IR 05000269/1975008
| ML19308B391 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/16/1975 |
| From: | Ebneter S, Jape F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19308B388 | List: |
| References | |
| 50-269-75-08, 50-269-75-8, 50-270-75-09, 50-270-75-9, 50-287-75-09, NUDOCS 7912300032 | |
| Preceding documents: |
|
| Download: ML19308B391 (28) | |
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~ 1E INVESTICATin3 REPOaT ML*:in"RS
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50 269/75-8
'50-270/75-9
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50-287/75-9 REGION 11 Subject:
Duke Power Company
Oconce 1,'2, 3.
License Uos: DPR-38, 47, 55 Docket Nos:
50-269, 270, 287 Allegation: ' An ' Investigation was conducted of stateraents transnitted to the USHRC Region II office alleging that (1) quality control functions at the Oconee I:ncicar Station (0::S) related to
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instrunentation were hampered by the other organir.ations; (2) that the drawings f~or the ONS instrunentation vere less than adequate and (3) that Duke Power Company (DPC) had for ONS.
e procured inadequate equiptrent
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Feriod of Investigation: May 19, 1975 June 3, 4, 5, 1975 S. D. Ebneter, Menctor Insnector Investigators:
Engineering Section Facil: t ies Construction Eranch F. Jnpe, Reactor inspector Facilities Section
Facilitics Test und Stcrtup Dranch R. C. Parker, Reactor Int.pector Nuclear Engineering Section Faci 11 tics 'icst and Startup 3 ranch p
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' Principal Inspector:
PLMA 2 4. 7."R
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, Dats F. Japh, Reactor Inspeg.or,/
Facilitics Section
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,Facili tiev Test and Startup Dranch
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Reviewed by:
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Date il. C. Lewl5";-Sent;or-Reactor Inspector
Facilities Section.
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Facilitics' Test and Startup Eranch
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licanon for Inve:;t.ijpgon, d a 1.:tter to the The Carolina Environnental Study Group (CESG) t ransmittethe Quality C Region 11 office suggesting thatThe CESG contacted a former employee of DPC intervicu hin. The forner nate to' Design Engineering.
and nade arrangevents for NRC investigators to d statencnt of three employee provided the investigators with a signeThis investigation uas condu allenstions (Attachnent 1).
the validity of the allegations.
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_Sunnary_
i was conducted 3-5, 1975, an investigat on l of DPC During the period May 19 and June
' to determine the validity of allegations made by a former (n d as a basis former cuployee to obtain f actual information that could be u pertcining to ONS.
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for further investigation. ducted nn investigation of DPC Charlotte opera
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June 5, 1975.
site investigation of 053 Units 1, 2 and 3 on t
nt containing The former employee had supplied the NRC vith a written statene three al]egations-
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Quality functions at Oconee nuclear Station vore ha. rered b
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their being centrolled by Technical Support.
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ei drowinga
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En7.ineering pronuced a icss than adequate net d
because of paor engineering practices, accccacy of dr dngs an Design 2.
usability of drawings.
1 and Equipment, unsuitable f or the npplication, has been n2.,
s i s. ut other t v p irchase of the equipnent van based upan f rie 3.
operat. icn.
do cu..m ta t ion or h n-dva r:.
The alleger had dif ficnity in identifying specif ic referred to of the equipment that could be investigated in depth and riostEach allegation van investigate 1 and 3 could not be sub-uns non-saf ety related.
possibic and it was concluded that allegr.tionsflouever, all This led stantiated.
to the finding that contrary to 50.5')(b) otho' saf ety significy.nce of na'<.ing evaluation uns not performed to determine ithout up:roval an re-changes to cafety reinted instrunentation systens winstalling ir..ctrumentatio1 quired by paragraph 13.5.2 of the FSNI, and nots he FSAR.
Sp:'ci fically.
the investigators found that the detailedreficct the au--built status cf the plant hich differs fren the instre:tentation ayatema did not and the instrunentation ras installed in a nanner vthe approvni of the 7.ont.
detail dcawings, without J. :.e he an infrr.::!.
Failure to perform a written saf ety evaluation in can'tidert I'
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Prepared by:
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S. D.-Ebucter
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Reactor Inspector Engineering.Sectton Facilitica Construction Uranch
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Dates of Investigation: June 3,4,5, 1975 Reviewedby:g hg fg. -gf y
Date L. L. Beratan
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Senior Reactor Inspector
Engineering Section Facilitics Construction Branch
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Details
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Persons Contacted
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Duke Poner Company (*,?C).
1W.11. Owen~ - Vice Pres,ident, Enginee' ring J.1 R. UcIls - Corporate -QA Manager C. B.. Aycock
. Cons:r.:ction QA Manager C. J. Wylic - Chief 2..vineer, Electrical
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R.11. Waltman - Prin ' pal Engineer, Electrical
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T. C. McMeekin -. Design' Engineer
i 93 at et W. E _ O 'Ueal - D em. i-j.
J. ::. Curtis - Vender ';C Manager
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. R. J. Drackett - Ass'stant QA Engineer - ONS
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J.. E. Smi th - Plant in erintendent - ONS K. U.: Schmidt - Asse:iate QA Engineer, Construction C. S. Dradham - Sup s:: atendent of Itaintenance - ONS
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'Allerg
? armer Employee of h Power Company
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Investleation of Allenation 1 Allegation 1 The alleger, in a signed statement (Attachment 1) dated fay 19, 1975, alleged that quality functions at ONS vere hampered by their being
"controll'ed" by Technical Support.
Intervieu uith Allener The NRC investigators interviewed the alleger on May 19 and June 3, 197*.,
to obtain information and facts as a basis for further investigation.
The alleger stated that he is a graduate electrical engineer and a registered professional engineer in the State of North Carolina.
Ile d:es not have any work experience in quality assurance (QA) or quality contral (QC) disciplines but has Interfaced with QA and QC on various assignmend.
The alleger stated that he uas not assigned to QA or QC at ONS but reported to Steam Production Departcent. He was not familiar with the QA requirements or organization structure as stated in the FSAR, Appendi:-:
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Ile stated that the Construction Department did not permit him to un the FSAR.
He also stated that he was not aware that a copy of the 1 sad uns available for his use at the public docenent room in the Walhal'.a County Library.
The allener stated he felt (?C uns nubnervient to De :irn end Techn D 11 Suppert, and that QC had no teeth.
Thin conclunica was based on his interf acing'ulth QC at DNS and his observation that QC ceuid request changes but could be overruled by Design.
Upon interroratlou, he stated that of the suggestions or requested changes. approxinately 20 percent vere related to problems and approximtely 00 percant uere
"helpf ul" suggestions based on the individual reques tor's enperience.
In reference to this, the alleger provided an apparent 11?C internal document (Attachment 2) uhich specified the duties and responsibilitics of QC inspectorn dated, September 26, 1972. This document lists ten responsibilities for Electrical and Instrucentation QC Inspectors. Thy alleger stated that this was the first fornal definition of QC functions and he felt that it uas helpful.
The alleger related that numerous problens existed in the ONS instrunen-tation but could not specifically identify any systen as being deficient.
He stated that the process instrumentation sensing lines installation criteria such as line slopes and routings were not detailed on drauings.
