ML20153G829

Ofc of Investigation Rept of Inquiry, Comanche Peak Steam Electric Station Alleged Falsification of Coatings QC Training Records, on 851125-26.No Falsification Noted But QC Supervisor Erred in Documenting Evaluation

ML20153G829
Person / Time
Site:	Comanche Peak
Issue date:	12/03/1985
From:	Griffin H, Herr R NRC OFFICE OF INVESTIGATIONS (OI)
To:
Shared Package
ML20153G788	List: ML20153G786 ML20153G802 ML20153G829
References
FOIA-84-487 QA-84-045, QA-84-45, NUDOCS 8805120030
Download: ML20153G829 (8)

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Title:

COMANCHE PEAK STEAM ELECTRIC STATION ALLEGED FALSIFICATION OF C0ATINGS QUALITY CONTROL TRAINING RECORDS Licensee: Case Number: Q4-84-045 Texas Utilities Generating Company 2001 Br yan Tower Report Date: December 3,1985 Dallas, Texas 75201 Control Office: 01:RIY Status: Closed Inquiry Reported by: Approved by:

Yk H. Brooks Griffin '

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AY Richard'K. Herr' Investigator, OIF : IV Director. 0!FO:RIV Beg 51gg O 800506 HARRY 84-487 PDR WARhNG N.

The tached documen eport has not been reviewed pursuant 10 C.F.R.

%2.7 (a)exempti s no has any exe 1 been d . o not diss inate or scuss i s content tside N Tr os "0FFICTAt-tSE ONLY.' U sn.-

DETAILS OF INQUIRY Purpose of Inquiry This inquiry was initiated to determine whether QC inspector recertification records for certain coatings QC inspectors at the Comanche Peak Steam Electric Station had been falsifieo by a QC supervisor.

Background

During August 1984, Bryan H0DGSON, a Brookhaven contract employee participating at, a member of the NRC's Comanche Peak Technical Review Team (TRT), reviewed a sainpling of Level I QC inspector recertification records which indicated that coatings QC inspectors had taken oral examinations for their recertification. HODGSON subsequently interviewed three coatings QC inspectors who testified they had not taken oral examinations for their recertification.

H0DGSON interviewed Curly KRISHER, the QC supervisor who had signed the recertification records which indicated that oral examinations had been given to the QC inspectors, liODGSON said KRISHER confirmed that he (KRISHER) had signed the recertifications. H0DGSON said KRISHER also testified that the coatings QC inspectors had not taken oral examinations. H0DGSON said that KRISHER said the inspectors' recertification was based on his evaluation of their individual job performance.

The TRT Project Manager referred this information to the NRC Office of Investigations as possible falsification of QC training records.

Review of Supplemental Safety Evaluation Peport (SSER) 9 The Comanche Peak SSG 9 issued by the TRT in March 1985, addressed Level I QC inspector recertifications. Pages M-122 through M-124 sumarized the TRT's findings. Paragraph 4 on paged M-124 stated as follows:

The TRT evaluated the process of Level I inspector recertification to determine how the proficiency of inspectors was maintained. The TRT reviewed approximately eight completed recertification fonns, which showed that written, oral, or practical recertification examinations had been given. However, the TRT found no supporting evidence that written, oral, or practical exaninations had actually been given for inspector recertification. The TRT found that recertification consists of an informal evaluation by the responsible QC supervisor, based on personal knowledge and supplemented by infonnation from the responsible lead inspector.

Interview with Robert SPANGLER, TUGC0 Assistant QA Manager and Robert SCOTT, TUGC0 Vendor Compliance Supervisor On November 25, 1985 SPANGLER and SCOTT were interviewed (Exhibit 1).

SPANGLER and SCOTT said the site procedures authorized the QC supervisor to recertify the coatings OC inspectors based cn their job perfonnance. SPANGLER anc SCOTT indicated the recertification form did not clearly reflect that the recertification was based on a subjective evaluation by the QC supervisor.

Review of Inspector Recertification Fom On Ncvember 25, 1985, during the interview of SPANGLER and !COTT, site procedure CP-QP-2.1 with the attached inspector recertification form was reviewed. Whereas, the procedure mentioned oral, written, or practical examinations for recertification, the recertification form only referenced oral and written examinations and did not include practical examinations.

