ML20237L453
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| ML20237L453 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/23/1987 |
| From: | Martin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Jennifer Davis NRC |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708200225 | |
| Download: ML20237L453 (58) | |
See also: IR 05000445/1985007
Text
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I NUCLEAR REGULATORY COMMISSION
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,. REGION IV
a I 611 RYAN PLAZA DRIVE. SUITE 1000
/ ARUNGTON, TEXAS 76011
& Cfsf'kG *Janu K ry 23, 1987LW
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NOTE T0:
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John Davis:
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Enclosed is an amendment t6 the material I sent
to you on January 22, 1987
~ Bob Martin
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Insoection Recert 50-445/85-07 50-446/95-05 (85-07/05r
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Concern No. 1 / ]
and PHILLIPS were concerned that Region IV (RIV) management
cowngraded the violation, concerning failure to translate design criterta into
specifications and drawings, to an unresolved item in the inspection report
issued without giving sound NRC regulatory and technical casts and unresolved
stems require no action.
In the inspection report (signed on October 2, 1986,- by the onsite NRC
supervisor and inspectorsi the violation reads as follows:
"6. Failure to Translate Deston Criteria into Installation Scectit cati on s,
Proceduras, and Drawinos; and Failure tc Centrci Deviations from These
Standards
"10 CFR 50, Appendix B, Criterten III, as implemented oy TUGC0 CAP,
Section 3, Revision 0, dated July 31, 1994, requires tnat measures shall De
established to assure that applicable regulatory requirements and the
design basis, are correctly translated toto spectitcations, drawings,
procedures, and instructions. These seasure,s shall include provisions to ,
assure that appropriate quality standards are specified and included in (
design documents and that deviaticns from sucn standards are contr311ec.
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" Contrary to the above, Unit 2 reactor pressure vessel installation l
crateria such as centering tolerances, levelness tolerances (sic], ,and shoe l
to brackat clearances were: (a) specifiec on Constru: tion Operation
Traveler ME-79-248-5500 based on NSSS vendor recommenced criteria which had )
not been translated into CFSES specifications, drawtngs, proceoures, or j
instructions; and it) changed on traveler withcut appropriately dccu. tenting 1
sucn engineering changes.
"This is a Severity Level IV Violaticns (Supplament.II.E) ( 4 4 d S 5 0 5- 0 5 ; .
The downgraded item in the final inspection repcrt reads as fellcws:
"12. Reactor Pressure Vessel and Internals instailatics - Unit 2
(
"ints inspection was perfccmed by an NRC Inspector to .'arify final
placement of the reactor pressure vessel (RPV) and internals by exacining
tne templeted installation and inspection racceds.
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"a. Requirements fer Placement of RPV
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" Requirements for placement of the RPV to ensura proper fit-up of all
other major NSSS equipment are in Westinghouse Nuclear Services
Divisten (WNSD) 'Procecure for Setting of Majcr NSSS Ccapenents,'
Revision 2. dated February 13. 1979, and ' General Rea.t.r Vessel
Setting Procedure,' Revision 2, dated August ;0. 1974 The HR- l
Inspector reviewed the f ollowing drawings, sht:n were ref erencac in
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the RPV operation traveler, to verify implementation at WNSD ---
recommendations:
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*NSD drawing 1210E59 ' Standard - Loop Plant RV Support Hardware
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Details and Assembly' '
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"NSD drawing 1457F27 ' Comanche Peak SES RCS Equipment Supports -
Reactor Vessel Supports'
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"E drawing 10773-171-004 ' General Arrangement Elevation'~
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"E drawing 10773-171-005 ' General Arrangement Plan' '
"Neitner site prepared installation drawings nor spectitcations (which
implemented the WNSD recommended procedures) were available and the
drawings examined did not show certain specific installation criterton q
such as centering tolerances, levelness tolerances and clearance '
between support brackets and support shoes. *
"The inspector considers this matter unresolved. (446/S505-051"
PHILLIPS' Understanding of Concern No. 1
Requirements: The requirements (Exhibits 1, 2 and 3) include the appropriate
10 CFR 50, Appendix B criteria; Final Safety Analysis Report (FSARi; and Texas
Utilities Generating Company (TUGCO) requirements. ,
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These requirements require: (1) design control interfaces between design
organization, (2) the translation of design criteria into specifications and
drawings, and (3) the organt:ational responsibilities must be described in the
organi:ation and program sections of the FSAR and Quality Assurance Plan (QAP).
Noncomoliances With Requirements: The NRC inspection of the reactor vessel
inst'allation activities identified a violation that appeared to be more closely
related to 10 CFR 50, Appendix B, Criterion'!II (Exnibit 1); however, the :1RC
inspectors reali:ed that violations of other criteria procaoly caused this
violation. Instead of writing violations of several criteria, the NRC inspector
selected what he considered the most significant violation and documented Lt.
This approach would allcw TUSCC to address this specific violation and perhaps i
wnat. appeared to be violations of otner criteria when addressing the corrective )
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action necessary, cause of the violation, and steps necessary to prevent
repetition. As TUGC0 was not required to take such action because the vtclation
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was downgraded as an unresolved ites, PHILLIPS identified additional v2clations
during the review of Attachment MM and development of these comments. They are
discussed below.
Introduction: The NRC inspector found that Westinghouse Nuclear service
Division (WNSD), " Procedure For Setting of Major NSSS Components." (a j
Pittsburgh, Pennsylvania procedure and not site specific) hao no signatures !
wnich would indicate that tne document had been reviewed and/or autnori:eo.
There was no evidence that this procecure was revieweo and approvao cy 3 foes k
Hill (3&H) and integrated into a specification, procedure, or drawing. This
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also applies to TUGC0 engineering. It was not included in the site document ---l
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:entrol system as it is probably not appropriate to do so as at is a proprietary {'
procedure with general application. Westinghouse IW1 recommended that the
customer generate a detailed site specific procedure for WNSD site personnel to
review; however, the next sentence disclaimed responsibility for this activity
with respect to W if the procedure, specialist, or consultants were used.
As no G&H specification, procedure, or drawing was developed and placed in che
document control system, it was impossible to meet Criterion III which requires
the same organi:ation that specified the design criteria to review changes.
This happened because the installation criteria were simply taken from an I
uncontrolled procedure and placed in an instruction (the traveler); therefore,
subsequent changes were not approved by the original design organt:ation. This
is contrary to Criterion III which states, in part, " Design Changes, inclucing
field changes, shall be subje:t to design control measures commensurate with
those applied to tne original design and be approved by the organt:ations that '
performed this original design unless the applicant oesignates anotner
responsible organi:ation."
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Failure of G&H to Perform Desian Interface / Coordination Responsibilities
The TUGC0 FSAR, Section 17.1.3 (Exhibit 2), and TUGC0 QAP, Section 3.0,
state that G&H is the architect engineer (AE) and that G&H is required to
control design interfaces and coordinate responsiollities and activities of j
participating design organi:ations. The reactor vessel installation is
dependent on the configuration of the reactor containment building for
which W has no responsibility. The W procedure describes prerequisites
which must be met prior to reactor vessel installation and it appears that
G&H was responsible for controlling such interfaces and ccoroinating such
interface activities.
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The NRC Inspector found no such involvement oY GLH. as evidenced oy a lack j
Of guidance in any specification, draw.ing or procedure reviewed and
approved by the AE.
This violates Centerton III and F5AR 17.1.; c:ncerning design :nterface
responsibility.
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Failure to Desertbe Westinohcuse 3ite Orcartration Responstallities
PHILLIPS found tnat W site organt:ation participate in revising design
:rt:eria; however, the FSAR, QAP, and implementing procedares do not !
describe any such design responsibilities. In a January !!. 1?S7, l
conversation, the W site manager said they have no site design I
responsibility or engineering responsibility. WESTERMAN states in his
testimony (page 73, July 10, 1996) that W is a super Quality Assurance s0Ai
organt:ation that is there to make sure tne utility is not inval: cat;ng the
warranty.
Notet also. WESTERMAN 540 scuot if TUGC0 was casacle of aa:itino tnem.
:HILLIPS areees in Concern No. ! below. WESTERMAN c:ntradicted tnis
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statement later by stating that W approved changes to design criteria on ----
construction operation traveler (traveler) ME79-248-5500,
did not identify the above failure to describe W responsibility
on-site; however, this failure to describe the W site organtcation also
violates Criterion I and II.
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Failure to Include Westinghouse Recommended Desian Criteria Into
'Soect(ications. Procedures, and Drawinos
PHILLIP5andIEEIIIIl~foundnoevidencethat9d'asigncriteriahabeen
formally. translated into the specifications, drawings and procedures; i.e.,
wara not reviewed and apprived by G&H, W, or by TUGC0 engineering.
Instead, PHILLIPS fr.und traveler ME79-2489-5500, which had been initiated
i., accordance with Brown & Root (B&R) construction Precedure CP-CPM-6.3
: Exhibit 4) but which makes no provisions for design responsibilities as
required in Criterion III of Appendix B to 10 CFR 50 or the TUGC0 FSAR and
QAP. This construction document provides great latitude for expediting
construction. It can be initiated and prepared by the construction
superintendent or discipline engineers. It allows approval by the
appropriate GA personnal who have no design responsibility. Procedure
CP-CPM-6.3 (Revision 5) requires W to review the construction traveler but
there is no DA program description or procedu're that describes the W
organization or responsibilities; therefore, neither W or B&R is autnort:ed
to make design changes. The B&R Quality Control (CC) inspectors are
authorized to make minor changes; however, other changes must be authart:ed
by B&R QA.
The y procedure (Exhibit 5) states that W nas no responsibility for
interfacing the Nuclear Steac System Supplies (NSSS) with the plant
structures. The procedure does recommend tolerances out takes no cther
respons:bility. Criterion III requires field changes to me reviewed and
approved by the original organi:ation. The NRC inspector found tnat the
design tolerances on the traveler were not treated as engineering cesign
criteria. No engineering design change authert:ation (DCat was processed
and the traveler tolerance was cnanged by B&R construction, CA, and W
representatives who had no such design responsibilities specifically
delegated to tnem in writing.
Tha s f ailure to translate design requirements into specifications and
I drawings is a violation of Criterion III and FSAR, Section 17.1.0.
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Failure to Follow Traveler Procedurg
lEEEEEEI~revtewed traveler ME79-248-5500 (Exhibit 6) for compliance to
tolerances and was either unaware of traveler Procedure CP-CPM-6.3 or
apparently did not choose to revtew the traveler against CP-CPM-6.3.
PHILLIPS, during the CIA investigation revaewed TU6CC's and
RIV management's claim that this traveler is squal to detaileo pecceduras
which are signed and authert:ed by persons navtng the proper autnority.
FHILLIPS' detailed review revealad tne following deficianc:es or
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noncompliance with the procedure, whicn means it cannot ce considered a "--
complete procedure. As a result, TUGC0 initiated the work with a faulty
procedure.
1. Procedure CP-CPM-6.3 is geared to construction and does not describe
design responsibilities. As indicated in paragraph 3.6.2 of the
procedure, it assumes that specifications, procedures, and drawings
had been reviewed and approved by design organi:ations and such
documents have been collected or referenced in a traveler package
which shows how each construction step is to be accomplished to
achieve the design shown in drawings, specifications, etc. No 4here
in this procedure did it delegate the autnority to change design
documents or criteria. W responsibility was not described other than
to acknowledge their review for :ommercial considerations.
2. Traveler Procedure CP-CPM-6.3, required the traveler package either
conta:n or reference appropriate drawtngs, procedures, instructions,
manufacturer's manuals / guidelines, or other information necessary to
accomplish the the activity. Traveler ME-79-248-5500 did not
reference the @ procedure for setting major NSSS :omponents and did
not incorporate all of this uncontrolled procedure into the traveler;
i.e., the traveler did not show that all prerequisites or conoitions
were met prior to installing the vessel which would be Step i in a
controlled procedure. '
3. CP-CPM-6.3 required that drawings and procedures ce referenced ano the
revision level be provided. No revision level was provided for
drawings 81210E59, W1457F27, C-E 10773-171-004, C-E 10773-!71-005 and
mechanical installation Procedure MCP-1. Thus, there is no assurance
that the correct drawing was used.
4. Step 6 of the traveler did not specift: ally state "not less than
1 inch," as stated in Step J of the W vessel setting procedure.
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5. Revision 4 (Step 11 cf the traveler) changeo the 75% =cntact recuireo l
by the W procedure to . contact area a::aptable to 'd. In this :ase, tne
uncontrolled H procedure was ignorea without an engineering change
ceing processed. M responsibilities onsite were not describeo in the
TUGC0 FSAR, Section 17.1.3, or QAP; however. nese documents 4: 0
assign this responstbtitty to 3&H and TUGC0 :ecause W nac no castgn
responsibility onsita. Without a cascriptian :f W in enese occuments,
the W representative may ce anyone; 1.e., requires no tecnrt:si
expertise.
o. Revision 3 documentee the violation at Step 1 for minimum engagement
for guide pins. The same : cements apply as far Revision 4
'. Revisi:n 2 deleted tne machining requirements witneut engineering
review and justift:ation. The same ::mments a 01 y ice Rev;ston 4
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8. Revision 5 changed the requirement to 0.020' for each side of the
vessel supporting to a range ci 0.015 to 0.025" for each sica. The
same consents as for Revision 4.
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9. The ! representative accepting revisions / deviations of the i
construction traveler (although inappropriate) does not appear to be
the same as the person who approved the original traveler. CP-CPM-3.3
required those who reviewed and approved the traveler during l
preparation must review and approve major changes to the precedure. -
Since ! responsibilities were not described, there is no way to
identify who in the M on-site organization or other M organizations --
was authorized to change tha uncontrolled procedure to the
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construction traveler.
10. Considering that the construction traveler was used instead of a
procedure (reviewed and approved by the appropriate design engineering
and QA/QC organizations) nonconformance reports (NCRS) should have
been written when the required tolerances were violated. As a
sinimum, appropriate site engineering and QA/QC organizations should
have dispositioned such deficiencies.
In September 1985 and presently, PHILLIPS understands the initial violation. He
also realized, then and now, that there are several other potential violations
in addition to M proposed violation which was dropped; i.e., additional
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violations of Criterion I and Criterion Il--TUSCO failed to describe ! in their
CA program; violation of Criterion V--failure to fo!!aw procedure CP-CPM-6.3;
Criterion VI--failure to control'the ! docusants; and Criterion XV--failure.to
wette NCRs. Neither B&R construction, QA or M even justified changes to
informal M documents and in some cases gave arbitrary tolerances. There was
more than enough information to cite the originally proposed a violation.
PHILLIPS' Understanding of Handlino/ Mishandling Concern 1
Backoround irected PHILLIPS to review the NRC MC 2512 inspection
progras in 0, ober 1984 and during this review of the NRC Fore 766 program
covering 10 years, it was f ouno that the storage and handling was caserved by
the senior resident inspector but the installation of the vessel was not j
inspected in accordance with inspection Procedure (IP) 50053. Procedure 50053B
showed completion by a RIV inspector in the Inspection Report 80-26; however,
vessel installation was really not observed as reported in the NRC Fore 766. j
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PHILLIPS subsequently learned that CASE, the intervenor, had suositteo -
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Contention 5 (Exhibit 7) to the Atomic Safety and Licensing Board (ASLB) which
stated that TUGC0 failed to adhere to quality assurance / control provisions, ;
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Appendix'B of 10 CFR 50, and the construction practices for various work and
specifically the placement of the reactor vessel for Unit 2.
In late 1984 and early 1995, M and PHILLIPS cecided that the
installation of Unit 2 shoul'7eo inspected to the degree possible (since
installation was completed July 26, 1979) because NRC inspection of the actual
installation was not apparent and this issue would likely be covered during the .,
hearings. When WESTERMAN replaced @ nd assuaec responsibility for the RIV l
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Comanche Peak Task Group, PHILLIPS discussed these issues with has and the '
importance uf the inspection. -
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In addition to this information, PHILLIFS and WESTERMAN were aware of* findings
in " Miscellaneous Item 2, Reactor Pressure Vessel," of NURES-0797, Supplement 8
(Exhibit 6), which describes problems found with regard to installing the Unit i
vessel. In this case, a design change was not properly coordinated between W,
6&H, and TUSCO to assure that design , requirements were incorporated into project
specifications, drawings, procedures, and instructions / travelers. This failure
to interf ace resulted in deficiencies; i.e., reactor vessel and insulation to -
the reactor vessel cavity fit, caused unacceptable conditians which were .
identified during hot functional testing.
PHILLIPS was also aware of another deficiency (Exhibit 9) which should have been
reported as a 10 CFR 50.55(e) deficiency. On February 20, 197o, TUGC0 reported
that a major error had been detected in the as-built configuration of Unit 2
reactor vessel support structure; i.e., the reactor vessel support shoes, their
ventilation duct work, and surrounding reinforcing steel had been rotated.45
degrees from the correct positions. Apparently, just prior to installing the
vessel, TUGC0 learned that the reactor vessel would neither catch the vessel
support feet nor would the piping system fit the other reactor loop cooponents.
This appears to have been caused by another design.interf ace problem; 1.e'., G&H
not assuring that prerequisites for vessel setting were acceptable as
construction proceeded.