- In general, when these deficiencies ucre detected and documented on Random inspection Uorksheets (RIU) and Variation Notices (V.1), correctt =.
action uns initiated for that specific deficiency; but ha stated that o6ly those that were specifically documented cere corrected. The investigators queried the alleger if established procedures for contrc:
ef RIWa and VNs were folloued to resolve problens.
He responded that he didn't knou ahcut the 111Us and he suoposed they did for V:'s.
He stated that there ucre no instrunent stand: teds at 02:S untti early.1%
and that inspection of the instrunent installations cere nade only to
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~ verJfy conformance to drawings which were lietited in th-detaI].
support his allegations.T!ic alleger provided additional DPC documenta
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e an.ount of 1973, which was prepared by the alleger while employ d b on to tho alleger nade reference to an " investigation "
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e y UPC to questioning, the alleger stated that he uns In renponse,
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investigation of his own and compiling inforgation b conducting on stated he was assigned to the Steam Productio ased on e.
Uc that he had no charter to, and any -investigation; it was strictly on his oun initiativnor had he be e.
_lnvestination and Interviews
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The investigators cet uith DPC personnel representi discussed various aspects of the' allegationsand Qua n June 4, 1975, and
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Appendix 1B of the FSAR describes the DPC approach t
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question is shown on Figure 1B-4 of Appendix in a l
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caplified by an organizational chart in NRC files titled "O
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er Nuclear Station Organization for Quality Control and Tconee Lupport" dated August 17, 1972.
echnical it was stated that Technical Support and Quality Coin discussions ui nization end had thr:e ereas of reepensiMlity:ntrol vere the same e ry-support.-
The QC function uns prinarily accomplished by ins qA, QC
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QA function by the discipline field engineer and technical sup p.ie tera, the perconnal.
The technical support'
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engineering duties.
personnel prir<artly performed Field common uithlu the nuclear industry in the Inte 60's hndThis fac t, the FSAR distinctly describes early 70's.
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paragraph 13.2.2 which states that this type of organization in
.. the proposed" Quality Ansurance CrJ teria." Duke conforns to.
a ningle general exception.
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that quality assurance f :nctions be perforned bThe' proposed criteria son
.. vith having responsibility for an activity. component separate an onponent uith respect to activitics performed by craf tsmenDuke conforns to this suggestion of. professional engineering as applied in design In the area
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and operation, Duke has intentionally assigned quality a, construction professional engineering activity. " responsibilities to the same ssurance nsible for
- DPC personnel stated that considerable problems had b
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uith some inspection personnel bypassing supervision and m ki een experienced
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tions or seeking soluti:ns to problems by contacti a
ng reconnenda-direc tly.
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the responsibilities of the QC inspectorsThis vaa reredied by lim e
n ng reapunuibilities apparen:1y is th::
Tbc latter definition of
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subultted to the 2C.
docuaent the all e ct and th. Cf.M.
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DPC personnel ntated that. there van no formal inntrouentation installat. ion criteria in the early 3970'u but that stan: lards were developed and inpl e --
taent ed in 1973.
Instrument installations vere innpected to drawing requirenents and the acceptance or rejection of an installat. ion uan based on the exocrience and judgenent of the inspector.
The FSAll uas available in the Construction Departnent offices and was used by QC personnel. Discrepancies were documented on VNs or R1Us.
NRC Inspections
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The NRC (iornerly AEC) inspection reports of the ONS during the late 1960's and early 1970's vere revicued to determine if thin subject had been covered. Report 50-269/69-8 noted the need for electrical installation procedures and 50-269/69-7 identified a requirceent for grea'ter depth of QA and QC in electrical areas.
Report 50-269/71-8
specifically cited weaknesses in the construction QC due to transfers of key people, resignations and poor training. The identification of these deficiencies was followed by DPC corrective action which resulted i
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in a continuously evolving QA and QC program.
I Conclusion The allegation that QC was subservient to and controlled by Technical Support is considered to be a result of aisinformation. As noted above, the QC and technical suppert functiona ucra integrated into a alagle organization. This uns a fairly cornon and acceptable approach in the early 1970's.
The alleger st.ated he vos not familiar uith the QA description in the FSNI. No evidence could be found that QC uns subservient to Design Engineering. The DPC int ernal meno, dated September 26,1972, (Attachaent 2) uhich listed ten QC respoasibilities uns based on the existing organization structure and assigned functions.
The nemo content appears to be consistent '-ith the FS UI descriptien and the alleger felt it was helpful. The investigators noted that four of the responsibilities uere written as negative.etatenents rather than positive. The responsibilities an defined cra thone that are nornally assigned to QC and insacetion.
It appears, based on statecents from DPC and the alleger, that inspectors and others uere eneceding their authority in interpretation of requirenents and resolution of problens.
.'n fact, the alleger stated he uns conducting his own investigation uhich was not uithin hts assigned duties.
The DPC cpproach to QA and QC at ONS was just one means of structuring a QA/QC organization. This particular approach has proven to be dif ficult to. control and, at the present time, is not considered to be the bes t approach. As noted, the NitC inspections identified areas where the QA/QC progran at ONS needed inprovenent early in the con-struction phase of ONS. These resulted in citations, where applicable, to DPC and subaequent corrective action.
No further investigation into this iten la planned.
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Invent Ipition of A1137;ation 2
AI I.f E.31I IL-The alleger, in a signed stat emen't (At tachment 1), dated !!ay 19, 1975, nueged that DPC Denign.En ;incering produced a lesn than adequate set of drawings because of poor engineering practiccc. accuracy of drawings and usabili ty of drawings.
Intervleu vith Alleger
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On t!ay 19 and June 3,1975, the NRC investigators met uith the allerer
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to discuss the allegation and obtain information regarding specific inadequacies as a basis for further investipation.
The alleger stated that numerous errors were evident on drawinys released to the field but he couldn't give any numerical figures of th~e extent of the problen. lie stated that instrument sensing line slopes were not specified, the drawings lacked details for
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inspection, and field changes vere not always incorporated on t
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revised drawings.
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The alleger could not provide specific details.with regard to poor engineering drawing practices.
In response to questions, he related that drawings are checked by a fellow designer but not an inds oendent group. He did rot knou if design revicus vere performed. The alleger referred to the instrumant grounding system ns one he felt did ant conforn to de:riinga and one uhich used confu ;in.2 terninology. He referred to drawings OEE-15, 0792, 0789,11789 and 2739 and 8"1-060-3 as documentation that uns in error and could nubstantiate his allepatica.
DPC inspection of instrumentation installation was made against design -
drawings which vere, in his opinica, inadequate and he stated that no instrenentat. ion standards vere available until early 1973. Ile further stated that ins trumentation piping details :hich repreuant good engineer-ing practice were not alunys shown on dravings, but they vould be lautalled by field engineers even thongh not'npecified by desiga on the details, lie stated that, as an eatinate, 20 percent of these changes ucre actual problets and apprnnicately 80 percent vere helpful suggestions based on the experience and judgenent of the DPC inspecter or other field personnel. lie acknowledged that none of these changes were incorporated on the detail drawing by red linlug and then transmitted to design. Others ucre handled by a VM, which is a formal design change notice used during the design and construction phase. Statica Modification Reports (SMR)
were used to eff ect a design change af ter the systens were turned over to Steam production. The alleger stated t at specific problems, or noncon-formances, were corrected when they ucre identified and docunented.
lloucver, the general problem related to the overall 0:'S uns not addressed by Denign Engineering. The alleger urovided the NRC uith copies of DpC internal ecmunications uhich support the contention that many problems existed nr.d the generic aspect >. were not coasidered.
