IR 05000346/1976011
| ML19319B652 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/15/1976 |
| From: | Foster J, Hayes D, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B601 | List: |
| References | |
| 50-346-76-11, NUDOCS 8001270148 | |
| Download: ML19319B652 (27) | |
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UNITED STATES NUCLFAR REGULATORY COL'!ISS N l
OFFICE OF INSPECTION AND ENFORCE' TENT
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REGION III
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IE Investigation Report No. 050-346/76-11
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j Subject:
Davis-Besse Nuclear Power Station l
Toledo Edison Company Oak Harbor, Ohio
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Docket No. 50-346
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CPPR-80 j
Allegation - Former employees of an electrical
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subcontractor alleged falsification of a quality j
control document and raised concern over the
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j adequacy of various electrical installations.
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j Period of Investigation:
April 28, 29; June 2, 3, 4, 9,
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and 11, 1976 Investigators:
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Reviewed By:
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D. M. Hunnicutt, Chief
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Reactor Construction and Engineering Support Branch
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('~'h; REASON FOR INVESTICATION
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i On April 23, 1976, information was received f rom a Cleveland, Ohio, newspaper reporter which indicated that former employees of an electrical subcontractor at Davis-Besse were concerned about the adequacy of electrical installations at the Davis-Besse nuclear power plant.
Additionally, it was alleged that a quality control inspection report had been falsified. One of the former employees had testified con-
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cerning the. falsified report during a hearing by the Ohio Bureau of a
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Employment Services into his claim for unemployment benefits. An investigation was initiated by Region III to determine the nature and substance of the concerns and allegation.
SUMMARY OF FACTS Individual "A" was employed as a Junior Quality Control Inspector at the Davis-Besse power reactor construction site by the Colgan Electric Company (Fischbach and Moore) during the period of April 16, 1974 - July 29, 1975.
On August %;, 1975s he fil,ed a claim with the. state of Ohio for unemployment benefits, which was disallowed on September 11, 1975.
A request for reconsideration of the decision was filed on September
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15, 1975, and the original decision was upheld on November 26, 1975.
On December 1, 1975, an appeal was filed, which resulted in hearings on
January 20, 1976 and on April 7, 1976. On April 19, 1976, the previous ps decisions were again upheld and unemployment compensation was denied.
,\\ j; A furt,her hearing has been indefinitely postponed.
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'I During the January 20, 1976 and April 7, 1976 hearings, an allegation was made by Individual "A" that, while employed on the Davis-Besse I
p roj ec t, he was ordered by the QC Manager to falsify a quality control equipment inspection report.
In addition, several concerns were expressed over the adequacy of electrical installations at the plant.
Due to state law, a transcript of the hearings was not made public.
Therefore, the actual statements mada during the hearings were not reviewed.
During the initial phase of the investigation on April 28 and 29,
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Individual "A" and three other individuals who had testified at the
t unemployment hearings were interviewed.
In addition, an exhaustive j
records check was made, in an attempt to identify the record which was
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alleged to have been falsified. Due to the volume and complexity of the records kept by Fischbach and Moore (F&M), initial efforts to locate and identify the inspection report referred to by Individual "A"
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were unsuccessful.
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f Each individual interviewed was questioned in detail as to his expressed
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concerns over the adequacy of other electrical installations at the
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l plant, and specific equipment was identified where possibic.
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majority of the items of concern dealt.uith problems which ha'd been j
previously identified by the NRC as requiring corrective action.
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remaining items will be reviewed durin; subsequent NRC inspections and l
will be resolved prior to the issuance of the Operating License.
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l A second investigation visit to the construction site was made on June 2 -
4,1976, and interviews were held with F&M quality control inspectors'
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and management personnel.
F&M quality control inspectors not inter-
viewed during this visit dere interviewed during a third site visit, June 9-11, 1976. While there are indications of incorrect dates on
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some quality control records, employees interviewed denied deliberate falsification of any quality control record or knowledge of any other employee having been ordered to falsify a quality control record.
Furthermore, each quality control inspector interviewed was asked to identify any electrical installation whose design or construction appeared inadequate.
During the June 2-4, 1976 visit, it was found that a FSM record audit had located an inspection record which appeared to be the alleged falsified inspection report, in that the listed equipment, inspection
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data and inspector coincided with information received f rom Individual
"A".
Individual "A" was interviewed again on June 9, 1976, and asked to
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inspecticn report.
Individual "A" stated that he could not positively
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identify the document and therefore refused to make a written statement concerning it.
