ML20238B810
| ML20238B810 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/22/1986 |
| From: | Taylor B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237F760 | List:
|
| References | |
| NUDOCS 8708210508 | |
| Download: ML20238B810 (56) | |
Text
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UN11ED STA1ES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
INVESTIGATIVE INTERVIEW l
l
(
s LOCATION:
ARLINGTON, TEXAS PAGES:
1-31 DATE:
TUESDAY, JULY 22, 1986 Aa-FEDERAL REPORTERS, INC.
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cy/ind %
444 North (
NDP1 Attachment LL
@2)
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NATIONWIDE COVERACE DR AD 5
0 45 G
T I
1 l
l I
l STATEMENT
_O_F BOB TAYLOR j
July 22, 1986 i
VIA TELEPHONE' HOOKUP BETWEEN I
NRC Region IV Headquarters Arlington, Texas i
and
{
The South Texas Nuclear Project t
Bay City, Texas 3:45 p.m.,
C.D.T.
i t
8 TAKEN SY:
George Mulley and Stephen Goldberg
{
REPORTED BY:
R.
Patrick Tate TATE REPORTING SERVICE, (713) 222-7177
.______-_m__-.m_.--.s
1 2
j 1
BOB TAYLOR 1
2 was examined and testified as follows:
{
3 EXAMINATION d
4 By Mr. Mulley:
l 5
0 The time is 3:45 p.m.
The date is July the 22nd, 6
1986.
We're conducting this telephonic interview of Bob i
7 Taylor who's a project inspector with headquarters Region 8
IV NRC, present are myself, George Mulley, who's the 9
Assistant Director for Investigations, Officer of Inspector i
l 10 and Auditor, NRC, Stephen Goldberg who's an technical 11 advisor to the Office of Inspector and Auditor and Pat 12 Tate, who's the court reporter.
r l
1 13 The reaspn for this interview is to discuss with 14 Mr. Taylor some information he may have concerning the 15 Region's inspection program at the Comanche Peak Nuclear f
16 Power Plant.
17 Mr. Taylor, before we begin, could you give us a I
18 brief resume of your background, especially at Comanche i
1 19 Peak?
l 20 A
Brief resume of my background at Comanche Peak?
1 21 Q
Right.
g
)
<1 22 A
Well, all right, I came with the agency, November j
l 23 1, 1974; during the -- and for about one year, plus or l
l j
24 minus a month, I was with the vendor inspection branch in l
25 the architect / engineer section.
TATE REPORTING SERVICE, (713) 222-7177 i
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3 i
i 1
1 I was reassigned then to a construction part of
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i' 2
the reactor construction branch, and from 1975, 1976, 1
3 beginning of '76, I was the project inspector for the South 4
Texas Project and for A&O 2.
5 At the beginning of 1978, with the resident i
6 program on the horizon, I was reassigned, acceptably to me, 7
to be the project inspector for Comanche Peak, with a l
l 8
reasonable certain knowledge that if and when the residents 9
program came into being, that I would be assigned as the 10 resident.
And that came to pass, and as of August 1, 1978.
11 Q
Okay.
And currently, you are assigned as the 12 project inspector at the Region and you are on assignment i
k 13 down to South Texas for this week.
Is that correct?,
i 14 A
That's right.
I'm down here approximately every 15 other week and have been since last October.
j_
16 Q
Okay.
l i
17 Q
(By Mr. Goldberg)
Hi, Bob, this is Steve 18 Goldberg.
19 A
Hello.
l 1
20 0
I want to start out with the method you used when 1
21 you were a resident inspector at Comanche Peak in terms of 22-budgeting your hours of assigning your hours to the various l
23 parts of the 25.12 program.
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24 A
I think you better stop right there.
First of 25 all, in the early days of the resident program, the TATE REPORTING SERVICE, (713) 222-7177
1 9
4 1
resident inspectors did not do 25.12.
Their primary I
2 assignment was a manual chapter called 25.92, which 3
referenced and contained the so-called C modules.
Didn't 4
have anything to do with 25.12 per se.
i 5
Q Well, let me not use the word 25.12.
We'll come 1
6 back to 25.12 later.
But let's just deal with 766.
We've 7
been attempting in CIA to use 766 to get a fix on how much 8
time you all spent, particularly yourself, in particular l
9 modules or procedures in the program.
Is that an accurate I
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10 picture, does that portray an actual picture of the actual 11 spent time --
l 1
l 12 A
only if you're reading it correctly.
1 13 0
only if you're reading it correctly?
l 14 A
That's correct.
i 1
15 Q
What do you mean by that statement?
16 A
You remember, in reading the 766 form, or the 766 17 computer printout, you'll see module numbers and I'll give I
18 just a number, 50090.
Now that has a B version and it has 19 a C version.
l 20 The B version was primarily done by the regional 21 based inspectors; the C version was primarily done by me.
I e
22 So most of the time, all you're going to see on the I
23 printout representing C time is mine.
Most of the time
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24 what you're going to see in looking at the B time is 25 regional based.
TATE REPORTING SERVICE, (713) 222-7177 L_____---_------------
5 1
Q Okay.- Fine.
What my question, though, is I i
2 think, let me try it a different way.
If we looked at the 3
C time,'C modules and we looked at the' time that's alloted t
l 4
for containment, structural review, QA modules and look at 5
the number of hours --
6 A
You won't find any QA modules with C numbers on 7
them.
8 Q
I've got to finish my statement, if you could 9
give me some time.
I 10 If one is looking at the number of hours in which 11 is assigned to that area, can one then assume -- or I'm 12 sorry, is put in to 766 in that area, can one assume that
~
/l 13 is the entire amount of time t'at Mr. Taylor spent in that 14 area to cover that module arid no more or no less?
15 A
I'd like.to say I filled out the 766 form 16 accurately.
And I would like to say that it was printed 17 out in the computer accurately.
I can't be more than 95 i
18 percent sure of that, but yeah, I'll go that far.
19 Q
The reason I'm asking the question, I'm not i
20 trying to pin ycu down is because we in the office are I
21 relying on that as input as'we analyze the amount of 22 coverage that was given to various disciplines and what was i
23 covered in various areas that are required by the earlier j
i j
24 version of the program, the later version of the program, 25 and various iterations thereof.
TATE REPORTING SERVICE, (713) 222-7177
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6 1
A I understand that.
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4 2
Q And all we're trying,- I'm trying to ask you is, 3
maybe you spent -- I den't know this but you'might have 4
spent more time i.n what is indicated in 766, on certain
{
5 aspects of the program.
l 6
A No, I don't think that would be a fair statement.
7 If I spent time on a particular area, I reported that time 8
on the a'rea.
9 0
Okay.
What I'm going to do, I'm going to. start I
10 by dwelling on the QA modules if I could, or procedures, 11 and ask~you, A,
what you remember of these modules and B,
)
12 if they weren't covered, what you know of why they weren't k
13 covered and what is picked up in the new program, if you j
i 14 know that, in the 9 areas.
And I've got six in front of me 15 which we've been looking at, specifically; the first one is 16 the module number 35020.
17 A
0207 18 0
020.
It's entitled, " Audit of Applicant 19 surveillance of contractor, QA/QC Activities."
20 A
Okay.
21 Q
I'm going to give you from my work what was l
22 required in, frequency and also give you what we know of in 23 terms of data in 766, I'm going to go down one by one.
24 It was required to be done five months after 25
' docketing, as an as-required module and it stayed that way TATE REPORTING SERVICE, (713) 222-7177
7 i
i up until the present time.
'i 2
According to 766, six hours of inspection was 3
expended.in 78-07, two hours in report 78-09, six hours in 4
report 89 -- 84-29, and a 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> in 84-32.
5 We understand that in inspection report 78-07, 6
the inspection report does not indicate an observation of 7
the implementation of the program as required by the 8
inspection procedures, moreover inspection report 78-09 9
gave a brief close out of an unresolved item.
10 We understand the first thorough inspection was 11 done was in 84-29.
Although the first inspection should 12 have been performed in middle 1975, we understand it was 13 only commenced in 1978, and there's some question whether l
14 it was an adequate inspection.
We need for you to comment l
15 on that issue.
16 A
I'm confused by your number.
350207 17 0
35020, that's correct.
l 18 A
I don't believe that particular procedure even 19 existed in 1975.
20 0
It existed in -- according to my research, I have 21 a copy of it, if you can hold on for a second, I can pull l
22 it out', I have'a 1979 copy of the module.
It existed when l
23 the 25.12 program was initiated.
j 24 A
I don't think -- I don't believe that's the case.
25 0
okay, maybe you can check.
TATE REPORTING SERVICE, (713)'222-7177
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l 1
A I don't have anything to check with but I don't 1
1 2
believe that's the case.
l t
3 0
I've got the back up, I can go back and see 4
what --
i 5
A What did exist, on a predocket level, was manual
=
6 chapter 25.11.
7 0
That is correct?
?
8 A
Well, then I recal what did exist also, in manual l
9 chapter 25.12 and the '75 to about '78 or '79 version, was
)
10 a procedure called mid-term QA which was 35200.
f 11 Q
Okay, we will get to that one and let's reserve 12 35200 to a later discussion.
But 35020 did exist on 13 January 1st, 1979 as part of the 25.12 program.
I 14 A
That may well be.
I 15 0
I have enclosure one to MC 25.12 on page 25El-4 l
l 16 and it shows that to be the case.
Now, I don't know in l
I 17 fact whether it existed before that date, you're right.
i 18 But it did, but you did do work on it in 1978.
l 19 A
I did?
I 20 0
And the question is --
21 A
Now wait a minute Mr. Goldberg.
Have you I
22 established that I did that?
23 Q
No, I didn't.
I've established that work was j
24 done on that.
25 A
All right.
TATE REPORTING SERVICE, (713) 222-7177
9 1
1 Q
By you, I mean the Region, you all.
2 2
A Okay.
3 Q
And the reason we're asking the question is to 4
establish that you did it, you personally did it or not.
5 A
I don't think I can answer the question.
My 6
recollection is no.
But that's not a very firm i
7 recollection, that's a long time ago.
8 Q
When did you start at Comanche Peak?
9 A
I think my first inspection there was sometime in j
10 February of 1978.
And that was as a project inspector 11 visiting from the Region.
l 12 Q
When were you the resident inspector?
k 13 A
I was not the resident until August of 1978.
14 Q
Okay.
So it's possible you didn't do these i
15 inspections in 19787 l
16 A
It's possible, quite possible.
17 Q
okay.
Well, gets back to the question then is, I
18 when you became resident inspector, did you have any l
19 interest in this area to pick it up and to determine 20 whether it was adequately covered or not?
I 21 A
No, I would not have.
Again, I take you back to 22 25.92, which is the resident inspection program, not 25.12.
23 And it did not contain QA procedures.
(
24 0
okay.