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The alleger stated that an audit of dmwing serica 0-422 might
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Investiga_ tion and Interviews, On June /..1975, the ERC investigators discussed design criteria, design control and design changes with DPC Lesign Engineering and Quality Assurance: personnel.
DPC personnel stated that all. drawings are checked by a checher prior-to release.- The final release requires a three party signof f by
- representatives from the Mechanical Division, Civil Division and Electrical Division.
Subsequent to release, no design or drawing
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The field has no authority to deviate fron design drawings or standards
. uithout prior approval by Design Engineering. The Variation Notice is the neans by which. design chant s were accomplished.
Instrumentation installations are specified on an instrument detail drawing which is a schematic representation of fittings, tubing, piping-an'. valves. 'The actual installation is done by " controlled field routing" d
as specified in Appendix 1C.3.5 of the FSAR. DPC personnel stated that instrumentation standards were issued in February of 1973, but prior to
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that time no formal. standards existed. Decisions ucre based on the experience of the field personnel.
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On June 5,' 1975, the ERC investigators inspected instrumentation related to 'the borated unter storage tanks on Units 1 and 2 and the reactor building ventilation cooling water system for Unit 2.
The installation was inspected to verify conformance with DPC instrumentation standards contained in Mechanical ' Instrumentation & Control, Instrument Standards, installation Field-Practices and the design drawings, series 0-422.
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The borated water storage tank level instrumentation consists of tuo redundant channels and is detailed on instrunent details 0-422-x-13 and 0-422-x-28.
Variations between the detail drawings and the insta,1 led system Luere.noted by the investigatues. For example, Valve V17 is shown.on drauing 0-422-x-13 but is not installed. An isolation
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. valve is -installed betueen 'the' regulator and instrement RT6, and an
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l isolation volve' is installed in the return air line, but'netther are shown on the detail. The datall shows the regulator and a local-indicator to be installed outside the protective box but both are
! installed.inside. Sin 11ar discrepancies were noted on the Unit 2 barated vater storage tank 1cvel instruments and the. reactor building
Lventilation cooling 'uater system. DPC personnel accompanying the NRC investigatoes stated that all ONS. instrumentation was installed to the same criteria and that cll cystems would exhibit similar discrepancies
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' betueen the detail drauings and the installation. The actual installa -
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tion f acilitates :caintenande ~ and calibration activities; -the systeu,
'if installed in accordance with the dravlugs, uould not.
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t DPC personnel :.t ated that instrunentation IJnea were fic]d run and only the Inst ronent locat lens uere shown on drawings.
Icola tf o r valvea, local pressure ganes, ait regulators and so forth uare not nhown on the detail drawings and hence any change of these i tenr.
uns not the subj ect of a Vtl.
The investigators had no quest. ions concerning the field run installation of sensing lines and the lack of detail shtraing ells, tees, and couplings for these lines.
11ow-ever, concern uas expressed regarding the lack of detail showing the isolation valves, local pressure gages and installation of air regulators.
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The investigators reviewed the grounding philosophy and criteria used at.05S.
DPC personnel stated that there vere three nain grounding systems namely, station ground, instrument ground and computer ground. Some confusion existed in 1972 about ground terninology and DPC issued a nemo on June 27, 1972, to clarify this.
Standardizing grounds terminology and symbology is necessary to reduce the chance of improper interpretation of design drawings.
DPC personnel stated that no major noise, interference or grounding problems had been experienced at ONS.
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The investigators reviewed drawings OEE-15, 0-903, 0-1903 and other drawings related to the ground system at ONS. The ground system was inspected at celected points and compared to the drawings.
Drawings 0-7 89-C, Revision 6; 0-1789-C, Revision 2; and 0-2789-C, Revi.sion 1 ~
applicable to Units 1, 2 and 3, respectively were reviewsd.
These latter three draaings are f-or transducer terminal cabinets and the latest revisions cef errect to SMX-21/-D.
The drawings had reterences either to OEE-15 or contained notes defining the ground terminology.
The equipcent installation was compared with the engineering drawings and the isolated ground traced from terminal blocks to the central bus.
No discrepancies uere noted. SIIR-217-D uns a nodification to add a 250 ohm resistor in series uith PT 14P and power supply.
The Srs appeared to be conplete and the documentation, including the drawings, were in agreement with the installation.
SMR-060-S, a station modification to add an addi tional compurer alarm as an aid for operators vas. revi.med end the investigators had no questions.
SMR-130-S relating to the installation of Bailey Cabinet No. 15 in the control roon uns also reviewed and no discrepancies uere nne.
Conclusion The investigation conducted at ONS on June 5, 1975, appears to'substan: tate the allegation of the inadequacy of some drawings. The instrumentation ins tallations are not, in all cases, in accordance uith the design detail drawings.
Since the instrumentation sensing lines are field run details for each tubing or piping fitting are not required.
Iloweve r, sys tem components such as valves are required on detail drawings se that the true syst em configuration is availabic for reference at the site. Ot!er-vise, in the event of an emergency, any analynis based en inaccurate instrumentation drawings, cou.ld be in error and could lead to more sr
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consequences.
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f The DPC qualit y amurance prograu deacript ion is conta ined in Append!: :.
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of the FS!.R.
Pa ragraph ] n.5.2 stat es that ".
. all drawings an.1 prore-
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durcs for con..t ruction of the station prepared by Duhe, consultaul u, er vendors are revieved and approved by engineering prior to release to tht Construction Departrent.
Any changes to these taust he approved by tlw Eny,ineering Departncut
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fulfilled in that changes to the inst rument deaign have not been docu-ocnted and current drawings are not available. Also, paragraph 1C.3.5c of the FSAR states ".
. All field engineered linea are schenatically
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shown either on a diagranaatic, an instrumentation detail cr a pipin3 drawing such that nistakes in valving, connection termination points and materials are virtually eliminated.
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related systems exaniued by the NRC investigators, this commit. cent appears to have not been followed. Also, the investigators did not find any evidence that a wri tten safety evaluation. was performed, as required by 50.59(b) of 10 CFR 50, to ensure that the installed changes from that described,in the FSAR.do not involve unreviewed safety questions. Failure to conduct a safety evaluation of the safety significance of these changes and to obtain approval of the changes as required by the FSAR is considered an item of noncompliance with 50.59(b) of 30 CFR 50.
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Investic.ation of Allegation 3_
AllegatLonJ tlc alleger prepared a sign:d stata:nt (Atto:.:a n 1), d:W liny 19,11 ~ f.
allegin ; that clutpacut, unauttable for the application, i na been u.c and purchase of the equipment u ta based upon f-icadships and other f ute.n unrelated to the requirements necessary for. proper operatien.
Intervieu uith Allener The NRC investigators n.at uith the alleger on :tay 19 and June 3,1975, t'o discuss the allegation. Thu investigators attenpt ed to ideatify specific equipneat itens that could be traced through Ppc records as a basis to catabilch the validity of the allenation.
Ont the technica:
aspects of the allegation were investigated.
Tha alleger stated that DPC awarded contracts to nuppliers with
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no previous nuc1 car experience.
