel.
The reject criteria established in the above sample plan was not exceeded. The inspections performed by QC personnel addressed by this NCR are considered satisfactory and therefore acceptable. Use as is.
Enclosures:
1)
Reinspections results for Inspectors "A" through "E" 2)
Engineering approval for placing approximately 375' of hanger area on protective coating exempt log
~
e.
CQ A-0047 TEXAS UTILITIES GENERATING COMPANY OTTICE MEMOR ANDUM To L. M. Popplewell Glen Rose. Texas - September 21.1984 Subject NCR M-84-0184 0 '
Transmitted herewith are NCR's E-84-100286. E-84-200287. IR's ME-1-0051000, M E-1-0050999, ME-1-0050998. M E-1-0050997, M E-1-0050995. ME-1-0050996 and an unnumbered inspectior report which documents two unsatisfactory conditions concerning thermolag application. These items were issued as a result of the recent drug related NCR M-83-01840 reverification inspections.
Please evaluate the safety implications of the items, assuming that the problems would have gone undetected.
Your prompt response is appreciated.
B. C. Scott QA Staff Engineer BCS/bil Attachments a
COMANCHE PEAK STEAM ELECTRIC STATION TDAS UTILITIES NONCONFORMANCE REPORT (NCR) g g7 GSWERATING CO.
UNIT STRUCTURE / SYSTEM ITEM /COMPO NT TAG /lO MUMSER LOCATION OR ELIVATION RIM NO.
p (ago\\ f gcg E%2)S9FA
$3OCcwi+oi&B5 p,p j
NONCONFORMING CONDITION coa E @ WRM is Not im Mih i d lM N
l Bc.co. bwe_ e rh %dg aSas Ea - o I6 o m i
b sh. ca&. w a outs.wo% scmsboy l
%pemo9 kpou-t. ET 2%%
Nob Tg AppLd8 l
O)
L
~
~
REV PARA e
RErERENCE DOCUMENT-
"" """ "7cw (h%W A4 s M P1 OATE:
QE REVIEW / APPROVAL:
$wY=
V I 2 31 1'*/
E oEPARTusNy '
Action AooREssEE Wh3 / 7t 8. W.we
~
Pos1 TION:
XX REPAIR USE AS IS SCRAP REWCRK Rework terminations of cable Efs218482 in 2-CR15 to agree with latest revision of E2-0160.
E I
s<
f(
w DATE:
QE REVIEW APPROV AL:
//
. Awou,
?i/18V dE+r oAn-i e
oisPOsmCN vEmiCATiON a CtosuaE:
y y
COMMENTS:
4 l
-4ee y
w
-.,-,e..--.r
-,w.-.+------.-----e-g
+w.
cm.ere-w
,--------------ec y-.w-wr 7
=7 "7
i
\\
COM AN CHE PEAx STEAM ELECTRIC S TATION i
g>erv*
/ or INSPECTION REPORT l=a,j, g j g,
ITD6 OEscuPTiom
- 0EMTIF16ATIQm MQ.
4T&TLM / 5TAWCTURE CE,siem47)ori CONDUIT RACEWAY SYSTEM r C/3c/ / 5959 s
PSr 3 c #
4 EPEC.MCA REv.
REF. Q.C. Occ. & REv. & Cnam&E MQ.
w m L QR TE5T ECh.nP. iOLNT. No.
01-0P-11.10-1 Rev. &
ed ES-100 s
2 e
v O l",3,ccyo, OP",r,7cirgnoa O T,8,?t#,*"
5 T,, ie, O q,y,t ne, c
IMSP. RE.5 ULT 3 b MSPCcTION CoWPLETED, ALL APPUCASLI ITD83 1AT1$ FACTORY h[ hl 9 " A
- Y*/
O insPccTx= ceWm.zTen, unsansracTony iToss usTro eEto.
io J
ITEM Mo.
8C INSPECTION ATTRIBUTES
- carg p,,
s e=
E e
n 1.
Verify support attachment per Para. 3.5.1.
4 l l
2.
Verify support assembly per Para. 3.5.2.
l l l l
3.
Verify syocort capacity and/or span per Para 3.5.3.
l l
l 4.
Verify support welds acceptable per Para. 3.5.3.11.
l l_
5.
Verify support backfit acceptable per Para. 3.8.2.d.
y SUPPORT SE00ENCE & TYPE UNIOUE NUMBER I REMARKS W s I
ORIGIN 4
l TA t S x. tant as:k.
M$
@N ~
l' d-I llNf'ORM/ irau R is9sp-t J
l 1; A
l l
~lE $
'"00hc/l/s 9s9 -l
> k A
1 Gd xM lIl T 1 M9 E/P119A uA 47; ul l
l %* L_2 W" Yi l
l l
j J
I 4.
f l
PPR /
w N
J A A>w 1.. w w ws/E,Aw L PN V l l l 4 K 1s? c tc al. deLJ r en-l l \\
%,r w w e x->J9W sm.
l l i
/$l>&> ' e ?A,41 a m MA,osts l l ld trL.J.
L t h v l l l
l l l l l
l l
l l l
l ROSAAMI (DWei,3Ptes, ETc.)
- Room No. /co A Per Paragraph 3.7:
a.
Bearing is SAT, all supports 4
b.
Exceptions listed on IR BP eg l
NOTE: Origin arJ end points not inspected on this IR.
I w
M sic =ATuns NS "C8 "C
- lg,g,etc3go g
oc msPtcTon
,a
- xy; jy PERM. PLT. RECORD RTN FILE. LOC-L l '/.l.99.'21 TI.;ii.e i.oci.'
CONDUlT NO.
.. ~'
COM AN CHE PE.AK STEAM ELECTRIC S TATION i er i m
INSPECTION REPORT l=o ggg ITDs OESCRAFTION CLNTIFaGATacM NQ.
&T& TEM / STRUCrg4E CEssnAr,on CONDUIT RACEWAY SYSTEM rC80'/Se75P i 852 -M i 5PLC.nc-AEN.
ALF. Q.C. Doc. 4 AEv. & CManst no.
G RE OR T E5i EQuar. e0E.a T. ac.
s ES-100 s
- 2 e
01-0P-11.10-1 Rev.
A'9 y
eM CDCn VER T
SP TlQ l
t: ton INSPE T1CN e
LMSP. RE31A.73 EinsPC"10M COMPLETED, ALL APPUC.Asd ITEMS SATtsFACTCRY y,
pj 4
p j,pg
- ^
' O insec:non couPuTrm, uasAnsrActent iTras usns ec.o-INSPECTION ATTRIBUTES
- k OATE e-i sic =ATunt,.
1.
Verify support attachment per Para. 3.5.1.
4e! l l
2.
Verify support assembly per Para. 3.5.2.
l l l l
3.
Verify sycoort capacity an:!/or scan per Para 3.5.3.
l l l E-l 4.
Verify succort welds acceptable per Para. 3.5.3.11.
l l
l
~
n. li 1
g 5.
Verify support backfit acceptable per Para. 3.8.2.d.
-SUPPORT SEOUENCE & TYPE UNIQUE NUMBER REMARKS l _Co d'i SD 36 /5 eo u d e%
hl l N CI 1 ORIGIN
- n i
tr \\RH Vth
.Ul\\
uwissgr-I
+
l l *% 9
\\
2 4 - - - n r 3r e, W esy s9 - l l
l l l
E Ed N
$ hU N f f V 219 3 L A M
l l
l 1 > V' A l
E l
s
\\m m'%11 f f 1V l
l
~
l i
l Al'i.n av m Jrid%L L ppg /
.1 l l l
II l
l o ttizL< J--f w -
l l?
l 14 7E 1x L T Ar,
_,n w w,,
. i/W cw_. 0,~1 l
6
@ Q Im E.m d-a.c~on L, A M./%L -
l l l
1 lu Mt,
l l ll
\\
a.
l l l l
l l
1 I
nosAan towes, set:s, rTc.)
- Room No. /oo A Bearing is SAT, all supports #
Per Paragraph 3.7:
a.
b.
Exceptions listed on IR BP e y:
NOTE: Origin and end points not inspected on this IR.
.a
"*8
- ee -- e
_3**7'",'g t.R. CLOSED O
w c r=spEcToR PERM. PLT. RECORD 1 FALL.'O C-FRTN t.
T 1 h!:.?'A' SUBF8LE LOC. h4DulT NO.
.CO
,_,&..,w,,
,,,.,,_3
_,,,,-,._y.m.y_
-my
... ~
_. ~..
COM AN CHE PEAX STEAM ELECTRIC S TAIlCN s>tn / er /
INSPECTION REPORT lac _g,93g[
iTD8 OE5cAWTem g 6f.ChTlFeGATeQ4 peQ.
%T& TEM / 5TRuCTURL pc,*,aT;on CONDUIT RACEWAY SYSTEM 2.3 C/5d /595 7 J
PS2 54 /
5PT.G.MC.
ACV.