Interview with M. G. KRISHER, Brown & Root QC Superviso_r On November 26, 1985, KRISHER was telephonically interviewed (Exhibit 2).

XRISHER, the QC supervisor who signed the coatings QC inspectors' recerti-fications which indicated that oral examinations had been given, said he considered his daily conversations with the inspectors as a form of examination. KRISHER said site procedures authorized him to recertify the inspectors based on his evaluation of their work. KRISHER denied that he intended to falsify the recertification records or deceive the NRC.

Closure Infomation The QC supervisor signed the recertification records required by the site procedures. The procedures authorized the QC supervisor to recertify the coatings QC inspectors on a practical examination basis. The recertification record did not clearly reflect that the recertification was based on a subjective evaluation of the inspectors' work. The QC supervisor did not falsify the recertification records, but rather erred in documenting his evaluation.

9 LIST OF EXHIDITS Exhibit No. Description 1 Report of Interview with SPANGLER and SCOTT, November 25, 1985 2 Report of Interview with KRISHER, November 26, 1985 l

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Q4-84-045 Report of Interview With Robert SPANGLER, TUCC0 Assistant QA Manager, and Robert SCOTT, TUGC0 Vendor Compliance Supervisor On fiovember 25, 1985, SPANGLER and SCOTT were interviewed by NRC Investigator H. Brooks GRIFFIN regarding their knowledge of Comanc% Peak site procedures for recertifying QC inspectors as it related to the f.sss~hle falsification of coating QC inspector recertifications. SPANGLER a*d LOTT reviewed site procedure CP-QP-2.1 which related to the training and cwtification of Quality Control personnel.

SPANGLER said the procedure allowed for recertification tests for Level I QC inspectors to be oral, written, or practical. SPANGLER indicated that CP-QP-2.1 w6s consistent with the requirements of ANSI /ASME N45.2.6 and that revision 16 included an attachment which is an inspector recertification fom.

SPANGLER said that if an inspector has actively perfomed related inspecticns within the past twelve months, the QC supervisor has the authority by prccedure to recertify the inspector without ?.ctual testing. SPANGLER indicated that most testing for recertification is for personnel who have not been active in those inspectiens for a period of time. SPANGLER speculated that M. G. "Curly" KRISHER, the coating QC supervi:,or at the time the TRT was perfoming its review, could have considered periodic conversations with his QC inspectors as compliance with the requirement to reevaluate the inspectors' perforr.ance for recertification.

SCOTT said the recertification fom attsched to the procedure was not a "good" fom. SCOTT said he was not aware of how KRISl1ER completed the fom, but said that if KRISHER recorded that cral examinations had been given and the inspectors testified that the oral exams had not been given, then KRISHER may have erred.

SPANGLER and SCOTT both expressed the opinion that although KRISHER had the authority to recertify the inspectors without a test, they understood why the QC supervisor's signature indicating an oral examination had been given might have misled the TRT representatives.

DATE PREPARED IN DRAFT FROM NOTES TAKEN DURING INTERVIEW:

Noverrber 27, 1965 Exhibit 1

Q4-84-045 Report of Interview With M.G. "Curly" KRISHER On November 26, 1985 KRISHER, a Brown & Root QC supervisor at the Conenche Peak Steam Elcciric Station, was telephonically interviewed by NRC Investigator H. Brooks GRIFFIN. KRISHER was questioned as to whether he recalled being interviewed by a TRT representative named H0DGSON regarding his signature on coatings QC inspector recertifications. KRISHER said he did not specifically recall discussing the recertifications with H0DGSON, but said he recalled discussing the subject with various TRT representatives on several occasions.

When KRISHER was asked for an explanation as to why the coatings inspectors' recertification records indicated they had taken oral exams, KRISHER said he coosidered his daily conversations with the inspectors to be a form of exam.

KRISHER said he recertified the inspectors based on his evaluation of their work and his conversations with them. KRISHER said that site procedures authortzed him to recertify the inspectors based on his evaluation of their performance. KRISHER denied that he had intanded to falsify the recertification records or to deceive the NRC.

DATE PREPARED IN DRAFT FROM NOTES TAKEN DURING INTERVIEW:

November 28, 1985 Exhibit 2 i

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