Ile referred to contracts awarded to Unit Electric Comp iny, Orlando, Florida, for control room equipment and panels at the ONS. He stated that Unit Electr ic had no previous nuclear experience but could not identi fy any specific deviations or inadequacies related to this procurement, either contractually or equipment related.
In response to questioning, the alleger said that he had not reviewed the procurement contract, had not beca involved in the preparation
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I of ti.e procureuent ::pecification and had not reviewed the specification in depth.
Tiie alleger also stated that D"C had t
auarded a cont.ract to some other f irms, which he could rat reca l l the nauen, to build panels and then had taifn tbc con trac t viay and gave it to Unit Electric Company.
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The a1)ccer stat ed that several hundred ITC Inperial J13P relays used
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Ills opinion was that
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these relays repreaented a neu design and were purchased without any DPCLt es t.i ng.
lie stated that he had not :revicued or prepared the procurenent npecification or contracts.
The alleger noted that considerabic purchasing power residea at the principal engineer level
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for procurement of relays, nuitches and cabinets.
In his statement, the. alleger specifies that "grandfcther clauses" effectively restrict the inclusion of now vendors onto approved vendor lists while assuring
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established vendors of virtual inclusion.
lie also noted that quality control. procedures and requircuents are supposed to be najor areas of concern.
Investigation and Intervicus On June 4,1975, the NRC investigators not with DPC personnel representing Design Engineering and Quality Assurance. The details of the procurement cycle were discussed and the specific procurements related to Unit Electric
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Company and ITE Imperial relays were revicued. DPC Procedures EP!t-1, i
EPR-2, and EPR-3 were revicued as these ucre procedures in effect during
the. time period in question. EPR-3 titled, " Criteria for Qualifying I.
- Suppliers of Nuclear Safety llelated Electrical Equipment and 11aterials,"
required pre-award and post-award evaluation of the supplier.
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DPC records were nade available for the Unit Electric Conpany (UEC)
A review of these recorda shows that D?C conducted a pre-avard contract.
curvey of USC on October 2.19,70, uhich is dace :ented on an Evaluation ::'
investigation of Proposed Bidder and Supplier Forn.
The survey-noted that this was the first to perforu nuclear vork.
DPC Specification j
03-309-1 for emergency power switching logic panela contained basic QC
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requirements and tes t requirements. The records include documentation-of subnequent surveillance inspection and witnessing of functional tests l
, at UEC. The cabinet's uere seisnically qualified by calculations in December of 1972, and subsequent seismic tccting of cabinet and components by Uyle Laboratories qualified then by test.
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j DPC personnel stated that for 035 Unit 3, a competitive bidder uns
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cuarded a contract f,or control roca panels and liuar da.
Ilowever, the l
company did not ncet schedules. The contract was cancelled and
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subsequently awarded to UCC, the second lowest bidder.
DPC Design Ecgineering personnel stated that the ITE imperial relay J13P'
uns nelected by Design Engineering based on design criteria related to
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' physical size, number of contracts e-4 voltage.
Previous experience with other nanuf acturer's relays prc J to be disappointing and the desir,
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of the neuly developed J13Pr appeared to ncet DPC requirements. The relays. were procured as a catalog item based on ITE supplied data.
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tlpe, voltnge drop-out, and simulated circuit applications to facilitate testing of the emergency start circuit. A neuo discussinp the test s dated August 21, 1970, included a reconnendation to use the relay in the start circuit.
The ITE records package uns revicued and extensive documentation uns
. availabl.c as objective evidence of tests performed, audits conducted
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and actlon taken.
During f unctional testing of panels at UEC in October 1970, ceveral of the relays f ailed or malfunctioned. DPC, in conjunction with ITE and Wabash 11agnetics,. conducted an in-depth f ailure analysis, test
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'and relay modification program.
DPC audited ITE and Wabash liagnetics facilitics and programs.. in June of 1971, DPC concluded from cyclical
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tests conducted in a dust environment at elevated temperature nud hunidity that the ITE relays were not acceptable for the intended application.
itens Cutler llammer type 11 relays were selected as a replacenent and test
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were subjected to cyclical operation under sinulated environmental I
.1-conditions.
Based on the test results and additional Cutler !!ammer data, DFC. felt the Cutler llancer relays ucre qualified for the intended applica-All of the ITE Inperial J13P relays were replaced at the OHS and tion.
Keovee Station. Th'e replacement uns accomplished in accordance uith a uritten procedura, was"uitnessed by a design enatucer and QC inspectors, and-lo fully documented in QA folder OS-S03. '1he investigators reviewed the OA folder for adequacy. Ac n final step to preclude furt her problem,
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DPC issued a letter dated Movenber 18, 19/1, to remove lie i elay.i itou s to ck. Tha investigators celected neveral pieces of equiptent ir.chich the original de.41ga incorparated the J13P relays for field inspection
'to verify that replacement had. been accomplished.
On June 5,1975, the investigators' inspected Kenuee Energency Start Channels. A and B at ONS.
Relays KB, SIB, and SESB in Channel B cabinet end relays KA, S1 A, and 8ESA vere-Cutler llacmer reJ ays and had been installed in accordance with DPC documentation and records.
Nnc Innpnctions NRC inspection reports uere reviewed for pertinent internation related to the 'J13P relay probleu. Reports 50-269/70-12 and 53-269/11-1 diccucs the relay failurcs. DPC reported the relay failure to NRC for _investi-gation into its possible generic inplications.
Conclusion
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- Tlie investigators could find no evidence to substantiate the al1egation that equipment unsuitabic for the application had been used. 11or could
.any evidence be found to substantiate the chzirge that procurenant contrac ts
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those auch as cost and schedulu uhich are normily consHered in the awarding of contracts. At the Line DPC avarde.! tiEC contrac tn, tiEC had previous i:xperience in-providing electrien1 equ i.p :.a nt for utility pwer
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,p an a lucludiun Florida Power and Liglit, South Caro]f na ElectrJe and cau l
t and' Carolina Pouer and Light..
In addition, Ur.C had r:anufactured equipment such na control panels for the I;ational Aeronautics c.nd Space Adninistration under stringent quality assurance requircuents.
It van felt that QC unu cot mensurate with the nize of the co:npany and that. DPC would have to provide assistance, in-interpretation of IEEE-279 and Class IE requircoents. Severnt other - suppliers with previous experionce, bid for the uork and considering all. factors, DPC selected UEC..
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C0PY Attachment 1
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1, A voluntarily give the following statements to Frank Jnpe and Dick Parker, who have identified themselves to ne as representatives of the U. S. Nuclear Regulatory ComJnission.
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Atte.ched are twenty (20) sheets of related information substantiating the followl.ts:
Quality functions at Oconee Nuclear Station were hampered by their 1.
being " controlled" by Technical Support.
' Design Engineering produced a less than adequate set of drawings 2.
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because of poor engineering practices in accuracy, usability of drawings, training of personnel, and other reasor1.
3.
Equipment - unsuitable for the application - has been used; purchase of much equipment was based upon friendships, and other
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factors unrelated to the requirements necessary for proper operation.
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Signed:
A May 19, 1975
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Supplementary Information Duke Power -Company entered the commercial nuclear power field with Oconee, a.three-unit station.
Many serious field problems occurred in lnit 1 from l
Initial construction through the transition (systems turnover) to an operational phase.