Rff. Q.C. OCC. & AEv. & CMANGE no, asea 5wAE OR TL5T EQunP. 6CLNT. NO.
ES-100 s
.2 s 01-0P-11.10-1 Rev. JT e'A T
Ol",SiePo, OParggrioa Olays,tgo" E P,y,,e,,,
OP;tyne, c s 2
e y
iM5P. RESULT 3
[;,,j f, / [,,
g* /. PM b MSPCCDON COMPLETtD, ALL AMUCA8Le ITD45 1AT1sFAcTCRT
' O inspeenoa ecuptrTro, unsAnsrAc cat artus ustro artew
,N, sigbg INSPECTION ATTRIBUTES DATE
,Y -
!i e
1.
Verify support attachment per Para. 3.5.1.
bd l l
2.
Verify support assembly per Para. 3.5.2.
l l 7 ll l
3.
Verify syoport capacity and/or scan per Para 3.S.3.
4.
Verify support welds acceptable per Para. 3.5.3.11.
- l l A
Wg 5.
Verify support backfit acceptable per Para. 3.8.2.d.
'y :
SUPPORT SE0VENCE & TYPE UNIOUE NUMBER REMARKS M~
ORIGIN
/#
Tt3/5 A u of N4 ll 5
~~
l' s cod is 9sw - I N
l\\
l
~
a i
\\ r0R VIA U T c,v eses,- /
I t
1 m aar w C/ N /5457-1 4
l 3
lI 4
4 'K 1R.7 V 4
i e
e Ed A'US A
ITV ar93 rA A
l l
lJ
AV r
l l
l fL x J-mx = ppw l
l JJ 7L rg L
+1 sL.. o nL 3 e e-.
I 1
as Ann-a n e H9: r k - (L L.
II s.
I o, ,-m i Abe:m t L ni/tLIJ l l I
li /A&.
llI I
^
1 II I
l l
noaAna (owas, spec 5, ric 1
- Room No. /M A Per Paragraph 3.7:
a.
Bearing is SAT, all supports 4!
l b.
Exceptions listed on IR BP
,e >pr NOTE: Origin and end points not/ inspected on this IR.
I a
DATE 1
ar_ATED nca =c e l 1.R. CLCSED r;
siaNATuns l
jp
-a oc insetcTer PERM. PLT. RECORD RTN g,gg,_ng.
L 17.1.99.21 SUSFILE LOC.
~
l CONDUlT NO. - _
1
[
ccMhcrE H.AA STEAM ELEC ;.: i am L
17.1.99.21 se.
i er ggy,ug toe, INSPE CTION REPORT g,,,j g g g,
nmi nv.
icEnTmcAyp/ T9 5 DATp_? s:Em / sinucTumE ocs;GNATica N no.
C-/3 y
b'S"2' $ 6 /
CONDUIT RACEWAY SYSTEM 4
5PEC.MO.
REV.
REF GLC-OCC. & AEV. S' CMANGC NO.
M M E QA TEST EQuaP. 40ENT. NC.
ES-100 s
2s QI-0P-11.10-1, P.ev.
/k CT-/9 7f
/ / & c, f'/
s y
Ol",,3,!c#e, O Pajpgcity,noN O y,7tEcy,'ot E P,~j,Eeye, O P,=,Eg7,,,
s y
3 IM3P. RESUl TS INSPECTICN COMPLETED, Al.L AP8.l CABLE ITEMS S ATISF AC T CRY
/ J.*2 [
fC g ^"
'"5"'C'"
O INSPECTION CCw ETE:. uNsATisriCTcar iTrus usTEo ec.Cw INSPECTION ATTRIBUTES N
DATE SIG N A**JE b
n it "
i?
d 1.
l Verify HK d's foe all st e cts within the eve + -
l (per Para. 3.4) l l
lil 2.
l Verify OC acceetance of all succorts within tM rystem (per Para. 3.5) f 3.
Verifv sean distance (Per S-09101 Y
1 I
4.
l Damaged galvanized surfaces repaired with Galvanox V
l l
l l l
._l l
l l
l l
LINE #
OPJWING #
UNTOUF e 1
%rt
.TR 15 to 33M (so inspccr)
~7-C A -( A O
~~)
ei%0f159SN -1 A
Eno
/F i/ 219 3 O A i
U TA ') U A" A U V
\\
s,Il u
1 I
f 5f T R DV l
% A 11 R
ll 5 Ef{h l
REMARKS ( DWGS, SPECS, ETC.)
gf j DATE A//
ISIGNATURE M2
/4
/g N
is
/g oC INSPECTO R i
16 l
- m. ~ '
causgest pgas 3 5.;u t.gc s.c /s hi;,,6s To.,
..t I
L 17.1.99.21 s - t" er INSPECTION REPORT gIO[h,[D mg
,g,
b ". R i s q _ _ _ _ ___, _
g WIi 11 bl.
IDDeT6FICAT s N NO, Kv M* Eaw / $7 Ry;7ygg gg,q,gg7lgg
,i
=
CONDUIT RACEWAY SYSTEM 2 C,/ 3./fCJ$~7DATd: 8 S 2
.3 Gr I 4
~~
sPT,C,ho.
REv.
REF. G.C. COC. & AEV. # CNANGE No.
MLA5aRE 04 TE5T EQufs. iOENT. No.
j
- 2.. at-or-11.10-1. Pev. - /L C.7- /9 7f
// z>ec F/
ES-loo i
7 lN PROCESS O PME INSTALLATION [ lNSTA;,L ATION f;lM5PECTION C PRETEST NAL INSPCCTION VERFICATION INSPECTION INSPECTicN IMSP. RE3ULTS INSPE7.CN COMPLE*!D, ALL AP*.lCABLE ITEMS SAitSF ACT ORY y
g,7, CC IN M CTOR CATE C INsPE:IlCN CCWP.ETED, UNSATtSFACTCRY iTEu3 LISTED 8ELow b
INSPECTION ATTRIBUTES
$ %QATE SIGN ATURE,,
,2 -
lY I
l 1.
Verify MK d's for all s ucesets within +ba eve +,-
l l
(oer Para. 3.4) l l
l 1 l
2.
Verify DC acceotance of eli suecorts within the system l
l l (per Para. 3.5) l l
}
3.
Verify span distance (Der ~,-09101
- l l
J l
4.
Damaged galvanized surfaces repaired with Galvanox
- l l
l l
l 1
1 I
LINE #
l OF"4TNG A UNf00F s
)
% rt
-G81 A 10 3'1/ [A /A5AEcr. )
2
('A I'-1 013 d/C 4 'si - I 3
End IFQzt93LM I
W:nDUIST.!nN.,
,5 v. u s a. 6 v
(G LJ K L
,)
A r.-
MEMARK3 ( DWGS, $PEcs, ETC.)
~2.3 2 3 O' IO l3IGNATURE Al/
ff g, R, CLOSED 4]
/A oc INSPECTCR i
is 16 r
v-c+-
,,-y. - - -,
-y-y
---,---w.-.e-,---.-----..----w
e au. coe.
GL Y./.td C N E PEAK STEAM i E;ThaC ST M #,b f
INDEXED 7ut- /VCf 2.
1.7.1.99.21 INSPECTION REPORT L
._E
.vuitt coc.
'"e
/ s rauCTunE misuAnoN d_ / 3 OI'o" ao-/<'M 7d ATE F Z ' > 0 /
4:
'oEa" CAT I G I O P4 D L! T P N N O.
c0evii KEmb 5isiin r
srEC.No.
REv.
' Ru G4 coC. a REv. af CNANGE No.
mLAsuRE OR TEST Eou P.icENT.No.
67-/975-y ggc.g/
.i ES-100 s
2_. s 01-0P-11.10-1, Rev.
/$
T OlNPe0CE55 C PRE INSTALLATION Ola5TAa'TIo" R Pa
O PRE TEST MSPECTION VERIFICATION INSPECTION INSPECTION INSPECTION 9
IMEP. RESULTS
% INSPECT!CN COMPLETED, ALL A"L! CABLE ITEMS SATISF ACT ORY p
/2-[-f CiNsPECTioN CountETE:, UNSATISFACTORY ITEMS LISTED BELOW g
INSPECTION ATTRIBUTES h
gighgg DATE n
t2
- 3 e/
1.
l Verify MK 8's for all s uccor+s within the evet.-
V I l
l (per Para. 3.4) l l
l l l/l l
2-Verify 1C aCeeotance of all succorts within the system
'd l
(per Pa-a. 3.5) ll
/
3.
Verift scan distance (per S-09101 1
l
~
4.
Damaged galvanized surfaces repaired with Galvanox dl l
II l
l l
)
LINr 8 DRAWING A UNinur a I
5+ar+
Tt8IS - /OTtaf (NO /MP& T.)
- 2 CA - S~o-A-IV S n 6 / s-cy g 4 - 1.'