He added that he had only been asked to falsify one inspection report and that he knew of no other inspector falsifying a j
record.
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CONCLUSIONS
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The record alleged to be falsified was reviewed and was found to contain numerous errors and inaccuracies.
It had been dated prior to the receipt of the equipment in question.
While the record may have been predated as alleged, such an action does not appear to i
serve any useful purpose on the part of the contractor or the utility.
(This document, even with its defects, has no impact on the quality of the construction of the Davis-Besse plant.) All QA
documents pertaining to the equipment after its receipt on site were examined and found to be in accordance with QA procedures.
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No evidence was found to suggest that the errors in the defective (i
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document reflect widespread discrepancies or falsification of other F&M inspection reports.
2.
During the course of the investigation a number of items of concern were brought out by the individuals interviewed (primarily Individuals " A",
"B",
"C",
and "D").
These concerns, in general, were indicative of the electrical quality assurance and instal-latian problems identified by NRC inspectors in previous inspections of the Davis-Besse plant. As a result of problems identified by
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the NRC in May 1975, Toledo Edison Company agreed to conduct a complete reinspection of all installed safety-related wiring.
Any problems found have been, or will be, resolved to the NRC's satisfaction before the NRC allows the plant to begin operation.
The adequacy of the Toledo Edison reinspection and any rework has been covered in other NRC inspections (primarily June 8-11, 1976) and will also be the subject of future inspections.
The following list identifies the items of concern raised during this investigation and the NRC finding on each item.
ITEMS OF CONCERN IDENTIFIED DURING INVESTIGATION 1.
Concern:
Installation of a pressure relief valve (PSV 1529)
in Room 125 was questioned regarding compliance with
/'~N code requirements. Also questioned was that valve
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PSV 1529 discharged into a tank with a pressure rating
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below that of the valve relief setting.
Finding:
The installation of valve (PSV 1529) and three other relief valves similarly installed were reviewed and cil four valve installations were in accordance with design specifications and applicable codes.
Valve PSV 1529 discharges into the Reactor Coolant Drain Tank which is protected from being over-pressurized by separate relief valve.
2.
- Concern:
(1) Electrical conduit was not installed in accordance with drawings; (2) Conduit supports were fabricated using unapproved drawings and did not, in some cases, meet seismic requirements; and (3) Procedures were not followed to assure that all field conduit support welds were properly inspected.
Finding: Those items were previously identified by NRC inspectors during April and May 1975 inspections.
The licensee has
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- Item requiring further NRC review.
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committed to perform a 100% reinspection of all conduit supports to assure that the supports and welds meet re-quirements.
Completion of this reinspection, correction
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of identified deficiencies and review by the NRC inspec-tors are currently in progress.
3.
Concern:
Many inspection reports submitted by F&M Quality Control (QC) inspectors were rewitten by the QC managers to suppress negative findings.
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Finding: The QC manager did rewrite many of the reports as permitted by the F6M QA program.
No evidence was found that the re-write did not accurately state the problem. QC inspectors were given an opportunity to revieu and sign the reports.
4.
- Concern:
Cable trays were initially on the "Q" list, taken off, i
then put back on by Bechtel Corporation.
Because of this, some cable trays may not have been adequately inspected.
I ("Q" list is a term used by the Bechtel Corporation to identify safety-related equipment.)
Finding:
This item was identified by NRC inspectors during a February 1974 inspection.
Resolution included the re-quirement that the licensee inspect all cable trays in-stalled during the time the trays were not "Q" listed.
NRC inspectors verified the completeness of the licensee's inspections.
Also, as a result of the many electrical l
problems identified during the NRC May 1975 inspection, s
Toledo Edison Company committed to a 100% reinspection of all safety-related cable raceways including trays.
Review of this 'correceive action is currently in progress.
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- Concern:
Some electrical cables were not routed in accordance with drawings. Thus, a possibility exists that cables for redundant safety systems may be misrouted and may not be properly separated.
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Finding: Three (3) cables were found to be incorrectly routed by the NRC inspectors during the May 19 - 22, 1975 inspection.
As a result of this finding the licensee initiated a 100%
reinspection of all safety-related cables for proper routing as well as for adherence to separation criteria.
Completion of this reinspection, correction of identified deficiencies, and review by the NRC inspector is in progress.
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Concern:
Water in embedded conduit could cause deterioration of conductor jacket insulation.
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(s Finding:
In accordance with approved installation procedures, each
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installed conduit is required to be cleaned by pulling an
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appropriate sized mandrel through the conduit.