Do you know if how this gets picked up in 1
25 your knowledge of the inspection program at Comanche Peak, TATE REPORTING SERVICE, (713) 222-7177
_ - ~ _ _
10 1
how it gets back and into other inspections?
I 2
A That should have been scheduled as part of the 3
so-called B program and that's what 25.12 was in those 4
days, by the Region, with regional based inspectors.
5 0
Okay.
I think we're going to have the same 6
answer on all five other ones, but we're going to go down 7
the list.
I 8
A We will probably indeed going going to have it --
9 Q
I'm going to go down the list for the record.
10 We'll go down for the record.
But I've got other modules 11 which we'll talk about after I do the QA moldules; you may 12 have a better recollection.
13 A
All right.
14 Q
Okay, management of QA activities, 35060.
15 According to 25.12, it came into effect on July 1st, 1980, 16 was supposed to be done once every 18 months.
When the l
17 program changed on September 15th, 1981, they went to a i
18 priority system.
19 A
Right.
20 Q
Priority one, priority two, priority'three, 21 priority one says do it in the second and forth year or the l
l 22 first years after the CP.
It got changed again in March j
23 30th, of 1984, supposed to be done every 18 months.
24 The first time this inspection was done was in 25
'1984.
Okay.
And I guess you're saying the same thing you TATE REPORTING SERVICE, (713) 222-7177
11 i
1 said earlier, you were a resident inspector, this was not 4
2 your area.
Is that correct?
j I
3 A
That's right.
{
4 Q
Okay, we will go to the next one, in depth QA 5
inspection, module number 35061.
According to to the 6
program, supposed to be done starting May 1st'-- I'm sor 7
July 1st of 1980, annually, then got into the priority 8
program in September 15th, 1981 as one per area for each of 9
the areas such as civil, structural, et cetera and then 10 changed again in March 30th, of '84 and be done annually.
11 Question is:
Are you familiar at all with that inspection 12 module?
f
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13 A
I'm familiar with it's existence, yes.
l 14 0
But did you not do any work in the area?
15 A
I did not.
16 0
okay.
Procurement, receiving and storage.
17 35065.
Supposed to be done starting July 1st, 1980, 18 annually after the CP was issued.
It changed on September 19 15th, 1981.to under the priority program to be done the t
20 second and fourth year after the CF.
Then changed it back l
21 on March 30th, 1984 as an annual requiremer.t.
Do you have 22 any knowledge of how this was performed?
23 A
No.
j 24 0
okay.
Next one, review of,the QA manual, 35100, 25 supposed to be done starting on March 31st, 1975, I'm' TATE REPORTING SERVICE, (713) 222-7177
12 1
sorry, supposed to be done prior to 1980 to be done each 2
inspection to be done per discipline.
And according to 3
what we understand, it was not done completely.
Do you 4
have knowledge of that module, of what what happened to 5
that module?
6 A
That's peculiarly strange one because 35100 has 7
existed for a long time.
But you did pieces of it through l
8 other modules and never reportsed it directly.
l 9
0 okay, how was it reported, then?
10 A
Reported as part of another module.
11 Q
Do we know how it was reported as what it was l
l 12 completed?
13 A
No, it would never have been reported at all 14 under the original system.
It would only have showed up 15 later in the !.5.12 program as a free-standing element.
But i
16 earlier on in the procedure reviews, that went with each of 17 the discipline areas, it was an implicit part of those.
18 You used it as a reference tool.
19 Q
Although you used it as a reference tool, how f
?
1 20 does one, when they go back and review all the modules to l
21 determine whether it was completed or not?
22 A
You wouldn't.
Can't.
i 23 Q
okay, let me go on to the next one.
- 35200, j
24 mid-term QA inspection.
It was done way back, in --
25 A
Latter part of 1978.
TATE REPORTING SERVICE, (713) 222-7177
13 1
0 1978, under inspection reports 38-20 and 38-23, 2
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> were given to that effort.
Are you familiar with 3
that inspection?
4 A
I was on site when it was going on.
5 Q
Do you think it was an adequate inspection?
6 A
I wasn't there to judge that.
That's my 7
superiors responsibility.
)
8 Q
Do you have any -- can you give me any l
9 information,on it?
)
10 A
Well, there were three or four people there for a-1 1
11 weak, that's about all I can tell you.
12 0
You don't know what was covered and and how it
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13-was covered?
14 A
No, they were out there in a little conference 15 room I had and they did there thing out there and I did my 16 thing separately.
17 Q
Okay.
18 Q
(By Mr. Mulley)
This is George Mulley, Steve is i
1 l
19 looking for some,other papers.
Let me ask you some general i
20 questions.
While you were at Comanche Peak - -
21 A
Say that'again, George.
I l
l 22 Q
While you were at Comanche Peak, did any Region 23 IV managers or supervisors discourage inspectors or you 24 from documenting, you know, exactly what they found during i
25 inspections?
l I
TATE REPORTING SERVICE, (713) 222-7177
14 1
A No, I don't believe so, not -- absolutely not.
2 Q
Were you ever harassed or pressured to not.
3 document violations or to downgtade violations by the i
i 4'
Region?
5 A
Never at all.
6 Q
Never encouraged to drop violations or to handle
?
'\\
7 things informally with the licensee?
'l) 1 8
A Never at all.
9 Q
In Region IV, do you think they encourage i
10 inspectors to concentrate their inspections on hardware 11 items and stay away from now the QA issues?
12 A
The inspection program is structured to do that.
h 13 25.12 reads that way.
14 Q
- Okay, i
15 A
Absolutely.
Look at the end product, not how you i
[
)
16 got there.
I'm a strong proponent of that one.
4 17 Q
You've already probably given me this 18 information, but you left Comanche Peak when?
19 A
Roughly the middle of January, I think abgut the l
i 20 23rd or something like that.
In 1984.
l 21 Q
Okay.
As the, you know, as Comanche Peak neared 22 it's licensing, were you ever directed by the Region to.go j
23 out and'just start closing out modules and inspection
[
24 procedures, just --
25 A
I was not.
I think I know where you're headed.
TATE REPORTING SERVICC, (713) 222-7177
4 15
\\
1 I may a'nticipate your questions, I'm sure you're referringL 2
to one of the insp'ection reports that closed a significant 3
number of modules with no time reported on them.
4 Q
That's correct.
5 A
All right.
When the priority scheme came out, my l
6 then supervisor, Mr. Crossman and I, agreed that I would go y
Q 7
through what we called the line item ch'eck sheetc thd t we j
8 had maintained on station from the first time I went there.
9 And those things which no longer were required by the first l
10 two priorities were considered complete and the module was j
t 11 considered complete.
And so taken care of on the.766 form.
12 Now if you have access to those she'ets, you'll see "X's" in 13 certain portions of them.
14 0
okay.
]
15 A
That says' basically that I closed them out on the 16 basis of review versus the priority scheme.
17 0
(By Mr. Goldberg), I don't understand that.
I 18 A
The module'was considered a hundred percent 19 complete at that level.
l t
20 Q
(By Mr. Goldberg)
You'll have to explain that, lk 4
21 Mr. Taylor.
I don't understand that, if you go back to the 22 manual and what's determined to be complete, I -- unless l
23 you have a documentation to tell someone how you closed i
24 them out, I don't understand by simply check sheeting it 25
'how you do it TATE REPORTING SERVICE, (713) 222-7177 1
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r-
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16 1
A Well, let me ask you this, Mr. Goldberg.
If we 2
have gone along for a period of time with an inspection 3
procedure and a new procedure with the same number comes 4
out and reduces the sample size 50 percent and you've 5
already inspected the remaining 50 percent, is not that 6
module complete?
7 0
Yes, it is, if you can verify if did you the 8
other 50 percent --
9 A
Same logic.
10 0
That's the key.
If you -- if you can track that 11 you actually completed the second half of those required 12 portions of the procedure; the requirements section, r
i 13 section two of the procedure.
14 A
I understand that.
15 0
In other words, you have to show that you've 16 completed in some way.
17 A
That's on the line item check sheets, it would la not appear in an inspection report.
19 Q
In other words, if one wanted to go back to the 20 line item check sheets, you would be able, one'could then 21 make a determination that all the requirements on each 22 procedure have been covered in one place or another?
23 A
That is my recollection, that's what the check j
24 sheets were for.
25 0
Do we still have those check sheets?
TATE REPORTING SERVICE, (713) 222-7177
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17 l
I i
l 1
A I dor. ' d have them, nd.
I leit them on site in3, 2
1984, what happenet.to them since then, I haven't the 3
vaguest idea.
]
4 MR. MULLEY:
Okay, that sounds good.
l 5
0,,
(By Mr. Mulley)
Region IV's regulation of I
6 Comanche Peak, waslit influenced in sny way by'the f a c e.
~
9 th,at the licensee was being'b'it pretty heavily by the 7
8 interveners and therefere the Region.to3k a p>sition of j
A 9
trying to minimize criticism by the interveners by keeping t
10 things, you know, tryIng to resolve issues and keep things T
11 outofwritijg?
12 A
No.
i 13 O
Sefue didn't, w-didn't lave a "we/they" f
+
14 a tti tude, yqq know, us and the utility against the I
15 intervenor?
l 16 A
No.
I 17 Q
Okay, so in your opin:.on, did the Region 1
l 18 ob]ectively regulate the construction of Comanche Peak?
19 A
As best we could, yes.
l 20 Q
Okay.
1 i
21 Q
(By Mr. Goldberg) I'm sort cf at an advantage
~
I l
22 over "you and I;have your inspection reports And I.'m goiny 23 to ask questions about them.
I don't know if you want to d
1 l
{
24 comment, or tel1 mc if you cdM..t, then we'll just do the N
L 25 best veican heceabecause it - <the medium we're using 10 i
l TATE REPORTING SERVICE, (713) 222-7177
+
8 u___________.
.pg 18 1
l 1-not easy because these are geared --
2 A
I don't'think it would probably be easy in any 3
case.
Go ahead, l
4 Q
I want to be doing it discipline by discipline.
5 The area I'm going to be talking about first is structural i
6 steel and steel supports outside containment.
The module 7
number is 48063.
In report number 79-19, it's reported S
that the amount of, percent of completion went from 20 to a 9
hundred percent.
But the subject is not mentioned in that 10l report.
Dc you have any comment on that?
y 11 A
Not offhand.
I'm curious on one thing, what 12 module number are we talking about?.
I.
13 0
48063, as I said earlier.
14 A
Let's have the suffix, sir.
B or C.
l 15 0
It's B.
j I
16 A
That is a regional inspector inspection.
17 Q
Okay.
I will not talk about -- okay, we will go t
18.
to the next one here.
I'm glad you asked that question.
19 A
It's critical.
I thought I explained that at the 1
l l
l 20 beginning.
21 Q
I yeah -- unfortunately what I'm reading from 22 doesn't have the B or C suffix, I have to go to another j
23 document.
24b Q
okay 51053C.