Proper Handlino:
PHILLIPS provided this background information tolllllll(prior
to helping his prepare for his inspection and explained vessel installation
Procedures IP 50051, 50053, and 50055 (Exhibits 10.a, 10.b, and 10.c) which .
require review of procedures, observation of work in progress or completed work,
and review of records. HUNNICUTT,RIVsupervisoron-site,directedEEElll[to
inspect the area and report his inspection findings. These findings were
submitted to HUNNICUTT, the reviewing supervisor, who was stationed on-site from
early 1984 through Jul .or August 1995. On June 10, 1996, tnis violation was
revtewad by , Branch Chief, and HUNNICUTT, prior to the management
exit interview. t was revtewed during the exit interview with MERRITT, TUGC0
Construction Manager; HALSTEAD, TUSCO Site QA Manager; and WELCH, Site QC
Supervisor; and they all acknowledged the violation. TUGC0 representatives were
also well aware of this violation in advance of the exit meeting.
CUMMINGS, a second Senior Resioent Inspector, took the lead with respect to
writing the report. The draft report (Exhibit 11) was completed. HUNNICUTT
asked PHILLIPS to review only the paragraphs of the report which he had written
because PHILLIPS had several special projects assigned, including involvement
with South Texas hearings and the Houston Lighting & Power vs. Brown k Root
lawsuit.
findings atPHILLIPS
this pointhadotheralmost no involvement
than routinely withinspection
discussing @ nsfection and with
results
l hia.
PHILLIPS assumed responsibility for reviewing the final draft report for I
accuracy when CUMMINGS left the site in August 1985. Acout Septancer 1989
WESTERMAN askeo FHILLIPS to become technically involved and to reva aw _ t
findings because,HUNNICUTT and CUMMINGS were no longer en-site. Also, in late
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August 1985, TUGC0 had complatned that they did not agree with all of -
findings. In late August or early September 1985, PHILLIPS and set with
TUGC0 representatives who presented information concerning ftndings.
The information presented at this ttee should have been readily available to
TUGC0 during the inspection and well before the exit. In any event, TUGC0
should have responded within at least a day or two after the extt meeting to
show compliance. Regardless, @ agreed to limited changes based on
information presented in these seatin s. PHILLIPS also arranged for discussier.s
between BOSNICK, NRC headquarters, Acui PHILLIPS. The final report was _
revised to reflect these changes anc on this basis PHILLIPS signed and concurred *
with it. HUNNICL'TT also signed on October 2, 1985 (Exhibit 12).
Mishandlinot WESTERMAN replaced % n August-September 1985; JOHNSON
replaced M ANd WUNNICUTT was removed fraa site.
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The mishandling occurred
shortly after WESTERMAN and BARNES were assigned to the RIV Comanche Peak Task
Group and case on-site. According to WESTERMAN's July 20, 1986, statement, it
appears that WESTERMAN sought out TUSCO personnel who were following up on i,e
report because in his sind, he questioned the violation concerning Item 10 in
Exhibit 11; i.e., where the NRC inspector was unable to retrieve records.
WESTERMAN further stated that he knew TUSCO's system was not fast but they have ,
always been able to come up with documentation. As a. result of TUSCO's ability
to retrieve one single piece of paper two months after the exit, WESTERMAN
launched into a reinspection of virt ully all findings. WEETERMAN
directed PHILLIPS to review findings and meet'with TUGC0 to listen to
their disagreement with fin'ings.
d PHILLIPS does not recall TUGCO's
ever disagreeing with Concern No. 1 in those meettngs but they did disagree with
some findings on the ASME Section III Code.
The final inspection report (Exhibit 12.a) was forwarded for N00 NAN's review and
apparently HAUGHNEY's consents were taken as an opportunity to make additional
changes. In this case, a consultant, who had reviewed and inspected nothing,
was used to counter the inspector's detailed review and inspection. WESTERMAN
subsequently set with and/or had long and loud conversations with PHILLIPS and
M several times between September 1885, and January 1996. was
badgered and harassed, for no good reason, to change his findings.
disagreed with WESTERMAN tach time he tried to persuade him that Co'ncern No. I
was not a violation. WESTERMAN attempted to solicit PHILLIPS support to
PHILLIPS
convince @ this
did not suppert was neither but
WESTERMAN a violation or an
agreed with unresolved
M and ites.
stated that this was
clearly a violation. WESTERMAN's attitude toward PHILLIPS changed at this point
and pressure and harassment to wear PHILLIPS down has continued until the
present.
It was WESTERMAN's responsibility to escalate the differences but instead
WESTERMAN ignored the differing professional opinions of both @ }nd
PHILLIPS and directed that the vtolation be downgraded to an unresolved iteo
without basis (Exhibit 13). This also appears to be snappropetate as it appears
that M and CUMMINGS were not contacted to get their understanding, advice,
or concurrence on such changes to the report. It is not clear as to whether
HUNNICUTT was informed of the difference and changes.
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PHILLIPS signed the re,2 't in October and thought that WESTEJAN had in some way - -
resolved
1986. PHILLIPS the issue
later wibe Q'c[ame aware that M h d refused to sign the reportM iefo
and never had agreed with downgrading the violation.
E and ,
[tatedtheirdifferenceoftechnicalopinionconcerning
changes in the final inspection report. JOHNSON, HALL, WESTERMAN, and BARNES
had a meeting with M and M 'on February 25, 1986, but PHILLIPS was not
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invited to this meeting. RIV management simply ignored PHILLIPS, CUMMINGS, and
perhaps HUNNICUTT as thay were not allowed to attend. If RIV management had
required all to attend, differing professional opinions would have resulted.
PH!LLIPS Understands A pi Safety Significance
This concern is significant.from several standpoints such ass (1) Contention 5
licensing issue, (2) failure of NRC management to regulate instead of proacte
the licenstng of Comanche Peak Steae Electric Station (CFSES), (3) TUGCO's GA
program and plan deficiencies, (4) technical deficiencies, and (5) differing
professional opinions. -
1. The significance of Contention 5 is that it claims that quality
assurance / control provtstons required by t!fa construction permits and
Appendix B of 10 CFR 50 were not adhered to concerning the placement of the
reactor vessel for Unit 2. It appears that the TUGC0 quality program was
not properly controlling all aspects of this activity; however, NRC
management refused to issue a violation which would have assured TUGC0
would take appropriate corrective steps.
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WESTERMAN, supported by BARNES and JOHNSON, made it clear to d
PHILLIFS that they were expected to promote the licensing process and to do
the work for TUGC0 by going to extremes to help them show comoltance. The
two NRC inspectors were held to unrealistic performance stancaros
concerning how far one must inspect after a violation is identified, in
this instance, while expecting little or no performance from TUGC0 to snow
compliance in a reasonable period of time.
3. The TUGC0 FSAR and QAP describe the design responsibilities; however, at
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appears that GtH did not discharge their respensteilities regarding tne
coordination of design responsibilities pertaining to civil structural, and
NSSS component interfaces as evidenced by their failure to develop
specifications or drawings wnich would incorporate W installation criteria.
Stallar problems were experiences concerning the vessel supports for
Unit 2, which should have been reported as a construction deficiency, and
if identified may have identified this problem as part of the corrective
action. The onsite W group responsibilities were not descriceo in the
FSAR, QA Plan, or other procedures; therefore, y activities are not under
l the control of the TUGC0 program and this is significant as, acccraing to j WESTERMAN, they were apparently performing engineering design functions.
Traveler Procedure CP-CPM-6.0 was supposed to be equivalent to a detailed
procedure; however, the failure tc follow this procedure defeated this
prentse. It is unrealistic to expect the traveler system to include all
design criteria and be a design cortrol document.
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,
.
-
10
)
!
4. and PHILLIPS do not agree with tne statement that DIA -
concludes no hardware problem exists. Only the AE, NSSS, and TUGC0 can
jointly determine this. NFJ anspectors perform ge'eraln inspections of
design, procurement, and construction on-site, but usually have little or
no der,tgn engineering expertence. Therefore, few NRC inspectors are j
qualified to evaluate the complex design of the plant. Instead, NRC
l
tnspectors assume that design criteria is specified by the AE or other j
design organizations and inspect for compliance to such criteria. Hhen
noncompliance are' identified, a violation is issued concerntng failure to
meet this criteria,and then, TUGC0 and the design engineering organization {
are required to evaluate this deficiency ano take appropriate action.
Since no violation was issued relative to this concern, the overall. -
technical significance is unknown until either TU0C0 or NRC engineers, with )
design expertise, fully evaluate all aspects of these deficiencies. It is
also unclear as to whether the prerequisites for vessel setting (Steps 1-19
of W procedure) were met as they were neither referenced nor checked off an
the traveler. Failure to meet the prerequisites could cause design
interface problems with other components because all they depend on
acceptable installation of the reactor vessel.
5.
d PHILLIPS have all been estraci:ed, downgraded, defamed,
disfranchised, and penalized for having differing professional opinions
with JOHNSON, WESTERMAN, and BARNES. They have been ridiculed to their
peers, who have carried away these attitudes and in some cases, false
rumors. WESTERMAN, acting as an agent of JOHNSON, harassed and pressured
4 [o change his findings to the point that he probably would have
given up if PHILLIPS had joined forces with WESTERMAN and JOHNSON. Despite
% ]nd PHILLIPS' differing opinions, this violation was downgraded
without sound regulatory or technical support. Subsequent meetings on
these differences have shown inspectors the futility and dangers of
expressing differing opinions. This message has a chilling effect on
inspectors and leads inspectors to take the easy way and that way is to
staply avoid differences by never documenting violations. The safety
significance of this effect is unmeasureacle because ci ths great influanca
that the NRC has on licensees and applicants.
The changing of reports after the inspectors have signed and concurred 11
unprofessional.
Again, the message is so strong concerning otftering
opinion, that the health and safety of the puolic is not well servec.
This appears to be a persuastve RIV samagement attttude. It is so strongly
promulgated that RIV inspectors soon learn to conform to the " party line"
and sit back, relax, and draw their pay. M says it quite well in
quotes shown in Exhibit 12.b.
Concern No. 2
PHILLIPS was concerned that RIV management downgraded _ stolation
(described below) to an unresolved item and because sound ragulatory and
technical basis were not provided to support their action. Also unresolved
items are a concern because they co not require TUGCO.to respon: to the NRC to
explain the corrective action, cause and future prevention of the violation.
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* '- 11
.
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In the signed inspection report the violation reads as follows:
"7. Failure to Maintain Tolerances Recuired and failure to Recort Tolerance
Deviations.on a Honconformance Recort
"10 CFR 50, Appendix B, Criterion XV as implemented by the TUSCO QAP,
Section 15.0, Revision 2, dated May 21, 1981, requires that seasures shall
be established to control saterials, parts or components which do not
confors to requirements; and nonconforming items shall be reviewed and _
ac:spted, rejected, repaired; or reworked in accordance with documented
~ ~
procedures.
" Brown and Root Quality Assurance Manual, Section 16, dated March 27, 1985,
requires that unsatisf actory conditionr i~dentrTTa3 on process control
documents shall be identified on a nonconforming report.
" Contrary to the aDove, clearances between the reactor vessel support
bracket and support shoes were not within the original or revised
permissible tolerance stated in Construction Operation Traveler ME79-248-55
and the deviation was not reported on a nonconformance report.
"This is a Severity Level IV Violation. (Supplement II.El (446-8505-56)
'
Violations which were droppw.d or downgraded to unresolved itses do not receive
the following treatment: ,
" Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric
Company is hereby required to submit to this office, within 30 days of the
date of this Notice, a written statement or explanation in reply,
including (1) the corrective steps which have been taken and the results
achieved; (2) corrective steps which will be taken to avoid further
. violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause
shown."
The final inspection report issued February 3, 1986, dropped these findings.
The items just disappeared.
PHILLIPS' Understanding of Concern No. 2
Recutreeents: The requirements are described in Exhibits 1, 14, 15, and 16 and
include the appropriate Criterion (XV) of Appendix B to 10 CFR 50, TUGCC FSAR
and QAP, and B&R QA Manual (QAM). These documents require the identification
and correction of deviations, deficiencies, defective material and equipment,
and nonconformances.
. Noncompliance with recuirementst PHILLIPS reviewed f' d'ng and
i
violation which had been approved by previous supervision and
HUNNICUTT). In September discussions withlEEEEEEE'related to Concern No. 1, it
wasapparenttoPHILLIPSthatjllllll understood the issues and had identified a
failure to occusent out-of-tolerance conditions and have
_
second violation; i.e.,
appropriate engineering organizations evaluate the nonconforming condition.
I ! L_ ___ _ _ ----
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,
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.
PHILLIPS subsequently inspected the vessel installation and identified other --
instances where a NCR and/or DCA would have been appropriate. See discussten in
Concern No. 1.
(PHILLIPS' Understanding Of The Concern) which discusses
revisions to the traveler to disposition several failures to meet W tolerances.
PHILLIPS' Understanding of How Ccncern No. 2 was Mishandled
Same as Concern No. 1.
I '
PHILLIPS' Understanding of Safety Significance -
.
-
' This concern is an extension of Concern No. I and the safety significance is
virtually the same.
Concern No. 3
and PHILLIPS were concerned
violation that RIV sanagement downgraded
(described below)
to an unresolvec item and because sound
' regulatory and technical basis were not provided to support their action Also, .
unresolved cause,
correction, items do not require TUGC0 to respond to the NRC to explain the
and future prevention of this violation.
.
"
The following violation was originally proposed in Exhibit 11. 4
"8. Failure to Audit RPV Specifications / Procedures.
Records Installation and As-built
"10 CFR 50,
Assurance (QAlAppendix
Plan, 8, Criterion XVIII as implemented by the TUSLO Guality
Section 18.0, Revision 2, dated July 31, 1984,
requires that a comprehensive systes of planned and periodic audits be
carried out to verify compliance with all aspects of the quality assurance
progras.
" Contrary to the a'bove, there was no evidence that TUGC0 had auditro either l
Unit 2hardware
actual reactor vessel installation spectfacations, placesc.-d proceoures,
placement, or as-built records.
"This is a Severity Level '!V Viol ation. (Supplement II.E) (446/8505-08)."
The downgraded ites in the final report (Exhibit 13) reads as felicws:
"d.
Records of CA Audits er Surveillance
The NRC inspector requested
by TUGC0 of the Untt 2 RPV installation.TUGC0 QA audits or surveillance performed
TUGC0 did not make available
any documentation
spectfted placeaant of an audit or surveillance which evaluated
criteria, placement procedures, hardware
placement, or as-built records.
This ites is unresc!ved pending a
more comprehensive review of these activities (446/8505-07)."
NOTE: See Exhibst 11 and 12 for report details that explain the basis for these
violations which were described in the Notice of Violation. I
1
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PHILLIPS' Understandtna of Concern No. 3 ' ~~'
Requirements! The requirements for auditing'(Exhibit 1, 17, 18 and 19) include
Criterion XVll! of Accendix B to 10 CFR 50 and TUGC0 FSAR, Section 17.1.18; and
QAP, Section 18. jlllllfiidnotincludeareferencetoB&RGAN, Section 19.0,
and implementing procedure QAP-19.1; however, B&R also had responsibility to
audit the installation of major NSSS components but no evidence of such audits
have been found. Also, both TUGC0 and B&R were required to implement ANB!
N45.2.12, " Quality Assurance Program Auditing Requirements for Nuclear Power
.
Plants." Criterion XV!!1 requires a comprehensive system of planned and
periodic audits be implemented to verify compliance" with all asoects of the
quality assurance program and to determine the effectiveness of tne program.
ANSI N45.2.l'2 (Exhibit 18) describes, in detail, the sinimum requirements to
meet Criterion XVIII of Appendix B and specifically addresses tne need to plan
the audit program which includes auditing complex activities. The W
installation procedure (a complex activity) states that the reactor vessel must
be set correctly as it is key to installing all other major components. In this
case, there was not only a requirement to audit complex vessel installation
activities, but also a requirement (Exhibit 18, paragraph C.4.3) to perform
supplemental
audits because of previous qualitg and design problems; i.e., the
reactor vessel supports were installed some 44 out-of-talerence and relates to
failed design interfaces between G&H, y, and TUGCO.
Noncompliance with Requirements: lllllll[requestedauditsofthereactorvessel
installation because of Concern No. I and'2, and previous installation problems.
jEEEEEEl3nspectedtodeterminewhy TUGC0 had not identified failure to control
design t'n Concern No..I and to issue a nonconformance on out-af-talerence
conditions as described in Concern No. 2. He contacted WELCH, TUSCO Site QC
Supervisor, to determine if audits had been performed concerning :he
installation of the Unit 2 vessel. TUGC0 found no audits of these activities
andlllllll}'asalsoinformedthatnosurveillanceswereperformed.
This failure to audit this complex and critical NSSS activity is a violation of
Criterion XVIll of Appendix B to 10 CFR 50.
PHILLIPS' Understanding of How Conceen No. 3 Was Handled /Mishandlec
The basis of the mishandling starts with the philosophy described in
Exhibit 12b. In order to understand the handling and mishandling at this
specific concern, it is important to understand the background concerning
TUSCO's audit program. Also, this failure to audit cannot be considered an
isolated case where the audit program did not work and this is supported by
comments in the next paragraph.
Backoround: TUSCO obtained their construction permit December 19, 1974. The CA
program delegated certain audit responsibility to the AE, NSSS, and the
constructor. Because of their dissatisfaction with G&H, AE, and tne contractor,
B&R, TUGC0 took away certain responsibilities from tnese organt:ations and one
specific function was portions of the audit function. TUSCO unwisely assumed
audit responsibilities that a highly experienced 11censee usually does not
assume and as a result, the IUGC0 audit prograa has been continuously oeticient.
A 1984 NRC inspection of TUGCO's audits of W site and TUGC0 sita activittas
.
