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NUCLEAR REGULATORY COMMISSION n
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MEMORANDUM FOR:
L. Shao, Engineering Group Leader Comanche Peak Project FROM:
C. Poslusny, Program Coordinator j
Comanche Peak Project i
SUBJECT:
ALLEGATIONS s
Enclosed is a listing of 3 allegations received from Alleger A-64 which need i
to be addressed.
Please provide the name of the lead reviewer when assigned.
l If you need further information on these, or a copy of the transcript of a i
previous meeting with the alleger, contact me on extension 27066 or M. Kline on extension 29548.
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Chet Poslusny, Program Coordinator Comanche Peak Project i
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Enclosure:
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1 FCIA-85-59 8607030209 860623 PDR FOIA GARDE 86-A-10 PDR E._._..___.__.____.-.__--._-.-..,._.
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AW-90 Downhill welding stringers are not permissible on nuclear power J
plant welding at CPSES.
i AW-91 CPSES is using welders obtained directly from the Fort Worth Trade School (implying they)do not have the required experience and the resulting knowledge.
1 AW-92 A welder was asked to heliarc a stainless steel pipe that contained I
. sand, gravel, and concrete that resulted from flushing concrete down the pipe.
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TEXAS UTILITIES GENERATING COMPANY p <,_
OFFICE MEMORANDUM M
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B. R. Clements Dallas, Texas September 15, 1983 TRANSMITTAL OF MEETING MINUTES gg Attached are the minutes of your meeting with the TUCCO Quality Assurance personnel on September 12, 1983.
R. E. Kahler REK:cp Attachment FCIA-8&sa P>s
y MINUTES OF MEETING BETWEEN B. R. CLEMENTS AND TUCCO QUALITY ASSURANCE PERSONNEL SEPTEMBER 12, 1983
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On September 12, 1983 the Vice President, Nuclear, Mr. B. R. Clements,
convened a meeting with all TUGC0 QA professional personnel and supervisors
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to discuss the results of the investigation of allegations concerning intimidation or coverup in the QA organization.
In addition, the
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's attendance at the meeting as were members of the investigative team.
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A The following is a summary of Mr. Clements' opening remarks:
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1.
As a result of rumors that Mr. Clements had heard, while at CPSES six or seven weeks before, concerning possible coverup or intimidation by QA management, he directed R. E. Kahler to assemble an investigative team to ascertain the validity of these rumors.
l 2.
The team conducted interviews with all QA auditors and inspectors and the results of these interviews were periodically reported to him.
As a l
result of these interviews, concerns regarding QA managements' actions during the radwaste audit were brought to light.
In addition, details concerning an event, possibly involving the intimidation of QA personnel, were discovered.
3.
At the conclusion of all interviews, the investigative team issued a report of findings to him.
Subsequently, he asked for and received from the team additional information to clarify four or five items from the report.
4.
Mr. Clements stated he was now satisfied with the report and believes that no coverup or intimidation took place.
5.
It appeared that QA management had in several instances exercised poor management practices.
For example, although QA management had discussed with conduct with a group of auditors and informed him that it was inappropriate, the results of this conversation were not provided to the audit group.
6.
He stated that he had directed the Manager, QA to implement written policies in several areas.
In particular, a method is to be established, in writing, to provide for the documentation of differing professional opinions between auditors and QA management.
7.
Mr. Clements emphatically stated that neither he nor higher Texas Utilities management would knowingly allow either a coverup to occur or a QA auditor to be intimidated by others or to intimidate others.
He
r indicated to the group that should any individual become aware of a possible coverup or attempted intimid.stion, he expected the individual to report it to Texas Utilities management.
This includes anyone from their benediate supervisor to the Chief Executive Of ficer. Furthermore, should the individual not desire to discuss the issue with corporate
.. management, then the individual has the responsibility to notify the Nuclear Regulatory Commission, Region IV.
8.
Mr. Clements offered to meet with anyone present, either in his office or elsewhere, if they desired to discuss further either the incidents or the results of the investigation.
Mr. Clements closed his remarks by asking for questions from the group. He was asked if the investigation had produced any other findings than those discussed during his remarks. He indicated there had been an additional allegation, made during an interview, concerning the falsification of a signature on an audit report, but af ter interviewing the individual concerned, he had determined that this was not true.
In addition, several issues had been identified concerning the use of personal vehicles on company business and the reimbursement of travel expenses.