25 A
C, all right.
What's the subject of 510537 I
TATE REPORTING SERVICE, (713) 222-7177
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2_____E____________________________._________________
19 l
j 1
don't recall.
l L
4 2
.0 It's in'the area of electrical components and 3
systems.
4 A
Okay.
5 0
It's electrical.
Unfortunately, I'll be honest 6
with you, it's merged together with 51054B and 51055B which j
7 are also in the similar discipline.
I 8
A That's right.
9 0
So we have some Bs and Cs together here.
10 It looks like in the case of 51055C, it's only up through 11 82-01, it got to -- I'm sorry, 81-18, it got to be 90 12 percent complete and then dropped to 50 percent complete in
(.
13 the 82-01.
I'm giving you report numbers.
I 14 A
Yeah.
I 15 0
Do you have any comment on that?
i 16 A
Not necessarily.
In the C program, at least the l
17 way I did it, in the absence of any guidance, and you'll 18 have to understand how the C program worked in order to I
19 make this logical, the C program -- first of all, the C 20 modules were what I called tourist modules, the inspector 21 went out and simply looked at things for the most part; 22 they're relatively little hard firm inspection; no sample i
23 sizes whatever involved.
24 You simply took a tour every so often in relation 25 to tha amount of work going on in the particular area.
TATE REPORTING SERVICE, (713) 222-7177 t._____.___.___m
______._-_____mm_._______
.I 20 1
Now, I assume 51053 probably dealt with the setting of 2
electrical cabinets and so on.
While that whs going on, 3
such as switch gear, motor control centers and so on, the 4
inspector was expected to go out and look at that -- look 5
at that work being done.
6 Records were relatively small piece of it.
Nor 7
were there any specific quantity that we were supposed to 8
look at.
If work went on for six months, look at it for i
9 six months.
When the work was done, it's done.
Now, the 10 percentages reflected on the 766 are not the percentage of
~
11 the module done in almost every case; they are an estimate 12 on my part of how much of the construction activity is i
13 done.
When the, activity, when the construction activity is l
14 done, the module is done, under the C program.
Do you j
15 follow me?
l l
15 Q
Yes.
17 A
Now, there's no other guidance in the system that i
i 18 I'm aware of en that subject.
The B program had specific l
19 samples size.
Now, if it hapened to be ten things you were l
20 supposed to look at and you were done completely with one i
l 21 of them, that was ten percent.
l 22 0
okay, let me just follow with that.
l 23 A
It isn't structured that way.
24 0
okay, in one of the reports, and again I'm 25
' advantage over you because I've got the colloquy on the TATE REPORTING SERVICE, (713) 222-7177
21 1
reports, let me just dig it up here.
I 2
The report states, this is under report 81-07, 1
3 and again there is some mixing between the modules, it may 4
be yours, it may be that region based inspector; work was 5
counted against 51053, but and it looked like 51053 got a 6
lot of coverage on that inspection, 81-07, let me just 7
check here.
It appears that 70 percent was completed.
8 Yet if you read what was the effort that was 9
being expended, there wasn't effort in procedural 10 implementation, missile protection, electrical separation 11 requirements for redundant systems, calibrations, trip 12 settings, et cetera, i
13 It's difficult to know what work you did,during i
14 that time to give it so much completed efforts.
I 15 A
I don't believe I wculd have done that.
The 16 electrical specialist from the office generally did that 17 sort of thing.
18 (Discussion off the record.)
19 Q
(By ir. Goldberg) Okay, now, I'm confused.
20 The C module, you say the C module is for the resident and 21 now you're saying a electrical specialist doing that?
22 A
Did you say that was a C module?
23 0
Yes, I did, 51053C.
[
24 A
In that report?
25 0
It's hard to separate,in that report how much you TATE REPORTING SERVICE, (713) 222-7177 l
22 1
did and how much the, as I safi earlier, what was 2
accomplished by the Region based guy.
d 3
A Who were the Region based guys.
4 0
I'll tell in a second.
It's 81017, inspectors 5
were Gilberg and Martin; I guess they are the_ Region.
6 A
Gilberg and Martin, both of them region based.
7 0
I'm really confused.
You are right.
51053C is 8
taken credit for in this inspection report and it's done by 9
region based people.
I throw-up_my hands.
don't know.
10 Okay.
We'll have to go to another issue,.
~
11 A
All right.
12 0
Okay, let's go back to the issue you said l
13 earlier, about percent of completion of the module.
I l
14 guess from my experience, percent of completion of the 15 module is not based on percent of completion of activity --
l 16 construction activity but rather, percent of completion of 17 the inspectors activity.
You are saying the opposite.
4 18 A
Mr. Goldberg, have you taken the trouble to go 19 read the C modules as they existed in '78, 79 and '807 20 0
Well, I don't have the C modules in front of me.
l 21 I have portions of another program.
But why don't you tell 22 me what you think it says.
l 23 A
Well, I thought it already had but I'll try it 24 again.
The C modules for the most part were entirely the i
25
' modules such as 53, which are observrLion modules, and they TATE REPORTING SERVICE, ('/13 ) 222-7177
1 23 i
1 were written in.that time frame to require the inspector to 2
make a weekly tour, a quarterly tour, a monthly tour, or I
3 whatever, and inspect the activity ongoing in the facility.
1 4
It didn't have any sample sizes in it, you weren't expected 5
to inspect 10 things, you were expected to inspect as much G
as you could on that tour basis.
7 Now, there were a lot of modules in the tour 8
basis, like 40 some odd and they all had these type.of 9
frequencies of tours.
Now, if you were on a touring basis 10 with no sample sizes, then you have to construct something i
11 else that says whether the module is complete.
That j
12 something else was if the activity is complete.
Then you 1
4 13 can't inspect it Tymore.
14 0
Okay.
Goes back to the the C program.
9 15
'Unfortunately we don't have the modules in front of us on j
s 1
16 the C program.
But I'll ask the question.
Did the C 17 program have specific line item inspection requirements in l
18 section two or some other version; did it have anything l
19 where the inspector is required to do the following?
I l
20 A
To do what?
21 0
Does it -- let me ask you, the description of the 22 module, did it have any kind of the inspectors, had certain l
23 required steps to take or certain requirements, written j
24 down?
25 A
It had things that you should look for.
TATE REPORTING SERVICE, (713) 222-7177
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24
)
i 1
0 But they did not have a section called inspection
]
l 2
requirements?
I 3
A Oh, I don't recall the title of it.
It's -- the 4
C module has inspection requirements, certainly.
5 Q
How does one then determine whether you've 6
finished those requirement, if you completed those l
7 requirements?
8 A
There's no way to do that.
There are no discrete 9
sample sizes in the C program.
10 0
I am --
11 A
You don't inspect 10 gizmos.
12 0
I am extremely confused.
}
13, A
I guess you are.
14 0
Because I don't understand how you know whether i
15 you completed what you're supposed to complete.
I don't 16 know what you're trying to get when you get to the final; 17 is it a piece of work is done, that maans it's a hundred i
18 percent complete from the module, even though you may have j
l 19 not even u:ed the mcdul:?
20 A
When a discipline activity was complete, then 21 that work was a hundred percent complete and that 22 inspection was a hundred percent complete.
23 0
Well, theoretically you might not do an 24 inspection and call it a hundred percent complete if the 25 work activity is a hundred percent complete?
TATE REPORTING SERVICE, (713) 222-7177
S 25 1
A Ordinarily you wouldn't report that at all.
2 Q
But you'could based upon what you're telling me.
3 A
I know, but I wouldn't have done it as an 4
example.
5 Q
You but you could?
6 A
I could, yes.
7 Q
That doesn't sound logical.
8 A
Dut that's the way the program was structured.
9 0
Well, there's something wrong then-because 10 literally you could have a hundred percent complete of 11 everything and never do any inspections.
12 A
That's if your dishonest, that's correct.
1 13 Q
No, based on what you,just told me, based on --
14 you said that the work in progress, controlled the percent 15 of completion of the module.
16 A
That's correct.
17 Q
Based on that, then, you could have no i
18 inspections done and be a hundred percent complete.
19 A
If there was no work in progress.
Now let's take 20 a hypothetical.
When I went to Comanche Peak in 1978, the l
21 vast majority of what was called -- well, take one straight j
22 one.
Called lakes and dams.
There was a module in 23 existence at that time.
24 Now, it was primarily devoted, almost entirely, 4
25
'to that pile of rock out there that separates the essential TATE REPORTING SERVICE, (713) 222-7177
1 i
26'
)
i i
cooling pond from the rest of the reservoir.
That dam was f
2 there.
It was finished, there was no work that I could 3
observe on it.
I 4
Now, there was a C module for lakes and dams.
5 Now, the only thing, if I ever did anything on it, it was 6
to go look and see if there had been any erosion of the I
J l
7 face of the dam from water wave action.
That would be all 1
8 I could have done.
1 9
0 Okay.
If, let me go to another question, I think i
10 we've gone as far as we can.
There are steps or j
11 requirements, and we don't have a C module here and I wish 12 we did, but we won't.
If there were requirements that are 13 listed on that, on the C module, or cook book steps, 14 whatever we call them, how do you view that, do you view 15 those that you must, like line items, go down that list and 3
16 accomplish each one'in that sequence and accomplish it so l
l l
17 you can be satisfied that that module is complete or do you l
18 view it more as a guide?
l 19 A
More as a guide.
l 20 0
(By Mr. Mulley)
This is George Mulley.
Could
)
21 you give me an example of the nature of some of these l
1 22 requirements; because I think we might be talking two j
23 different things here.
What would some of these 24 requirements be?
Do you have --
3 l
25 A
Let me take you to a scenario that you might TATE REPORTING SERVICE, (713) 222-7177
i 27 1
understand more easily.
There were some modules in the 51 1
2 series, and I dont recall the numbers, that dealt l
3 essentially with installation of cables, electrical cables.
4 0
okay.
5 A
Now, in the a module, my recollection is, that it 6
told you to observe the installation of 10 safety related 7
power cables.
And it broke them out into so many for-the 8
RPS system and so many for this and so many for that.
And 9
when you had completed those 10 cables and all of the 10 characteristics th.ereof, then that module would have been-11
- closed, i
12 Q
Right.
13 A
Now, in the C program, it gave you, it told you 14 to go observe cable pulling, cable installation, cable et 15 cetera; and gave you certain characteristics that if that t
l l
16 was happening, that you should look for --
17 Q
For example?
I j
18 A
-- were happening.
Now, there was no sample size j
\\
19 that said "De this weekly."
)
20 0
For example, what characteristics would they ask l
1 1
21 you to'look at in the cable pulling?
j l
22 A
Well, to see-that you, that you're tray was clean i
23 and free of burrs.
l 24 0
Oh, okay.
25 A
All right?
i TATE REPORTING SERVICE, (713) 222-7177 1
_- ~
28 1
Q Right.