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( 14
revealed violations whicn were documented in the Inspection Report 8462/11 -
(Exhibit 20). It also appeared that SLR eite work activities nad not been
properly audited. Specifically, the sCcond part of the 64-32/11 Inspection was
to similarly review the BLR audit program; however, PHILLIPS was unable to
complete the inspection due to limited resources and other assignments. As the i
B&R audit program was also suspect, this inspection was to be continued by C. l
HALE's group on-site.
{
In addition, one must also consider that three consultant's reports, by LOBBIN !
and Management Analysts Corporation (MAC) indicsted that in 1976, 1977, 1976, I
and 1982, serious problems, existed in the TUSCO and B&R QA program; nowever, 1t
appears that TUGC0 took ltttle or no corrective action to correct these
deficiencies. One of the significant itndings that was common to TUGCC and 3&R
~~~j
In these consultant's reports was ineffective audit programs. Since the auctt
programs validate the other 17 criteria of Appendix B to 10 CFR 50, tnis 2s
signaticant because of the impact on many other areas wnicn may ce deficient and
go undeti:cted.
PHILLIPS also found that the NRC had not perforaeo'an in-depth review of the
- TUSCO corporate office from 1974-1984 Because of this, previous violations ano
'
fa21ure to perform required IE inspection, PHILLIPS has emphasiced the
inspection of onsite audits by TUGCC and B&R to deteretne what activittns have
or have not been audited by TUGC0 and B&R. In cases where audits have not been
performed, RIV management takes the position that there is nothing that can be
done as the opporutnity to audit has been lost. This is not entirely accurate
as those activities can still be audited through the review of completed work
records and accessible attributes for equipment or components may still be
observed as a part of tne audit.
In 1978, MAC (Exhibit 21) conducted an audit of TUSCO which was highly cr2tical
of many TUGC0 QA program areas such as organtcation, design, procurement,
complicated procedures, inadequate inspection criter2a, in-service inspection
ma-ktngs, exclusion of proper engineering of nonconformances, records storage j
facility, and an inadequate audit program. These areas impactec techn: cal work.
Although Concern No. O relates to audits, tne audit program is responsi:le for
assuring these other deficiencies do not exist. Subsequent NRC Inspections nave
snown that corrective action was not taken on these deficiencies until 1994 and
in some cases certain of these corrective actsans were not effective. In May
1985, PHILLIPS received the ASLB Notif; cation fres TUSCO attorneys, WORSHAM, .
FORSYTHE, SAMPLES & WOOLRIDGE memorandum (Exn2 bit 22), dated May 29, 1995.
According to this memorandum, it appeared tnat TUGC0 made a material false
statement to PHILLIPS during the NRC S4-32/11 inspection of corporate aanagement
as they said they had no other consultant reports but they nad this report that
was criti
and the r,esulting
cal of the areas thatNotifteation
PHILLIPS was inspecting. The NRC investigation
NRC Board 35-067 and 55-076 (Enhisit 2D
confirmed this material false statement; however, 0! failed to confirm an
additional material f alse statement about TUGCO's knowlecge of tne MAC auct; of (
BLR.
In January 1996, PHILLIPS ident:ited defic:encies in :ne B&R audst program and
followec uo en :nese NAC auctts. In 1956, it became evident tnat TUSCC ano skR
had still not taken complete ano effective corrective act2on :oncerning tne:r
1
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gg
audit programs, in May 1986, PHILLIPS wrote violations for fatlure to take "--
corrective action but in September 1986, was directed by IE headquarters and RIV
management to drop these violations out of NRC Inspection Report 96-08/06
(Exhtbit 30) as they claimed C. HALE, NRC inspector, would take care of the
violations. To date, these violations have not Deen issued and in a recent
conversation with HALE (on January e, 1986) he said he had no intention of
following up on the MAC reports. If violations are not written, PHILLIPS has
informed RIV sanagement that a differing professional opinion will be written.
In February 1982, pages 1, 2, 3, and 14 of the P. S. LDBBIN audit (Exhibit 24)
,
again advised TUSCO manageeent of serious deficiencies in the QA program which ,
included inadequate expertence, deftetent audit program, and an ineffective
surveillance program. On June 1, 1982, a TUSCO letter (Exhibit 25) sent a copy
of this audit to RIV. Contrary to what WESTERMAN says in his statements, this
should have caused an in depth audit in accordance with IE Procedure 35060,
" Audit of Licensee Management of QA." This alone made Procedure ;5060 priertty
and it should have been performed in 1980 under MC 2512, priority 2, and special
audits in 1981, 1992, 1983, and 1984 until these problems were resolved.
RIV took no such action and in fact TUGC0 management of the QA fun: tion was not
audited in depth from 1974 until PHILLIPS audited TUGC0 in August 1984.
WESTERMAN became very def ensive about this; i.e., RIV failed to perform QA
inspections and this was in November-December 1, 1984, before he was reassigned
to Comanche Peak.
He later made veiled threats to PHILLIPS about these matters
it in' December 1985 while assigned to Comanche Peak.
j
l
NRC Construction Assessment Team (CAT) Report (Exhibit 26), dated April 190s, i
(conducted January 24 through Maren 3, 1983) identified sertous QA and hardware
violations. The audit program (Exhibit'26, pages 1, B-1 through B-3,. and VIII-1 j
through VII-3) was again singled out and this time it was tied to causing HVAC. '
and electrical separation deficiencies. RIV vtgerously opposed the CAT team
while onsite and later their inspection report findings. The qualifications of
the team were, questioned. Again RIV ignored the QA program deftetenctes at
TUSCO corporate office and failed to perform required QA inspection per
.
Procedure 35060. Even today, it is clear that RIV management and inspectors
I
still believe Comanche Peak ts the best plant in the country and the fault was l
with CAT members and Technical Review Team, et al.
l
NRC Inspection Report 84-32/11 (Exhibit 20) NRC
Division Director, directing PHILLIPS and two NRC consultantswas o aucat the result of lllllll T
management of this QA program. In preparing for this inspection per
Procedure 35060, PHILLIPS reviewed old inspection reports and interviewed
inspectors.
PHILLIPS contacted CAT inspectors to avetd dupitcation of effort.
HANSEN, NRC CAT inspector, told PHILLIPS he inspected the progras at the TUGC0
Dallas office but really had not had enough time to completely analy:e their
progras; however, he considered their audit program to be somewhat deficient
from 1974 through 1982. HANSEN sent his field notes to PHILLIPS prior to the
inspecticr.
As a result, this inspection was also a follow-up on has findings.
PHILLIPS elected to audit TUGCD's program for 198; to avoid dupitcation.
PHILLIPS found serious violations tnat indicated they had not corrected the
deficiencies (Exhibit 24 and :6); however, in August 1984, PHILLIPS was unaware
- _ _ _ _ _ - _ _ - _ _ _ _
_ _ _ - _ _ _
. ,
16
of the MAC audit of TUSCO (Exhibit 21) as TUGC0 purposely dented NRC this -
information.
Pages P-31 through P-33 (Exhibit 27) o RC ER No. 11 of NURES 0797 referenced
PHILLIPS' 84-32/11 inspection report. elected to have TUGC0 respond in
the Action Plan and final TU6CO Result Report; however, this was done with the
thought that TUSCO would take prompt corrective steps and advise NRC of the
results in a satter of 3-4 sonths. This did not happen because the TUSCO
Results Report on audits was not issued until April 1986. PHILLIPS became
uncomfortable with TUSCO's delay in Septesber through Octater 1985, and wrote -
senos to both WESTERMAN and HALE (RIV CPTB) to folles-up on 84-32/11. This did
not happen until about March 1986. However, PHILLIPS disagreed with HALE and '
the Results Report because it appeared that TUGC0 has still not corrected the
probles, determined the cause, and took steps to preclude repetition. This was
based on PHILLIPS findings in February 1986, which showed tnat in 1980 B&R had
not audited 12 sections of their ASME QA sanual and 11 sections of Appendix B to
10 CFR 50. This was teentified in February 1986, but WESTERMAN downgraded this
violation to an unresolved ites. This was subsequently documented in PHILLIPS'
Inspection Report 86-08/06 with two other violations (concerning TUGC0 and B&R
failure to take corrective action) which were dropped. PHILLIPS was told he
could not follow up on his own findings in 84-32/11 as this responsibility had
been given to HALE. This is most unusual. Little.or no coordination with
PHILLIPS has occurred on the closure of his findings.
Inspection Specific Action Plan VII.a.4 (Exhibit 28, pages 5, 6, 7, 8, and 9)
and Results Report VII,.a.4 (Exhibit 29) are TUSCO's answers to audit progras
deficiencies; however, they do not specifically address the MAC audit
deficiencies ar.d B&R audit progras deficiencies. That is the reason that TUGC0
should be cited f or f ailure to take corrective action.
TUGC.0 has never specifically responded to these violations and PHILLIPS is
concerned that Unit 2 will be almost complete before they respond and by that
time there will be nothing to correct. PHILLIPS contends that corrective action
has not been taken by TUSCO and B&R concerning deficiencies in the site audit
prograss. The RIV GPTS management has not required prompt corrective steps of
TUSCO, especially with respect to the finding in 84-32/11 and previous NRC
inspection / consultant findings. Although the above events happened outside the
specific inspection period of Concern No. 3, such information shows the
continued pattern of dropping violations and disregard for QA.
Procer Handlino The inspection and documentation was properly handled while
directed by M ~HUNNICUTT, and CUMMINGS. PHILLIPS' involvement was
_
-
secondary as he only provided EEEEEE(with background inf ormation relative to
inspection Report 85-07/05 and guidance on the requirements of IE IP 50051,
50053, 50055, (Exhibit 10) which cover inspection of reactor vessel procedures,
work installation, and records of all activities. Exhibit 10 (50055 page 11-1;
shows the IE requirement to inspect audits (quality control inspections)
performed during various reactor vessel activities.
I5lllll(under HUNNICUTT's supervision, proceeded to inspect in accordance witn
Exhibit to and documented his findings. ]Elllll[Tound that reactor vessel
installation (and no other audit of any NSSS component was offered) had not been
.
_ _ _ _ _ _ . .
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< s
. . 17
.
audited by TUGC0 and no surveillance were effered to snow that something was
l done. At the exit interview, M with Mnd HUNNICUTT's concurrence,
identified this failure to audit as a violation. Three senior TUGC0 managers
(MERRITT, HALSTEAD, and WELCH) were at the exit and acknowledged this finding.
They offered no discussion or disagreement. As previously discussed in Concern
No. 1, the report (Exhibit 11) was processed for inspectors final signature.
The handling was proper to this point.
Mishandlinal As discussed in Concern No. 1, the sashandling, again, occurreo
because of attitudes described in Exhibit 12.0. The handling was proper until
WESTERMAN and BARNES became involved and stated that this was no violation
because Criterion XVIII of Appendix B, 10 CFR 50; FSAR, Section 17.1; and ANSI
N45.2.12 requirements do not specifically require that the audit activities
concerning the reactor vessel activities.
PHILLIPS disagreed with this narrow interpretation of the regulations because
NRC regulations require the audit of many things that are not specifically
called by name in (Exhibit 1, 17, 18, and 19) regulations and requirements.
This illogical reasoning cannot be appited to auditing as it would allow TUSCO
the option of choosing to audit the residual heat removal system but not the
safety injection system, or worse, if carried to further extremes as the audit
requirements do not specifically name the NSSS systems.
PHILLIPS further contended, with no success, that the narrow logic that TUGC0
does not have to audit the reactor vessel activities is unsound because it
ignoress (1) previous NRC findings and problems experienced with Unit 1 and
~
Unit 2 reactor vessel, (2) Contention 5, and (3) NRC and ANSI standard
requirements. The logic was also unsound because it also reasons that a
component does not have to be audited because NRC regulations and ANSI standards
do not specifically name components to be audited.
Appendix B, Criterson XVl! (Exhioit 1) states that s!1 aspects of the GA program
shall be audited to determine compliance and effectiveness. PHILLIPS concludeo
that all aspects also includes important components such as the reacter vessel.
The FSAR list of quality items (Exhibit 31) lists four major NSSS components
that have always been high priority items for the Applicant and NRC relative to
observation of work. The reactor vessel has always been given the highest
priority and order of protection. It is reasonable to expect TUGC0 to audit all
four NSSS components listed in the Q table.
FSAR, Subsection 17.1.18, and the TUGC0 QAP, Section 18.0, repeated the werds of
Criterion XVIll of Appendix B to 10 CFR 50 and has placeo this requirement on
the AE, NSSS, and site contractors (Exhibits 17 and 18).
The FSAR and QAP are cited as examples of requirements; however, while making
l
the comparison during the preparation of Comments on Attachment MM, it also
i became evident to PHILLIPS that natther of these documents references ' ) paragraph 3.4.3 of ANSI N45.2.12 nor incorporates all of the specific { requirements of this standard; i.e., supplemental audits which are to be l performed at specific times in the contract life wnen significant i reorgant:ations or proceoure revisions occur and when safety-relateo stems are
_ _ _
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* * .
18
1
in jeopardy, etc. The same is true of QAP 18.0 (Exhibit 191. This is an
example of a deficiency in the QA program a'fter all of TUGCO's reviews. This is
another potential deviation that has not been addressed and this deviation has
caused TUSCO to fail to perfors reactive audits and it say be a violation.
Again, this probles can be traced to probless with procedures discussed an the
MAC Report (Exhibit 21).
BARNES, HALE and WESTERMAN in O!A statements (D, J, and N) reiterate that .to
audit of the reactor vessel is required but offer no evidence other than that is .
their belief. Individuals saking statements J and.4 have no construction *
experience, that I as aware of; i.e., until reassigned from the NRC Vendor
Program Branch in late 1984. Experienced construction inspectors know
procedures and the requirements and how the requirements have teen applied
during construction. The individual in statement D has scae construction
expertence; however, he argues against any violation in tne Appitcant's f avor.
With this combination, faulty reasoning has prevailed and findings were
downgraded regardless of the requirements. These individuals ignored the fact
that previous probless in this area should have caused suppl.esental audits in
additten to routine audits to restore confidence in quality control,
engineering, and construction work over the years. A violation should have been
issued. ,
The saga of this failure to audit cannot yet be concluded. In May 1985, the
TUGC0 QC supervisor followed-up on this item and concluded, as WESTERMAN did,
that no audits were, required on the reactor vessel. PHILLIPS believes that this
is whers WESTERMAN's position originated on this issue; i.e., from TUGC3.
Mand PHILLIPS set with TUSCO, at WESTERMAhls insistence, sonths af ter the
exit meeting, and M and PHILLIPS asked at this meeting for any
surveillance or audits by TUGC0 or BLR. Between September 1985, and ,
I
Feoruary 3, 1986, when the Inspection Report 86-07/05 was issued, the TUGC0 QC
supervisor offered nothing to the K or PHILLIPS concerning the unresolved
ites in Exhibit 13, as he had what the wanted--the violation dropped. In
Nevesbar 1986, the Senior Resioent Inspector insisted on having information and J
the QC supervisor finally provided a few surveillance but found that no audits j
of sajor NSSS equipment installation. This information was proeuced only ~
because the NRC inspector inf os ted him that he would go to the next level of
supervision to get the information if he did not cooperate.
Safsty Stanifteances The significance of this concern is similar to Ccncern
No. 1. In addition, this ites has been unresolved over one year without any
real correctivs action by TUGC0 (i.e., TUGCD did not aucit the installation
records or if they did, they were not required to advise NRC of this corrective
actieni. In December 1986, it was learned that neither TUGCD nor B&R audited
the installation of sajor NSSS equipment; however, limited turveillances were l
performed. These surveillancas provide a little assurance that the work (not
I
I
the vessell was checked; however, ANSI N45.2.12 does not allow substituting I
surveillance for audits. It appears that they nave been in violation for over
a year. There is no way for the NRC to determine the full significance of the
quality assurance and technical implications as only TUGC0 is in a posttton to
determine this. If they had answereo the proposed violaticn, ?HILLIPS or _
might be in a position at this time to determine the significance.
l
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1
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In addition to this specific issue, many more audit program deficiencies go
unanswered after years and the significance is again great because many of the {;
hardwar e issues in the plant do relate to inadequate audits which allowed QA
program breakdowns and', in turn, design and construction deficiencies to {
accumulate for years. It is also a current concern as massive amounts of work
on Unit 1, "Get Well Prograa," and Unit 2 construction have been and keep
proceeding. At the present rate, all work will be completed before the NRC has
all the answers and corrective action to whicn they are entitled.
Concern No. 4
and PHILLIPS were concerned because about three months after
TUGC0 was formally informed of the spool pieca violation, WESTERMAN directed
jochangetheviolationtoaccomodateTUGCO.
The following is the violation that TUGC0 acknowledged at the e::s t meeting and
that was described in the first final draft inspection report (Exhibit 111.
"9. Failure to Properly Identify a Scool Piece
"10 CFR 50, Appendix B, Criterion VIII, as implemented by the TUGC0 QA
Plan, Section 8.0, Revision 0, dated July 1, 1973, requires that measures
be established for the identification and control of materials, parts, and
components, including partially fabricated assembites. These measures
snall assure that identification of the item is maintained by heat number,
part number or other appropriate means.
" Article NA3766.6 of ASME, Section III, 1974 Edition, requires t*at the
identification of material consist of marking the material with the
applicable matersal specification and grade of material, heat number or
heat code of the material, and any additional marking required by this
section to facilitate traceability of the reports of the results of all
tests and examinations performed on the matertal.