QA management has been directed to take action to resolve these problems. There were no further questions and Mr. Clements adjourned the meeting.
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TEXAS UTILITIES GENERATING COMPANY B. R. CLEMENTS OFFICE MEMORANDUM B. R. Clements October 5, 1983 To Danae, Texas Ref: Memo dated September 9, 1983 Subject
" Request for Glarification/ Action of QA Atems~
The following is my response to your memo dated September 9,1983:
1.
During the course of this audit, I received several complaints from the management of the audited organization regarding the demeanor and objectivity of both of the team members - especially I determined that neither of the auditors was being objective, as evidenced by the discussion which follows.
- Further, I determined that had repeatedly lost control of when discussing with others what considered to be problems.
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inability to control caused supervisor to preclude his participation in site construction and QA/QC audits shortly af ter these incidents.)
I verified that these two auditors had shifted from an objective audit to a personal crusade of some sort when I saw the report they had prepared.
It was laced with inflammatory language, and it contained an erroneous interpretation of an ANSI Standard.
the involved, rewrote the report, removing the errors and the gratuitous remarks. They presented both versions of the report to me, and I signed the revised one. The original report was placed in the pemanent audit file, as was a memo from expressing disagreement with the changes which had been made.
The conduct of Audit was quite unprofessional. As the revised report states, positive cont: ils were in place to assure that only welders qualified to the procedure being used were able to receive filler material. Two items remain open at this time.
We have concluded that the method of identifying welders on the WFML meets the requirements of the ANSI Standard; however, it was identified during the audit that this method was not consistently implemented. Engineering has been requested to evaluate this.
Additionally, we have requested that Engineering assess the adequacy of visual inspection and hydrostatic testing to meet the requirements of The response from Engineering is due by October 12, 1983. You will be notified when this question is resolved.
2.
There should have been no confusion on the part of as to whether the was safety-related. The was fabricated non-Q and subsequently became subject to This infomation was discussed verbally and documented in a memo from to prior to the audit.
F0ia-85 59 P)34
p 1 In the conduct of on-the-job training for qualifying lead auditors, an individual is assigned as a Team Leader under the direct guidance of a Qualified Lead Auditor.
In this instance the Qualified Lead Auditor failed in leadership responsibility to
-- maintain professional conduct and objectivity within the audit team.
As to the now discontinued use of Acting Team Leaders (ATL's),
they were always under the direct supervision of a qualified lead auditor. We will continue to assure that team leaders are qualified to perform the audits to which they are assigned.
3.
I have on numerous occasions counseled the people in my department that audits will be conducted in a business-like atmosphere _by_ all parties and that intimidation by anyone will not be tolerated.
This admonition was repeated in the QA Department meeting on September 12, 1983, part of which you attended.
4.
The applicable specification to the imposes ANSI B 31.1 1973, which requires that the welder be identified "as directed by his employer". Brown & Root, via procedure CP-CPM 6.9B, directs that the welder be identified on the WFML. This is acceptable in that it complies with the applicable requirements.
However, inconsistencies in implementation of this method were identified during the audit and are being addressed by Engineering.
5.
The auditors' concern regarding traceability of qualified welders to specific weld joints is addressed in item 4 above.
The piping was originally fabricated as non-Q and did not require inprocess inspection by Q.C.
Subsequent to the initial fab-rication, Q.C. became involved in the inspection process. At this time, questions surfaced regarding welder stamping requirements, and an NCR was issued for clarification.
Site QA has detemined that the inspection requirement to document welder symbol identification is not required ~and has deleted the requirement from the procedure.
In order to assure ourselves that the present requirements for visual inspection and hydrostatic testing are adequate to meet our commitments, we have requested an evaluation from Engineering.
See item 1 for additional details.
6.
I have found no evidence of QA audit personnel being threatened or harmed physically.
7.
I have reiterated to my personnel that it is not the job of the audited party to determine whether an auditor is qualified; neither is it the party's place to mix " politics" with QA duties.
8.
Our practice has always been to allow an auditor to express a view which is in conflict with that of the formal report. This practice has now been documented.
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9.
During the course of the investigation, QA Personnel, including Supervisory Personnel, were asked whether a specific activity was covered by a procedure. Procedures at times provide for an activity in general terms. This may have contributed to an s apparent confusion.
However, we will have additional discussions on procedures that apply to specific jobs.