They ranged from schedule disruption to catantrophic equipment failures.
The source of those problems uas undefined.
Was
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equipment being utilized improperly? Was this inherent in nuclear facilities? Could it be sabotaged,7 Those were some of the questions belug asked. Tne steau Production Department requested assistance to locate the source, solve the problems, and prevent recurrence in later units.
Design Engineering management volunteered personnel for the task assuming the fault origincted elsewhere.
Mr. B, Chief Electrical Engineer
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selected me to represent the Electrical Division in an onsite inspection requiring coordination between Engineering, Construction, and Steam
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Production.
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Field experience demonstrated problems and errors were numerous and repetitive.
A few thousand Unit 1 changes were formally documented; perhaps
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a similar quantity were never documented.
Analysis indicated the majority
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l were attributable to improper engineering practices in Design Engineering.
Poor drawing practices including failure of personnel to properly implement changes, a casual attitude regarding the accuracy and checking of drawinsa, and indifference for the drawings' utility were among the core prominent An additional problem beginning with Unit 2 was failure to implement causes.
changes on subsequent units.
L during visits to the Charlotte office.These problems were discussed uith ny cupavio- -
When they realized the magnitude of j
problems created by Design Engineering, they bec~
reluctant to improve f
the situation.
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l They insisted on neeting schedul-
'lorities in designing-Valt 3 and other new fossil, hydro, and nuclear of Design nanpower for Units 1 and 2.
.wiens - forcing curtailnent l
e Upon returning to Charlotte, I assumed the position of staff engfueer for Mr. C. Principal Engineer in charge of Electrical Control and l
Instrumentation Design.
One of my responsibilities uas un' overall
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Inspection of Oconae drawings before issuance to alleviate past problemc.
.iny changes 1 considered necessary were to be enacted if a paximum of one day's delay was observed in drawing issue and if no
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Design Group Supervisor raised an objection of a technical nature.
-Those Supervisora vere under extreme pressure to release drawings for neuer stations by a nanagement that considered Oconee complete.
Even though Nr. B had assured ne the required authority accompanied the responsibility, hr. ' C virtually ignored my repeated requests for ass tatance to offset an excessive workload and to avoid further delays.
The Supervisors'
resultant objections became purely arbitrary because of tight, unrealistic l
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nchedules established by management.
Mr. C preferred to avoid intervening I
in disagreements between the Supervisors-and myself.
Instead, he
followed Mr. B alleged insistance that drawings be issued regardless of
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Thn combJnation of factors - adequately revicuing drawing.;, management's attitude, and other dutics -- created very unsatisfactory corhing conditicas during the next fourteen months.
The situation of havJng been assigned renponsibility without meaningful authority led to my serJously considerin,:
outside employment.
Ilowever, I felt a responulbility to alleviate as many of the problems as possible within the guidelines established, realizing the,y would remain uncorrected otheruice.
On October 10, 1974, during my first work performance appraisal in approximately eighteen months, Mr. C requested ny comments.
The points listed above were given with the fact that had made a conscientious effort to improve employee capability, cfficiency, and morale uhich would have resulted in better work performance - both quantitatively and qualitatively.
I requested treatment commensurate with my performance and qualifications.
Because of unresolvable differences of opinion, he suggested I contact Mr. B.
My tarliest opportunity to see Mr. B vas preceded by Mr. Cs conversing with him.
11r. B was callous to my viewpoint, accused me of disloyalty (insubordtaation?), and frequently stated that only his
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opinion counted and mine was unimportant. The only possible question involving my loyalty is that of why I refused to blindly accept Mr. E
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directives and to "go along with the crowd, and keep my mouth shut."
On October 11, I was fired by Mr.
D, Vice President of Design Engineering following my refusal to resign.
Summartzing, my dismissal resulted from a personality conflict arising Io.c a...
T.c hw rn.r y.e pone engitu.ycing p:-w.im ehl_h.fe ce
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violatin:: professional ethics in matters involvJng publje safety.
Ihnagament resented being asked to remedy those ahortennings, and resented my refusal to realgn.
I have reason to believe that Duke Power Conpany nay give misleading informatica regarding my work performance and/or subr.cquent dismissal.
You may contact my other employers without restriction, but all informacian exchanged bet"een you, Duke Power, and agents representing either organization must be written; no verbal exchanges are permianible.
No.
tnconditional release will be given concerning any Duke Power nuppiied info rma tion.
I request that any decision concerning my enploycent be based upon accurate and complete inforcation; therefore, I uill be pleased to answer cay questions arising from uritten information.
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'Ene16aed are-two copies each of:
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Mr. F'n letter of l'ovember 20, 1972, on flow instrumentation.
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!!r. C's letter of September 26, 1972, on QC responsibilities.
3.
!!r. H's letter of October 5,1972, on instrument installation practices.
4.--Mr. I's letter of November 20, 1972, on preliminary instrument standarde.
5.
Station Problen Report Number 94 of January 20, 1973, on poor installation of instrumentation.
6.
Instrument Standards-of February 8, 1973.
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Mr. J's letter of February 9, 1973, listing questionable items of instrumentation.
V QC was unable to obtain a clear definition of their responsibilities prior to item 2 above. This was issued shortly after Mr. G replaced Mr.1; as !!ead of Tech-Support.
Repeated requesta of 1; fro a J produced no results. J repeatedly told me that QC was unahic to look at the 10 CFR 50 or TSAR. That letter further illustrates i.hr actions by
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tech-sirpport to prevent proper functioning of QC. Soon af ter my first conversation with you approximately one month ago, I asked L to let
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me look at their copy of the two docunents.
Immediately I; sharing an office with L became quite sensitive.and defensiva that anyone chould want to see the documents, lie quickly explained that one was a collection of "motherhoed" statements, uhich vould not provide ne much information, and that the other book was available in operationa.
Nevertheless, both virtually refused to permit me to vicu their copies.
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I feet that aforementicned parties 'in tech-support are delibarately trying to cover their asses and raake it lock as if there 2s a good QC
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program at Oconee, in-fact, QC is being used as a front to make those
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efforts look legitimate to the AEC and anyone else concerned. QC's b:inds are presently tied because all QC work must meet approval of tech-support.
I have been told by you and others in Charlotte that QC is not supposed to be limited by tech-support.
In reality, the opposite is tr.ae.
Further, J told me of repeated efforts via Randon Insp2ction 11ork Sheets (RIW) to get instrumentation problems solved.
In: stead of correcting problems, M sent the request to construction -
who said that installation' was acceptable - and then M returned J's RIU's
.uith answers that generally meet the criteria.
" Construction says it is okay, and that is the end of_it.
It is none of your busiacas to pursue
.the cittar further, "or that M didn't give a damn about correcting the problem.
If a diacrcpancy existed between the engineering prints c.nd io.stallation, than a~ variation notice followed to change the drawings,
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but neldon were the innta11ations changed. This attitude of poor or no quality ef fort o in Justa11atin is especially painful in the case of-sensitive equipnent, such as that which would be advernely affected by improper installation (ref letter of October 5,1972).
Also, C, K's yes can - has told QC that no ef fort uill be made at making the Instrument Standards retroactive.
Ins'tcad, anything wrong vill remain so until someone raises enough hell in the right places.
There are many areas of which I am totally ignorant which should also be ideal sources of information such as - but not limited to -
. construction departments.