So there's --
2 A
The conduit had been swabbed; if I happened to be 3
watching a cable pull through tray, I wouldn't observs the l
4 conduit being swabbed and vice-versa.
5 Q
Right.
6 Q
(By Mr. Goldberg)
Would you acknowledge that in 7
the inspection report that you did not observe it or did 8
observe it?
9 A
No, oh, no, it would not say that, we only,say 10 what we do observe.
We don't say what we don't observe.
11 0
So basically, if there is guidance on what to 12 look for but there wasn't an opportunity or it wasn't f
13 practical to do it, you did not account for each of the 14 things that are written in the manual; in other words you 15 don't have a one for one for things in the manual what you 16 did do -- or what you didn't do; all you accounted for is i
17 what you did do?
i j
l 18 A
That is correct; that's what the manual chapter 19 on writing reports says.
t l
20 Q
(By Mr. Mulley)
From what I understand, the t
i 21 things that'you were looking at aren't requirements, j
22 they're guidelines to what to look at when you look at a
{
23 cable pulling?
24 A
That's correct.
3 25 Q-Yeah.
I understand.
TATE REPORTING SERVICE, (713) 222-7177
1 l
29 l
1 Q
(By Mr. Goldberg) 'Okay, we're not going to go l
2 further because as I looked at tne other things that we're i
3 looking at, they're all as.
So I don't think it's 4
worthwhile to talk to Bob about the Bs.
5 MR MULLEY:
Okay.
6 MR. GOLDBERG:
Even of the each of the discipline 7
areas.
8 THE WITNESS:
I will go one thing further for 9
you, Mr. Goldberg.
10 Q
(By Mr. Mulley)
Yes.
11 A
At one point in time, the 766 had three fields on 12 the front face of it has the inspector checked;'one was if I.
13 it were a resident inspection; another one was if it's a 14 regional based, and the third was other.
Now, if I checked 15 the resident modules and attempted to report a 5105'4B, it 16 would be rejected by the computer.
17 MR. GOLDBERG:
Okay.
I agree.
18 Q
(By Mr. Goldberg)
Let me ask you, throw it back 1
19 to you, do you want to provide us any information on the i
2-0 completion of the program, because that's an issue that i
j 21 we're working on right now, in terms of what was completed,
'22 when it was completed, how well it was completed, and why l
23 wasn't, if not completed during the time it was. set, 24 particularly in the 12 program.
We've been concentrating on i
25 the 12 program and I'll be frank with you, my preparation TATE REPORTING SERVICE, (713) 222-7177
30 1
for this interview today was in the QA area, not in the 2
other areas, that's why there was a little bit of a prob 1cm 3
in trying to translate back to B --
4 A
Recollection, and nothing more.
In regard to the 5
QA' modules, up until either '79 or '80, and I'm not i
6 completely clear on the date, the 25.12 manual chapter, 1
7 insofar as as post CP was concerned, only had 35200 in it.
8 Now, 35100 was imbedded in many other procedures.
9 But you don't, you didn't report 35100 per se on the 766, 10 at that point.
Now, when these newer manual chapters came 11 out, it had only been about a year, perhaps a year
]
12 and-a-half, since 35200 had been done.
And looking at it
]
13 in retrospect, like 35060, which in part goes into the same.
i 14 things that 35200 did, rather more thoroughly I might add, l
15 35200 wasn't a very good procedure, I might add; it was i
l l
16 just what we had.
17 Now, at that point in time, 1979, 1980, 1981, i
18 South Texas was consuming almost all of the regional 19 resources that 'nron't dedicated to the resident prcgram.
l 20 Now, the regional management has the-21 responsibility to decide with the finite resources they 22 have where they're go'ing to concentrate them to do the most f
23 good.
And at that point in time, Comanche wasn't the 24 place.
It was here.
25 Q
okay.
So it was priorities that dominated at TATE REPORTING SERVICE, (713) 222-7177
31 l
l 1
that time?
2 A
Manageme~nt priority, that!s correct.
Now,'by 3
'82, as an example, early in '82, the hearings started up.
4 Management plus ELD nominated me to be the principal 5
spokesman at the hearings.
And from 1982 until 1984, i
6 hearings plus allegations were about all of the inspection 7
I did.
8 0
okay.
9 A
I did very little other than that.
And if you 10 look at the reports in '82, you'll see that t' hey got i
11 further and further and further apart to the point where 12 almost a year was captured in one of them.
{
13
'Q Okay.
George?
I 14 A
And most of that was allegations.
l 15 0
(By Mr. Mulley)
Okay.
16 MR. GOLDBERG:
Thank you, very much.
17 A
Management priorities.
Okay?
18 MR MULLEY:
Yeah.
That's all we had.
I i
19 appreciate your time.
i 20 (Statement recessed at 4:30 p.m., C.D.T.)
21 I
22 l
23 l
[
24 25 l
TATE REPORTING SERVICE, (713) 222-7177
32 1
THE STATE OF TEXAS:
2 COUNTY OF HARRIS:
3 4
I, R. Patrick Tate, CSR #1730 and Notary Public in and 5
for the State of Texas, certify that the facts as stated in 6
the caption hereto are true; that the proceedings indicated 7
were had before me, and the same were thereafter reduced to 8
typewriting by me or under my direction.
9 I further certify that the above and foregoing 10 transcript as set forth in typewriting is a full, true and 11 correct transcript of the proceedings had at the time 12 indicated.
13 In testimony whereof, witness my hand, this 23rd 14 day of July, 1986.
)
f.
15 16 17 My Business address is f rh
~
s 1712 Esperson Buildings
- h. Patrick Tat 5, CSR #1730'"
i
~
18 Houston, Texas 77002 Notary Public in and for My current certification the State of Texas 19 expires: 12-31-86 My Commission Expires: 10-27-89 i
20 l
l 21 L
22 f
23 24 25 TATE REPORTING SERVICE, (713) 222-7177
TECHNICAL REVIEW OF PHfLLIPS' ISSUES l
CONTAlntu In tumAncMt PLAK INbPELildh" REPORTS INTRODUCTION This is a technical review of the issuer contained in inspection reports 85-07/05, 85-14/11, and 85-16/13.
The review of these issues should provide input to address the following PHILLIPS allegation:
" Region IV management harassed and intimidated inspectors to pressure d
them to change or delete proposed inspection findin downgrade proposed inspection violations at CPSES."gs and to change or
- is c 1hting of 34 technical issues that were included in l
PHILLIPS' draft inspection reports and were discussed with Region !Y pebson-nel, principally WESTERMAN, during OIA interviews.
In addition, the technical issues applicable to inspection reports 85-14/11 and 85-16/13 were listed in a j
matrix that was prepared by PHILLIPS to point out which of his proposed violations were changed, downgraded or deleted by Regional management.
1 However, for the purpose of this review, only the 16 technical issues that were specifically raised by PHILLIPS during his March 19, 1986, interview with 0!A were reviewed (see underlined items in Attathment 1). A review of 16
(
issues should provide an indication of how PHILLIPS and Regional management J
generally addressed technical problems at CPSES. It is unclear whether the 1
sremaining 18 issues $re specific concerns that PHILLIPS wanted 0!A to address.
If they continue to be concerns to Mr. PHILLIPS, it is suggested i
that a technical ' team composed of non-Region IV inspectors be utilized to i
review the remaining issues.
l This review will address how the issue was origina11ygtate(lo include the in the draft inspection reports; the rationale used by PHILLIPS or 2 c -
finding or violation; the rationale used by Regional Mirfiiteisikat to change.
i l
delete, or downgrade.the finding or violation; and conclusions that could be made based on a review of the testimony presented by both parties and a review of 7U6C0 documents.
1 It should be understood there are limitations on the reliability of the l
testimony received by 01A and supportinq evidence because it is unclear whether this evidential matter was deve' o Ht5 during the inspections, shortly I
after the inspections, prior to issuing tie inspection reports, or just prior to 01A's meetings with the parties.
1 l
Attachment MM I
e i
I 2
1 REVIEW INSPECTION REPORT 85-07/05 Concerns No. 1 and No. 2 PHILLIPS was concerned that Region IV management downgraded the following design control-related violation to an unresolved item:
" Contrary to 10 CFR 50, Appendix B, Criterion III, and TUGC0 QA Plan, dated July 31, 1984, (a) Unit 2 reactor pressure vessel installation design criteria recommended by the nuclear steam supply system (NSSS) vendor, such as centering tolerances, levelness tolerances, and shoe to bracket clearances, were not included in installation specifications, procedures, and drawings; and (b) the criteria were specified in Construction Operation Traveler ME-79-248-5500, but were not treated as design engineering criteria as evidenced by an undocumented change of shoe to bracket clearances (page 3 of the NOV, item #6)."
j According to the draft inspection report, the inspector reviewed a series of drawings, which were referenced in the reactor pressure vessel operation traveler to verify implementation of Westinghouse Nuclear Services Division (WNSD) recommendations.
These recommendations concerned placement requirements for the reactor pressure vessel established to ensure proper
, fit-up of all major NSSS equipment.
According to this draft report, the l
' inspector found neither site-prepared installation drawings nor specifications were a'vailable and the referenced drawings did not show cer.tain specific installation criteria sucb as centering tolerances, level tolerances, and clearances between support brackets and support shoes. The inspector reported that this lack of engineering documentation did not provide full control of the action and would allow installation changes to be made without complying with established design change procedures.
Related to the above, PHILLIPS was also concerned that Region IV downgraded the following violation to an unresolved item:
" Contrary to 10 CFR 50, Appendix B, Criterion XV and TUGC0 QA Plant dated May 21,1981, and Brown and Root Quality Assurance Manual Section 16, dated March 27, 1985, clearances between the reactor vessel support brackets and support shoes were not within the tolerance stated in Construction Operation Traveler ME-79-248-5500 and the condition was not reported on a Nonconformance Report."
According to the draft inspection report, the inspector found that the clearance between the support bracket and the support shoe had been changed for the reactor vessel installation even though the installation data reflected in the traveler that controlled this activity exceeded both the original and revised tolerances (this traveler implements requirements, including the tolerances for centering and levelling the reactor pressure vessel, which are recomended by Westinghouse). TUGC0 did accept this condition, based on a Westinghouse concurrence. However, there were neither
i nonconformance reports nor documented evaluations to determine if the condition was accep%able.
i Underlying both issues, but not included in the inspection report, PHILLIPS stated in a referenced document that the process traveler system appears to his far too casual for controlling the setting of critical NSSS components.
According to PHILLIPS, this system allows great latitude to the engineers who do not have to reference an engineering evaluation or a desigo chagpe au' theorization. Also 0!A viewed documentation prepared by Jon this 3
issue. PHILLIPS and(,,~
elieve the TUGC0 traveler for the reacYor vessei
~
should not substitute ior more formal document control and design control process, including the use of design change notices when design specification changes are prepared.