3 C A-L R-N
'4
-l 4
End I F V1/ 9 7 84 O( n 141$
y e
- -c avr~ 0 v Ap%r A s m wy -
1 'd MJ V v %v A A
N3mf RDIA:
( DWGS,$PEC2, ETC.)
'~IdV
- 2. j 2 3 0910 i
sa
// Q jDATEA/
j 3,cug7yps #
"CR "o-MA 1.R. CLOSF_DM D
fy]QC INbPECTOR I
I
/M is 16 l
- MAN nE FEax STEAM E E:::.c 5 T;T.cx 5-ct-1 e
INSPECTION REPORT I=as.r I-( ( & e fle 9.,
e irtu atscairnen pec.sm.ca:.c= =c.
gsysitu e st a-creat ca.aar.c=
Conduit Racewav Suocort tu re A cr* / ?". ?ct ~2t v Sw. A B 2..
pr1 al sesc. c.
atv.
au o.c. ccc. a atv. a cnaar.c no.
s psvatcmTuT ccvia..om ac.
i~.5 - ee s
.2 s 01-0P-11.10-1 Rev.
.2 Y v
sr e
01"ma'n.eris a p=venric4Pom O r=insatenen tinsTi Tio" statt2nea E F:=4'acemen O Per'tsT tenon ins mispecnon ansP. IEE5ULTS O secTian couatrTre. at.' aa ucastr irex:
J,,d /,/ [m e se/
sanspacreat
@$nsateton oc insetem /
un countrTED. unsansra:Toey attw usTro ottow ec INSPECTION ATTRIBUTES O
0*TE alsna m n
um E
s e
IDENTIFICATION OF UNSATISFACTORY CON 0fTf0N9(SI -
h 1.
lsoor,n-t-e% <
c.s Ac r,
,%d L-le
,e L.,4 n ef' W S we C Sh -ise Id I
- 1I I
n ll l
1 I
l l
l I
i i
l i
I I
i I
l 1
l l
l l
l l
l II i
lI i
i ll I
i i i
I l l l
Resana (owas,spres, ETc]
- 3. cy,e
- d.
ROTC MCA 'C iMR i slGN4ME g,g, cLosgp g
i.
I i
QC rN!PEcT L R gg M1/04 7/84
-m-----me.mqv.-w,--
--4,,e---.--w, q
,w,me,.
qm y -
we,y m-wv- - ~
w--w
4
- M AN OME FEaK
$ 7 E A.V E ECTE;C STAT CN o
St"
-r t
i INSPECT 10N REPORT l=,. jg ej,,g, (TD GL5CALPTION iCb71FsGaT.Gn W.
g5f &~LM / ST Ru;7.at CL5:enar.cn Conduit Raceway Succort t ('ed6 J / 3 3 I -/>
m 962 56/
R,,, /u A e.c..sc.
acv.
au o.c. ccc. a atv. a cnaast so j=tasuntcaiuT ceva..oc3T ec.
/~5./c.
s J
/#
c inst'a 01"as*p*renon acr18 O P'inseccrion rrau.2noa E raai.
OParw P=vcmcaPonrica
=seren0N W5PECn0M g
an5P. RESULTS O
cer:a= ce=ateTre, att an ucastz irrus sarisracrenv A,jjt/I,,
r.2 7/
E'iamenon eeuntrno,unsansra.Teny irem urns sc.sw
- "8'5*' *" '
" ^
- to
{
ac inseccriou arrnisures oart
,m,,
e LIDENTIFICATION OF UNSATISFACTODY CONDTTTONR(SL l
l 1.
IR.,- u-3e eod u nn.,r a2;u,,,+
t,- w l
ln s + 1,c ex -r,.v 'n
'G U c, J 1.Jls l
l n.., x lesm.e: es
.e s,-s of &
' l /
\\
l l
u I
ll h
I I
l u l i
1 l
l l
l l
l 1
I II' l
I I I
l-1 I
I l
l l l l l
l
~
l l l
ll I
asmaaa wwas,mes, rrea 3,y,,
1 l
l I
wi h m McR M i"
i38GNa N 5 l
l.R. CLCSED C
t ce :NsPE:Tsm rs i,,
l l
M1/04 7/84 l
w
-,e w e -
---w--g
-,y__-
w-.y c._m-
--yy.
y9-ar--v
---a--
s-e r-----Nm----"""--N
- - - - " " - ^ ~ -
0".;M AN CHE FEAK STEAM E I:70C S T A T.CN e
s-m I er INSPECTION REPORT 4, j,gg.f,f, TLv otscaiPT;ca pctsm cat.cm w.
gsts:Lw/siaucNAE c(s.e nar.c.s Conduit Raceway Succort eld &/25 Ac)
Wr 4.,.cA
/
=.
srtc.ac.
aty.
mLa cA occ. a mEv. a cnaast no g=LahmE cm TisT Eevie.omT.sc.
TS-/c.
s 2
s OI-0P-11.10-1 Rev. 2F tt AT e
QIN**octss petiNsT'at.t4 Tion pestaLL27to" E Fw-(C'.10N O Perw BiSPECTION V G FICAT4CM INSPECTION Ifq3P a>EPEcTION 9
INSP. RESULTa O sinceT:oM csMatrTre att AP ucaste iTos maTisracT0=v A;j n; 4,
p ;. p,/
f 0
thSPECT10N CDwPLETED, UNSaT15 FACTORY ITEMS USTED SELow to aT E M 880.
INSPECTION ATTRIBUTES e
C Datt SIGhATURE n
m a e
IDENTIFICATION OF tfNSATfSFACTODY CONDITf0N9(S).
l l
1.
, R.r cL + ca u za m e c 11, es,, 1,e 2'e n e l
l
-[o LJ e,-_.Ar),n>,Y J'/1' l/t l
,. g l
2 II I
l l
l l
l l
1
.f l
l l l l l l
l li l
l l l
l l 11 I
i l
l l 1I I
t l
I I I
l l
l REMaams (Dwas,sPE:s, ETc.) 3,9,e i
41 RUTD " C A
i 5 88GNAN5 l
l.R. CLCSED Q
j is i
i oc aspicTcn J
M1/04 7/84 l
~.
'~' 0 ll* iS $l /
COMANCHE PEAK STEAM ELECTRIC STAilON m,; t ; titts "U
6 CENERA1:NG CO.
NONCONFORMANCE REPORT (NCR)
UNIT STRUCTURE /5Y TEM ITEM /COMPON TAG /ID NUMBER LOCATION OR ELEVAT60N RIR NO.
EG l(\\3c/-tm 967 Sf*C M M*
l 2de. spec.e 3g reemMt'oO 133 g4
%m NONCONFORMING CONDITION ku Gcco e Nc e g
CG6te. OC;- \\\\\\'50% Ih 15 Mo1 eth Drawdg QD3 -Ei Oln Tl. %
e E
Docs Wo1 r10v E C M G o % h ",,lhut fEG-ll\\309.
E omswosg suu hoy g
cew ps s i
W s,p e c. tt ore 'i2 P o r t 6T 2837 A
~
REFERENCE DOCUMENT-REV PARA
~
DATE:
OE REVIEW / APPROVAL:
Yd47)s/Mm =
O?123/YY wO ACTION ADDRESSEE DEPARTMENT
@, f
[ /~ g sr -- - l DISPOSITION:
REWORK REPAIR USE i IS SCRAP l
w E
l
~
s i
8<
s l
ENG. REVIEW / APPROVAL DATE:
l E
OE REVIEW APPROVAL:
DATE-I
/
wO DisposlTION VERIFICATION & CLOSURE:
DATE:
I COMMENTS:
g
+ - - -
-w
~~.
-' hadanoot.mc.
INTEROFFICE MEMO TO:
A. Vega July 18, 1984 FROM:
G.R. Purdy SU3 JECT: CPSES, 35-1195 Reinspection Of ASME Items Previously Inspected By ASME QA/QC Employees.
As depicted in Attachment 3 to QA Procedure CP-QAP-3.1, " Site ASME QA Organization, Functional Responsibilities, And Program Implementation",
attached, the corner stone of the ASME QA Program is an iterative inspection and verification process. Sumuarily, this process provides for the micro-scopic inspection of each quality related process within an ASME fabrication or installation activity, and a final macroscopic inspection to assure as-constructed compliance with the design requirements. As indicated in the following activity briefs, this process generally encompasses: numerous in-process inspection attributes; a high probability that more than one inspector will be involved in the acceptance of any given item; third party (ANIA) inspection in one or more of the attributes, or final acceptance; vendc or field engineering corroboration on numerous instances; and a final QC verification of acceptability prior to or during testing, or preceeding cert fication.
A.
In-Process Inspectione 1.