Because of the above and other leads,I have and/or am pursuing, I feel that a completely unannounced freeze of all variation notices, all RIU's (formally QC-53's), and a conplete check by qualified people thoroughly
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familiar with correct instrumentation installation and all QC records i
on site would identify nany problems of which I feel are not in the best interests of Duke.
Further, confidential conversations uith ixiny individuals working on-site should identify t:any other problem arean which may not be documented.
1 must stress the irportance that any 'inforcation uncovered will probably be dif ficult to prove, and that heads of innocent vorhers in no uay responsible for the decisions vould certainly roll if persons involved even cuspected such' an investigation was being held.
Please handle very confidentially all information you receive because of this.
J quit last l'riday to work for another firm out-of-state.
1: fornerly of tech-support, replaced him.
If I can be of further assistance, please do not hesitate to contact -
me.
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i Respectfully, A
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Signature burch 21, 1973
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Y.cn April 2.. 197's
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I have reanon to believe that enttain Judividualu Jn renponsible position 4
of Dohe Power Corp;my Design Engineering Department and Mill Power Supply Company-Duke's purchaalng agent-are acting in their own Interentn, to the detrinent of both Duke Power and the public.
I.e t r.e describe a bit of my experience uhile nt Duke Power, prior to explaining the above statement.
I began vorhing for Duke as an Engineer Associate in the Elect :1 cal Controln and Instrumentation group on thy 31, 1970.
Duties included the design of Keowee 11ydro Station, Oconee Nuc1 car Station, and other plants as well as the occasional investi'gation of special problems.
O, another newcomer to Duke in early suumer, 1970, and I vorhed under the direction P for several months, in design and checking drawings on Keowee, the emergency power source for Oconee. C began placing complete confidence in P decisions, and avoided trusting anyone else.
If a dif ference of opinion occurred, P comments were those used by C.
Knowledge and experience were discarded, a pattern used to the present time by C if P is remotely involved in a decision.
P experience prior to joining Duke in late 1969 or 1970 was graduation from high school i
followed by a tour in the U. S. Navy aboard a submarine.
1 na uncertain,
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but it nay have been a nuclear-powered ship.
Under O's direction, the compicnity, equipment required, and attendant costs of Unit 2 were reduced by come fifty percent coreared utth P desiga of Keowee Unit I controls.
I will not elaborate, but neveral,other inportant comparisons can be cited choning the contrasts in these persons eethods, that of brute force versus an overati view a ' objectiven with suf ficient ability to succeasfully manage a task or project.
I performed several engineering taska in addition to Keowee design through nummer 1971. Approximately May 1971, it was discovered that Oconee Unit 2 uns not a mirror 1 mage of Unit 1 as Duke had told the AEC it vould be in the PSAR, and later uould he included in the FSAR.
Civil was the least af fected Enginaering Division by this change, often called the "A & B swap", or "buildlug roll".
In contraat, the Machanical Division was required to make a substantial number of changes, and
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the Eleettical Division considerably are.
Several peruona :are involved in the summer and fall,1971 r d.ing those changao.and checking s
them in Electrical.
Late in 1971 approntrately six to eight persons-including triself--ioined those already involved in a thorough recheck of Unit 2 drawin2s. lhe number of persons rapidly dialnished until only three of four total ucre working on Oconee, two part or full time by nidwinter.
The others began working on Belews Creek and other projects.
l'aay of the errors discovered during those checks were ultimately lost because a majority of the drawings narked with corrections uere lost or destroyed. Most of the remaining marked drawinga were lont 'chen Design EngineerJng noved to its present location in the Charlotte Trade Mart in summer, 1972.
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Ideally,1ngineering designs a system, Construction innta11n and verifica that all equipnent operates, motors and pumpn rotate in the proper direction, instrumenation is operable, ulth lialnon provided by Field Engineering to resolve problems, and finally a nysten is released or " turned over" to Steam (Operations) uith a list of thone items missing, broken, etc., required to complete the system.
Tn practice, Oconec 1 cystema uere turned over to Steam in an incoaplete, and otheruise unacceptable manner.
Steam Department managers nuspected nany of the problema inherited uere avoidable and should be reduced to an acceptable quantity.
They requested the loan of one representative cach from !!echanical and Electrical Divisions to work one year oneite to perform a special check prinarily for the benefit of Steam. This consisted of identifying all the equipment in each system, verifying its installation, identifying missing and/or damaged equipment, and tabulating any auch equipment or other discrepancies.
Engluearing i
would benefit from personal involvement in checkout and the experience gained.
It should also provide a means for identifying good and bad
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I features in their respective modus operandi.
Q uas celected to represent Mechanical, and 1 to represent the Electrical Division.
In late February, 1972 I arrived casite, uith Q co:ni.n3 one month later.
I varked for R, Supervinor of the instrumentation Department.
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Generally speaking, &chaniaal dealgns the procesa syste.n, and det erninen the controls necessary for operation, as wellan instrumenation required for monitorlag.
!!achanical determines size, Jocation, and type for each valve, pump, pipe, and instrument, as well as identifying each device.
hte that nay items supplied in a purchased system utl1 be identified by systems nanufacturer, such as that of a nuclear steam nupply systen and util theceby acquire duplicate identification.
A third isthod of identification could and frequently did occur at Oconee uhnn Steam r.ctached ita identification to a device.
Virtually every such iten at Oconec ncquired either double or triple identification.
Af ter !!cchanical has aesigned its own set of identificatic.n to purchased systems and included only that identification on &chanical drawings, the key for relating the tuo sets is discarded. Several months later Electrical must extract information to properly identify each device nuch that the electrical portion of the engineering package for a plant can be drawn.
At this t Eme the information desired by Stcan cust be included on the electrical drawings.
I shall give credit where due eith this point?
Steam now agrees to use the identification attached to an item by Engineering, reducing confusion considerably.
One can only hopa
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this, or a similar problem, will not be reinvented through a lack of f
experience, or otheralue.
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A nue*mor unit hau neveral hundred each of procean, cont rol
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Inut rum ntat ion draulngs ulth numerous ancillary drawings
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, and etc.
tabulations,
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Hy'three assiutants-part tine coployees who were engineer at lCicusen University-and I catalog.ued the power sources,ing students i
instrumenation, and all interconnecting cables required for eachcontrol equipme An inspection team comprised of one person from 76chnical Support system.
from our group, and a construction electrician verified installation of
, one all equipment in each system as thoroughly as feasible using Engine drawings for a guide.
These inspections were expected to occur after systems were considered complete, but prior to actual turnover.
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These types of errors were observed 'n installed equipment o
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Incorrect field installation which disagreed with accurate Engineering drawings.-
2.
Installation per erronious drawings.
3.
Installation corrected by construction, but drawings remained uncorrected.
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Electrical terminals unidentified by equipment manufacturer because~a sintlar contact was used instead of that ind
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drawings.
5.
Unacceptable inscallation practices upheld by person (n) responsible for their avoidance.
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. Solutions to the above problems varied, but usually followed this patt respectively:
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1.
- The Construction elcetrician.nade minor corrections "on the spot "
Large probleng requiring coordination with other departments were
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tabulated, and appropriate personnel were provided a copy Construction made modifications, and later inspections determined
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the remaining problems.
2.