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conduits checked by NRC inspectors have shown no evidence of water. All electrical conductors have been tested and verified to be moisture, heat, radiation and ozone re-sistant.
Should water in a conduit result in failure of conductor jacket insulation, this will not be of safety concern.
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7.
Concern:' Conductors were nicked when knives were used to cut cabic.
Finding:
Removal of cable outer jackets was performed in accord-ance with approved installation procedures, i.e., with an electrician's knife.
Minor surface cuts were observed by NRC inspectors on individual conductor insulation.
Individual cable conductors located within the cable outer jacket were stripped with fixed blade type stripping tools periodically calibrated to verify cutting depth.
In no case was the metallic conductor observed to have been damaged.
8.
Concern:
Cable not taped after meggering (insulation testing),
and moisture could cause deterioration cf conductor insulation.
Finding: The primary purpose for taping cable ends is to prevent
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moisture absorption; however, the primary concern is with cables stored outdoors and susceptible to the elements. Under normal conditions, conductor ends are routed to indoor areas removed from the elements and therefore would not require taping after meggering.
In outdoor areas such as manholes, procedures do require retaping. Taping of cable ends has been verified during routine NRC inspections.
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- Concern: Cable meggered (insulation tested) before installation completed.
Damage may occur to cable insulation during the subsequent installation process.
Finding: This matter was identified previously by NRC inspectors during a May 1975 inspection. Resolution involved a 100% reinspection of all safety-related cables raceway and associated electrical equipment including reinspection of routing cards prematurely signed off.
Review of corrective action is currently in progress by NRC inspectors.
- Item requiring further NRC review.
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- Concern: More cables than allowed by specifications have been in-s,,/
stalled in some conduits. Also, when added cables are
" pulled" into conduits already nearly full, damage could
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occur to previously installed cables by the pull rope.
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Findl ':
No deficiencies relative to conduit overloading have been noted to date by NRC inspections.
Conduit cable installations in the three areas identified by the QC inspectors will be thoroughly examined during future inspections and this issue
resolved prior to issuance of an operating license.
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- Concern: "Hilti-Kwik" supports were not properly tightened.
Components secured by "Hilti-Kwik" concrete anchors (i.e., cabinets, raceway, etc.), if not properly tightened, will not pro-vide adequate seismic mounting.
I Finding:
This matter wai identified by NRC inspectors during a June 1975 investigation relative to alleged poor electrical work practices. This matter will be reexamined following
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completion of work by the licensee.
12.
- Concern: Junction boxes are not seismically mouhted in accordance with approved drawings.
Finding This matter was identified previously by NRC inspectors during a May 1975 inspection.
Resolution involved a 100%
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reinspection of all cables, raceway and associated elec-trical equipment. Further, on June 16,19'5, all work
was stopped relative to installation of conduit, junction boxes and associated devices until approved installation
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drawings were provided. Work has subsequently resumed and review of installation are currently in progress by
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NRC inspectors.
13.
Concern:
Raceway cards were stamped by quality control inspectors when inspections had not been performed.
Finding: This matter was identified previously by NRC inspectors
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during a May 1975 inspection in that cables had been
misrouted and raceways impr rerly inspected.
Resolution
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involved a 100% reinspection of all cables, raceway and i
associated electrical equipment-Review of the reinspection and corrective action is currently in progress by NRC inspectors.
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14. * Concern When QC electrical inspector found problems the inspection
i procedure was changed such that inspection in areas where the problems were identified would no longer be. required.
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- Item requiring further NRC review.
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/'~'g Finding: A few F&M inspection procedures have been revised several (
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times.
Preliminary review indicated that inspection ac-
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ceptance criteria became more stringent because of the changes rather than icss.
However, two frequently changed procedures have been selected and the history of the changes and reasons for the changes will be developed to assure that required inspection criteria have not been compromised or deleted.
The results of this review will be documented in a future inspection report.
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Concerni Wiring had been jammed into push-button control stations.
(This concern had previously been identified by a former electrician at the Davis-Besse site and reviewed by two NRC inspectors However, it was expressed during the current investigation that the NRC inspector had not adequately reviewed the matter.)
Finding: During the MRC inspection conducted May 29 and June 1975 an electrician was not available to open the specific control station identified by tne former electrician, but others without covers installed were examined and found to be properly installed.
The w' iring on the remain-ing con rol stations in question were examined during the NRC ins,ection conducted on August 18-20, 1975, but this fact um inadvertantly omitted from the inspection report.
The fincing, which was that the wiring met specifications
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and applicable electrical codes and standards, will be (
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documented in the current report for the inspection conducted
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on June 8 - 11, 1976.