"' Contrary to the above, spool piece ;01 (DWG No ERP-CS-2-RS-76) nad
netther been marked with the material spectitcaticn and grade, heat nuacer
or neat code of the material.
"This is a Severtty Level IV Violation (Supplement II.E) (44c/8505-09)."
The following 15 the report paragraph wntch shows up in the second signed draft
(Exhibit 12) and the final report (Exhibit 13):
"C.o. CVCS Scool Piece 301 - Requirements for this item are stated
in ASME, Section Ill, 1974 Edition through Summer 1974 Addenoa, which
15 the comettaent from the FSAR, Table 5.2-1. The item was field
fabricated from bulk piping and purchased elbows and installed in tne
CVCS with field welds number I and 6 (ref. BRP-CS-2-RB-07es. Tne
following records were reviewedt
. "BtR Code Data Report
_ _ _ _ _ _ _
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. .
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20
. " Field Weld Data Card -
. 'NDE Reports
. "QA Receiving Reports for piping and elbows .
. "CMTRs
"The installed spool piece was inspected for weld quality and to
vertly that marking and traceability requirements had been set. The
item had been marked with the spool piece" number (3Q1) and the B&R
drawing number which providad traceability to the material
certificat'ons."
Notes Exhibit 32 is two pages of text taken from the details of the original and
final tnspection reports.
.
PHILLIPS' Understanding of Concern No. 4,
In this case, the issue is straight forward. llllllllfieldInspectedSpool
Piece 301 which is a part of the Chemical Volume and Control System. As
previously described in the original violation (Enhibit 11), the spool piece was
not identified as required by the Code.
Requirements: The requirements for identification of this spool piece are
discribed in Exhibits 1 and 33-07 which include Criterion VIII of Appendix B to
10 CFR 50; FSAR, Subsection 17.1.8; and TUSCO QAP, Section 8.0; require material
traceability. ASME, Section III, 1974 Edition through Summer 1974 Addenda,
requires material traceability and identification as does the BLR implementing
procedure.
The spool piece was field fabricated by S&R from bulk matertal. Asllllllll'
HUNNICUTT and CUMMINGS (Branch and Section Chiefs) nad acceptec tnis fancing,
PHILLIPS only reviewed the write-up (Exhibit 11) to assure prcper references
were in the report.
During the preparation of Comments on Attachment MM. PHILLIFS reviewed the
requirements more closely, considering this review anc the olffertnc tecnn1-$ _
opinion that surfaced during a February 25, 1966, meeting between
versus JOHNSON et al. Pages 6, 7, and 5 of B&R Procedure 01-QAP-ll.1-2o require
three daiferent levels of identification tExhibit 37).
Noncompliance? with recutrements: llllllllfppropriatelyident1ftsdSpcolPiece
301 as not having the appropriate material traceability and scentification
markings apolled. "
During a subsequent detailed review, PHILLIFS found tnat the cult pipe for
i fabricating piping was not marked tr. accordance with BLR Frececure
GI-0AP-11.1-26 which requires bulk pipe to be scentifieo Oy heat nusber,
l ASTM /ASME type and grade, schedule wall thickness, scool nuncer, drawing nummer, j and piece number. This failure to idents.iv the spool piece is a violation ci
the Coce and the BLR procedure.
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
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a . 2I
PHILLIPS' Understanding of the Handlino/Mtshanditna of Concern No. 4
Proper handlinoi PHILLIPS provided MTith the background ano status of
inspections relative'to IE Procedures 49051, 49053, 49054, 49055, and 4905e i
(Exhibit 39) which are the sinisus IE inspection requirements for the reactor
coolant pressure boundary piping. [
completed the inspection of the pip %~
ing in under HUNNICUTT's
accordance supervision,
with Exhibit 39 which
identifed the violation; conducted the exit meeting with T,UGC0 management; and
documented the inspection.
.
-
.
Hishandlino: This finding was properly handled until WESTERMAN; BARNES and -
ELLERSHAW (page 148 of Attachae'nt D to OIA Reports reviewed the fina r e c ar,t
which had been signed by all involved and was about to be signed by NR;
Division Director. WESTERMAN stoppet the report from being signed-off on the
basis that M3as in error relative to his interpretation of the ASME !!!
Coce. This is inappropriate for a numcer of reasons; i.e., RIV management and
TUSCO had known about M interpretation at the exit meetings. Also, j
W _and the TUGC0 representative (who accompanied him) were unable to find '
the TUSCO required numbers on the spool piece during the inspection. TUSCO had
not found them for more than two months afterwar.ds or at least they did not
bring it to
or PHILLIPS' attention and this is an inordinate amount of
time for TUGC0 to find the identification on one spool piece. This concerned
K b_ecause neither he nor the TUSCO representative could find it during the
inspection. Regardless, M and PHILLIPS looked again during this second
inspection and found the spool piece number was there with no explanation as to'
how it got there.
At this point in time (September 1985), it was inappropriate to change findings
in a report that had been presented at the exit meeting; i.e., without at least
discussing in the NRC transmittal letter that this follow-up inspection was done
in the August through September 1985 inspection period.
In WESTERMAN's statement, he stated that he consulted SARNES on ASME III,
Division 1, who is a Code expert, page 150 of Exnibit 40.a. ,
EARNES stated on pages 10-13 of OIA, Attachment "J", that M Tas an error
(Exhibic 40.b, page 11). WESTERMAN advised PHILLIPS of 3ARNES conclusion. It
is not clear but based on WESTERMAN's statements, it appears that NRC management
first challenged M ding and discussed it with TUSCO prior to
discussing at with .p_r PHILLIPS. Accordingly, PHILLIPS, who does not
consider himself a Code expert, relied on BARNES expertise.
In addition, PHILLIPS did not perform c more detailed review of this matter
(September 19851 because 'under pressure, agreed that the material could
probably be traced and droppeo t<e violation. He did not agree with BARNES'
interpretation because BARNES was considering the issue from the standpoint of a
spool piece manufactured at a vendor when in fact, it was fabrtcated from bulk
material on-stte.
In preparing Consents on Attachment MM and Concern No. 4, PHILLIPS perforaeo a
more detailec review and it aopears that B&R failed tc follow their marktng and
identification instructions on pages 6-8 of B&R Procedure QI-QAP-11.1-26,
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l . . 22 1
Reviston IB, and earlier revisions (Exhibit 37). The subject spool piece was -
cut from bulk and this requires the app!tcation of the heat numoer, ASTH /ASNE
type and grade, schedule / wall thickness, spool numner, drawing number, and piece
number. This ASME procedural requirement is identical to lllllllll'or2ginal
finding; however, it appearc that because llllll[3a's pressured, he ' erroneously
agreed to downgrade the violation as the final report states that only the spool
piece number and drawing number were applied.
l FHILLIPS, although not a " Code Expert," pursued this matter f urther when the l
procedureagreedwith_jlllllll[[echnicalopinton. A B&R staff engineer was
contacted and was presented with M ]without naming persons)
interpretation that NA0766.6 of ASNE, Section III, 1974 Edition,. Summer addenda
versus BARNES' interpretation. The B&R construction engineer independent)y
researched the Code and stated that NA37ct.6 acclied. It appears that BARNES'
interpretation is not only different fromjEEElll[[butalsoc2fferentfrom
PHILLIPS and a B&R staff engineer with Coca responsibility.
BARNES' statements on pages 2 and 3, CIA Attachment J (Exhibit 40.b), indicates
that hts experience has been almost solely manufacturing prior to coming to the
NRC 4nd his expertence as a vendor inspector did not incluce nuclear power plant
construction expertence. This may be the reason he interpreted the Code from
tnat perspective. .
Exhibit 40.a, page 112 and 113 gives the tapression that WESTERMAN may have lost
his objectivity because of hearsay and, in turn, doubted PhILLIPS objectivity
concerning this report for which he was not ortganally responsible. It appears
that tne follow-up on M Code items and tnis specific tssue may nave
become suspect for the same reason, discussed on pages 148-158. He also states,
that M iss an enormous hard head." Next, TUGC0 accepts findings son
pages 154 and 155) but on pages 155 and 1:a WESTERMAN states he felt 2t
necessary to defend TUGCO, speak for them, and reinspect to shou compliance.
Safety Siontiscance The safety significance acoears to be tnat for about tnree
months TUGC0 does not have the ability to snow g ~that a single spool piece
is marked. It also appears that they think thsy are in compliances however, tne
marking on the spool piece does not conform with their own procedural
requirement 6.
It is also very significant that an inspector was pressured into dropping what
appears to be a valid violation. The OIA report documents tnat there is a
pervastve RIV philosophy of handling viciations informally or as unresolved
items (pages 29, 30, 02, 25, 3e and 37 of the OIA reports. When inspectors feel
pressured and harassed and stop reporting conditsons adverse te quality, the
safety significance is great but cannot be measured because it is an unknown.
That is the reason NRC sust have the same freeoom (". . . organizational freedom
to identify quality problems; to inittate, recommend or provide solutions; and
to versfy implementation of solutions . . . . ") as cescr:Ded for Util2ty
personnel in Criterion I of "Organtratton" of Appendix B to 10 CFR 50. A
regulator should understand thas concept better than anyone.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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Concern No. 5 ~~~
PHILLIPS was concerned that RIV management did not require TUSCO to respond in
writing tc the vtalation concerning concrete mixer blades.
The following is Item 2.c. of the Notice of Violation in the final report:
" c ., Brown & Root Procedure 35-1195-CCP-10, Revision 5, dated December 4, 1973,
requires that central and truck mixer blades be enecked quarterly to assure
that mixer blade wear does not exceed a loss of 10% of original blade
height.
" Contrary to the aoove, on May 31, 1985, the NRC inspector determined tlat
there was no objective evloence (records) that the mixing Olades nac oren
inspected quarterly since the trucks were placed in service in if77.
(445/0507-04; 446/35-02)"
The following is the required response in the ortginal drait report:
"During this inspection, it was found that certain of your activities were in
vtolation of NRC requirements. Consequently, you are required to respond to
this violation, in writing, in accordance with the provision of Section 0.001 of
the NRC's " Rules of Practice," Part 2, Title 10, Code of Feceral Regulations.
Your response should be based on the specifics contained in the Notice of
Violation enclosed with this letter."
The following (paragraphs 3 and 4 from NRC letter of transmittal, dated
February 3, 1985) show that the requirement to respond to the violation was
dropped.
"During this inspection, it was found that certain of your activities were in
violation of NRC requirements. Consequently, you are reautred to respond to
this violation, in writing, in accordance with the provision of Section 2.201 of
the NRC's " Rules of Practtce," Part 2, Title 10, Code of Federal Regulations.
Your response should be based on the spec fics contained in the Nott:e of
Violatton enclosed with this letter. Since B&R Procedure 35-1175-CCF-10 has
been revised to provide documented inspection of truck mixer blaces, there was
no abnormal blade wear identified as a result of blade inspection, and tnere
have been consistent concrete strength and untforalty tests, no reply to
vtalation 0.c is required.
" Pursuant to the provisions of 10 C"FR 2.201, Texas Utilities Electric Company is
hereby required to suosit to this office within 30 days ci the cate of -he
letter transmitting this Notice, a written statement or explanation in reply,
including f or each vt alations (1) the reason for the violations ti admitted,
(2) the corrective steps which have been taken and the results achieved, (;) the
corrective steps which will be taken to avoid furtner violations, and (41 the
cate wnen full compliance will be acnieveo. Where good cause is shown.
:enstderat1Jn will be given to extending the response time."
The details of this inspection are descr2:ec 2n Enni:it 11-10.
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PHILLIPS' understanding of Concern No. 5
Reovirements: The requirements are described in the Notice of Violation quoted
above and in Exhibits 11-13.
Noncompliance: The noncompliance is also adequately described in ;
Exhibits 11-13.
PHILLIPS' Understanding of Handlino/ Mishandling of Concern No. 5
Proper handlino: Similar to Concern No. 1 and four other concerns, tn. 4!ncings
were being properly handled by M and HUNNICUTT. @ letter ar,u Notice
of Violation required a respons? to this violation. PHILLIPS probably should
have made thip violation a Level IV violation; however, TUGC0 was given the l
benefit of this doubt.
M'I s h a n d l i n o The mishandling occurred when ,BARNES and WESTERMAN came to site
and got involved. WESTERMAN informed PHILLIPS that TUGC0 would not be required
to respond. PHILLIPS disagreed and never subsequently agreed with this position
because.of the following:
. PHILLIPS only inspected the blades of one of three trucks for wear. Since
no response was required, TUGC0 does not have to look at the other two
trucks and inform the NRC of their condition or if safety-related concrete
placements were affected.
l
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PHILLIPS found that an inspection requirement existed for quarterly l
inspection of the blades for 10 years but tnere was no evidence the l'
inspections had been conducted. This alone merits a response, as no
apparent technical problem (an unapparent technical proolem may e::1st) does
not justify dropping QA corrective action.
j
.
PHILLIPS also stated that a required response often causas the utility to i
look deeper to find the cause. Sometimes it applies to other inspection l
areas or procedures. Therefore, a response may have caused the quality
assurance organization to review other inspection procedures to determine
if inspections were being accomplished as required and documented. In this
case, it is also important to note that the blade inspection frequency
should have been less frequent as it was a waste of inspection time that
could nave been applied to other higher inspection priorities.
.
WESTERMAN again gave the impression that he was protecting TUGC0 from .
unreasonable demands by inspectors.
Safetv Significance: The technical significance of this violation as it l
specifically relates to concrete mixer blades of one truck and adequate concrete ,
l
is quite low technically; however, PHILLIPS states that the safety significance
may be higher with respect to the two trucks not inspected oy NRC. To saf it ;
has low significance would require the NRC inspector to tnspect all trucks. l
Obviously, a single NRC inspector cannot, and should not be expected to inspect I
three trucks under the circumstances; 1.e., once the violation is established, )
it is TUSCo's responsibility. l
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Insaection Report 50-445/05-14: 50-446/95-11 (95-14/11) '-~?
Concern No. 1,
2. and 1
PHILLIPS and YOUNG were concerned that RIV management not only downgraded i
violations concerning the shipment of sole copies of design records to
!
,
Stone and Webster Engineering Corporation.(SWEC) in New York and several other
, branch offices in different states but also dropped these fi'ndings from the
report.
i
OIA Report, Attachment MM, (Exhibit 41.a, page 9) adequately describes che
issues.
.
The violations in Exhibit 42.a were to be written as one violation of
Crite-ion XVII vio'ation with multiple exampies. The one exception was
.
Criterion V violations; i.e., TUGCO's failure to have procacures in place to
control the shipment of design records. Pages 1-4 of Exhibit 42.4 toriginal
draft report, paragraphs 5.a-b, in the Details Section) cover these issues;
.
however, one concern was not addressad in Attachment MM; i.9., the failure to I
incorporate 10 CFR 50, Appendix B, requirements and commitments into the highest-
QA manuals by reference cr.by describing sucn requirements in the various QA
sections.. Exhibit 42.b, pages 67 and 68 of the second draft, dated Decemoer 3,
.1986, shows that violations were downgraded and much of the text was also
dropped from the final report.
PHILLIPS' Understanding of Concern rios, t. 2. and 7.
Requirements: The requirements are described in Exhibit i, 43, 44, and 45,
which include appropriate portions of 10 CFR 50 (Criterion XVII) Appendix B;.
FSAR Section 17.1; ANSI N45.2.9l and TUSCO QAP.
Noncocaliances with Recutrements/ Commitments: The following discusses the
original noncompliance which YOUNG identified and are described in
Exhibit 42.a.
.
"TUSCO failed to have/use procedures to control shipment of original
records to SWEC."
This finding was dropped from the report. ~ ' -
'
innding is very important as it
may be the cause of all of the noncomplian. acerning records cescribid in
the Inspection Report 85-14/11. Accordingly, tne most important aspect of the ;
proposed violation was lost and, of course, TUGC0 does not nave to address tne
correction or cause if it is not in the fina! Notice of Violation.
Criterton XVll, Exhibit 4, states that the Applicant shall establish
requirements for record retention.
FSAR 17.1.17, Exhibit 43, requires pracedures which will estaclish a QA records
system to include all of the elements to control, account for, and protect
against deterioration and damage.
I
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26
FSAR LA(b)-3o (Exhibit 44.bl commits to implement the requirements in accordance
with ANSI N452.9. Paragraphs 5, 5.3, and 7 (Exhibit 44.a) require procedures to
include a description of the storage area (or areas). This would include
permanent and nonpermanent storage areas. Special processed records; such as,
' radiographs, photographs, negatives, and microfilm are relutred to ce stored in
an area to preserve them. Section 6, Retrieval, states that the system snall
provide f or the accurate retrieval of information without undue calay.
.
.Section 7 describes the requirement to assure the accumulation and transfer of
records.
" Comanche Peak Steam Electric Station QA Plan," (Exhibit 45) does not fully
comply with Exhibit 1, 43, and 44. as it does not spectftcally include ano
address all the requirements of the higher tier document as they apply tJ tne
site as follows:
.
The definition of a 04 record (Exhibit 44.a, page 11).
.
Location of all permanent and temporary storage areas or reference to suo
tier procedures which give location (Exhibits 43 and 44.a).
.
Specific on-site organi:ations responsible for permanent and temporary
records storage; e.g., TUGC0 vs Chicago Bridge & Iron, Bahnson,
Westinghouse Service Division IWl, etc. and interface req ~utrements and
agreements when records are to be transferred between organt:ations
(Exhibit 43 and 44.a). .