Technical Support contacted the. design supervisor responsible for
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that. system and verbally described the problem, proposed a soluti and :rece1ved a verbal agreement to the solution; otherwise the
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on, supervisor suggested an alternate solution.
' Tech Support then initiated a variatica notice -(VN) to alert Engineering of the chang required and to permit Construction to make required changes without es waiting for revised drawings. -
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The VN contalued npace to ident Lfy which unitu(s) ucre af fected.
If Technical Support falled to indicate all the affected units, or if Engineering failed to make the required changea on all af fected units, it became necessary to solve the same problen repeatedly.
The latter "If" occurred profusely because Engineering managers nivays stressed the intent to get drawings to the fjeld for the unit considered most needed while choosing to ignore all other
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3.
A VN should have been uritten to cover this situation since it involved deviating from Engineering drawings, even if it una required for proper sy9tems operation.
C, my Engineering supervisor, and I had several lengthy and sometimes heated discussions regarding this issue. He contended that any deviation should-and would-be covered via VN.
C philosophy was that problems could not exist in the absence of a documented account from the field, therefore, do not attempt to make corrections unless the field n. aplained loudly and frequently. My experience at Oconee led
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na to believe that many problems and resultant changes were concealed forever because of insufficient documenation. 1:any such losses resulted from someone's forgetting to notify those responsible for followup of problems, but I feel that a substantial quantity uere deliberately
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overlooked because it would have required sonence's tire and effort to properly docunent tha nituation.
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Another explantion was that VM's and subsequent drawing changes vere being processed, but were currently unavailable.
This condition was acceptable and neigher caused nor resulted from the previous situation.
4.
This type prob 3ca'became less frequent than several others during Oconee's evolution because Engineering issued standards for identification of equipment terminals, cable color codes, etc.
Nevertheless, several (
drawings were revised only because Construction installed equipment incorrectly, verified systen operation and lastly notified Ea+;ineering of l
the problem.
Drawings uere changed rather than argue over the problem.
f 5.
Prior to Ocones, Duke installed littic or none of the instrunentation required in its plants. An outside firn uhose specialty vaa instrumentation
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prov]ded those services.
Oconea instrumentation una installed by persons professing similar experience. No Duke standards e :isted regarding proper installation until well into the construction phase
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of Unit 3.
The installation at best reflected those principles learned on previous projects in a multitude of industries.
- 1 npplied for enployment as an instrumentation specialist in Technical Support at Oconee. He was refused employnent ensite and contacted sancone in Charlotte.
That same someone instructed Technical Support to erploy M immediately.
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Au ' uudenirable cituntlon involving M occurred frequently.
Suppose
..Conatruction has installed an instrument such that it operates improperly.
Piping for the instrument may'be sized. Improperly; it could require additional-outlets for purging; tha slope of the piping may be Jnsufficicat.
Most iuportant is the possibility that thick-walled piping, capable of ulthstanding clevated' temperature and pressure in a highly radioactive environment, han heen welded, rridiographed, and considered complete.
= Regardless ~ of the nature of an instrumentation problem, Construction of ten contacted M, uho issued a VN to change any drawings in disagreement.
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Attached ace copies of letters and memos relating numerous problems as viewed by key personnel responsible for management of Oconee during both construction and operational phases.
During my residency at Oconee I beca' e acquainted ~ with many persons m
throughout the system in capacities ranging from laborers to departmental supervisora.
One such person was J who was employed in Quality Control as an inspector for a few years.
In March, 1973 he resigned to accept
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othar employment outside Duke's service area.
J related r.my incidents such as that described above involving 't.
Other incidents involved K, who vas second in Co.uand in Technical Support cnd reported to L.
At the time Quality was actually controlled by Tecnnical Suoport, reward. lens of contrary claims. Eersons in Quality repeatedly requested a written list of their duties from K since his verbal comments were undescriptive and generally useless.
Those same persons repeatedly asked for and uere refused access to 10 CFR 50, PSAR, FSAR, and other documents by K.
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In ' late summer,1972 I contacted L and requested to vicu a copy of 10 CFR 50 and any document describing general duties, responsibilities, and nuthority of Quality related personnel.
K, sharing the office space with L, immediately became indignant because anyone would cake such n request, and suggested 1 view a copy available in the Steam Department.
He emphasized those documents contain only "cotherhood" statementa and are so neceral (vague?)
that little if any useful, specific information can be obtained from them.
1 concluded that J statements were correct, and K uns totally unconcarned regarding the true intent of Quality Control.
G replaced K uhen the latter was promoted. On Septesber 26, 1972, G issued a ten-iten directive listing "the official interpretation of responsibilitica for Electrical and Instrumentation QC Inspection."
The. enclosed copy shows.that QC is rendered incapable of making a binding
. decision and is conc Ldered to function entirely subservient to outside
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groups. This implied that QC vas exactly what had been sustpected-a spincless, paper organization whose sole purpose vas to answer AEC questions.
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ltealizing the nituation,.I contacted E, the Director of Qtiality related Iunctions in Dant;;n Engineer 1ug's Electrical Division.
!!y letter of Ilarch 2.1,1973, -and a.11 documents referenced therein uere pernonally
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delivered to E.
Ua alao discussed ny overall irpression of the circustances at Oconee.. Ile suggested letting hin pursue that matter further through channels and informing him of any further. developments.
I agreed, and contacted him,later to determine the results of that information. He stated that the proper-persons were working on it.
K'is presently a Quality llanager in the Electrical Division, and reports to h, according to sources within Duke Power Company presently.
While working at Oconee, I maintained ' contact with my supervisor and B, head of the Electrical Division.
It was erphasized repeatedly that many problecs could be avoided by adequately checking' drawings, prior to reissue, rather tham
- depending upon field personnel to find errors. I had carried marked copies of current drawings to C several tikes requesting his. people transfer the information exactly as shown on the nacked drawings. Rarely did that inforrazion return ' to the field correctly.
i During one of his mid-summer visits to Oconee, B and I discussed my future role in the Electrical Division. I would be responsible for inspecting all electrical control and instrurentation drawings prior to their issue or reissue for field usage at Oconee. 1ly asking "Poes this nean I uill have the authority to get things done, or caly the responsibility?" uds answered, "Teu will hava bc:h respencibility and authority fer m'.in; =y uW:es. ; urrea,-
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nonta, or uhatever".
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Upon returning to the of fice Septer.ber 3,1973, I cas given relatively f re reis.,n in inspecting and improving the drawings issued by the Electrical Controls and Instrumentation Design.
I uas instructed to avoid delaying cny drawing more than one working day, and doing anything which could af fect th e safety and/or operation of the plant.
For the first few nonths I was severely
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overloaded and requested assistance which never arrived except for tuo and one-half man-days help on computer inputs.
I wrote B a letter in nidsummer,1973 containing 14 suggestions for assistia;.
and improving the Electrical Division.
C and I discussed that letter in October.
During the discussion I volunteered a concent ralating ry feelings that it uas rather obvious that at least one, perhaps several, persons wera involved in arrangement with.'a vendor, and I expressed ny hope that he uas not' involved.
I had no conclusive proof and readily acknowledged it.
However,.
1 refused to furnish nanas as he had requested,' hut I did compare the situation uith Uatergate with possible strings going toward the top of the Company. 7:a e -
subject uas never again discussed between C and myself.
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~11y employment uith Duke Pouer ceased October 11, 1974 uith c con =ents, n concurrence, and D piving re a choice of resigning or being fired.