After a series of Regional management reviews, the final report identified these issues in the following way:
"Neither site prepared installation drawings nor specifications (which implemented the WNSD recommended procedures) were available and the drawings examined did not show certain specific installation criterion such as centering tolerances, levelness tolerances and clearance between support brackets and support shoes. The inspector considers this matter l
unresolved. The installation data reflected in attachment 3.B. of the traveler indicated an as-built clearance of 0.012 to 0.026 inch which i
exceeds both the original and revised tolerances. This condition was accepted on the traveler based on Westinghouse concurrence, and there was no documented engineering evaluation onsite justifying the final tolerances. This matter is considered unresolved pending documentation o
validating the final installation tolerances."
OIA was told that the need and rationale for Re ional mariagement to make such a change were strongly influenced by Mr. HAUGHN Y, an.NRR consultant, who was l
l charged to review Region IV draft reports on CPSES. HAUGHNEY was employed by i
NRR to provide a broad perspective of inspection findings, based on tis knowledge of the inspection report's impact on the ongo< ng ASLB hearings.
HAUGHMEY told OIA that, based on his experience, he thought the-traveler i
written to install the reactor vessel could have been a very explicit instruction for construction activities, although he never ins sected the traveler itself. Consequent 1y' he raised his question to WEST ERMAN.
ifESTERMAN concurred with HAUGHNEY's question about the violation concerning the installation design criteria because WESTERMAN believed that the traveler was a controlled instruction, that the Westinghouse representatives concurred on these changes, and that changes to installation requirements does not require a formal design control review with accompanying signatures.
In addition, WESTERMAN d'd.not agree with PHILLIPS concerning the writing of a nonconformance report for changes to clearances stated in the traveler (i.e.,
clearances between the ) tactor vessel su) port brackets and support shoes),
since the traveler could be changed in tie field according to the plant procedure for the preparation, approval and control of operations travelers.
Thus, it appears that the Regional management not only believes neither of these issues are violations, but also they question whether they are findings 4
1 l
at all. The Regional management only reports them as unresolved items to demonstrate to PHILLIPS the Regional managenent did not avoid any issues.
i Technical Evaluation of These Concerns
)
The following documents were considered in reviewing both issues:
l 1.
Plant Procedure Concerning the Preparation Approval, and Control of Operations Travelers, CP-CPM 6.3., Rev.11.
2.
Reactor Vessel Installation Traveler, Traveler No. ME-79-248-5500, 3/20/79.
l 3.
General Reactor Vessel Setting Procedure. Westinghouse Nuclear Service Division, Rev. 2.
i 4.
Letter from R. S. Howard, Westinghouse, to J. T. Merritt, TUGCO, Accep-tance of Unit 2 Reactor Vessel Support Shoe Side Gaps.
According to 'the above )rocedures, TUGC0 considered the operation traveler to I
be an installation checclist so as to achieve a quality and product in an officient manner. As an installation checklist, the traveler should pmvide j
sufficient information for plant staff to perform its duties in concert with their training and work experience. The details of a traveler or installation checklist vary and depend on the complexity of the job. Because TUGC0 does i
not -use a standard traveler, the Region would have had to inspect each individual traveler to determine its adequacy. This installation traveler is over 20 pages long, has several instructions, and has attached to it a series I
'of data sheets and drawings. Further, the traveler, according to procedures, is to include all dimensions and tolerances necessary to assure compliance to
~
design drawings and specifications; and, when design changes are received that af'ect issued and approved travelers, the applicable changes will be made to l
the traveler and it will then be reviewed in the same manner us the original issuances. This installation traveler does specify dimensions and tolerances, and does indicate that when changes were made personnel from the technical and QA/QC groups did initial such changes. However, it cannot be determined if all the required tolerances NRC were specified and if all the requirements of i
the design change process were also satisfied.
Both parties do agree Westinghouse, the NSSS supplier of the reactor vessel, approved the design changes in question.
In fact, the Westinghouse letter acknowledges its approval of the design changes proposed by TUGCO.
l Based on the foregoing, CIA believes that none of the parties acknowledge that a hardware problem resulted when the changes were made in tolerances during i
the reactor vessel installa philosophy than PHILLIPS o
~on.
nstead, Regional management has a different bout whether the traveler can be used as a l
d2 sign control document,
~ ute'o the way it is used at CONANCHE PEAK.
Thus.-withouta.fomal design control' process in place at COMANCHE PEAK, PHILLIPS andL Delieve that the plant is in noncompliance with Appendix i
8; Regional innagetEent disagree, i
s I
5 Conclus' ion For These Concerns It is inconclusive whether a violation or a finding is appropriate to be included in the inspection report for these two issues, because it cannot be determined if the TUGC0 traveler system may substitute for a formal design control process.
If the Region believed that neither issue warranted to be reported as a finding, both issues should have been deleted from the final report and not just be included as unresolved items.
This practice is contrary to the requirements in Chapters 0400 and 0610 of the IE Manual for f
the reporting of findings and potential enforcement action.
In addition, i
prior to making its dec'sfon to downgrade PHILLIPS' violations, the Regional j
manageme'nt should have reviewed:
(1) the actual traveler; (2) the procedure q
for preparation, review and approval of travelers, and (3) the Westinghouse i
design specification for the Reactor Pressure Vessel Installation. Regional management is responsible to connunicate technically competent findings and appropriate actions the Region and/or the utility are planning to take to address findings in NRC inspection reports.
Concern No. 3 PHILLIPS was concerned that Region IV management downgraded the following audit-related violation to gn unresolved ites:
" Contrary to 10 CFR 50l Appendix B, Criterion XVIII and TUGC0 QA Plan Section 18.0, there was no evidence that TUGC0 had audited either Unit 2 reactor vessel installation specifications, placement procedures, actual hardware placement, or as-built records."
a According to the draft inspection report, the inspector requested TUGC0 QA audits or surveillance perfomed by TUGC0 of the Unit 2 reactor pressure vessel (RPV) installation. TUGC0 did not make available to the inspector any audit or surveillance reports of specifications for placement criteria, placement procedures, hardware placement or as-built records.
1 Underlying this issued impitcations of this finaing kptated in a referenced document that the generic i.e.
inadequate implementation of the QA audit and/or surveillance program concern,ing RPV placement activities) are extremely significant, indicating L pote equipment installation. (,l ]gial QA program breakdown concerning stated that:
"The licensee apparently did not ensure adequate audits and/or surveil-lance during the placement of the RPV anti it is not likely that such adequata audit and/or surveillance activities were provided during the placement of other safety-related equipment at CPSES."
After a series of Regional management reviews, the final report identified this as a finding in the follow' ng way:
"TUGC0' did not make available any documentation of an audit or surveillance which evaluated specified placement criteria, placement procedures, hardware placement, or as-built records. This item is unresolved pending a more comprehensive review of these activities."
6 WESTERMAN and BARNES told OIA that the utility is not required to perform an audit in this area. WESTERMAN also stated that, in general, the effectiveness of such audits would be very questionable; audits don't always catch every-thing; and, if TUGC0 made some minor changes to their surveillance for the 1
installation of the vessel, they could have made an audit out of it.
- However, j
OIA asked WESTERMAN if he had PHILLIPS check TUGC0's audit plan when PHILLIPS proposed this violation. WESTERMAN told 0IA that he did not know whether the audit plan was adequate and did not have PHILLIPS pursue this issue.
In any case, he included this finding in the inspection report as an unresolved item to demonstrate to the inspector that he did not avoid the issue.
Technical Evaluation of This Concern OIA reviewed the general requirements for audits, including the specific activities and equipment to be specified in an audit plan.
According to the ANSI Standards (ANSI N45.2.11 and N45.2.12), the audit plan identifies the audit scope, particularly, the functional areas to be audited and the extent of the audits within these areas.
The regulations (10 CFR 50, Appendix B,
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Criterion XVIII) only address the need for a comprehensive system of planned and periodic audits. The inspector would have to refer to the audit plan to determine:
(a) if the vessel installation activity was included but was not accomplished; (b) the adequacy of the audit plan itself; (c) and whether the system of audits or surveillance implemented by TUGC0 satisfies Appendix B.
j In the absence of such a review, none of these determinations could have been made.
Conclusion For This Concern 3
Based on the available information, it is inconclusive whether a violation is appropriate for this issue, because the inspector would need to review the audit plan to ascertain the licensee's compliance with the regulations and/or q
its conformance with the ANSI standards. Therefore, until the Region j
accomplished this, the issue should have been and, correctly, was considered
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unresolved.
(This finding might have been resolved quickly had WESTERMAN j
instructed PHILLIPS to look at the audit plan.)
The rationale used by i
Regional management to include this issue as an unresolved item was not based
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on any further NRC action, including the review of the audit plan. This practice is contrary to the requirements in Chapters 0400 and 0610 of the IE Manual for the reporting of findings and potential enforcement action, i
Concern No. 4 PHILLIPS was concerned that Region IV management dropped the following traceability-related violation:
)
" Contrary to 10 CFR 50, Appendix B, Criterion VIII and TUGC0 QA Plan, Section 8.0, Revision 0, dated July 1, 1978, and Article NA 3766.6 of ASME,Section III, 1974 edition, spool piece 3Q1 (DWG No. ERP-CS-2-RB-76) had neither been marked with the material specification and grade nor heat number nor heat code of the material."
According to PHILLIPS' testimony, a mark identifying the spool piece number i
anc' drawing number was found by TUGC0 several months after the conclusion of
7 the inspection. He questioned whether this was an appropriate practice considering that the final repo' t did not state that the identification number r
was located months after the initial drafting of the report, After a series of Regional management reviews, the final report did not identify this as a finding and stated the following:
"The installed spool-piece was inspected for weld quality and to verify that marking and traceability requirements had been met. The item had been marked with the spool piece number (3Q1) and the. Brown and Root (B&R) drawing number which provided traceability to the material certification."
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Both WESTERMAN and BARNES stated that the inspector rechecked the spool piece and found t marking on the spool piece that provided sufficient identifica-tion. BARNES stated that, according to the ASME code, a mark number was sufficient and there was no requirement to maintain specific design specifica-
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tions, graded material, and heat number or heat code, because the spool piece wa,s part of a piping subassembly that could be traced back to the vendor and the vendor's processes. It is questionable whether BARNES' argument was used a
by the Reqional management while changing and finalizing the inspection report.
Et is unclear whether the piping subassembly identification was a i
factor considered by the Regi6n whyn accepting the spool piece number and the
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drawing number, because the final report does not mention piping subassembly
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traceability at all.
i Technical Evaluation of This C5ncern i
'This technical evaluation is meant to address the adequac of TUGC0's
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traceability of the spool piece but not to address the ti nest of finding l
any marking on the spool piece. According to a referenc
.. document, i
this part of the inspection was to verify.that the licens Ophattices
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regarding identification or traceability by means of markings was in accordance with ASME code requirements and Criterion VIII of 10 CFR 50,
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Appendix B.