In addition, exams will be administered to demonstrate an understanding of these procedures. Changes to these procedures will be discussed in staff meetings in addition to being distributed to applicable personnel.
- 10. Questions regarding expense account items such as personal car usage, meal allowances, etc. were discussed as a group in the September 12 meeting. All questions were resolved satisft:torily.
If you have any questions, please advise.
D. ii. Chapm n Manager, Quality Assurance DNC:1jj
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,1 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM 7 _ B. R. Clements Dallas, Texas September 6. 1983
$=bject Report of Investigation of Intimidation and Cover-up on the Part of Dallas QA Management (Re: your memo of August 29, 1983, same subject)
By your memo of August 23, 1983, you requested clarification on several points contained in the Report of Investigation.
The team response to each point is attached.
Richard E. Kahler REK:kh Attachments F0lA-85-59 7 \\sr
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Responses by the Investigative Team to B. R. Clements Regarding the Clarification of Certain Points in the Report on Allegations of Cover up and intimidation by TUGCO, Dallas Quality Assurance.
The following responses are provided by the investigative team to B. R. Clements (refer to memorandum from B. R. Clements to R. E. Kahler, dated August 29, 1983) for clarification of certain points contained in the investigation report.
For convenience, each request for clarification' has been repeated along with the team's response.
Finally a general comment relating to the meeting on August 26, 1983 between B. R. Clements, R. E. Kahler, G. S. Keeley and R. G. Spangler is included for the sake of documentation.
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Requested Clarification Page 5, Item 4 - Please clarify the last statement which begins "In addition, discussed with...".
The portion that I am particularly concerned about is concern about the conduct of the audit team.
Investigative Team Response I
The phrase "
discussed with T. Brandt and personal concerns in this area...", as used in the investigative report, means that discussed audit findings, which had resulted from work in assisting the audit team, with T. Brandt and recognized that there were problems in the area of weld to qualified welder tracability and he discussed these problems with QC Supervision.
The discussions between T. Brandt and concerning the conduct i
of the audit team refers to accusations by the audit team members that they had not been receiving adequate support from the site QC organization and that and Mr. Brandt had been discourteous to them.
discussed these accusations with both Mr. Brandt and In particular, the audit team informed that Mr. Brandt had indicated he would not be available to the audit team.
discussed this accusation with Mr. Brandt who stated 1
that he had told the audit team his availability would be limited due to a three day business trip.
Mr. Brandt denied that he had been discourteous to the audit team. As a result of the team's accusations and subsequent discussions with Mr.
Brandt and arranged the meeting referred to in item 5 on
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page 5 of the report. His objective was to get all parties together and " clear the air", if possible.
It was during this meeting that began to read Appendix B to personally felt that this was an inappropriate action on part and counter productive to the intent of the meeting.
indicated that although was offended by this action he remained i
quiet and " handled it quite well".
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Requested Clarification Page 5, Item 6 -
states that the " Audit report summary and statement of findings were unacceptable". Please give the reason for conclusion.
Investigative Team Response indicated to the investigative team that the draft report as submitted by lacked objectivity and was written in an " inflammatory manner".
The audit team, in opinion, had reflected their personal animosities with Mr. Brandt and in the audit report sunmary and statement of findings.
In particular, the audit team's draft report was very explicit in criticizing the disposition of NCR M-81-01680 by Mr. Brandt, which allowed welder and material tracability via the Weld Filler Material Log.
felt that the report needed to only identify the shortcomings of the disposition without excessive critical comment.
In addition, the deficiencies were labled
" Generic Deficiencies" in the draf t and report. This was and is not normal QA practice.
It had been done by QA Management once before to bring added CP Management attention to a particular area; however, did not feel that it was appropriate for this audit and deleted the term generic.
Requested Clarification Page 6, Paragraph at the top of page, last sentence - It is unclear to me to what position" is referring. Is it position as an auditor with the company or position on the
?
NkvestigativeTeamResponse The report refers to personal feelings regarding the I
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e e Requested Clarification Page 6, Item 5 - Is it the point of this paragraph that the auditors believe that " management prerogative" extends to changing the intent of auditors to that of management? If so, are examples of this available?
Investigative Team Response It is important to remember that the auditor's responses to questions concerning management's changes to audit report drafts covered the range from editorial in nature to alteration of intent.
In fact, only two auditors felt.that reports had been altered to reflect management's views vice their own.