Wel ng Processes a) ypically, a minimum of 4 QC inspection points will be established fer each ASME weld (fit-up. cleanliness,
-preheat, and c final visual examination);
b) All piping welds will have a QC inspection field hold point for an NDE method, which also requires compliance with visual acceptance criteria; c) All class 1 component. support welds and any ASME full-fillet weld will have a QC inspection field hold point for an NDE method, which also requires enspliance with visual acceptance criteria; d)
\\ll welding process control documents are submitted to che ANIA who established field hold points'to the extent ne considers necessary to assure implementation of our approved QA Program (i.e., approximately 10% for Class 1 and 2 activities and approximately 1% for Class 3 activities);
Page 2 of 5 c
e) For all Class 1 and 2 welds requiring radiography, the ANIA reviews 100% of the radiographic film for accept-ability of the weld; f) For all B&R welding conducted on NSSS components or material, Field Mechanical Engineering and the cognizant Westinghouse Engineer routinely assure acceptability of the fabrication or installation process; and g) For special welding techniques and repairs, Welding Engineering routinely establishes independent field hold points in the process.
2.
Mechanical Processes a) Construction Operation Travelers (C0T) are generated by Field Mechanical Engineering for mechanical fabrication or installation processes; the most basic of COT's (Bolting Nuclear Pipe Flanges) has 11 QC hold point attributes; b) All COT's involving installation of ASME Code items are submitted to the ANIA who establish field hold points to the extent he considers necessary to assure implementation of our approved QA Program (i.e., approximately 1%);
c) Field Mechanical Engineering has established field hold points at critical operations on the COT's involving mechanical equipment installation and alignment; and d) Westinghouse Field Engineering has established field hold points on critical activities involving the installa-tion of all NSSS components.
B.
Completed Installation Inspections 1.
Piping a) All piping systems have been reinspected by QC for compliance with an Engineering issued N-5 as-built drawing, into which all design changes have been incorporated, to assure that the as-constructed condition meets the as-built requirements, and that no damage had occurred to the pressure boundary; this inspection is sufficiently detailed to, and does identify existing visual defects; b) Piping configuration has been independently verified by Technical Services Engineering for the purpose of as-built stress reconciliation; and c) All socket welds have been reinspected.
Pcgs 3 of 5
- 2.. Component Supports a) All component supports have been reinspected by QC for compliance with an Engineering issued as-built drawing, into which all design changes have been incorporated, to assure that the as-constructed condition meets the as-built requirements, and that no damage has occurred to the-support; this inspection is sufficiently detailed to, and does identify existing visual defects; b) Component support configuration has been independently verified by Technical Services Engineering for the purpose of as-built stress reconciliation; c) All component support velds accessible to unauthorized 4
work or modification have been reinspected; and d) All component support skewed welds have been reinspected.
3.
Mechanical Equipment a) The installation configuration and mounting of all mechanical equipment has been reinspected by QC.
C.
Post Installation Acceptability Inspections 1.
Pressure Testing a) All piping systems have been pressure tested in accordance with ASME requirements; and b) During pressure testing, every B&R weld, untested vendor weld, high stress point, and base metal repairs requiring retest have been visually examined for integrity by QC and the ANIA; this inspection is sufficiently detailed to, and does identify existing visual detects.
2.
Hot Functional System Testing a) The acceptability of critical piping systems installation, thermal growth and component support design function has been verified by Design Engineering and Start-up Systems Engineering during Hot Functional Testing; b) The acceptability of Secondary Hot Functional piping systems installation, thermal growth and component support design function has been verified by Design Engineering and Start-up Systems Engineering during Secondary Hot Functional Testing; and c) The acceptability of variable supports to serve their design function on floated systems has been verified by Design Engineering and Start-up Systems Engineering.
a
.-,.c-.,n, v,
w-
Page 4 of 5
-a.
i 3.
Acceptance And Preoperational Testing a) The acceptability of piping system installation has been j
verified by Start-up testing; and b) The acceptability of mechanical equipment installation has been verified by Start-up testing.
During the last 3 years, the ASME QA Program has been the subject, or one of the subjects, addressed by numerous and exhaustive field inspections and program audits, conducted by multiple independent organizations. These activities have included: an ASME Survey, 12 complete program audits by the ANIA, an INPO audit and field inspection, an NRC CAT field inspection and audit, at least 2 complete building. turnover inspections by Region IV of the NRC, follow-up and closeout of the CAT inspection by Region IV of the NRC, an unannounced major field inspection and audit by Region II of the NRC, and NDE audit and field inspection by Region I of.the NRC, at least 9 QA Program audits by B&R Corporate QA, numerous audits and field inspections conducted by the Owner, an audit and field inspection conducted by Cygna on behalf of the ASLB, allegation inspections resulting from the ASLB, and a continuing field inspection and investigation process implemented by Region IV and the Region IV RRI of the NRC.
l The results of the above investigations have totaled less than 50 field i
fabrication or installation problems; all of the problems have dealt with a single inspection attribute. To place this number into proper perspective it is necessary to realize that since mid 1979, the ASME QA/QC personnel have inspected the exceptionally conservative number of 3,500,000 attributes, not including document verification.
To further place into perspective the significance of these findings, which also emphasizes the validity of the ASME QA Program as implemented, the following information is germain:
1.
1 problem was engineering oriented, which resulted in redefining U-bolt configuration requirements on design drawings, and a complete reinspection was conducted by QC; 2.
21 problems were identified prior to completing the final inspection process discussed in paragraph B, above; 3.
1 problem was identified relative to the bolting on equipment mounting, which has been incorporated into the final acceptance inspections discussed in paragraph B; 4.
Several problems were identified relative to loose hardware or missing cotter pins, which has been incorporated into the final acceptance inspections discussed in paragraph B;
(
1-.____.,,_
L...-.. -.
. ~.
..Pcgs 5 of 5 5.
With the possible exception of item 1, no problem was evaluated as safety significant by Engineering; 6.
1 component-support veld has been found undersized on 1 leg by 1/32"; and 7.
O problems have been identified relative to piping, pipe welding, or NDE.
In summary, I cannot conceive of any. reason why it would be necessary to reinspect any previously accepted ASME inspection attribute, unless re-quired by Engineering as a result of design considerations, after completing the iterative inspection process required by our QA Program.
mA/
G.R. Purdy jI Site QA Nhnager
'GRP/bm cc:
R.J. Vurpillat R. Siever J.T. Blixt B.C. Scott SQAM File i
l l
i k
~
t PROCEDURE EFFECTIVE SROWN & ROOT, INC.
NLHBER REVISION DATE PAGE CPSES JOB 35-1195 CP-QAP-3.L 6
JUN 111984 16 a 16 ATTACHMENT 3 TYPICAL INPROCESS QA PROGRAM IMPLEMENTATION I
E
._m.
._ =
~
~
e
._ i
. =.-
n
- =.::.--.
mn
.a i
N_.,.
g
._ f
.=
= ~ ~.
j
--~
.N~ A.
e
.g,3 4
N MlW'ME M W.E.8.
.e.e....a N$
W.a
.u.
-n..
l
=
?
- S
.,a
--.a
.e R. A
,lW.W."*.R ***,.=
m~ u g
=
l
.s
-... g p..g'4*
8e El
- 9. e.e.g.
N..\\ =n. 4 o
.e _
....r.. a.,,.,.
.s.
pg n.gg,j g,,,,
- 80. ns.
I%
.t WP g
gy gggggy ggy, EEE 9
.D gagg ggg MM "8
m W
8" es g.,
ggg m
~~
i
.. IIP.68.,
.ga. 43 s M.aa.3 g
e
.lllllll,:;*.:::,
.3,""".,;.
M M
.m e m
.m N44...
Nf3 8 WP.45.0 s.ea.a M.6 p
.e=*..
e
..s a
e o.
...,s,,....s.
- se. * -
am...e..
.--,----.t
-.-m
,p.
_.,.-,g
, wm _ w.
m,
TUQ-2220.1 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMOR ANDUM To B.C. Scott Glen Ito. Temme July 16, 1984 Subject Inspection Samplino plans The following are recommended inspection sample plans for use in comfirming the adequacy of the work performed by those individuals who left CPSES QA in connection with the narcotics investigation.
These plans were selected from ANSI 21.4 (MIL-STD 105D) under-general inspection Level II, single, normal inspection with an acceptable quality level (AQL) of 4.0.
l.ot Size Sample Size Accept Reject-1284 125 0-10 11+
5116 200 0-14 15+
169 32 0-3 4+
70 13 0,1 2+
1068 80 0-7 8+
50 13 0,1 2+
For example, in the case of the inspector who had performed 1284 inspections, reinspect 125 of these.
If 10 or fewer of those 125 are unsatisfactory, accept the entire lot (of 1284). If 11 or more of the 125 are unsatisfactory, reject the entire lot (of 1284).
The above inspection sample plans are based on a maximum of 4 percent defective or a minimum of 96% acceptable and will provide further assurance of the adequacy of the subject inspections.
L.M. Bielfeldt Quality Engineering Supervisor LMB /1j i
2 6 APR 1983 MEMORANDUM FOR:
Richard C. DeYoung, Director, Office of Inspection and Enforcement FROM:
Paul S. Check, Deputy Regional Administrator
SUBJECT:
REPORTS OF DISCUSSIONS WITH TEXAS UTILITIES GENERATING COMPANY (TUGCO) ON DRUG AND ALCOHOL ABUSE Enclosed is the subject report which is being transmitted per TI 2596/1.
C rig:r.:.. S.. :....
Paul S. c ::v.:
Paul S. Check, Deputy Regional Administrator-
Attachment:
As stated cc w/ enclosure:
J. T. Collins J. E. Gagliardo R.
L.' Bangart G. L. Madsen L. I. Cobb, D/DFFMS RP81 V
GMa I n Ch ck 4
83
/83
-,+n RIY Offloial l'ila copy
@@MJ '
/$
r-
,'a Discussions With Texas Utilities Generating Company (TUGCO) 4 Dockets: 50-445 and 50-446 Comanche Peak Electric Power Station Glen Rose, Texas Persons Contacted B. R. Clements, Vice President Nuclear R. A. Jones, Manager Plant Operations R. Wistrand, Administrative Superintendent Utility Perception of Drug and Alcohol Problem TUGC0 is aware of problems associated with drugs and alcohol and that their company is not immune to these problems. Employee assistant programs have been established and TUGC0 conveys a strong sense of its responsibility for the safety a.-i security of their personnel and the public. TUGC0 relies heavily on supervisory assessments of employees' performance and capability to perform and as a result provides all supervisors with special training. TUGC0 makes it clearly understood that if job performance is adversely affected by drugs or alcohol that punitive action may be intitated.
Company Policy on Use or possession of Drua or Alcohol TUGC0 has provided copies of their policy statement.on alcohol and drugs (Attachment 1) to all of their employees. Additionally, the new employee indoctrination program (Attachment 2) provides coverage on the subject. The policy statement states that employees having possession of drugs or alcohol on company property or where there is reason to believe.the individual is under the influence of intoxicants, drugs, or narcotics, while on company property, will be subject to immediate discharge. It further states, where there is reason to believe an employee is under the influence of intoxicants, drugs, or narcotics while on company property, the employee may be required to take a blood test, uranalysis, or other diagnostic test. Refusal on the part of the employee shall constitute a flagrant act of insubordination and will. subject the employee to immediate discharge. Additionally, each employee i
is reminded that according to safety rules. it is an employee's responsibility to report unsafe working conditions or hazardous' activities which jeopardize
.their own or fellow employee's safety.
l Contractors of TUGC0 are bound by contractual agreement to the company policy on drugs and alcohol. TUGC0 believes th.amployees have a responsibility to conduct themselves properly on their M t me, since public confidence in l
their employees is important. Ho, M r. i an employee's off-work activities are within the bounds of the law vj. w
- affect job performance, TUGC0 believes it is inappropriate for tnem to oe involved.
i I
-99E N M.P
,m,
~
.g.
Types of Programs Available An Employee Assistance Program (EAP) has been instituted by TUGCO. The program includes special training for management and supervision, documentation of performance, and a written action plan signed by the employee and supervisor.
Additionally, TUGC0 has four Dallas doctors under contract to provide consulta-tion to their employees and family members, on a self-intitiated and confidential basis. Employees may also be referred for consultation by supervisors, doctors performing physicals, or family members. Experience has shown that the program is well received and has been utilized by many of their employees.
Utility Use of Background Checks Employees or contractor personnel, scheduled to require unesecrted access to operating units at Comanche Peak, receive background checks in accordance with the ANSI 18.17 criteria. The background investigations are performed on a contract basis. The background checks include conviction records, arrest records, education, military experience, medical history, county court records, and credit records. TUGC0 has an audit program to assure that background investigations meet acceptable standards. TUGC0 does not use polygraph examinations; however, they do check background data versus job application data.
TUGC0 has on going meetings with unions and are striving to minimize the need for temporary personnel for the performance of work activities. Their intent is to have the potential work force cleared and indoctrinated.
If temporary personnel is required, they would consider requiring constant escort for all personnel without background clearances or indoctrination.
Use of Psychological Tests All TUGC0 personnel for Comanche Peak are tested using the MMPI, with contractor personnel administering, scoring, and interpreting the results.
Some 290 employees that were on the rolls were tested and five results indicated deviation from the norm.
Followup clinical evaluation indicated that in three cases security was not involved and two individuals will not receive a security clearance. New applicants showing deviation from the norm are not normally. retested or given clinical interviews. Experience to date indicates I
that about eight or nine percent of the new applicants are screened out by the
[
psychological testing.
Utility Use of Supervisory' Training and Observation of Apparent Debility l
(Behavioral Observation)
Personnel Decision, Inc., developed a Behavioral Reliability Workshop training for TUGC0 that is required training for~those supervising people working at a licensed operating unit at Comanche Peak. The behavioral program includes observations, feedback on performance, guides to behavioral changes, and practices and actions to be taken. Supervisors are instructed to make their evaluations based on job performance.
p
, Employee Awareness Employees.have been made aware of the impacts of drug and alcohol mainly through_the TUGC0 policy statement made available to all employees and though the EAP information and training program. All new employees are indoctrinated on this subject as part of the general employee training program. Personnel are made aware of the effects of drugs and alcohol mainly as to the potential impact on job performance and safety.
Detection Program TUGC0 relies heavily on supervisor observation of employee behavior and performance and the responsibility of all employees to report for duty in fit condition and to inform supervisors if they become unfit for duty.
Absentism is looked at as one indicator of personnel behavior. The individual supervisors are the principle evaluators.
Inspections as opposed to searches will be made of lunch boxes, brief cases, and packages entering the protective area for operating units. Work lockers, desks, tool boxes, etc., are not inspected routinely, but are subject to inspection if probable cause is present. Dogs have been used for searching of the construction activities at Comanche Peak.
Report Prepared By:
Jh/FA G. L. Madsen, Chief Reactor Project Branch 1 (s
Paul S. Check, Deputy Regional Administrator i
l
TEXAS UTILITIE5 GENEliA A AbLU;utnNa OFFICE MEMORANDUM ATTACHMENT 1 Tc, CPSES Ecolovees Tyler. Texas 4
TUGCo Policy Statement On Subject Alcohol and Drua Abuse
/
The responsibility to develop and implement an Alcohol and Drug Abuse Program for CPSES is assigned to the Manager, Plant Dperations, CPSES.
To meet Company and Nuclear Regulatory Commission guidelines, this program should contain, as appropriate for the level of access authorized, the following points:
1.
An employee alcohol and drug awareness program.
'2.
An employee screening program which includes the use of testing as part of the pre-employment physi cal.
3.
An alcohol and drug detection program which includes
~
continual behavior observation.
4.
An employee assistance program.
The Alcohol and Drug Abuse Program, developed for CPSES in accordance with this policy, will apply to all Texas Utilities Company employees whose job duties require that they have access to Company property at CPSES.
i R. J. Gary -or-B. R. Clements i
i 4
4
,.,,.,,+
.n-,--,
,.,..,a e- - - -,. - -, -
-r
~w
=
j TEXAS UTILITIES GENERATING COMPANY POLICY STATEMENT ON ALCOHOL AND DRUG ABUSE Texas, dtilities Generating Company recognizes alcohol and drug abuse as a significant problem.
The objective of this policy is to provide the opportunity and encouragement for employees and their families who may develop addiction to or dependence upon alcohol and/or other drugs, and assis-tance which may help the employees or their families to arrest the condition.
We believe the decision to seek diagnosis and accept treat-ment for alcoholism and drug ab'use is the responsibility of the employee.
However, an employee may be referred to help by his supervisor and may be required by the Company to secure such adequate rehabilitative counseling or other services as he or-she may need to resolve his or her alcohol or drug problem so that it will not affect job performance.
~
An individual's refusal to accept referral for diagnosis or to follow prescribed treatment will be handled in accordance with existing TUGCo policy-and practice with respect to i
unsatisf actory job performance.
I' Persons pa'rticipating in this program will be expected to meet job performance standards and work rules within the framework of existing TUGCo policy' and practice.
This policy is not intended to supplant the normal disciplinary process or to result in special privileges or exemptions 'from job performance requirements, nor will this policy affect the plant rules concerning the consumption or possession of alcoholic beverages or drugs on company property or report-ing to work under the influence of alcoholic. beverages or drugs.
j The confidential nature of the records of individuals in i
the program will be strictly preserved.
l l
~wse - -.
w.,*---v-p 79y-._,
9,m__
.a,-9y-..c---,. -,,,,_
-,--f
,+--_.y,-,-m
s-
?
\\
The rules regarding ' intoxicants, drugs and narcotics are based on TUGCo's concern for the saf ety of its employees.
The use or possession of these substances creates a danger.
not only to the employee using or possessing them, but to all employees.
Accordingly, the rules regarding intoxicants, drugs and narcotics will be strictly enforced.
Each employee -is also reminded that according to the Safety 4
i Rules as set forth in the Safety Handbook, it is an employee's responsibility to report unsafe working conditions or hazardous activities which jeopardize their own or their fellow employee's safety.
This responsibility includes-reporting the use or possession of intoxicants, drugs, or narcotics.
All such '
information will remain strictly confidential and will be used to insure a safe environment for you and your fellow empl oyees.
RULES REGARDING USE AND/OR p0SSESSION OF INT 0XICANTS, DRUGS AND NARCOTICS Any employee who attempts to bring or brings intoxicants, drugs or narcotics or who has in his possession intoxicants, drugs or narcotics on Company property or where there is reason to believe he is under the influence of intoxicants, drugs or narcotics while on Company property, will be subject 1
i to immediate discharge.
Where there is reason to believe an employee is under the influence of intoxicants,' drugs or narcotics while on Company i
property, the employee may be required to take a blood test, I
urinalysis, or.other diagnostic test.
Where there is reason l
to believe an employee is in possession of any intoxicants, drugs or narcotics while on Company property, the employee i
is subject to having his/her person and/or property searched by Company representatives.
The refusal on the part of the. employee, after being requested to do so, to submit immediately to a search of his/her person and/or property-or to be tested, shall constitute a flagrant act of insuburdination and, will subject the employee to immediate discharge.
....-.,o
. - -. +
T.
Prescription drugs p'rescribed by licensed physicians for the employee which could af f ect an employee's job perfor-mance or non-prescription drugs which could affect an employee's job performance, are allowed if they have been previously cleared by the employee's supervisor.
Any employee taking such medication must inform his/her. super-On request, visor of the medication and dosage being taken.
the prescription shall be verified in writing by the issuing physician.
An exception to these rules is th:t reasonable consump' tion of alcoholic beverages is not prohibited in the Company Also, possession of alcoholic beverages, but no s
park.
consumption of, is permitted at Company-authorized parking However, where there is reason to believe an employee areas.
is in violation of any of the above rules, the employee is subject to having his/her person and/or property searched by Company representatives, including property in the Company park and authorized parking areas.
Regarding conduct in Company park, see Company park rules.
9 e
d e
O S
9 e
0 m,-
_.-m_
.g-.
...w.-..
N. -
7 TNO-821094 TEXAS UTILITIES GENERATING COMrANY OFFICE MEMORANDUM Distribution mm,7. October 29. 1982 7,
New Employee Indoctrination Attached is a copy of Revision 4 to New Employee Indoctririation.
Copies of handouts will be available from Personnel, b
C Turner CLT:sjb Attachments cc: ARMS (w/o attach)
Distribution:
J. C. Kyykendall R. T. Jenkins R. A. Jones G. E. Jergins' E. Alarcon B. W. Kaulfus J. J. Allen J. A. Kelley J. R. Allison B. T. Lancaster T. E. Bain G. D. Lytle L. G. Barnes G. B. Moore T. J. Beaudin W. J. Nixon J. L. Brackney J. M. Purdy M. R. Blevins J. Rumsey D. W. Braswell M. J. Riggs R. E. Cowan C. E. Scott R. L. Cox R. B. Seidel J. R. Curtis C. W. Smith D. L. Davis P. G. Smi th B. D. Delano W. E. Stone D. E. Deviney B. B. Taylor R. E. Fishencord R. L. Theimer R. L. Fortenberry C L Turner T. L. Gosdin S. M. Ward K. Y. Graves W. H. Westbrook T. G. Heil R. R. Wistrand f.gl W
fA}'O"
a.
NEW EMPLOYEE INDOCTRINATION (REVISION 4)
A.
The focal point for indoctrination is the new employee's supervisor.
B.
It is the supervisor's responsibility to guide the employee through his initial orientation with the Company and to provide continued guidance throughout employment.
C.
The reference document that should be used for personnel indoctrination is the Supervisor's Handbook; its use ensures that 1.
All rules and policies are understood, and 2.
All rules and policies are applied and enforced consistently.
D.
Areas of Indoctrination 1.
Personnel a.
Organization 1)
Supply a diagram of and explanation of the Texas Utilities organization.
2)
Supply a diagram of and explanation of the TUGCo (CPSES) organization.
3)
Explain the relationship of TUSI, B&R, and TUGCo at CPSES.
4)
Explain the employee representation at CPSES by a bargaining unit, a)
The Electrical / Mechanical Maintenance workers and the Operators are represented by the IBEW (International Brotherhood of Electrical Workers) Union.
b)
Their representatives at CPSES are:
Handout material
. - ~
.~
a.
1)
Operaticas Department Stewards Mark Ford. Travis Broughton, and Jimmy
- Barnard, ii) Maintenance Department Stewards Dennis Caughron, David Carroll, Carroll Valentine, and David Selle.
b.
Individual Introductions 1)
Superintendents - introduce the new employee to all CPSES superintendents.
(This should normally be accomplished within the first month of-employment.)
2)
Department - introduce the new employee to all individuals in his department with whom he will start to work. Ensure that he continues to be introduced to all others within the department.
3)
Interdepartment - introduce the new employee to individuals in other departments with whom he will have frequent contact to start to work.
2.
Facilities a.
Toilets - show the individual the location of restrooms near his work location.
b.
Drinking fountains - show the new employee the location of water fountains in the vicinity of his work loca-tion.
c.
Lunchroom 1)
Show the new employee the location of the lunchroon (II-11) 2)
Explain the policy for work breaks.
a)
Two breaks of 10 to 15 minutes each are scheduled by the supervisor on each shift for each employee who desires it, and when work.
permits.
(
)
Reference to Supervisor's Bandbook 2
- w..
4 b)
Breaks are taken in the break area in the morning and afternoon. No coffee or other drinks are allowed in offices.
3)
Lunch break, a)
Thirty minutes is allowed for lunch.
b)
Show the new employee the kitchen. facilities and indicate the time that is normally scheduled for lunch.
d.
Tour of the site 1)
Point out major offices on the site 2)
In particular, show the a)
Administration' Building b)
Maintenance Building c)
Warehouse Building d)
Shift Supervisor's Office / Control Room e)
Instrument & Control Shop / Chemistry & Health Physics Offices f)
Nuclear Operations Support Facility (NOSF) e.
Work facilities 1)
Show the new employee his work location.
2)
Ensure that he has all supplies, equipment and furniture needed for work, a)
Tell him how to get more supplies from the supply closet (himself).
b)
Tell him how to obtain supplies and equipment that are not on hand (through supervisor and Office Services Coordinator).
c)
Provide a hard hat.
3)
Ensure that a car sticker application form has been provided and the limitation as te, use of 3
-.. ~..
s.
personal car on CPSES property has been explained 1
(the differences in parking stickers).
4)
Explain the parking facilities available.
(III-1) 3.
Moving Expenses a.
Assist the new employee in making claim for reimbursement of expenses in accordance with Policy Letter V-1, " Relocation Expense Reimbursement Plan".
b.
Transfer employees may be eligible for relocation house purchase and mortgage assistance. Use the Supervisor's Handbook for guidance.
4.
Work Practice a.
Security Gate Security 1)
Each person will be required to show his ID. badge to the guard at the batch Plant Gate to gain access to TUGCo's parking lot.
It will not be necessary to exhibit badges upon leaving the site.
2)
Visitors may be admitted to the site after approval is provided to gate security. The gate guard will log visitors in and issue a visitor's badge. Upon leaving the site, a visitor is required to check out with the guard and turn in his badge.
b.
Safety 1)
Site Evacuation l
I a)
Should it become necessary to evacuate the site, follow the evacuation procedure.
b)
Provide the site evacuation procedure and I
map.
I 2)
Job safety - all job safety rules and signs should be followed.
Handout material
(
)
Reference to Supervisor's Handbook 4
,,,.--...-w.
7
a)
Wear hard hats in construction areas and wear them properly.
b)
Avoid areas and situations which require safety equipment that you do not have (safety shoes., protective soggles, safety belts).
1 c)
Make sure plankina, footina. railinas will support the weight you put_on them. Also ensure you know the depth of the '* puddle" of water into which you intend to acep.
d)
Crane loads -
Do not walk, stand or work under crane loads.
Do not stand in the swing area of a crane or crane load.
e)
Barricades and Signs Stay out of barricaded areas (work and radiography).
Read and' follow instructions of signs.
3)
Emergency Medical a)
Brown and Root maintains paramedics and registered nurses on BAR work shifts.
b)
Brown and Root also maintains and operates an ambulance service from the site to Glen Rose (Marks-English) Hospital during BAR work shifts.
4)
First Aid Box Locations a)
A first aid box is located in the Chemistry / Health Physics Offices in the plant.
b)
A box is located near the north, upstairs exit of the Administration Building.
c)
Another first aid box is located near the foreman's office in the Maintenance Building.
d)
First aid facilities are located in the East and of the Nuclear Operations Support Facility.
5
5)
Fire Reporting During. Construction Phase a)
A fire discovered in any area of the plant should be reported to the Control Room, ext.
3250.
b)
Personnel should attempt to extinguish or
- ontrol the fire until fire department personnel arrive.
c)
Do not place yourself in danger or perform actions you do not feel qualified to do.
6)
Alcohol Drug or Narcotic Use a)
The use of these substances constitutes a danger to the employee and other employees.
b)
An employee who possesses, uses or is under the influence of these substances at work is subject to discharge.
c)
When there is reason to believe that an employee possesses or is under the influence of any of these substances, he may be re-quested to take a medical diagnostic test and/or submit to a physical search.
d)
Prescription or non-prescription drugs which may affect job performance should be cleared with the supervisor.
c.
Telephone 1)
The phone number - for TUGCo is 817/897-4856.
2)
Some telephones can access local outside lines.
i l
On these phones, an outside line is obtained by dialing 9.
3)
Local es11s - are Glen Rose, Whitney, Crawford, Morgan, and Walnut Springs.
I 4)
Long Distance - calls should be accompanied by a completed yellow call slip. Personal long dis-tance calls will be charged to the. individuals making the calls.
5)
Some telephones can access toll free metro service to Dallas and Fort Worth. Access is obtained by dialing 80.
Metro service is to be used for business calls only and should not be used for i
long distance calls.
- Handout asterial f
6 L.
6)
Site extensions a)
TUGCo extensions - are called by 01aling a four-digit number.
b)
Brown & Root extensions - ar.e reached by dialing 9 - 4881 on a phone with local access capability and asking for the B&R extension, or by dialing 70 and the B&k extension number on a telephone with B&R line access.
c)
Transferring calls - between extensions is accomplished by pressing the telephone latch momentarily, releasing, then dialing the extension. After the extension is reached, momentarily depress the latch, release and three parties are connected; hang up the phone and two parties are connected.
d)
Camp on - may be used to automatically radial
" busy" TUGCo extensions made from other TUGCo extensions. When a busy extension is reached, momentarily depress the latch, dial ll, and hang up.
When the extension is free, your phone will ring. After you pick up your phone, the redialed extension will begin to ring.
7)
The Gai-Tronics phones are used by giving a paging directive to answer a particular channel. During the construction phase, lines one and two are assigned to B&R; lines three through five are assigned to TUGCo.
" Jim K ykendall, line two."
Example:
u d.
Secretarial Staff 1)
Typing / Work Request slips are used to request secretarial assistance. The work is submitted accompanied by a request form to the secretary of the Manager, Plant Operations.
~
2)
Finished typing should be signed or initialed and returned to the secretarial staf f for logging, distribution, document control and mailing.
3)
The secretary of the Manager, P3 ant Operations a)
Schedules the use of pool cars b)
Schedules the use of conference rooms 1
7
--n-,w'-
+'
.-w---
4---,,w g
.--.-.m-p.y e
.-c_-,.-
w,,..,-,3 w
C.'
r.
(II-5) e.
Payroll 1)
Time charge reportina - each new employees should be given an explanation of how time sheets are prepared, if applicable.
2)
All employees subject g overtime on the semi-monthly payroll are paid twice each month, on the 16th and the 1st day of the month..for work performed through the 10th and the 25th, respectively.
3)
All employees on the hourly payroll are paid every other Friday for the 14 day period ending on the preceding Sunday.
4)
All employees not subject g overtime on the semi-monthly payroll are paid twice each month, on 4
l the 16th and on the 1st day of the month, for work performed through the 15th and the last day of the month, respectively.
5)
Employees who cannot pick up their paycheck or pay day may make other arrangements with their supervisor. Checks not picked up will be main-tained in the safe by the accountant.
(II-3) f.
Absence from work l
l 1)
Personal business - time off from the regular work j
schedule for strictly personal business reasons l
may be arranged upon request to the supervisor.
l provided overtime is not involved.
i l
2)
Disability - Sickness a)
Injury - Industrial If an employee is injured while performing assigned job duties, the Company may, for a reasonable length of time depending upon the circumstances, pay the difference between the amount of employee's Worker's Compensation Insurance and the employee's regular salary.
(
)
Reference to Supervisor's Handbook 8
b)
Injury - Non-Industrial If an employee sustains an injury while not performing assigned job duties, the employee is given the same consideration as if the absence was because of sickness. However, due consideration is given to the circum-stances surrounding the accident.
c)
Sickness An employee who is absent because of sickness may be carried on the payroll at full or partial pay, depending upon the circum-stances,'for a period not to exceed one calendar month for each year of employment, or not to exceed six months, unless approved by 'the president or his designated repre-sentative.
d)
Absence for Maternity 4
Absences due to pregnancy or pregnancy related problems will be treated as an absence due to sickness.
3)
Jury Duty The Company recognizes an employee's obligation as a citizen to serve on jury duty when called and; accordingly, necessary time off with pay is usually allowed. When an employee receives a jury summons, the employee should notify the immediate supervisor.
4)
Death in Immediate Family Depending upon the circumstances, an employee absent because of death in the immediate family may be allowed time off with pay. Immediate family is defined as spouse, mother, father, son, l
daughter, brother, sister, grandparents, grand-children, stepparents, stepchildren, or the spouse's mother, father, son, daughter, brother, sister, grandparents, grandchildren, stepparents or stepchildren.
9
..1
s.
5)
Sickness in Emplovee's Family Depending upon the circumstances, each case of time off due to sickness'in the employee's family will be judged separately.
6)
-Notification by Employee An employee who is absent from work must inform the immediate supervisor of the reason'for such absence as far in advance as possible and in no case later than one hour before the scheduled time to report to work. Failure to do so may result in disciplinary action or loss of pay f or that work period. Further, an employee should continue to keep the supervisor informed of his/her statua during the period of absence.
7)
Leave of Absence - Military Military leaves of absence are handled in accord-ance with existing laws in effect at time of such leave.
8)
Leave of Absence - Non-Military At the option of the Company, a leave of absence without pay for a reasonable length of time may be arranged upon request, provided it is practicable for the employee to be relieved from his/her duties with the Company. Details of this policy are found in the Supervisor's Handbook.
5.
Benefits (I-1) a.
Group Life insurance Plan The coverage is described in the Booklet-Certificate which is issued to each employee enrolled in the plan.
Important facts to remember are:
1)
All regular, full-time employees are eligible for life insurance on the date they complete three months of continuous employment. The amount of
(
)
Reference to Supervisor's Handbook 10 4
m
- -.__~ --
- V coverage is equal to apprpximately twice the employee's annual base salary. All new employees should be encouraged to enroll in the plan within three months and 31 days of employment. Failure to do so will require the employee to prove insurability.
2)
A change in marital status could mean a change in beneficiary. Employees should be encouraged to take care of this immediately by completing an
" Addition Of Dependent" Form and submitting it to the Personnel Coordinator.
3)
The Company pays for the first $20,000 of life insurance and the employee pays 60 cents per month for each additional $1,000 of coverage. The employee must carry the full amount to which he is entitled' for the Company to pay for the first
$20,000 coverage.
4)
The amount of insurance changes automatically with any qualifying change in salary.
5)
The Personnel Coordinator or his representative is responsible for assisting TUGCo personnel with insurance matters.
(I-2) b.
Group Medical Plan The coverage is described in the Booklet-Certificate which is issued to each employee enrolled in the plan.
Important facts to remember are:
1)
The full cost of employee only insurance is paid by the Company. The cost to.the employee for dependent coverage is $7.50 per month if one or more eligible dependents are under age 65.
If the only dependent is over age 65, the cost for dependent coverage is $1.50 per month.
2)
Insurance for you and your dependents will become l
effective after you have completed three months' active, full-time employment provided you have enrolled within this period. If you enroll within l
(
)
Reference to Supervisor's Handbook i
11
,,,e-
n--
,,,_,,a,
-,-,,---------=..-----m---------nw
---mw--s--
--,ww--w-
-~~ -- - - - - - ---s
i C
I the next 31 days, your insurance will become effective the date you enroll. If you enroll more than 3 months and 31 days after date of employ-ment, you will be required to furnish, at your own expense, evidence of insurability satisfactory to the insurance company before insurance will become effective.
3)
If you are covered for employee only insurance and acquire a dependent, you have 31 days to enroll the dependent. Coverage will be effective the date you ecroll for dependent insurance. If you do not enroll for dependent coverage within 31 days, evidence of insurability will be required.
i 4)
All medical expenses should be filed as soon as possible through the Personnel Coordinator.
5)
The Personnel Coordinator or his representative is responsible for assisting employees with their insurance needs; therefore, he should be contacted concerning claims, insurance coverage, change of beneficiaries, etc.
c.
Group Dental Insurance Plan This coverage is described in the Booklet-Certificate which is issued to each employee anrolled in the plan.