Appendix B states that identification and control measures should i
be designed to prevent the use of incorrect or defective material, parts, and equipment. It was not reported in the draft or final inspection report that there was any use of a nonconforming spool piece. Further, the licensee generally establishes an appropriate program to control traceability at the plant, whether at the subcomponent, component, or system level, at which point specific design, manufacturing, and procurement infomation is included.
Neither the regulations nor the code are prescriptive about the type of item that needs to be traced. If the spool piece needed to have sufficient identification (heat number, design, specifications, etc.), then a marking that did not contain all the requisite traceability data would not have been sufficient to comply with the regulations.
Conclusion For This Concern Based on the available infomation, it is inconclusive whether a violation is a ppropriate for this issue. Even after a mark was found, its is unclear wwther it provided sufficient traceability that is required to be in compliance with Appendix B; however, licensees generally are given latitude on i
establishing an appropriate level of traceability..The matter of finding a
1 I
8 l
r.a-king on the spool piece after the initial drafting of these inspection l
re sort and including it in the final report is an inspection policy issue and net a technical issue.
Cercern No. 5 PH:LLIPS was concerned that the Region required no response concerning the violation (in the Notice of Violation for Inspection Report 07/05) for the failure to document or provide record evidence that the cement mixing blades had been inspected quarterly since 1977.
PHILLIPS believed, even though this was not a hardware problem, it was a QA/QC problem that should have been addressed.
In the draft inspection report, the inspector did acknowledge that:
(1) the vendor representative stated that the mixing blades were periodically inspected and laboratory testing would have probably indicated if there was a problem with the mixing blades; and (2) strength and uniformity tests have consistently been within the acceptable range indicating that concrete production was acceptable.
However, PHILLIPS stated that, without a TUGC0 response, TUGC0 did not have to look into the issue and determine what the cause of the problem was to preclude repetition.
He believed that it was possible that other inspections, required by procedures, were not being documented.
In the Region's letter dated February 3,1986, forwarding this inspection report, it stated that no applicant response to this violation was necessary because (1) the procedure had been revised to provide documented inspection of the blades, (2) no abnormal blade wear had been identified, and (3) there had
@een consistent concrete strength and uniformity tests.
The Region received comments from HAUGHNEY, the NRC consultant, who did not believe inspection time should be expended in this area at this late date.
The Region took HAUGHNEY's opinion and changed the language in the Notice of Violation, based on the rationale, that: (1) the concrete work at CPSES during this period appeared adequate, and (2) inspections were periodically s
conducted.
However, HAUGHNEY and the Region never reviewed or asked the inspector to review other areas that required QC documentation.
Technical Evaluation of This Concern i
f All parties agreed no hardware problem resulted from the lack of documentation
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l cf inspections. The only issue is whether TUGCO's inspections of quality I
activities are not documented in other quality areas.
The inspectors provided no evidence to support this hypothesis.
Therefore, it was not necessary for the licensee to respond to the violation.
Conclusion For This Concern Based on the available documentation, it appears there was no need to include larguage in the Notice of Violation to require an applicant response to the violation involving a lack of documentation of inspections of mixer blades.
l However, the Region should consider possible QC documentation problems in l
future NRC inspections.
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9 l
INSPECTION REPORT 85-14/11 Concerns No.1, No. 2, and No. 3 PHILLIPS was concerned that Region IV dropped the following records related violations concerning the shipment of Stone and Webster Engineering Corporation (SWEC) records offsite:
" Original design records shipped in cardboard boxes without making backup Copy."
" Failure to. control and account for QA/ design records transferred from site to SWEC."
"TUGC0 failed to have/use procedures to control shipment of original records to SWEC."
According to the draft inspection report, the inspector was concerned about whether procedures existed to control such shipments, the number of records per package, and how the records were protected from possible hazards during shipment. The inspector found such shipments had been controlled by a TUGC0 j
procedure but the procedure had been deleted. These records were the original i
. calculations, including the calculation checklist, for pipe support work on such items as Hilti bolts.
The inspector stated that these records while enroute were not afforded the minimum protection which was required for the l
oyears those records were on site, i.e., they were shipped in cardboard containers which do nat meet the site's temporary storage requirements of a two hour fire-rated container. The inspector also repo.rted that TUGC0 did not i
inventory the shipment, including the number of records shipped.
PHILLIPS believed, according to the testimony, this is contrary to the requirements in Appendix B for records storage and ANSI N45.2.9 regarding the storage of records in an approved fire-rated vault.
After Regional management review, the final report was changed to reflect the following violation:
" Criterion V of Appendix B to 10 CFR Part 50, as implemented by TUGC0 QAP, Section 5.0, Revision 3,' dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
"Section 17.1.17 of the Final Safety Analysis Report, Volume XIV, Amendment 50, dated July 13, 1984, connits to procedures requiring that records be controlled and accounted for during transfer between organizations."
" Contrary to the above, original sole copy design records were ascertained on October 16, 1985, to have been shipped to Stone and Webster, New York, without the establishment and implementation of procedures that address required control and inventory measures."
L____._._________
The Regional management essentially took the three violations proposed in the draft report and developed one ' violation associated with the use and estab-lishment of procedu-es to control the shipment of records offsite.
The Region believed that ANSI N45.2.9 did not clearly address PHILLIPS' other issues.
Even though Region IV management did not consult with TUGC0 on this issue, WESTERMAN and HALE considered the SWEC documentation to be in-process documents and not records, since they were design calculations that were being i
sent to SWEC's engineering offices for reanalysis. Also, HALE told 0IA that j
these records, if removed from the vault, are no longer records; they become j
in-process documents and are not subject to the same kind of controls that are required by ANSI N45.2.9 or Criteria XVII.
However, it is questionable this fact was considered by the Region, sir.ce this was not mentioned in the final inspection report.
Technical Evaluation of These Concerns A review was conducted of the records requirements of Appendix B (Criterion XVII), ANSI N45.2.9, Section 5.3 and the letter from W. E. Counsil, TUGCO, to j
E. H. JOHNSON concerning TUGC0's response to the violation involving the i
failure to follow established procedures.
Appendix B does not specifically address the control of records in transit.
The ANSI standard does specify the following:
"...a written storage procedure shall be prepare d... This procedure shall include...a method for maintaining control of and accountability for records removed from the storage facility."
This ANSI standard is similar to the requirement in the FSAR and the TUGC0
' Quality Assurance Plan concerning the establishment and implementation of such procedures. Regional management determined that the issue was a procedural problem and was able to establish a Level V violation.
If the Region had chosen to demonstrate that TUGC0 did not conform to this ANSI standard requirement, the Region likely would not have been able to establish a violation but rather only establish a deviation for this issue.
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In addition, TUGC0 responded to the violation, by stating in a letter that the following corrective action was taken:
" Measures to establish compliance with TNE procedure TNE-AD-4 and subor-dinate THE instruction TNE-AD-4-6 (issued specifically for transmittal e
and duplicate retention of pipe support calculations) have been imple-mented for pipe support records previously forwarded to SWEC. These efforts, involving the return of copies and complete accountability, were completed in February 1986."
"TNE-AD-4-6 was issued November 25, 1985, establishing a program for transmittal requirements for pipe support design records.
In addition.
TNE-AD-4 will be reviewed and revised, if required, to assure the adequacy of measures prescribing the offsite transmittal of engineering documents."
Based on a review of this, TUGC0's corrective actions appear adequate to respond to PHILLIPS' concerns.
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j Conclusion For These Concerns l
It appears that one violation involving Criterion V of Appendix.B was e
appropriate to address PHILLIPS' three issues.
In addition, following issuance of this violation, the Region was able to achieve effective 1
corrective action. However, some of the reasons provided to 0IA by Region IV j
personnel to respond to PHILLIPS' concerns appear questionable.
For example, i
the SWEC calculations should be considered design racord*, and not in-process documents, even through SWEC is planning to reanalyze these calculations.
Because the Region did not include the issue of in-process documents in the final inspection report, it appears this document-versus-record issue was not considered by the Region at the time the violation was imposed.
Concerns No. 4 and No. 5 PHILLIPS was concerned that Region VI management downgraded the following record-related violations to an open item and to an unresolved item:
" Site records of Chicago Bridge & Iron (CB&I) work shipped to Houston in cardboard boxes. Originals subjected to little protection without retaining back-up copy at site."
"TUGC0 failed to inventory CB&I records sent to Houston.
Therefore, cannot determine records that must be returned."
'The draft inspection report indicated that the inspector requested records pertaining to the Unit 2 reactor containment liner and mechanical penetrations but was informed that they were not available on' site because they had been shipped to CB&I, Houston, Texas, to be copied.
As a result, in October 1985, 1
I the NRC inspector reinspected the CB&I records transmitted and found that the original construction QA records were transmitted to Houston, Texas, without retaining a copy. The NRC inspectors interviewed the TUGC0 civil engineering l
project contact and Brown and Root subcontract supervisor to determine if the CB&I records were transmitted in accordance with a TUGC0 procedure because he believed that these records, although in the custody of CB&I, were site records and belonged to the owner. Removal from site should have been authorized and controlled by TUGCO. The NRC inspector also asked how these q
records were shipped and if a method of accounting for these records were 1
described in TUGC0 procedures.
No TUGC0 procedure was jdentified and there was no record of a detailed inventory list or accounting for records transmitted.
Region IV management reviewed this information and decided to revise the finding in the following fashion:
I "As a result of knowledge of an earlier shipment of CB&I records off site, the NRC inspector has asked the utility to provide records to demonstrate the CBal record controis that were implemented.
It is CB&I's practice to ship all records off site for copying. This matter is l
considered unresolved."
I
1 12 "The utility has indicated that the receipt of records from CB&I was handled in the same manner'as the receipt of records from any vendor.
Region IV will inspect the receipt of vendor records and this matter is considered an open item."
The inspection report acknowledges, similar to what DIA was told, that Region IV was pursuing with IE Headquarters, QA Branch, the minimum protection that should be afforded records in shipment.
In any case, WESTERMAN and HALE also told OIA that TUGC0 was not directly responsible for these records control practices, because TUGC0 had delegated the records control practices as well as other QA practices to CB&I, similar to any contractor or vendor who works for TUGCO.
In addition, WESTERMAN told OIA he considered these documents not as records even though he did not consult with TUGC0 on this matter. However, it is questionable this fact was considared by the Region, since this was not mentioned in the final inspection report.
Technical Evaluation of These Concerns According to Criterion I of Appendix B, "The applicant shall be responsible for the establishment and execution of the quality assurance program.
The applicant may delegate to others, such as contractors, agents, or consultants, the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility therefore."
Based on the above, TUGC0 had a continual responsibility to monitor how CB&I was controlling its records for the container liner and penetrations.
If the erecords were not properly controlled, then TUGC0 had the responsibility to require corrective action on the part of CB&I.