Both of these individuals were aware of their right to place a memorandum in the audit file outlining their disagreements.
Neither individual felt strongly enough about any changes to do so or to identify specifics to the investigative team.
Apparently, the problem is not with the deletion or alteration of findings but rather relates to the significance attributed to findings by the report write-up.
It is the opinion of the investigative team that a difference in philosophy exists between some auditors and QA Management.
Furthermore, these auditors recognize this and understand that their management does not always view findings from the same perspective as themselves.
In this sense, they recognize management's actions as being part of the supervisory process.
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General comment relating to discussions of the Investigative Report between B. R. Clements, R. E. Kahler, G. S. Keeley, R. C. Spangler.
During the discussions on August 26, the Vice President, Nuclear questioned the wording of the report concerning as to whether or not intimidation had occurred.
The investigative team does not believe that any intimidation took place dispite the actions and words of the person accused. There were no persons interviewed who indicated that they would not perform their QA duties assigned or write-up findings because of the statements made by the person accused of intimidation.
It is our belief that the statements were made in order to prevent any friction between QA personnel and the crafts which could result in bodily harm to QA personnel, and to indicate that craft personnel were accustomed to dealing with QC personnel. We also believe that the person accused of intimidation made these statements because believed that interface between QA, Dallas and the crafts was department's responsibility.
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R. G./Spanfer v'
Approval f
R..E.
Kahler
TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM To Memo to file
- Dallas, Tex as 9aara-har 0 - 1081 Subject A11eeed Formed Signature on Audit Report During the investigation of allegations concerning coverup and indication of intimidation by TUCCO QA supervision, one of the persons interviewed indicated that there was a report which bore the signature of but the signature wac not that of On September 6, 1983 I discussed this allegation with in the privacy of my office. No one else was present.
I asked if the allegation was true and said no it was not and that the person who had made those allegations was talking out of school.
further indicated that if there were such a report would be aware of it because when acted as team leader knew the reports had to be signed by did not know of any reports of audits which had not signed as required to do so.
After my discussion with I consider the matter closed.
B. R. Clements 1
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TEXAS UTILITIES GENERATING COMPANY
" 'u ti, JI t tofit OFFICE MEMORANDUM To D. N. Chapman DaHae, Texas September 9. 1983 Subject REOUEST FOR CLARIFICATION / ACTION OF QA ITEMS Below are a random list of items that I need clarification and/or action i
by you. These matters came to light during the investigation recently I
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.t completed by R. E. Kahler, et al.
1.
I would like for you to make a thorough review of the conducted and report personally to me you views on that audit, including the conduct of it, results, and is j
there further action required by anyone for any reason.
2.
seemed to be confused prior to the as to
.whether the was "non-Q or Q".
This makes me doubt l
qualification to be an Acting Team Leader (ATL).
I realize'that you no L
longer use the ATL concept, but I desire that you make certain of the i
qualifications of audit team leaders before they are assigned as such.
3.
It is imperative that you do not allow personality conflicts to have an impact on our conduct of audits.
Intimidation by either side in an f
audit WILL NOT _B_E TOLERATED!
r 4.
In the there was some discussion whether or not the
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method of identifying a welder by WFML is acceptable.
Is it?
l 5.
The principle concerns of the audit team in the regards I
the traceability of qualified welders to specific weld joints and the adequacy of the QA inspection effort on the appears in the
.Please brief me on how these matters have been worked out in a satisfactory manner.
6.
Have we ever had any incident of QA audit personnel being threatened and/or harmed physically by craft personnel at CPSES?
7.
I want it understood that no one will be " hurt" politically for any actions taken during an audit as long as that person is acting in good faith and within the policy of TUGCO.
It is the job of QA/ audit j
supervision to make certain that the people doing audits are qualified.
l You must make it understood by people reporting to you in the field that it is not their job to-determine the qualifications of these audit personnel.
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%,trMr-!{/[,i eN You and I have previously discussed several areas in which your policies /
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procedures are verbal.
I expect you to write procedures / instructions or
- -policy letters to cover these areas.
"9.' ~TnTditi5if,~the QA personnel appeared to have a very sketchy knowledge --
of what procedures are available or whether or not procedures 7 gg C
avatlable.
10.
In addition, we have discussed certain personnel expense report practices that need to be put in writing and maybe modified by our discussion.
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j You are requested to respond to these items no later than September 26, 1983.
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