Important facts to remember are:
1)
All regular, full-time employees are eligible for dental insurance on the date they complete three i
months of continuous employment. The full cost of l
employee only insurance is paid by the Company.
l The cost to the employee for eligible dependent coverage is $7.50 per month, i
2)
If you have not enrolled your dependents within 4 months of continuous employment and later decide to enroll them, you must pay the required monthly dependent premium for one year before coverage for any dental expenses (other than those due to an accident) is in effect.
3)
The Dental Insurance Plan will provide 90% payment for preventive and diagnostic service, with no l
deductible. Examples of these charges are i
i i
17 i
checkups, x-rays, cleaning, and fluoride applications.
4)
The Insurance Plan will pay 50% of ar. lor services and treatment, af ter $25.00 per calenaar year deductible. The maximum benefit for Major Services and Treatment is $1,000 per person per year.
5)
Orthodontic expenses will be reimbursed for 50% of eligible charges with a lifetime maximum benefit of $1,000 per person.
5)
The Personnel Coordinator or his representative is responsible for assisting employees with their insurance needs; therefore, he should be contacted concerning claims and insurance coverage.
(I-3) d.
Accidental Death, Dismemberment and Disability Benefits Plan This insurance provides benefits for all accidents on and off the job, twenty-four (24) hours of every day.
The principal sum of insurance is equal to approxi-mately twice the employee's basic annual salary and is 3
provided by the Company at no cost to employees. All i
employees are provided with this insurance even if they are not enrolled in the Group Life Insurance Plan.
(I-5) e.
Holidays The holidays that are observed are as follows:
New Year's Day Thanksgiving Day Good Friday Christmas Eve Day Memorial Day Christmas Day Independence Day Floating Holiday Labor Day Floating Holiday Supervisor's are responsible for making appropriate arrangements when shift work is involved: Refer to I-5 of Supervisor's Handbook.
(
)
Reference to Supervisor's Randbook 13
9-(I-6) f.
Vacation Every regular employee who has accumulated service with the Company, or with the Company and another System Company, of six months or more is eligible for vacation with pay during the current year as follows:
LENGTH OF SERVICE LENGTH OF VACATION Less than 6 months NONE 6 months 6 Working Days 10 months 10 Working Days January 1 of Sch Anniversary Year 11 Working Days January 1 of 6th Anniversary Year 12 Working Days January 1 of 7th Anniversary Year 13 Working Days January 1 of 8th Anniversary Year 14 Working Days January 1 of ' 9th Anniversary Year 15 Working Days January 1 of 10th Anniversary Year 16 Working Days January 1 of 12th Anniversary Year 17 Working Days January 1 of 14th Anniversary Year 18 Working Days January 1 of 16th Anniversary Year 19 Working Days January 1 of 18th Anniversary Year 20 Working Days January 1 of 20th Anniversary Year 21 Working Days January 1 of 22nd Anniversary Year 22 Working Days January 1 of 24th Anniversary Year 23 Working Days January 1 of 26th Anniversary Year 24 Working Days January 1 of 28th Anniversary Year 25 Working Days g.
Employee Stock Ownership Plan (ESOP) 1)
The Employee Stock Ownership Plan is designed to help the employee acquire Common Stock cf Texas Utilities Company, and thereby to have an ownership interest in the Syste= to which he contributes his services.
2)
Each employee automatically becomes a participant in the non-contributory portion of the plan upon the completion of one year of service or the attain ent of age 21, whichever is later, unless he elects otherwise in writing. The ESOP allows the Company and its subsidiaries to claim an additional 1% investment tax credit against federal income tax liability if that amount is contributed to ESOP. This feature is non-contributory.
(
)
Reference to Supervisor's Handbook 14
,---ww- - -. - -
~~
$l 3)
In addition, the Company and its subsidiaries may claim and contribute to ESOP a further investment tax credit up to 1/2 of 1% of eligible expenditures to the extent that the amount is matched by contributions of parti-cipants. This feature is contributory.
4)
Shares allocated to participants will generally remain in account until termination of employment.
(I-8) h.
Employee's Thrift Plan The Employee's Thrift Plan of the Texas Utilities Company System is intended to furnish a means by which Texas Utilities Company and its subsidiaries may encourage employees to establish a regular savings program, assist employees to acquire Common Stock of Texas Utilities Company as an incentive to efficient operation through ownership of an equity interest in the System, and promote the best interest of the System by attracting and retaining desirable j
employees.
1)
Full-time employees who have completed twelve months' continuous service and have attained 21 years of age are eligible to participate.
2)
To participate, an eligible employee elects a 2%,
3%, 4%, 5%, or 6% deduction from regular salary or wages.
3)
The Company contributes an amount that is a percentage of the employee's contribution as follows:
LENGTH OF SERVICE CONTRIBUTED BY COMPANY Less than 10 years 40%
10 years, but less than 25 years 50:
25 years or more 60%
4)
All company contributions are invested in common stock. The employee may elect to invest in a Guaranteed Fixed Income Fund or in one of the following investment options Option A:
100% Common Stock of Texas Utilities Company
(
)
Reference to Supervisor's Handbook l
l 15
..--,_.-.,_..--,r,m.
-,-r.
~,
---.._.,,.._m.
.-,,.,_.~..,...-..-,_..-.,_,.,_~..._y-,
--...w_m,,,,, -- - - -,..,
_,-_m._..-.,_,,.,y
n...
l
(
Option B: 50% Common Stock of Texas Utilities Company.
50% in United States Government Bonds Option C:
100% United States Government Bonds Option D: Multiples (not less than 25% each) of Options A B, or C.
(I-4) 1.
Purchase of electrical appliances The Company has a plan whereby major household electrical appliances may be purchased.
1)
All regular employees who have been employed by the Company or affiliated companies for six months or more are eligible to purchase major electrical appliances for their own use.
2)
All sales are treated as confidential. Do not discuss purchases with individuals outside the Company.
3)
Payments may be extended to a period not to exceed 24 months through payroll deductions without interest or carrying charges.
(I-7) j.
Education Reimbursement The Company has an Educational Expense Reimbursement Plan for employees.
1)
All employees are encouraged to continue their education and development in those areas related to work.
2)
Basically, the Company will reimburse the employee 75% of the total enrollment costs, including textbooks, upon satisfactory completion of approved courses.
(I-10) k.
Energy Conservation Financing Program for Employees' Homes The Energy Conservation Financing Program has been designed to provide financial and technical assistance
(
)
Reference to Supervisor's Bandbook 16
Yr e
e to employees in making certain energy conservation improvements to their personal residence. It applies to retrofitting of an employee's existing home with insulation, storm windows and doors, caulking and weatherstripping, electric heat pump, a high EER air conditioning unit, solar heating or solar water heating which results in the employee's home becoming more energy efficient.
s 17
a.
y:
Index of Handout Materials New Employee Indoctrination Texas Utilities Organization Texas Utilities Generating Company (CPSES) Organization Evacuation Procedure and Maps Rules Regarding Usa and/or Possession of Intoxicating Drugs and Narcotics 18 l
l
COMANCHE PEAK STEAM E:.ECTRIC STATION TEXAS UTILITIES
' " C " ""
NTaNo Co.
NCNOONFORMANCE REPCRT (NCR)
' /? 89' 6/8t/O O
UNIT STRUCTymEc 3ySTEM
' (TEu/ COM PCNENT, TAGiD NvuSEM
' CCAfiCN Cm ELEVA"CN min y
/W
))L L A).4 hS/UkS kLL llh i
NONCONFCAMING CONQiflON a
l a
/
Da.s to Mc tzernmaa ofaAMC &fsonna l
Fe su.spicion of tAMiM.bcu.a.s wMiLs. Ararmins I
g QA/CL Pa.n t +1o n.c tar CD.n Lif) Of An Y ZTZns S l
Zn.sPzctr.b ce Rtuit aud S.y Q A/GC Prv.sonnzt usdo NAdt I?zrn trerhinAtrd toe A.beu c,.-RrlAtr.b gc C.NAc&L BtCotstS Endt fcn m ill A+r.
8 S
i-Nott.: rna i.s neeneric Mc.:2.
I
!N d
O mEFEmENCE OCCUMENT-mEV enma REPCRTED BY:
' ]
CATE.
?
J1FA.
b / /h QE AEVIEW/ AP99CVA4 Q
dQ ACTION A00mESSEE 4"EPART8M4 &.
T l
A Usm e, i
- h i
.s s
O!SPCSITICN:
1 AEWCAk REPAIR U$E A$ 83
$ CRAP E!
i E
~
See attached i
NOTE: Documentation associated with the disposition and closecut of this NCR l
will be retained in the PPRV filed with the original NCR. Distribution g
copies of this NCR will not have supporting documentation attached.
EMG. AEVIEW/APPmQVs DATE.
/
/
QE REVIEW APPPOVAL:
g OATE.
- = >
. [,.
Y
/
CISPOSITICN VEMIPICATION & C' CSURE.
DATE.
l
/
/
, COMMENT 3:
.