ANSI N45.2.9-1979, Section 5.3., as reported earlier, does require that the utility establish a procedure to control and account for records removed from the storage facility.
It is unclear, based on the available documentation, if the inspector made such a determination.
It appears the Region is not F
following up on this issue.
Even if CB&I did not have a procedure, the Region could only issue a deviation not a violation, because the utility did not violate a regulation but instead, was in nonconformance with an ANSI standard.
Conclusion For These Concerns l
Based on the available documentation, it appears no violation should be imposed for the CB&I issues that PHILLIPS had found during this inspection.
However, the Region's management's reasoning not to cite TUGC0 appears questionable, because they failed to consider that TUGC0 had continual responsibility for the records,-in accordance with Criterion I of 10 CFR 50, Appendix B.
In addition, the Regional management should have had the inspectors follow up on whether TUGC0 was not conforming to Section 5.3 of ANSI N45.2.9-1979 regarding the establishment of procedures to control and account for such records.
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Concern No. 6 l
PHILLIPS was concerned that Region IV management downgraded the following
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records-related violation associated ~with TUGCO's Paper Flow Group:
l
" Failure to provide temporary or;pemanent storage facility for records comingled with in process documents ir. Paper Flow Group."
According to the draft inspection report, NRC inspectors inspected tle Paper Flow Group storage facilities and dettmined that a large number of trechandal and electrical records had been removed from the permanent storage crea and had been placed in paperflow packages which were stored in non-fireproof cabinets.
Previous NRC inspections in this^ area documsnted isolated cases t:here QC records were found in these packages.
However, during this inspection it became clear. that.large numbers of all tyocs of construction QA records were stored in those files. The Paper Flow Group. personnel stated that records of component installation were stored in thase non. fire-rated cabinets; i.e., completed records such as steam generator records / packages and QA records for other systems, without a backup copy in a separate and remote locaticq.
The Regional management downgraded this proposed violation 20 unresolved, as was stated in the final report,:
...In SSER No.11, the TRT corisid2 red the documents in the paper flow groups to be inprocess; however, SSEo No.11 also irdicated thht the records are maintained in firl-proof cabinets. The, NRC inspectors found that there are some records stored in non-fire-rated file cabinets. This matter is considered unresolved."
I WESTERMAN told OIA that he relied on HALE's group (who were part of'the TRT I
team) to resolve this issue and in his op'nion, it was the same issue as was resolved in SSER-11. However, HALE said SSER-11 did tot apply in this case.
In addition, according to HALE, TUGC0 has hud a procedure that states when-l records are taken from the vault and returned to paperflow, they should be taken off the records index... He told 0IA tnat records taken out of permanent storage, in his opinion, should be classified as documents not subject to the preservation requirements of ANSI N45.2.9.
Technical Evaluation of This Concern i
Appendix B does not provide, specific requirements for preservation of records.
l The ANSI standard does not provide guidance on how to differentiate an in-process document from a final record. The ANSI standard dees state in 5.4.12:
...those records stored within a temporary storage f aci$ity shall be afforded preservation by use of fire resistant cabinets."
lt is unclear whether tb fil'e cabinets in the paper flow group areas are con-sidered a temporary storage facility.
In addition, based on a reviet of SSER-11, the issue considered in the SSER was a different one because it
[
involved documents that b.d never been placed in permanent storage.
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Co_nelusioq For This Concern It appears that no violation should be imposed. based on this finding.
It is incor.clusive whetha-a deviation is warranted,-because the requirements in ANSI N45.2.9 are r Icar.
Regional management should be communicating directly or thr~.gn IE to the ANSI board to provide advice on this matter - In-cddition, references made to SSER 11 in' the final report are irrelevant, because documents in the paper flow group mentioned in the SSER had not been eritered into permanent storage.
I INSPECTION REPORT 85-16/13
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Concerns No. 1, 2, and 3 l
1 PHILLIPS was concerned that Region IV downgraded a series of potential vi~ola-tions involving TUGCO's system for controlling 50.55(e) documentation to l
unrtsolved items.. According to the draft inspection report, these potential
)
violatic.ns includ6d the following:
J 1
r TUGC0 fsiled to develop / implement a procedure to show or reference I
objective evidence that deficiencies were corrected.
TUGC0 failed to revise implementing procedures before corporate NEO I
Procedure CS-1 was implemented, resulting in conflict with five other procedures.
i TUGC0 failed to maintain 50.55(e) files (QA records) that were
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retrievable, i.e., could not produce record in almost a month.
PHILLIPS' issues originated from his and his contrace. ors' attempting to follow up the corrective action taken by TUGC0 on hardware it; the plant as the result of its filing of.50.55(e) reports to the NRC. Consequently, according to
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PHILLIPS, they cauld not perfonn the inspection of the applicant's corrective action involving the 50.55(e) reports.
Regional management reviewed the issue together with other issues involving the 50,55(e) files and reported the following in the final inspection report
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as-Unresolved items:
"The NRC inspectors evaluated corrective action taken on reportabit i
deficiencies by reviewing TUGC0 deficiency reports. The inspector found no corrective action completion date for CP-84-29, HVAC Fire Scenario.
It was noted that corrective action for deficiency CP-84-27, Ventilation Exhaust Dampers, was to be completed for Unit I by September 1985 and for Unit 2 before startup testing. However, as of November 30, 1985 Unit 1 deficiencies were r.ot corrected and it was not clear how corrective action for Unit 2 will' be tracked.
Deficiencies CP-85-13 and CP-85-05, which are described in deficiency reports and the open items list, also give no corrective action dates."
15 "Several final 10 CFR Part 50.55(e) reports contained corrective action completion dates; however, work was neither completed by the reported date nor was a supplemental report made to the NRC to report on significant corrective action date changes.
Deficiency report for l
CP-84-31, ' Control. Room Separation Wall,' stated that corrective action was scheduled for completion by December 15, 1984; however, it was not completed as of November 30, 1985. Similarly, deficiency reports for CP-85-11, 'In b Tent Fitting Locations,' and CP-85-12, ' Auxiliary Feedwater Pressure Control,' stated that corrective action was scheduled to be completed for Unit 1 by May 1985. The open items list indicated that they were not completed on November 30, 1985."
^
JOHNSON and WESTEfAAN told 0!A that both of them realized there was a problem with the utility's handling and control of 50.55(e)'s, that both of them met on site with the utility to discuss the problem, and that the utility comunitted to establish a task force to put the 50.55(e) records in order; this latter point was referred to in the final inspection report.
WESTERMAN told CIA, however, that there are no requirennts in the regulations for identifying the time frame to retrieve the 50.55(e) ' documents, there was no urgency for these recordt since a decision on an operating license was not pending, and the procedures that' implement 50.55,(e) reporting requirements do not fall under Appendix B.
JOHNSON admitted that TUGCO's record system was somewhat archaic and confusing but that the utility could retrieve a record, if the right person was contacted.i T_echnical Evaluation of These Cone' erns oIn the process of performing a technical evaluation, the following plant documents were consulted:
1.
TUGC0 Procedure NE0 CS-1, Rev. C. " Evaluation of and Reporting of Items /EventsUnder10CFR21and10CFR50.55(e),11/1/85.
2.
TUGC0 Procedure, CP-QP-16.1, Rev. 6. "Significant Construction Deficiencies,' 1/16/85.
3.
TUGC0 Procedure CP-QP-15.6, Rev. 3. "SDAR Status Tracking " 1/16/85.
4.
TUGC0 Nuclear Engineering Procedure TNE-AD-5, Rev. 5. " Identification of l
Design Deficiencies and Errors," 9/3/85.
x.w 5.
Letters Clement, TUGC0, to NRC,50.55(3) Reports:4/15/85 CP-85-13, SDAR-173, CP-85-3 Isb -73), and CP-55-12 (SDAR-173); and 4/10/85, CP-85-11 (SDAR-173).
Concerning the first two PHILLIPS' concerns, it appears that NE0 CS-1 is TUGCO's administrative procedure for the evaluation of and reporting of items under 10 CFR 50.55(e). The other three procedures implement the administra-tive procedure at Comanche Peak. All of these procedures are QA-controlled procedures. During a review of these procedures, it was detennined there are some inconsistencies in areas such as the responsibilities of plant and i
corporate staff to evaluate and detennine the deportability of construction deficiencies and to serve as the point of contact with the NRC.
It is understood by the utility that those deficiencies exist, and TUGC0 is
i i
16 currently implementing corrective action.
However, on the basis of the version of the procedures that were available to the inspectors at the time of the inspection, it is likely these procedures would not have satisfied the QA requirements in the document control section of TUGCO's QA program, which implements Appendix B, In the absence of a review of TUGC0's QA program, this could not be determined.
Regarding the third PHILLIPS concern, TUGCO's 50.55(e) files could be con-sidered, essentially, part of its nonconformance file system.
In addition, the ANSI standards provide guidance for the retrieval times for such documents or records. Control of these files is subject to the controls placed on all nonconformance documents and records.
For example, THE-AD-5 addresses control of TUGC0 design deficiency reports.
However, in the absence of a complete review of the control of TUGCO's nonconformance documents and records, it could not be determined whether TUGC0 satisfied the nonconformance section or the records section of its QA program, which implements Appendix B.
Conclusion for This Concern Based on the available information, it is inconclusive whether a violation is j
appropriate for those issues because:
l 1.
the inspectors did not establish whether the requirements in the QA program for document control, records control, nonconformance control had not been satisfied; and 2.
.the inspectors did not provide a regulatory basis for determining that lengthy retrieval times of 50.55(a) files are a noncompliance.
Although PHILLIPS' issues were identified in the final inspection report as unresolved items, OIA was.not told, and it was not reported, that any of the above actions were or are now being addressed by the Region.
Because of this, Regional management's actions in identifying PHILLIPS' issues as unresolved is contrary to IE manual requirements, identified in Chapters 0400 and 0610, for dealing with unresolved items.
Concern No. 4 PHILLIPS was concerned that Region IV management downgraded the following i
document control-related violation to an unresolved item.
"TUGC0 had replaced NAMCO switches per IEB 79-28, but two of 14 that were field inspected were not properly identified on installation traveler."
According to the draft inspection reports, the inspector found that the master data base, the travelers, and TUGC0 inspection documentation did not match the NAMC0 switches installed in the field.
Specifically, these were replacement NAMC0 limit switches on residual heat removal valves.
According to PHILLIPS' referenced documentation, two new travelers were presented a month later to NRC to show that (1) one of the NAMC0 switches was non-safety-related and, thus, not a concern of the NRC and (2) a later version of the traveler was found to have the correct identification number.
The inspectors also had a
17 concern why the travelers were not placed in the master data base or QA vault for more than a year after the travelers were completed.
After a detailed review, Region IV management changed this potential violation to an unresolved item, to allow TUGC0 to evaluate the inconsistencies with the documentation for NAMC0 switches and determine if there is other documentation to account for the inconsistency.