.
The definition of Lif etime/ Nonpermanent QA records to classify records as
required (Exhibit 43 and 44.c).
. Requirement .to index (Exhibit 43 and 44.al.
.
.
Retention requirements (Exhibit 43 and 44.al.
.
Receipt of records (Exhibit 43 ano 44.4).
.
Retrieval (Exhtbit 43 and 44.a).
.
Accumulation and transfer of records (Exhibit 43 and 44.a).
.
Instead of the CPSES QA Plan, Section 17.2, estaclisning the requirements,
it states, " Quality Control documents are initialed, collected, ano
maintained in accordance with approved procedures,' and infers tnat the
lower tier documents set the requirements. This procedure is also improper
because it only addresses QC procedures and should be addresstag CA
procedures, it defers responstbtlity for defining records to the
organt:ation implementing procedures. The responsibility for record
!
systems is also described in tne lower tier procedures. This .
!
organi:ational approach to control of recor:s nas caused estreme problems.
l
.
" Original design records shtsped in caraboard boxes althout making backup
Copy."
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.
This findtng was drcpped from tne report; however, it is an important part of "- '
the originally proposed violation. Criterion XVII of Appenoix B requires a
description of record retention and that includes assigned responsibility,
location, and duration (Exhibit 1).
Exhibit 43 gets more specific and states: (1) procedures shall descrice
responsibility, (2) that records will be protected against damage ano
deterioration, and (3) the method of transfer between organi:attons.
Exhibit. 44.a describes in even greater detail how to meet tne 10 CFR 50,
Appendix B, Criterion XVII requirement. Although no document is ever totally
prescriptive enough to cover absolutely everything, this ANSI document is
sufficiently prescriptive and descriptive tc tell a new applicant (TUGCO) how
records should be :entrolled. When construction tirst begins, each applicant is
.. quired to protect and preserve the first piece of paper down to the last piece
oi paper that is defined as a OA record of safety-related activities. AN31
defines unat a Qa record is. Paragraph 5.4(1) requires that records be kaot in
a permanent f acility in standard steel cabinets or, if this is not practical,
keep them tn fire resistant cabinets (1-hour rating) or an alternative is to
keep duplicate records stored in a separate, tesote location.
'
This logic does not change when all design activities are completed. The
requirement to afford permanent.or temporary protection for design of piping
racercs became more important at this point. The precedent for an NRC inspector
has been to write violations on a few important records not given tai s minimum
protection when construction begins and this is a well established fact.
Therefore, it is illogical that a violation would not be written anen the bulk
records were not protected. Regardless, paragraph 5.3(6) states tnat a method
of control and accountability must be established by procecure. Control
includes preserving bulk destgn records during movement from point a to point 3.
This can be done two ways (1) transfer the records in fire rated cabinets,
oaxes, or wrap with fire resistant matertal; or (2) retain a duplicate copy.
TUGC0 neither accounted for the records (inventory) nor assureo that the methoe
of transfer was appropriate. Instead, TUGC0 informed the NRO thats til it was
too expensive and time consuming to cuplicate the recor s or seno them in fire
resistant cabinet or otherwise, and (2) they had the rignt to proceso at their
own risk. The last statement appears to disregard tne regulatory requirements
in favor of cost ano schedule.
.
" Failure to :ontrol and account for QA/cesign records transterrec trom site
to SWEC."
This was a concern but not because the proposed violation was dropped. The
concern nere was that the details were severely edited and this left out tne
magnitude of the problem and the stated reason for the violation; 1.e.. TUGCO's
policy was to proceed at rtsk because of senedule and cia not duplicate or snto
the records in fire resistant cabinets because of :ost. This poilcy was also
stated to NRC oy var tous corporate CA and site managers wnen tne C211 issue
arose.
.
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I
PHILLIPS' Understanding of Mishandling: YOUNG identiftad the violations -
i
described in Exhibit 42.a. While the inspection was still in progress,
WESTERMAN became aware of these violations and the inspector was unable to
complete the inspection before pressure was being applied to not consider these
as violations. WESTERMAN stated that TUGC0 could proceed at risk and co what
they wanted to do with these old records because the records became in-process
documents when removed from the QA records vault and no longer have to oc
protected in accordance wi.th Criterion XVl! Records of Appendix 9 to 10 CFR 50
and ANSI N45.2.9. An additional reason was stated to be the fact that once the -
engineering reanalysts is completed they will be no longer be needed and the new
analysts is all that is important.
PHILLIPS and YOUNG having many years of construction experience on-site did not
agree these illogical arguments. Toward the end of the month, HESTERMAN stated
he would agree that TUGCO's failure to have and implement accountability and
inventory controls was a violation but, after much pressure and badgaring,
directed that all the other items be dropped.
WESTERMAN mishandled these issues because he dropped ta ortan _ details from the
body of the report. Also, his technique desertbed in statement was to
harass, pressure, and badger the NRC consultant and sentor resident into
surmission. He spent so such time doing this he actually disrupted several
inspections. So euch of PHILLIPS' ttee was used between Septemoer and
December 31, 1985, that he experienced difficulty in getting his other work done
and in providing guidance to three personnel who worked for him at that time.
Safety Significance:
The safety significance is that TUGC0 has completed Unit I
but has not fully described QA record requirements in TUSCO QAP, Section 17.0.
Exhibit 21, MAC Report, page 5, describes a complex array of procedures which
are difficult to maintain current and consistent.
Exhibit 21, MAC Report, page 15, shows that this consultant also recogni:ea that
neither TUSCO permanent nor temporary storage met ANSI N45.0.9 requirements in
1978. TUGC0 never corrected the records problem as they said they would in
their response to MAC.
\
The significance of shipping all of the paping design records to SWEC, New rork,
and various offices is that TUGC0 risked the loss of all tnese design recer:s
because of cost and schedule. This attitude has causeo them to fall inte the q
big hole tney are trying to climb out of; however, this attttude still Itngers, ]
j
l The significance of shipping all records without a spec 2fic inventory ano a !
method of accountability (i.e., how many records were sent from site and now
many records did SWEC receive and the reverse process to return to site) results
in not knowing if all records were received by SWEC and all were returned to
site.
The significance of dropping the issues from the NRC report is that TUGC0 was
not formally required to address these issues that appear to be generte.
The significance of WESTERMAN's application of pressure and badgering inspectors
caused tospectors to drop tmportant findings. Perhaps the NRC will never know
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how many issues were never brought up by other RIV inspectors on this and other -
projects. Differing professional opinions do not come about in this type
anytronment.
Concern No. 4 and No. 5 -
PHI P a.ndllllllll ere concerned that RIV management downgraded two of
violations concerning TUGCO's failure to assure that CB&I records
(generated on-site) were'not af' forded temporary storage protection in transit to
Houston, Texas, and these records were not inventer.ied and accounted for prior '
f
to leaving site which made a seaningful inventory after their return to the site
unlikely.
1
I
Exhibit 46, pages 11 and 12 of Attachment MM to OIA Report, describes this
concern in more detail.
Exhibit 42.a. pages 2, 3, and 4, of the original draft report descri nes llEEEEEEE
violations as originally written in the body of the report. One was downgraded
in the body of the next draft report (Exhibit 42.b, pages 68-70) and the other
was subsequently downgraded before the final report was issued. j
I
The final inspection report-(Exhibit 42.c) was iss,ued March 6, 1986, and was j
watered down to the point that it has little resemblance to tae origtnal l
findings. l
I
P H I L L I P'S ' Understanding of ' Concerns No. 4 and No. 5 )
i
Requirements: Exhibits 1, 43, 44, and 45 which applied to Concern No. 1, 2, and
]
3, also apply to Concern No. 4 and 5.
Noncomoltance with Requirements / Commitments: lllllllidentifiedaviolation ,
which would have been a further example of one violation of Criterion XVl! ,
1
examples; 1.e., failure to assure proper control, inventory, and transfer of
records between organizations as required by the above exhibits. Specifically,
the requirements of Criterion XVll of Appendix B to 10 CFR 50 as described in
Subsection 17.1.17 were violated as follows:
. "This f ailure to transmit records in accor3ance with a procedure and afford
protection in transit equal to temporary storage reguirem4Ats are
additional examples of violation identified in paragraph a b 'o v e . "
Exhibit i requires that the applicant establish requirements concerntag record
retention. The other words in Criterion XVII (assigned responsibtitty and
locations mean a description f rom top to bottom of the handling of records.
Location, not only means static, but also means dynamic or movement. UEEEEEEE~
found no such controlling procedure in place and TUSCO did not state that thev
had not assured the implementation of such controls. CBLI had left site,$EEEElIE$_
was forced to accept TUSCO's statement regarding what happened. An alternative
would have been for CB&l, Houston, tb come tc tne site but it appcared that
TUGC0 provided sufficient information to show it was a violation. Also, it is
doubtful that all personnel involved were at CB&I,. Houston, Texas, and could
have shed more light.
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Itshouldbenotedthatllllll[[aswellcwarethataCB&lprocedureexisted;
however, his review of their procedure showed that the CB&I procedure was
inadequate; i.e., they had the option to send records in cardboard boxes or
otherwise sail them. None of these measures assured protection in route
commensurate with FSAR 17.1.17 requirements (t.e., protect from damage or
' deterioration). The final NRC report erroneously shifts the emphasis from a
TUGC0 responsibility to a CB&1 procedure; however, TUGC0 at no time showed that
they had in any way assured that CBLI gave required protection wnile shipping-
-
thase irreplaceable records.
.
"The failure to maintain control and provide accountability of records
removed from storage is another example of the deviation identified in
paragraph above."
This should have been a violation as tt also violates the
Criterton XVII concerning responsibility and location.
CPSES QAP 17.0 (Exhibit 45), is a shallow procedure and requirements such as
method of transfer between remote locations ano inventory are not specifically
addressed. This allows lower tier organt:ations on-site to establish arbitrary
requirements and this is not proper as lower tier procedures are to implement
the requirements. -
PHILLIPS' Understanding of the Mishendlina of Concern No. 4 and No. 5
PHILLIPS incorporated M [tndings into the report. In this case,
WESTERMAN concentrated tne pressure on PHILLIPS to remove the violation from the
report and finally directed that it be removed when PHILLIPS would not agree
with WESTERMAN's logic that site generated containment liner and other records
belonged to CB&I instead of TUGCO. TUGCO, in WESTERMAN's presence, also
maintained that important and irreplaceable site records; such as, containment
liner, structural steel restraints, tanks, etc., belonged to CB&I and they were
free to control them as they pleased. In reply to PHILLIFS' question of such
records being destroyed in transit, sentor TUSCO management stated that tt was a
TUGC0 policy and they could proceed at their own risk. PHILLIPS contends that
if nd requirements existed, it would not ce prudent for WESTERMAN to endorse
such a policy.
When WESTERMAN found that PHILLIPS would not agree, he directed that the
violation be dropped from tne report and gave PHILLIPS the option to wrtte a
letter to Headquarters to resolve the ditference in technical opinion. PHILLIPS
wrote this letter which discussed the differences and forwarded it to WESTERMAN.
According to the 014 report, this letter " languished" in ERIC JOHNSON's office.
WESTERMAN made no further effort to follow Concerns No. 4 ano 5 until after the '
0!A investigation started. In desperation, WESTERMAN apparently had a number of
people working on the concerns and other matters in report 85-07/05 and other
reports to and his during the CIA interview process. PHILLIPS was never acvised
of this additional work; however, in tne various 01A statements tt is apparent
that such work was done. It was probably done netween WESTERMAN's first
interviews on July 11 and July CO. 1986, the day before the last interview. For
e/ ample. WESTERMAN states that CB&I transferred the records to Houston, Texas,
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in fire resistant cabinets. This information is not even in TUGCO's file. "--
PHitLIPS has followed up on this information with TUGC0 but tney nave never
stated this to be the case even as late as December 198o.
Safety Significance It is safety significant tnat TUGC0 has not shown to date
(and will probably be unaole to) that every record that left site was returned.
This is significant from a quality assurance and a hardware standpoint because
records prove the quality of the reactor liner and other hardware. This-does
not even consider the tnit I records transfer and how it was nandled. NRC
follow-up inspection is incomplete and the full significance is not yet known.
TUGC0 has stated that the records have been returned; nowever, it is safety
significant that sucn irreplaceable records were transferred in accordance with
a CB&I procedure that does not require that a duplicate copies be retained at
site or shipment in fire resistant containers or wrapping. TUGCO's stated
policy allows them to continue the practice as TUGC0 says it is at their own
risk.
The fact that NRC managers downgrade or drop safety concerns and do not forware
letters containing differing technical opinions is very significant because it
is downgrading the NRC regulations that nelp protect the healtn and safety of
the public. Pressure and harassment of inspectors also add a dark cloud instead
of professionally resolving the issues. This is highly significant because of
the need for freedon to identify problems and see that soluttons sc1ve
conditions adverse to qualit / including the control of records of harcware
acceptability.
Concern flo, 6
'
PHILLIPS and YOUNG were concerned that management dropped 10UNG's /tclation
concerning the failure to affarc protection to records removed from the Q4 vault
and placed in nonfire-rated cabinets located in trailers at multiple iteld
locations.
Exhibit 47, pages 10 and 14 of Attachment MM to the OIA Report, descrises
Concern No. 6.
Exhibit 42.a, pages 4-5 of the original draft inspection report, descrites tne
violation wnich was ortginally written. In accordance with IE guidance
IMC 0610), this was to be an example of the one Criterion XVII violatten
proposed.
Exhibit 42.b, pages 76-77 of the second draft inspection report, dated
Deceober 12, 1985, was rewritten to provide more information to convince RIV
management that this was a violation.
Exhibit 42.c, page 1; of the final inspection, downgraded the vtalation.
PHILLIPS' Understanding of Concern No. 6
Requirements (Exhibit '
, Criterton 4VII: Ennioit 43, 44, and 453 watch also
apply to Concerns No. 1, 2, and 3, also apply to tnis concern.
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Nancompliar;L: The failure to protvet GA records removed from tne CA vault to - - -- l
facilitate work in process is a violaticn of Criterion XVII; newever, it may
alternatively be considerad a deviation from Exhibit 44.a. All of the
references require the protection of GA records from damage and deterioration.
PHilLIPS' Understanding of the Handlina/ Mishandling of Concern No. 6
Proper Handlinc: YOUNS found that TUSCO had removed large quantities of QA
records from the OA vault in order for construction personnel to be able to
revtew previously completed work and facilitate new work. The records were
moved to several different locations on-site that would be convenient for
construction. Both PHILLIPS and f0VNG considered this move to expedite work a
good work practice; however, both cecame concerned when it was learned that the
completea original OA records removed from the QA vault were stored, in some I
cases, in regular file cabinetc in tra11ers without maintaining a backup copy.
f0VNG and PHILL-IPS challenged this practice and asked wny this pas done. The
first answer was that it was too expensive to purchase fire-rated cabinets.
Further, review of this matter revealed that the definition of a raccrd in their
commitment (Exhibit 44.a, page 11) had been ignored by TUGC0 and they replaced
thic definition with their own definition (Exhibit 48). TUSCO created a
definition to fit the practice instead of fitting the practice to the ANSI
N45.2-9 definition which states, in part, *0ualitv 4ssurance Recores. Those
records which furnish documentary evidence of the quality of items and of
activities affecting quality. For the purposes of this standard a document :s
considered a quallty assurance record wnen the document has been comolet?d."
The practice was to take a multitude of completed documents that had alreacy
been classified as QA records and were in the vault, mix them with incomplete
documents where work was still in-progress, place a work traveler on top of the
package, and call this mixture "in-process" documents. These cocuinents were not
in fire-rated cabinets and no duplicate existed.
YOUNG's finding was presented at the extt as a violation by PHILLIPS. MERRITT,
Senior TUGC0 Manager, asked for clarification and discussion. PHILLIPS
explatned again and a BLR manager at the meeting stated that it would be too
costly to store these OA records in fire resistant cabinets.
Mishandling: At the exit, WESTERMAN apparently agreed with the cost statement.
He later told PHILLIPS there was no requirement to protect GA records (completed
documents) removal from the vault because they oecame in-crocess dccuments.
PHILLIPS and YOUNG agreed that GA records could be removea from the file to
facilttate work but that TUGC0 ts required to give the QA records atxed witn the
in-process document temporary protection at the- end of the work day as requireo
by ANSI N45.2.9.
WESTERMAN spplied pressure to drop this finding altogether tecause he said tne
NRC Technical Revtew Team (TRT) had found iie practice acceptable and so
documented it in SSER 11; however, the CIA report also pointed out that SEER 11
also inoicated they were in fire resistent cactnets.
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4
O
HALE concurred with WESTERMAN's definition of in process documents; newever, ___
HALE only gave his opinion and no supporting documentation. HALE gave no
precedent because he has little construction expertence as ne worked in NRC
Vendor Branch until 1984. P.HILLIPS and YOUNG have years of construction
expertence and have observed many licensee's and appitcant's practices across
the United State 3. This is the first time they encountered a utility that so
grossly does not understand this requirement to protect records. It is also the
first time to encounter NRC inspectors who do not understand this reoutrement.
PHILLIPS was directed to drop this violatton.
WESTERMAN met with TUGC0 management, without PHILLIPS being present, and later
tnformed FHILLIPS they did not consider it a requirement to protect these
records but would buy the fire-rated cabinets to protect these records.
Subsequent to this, other TUGC0 QA managers stated, at different times during
the last year, that they would not~be"plice~d into the appropriate cactnets.