I refus=d
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The f ollowing liuts the individualu, firns, and other infornation duncribing the' situation in which I suspect Duke Power Company's supervisors are involved
- much uore than is acceptabic in a legiteate businaus reintionship:
Several hundred ITE ILyerial series J13P industrial control relays used in
- Koowee and Oconee control systems required replacement in whole or in part three tires. Those relays represented new desirm, and were purchased without any form.of Duke testing, but with the encouragement of S, Principal I
Engineer superviuor of Electrical Control and Instrumentation Systems.
believe this was ITE's first attempt to produce such a relay.
Consider the fact that. virtually all the controls for Keowee nnd Oconee Unit 1 were installed and operative during the exchanges.
It was connon knowledge that larranged fishing trips for the benefit of its customers. B definitely exercised undue' influence and poor judgement in selecting this particular equipment,
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and possibly received other favors from 1TE for their actions.
Approval for a purchase requisition' varies depending upon the value, but it permits considerable purchasing power at the levels of Principal and Chief Engineer, especially if the purchase is piecemeal. Typical of this situation is the purchase of control relays, switches, and cabinets. Larger acquisitions are influenced by an Engineering evaluation of the bidders' f acilities, quality control program, prices, and any other information considered necessa
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One important criterion is how " closely" the vendor vorhed with Duke in past contracts.. Grandfather clauses ef fectively restrict the inclusion of
- nei vendors onto approved vendor liata uhile Loauring establishad vendors of virtual inclusion.
Qun11ty Control procedures and requirements are supposed to be ma, lor-areas of comden. Mill Power evaluates the package cad awarda the contract -toLthe succeaaful bidder.
Unit Electric of Maitland, Florida has been the cuestionabic recipient of several Duke contracts for building control panels, consoles, erc during the past three in four years. Unit's first nuclear experience was at Oceace, with little or no changes nade from their previom non--nuclear power plant designs. Unit can now clain extensive experience in nuclear designs without question.
In ny opinion S, E, C, and T and other Principal Electrical
' Engineer, with U of I!ill Pcuer are deeply involved.
The aforerentioned individuals as well as other Engineering representatives were ' visiting Unit on a Thurnday and Friday in 11ay or June,1973 f or the purpose 'oE i~nspecting control boards.
S, B, C, and T vere not inspecting equipment 'as alleged;. rather, they were elsewhere. Deducing from their invitation which V declined to accept and other people'n observations, they remained in florida af ter Thursday for a corhination fishing and/or boating. excursion complete with feminine companions.
I feel it uou14 4e reasonable to state that other " inspection " trips uere equally fictie tous.
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-M,-~ a' Unit. repret.cntative located in' Charlotte, host:
S, M,' C, T and U to-Junch:'nt leant once cach week. Ocasionally otheripersona have been invited
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uhen sorne of the above are absent. W conversations irnp3y that the luncheon
'in :usually non -business related.
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.1 realiza the 'above information is brief, but it is a collection of:
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observations by r:yself'and others.
So far.as we know there will he no written proof anywhere as all arrangenents were surely handled in person.
or via telephone.
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ikiten of General-Problems Observed Uhlle C Oconee
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Probleas. obr.erved at Oconee and discussed uith B and/or C ucre numerous, frequent, and repetitivo.
Basically, Design Engineering personnel were careless in their checking of control drawings prior to reissuance to the
' field,- or ' vere completely ignoring the true meaning of " checking" a drawing.
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Another major problen uas Design's attitude that "any coincidence between released drawfngs and their usefulness to field personnel was unintentional."
Many times 1 have heard C and others in Design say the nost inportant thing is to get ' drawings to the field, and concern ourselves uith finding and correcting errors at some later date, i.e. drawing revision. Each time this ruas expressed. it was attributed to B initiation.
In reality, the field (construction) personnel were the ones who found and corrected the trenendous quantity of' errors on each unit. Variation notices were the method nost of ten used by field personnel to notify Design of errors on problens which vere solved' or changed to facilitato usage, and required a drawing change to acknowledge thore nodifications.
I contend that acurrate drawings do not require complete and repetitive checks to assure their correctness.
My_ frequent requests for improving accuracy and usefulness of drawings was
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essentially ignored by C and others.
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ltens uith uhich I disagree in part or in whole with C - Summer 1974.
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C's refusal to try to correct all grounding s'wtches on an s, uhile belus repeatedly cognizant of the problems in the fic.ld due te poor infornation and/or conflictiny infornat to, *,u ned,-i., Dcuign enginse'e-
(1) Verbal, (2) letter, (3) S:tRO-60-D.
2.
Despite un obvious and c:: pressed need for full-time assistance, C has
. provided only one half ueek of it via X during the ueek prior to Chris tmas, 19 73.
It was expressed that conputer and a Li other areas of string checks vould he parformed, yet only those relating directly to the computer were given any checks.
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3.
Regarding ny letter of summer,1973 to B deferring scree 14 areas that should be iuptovwd, C and i worked late one night in thelarly W.11 discussing those items.
Since then no other discussion has eusued,
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and it is.quite obvious that pany of the points centioned are in no manner being actively icproved on future stations.
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~ ' Sep'te.:bf r 26, 1972
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Ef f echive $tnedintely," the 'following is the of ficia'l int'eiprEtction
- of L hef :respcnsibilities f or : Electrical. i.nd Instru:entction QC Ir.s pec-
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tion.
-1.11hc QC Inspection group is not directly responsible for the con-
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tents of ICC'!230 or the FSAR.
All interpretations of these two doeurents sh:11 he obtained from the Field Engineer.
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2.
The ccount, cost, or tima' spent on rework is not the responsibility and shall not concern QC Inspection.
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3. - Unless 'noted on prints, the serviceability of equip =ent installed
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is not' the responsibility of QC Inspection.
Questions as to the
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serviceability _or the recoval of equipcent for calibration or repair uill ba submitted by Operations to Design Engineering.
- 4.z It.is not the responsibility of QC Inspection to revicw or ques-
' tion the design of a system or instrument loop. The responsibf.11ty t
of QC Inspection to the Construction Dapartment is to see that the equipment is installed according to applicable printa.
The design. of-a systen is the responsibility. of Design Engineerin3 If fer =ny reason a systen does not perfer= its intended function, Operations u til submit a request to Design Engine.ering en have enr.
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design changed.
No technical questions. uill be subnitted to :
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. Construction Technical Support or any other departcent.
l 5.
There vill be no suggestions to field forces as to the best 727 to install any equipment.
Disdrepancies may be pointed out to
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field forces.
If discrepancies are 'not corrected af ter bein; pointed'out, a Random Inspection Ucrksheet should be written.
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6.
0bvious errors on prints,. details, OM drawings, Variation notices,
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or pertaining to the installation of equipment, vill be vri::en up-
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on : a RI'J.
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'7...The use of the RIU uill be limited as stated in paragraphs 5 and 6.
No' suggestions or requests will be note ~d on this form.
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8. _Any answers received f rom Technical Support or Design Engineering will be final-and not questioned a second time.
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'9; Suggestions nay be submitted through normal channels, but on either blenh stationery or cocpeny stationery, and only pertaining to the
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QC program.
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[ 10.. The issuing.of-standards. for Construction and QC will be done by
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LDesign EngIncering.
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