WESTERMAN provided 0IA copies of a TUGC0 l
nonconformance report and four travelers to substantiate that one of the switches was powering a non-safety-related system and, in the other case, the correct NAMC0 switch was obtained. However, WESTERMAN told 01A that he did not ask PHILLIPS or another inspector to expand the sample size to determine if other switches had documentation problems.
Regional management believed that, based on PHILLIPS' findings, no hardware problem was involved with this i
issue.
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Technical Evaluation of This Concern A review was conducted of the inspector's log for reviewing travelers and the portion of the IE Bulletin applicable to NAMC0 switches, the nonconformance report addressing the identification problem for travelers concerning NAMC0 switches, portions of TUGC0's audit response involving IE Bulletin 79-28, and internal TUGC0 documentation involving NAMCO switches.
It was learned that l-NAMCO switches were being replaced in the plant to confom to IEB 79-28, and the only issue is whether old or new switches were present. According tc the IE Bulletin, the old limit switches were defective because above 175'F their top cover gaskets emit a vesin vapor that condenses into deposits on the normally open contacts and thereby causes the switches to malfunction.
' Conclusion Based on the available information, OIA cannot determine if a violation should have been imposed in this' area.
The Region should have continued to review the area by expanding the sample size and determining the hardware implications.
It was identified as unresolved so that TUGC0 could locate the appropriate documentation.
Concern No. 5 PHILLIPS was concerned about potential wrongdoing by Brand Industry Services, Inc. (BISCO) in their certification of their design tests for fire seals.
l PHILLIPS recomend an 01 investigation and IE vendor inspection of the matter in two draft memoranda. PHILLIPS' management criticized both draft memoranda because Regional management considered them inflammatory. On April 4, 1986, Region IV management did refer PHILLIPS' concern to IE management; this was at least six months after the finding. Also, PHILLIPS had identified in his draft inspection report (85-16/13) issues involving the filing of a false report by BISCO, insufficient evidence of successful testing of BISCO fire seals; and potential violations involving the utility's failure to adequately evaluate and report a construction deficiency, per requirements in 10 CFR 50.55(e) and 10 CFR 21. The failure of Region IV to promptly consider PHILLIPS' concern as potential investigative matter was communicated by PHILLIPS to 01A.. However, PHILLIPS concern about downgrading violations and changing his findings concerning the BISCO seal problem was identified in his.
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matrix but was not addressed by PHILLIPS during his interview with OIA.
There might have been potentially safety significant issues that were dropped and changed in the draft report (those should be referred to the EDO for his i
follow up and not considered to be part of this investigation).
PHILLIPS wrote two memoranda to his management and one memorandum to IE Vendor I
Branch about the generic implications of certification problems with BISCO seals. According to PHILLIPS' and draft memoranda, the records for fire rating tesi.s at BISCO were destroyed by a fire at BISCO during 1976, but BISCO i
maintained certification on these sea s in the absence of these records.
j JOHNSON tuld OIA that he did not discuss the technical issues with PHILLIPS but he did discuss the wrongdoing' aspect with a Regional 0! official who chose not to pursue it.
JOHNSON was upset that PHILLIPS desired to communicate directly to IE's Vendor Branch and not through Region IV management.
WESTERMAN told OIA that he chose not to pursue the violations concerning the utility's failure to file a 50.55(e) and the lack of an adequate engineering l
evaluation concerning these seals.
Technical Evaluation Of This Concern i
It was learned that, based on the April 4 Johnson letter, the IE staff did pursue the matter.The IE staff acknowledged that BISCO fire seal problem might have been a generic problem. The IE staff referred 01A to a Region III inspection report at the Clinton facility.
This report concludes that the inspectors found tnat the BISCO fire seals did satisfy the regulatory requirements. However, it is unclear whether these seals are similar to the ones at Comanche Peak.
' Conclusion For This Concern Based on the information in PHILLIPS' draft memoranda, the Region should have promptly referred the matter to IE to determine the generic implications of
)
the BISCO fire seal problem. Until a determination is made concerning the i
safety significance of PHILLIPS' findings and whether the resolution of the l
fire seal problem at Clinton applies to the seal problem at Comanche Peak, it i
is premature to determine whether an 01 investigation is required.
I 1
I L---- -
19 ATTACHMENT 1 LISTING OF PHILLIPS' PROPOSED VIOLATIONS DOWNGRADED, DROPPED, OR CHANGED INSPECTION REPORT 85-07/05 ISSUE RESOLUTION IN FINAL REPORT
- 1. Failure to translate design criteria Violation downgraded'to an into installation specifications, unresolved item procedures and drawings; and failure (446/8505-U-06),
to control deviations from the requirements contained in these f
documents.
- 2. Failure to maintain tolerances Violation downgraded to an required and failure to report unresolved item tolerance deviations on a non-(446/8505-U-05).
conformance report.
- 3. Failure to perform audits or Violation downgraded to an surveillance of reactor pressure unresolved item vessel specifications, procedures (446/8505-U-07).
and installation.
- 4. For the CVCS spool piece, failure V.olation dropped.
to maintain traceability of item by applicable specification and grade of material and heat number of heat
~
code.
- 5. Deferral of hydrostatic test on cold Unresolved item in draft report leg test subassembly.
was dropped in final report.
- 6. No objective evidence (records) that Violation maintained but no mixing blades had been inspected requirement for utility to quarterly since trucks were placed respond to this violation.
in service in 1977.
__=_-_
l 20 INSPECTION REPORT 85-14/11 ISSUE RESOLUTION IN. FINAL REPORT f
- 1. FSAR does not describe TUGC0 Violation downgraded to i
records system.
unresolved item
(
(445/8514-U-04; j
446/8511-U-04).
- 2. QA manual does not address ANSI-Violation downgraded to N45.2.9 requirements / commitments.
unresolved item l
l (445/8514-U-05; 446/8511-0-05).
- 3. TUGC0 failed to have/use procedures Violation established based.
to control shipment of original on TUGCO's failure to have records to Stone and Webster.
site procedures.
- 4. Original design records shipped Violation dropped, in cardboard boxes to Stone and Webster.*
- 5. No backup copy of records made Unresolved item dropped.
for records shipped to Stone and I
Webster.*
I
- 6. Failure to control and account Violation dropped-.
for records transferred to
, Stone and Webster.
- 7. Site records of Chicago Bridge Violation dropped.
and Iron shipped to Houston, Texas 1
in cardboard boxes.**
i J
- 8. No backup copy of records made for Violation dropped. An open records shipped _to Chicago Bridge item created involving records and Iron.**
received from vendor (445/8514-0-06; 446/8511-U-06).
1
- 9. TUGC0 failed to inventory records Violation dropped. Unresolved
]
sent to Chicago Bridge and Iron.
item created involving Chicago i
Bridge and Iron records control (445/8514-U-06;446/8511-U-06).
- 10. TUGC0 did not document audit Violation dropped.
of records.
- and ** items were combined for the purposes of this review.
l
21 ISSUE RESOLUTION IN FINAL REPORT
- 11. Failure to preclude rain from-Violation dowagraded to Open entering QA intermediate records Item (445/8514-0-02; vault over several years time.
446/8511-0-02).
- 12. Failure to preclude food and coffee Violation dropped.
pot from QA intermediate records l
vault.
- 13. Failure to install fire suppression Violation downgraded to system, drains, and a sloped floor unresolved item at permanent vault.
(445/8514-U-08; l
446/8511-U-08).
l
- 14. Plant records stand in folders or Violation downgraded to binders in open face cabinets at unresolved item records center.
(445/8514-U-07; 446/8511-U-07).
- 15. Failure to provide temporary or Violation downgraded.
j permanent storage facility for records co-mingled with in-process documents in paper flow group.
- 16. Weld rod not identified at main Violation dropped, distribution station.
5 l
N l
l 1
)
l l
1 1
22 INSFECTION REPORT 85-16/13 ISSUE RESOLUTION IN. FINAL REPORT
- 1. Failure to develop / implement Violation downgraded procedure to demonstrate 50.55(e) to unresolved deficiencies correct J.
(445/8516-U-01; 446/8513-U-01).
l
- 2. Failure to revise implementors Violation Downgraded procedures containing 50.55(e) to unresolved reporting.
(445/8516-U-01; 446/8513-U-01).
l
- 3. Failure to maintain retrievable Violation downgraded 50.55(e) files.
to unresolved (445/8516-U-01; l
446/8513-U-01).
- 4. Failure to report to NRC corrective Violation downgraded actually action taken on 50.55(e)s.
to unresolved.
- 5. TUGCO's 50.55(e) files not audible.
Violation downgraded to unresolved.
- 6. TUGC0 never responded to all aspects Unresolved item downgraded j
of IEB 79-14.
to open item (445/8516-0-03, 446/8513-0-03).
J i
- 7. TUGCO's IEB record files were Unresolved item downgraded incomplete.
to open item (445/8516-0-05, 446/8513-0-05).
- 8. NAMC0 switches IEB 79-28 were not Violation downgraded to properly identified on travelers.
unresolveditem(445/8516-U-04; j
446/8513-U-04).
- 9. Deficiency in TUGCO's procedures Violation downgraded to to handle IEBs.
unresolved item (445/8516-U-02; 446/85136-U-02).
- 10. No focal point at TUGC0 to track Violation / unresolved item IEB actions.
dropped.
- 11. TUGC0 internal letter stated that Paragraph dropped in final TUGC0 not identify non-conformance report.
on IEB 79-14 to NRC.
- 12. Insufficient evidence of successful O! investigation requested testing of BISCO fire seals - filing but rejected by Regional of false report by BISCO - Validity management.
Inspector's of BISCO seals questioned, unresolved items maintained (445/8516-U-06.446/8513-U-06);
445/8516-U-07 ;446/.8513-U ).
Frequency of 0A Modules Based on Past Versions of the MC 2512 Program QA Module 3/31/75 7/1/80 8/80 9/15/81 3/30/84
- 1. Contractor As Req'd As Reg'd As Req'd As Req'd As Reg'd Surveillance (5 mo. after (35020) docketing)
- 2. Pgmt of QA N/A Once every Once every
- PI - 2/4 Once Activities 18 mos.
18 mos.
first yrs.
every (35060)
PII - 1 in 5th 18 mos.
and 6th yr.
PIII - remainder
- 3. Indepth QA N/A Annually Annually
- PI - 1 per
'nnually inspection area (civil)
(35061) structural, etc.,
P-III - remainder
- 4. Procurement, N/A Annually Annually
S torage 535065)
PII-1 in 3rd yr.
PIII-remainder
- 5. Review of QA Each insp.
As Reg'd As Req'd As Req'd As Req'd Manual (35100) of discipline
- 6. Mid-tern QA Cnce N/A N/A As Reg'd As Reg'd
.l Inspection (35200)
- P - Priority j
l Attachment NN
.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ -