IR 05000341/1979009
| ML19269E168 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/16/1979 |
| From: | Danielson D, Marsh R, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19269E161 | List: |
| References | |
| 50-341-79-09, 50-341-79-9, NUDOCS 7906260598 | |
| Download: ML19269E168 (13) | |
Text
{{#Wiki_filter:. U.S. NUCLEAR REGULATORY COMMISSION . OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-341/79-09 Docket No. 50-341 License No. CPPR-87 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Enrico Fermi Unit 2 Investigation At: Enrico Fermi 2 Site, Monroe, MI Investigation Conducted: January 3 and 4, 1979 hh l'L . 'f_p, - Investigators: K. D. Ward /. / '(Date) k h
- 'd' /7:l
.\\/ (Date) 7E/ b u b Approved By: D. H. Danielson, Chief 7 /f Engineering Support Section 2 (Date) h.MO M 6 !7'? C.
E. Norelius ' Assistant to the Director (Date) Investigation Summary Investigation on January 3 and 4, 1979 (Report No. 50-341/79-09) Areas Covered: Because of allegations of records falsifications, reviewed qualification and certification documentatira for selected individuals performing nondestructive examinations (NDE), reviewed NDE work logs, and conducted interviews of personnel.
The allegations were basically substantiated.
Results: Two items of noncompliance, both infracti* ins, were identi- -- fied: (1) 10 CFR Part 50, Appendix B, Criterion IX - inadequate - .., 4.
- qualifications of NDE personnel; paragraphs 3.a 3.b and 3.c, (2)
, 10 CFR Part 50, Appendix B, Criterion XVII - maintenance of test ' records.
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. . . INTRODUCTION The Fermi 2 Nuclear Power Station, licensed to the Detroit Edison Company, is under construction at a site near Monroe, Michigan.
Sargent & Lundy is the Architect-Engineering firm for the plant, which is being constructed by the Daniel International Corporation.
The facility will utilize a Boiling Water Reactor (BWR) designed by the General Electric Company.
The Materials Assurance Company is one of several subcontractors supplying nondestructive examination services for the Fermi 2 site undcr contract to General Electric, Installation and Service Engi-neering Division (GE, 1&SE) Oakbrook, Illinois.
The nondestructive examination (NDE) services provided by the Materials Assurance Company to GE/I&SE are limited to penetrant dye and ultrasonic testing (PT & UT).
NDE personnel are hired by Materials Assurance Company on a consultant basis and, following qualificat'on and certificaticn by Materials Assurance Company, work under tue supervision of the GE, I&SE Quality Assurance manager at the construction site.
REASON FOR INVESTIGATION On December 13, 1978 a telephone call ecs received by Region III in which it was alleged that the Materials Assurance Company (MAC) was employing irregular procedures, including the falsification of records, in the certification of its nondestructive examination personnel. A personal interview of the alleger and an associate, conducted on December 15, 1978 elicited detailed allegations and documented examples of what were purported to be falsified entries in the certification records of MAC personnel.
As a result of the receipt of these allegations an investigation was initiated by Region III.
SUMMARY OF FACTS Evaluation of the information supplied by the allegers (Individuals A and B) in the phone calls of December 13, 1978 and interview of December 15, 1978, resulted in an agreement with Individuals A and B that the following allegations would, as a minimum,,,be investigated: _ "ky '.; -
- - -
1.
Falsification of Certification Records - Testing 4: - . e-2-2}hk
. . . 2.
Falsification of Medical Certificate (Visual Test) 3.
Suspected Falsification by a MAC examiner of past experience and training entries on MAC's certification forms.
On January 4 and 5,1979 an investigation of the allegations was begun at the Enrico Fermi 2 Nuclear Power Station, Monroe, Michigan.
Due to inconsistancies noted in the certification records of the two onsite MAC employees (identified as M-2, M-3), correspondence was initiated with selected past coployers of MAC employees M-2 and M-3.
Attempts were also made to locate the medical specialist whose signature appears on M-3's eye test certificate.
The results of these checks revealed a falsification of records in each instance.
On J.:nuary 9 and 10,1979 the investigation was continued at the LaSalle Power Plant (Unit #1) Seneca, Illinois. Additional irreg-ularities were identified in MAC certification records which again requi ed offsite investigative efforts to determine their authenticity.
MAC was unable to produce the required original test records for employee M-4.
A review of work records at the LaSalle site in an attempt to validate work experience claims of M-2 as a Level II ultrasonics examiner, observed in M-2's certification records at Fermi, resulted in the identification of approximately 280 hours of uncorroborated work experience.
On January 18, 1979, in a meeting with MAC representatives at the NRC of fices, MAC management agreed to provide " corrected" certifi-cation documents for their employees.
On February 5, 1979 MAC provided " corrected" certifications for four employees. These new certifications identified additional inconsistancies concerning previously submitted statements of work experience, training history, and the accomplishment of required eye tests.
The of fices of GE/ISSE, Oakbrook, Illinois were visited on February 7, 1979 by the NRC investigators where GE's relationship with MAC was reviewed. During this interview GE/I&SE's knowledge of the allegations was discussed and their resultant actions evaluated.
' As a result of the overall investigation the substance of the alle-I gations was substantiated. In those instances where s.ubstantial evident.4ary " fact" could not be obtained, a preponderance of circum-stancial evidence pointed towards the truthfulness of the allegation.
Only those phases of this investigation pertinent t,o the Fermi 2 f{ - license will be presented in this report.
It can be noted the ~; . investigation was continued at two additional reactor construction g,. sites and GE/I&SE main offices.
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. . . CONCLUSIONS 1.
Allegation One (Falsification of certification records - testing) was found to be substaniated.
This resulted in one item of non-compliance with NRC regulations (10 CFR, Part 50, Appendix B, Criterion IX) based upon the identification of several instances of falsification in the records of MAC employees with work exper-ience at Fermi 2.
Additional examples of this noncompliance were identified in lapsed medical certificates (visual tests) for GE/ I&SE and MAC Level III examiners.
(Ref. Details, Pg 9, Para. 3.a) 2.
Allegation Two (Falsification of Medical certificate (visual test) for MAC examiner M-1) was found to be substantiated. MAC examiner M-1 was found to possess no record of having worked at Fermi 2 and the " substantiated" finding is based on specific findings identified in subsequent investigative phases. However, the identification of a similar falsified eye test record for MAC examiner M-3, at Fcrmi 2 supports the implication of the allegation.
This falsification of records was identified as an additional example of the noncompliance with NRC regulations cited above (Criterion IX).
(Ref. Details, Pg 9, Para. 3.b) 3.
Allegation Three (Suspected falsification in MAC examiner M-2 of certification records - past experience / training) was found to be substantiated. The inability of MAC managenent to produce the required current test record for MAC examiner F -4 was identi-fled as an item of noncompliance with NRC regulat. tans (10 CFR, Part 50, Appendix B, Criterion XVII).
(Ref. Details, Pg 10, Para. 3.c) 4.
The irregularities alleged were, as a result of this investigation, found to pervade the MAC operation to a greater degree than in the specific instances addressed by the allegers.
5.
The revelation that GE/I&SE management had been made aware of these allegations at a time prior to the NRC being contacted by the allegers resulted in a decision to perform an additional investigative phase to evaluate GE/I&SE Quality Assurance pro-gram and the adequacy of their response to the allegations.
(Ref. Details, Pg 13, Para. 4) -Y.- .~ 4.
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. . DETAILS 1.
Persons Contacted Individuals A, B, C Materials Assurance Company (MAC) Peter K. Olsen, President Patrick W. Cox, Quality Assurance Manager Employees M-1 to M-12 General Electric - Installation & Service Engineering (GE/I&SE) William Kozik, Quality Assurance Manager
- David L. Rybarik, Site Manager
- Thomas J. Dykes, III Edison A. Alexiou, Assistant Project Superintendent
- H. A. Walker, Site Project Quality Assurance Enginear
- J.
D. Ryan, Quality Engineer
- G.
Carter, Quality Control Engineer
- Denotes those attending site exit meeting.
2.
Scope and Chronology This investigation was conducted to determine the fact and substance behind allegations of improper certification procedures levied against the Materials Assurance Company at the Fermi 2 and other nuclear power plant ccustruction sites.
This investigation con-sisted of interviews with licensee, GE/I&SE, and MAC personnel; a review of pertinent procedures and records; and where deemed warranted, correspondence with selected past employers and medical specialists. This investigation also addressed the appropriateness and adequacy of licensee and subcontractor managerial action where previous knowledge of these allegations was indic ted.
On December 13, 1978 Individual "A" contacted RIII.
Also, on that same date Individuals "A" and "B" telephonically provided detailed allegations against MAC's NDE operations at the Fermi 2
,j( * construction site.
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. . . On December 15, 1978 Individuals "A" & "B" were interviewed.
On January 4 and 5, 1979 an investigation was conducted at the Fermi 2 site.
On January 9 and 10, 1979 an investigation was conducted at the La Salle 1 construction site.
On January 12, 1979 Individual "C" telephonically provided the RIII investigators additional information corrobative of the allegations under investigation.
On January 18, 1979 a ueeting was held with MAC manl 3ement personnel at their request.
On January 30 and 31, 1979 an investigation was conducted at the Cooper Nuclear Station (RIV).
On February 5, 1979 MAC management provided RIII " corrected" certification forms for several employees.
On February 7, 1979 an investigation was conducted et GE/I6SE headquarters.
At various dates throughout the investigation periodical corre-spondence was conducted with various firms and medical sources in an attempt to authenticate MAC certification entries.
3.
Findings The following numbered allegations are those developed from information provided by Individuals "A", "B", and "C": a.
Allegation One: " Falsification of Certification Records - Testing" Discusssion Individual "A" alleged that qualification tests required by SNT-TC-IA (June 75 edition), Section 8, " Examinations" were never administered to him during the period of his tenure with MAC for any NDE discipline (UT, PT, etc).
Further, that the scores reflected on his MAC Form 1, " Certification Statement" dated 1/29/78 are therefore false.
Individual "B" -{{ - alleged that on about April 4, 1978 he was provided a com- -....
- g pleted MAC Form 1 " Certification Statement" for Liquid
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. . . Pet.e trant, Level II, bearing his name and dated February 4, 1978 by MAC management with instructions to accomplish an accompanying series of written tests in such a manner so as to have the tests scores equal the existing entries on the predated Form 1.
Individual "C" also alleges that written qualification tests as specified above were never admin-istered during his tenure with MAC.
During the investigation of January 4 and 5, 1978 at Fermi 2, it was founded that certification forms on file with GE/I&SE corresponded with the information (and specimens) provided by Individuals "A" and "B".
It was also found that the current examination required to be available by MAC Procedure No.
MAC-77-026 Rev. 4, Para. 9.5.e to be part of the certification record on file at the " Materials Assurance Company Office" was not available for Individual "C".
This is an item of noncompliance with NRC Regulations in that it is contrary to 10 CFR 50, Appendix B, Criterion XVII which requires that quality assurance " Records shall be identifiable and retrievable."
Review of the " current examinations" provided by MAC manage-ment and attributed to Individuals "A" and "B" reveal (1) dates on these documents coincide with those on the pertinent MAC Form 1 as do the scores on each test, (2) the printing on the haading (name, address, etc.) of each test appears identici.1 for the series attributed to both Individual "A" and to :ndividual "B".
MAC management initially (January 10, 1979) stated that A and B had failed to complete the heading and that he (MAC President Peter K. Olsen) had completed those sections.
Subsequently, Mr. Olsen revised this state-ment to indicate the headings for each were in the handwriting of the individual (A & B).
No signatures or other personalized markings appear on these documents. Review of the tests with Individual A and B reveal that both were in California on the specified dates but not near the locations identified by MAC as being the sites where the tests were administered. Further, Individual A states that the February 11, 1978 test date listed predates his first awareness / contact with any repre-sentative of MAC (approximately last week of March '78).
A review of the MAC supplied NDT Level II Ultrasonics exam, alleged to have been completed by Individual A, and the {{{ ' corresponding MAC Form 1 " Certification Statement" for __ Individual A reveals that sithough individual A is certified ".'." n' as a Level II examiner, only a Level I practical has alleged ${ to have been administered.
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. . . - This is an item of noncompliance with NRC regulations in that it is contrary to 10 CFR 50, Appendix B, Criterion IX which requires that special processes (including nondestruc-tive testing) are accomplished by qualified personnel.
In reviewing NDE certification records, it was found that GE/I&SE's Project Quality Control Supervisor, a Level II PT examiner maintained medical certifications that had expired October 5, 1978. After the certification had expired the Quality Centrol Supervisor performed liquid penetrant examinations on the following welds and possibly others.
This has also been identified as an item of noncompliance with 10 CFR 50, Appendix B, Criterion IX.
Welds Date FPT(E-N2F) R-TD-2A 10/05/78 FPT(JP-06-DOSB-F) F-TD-1A 11/28/78 FPT(JP-09-DUSL-A) F-TD-1A 11/28/78 FPT(JP-10-DUSL-B) F-TD-1A 11/28/78 FVT(JP-18-DCSB-E) F-TD-1A 12/04/78 FPT(JP-06-DOSB-G) F-VB-1A 11/28/78 FPT(JP-16-DOSB-G) F-TD-1A 11/28/78 FVT(J-JP-01) F-TD-1A 12/04/78 FVT(J-JP-01) F-TD 1.A 12/04/78 FVT(J-JP-02) F-TD-1A 12/04/78 FVT(J-JP-03) F-TD-1A 12/04/78 FVT(J-JP-04) F-TD-1A 12/04/78 FVT(J-JP-05) F-TD-1A 12/04/78 FVT(J-JP-06) F-TD-1A 12/04/78 FVT(J-JP-07) F-TD-1A 12/04/78 FVT(J-Jv-08) F-TD-1A 12/04/78 FVT(J-JP-09) F-TD-1A 12/04/78 FVT(J-JP-10) F-TD-1A 12/04/78 FVT(J-JP-ll) F-TD-1A 12/04/78 FVT(J-JP-12) F-TD-1A 12/04/78 FVT(J-JP-13) F-TD-1A 12/04/78 FVT(J-JP-14) F-TD-1A 12/04/78 FVT(J-JP-15) F-TD-1A 12/04/78 FVT(J-JP-16) F-TD-1A 12/04/78 FVT(J-JP-17) F-TD-1A 12/04/78 FVT(J-JP-18) F-TD-1A 12/04/78 FVT(J-JP-19) F-TD-1A 12/04/78 FVT(J-JP-20) F-TD-1A 12/04/78 The above findings support and corroborat the allegation - .g
- /j
- as provided.
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. . s b.
Allegation Two: " Falsification of Medical Certificate (Visual Test) for MAC examiner (M-1)." Discussion Individuals A and B allege that the SNT-TC-1A required certi-lication of visual acuity (MAC Procedure MAC-77-026, Rev. 4, Para. 8.1.a and Form IV, Jaeger Vision Test) for MAC examiner (M-1) has been falsified.
As a result of the investigation at Fermi 2 it was determined that available records reveal no use of MAC Examiner M-1 at the Fermi 2 location. However, pertinent investigative findings associated with this allegation are provided below.
Findings An in,terview on January 3, 1979 with MAC examiner M-3 raised questions regarding the validity of M-3's eye certificate.
M-3 could provide only vague recollections on when and by whom his eyes had been tusted.
M-3 stated he initially began work with MAC in July of 1978.
Inconsistencies in his certification records regarding past employment and his date of certification (May 29, 1978) were discussed.
M-3 recalled that he had had his eyes checked "around Boston, Mass." just befere he began work with MAC in July 78 at La Salle, Illinois.
Subsequent checks on January 4, 1979 with the Bell Telephone Company for any listing (private or professional) in the Boston, Massachusette environs with the name on the certif-icate (or any similar name) resulted in a negative finding.
When NRC's irability to locate this medical specialist was discussed wita M-3 on January 4, 1979 he could provide no additional information and declined to make any additional statements.
On February 5, 1979 MAC President Peter K. Olsen provided " corrected" certification forms for specific MAC employers.
Included in these was a new medical certificate (visual test) for M-3, dated January 11, 1979. When asked by the NRC investigator about the validi?.y of the original medical certificate for M-3 provided to NRC on January 3, 1979, Mr. Olsen ".tated that "some of the allega,tions you received gj_j.'- must be considered as true."
then specifically asked to corment on M-3's medical certificate he stated it "would
,. ~ have to be considered false."
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. . . A review of work records at the Fermi 2 site revealed that MAC examiner M-3 had performed the following NDE examinations, including those on safety related systems, during a period in which no valid medical certificate was available for him.
12-07-78 FPT (ARI-STB-135L)F-GF-lR Pg ARI-STB-XXX0 12-13-78 FPT (RCS-05)-R-GF-1A Pg RCS-XX0 12-20-7s FPT (X48-409)-R-GF-1A Pg X48-4XX 12-20-78-13 12-20-78-17 12-20-78-25 12-20-78-33 12-20-78-41 12-20-78-49 12-20-78-53 12-20-78 FPT (A-STB-225L)F-GF-lR Pg A-STB-XXX0 This is an additional example of noncompliance with NRC regulations in that it is contrary to 10 CFR, Part 50, Appendix B, Criterion IX which requires that special processes (including nondestructive testing) are accom-plished by qualified personnel.
c.
Allegation Three: " Suspected falsification of certification records - experience and training.
Discussion Individuals A and B alleged they first met MAC examiner M-2 on or about the last Friday in March 1978 in California because Individual B had been instructed by MAC management to instruct M-2 in PT procedures. During the instruction process M-2 stated he had no previous NDE experience but had been a used car salesman with a specific firm in California.
Individual A and B subsequently discovered M-2 was performing duties as a Level II examiner in UT and PT.
Findings Correspondence with "past employers" specified by M-2's " Certification Statement" revealed no record of M-2's alleged employment by the U.S. Steel Corp., Dusquense, - Pennsylvania during the period "7/69 to 8?71" nor any . . 4.. . .
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. . . training record of his having received "80 hrs General NDT Course" by that firm in 1970. His past employment as a car salesman in California was confirmed.
During an initial interview conducted on January 4, 1979 at Fermi 2, and before the atove confirmation was received, M-2 stood firmly by his past employment statement even after being advised of the implications of 18 USC 1001 concerning the submission of fradulent statements to a federal official.
During a meeting on January 18, 1979 requested by MAC manage-ment at which M-2 was present, MAC agreed to provide " corrected" certification statements.
These were received on February 5, 1979 and found to contain new certificates for M-2 on which the employment / training by U.S. Steel had been deleted. When questioned by the RIII investigator, MAC President Peter K. Olsen stated the earlier statements of M-2 et. al., would have to be viewed as false.
In addition, the review of M-2's records during the inves-tigation at Fermi 2 disclosed M-2's certification as a Level II UT examiner to be based in part on the above described experience with U.S. Steel Corp. as well as 292-hours of UT stated on MAC Form III to have been accrued during working assignments at La Salle site (May - August, 1978).
During the subsequent investigation at the La Salle site (January 9 and 10, 1979) it was determined from GE/I6SE Quality Control personnel that all UT work was documented on specific written records which detailed the item tests, operators, serial nos. of equipment used, etc.
A review of all available UT specification sheets for these tests iden-tified only two dates upon which M-2 documented any UT work.
The work experience record (MAC Form III) for M-2 provided the NRC investigators at Fermi 2 on January 3, 1979, lists 60 hours of UT (Level II) performed by M-2 on the Fermi 2 " Torus shell" during the week of 10-23-78, 10 hours of PT (Level II) on "RPV internals" during the week of 11-27-78, at Fermi 2 and 40 hours of PT (Level II) on "RPV internals" during the week of 12-4-78 at Fermi 2.
In addition, a review of site work records reveal M-2 to have performed the following NDE examinations during December 1978 at Fermi 2.
Jd[ ' 12-1-78 FVT(JP-07-DCSB-E)F-TY-1A Pg JP-XX-DCSB-E ,, -a-08 '
-09 ~ w - 11 - 2134 077
. , s 12-14-78 FVT(G134-G146) F-TY-1A Pg G134-GXXX Thru (G134-G159) The above work performed while under certification based upon apparent falsified information (e.g. insufficient work experience for certification Level II UT & PT) is an additional example of noncompliance with NRC regulations (10 CFR, Part 50, Appendix B, Criterion IX) which requires that special processes (including nondestructive testing) are accomplished by qualified personnel.
In a related investigative finding at the Fermi 2 site, MAC examiner M-3 was interviewed and firmly asserted his certi-fication statement of past employment by the firm F. L. Clifford Associates as a Level II PT examiner during the period "7/76 to 1/78" was true and correct.
M-3 also made the statement after being provided a copy of 18 USC 1001 and being advised by the NRC investigators of the seriousness of the allegations.
Due to the implications of the allegation and M-3's inability to provide any definitive information as to the details of his eye test as previously discussed, additional investigative checks were accomplished on January 4, 1979, in an attempt to determine the authen-ticity of M-3's stated work experience.
These checks resulted in flat denial by Mr. Frank Clifford (a one-man consultant firm) of ever having employed M-3.
When confronted with the above inconsistancies and requested to provide more definitive information on the nature of his employment, possible mispelling/ identification of his employer, etc., M-3 declined to make any further statements to the NRC investigators.
Subsequently, F. L. Clifford has confirmed his telephonic statements in a letter.
This is an additional example of noncompliance with NRC Regulation in that it is contrary to 10 CFR 50, Appendix B, Criterion IX which requires that special processes (including nondestructive testing) are accomplished by qualified personnel.
The investigative findings at the Fermi 2 site relative to MAC employee's M-2 and M-3 are in corroboration of Allegation 3 which is therefore substantiated as true.
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, . 4.
Other Findings Interviews with GE/I&SE project supervisors, T. Dykes and D. Rybarik on January 4 and 5,1979 corroborated individuals A and B's statements that the allegations provided NRC had been given to T. Dykes during the week of December 4-8, 1978.
T. Dyke, description of the specific information received from indivia2als A and B agreed in content with that provided the NRC investigators on December 15, 1978.
Both T. Dykes and D. Rybarik indicated these allegations had been telephonically provided to their management (Mr. W. Kozik, Quality Assurance Manager) at Oakbrook, Illinois " shortly" after they became aware of them.
During the February 7, 1979 visit to the GE/I6SE facilities at Oakbrook, Illinois by the RIII investigators, Mr. Kozik confirmed his knowledge of the allegations.
Mr. Kozik questioned NRC's use of the term allegation stating that GE's evaluation had failed to " prove" these concerns.
Mr. Kozik stated that upon receiving the allegat.ons he instructed T. Dykes to "look into the matter" being sure to (1) make no commitment on the part of GE/I&SE, and (2) to limit the evalu-ation to a " paperwork audit."
When asked by the investigators in view of the content of the allegation why he did not look deeper into the work / training claims on the certification, Mr. Kozik replied he limited the evaluation because of "the size of the job" and because of possible Privacy / Freedom of Information Act considerations.
Other matters not pertinent to the Fermi portion of this inves-tigation were also discussed.
In an exit briefing, limited at Mr. Kozik's request to himself, GE/I&SE was advised that the NRC Investigators viewed the response by CE to these allegations to be superficial; particulary so due to the nature of the NDE work being performed by this GE subcontractor on the reactor vessel internals.
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