PHILLIPS has oeen unable to followup on this iten as TUGC0 has been delaytng in
hopes that the finding would go away.
PHILLIPS last conversation with the TUGC0 QA Director on December 15, 1986,
revealed that they would not revise their procedure to require any such practice
but they will do it only because it is prudent. PHILLIPS replied that this is
not acceptable because they will not admit it is a requirement.and/or a .
commitment and if they store for prudency only the NRC has no reason to inspect
the QA records so stored.
Safety Significance: The significance of this concern has diminished somennat
because TUGC0 says the QA records are now stored in fire-rated caoinets;
however, the NRC cannot be assured that the records will continue to be stored
in this manner because TUGC0 refuses to consider this a requirement. It is
significant that on January 8, 1987, PHILLIPS requested the TUGC0 QA Director to
provide the locattons of all QA records storage areas, coth temporary and
permanent, and the procedures which describe such locations. As of January 1c,
1997, the TUGC0 QC supervisor had provided procedures but could not state wnere
all temporary record storage areas are.
*nscection Reoort 50-345/95-16: 50-446/95-17 (95-16/13)
Concerns No. 1. 2. and 3
FHILLIPS was concerned that RIV downgraded a series of potential violations to
unresolved items involving TUGCO's system for controlling construction
deficiency reporting or 50.55(e) documentation. fccording to the deaft
inspection report, these potential violations included the following:
.
"TUGC0 failed to developrie:<lement a procedure to show or reference
objective evidence that deficiencies were corrected,
i
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"TUGC0 failed to revtse implementing procedures before corporate NE]
Procedure CS-1 was implemented, resulting in a confitet utth itve otner
- procedures.
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"TUGC0 failed to maintain 50.55(e) files (QA records) that were ---
retrievalbe, i.e., could not produce record in almost a conth."
Exhibit 49, page 14-16 of 01A Report, Attachment Mit, adequately describes these s
specific issues. '
Ex'hibit 50, original rough draft report completed about December 20, 1985,
pages 3-1 through 3-6, shows these violations as originally written. This rough
draft was handed to WESTERMAN before typing and editing to allow JOHNSON and
WESTERMAN to prepare for a meeting on the subject. PHILLIPS had told WESTERMAN
about difficulties experienced si.nce October 1985 and, proposed violations would
have resulted in the following: (1) a violation of Criterion V, " Procedures,"
with two examples; (2) a violation of Critericn XVII, "0A Rec rds"; and (3) a
10 CFR 50.55(e) violation, " Failure to Report Corrective Action."
The final report issued August 16, 1986 (Exhibit 51), dropped all the proposeo
violations and inserted an unresolved item based on otscussions between
WESTERMAN and TUGC0 in which PHILLIPS was not involved. WESTERMAN later
Informed PHILLIPS of commitments made by TUGC0 to form a Task Force.
PHILLIPS' Understanding of Concern No, t. 2. and 3
Recutrements: The requirements are desertbed in E::hibi ts 1, 14, 15, ! 6, 44.a,
52 and 53 which include 10 CFR 50.55(e); 10 CFR 50, Appendix B, Criteria V
and XVII; ar.d the TUGC0 FSAR, TUGC0 DA Plan.-
Guidance: The NRC had provided TUSCO with 10 CFR 50.55(e) guidance which is in
the back of the IE Manual Chapters (Exhibit 54) as RIV routinely did this ta
1979-1981. This is guidance to the NRC inspectors concerning the applicact!ity
of Appendix B Criteria.' Contrary to statements made by WESTERMAN, the IE
Interpretation is that construction deficiency reporting comes under appl.caole
Criteria of Appendix 3 to 10 CFR 50; t.e., as a minimum Criterton V ann XVII.
Noncompliance with Requirements: The'iollowing disc'.sses tne logic f or each
violation ortgtnally proposed.
"TUGCD failed to develop / implement a procedure to show or reference (
J
objective evit'ence that deficiencies were corrected."
This proposed violation is the most important aspect of this :oncern as it ias
caused TlfGCO's 50.55(e) reporting system to be deficienct. MCOLESKY, NRC
consultant, started inspecting the TUGC0 30.55(e) systeo sn October 1985 and had
made little progress by February 1996. A large number of man hours were
expended before giving up the efiart as useless at the time.
PHILLIFS and MCCLESKY (experienced in 50.55te] reporting) asked for information
to close out the 10 CFR 50.55(e) deficiencies and TUGC0 was unaole to provide
it.
MCCLESKI was to review the individual 50.55(e) files and then fteld ve tfv
i
the correction of these deficiencies. TUGCC could not reactly tcenttiy the NCR,
! DCA. or test deftciency report (TDR) which originally identifted or descrtbed ( tne deficiency. The reason they could not readily ident:ty tnese reports was j i
that their 50.55(ei reports to NRC were so poorij written tnat they dij not
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reference the documents which identified tne deftetency in the field or Identify ~~~
the resultant corrective action document. Either document, if referenced in, the
l
report to the NRC, would have allowed tne inspector to pull the report from the
file and identify the proper document. This would allow the inspector to go to j
the QA records vault and obtain.the document from a file clerk snd, after
reviewing this document, he could go directly to tne field and observe the
deftcient systems component or part. If the records were in the " paper flow
group," they should be indexed and retrievable. The document would also provtde
identification numbers whereby the inspector could obtain specifications and
drawings from the document control office. ]
1
TUGC0 could only respond to such a request dy directing the inspector to a
manager, an engineer, B&R inspector, or some other person who may have been 1
involved at one time. In many cases, this method led to gotng from person to
person over a several day period to learn what they knew. The information tney
provided was sometimes from memory or notes in their desk drawers. After a
knowledgeable person was found, the search started for the appropriate
documents. It took varying amounts of time to identify one appropriate document !
out of thousands in the GA records vault. The person's ability to retrieve I
documents is also impacted by other priorities and memory. Instead of ;
retrievab!e GA records system, TUSCO has a retrievable persons system to get !
many of their records.
L
i
Cnce faced with this serious retrievability problem, TUSCO finally admitted they i
l
had a problem with 50.55(e) records and asked the NRC inspectors to terminate !
their inspection untti they could get a handle on things.
l
TUGC0 stated that they were writing a new Procedure (NEO CS-ll whicn would help
correct these problems. They asked PHILLIPS and MCCLESKY to review the final
draft and make comments, and MCCLESKY made comments to TUGC0 which spect f t cally
ccacerned the fact that the procedure did not adequately describe what
identification and corrective action documents should be otther referoncac in {
the 50.55(e) report to the NRC, or referenced in a letter to t'ile, or otr.erwise j
cross indexed to or from the nonconformance or design change log. Gescate these !
l
comments, TUGC0 issued the procedure without aadressing how the 50.55(et report j
referenced the NCR, DCA, cr TDR, or cross indexed logs to tne 50.55(e# l
deisciency report.
)
NOTE: One must not lose sight of the fact that this 4pplicant is not just
starting to construct a nuclear plant but has completed Unit 1 anc is close to
! completing Unit C. PHILLIPS and MCCLESKY had never encountered such ineptness
and they have inspected a large number of other nuclear plants.
This failure to have adequate procedures as required by Exhibits 1, is a
violation of Cetterton V of Appendix B to 10 CFR 50.
(
, "TUSCO failed to revise implementing procecures before corporate NEO
Procedure CS-1 was implemented, resulting in conflict dith five other
procedures."
l
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MCCLESKY directea the acove violation to FHILLIPS attertion. FHI L1ri, antle I
writing the violation, checkeo to vertfy tnat TUGCC nad revised tne sucorcinate
.
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~- '
implementing procedures before issuing the corporate procedure. Such revtstons
were important because the corporate prockdure affected responsibilities,
deportability critert a, notification policy, and reporting instructions. This
failure to revise procedures as required by Exhibit 53 is a violation of
Criterion VI, Document Control.
i
"TUGC0 failed to maintain 50.55(e) files (QA records) that were
retrievable, i.e., could not produce record in almost a month."
.
TUSCO's inability to retrieve records is a violation or at least a deviation,
depending on onw's enforcement outlook.
Exhibit 43, page 17.1-41, states that the method of identification and indextn3 l
of records for ease of retrievability will be assured oy procedures ~thIt-~ '~ j
I
tapiament this FSAR requirement. PHILLIPS interprets this as a requirement
which was violated; however, at a etntmum a commitment was violated in f'
Exhibit 44.a, paragraph 6.2 which states, in part, ". . . retrieval at
information without undue delay."
P H I Li, I P S ' understanding of How Handled / Mishandled
Backoround Prtar to initiating the inspection of the TUGC0 10 CFR 50.55(es
reporting system, PHILLIPS had performed a trend analysis of TU3CO's deficiency
reporting as directed by Hunter. An adverse trend was identified basec cn
reviewing RIV inspection reports lover 200 violations and unresolved itesse.
Six violations had been issued and three unresol,ved items appeared to os
violations instead of unresolved items. Including PHILLIPC' experience at
plants in Region III and the South Texas Project, PHILLIPS concluded this was
the worst enforcement history he had witnessed (Exhibit 55, Trend Analysis).
1
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Thisanalystswasfurnishedtolllllll}[hoplannedtofactorthisintotheRIV
Comanche Peak Task Group.-(CPTG) follow-up inspection of TUSCO's third party }
inspection, the Comanche Peak Response Team (CPRT). This was never done because !
j
WESTERMAN replaced lEEEEEE[Ind he rejected the trend analysis and the idea of
factoring this into the follow-up inspection which is consistent with his j
rejection o3 adverse trends in the GIV inspection program for Unit ! where it
appearad that RIV inspectors had performed inadequate inspections. He also j
rejected reinspection of the various MC 2512 inspection procedures which aculd {
have looked at 50.55(e) deficiencies in conjunction with reinspecting the
deftcient areas concerning NRC inspection procedures of MC 2512. WESTERhAN also
directed the subject of tren' ding be dropped from inspection report 65-07/0. j
which is discussed in a different concern.
In 1980 PHILLIPS alerted RIV management about BhR work anc problems when he was
at South Texas but it was ignored (Exhibit 56, two memorande; S pages). l
'
Considering Exhibit 56 and if these trends had been identified in 1980 or
earlier, special NRC inspections could have averted what his napoened at
Comanche Peak.
Proper Handlino: PHILLIPS provided MCCLESLf with back;rounc saterial ano IE l
Procedure 92700 which require the inscection of TUGCC's 50.55.es system. As l
Indicated in his field notes (Exhibit 57.a and b), MCCLESKf e:pertenceo l
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immediate problems wnile inspecting the 50.55(el procedures and files. The ~ ~ ~ ~ '
corrective action portion of the procedure was inadequate. Insufficient
information was on file to determine if nonreportable items were properly
evaluated or if reportable items had been corrected. In October 1985, 6 of B
files reviewed were deficient regarding sufficient information to verify
corrective action. Twelve additional files cantained nonreportacle
deficiencies; however, of three of these files were deficient to the point that
the inspector could not determine whether or not the deficiency was reportable.
Thts data was presented to WESTERMAN by PHILLIPS and MCCLESKY.
Misnandlino: PHILLIPS told WESTERMAN that he had not seen such a mess in all
his time with the NRC. PHILLIPS had decided to shield MCCLESKy and keep him out
of the line of fire regarding violations cecause WESTERMAN had already let
YOUNG's contract expire becaust of his QA background and his tjentifying l
problems; 1.e., writing violations.
In this case, WESTERMAN concentrated all the wrath ne could to pressure, narass,
and intimidate PHILLIPS to drop these violations. His statements suggested that
PHILLIPS would be removed from the job because he was not a team player; 1.e.,
would not agree to drop the violations. Veiled threats about--did not PHILLIPS
make good money and suggesting he would make less when removed from
site--started to become serious from PHILLIPS standpoint. Such unprofessional
behavior nad never been encountered oy PHILLIPS in nearly 29 years of working.
MCCLESKY had about one year left on his contract but he was terminated to
further isolate PHILLIPS.
PHILLIPS returned from three weeks leave on January 13, 1996. PHILLIPS was
confronted with the draft inspection report on which JOHNSON nad made
unprofessional comments and rediculed PHILLIPS' draft Inspection Report
86-16/13, (Exhtbit SS). These comments are not only uncalled for out also
erroneous. This is probably because of a lack of expertence as JOHNSON's
statement, Attachment P to the OIA Report shows that he does not understand
quality assurance and construction. His personal attacks in Attachment P and
comments on this memo are improper conduct for a senior manager. In reading nts l
OIA statement, it was evident he could not answer simple questions en IE MC 2512
and QA procedures.
WESTERMAN said he had talked to JOHNSON about the proolems PHILLIFS was creating
for him. WESTERMAN told PHILLIPS that something was going to nave to se cono.
JOHNSON came to the site to browbeat PHILLIPS over the SISCO memorandum PHILLIFS
had written. During this visit, JCHNSON and WESTERMAN met with TUGCC to discuss
their 50.55(e) system and PHILLIPS was told he was not needed. As a result of
PHILLIPS absence, TUGC0 made commitments and went overocard. They formeo a task
force to develop huge folders on each item when a simple ref erence in :ne
50.55(e) report or list maintained in tne file or any method of indexing to tne
.
existing NCR, DCA, etc., logs would have been sufficient. This task force nas
l worked for a year and has had 5-10 people working on it. If PHILLIFS had been } at this meeting to explain, TUGC0 may nave elected to go tne stsple and more { inexpensive route; however, it ts PHILLIPS's Delief tnat their conitdence in {
j
th:5 area was 50 shaken they elected to periorm a massiye review.
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Instead of being t this meeting, PHILLIPS~(with a broken rtb) was asked to give *--
[ GAGLIARDO an onsite tour. Initially the purpose was unclear as GAGLIARDO had
been on-site for months in 1984 and since he was already very familiar with the
site, PHILLIPS gave GAGLIARDO a casual tour. WESTERMAN later told PHILLIPS that
the purpose of the tour was to test his for site knowledge and that he dio not
do well. JOHNSON telephoned PHILLIPS a couple of days later to repeat this and
say that he questioned PHILLIPS' construction experience after reviewing his
resume. All this was to make a point.
The point was that 11 PHILLIPS insis,ted
on writing violations he would stay in trouble.
At this point, PHILLIPS told WESTERMAN that he recognt:ed these things as a " set
up" and told WESTERMAN to tell "them" to back off; i.e., he would write this
inspection report as RIV management desired, and ne would ask what they wanted
written in the inspection reports in the future. PHILLIPS followed this policy
until May 1986 when Inspection Report 86-08/06 was written. Again, this is
precisely in line with the RIV policy described in ment
(Exhibit 12bt.
The mishandling of these items is abunduntly clear free reading WESTERMAN's
statement (Attachment D, Volume II, dated July 11, 1986). His twisted logic and
lack of understanding the requirements of 10 CFR 50.55(e) are evidenced by the
following references; however, pages 348-412 must.oe read for a full
understanding.
Pace 350: "Now it was my poisition and still is my position that there's no
requirement in 50.55(e), or a procedure, that having a procedure to cover
50.55(e) is not an Appendix B requirement. 50.55(e) is a reporting requirement
which is placed on the untility via the code of requaltions."
Comment: This conflicts with I.E. Guidance in Exhtbit 54.
Pace 351: "O Okay. Are there procedures for identification, documentation and
notification of affected organizations --
"A Yes, str.
"O -- for nonfonfirming items?
1
"A Yes, sir.
"O Okay. Are we talking about that here?
"A Not -- well, what we're talking about that Mr. Phillips wanted, was
'
for the utility to have a status in a file for each 50.55(e) which he could
go over to and look in that file and close out a 50.55(e). And I'm saying
,
' I don't know of any requirement that would say the utility would have to
have those in a file for the convenience of the Commission. Those records
i
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are there; they are maintained; they are part of the permanent. Now, if
l's a prudent licensee, I Will have that kind of a system.
" 12 Did they have a system, not for 50.55(e), it's --
'
"A Yes, sir."
<
Comment: This is a false statement as PHILLIPS never asked for such a system as
he only asked that the 50.55(e) report (to NRC) to refarence tha nonconformance
r e p o'r t , reference it in the file, or reference the 50.55(e) report on the NCR
log. PHILLIPS and a witness can prove that this statement is false.
!
Pace 360: "If you went to look at nonconformance reports, you woulo citaarly be l
able to identify whether it was a 50.55(e) item."
l
i
Comment: MCCLESKY claims just the opposite in Exhibit 57.
Psoe 362: In response to how many 50.55(e) reports had been received: "Oh we
haven't gotten very sany here of late."
Comments PHILLIPS tracks 50.55(e) reports and this is a false statement.
Exhibit 59 shows that CP-86-50, for example, had b,een received by July 17, 1936,
and this means that a total of fifty 50.55(e) reports had been issued thus far 1
in 1986. WESTERNAN testified on July 11, 1986, and knew this to be a false
answer.as PHILLIPS furnished these reports and status reports to make him aware
of technical reports by number, in fact, the last report (November 26, 19861
shows that 76 reports had been received in 1986. PHILLIPS' experience has been !
that some projects have not received this many 50.55(el reports during all of j
these 6-8 years of construction. i
j
.Paoe 3e3: "I'm telling you 50.55(el does not fall under Criterion 15." )
Comment: TUGC0 FSAR, Exhibit 14. page 17.1-38, and Exhibst 15, OAP, ,
Section 15.0, consider 50.55(s) to fall under Criterton 15.0. This is an j
example of WESTERMAN's defending something that TUSCO could not even defend. It l
s impossible to deal with his logic as it skt;:s f rom potnt to point without {
rationale. His only logic is that is the way it is becaute he says it as that l
way. PHILLIPS, M 'f0UNG and MCCLESKY were bombarded with this lack of I
logic and unless they were willing to agree that dark is daylight, he started
narassing, pressuring, and threatening.
Pace ~61: "There's no time liett on 'retrievabil2ty'."
Comment: TUSCO FSAR and ANSI N45.2.9 state that there is a limit (Exhibit 44.a,
page 17.1-41 and Exhibit 43). These words do place a time limit; i.e., a 1
reasonable amount of time or the norm. PHILLIPS and MCCLESKY considereo a month
i excessive time to retrieve records. In addition, all WRC teams who have come to I the site have experienced this problem because at is a generar problem.
]
l
Similar comments could be made on many of WESTERMAN's statements. As WESTERMAN
{
was being advised by BARNES, HALE, anc ELLERSHAW (who nave almost no i
construction but have NRC Vendor Program experientel, WESTERMAN and JOHNSON
,
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proceeded to downgrade all of PHILLIPS' and MCCLESKf's findings because of a "--
lack of canagement and construction expertence. In reading statements by
JOHNSON and WESTERMAN related to these concerns, PHILLIPS detected
unprofessional conduct to the manner that PHILLIPS was attacked and it appears
they have lost objectivity.
Safety Significance: These concerns are safety significant as thess violations
show TUGCO's sytem for reporting 10 CFR 50.55{e) deficiencies has been deftcient
during the entire construction of Unit I and 80% of Unit 2 construction. This
statement is supported by PHILLIPS' trend analysis and by findings of the NRC
TRT team in October 1984 (Exhibit 60, SSER No. 11 of MUREG-0707). Almost a year
after TUGC0 learned of the weakness in their 10 CFR 50.55(e) system as described
by the SSER, NRC inspection report S5-16/13 documented the fact that TUGC0 had
not taken complete and effective corrective action. This was also after
PHILLIPS' brief inspection in mid-1985 which showed basic probleas in their
reporting (i.e., not including which unit a deftetenctey app!1ed to as evidenc?d
in a few corrections in Exhibit 61, TUbCO's letter, itX-4508, dated July 9,
1985). A prudent utility would have performed an extenstye review after readtng
the SSER, but they did not.
In November 1985, PHILLIPS and YOUNG also found that TUGC0 did not report on
potentially sertous deficiencies with BISCO fire seals and only did so in 198a
after this became a subject of Inspection Report 85-16/13. The seriousness at l
these violations, when past deficiencies in this system are considered, should
have resulted in the 50.55(e) violations being made a part of the Notice of
Violation from James M. Taylor to TUGCO, dated May 2, 1986. Sucn enforcement
can hardly be constdered now as these violations were downgraded, droppeo, anc
report details were gutted. As a result, TUGC0 has not been required to give
,
NRC written assurance that they have corrected the deficiency and deterstned the j
cause to preclude repetition and the NRC continues to solve TUGC0 problems
informally as described in Exhibit 21. During a recent November 1986 inspection,
it was found that one of two files checked revealed that corrective action could
not be field verified because of missing engineering documents and inacequate
design change documents. TUGC0 issued corrective action request.
The significance of RIV management's lack of experience and knowledge witn
respect to 10 CFR 50.55(e) reporting, is more safety significant as TUGCO's
deficient management and knowledge of the system because RIV management's
influence affects many utilities.
Another strange practice in RIV is the fact they do not acknowedge receipt of
the Applicant's 50.55(e) reports as do other regions. This may contribute to
the inadequate reports made by TUGCO. It may also follow that if RIV management
does not understand 10 CFR 50.55(e) reporting, follow-up inspection, and
accordingly RIV inspections of these areas have not been as good as they snould
j '
have been. If TUGC0 had been strictly required to implement an adequate
10 CFR 50.55(e) reporting system, RIV or NRC headquarters most likely would have
i recogntced trends that are now snowtag up in the areas of design and
construction engineering. What can De more significant than this considering
the poor position TUGC0 finds itself in today.
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Concern No. 4 -
PHILLIPS was concerned that RIV aanagement downgraded the following document
control-related violation to an unresolved item:
"TUSCO had replaced NAMCO switches per IEB 79-28,.but two of 14 that were
field inspected were not properly identified on installation traveler.'"
. Exhibit 62, pages 16 and 17 of OIA Report-, Attachment MM, adequately explat.ns
the concern.
Exhibit 50, pages 4 of the original draft inspection report, describes the
violation which was dropped.
Exhibit 51, pages 6 and 7, final inspection report issued, recorded the item as
unresolved.
PHILLIPS' Understanding of Concern No. 4
Requirements: The requirements are described in Exhibits 33 and 34 and include
appropriate portions of 10 CFR 50, Criterion VI!!, Appendix B; FSAR.
Section 17.1; and TUGC0 QAP..
Noncomoltance with Requirements: This noncompliance was identified as a
violation of.the identification requirements in Exhibits 1, 33, and 34 as
described in the original draft report (Exhibit 50).
PHILLIPS' Understanding of Handlino/Mtshandlino of Concern No. 4
B a c k a r o u n _d_: Prior to performing this inspection, PHILLIPS reviewed RIV
Inspection Reports dating back to 1983. This was done to prevent duplication of
effort. The six RIV inspections reviewed did a fair job with respect to
inspecting line IE IP90700 items; sucn as. TUGC0 actions or applicability
- distribution, assignment of responsibility, and corrective 7.ction documented.
These reports did not generally emphast:e field verification of hardware
replaced, repaired, or modified. Therefore. MCCLESKY's task was to field vertiy
selected IE Bulletins.
Proper Handlino: MCCLESKY reviewed IE Manual Chapter requirements and tne
'
l
l background material provided above.
The results of this inspection (Exhibit 50 and 63) show that before Novemoer 13,
1985, a potential violation had been identified to high level TUGC0 engineers
who were involved in this review. These exhibits also document TUGCO's inability
to.show in a reasonable time the correct switches on resicual heat removal
valves that are installed.
PHILLIPS translated these findings into a draf' inspection eport as MCCLESkt
had contacted TUGCO's official points of contact (circled on E::hicit 64) and
others. B&R thought it deficient and issued a nonconformance report.
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Mishandling: PHILLIPS handed a rough draft of the Details section of the ~~~
inspection report to WESTERMAN. With respect to this particular item (NAMCO
~
switches), WESTERMAN started searching for the travelers by going to BRANDT,
TUGC0 QE, who was no*, on the list of contacts provided. After a long period of
time (months), two additional work travelers were produced. WESTERMAN then
concluded MCCLESKY had not contacted the right people which is jut not true. No
explanation was provided as to why these work records were not in the QA reccros
vault when MCCLESKY repeatedly asked for them; however, the specific NAMCO
switch travelers should have been readily available as Unit I was completed.
Even af ter WESTERMAN claimed BRANDT could provide inf ormtion, MCCLE5KY had a
number of questions that BRANDT never answered. MCCLESKY left tne site in
Fetruary 1986. Shortly before he left, there was disagreement it a meeting
attended by PHILLIPS, MCCLESKY, BRANDT, WESTERMAN and SARNES regarding the f act
that BRANDT never provided the information requested. The violation was
dropped. TUGC0 should have oeen cited as originally written in Exhibit 50,
page 4-4; however, after it drug out so long they finally found the records. At
this point, they should have been cited for failure to retrieve records, a
different violation, but according to WESTERMAN, there is no time limi t. .
{
The protracted time for getting NRC reports issued has caused many problems as i
in this case because TUSCO is following-up while the draft report lingers in
offices. The inspection ended November 30, 1785. WESTERMAN was on-stte such of l
the time until the draft was transmitted to RIV in February 1986. He was
l
Insisting on not allowing violations to be written based on information recetved l
in late December 1985, and early January 1986. This was not properly documented l
In the NRC transatttal letter; t.e., additional inspection outside the l
Inspection period. BEACH, NRC enforcement officer, cor.siders this improper in
Attachment 00 of the 01A Report (Exhibit 65, Inspection Report 35-to/13, RIV
Report Traveler) shows how reports linger for no g000 reason.
I
PHILLIPS has performed follow-up Inspection in subsequent inspection periods but
l
has not closed the item because of the multiple problems found. In late
December 1995, one switch was found to ce a Train "C" ( non sa f e r.y-r el at ed )
switch; therefoce, only one switch is the subject of further discussions.
MCCLESK'I's field notes dated in Novemoer 1o85 conflict witn the Master Data
Base, enecked on July 25, 1986. This information Master Data Sase was not
produced for MCCLESKY in 1985, but PHILLIPS confirmed it was there in 198o.
PHILLIPS found new findings; i.e., multiple violations of the work traveler
Procedure CP-CPM-6.0; tnerefore, the item remains cpen.
Traveler EE 02-1415-58nt dated Julv ?. 1982:
Comments:
1. The initial or first traveler was not reviewed, signed, or dated as
required by procedure.
2. Operation Number 1 does not reference and require ctsassemuly per
Instruction EEI-21, " Installation Requirements for NANCO Ltr.it Switches,"
Revision 0, cated August 20. 18S2.
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3. Operation No. 2 & 3 states to tighten " snug tight." Since these valves are "'-
equipment qualification tested (sessmic), what would happen if there are
drastic dif f erences (i f snug tight approaches loose) and then the switches
on the valves vibrate during an earthquake. This might cause failure if
the switches on the valves in the field are not tested to the same
tightness as those tested.
I
4. Operation No. 5 does not require determination per Procedure EEI-8,
" Class IE and Non-Class 1E Cable Terminations," Revision 3, dated May 18,
1982. .
5. Operation No. 6 does not require steps to te in accordance with eel-21.
6. Drawing Revision was not recorded; and Procedure Revision were not
recorded.
Replacement Travelar EE 93-0450-5801 dated May 23, 1983: {
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1.
This second traveler does not reference the first traveler and was not In
the QA records file at the time the inspection was performed. One could I
easily conf use which traveler is the first or last one.
2. The first statement on this traveler is that the switch must be replaced
because it needs to traval the reverse direction. This means one of two
things: (1) the design drawing / traveler was correct and was not installed '
per these documents, or (2) the design drawing / traveler was wrong and the
Norkers installed the switch per these documents. (No such description in
the NCR was written if the first is the case and no DCA was written if the
second was the case.)
!
!
The discrepancies above show a weakness (if not a violation) of 04 program j
requirements; that is, generic with respect to not requiring installation of j
switches per procedures. Even if procedures were referenced on the traveler, no I
revision was on the traveler and no revisions for the drawing were recordec.
What effect this has had on several hundred installations is unknown at th:s
point.
Exhibit 66, " Conversation Record," dated July 8, 1986, documents the TUSCO
representative's statement that they had similar problems as did MCCLE5KY.
Safetv Significance: The replacement of hundreds of switches wsed ir various
system is still unknown as the traveler system procedure was not fellowed.
Although the original problem with identification was mysteriously solved,
switches identified on the traveler vs switches installed was a violation at the
l time it was found. After the document was found, RIV management should have
directed the violation to be changed to a failure to retrieve the accuments
which is a violation,
in fact, if TUGC0 had been requireo to pursue this :ssue,
they may have found :nd prevented multiple violations on tnetr travelar system
identified in NRC Inspection Report So-20/17; i.e., 30 of 00 miscel;aneous work !
travelars reviewed were deficient.
]
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This item has wasted a great deal of the NRC inspectors time and is still not ' - '
solved. This in itself is safety significant in that the anspector ends up
inspecting less. This would not have happened if WESTERMAN and JCHNSON nad not
intervened.
Concern No. 5
PHILLIPS and YOUN6 was concerned about the technical adequacy of BISCO fire
seals installed at Comanche Peak because certain configurations had recently
failed in testing. A detailed review of the certifications showed them to be at
least indeterminate and, at worst, false. Records of testing were destroyed in
two successive fires according to BISCO management; however, test dates and
dates of the fire conflicted in one case. RIV management appeared to be more
concerned about protocol of who to address the memorandum to than these
technical problems.
Exhibit 49, pages 17 and 18 of Attachment MM to the NRC CIA Report, generally
describes the concern; however, greater detail about these concerns is described
in a subsequent paragraph (Mishandling).
Exhibit 50, pages 6-1 through 6-4 of the original draft Inspection Report
85-16/13, describes one unresolved item and two violations.
Exhibit 51, pages 7 through 9 of the final Inspection Report S5-1s/13, shows two
unresolved items.
P M IPS' Understanding of Concern No. 5:
Requirements: The requirements are described in Exhibits 1 and 52 which include
appropriate portions of 10 CFR 50 to Appendix S, Criterion XV; 10 CFR 50.55(e);
and FSAR, Section 9.5, pages 9.5-29, 58, 67, 68, 69 and 223 as described in
Exhibit 67. The testing requirements are ASTME 119 and IEEE o34
Nencomoltance with these Reautrements: Ennib:t 50 adequately describes the 4
noncompliance.
Bactorcund: PHILLIPS identified an unresolved item and a v2clation concerning
certifications and damaged seals in 1994 (DUNG was assigned to follow-up and
close these items, if possible, during inspection 85-16/10.
Procer Handlino YOUNG brought the additional findings as described in
Exhibit o7 to PHILLIPS's attention about midway through the inspection pertoc.
I
Because these technical problems might affect other plants, PHILLIPS wrote a
memorandum to expedste the issue. The memorandum recommended an CIA
investigation prior to a technical evaluation or a joint office Investigation
and IE because if 01 found false or misleading certifications, the issue was
much broader than the specific Comanche Peak technical problem as these seals
are used in many plants. This recommendation also considered the long stand:ng
understanding that if potential wrong doing may be involved, tne investigators
should review it first or jointly.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _
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'"'--
Mishandlinat The mishandling started when WESTERMAN received information
regarding potentially deficient fire stops. Instead of assisting the
inspectors, WESTERMAN and JOHNSON actively blocked the memorandum from going
forward to Headquarters. JOHNSON came on-site in January 1986, not to discuss
l the technical issues, but to criticite PHILLIPS for addressing the issue to a l branch chief in headquarters instead of his signature. PHILLIPS accepted the
criticism without telling JOHNSON that he was following WESTERMAN's directions
as to the addressee. This issue was raised in sid-November 1985 and was still
in the review cycle in aid March 1986. If JOHNSON had been an experienced _
sanager, he would have forwarded this issue insedia,tely as he could have
-
rewritten it to suit his style i~ ss n an hour. It took about 5 sonths for
the seacrandum to leave RIV. In
~
itatement, he defines it as worrying
the inspector's work to death an his ey have done to all of PHILLIPS' work
since he supported jEEEEEEElviolations in the Inspection Report 66-07/05 in
September 1985 through Inspection Report 86-08/06, etc.
The violations on BISCO seals were sishandled because of WESTERMAN's and
JOHNSON's lack of construction knowledge and expertenca as evidenced acove and
in WESTERMAN's statement (Attachment D, DIA Report) as quoted below
'A. Now, first off, the violation that I read you in here said that there
was no non-conformances required by G1-OP-le.0-4, Revision 1. That's
talking about Class 1-E equipment with deficient IEEE-323-344 test reports.
We are talking in this particular documentation wsth Appendix R
requirements for which there was not documentation of test requirements in
accordance with ASTME 119 and IEEE 634
That's why I'm telling you the violation is not proper even if there
had been a violation. I cannot go from - you want to make this an exhibit
to take a look at -- from the procedure which he says they violated which
deals with IEEE-323/344, which is environmental and sessaic qualification
of electrical equipment, to say that on an Appendix R type ites, which is
ASTHE 119 and IEEE 134, that that procedure would have required them to
write a non-conformance report." j
Comment: It is ey opinion that this statement is technically incorrect because
this is not solely an Appendix R requirement. The fire stops used throughout l
the plant are required to meet test criteria of IEEE 634 and ASTME 119. Also,
l'
such fire stops are an integral part of a bundle of Class IE cables which
penetrate walls, floors, etc., and are not Just a fire protection system
requirement.
Exhibit 68, pages 9 and 10 of IEEE 634, support this in paragraphs 2.1 and !.
It also appears that the design Criteria 3 and 17 of Appendix A and Criteria 111
and XII of 10 CFR 50 require the cable and fire stops to provide protection to
e cable from a redundancy standpoint alone,
i
Page 6351 "Q. There are several parts of the TDR. There's the issue of I
' deficiency and also a box called potentially reportable under Part 21.
A. I will you that I told Mr. Phillips if he wanted to make a
j violation out of that, he snould make a vtolatton out of that. l
I do not remember his line of logic, but he gave se some line of l
'
logic about not wanting to cite on deportability.
I
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x
Now, if you go back to the final report, he added in an item in "~~
here on page 9-A. Now that was his choice."
Comment; PHILLIPS does not recall WESTERMAN's advocating the proposed violation
conce.ning f ailure to adequately evaluate a construction deficierc7 IExhibit 50,
page 6-4). The basis of the proposed violation was that the TUGOD engineer did
not know (evaluatel tf the fire stops involved systems for safe shut down. 'Ti.is
teing the case, an improper evaluation always leads to a nc reporting sitL4ttan.
WESTERMAN would not allow such a violation to be written'.
These discussions with TUGC0 and the unresolved item.in Inspection Report
85-16/13 finally forced an adequate evaluation ano a potentially reportable itee
followed as evidenced in Exhibit 69. The design deficiency report in the
exhibit is still unresolved. NRC follow-up inspection has no'c seen accomplished
to date to determine the full acceptability of the way these tecnnical.1Ssues
have been handled; however, a quick review in January 1986 indicates the
50.55:e) was considered nonrepo,rtable but not all of. PijlLLIP3' and (0UNG's
technical concerns were addressed. <
Safety Significance: The saf ety significance of this, issue is similar to
Concern 1, 2, and 3 and should be considered a part of that greater concern.
,
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LIST OF EXHIBITS
1 Part50,Appefdix B, Criteria 18............................pp 413-416
~
2 FSAR Section 17.1.7, Design Contro1.........................pp 17.1-14 thru 18
! TUSCo QA, Se'ction 3.0, Design Contro1.......................p 1
4 B&R Traveler Procedure CP-CPM-6.3...........................pp 1-11
$ Westinghouse Procedure......................................pp 1-8
s
6 Traveler HE 79-248-5'500,....................................p 1-8
7- C o n t e n t i o n 5 . . . . . . . . . . . . . )s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p p 3 - 4
EL 3' DUREG-0797, Miscellaneous Item 2............................pp K-99 tnrv 102
.
9 RIV Report 79-03/03......................................... Letter and page 3
>
101 IE Proceoure for Vessel Installation: BOO 51.................pp Il-1 thru 2
.
'
10b IEP for Vessel Installation.u 50053...'.......................pp 11-1 thru 2
s 4 10c IEP for Vessel Installation: 50055..........................pp 11-1 thru 2
ano 111-1 thru 2
Trangnittal Lettar..........................................pp 1-2
N qt i g o o f V i o l a t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p p 2 - 5
11 Original Final Draft Inscection Repc-t 85-07/05
Submitted to nicutt. ...................pp 1-21
(1s., ,
Transmittal Letter..........................................pp 1-2
Notice of Violation.........................................pp 1-4
' *
12a Secono Final Draft > Inspection Report 85-07/05, Rev.1,
Signed October 2, 1985, Submitted to n!V and HQ.............pp 1-21
12b @ Comments
CIA Report..................................................pp 30, 42, 43
OIA Attachment..............................................pp 9 thru 14
13 Rtport 85-07/05 Issued February 3, 1986.....................
A
14 TSSR Section 17.1.16.................................... ...pp 17.1 ~3 tnra ~9
.
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LIST OF EXHIBITS
15 TUGC0 QAP Section 15, Nonconforming items...................pp 1-2 Section 16. l
i
Corrective Action...........................................p 1
!
to SLR QAM, Section 16, Contrcl of Nonconforming items.........p 1
)
17 FSAR Sect. ton 17.1.18, Audits................................p 17.1-3o
18 ANSI N45.2.12, Draft 3, Revision 0, 1973, Requirements for
Auditing QA Programs for Nuclear Plants.....................pp 1,5,6 ;
1
19 TUGCo QAP Section 18, Audits................................p 1
20 NRC Inspection Report 84-32/11, Nottce of Violation and
Letter......................................................pp1-3
1
21 MAC Audit of TUGCo and Response.............................pp 1-6,13,16
22 Worsham, Forsythe, Samples & Wooldrige Meme, May 29, 1965...pp 1-2 l
2 NRC Board Notification Nos. 85-067 and 85-076 Memo..........pp 1-2
24 PS Lebeln Report. February 1922.............................pp 2. 3, 44
25 TUGCo 7eansmittal Letter to NRC (enclosure Lobbtn Report)
26 NRC CA7 Report..............................................pp
S-1 thru 3
VIII-1 thru 5
27 NUREG-0797, SSER No. 11;....................................pp 31-33
28 Ccamanche Peak Response Action Plan--ISAP VII.a.4...... ....pp 5-9
29 Results Report--ISAP VII.a.4................................pp 1-53
30 Letter and Draft of the Notice of Violation So-00/0c........pp 4-4
31 List of Quality Assurec Structures, Systems, and
Components..................................................pp 1-2
.
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(
LIST OF EXHIBITS !
.
Original and Final inspection Report
'
32 Catails................pp 16 and 17 "
33 Identification .nd Control of Materials Parts
and Components, FSAR 17.1.9.................................pp 17.1-25 thru 17
~4 TUGC0 DAP, Section 8.0, Identification and
Control of items.. .........................................p 1
l
35 Code Requirements NCA 3886.6 and NCA 41!4.S............ ....pp 36, 4o
36 B&R QAM, Section 9.0, Identification and Control of Items...pp 1-4
.
37 -B&R Procedure CP-CPM-6.9E, Revisions 2 and 4................pp 16-19
,
01-QAP-11.1-26, Revisions 4 and 88..........................pp 6, 7, S
38 B&R Isometric PRP-CS-2-RB-076 (1 page) and
3til of Materials (1 page)
39 IE Inspection Procedures 49051,-53,-54,-55, and -56 (23 pages)
40a Portions of 01A Attachment D................................pp 112,11*
and 148-159
40b Portions of Attacnment J....................................pp 1-3 anc 9-13
41a Attachment M M o f 01 A R e p o r t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . p 9
42a Original Draft inspection Report 35-14/11...................pp 1-4
42b Second Draft Report $5-14/11 (with otrecteo cnanges)........pp 67-79
42c Final Inspection Report 55-14/11, March 6, 198e.............pp 10 and 13
43 FSAR Section 17.1.17, QA Records............................pp 17.1-40 thru 41
44a ANSI N45.2.9, Requirements for Collection. Storage, and
Maintenance of CA Records...................................pp 11-12, 14, 16-21
44b FSAR Commitment, ANSI N45.2.9........... ...................
45 TUSCO QAP, Section 17.0, Site Construction
Quality Records and Record Retention and Storage............p 1
4e Attachment Mh to 01A Recort.............................. ..pp 11-12
> I ! L ! r
3
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, v .
LIST OF EXHIBITS
47 Attachment MM of OIA Report.................................pp 13-14
48 TUGCo QA Record Receipt Controll/ Storage
Procedure CP-DD-18.4, Revision 7............................pp 1-2
CP-CPM-7.1, Revision 3, and.................................pp 2-4
STA-302, Revision 11........................................p 2
49 OIA Report, Attachment MM...................................pp 14-18
~
50 Original Rough Draft Report 85-16/13........................pp 3-1 thru 3-5
4-1 thru 4-4
o
6-1 thru 6-4
51 Final NRC' Inspection Report 95-16/13............. ..........pp 5-9
52 Regulation 10 CFR Part 50.55(e)..............................p 388
53 TUSCO QAP, Section 6.0, Document Control....................p
.
1
54 IE Gui dance on 10 Code of Feder al Regul ati on. . . . . . . . . . . . . . . .p 8-9
55 Trend Analysts..............,...............................pp 1-10
So South Texas Memorandum (Lessons Learned.....................pp 1-5
B&R Engineering Memorandum..................................pp 1-2
57 McCleskey's Field Notes
574 Review of Procedure NE0 CS-1................................; 1
57b Review of Construction Deftctency File......................pp 1-10
58 Johnson's Comments on Draft Report Se-16/13.................pp 1-5
59 Comanche Peak 50.55(e) Tracking.............................p 1
60 NURES 0797, SSER 11, Ceauents on 50.55(e) Reporting.........pp 0-279-280
61 TUGC0 Letter .TXX-4508) Unit Number Correction..............p 1
62 OIA Report, Attachment MM.................'..................;p 13-13
,
4
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LIST OF EXHIBITS I
. .
63 McClesky Field Notes on IE Bulletin Revtew
Notes dated November 1, 1985................................p 2
Notes dated Novemoer 2s, 1925...............................pp 1-10
Notes dated November 26, 1985...............................pp 1 and *
64 TUGC0 Official Contact List.................................pp 2
65 RIV Traveler for Report 85-16/13............................p 1
6o Conversation. Record, Phillips--Baker........................pp 1 and ;
67 BISCO Fire Penetration Seal Memorandum
November 25, 1935, Draft....................................pp 1-;
March s, 198o, Final........................................pp 1-3
8 Attachments (14 pages)
oa IEEE Standarc e;4...........................................pp 9-10
69 TUGCD/ BISCO Seal Documents
Design Deficiency Report....................................
TXX-43;8....................................................p;1i
TXX-4966....................................................; 1
TIX-4996....................................................c 1
50.55te) Evaluation No. 0177................................a 1
TSG-19695...................................................pp 1-2
5
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -
-- n -w wo
.
'
I. Ffndtne Sumart-
Our to QA.
B&RP1 arttoand Procedures. do not reflect current
autnarity delegations and G&H. f( ARS
Response:
At the time of, the audit we were operating under properly.
approver deviations. I
These deviations were incorporated ints a
permanent QA Plan Manual revisfort on July 1,1978.
E., Finding Summary:
enange review provides significant risk of error and is. inThe curre
noncompliance with 10 CFR 50 Appendix B.
.
Resoonse: We disagree err both counts. The gar Resident Engineer
has exercised extremely good judgment in implementing the authority
deisgated:to.him.
Of the; approximately 2000. changes /devia-
tions/cTarffications issued under the systant, we are aware of none
.. that trave provided exposure to. & significant risk of error. To
provide greater visibility of the design change functierr, e system
was. implemented err May 25, 1978 that provides an analysts of all
'
changes, and permits continuing evaluation of the field efforts.
Thts. system is current for ongoing activities at the present time
and wtTT be compTeted. for past activities art or before July 15.
1 19E T6dr cetter r.nac u are in fact irt compliance w1tn- LG CFR SQL,
(LC , l
(Appendix 5 is, supported by internal audits by TUGCQ QA personnei and
s independent audits by two separate NRC Inspectors. We propose to
(Teave the design change sfysten as is. -
l
3'. Ffndine Summary:
anc :nanges thereto TUGC0
priorQA does. not review ali procurement docunents
to release.
'
Response:
We disagree that this is a requirement. ~
requirement section, approved by TUGC0 CA, is included with eachA separate QA
purchase order and is. applicaole to all supplements.
these requirements. are authori:ed only by Quality Assurance. Changes to
4. Findf ne Sumary:
complex anc. atificuit to maintairr,.The current array of QA manuals and pro
Response: We agree. The new Plan manuai was, issued July I,1978.
Tne corporate
goal QA Program.
of streamlining; it'. Manual is currently under study with the
'
E. Findine Sumarv:
clearly. Records do not reflect the as. poured configuration
Response:
Configuratiert has always been made visible to inspectors,
.
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o
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; W Wi?-d&% M * MM!WMt W W W ~%
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4 .
.
OBSERVATIONS AND RECOMMENDATIONS. (APPENDIX. 8)
/
I Oroantzatierr
Reconnendation:
(planntng). Separate
-
inspection fron Quality Engineering
Reseense: We had begurt work orr this before the audit. Our product
assurance groupt has taken responsibility for Quality Engineering.
.
Recommendation:
comit:ee. Re. evaluate the charter of the Quality Surveillance
.
Response:
4
Consittee. We have decided te discontinue the Quality Surveillance
to keep top managrenent apprised of the status of QA matt
including
August quality
15, 1978'. trends. The first suc!t. report utiT be issued by
* '
.
Reconnendation: M re more seasoreti inspectoNr. litre any future
engtneers fr6iii outside the company wf th experience fit nuclear plant
construction.
Response:
We are orr the tookout for we1T qual.ffied: personnel and
continue to review appiteants from outside the company. The .
reTativeTy young: fnspectors.wil1 be strengthened best and qufckest
by taking from them the responsibility for inspectiore pTanning and
provfding them wf tte adequate, but concise instructions and
checklists.
This has beert done and fs effective.
II Quality Assurance Progrant
Recommendatfort:
Revamp our present QA manual systeur.
Resoonse: We agree.
L918. TUGCG QA issued a revised QA Manual on July I,
Opfnferr:
worn ts doneOtttairtfng
by others.our ASME Code stanrp wfTT be difficult if all the
'
-
Resoonse:
We know ft wtiT be dtfficutt, but tt carr be done. The
M. stamp. report oces not accurately record our stated. reasorr for obtaining an
III Desterr Controi
Recommendatiert:
Abandorr our present system of expediting field
.
_ _ _ _ _ _ _ _ _ _ _ _ _ ~ - - - - ^ -
'
. -"ILmw.tro.aws;.smesseb rsawr~mamvm+eswre i 1 -_=-- h
.
+
D. . . 3
'
.
A
, changes.
Reseense: We wilt leave ft as it is.
.
'
IV Procurement Document control
Recommendation: All procurement documents should be reviewed by QA.
,
Resconse: We dfsagree for reasons stated on Page 1.
. ..
V Instructions
Recommendation: Streamline inspection planning and checkTist.
preparation
Resoonse: We agree,, and have been actfve in this effort since
January. -
Recommendation: Of scontinue mappfng individuai standard imbeds.
Resconse: Mapping has been dtscentinued,' but we have retained. e
reasonante degree of traceabtTity on embedded. f tems.
Reconnendation: Comofne construction and QA procedures.
R'esconse: Sfnce January we have been doing this for new procedures
and, wnerr revisfng aid procedures.
Reconsnendtion: Of scontinue requiring B&R Houston approvat of
procecures. *
Resconse: All procedures except those invoTving ASME Code wort are
now approved at the site.
Observation: ATT appTicable CC/00A's are not included. fn supporting
COctEDentatTon.
.
Reseense: Refer ta Page I.,, Appendix A., Itenr 5.
R, econnendatton: Estabtfsh a formai site procedure for planning
construct 1ctr worie.
Resoonse: This planning is. being done. We don't intend to create a.
formal procedure for it.
O
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* - _ .. ,;.c._ _.=eenue MeisseasduuL1 mis 2srast '
..2 ,
*
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.
, VI- Document Control
Observation:~ The ARMS system should be backed up by a manual systes-
(stated vercally in exit management interview). ~-- -
Response: The auditors. lack of confidence in ARMS was the risTirt
if insufficient familfarizatfort with the system. orr their part.
. . . . , . ~
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. . . . . . = -
'
FVII Control of Purchased Material Ecuiement, and ServicesC ' '
, ,
Observation: The QA plan f s not up to date in this. area
.
. . . I
Response: Manual'.revisfort was. compTeted arr JuTy L.
. . . .
Statement: Source inspectors. (TUGC0 QA) appear te be at the mercy
of tne supplfer fr> determining * what changes have beerr incorporated.
R'esponse: . Thfs. fs not true. We (TUGCO' QA) prepare our owrr
chectlists after searching the appropriate filer. We agree wittr the
auditors' (verbal) consents that this method, placas are additional
burdere orr ourselves; however, the orfginal (and. TogicaI} approach of
depending uport G&M. ta prepare the checklists dfg not, worie.
VIII Tdentfficatforr and Control ch MateriaTs, Parts, and Comoonents '
No observations j
1
IX Soecial Processes
]
Reconnendation: The use of Iridium 192 shouTd. be regiaced by x ray
for all snop welds. and for field welds where practicaT.. l
Resoonse: Browrr & Root is studying t.*rfs reconnendatfort,, and is
comitted ts have a report for TUGCO/TUSL by July 15. 1
'
Recernmendation: Reduce the ntanber of individuals reviewing,
raciograpns and estabitsh the policy that Code-acceptabTe
indications. be recorded but not repaired.
i
Resconse: This had been accomplished prior to the audit, but
apparently the auditor- talked with someone who wastr't aware of it.
Reconnendattent C7arify the responstbf Tity of the NDE supervisor
relative to code work. i
-
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t ._ - - - _ _ _ - - - - - - - - - - - - _ - - _ - - _
_ _ - - - - - - - - - - - - - - --
*
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,
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.
i i l , Response: The auditors were confused .in this area. Our only Level
LIL at the site. is in civil work, not ASME Tec. III Div.1 work.
l
,
)r Inspection
,
Included
in here was a re-statement of observations covered elsewhe
the report. -
,
XI Test Control
-
Recommendation:
used ouring startup.Existing nonconformance control systeins: shouTd be
_
Response: . . . .
The new CA Manuat,. wf th fnput free TUGC0 Operations, will
,
accress. nonconformance controT systems.
XII ControT of Measurine and Test Ecufement '
Recommendation:
Equipment shoute not be recaTibrated on the due
date if te nas not. beerr used. - *
Resoonse:
The recommendation has. beert adopted for f tems whose
calteratiare is not subject te change white not frt use.
Implementatfort date was July 1. - -
XIII Insoectierr,. Test and Ocerattne Status
No observations
XIV HandTine, Storace and Shiocing
Recommendation:
revieweo. Extertor storage & protectiotr practices should be
Resconse:
We had previously reviewed the storage practices and have
no: reason ta teTieve that a problem extsts. Various NRC inspectors
have also fnspected tafs activity. However,, Westinghouse is
revtewing: this,, and thefr metallurgist wtll report by JuTy 15.
XV
Controi of Nonconfor-nances -
..
Observation:
Contrcl. Thfs is a restatement of concerrr over nonconformance
Resoonser
-
ratner- than corrected at CPSES.We reject the inference that problems are circu
J
_
. _ _ - _ _ - _ __ _.
'
e' .O
g,
, . . .
/ .
S.
r. .,/, .
*
- XVL . Corrective Action-
/ No specific findings.
-
_ _ . . _ .
XVII [w:ords,
.
Recommendation: This sectiert restated the need for ff[ protection
syster.
.
__ Rese.nse: The f nert gas' system will be installed by Augdit:.1,,_I,373;,,, ' , _ , _ _ ,
_
. --:..
XVIIIAudfts ~ ' ~
.
Recorrmendation: . The audit (D'aTTas). and survet1Tance (. site)
acetytt1es snould be comained.
Response: We intend to Teave our audit progars. separate frdar site
survet11ance.
.
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