16.
Concern:
Circuit breakers installed in non-safety related (non "Q")
switchgear that are interchangeable with circuit breakers installed in safety-related switchgear were not being properly protected.
Finding: This matter was previously identified by NRC inspectors.
Corrective' action (reviewed by the NRC inspector) included checking and cleaning the breakers and assuring that in-spection procedures were followed in providing routine surveillance of these breakers for proper protection.
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Concern:
Drawings were changed to match the installation, rather
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than correcting the installation to match the drawing.
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- Finding: This item could not be substantiated without specific examples
and none were provided.
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Concern:
Electrical cables were being installed before ~the raceway was completed.
This resulted in the cable being only j
partially installed and the end coiled.
Some of the coiled cables were not properly secured, fell to the
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floor and were walked on.
i Finding:
In some instances, cables were installed prior to com-
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~ pletion of raceways to maintain work schedules and keep cable pulling crews busy. Although this may not be i
a sound practice, there are presently no NRC requirements
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concerning this matter. The coiled ends of the cables are required by procedure to be inspected at the i
time the installation is completed.
In addition, each
cable is tested for installation defects and damage before
it is terminated.
Cables found to be defective or damaged
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are replaced.
Selected records that were reviewed sub-stantiated that this was being done.
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19.
Concern F&M's inspection workload did not allow time for adequate QC inspection.
1 Finding: FSM inspectors, when interviewed, reported they were able to adequately perform the inspections required under their present workloads.
This may have been a valid concern at the time Individuals
"A", "B",and "C" were employed
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by F&M.
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Concern:
Electrical installation inspection procedures were de-
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i liberately written to confuse the workmen.
i Finding:
NRC inspectors felt that although some procedures are
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unnecessarily lengthly and complex, inspection require-ments are clearly identifiable and understandable.
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- Concern: The leak rate for the electrical penetrations is greater than allowed by code for shop fabricated units.
Also, the purchase specifications were revised so that the
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pe~etrations would be acceptable.
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l Finding: This item had not previously been reviewed by NRC in-
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spectors and will be examined thoroughly during a future
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inspection.
NRC Regulations require that prior to fuel
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loading the licensee must pressure test the containment I
vessel and conduct leak rate tests.
NRC inspectors are
routinely present during portions of these tests and j
review leakage rate results for electrical as well as j
other penetrations.
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INVESTIGATION AND INTERVIEW DETAILS
[V Scope This investigation focused on the quality control inspection activities of Fischbach and Moore. Incorporated (F6M) and the Colgan Electric Company (a joint venture) related to the electrical installations at the Davis-Besse Nuclear Power Plant, Unit 1, with specific emphasis on an allegation that a quality control inspection record had been falsified.
During the period April 28 and 29, 1976, interviews with the alleger and others were held, contacts were made with Toledo Edison, Bechtel and F6M management, and pertinent records were reviewed.
On June 3-4, 1976, intervieus with F&M employees and management were held, and records reviewed.
During the period June 9-11, interviews were held with FtM employees and management, records were reviewed, and a signed statement was obtained from Individual "E".
In the two periods (June 3-4 and June 9-11) all F&M QC inspectors currently employed and involved in field inspection activities were interviewed to identify any areas of concern they had with the electrical installations. The allegation and items of concern were discusse<i. tith Toledo Edison Company management personnel on June 9, 1976.
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Introduction On April 23, 1976, a newspaper reporter advised the Region III office of the Nuclear Regulatory Commission that three former employees of an electrical subcontractor at the Davis-Desse Nuclear Power Plant had testified during a bearing of the Ohio Bureau of Employment Services that a quality control inspector had quit his employment with a subcon-tractor because he was forced to falsify a quality control inspection record.
Details as to the identities of the individuals involved and the date of the unemployment hearing in question were obtained from the reporter, and arrangements were made to individually interview the individuals concerned.
t Interview with Individual "A" on April 29, 1976 Individual "A" was interviewed in Fremont, Ohio, concerning his allegation of a falsified record. The main point of his allegation was stated as follows:
"On July 25, 1974, when I was a Quality Control Inspector working for the Colgan Electric Company at Davis-Besse Nuclear Power
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Quality Control Manager, to sign (with my acceptance stamp) a quality control certification for substation E6-F6 and write May 5, 1974, on it as the date of certification.
The equipment covered by this certification was not roccived at the plant until July 25, 1974."
During the interview, Individual "A" stated that in July 1975, he had left the employ of Colgan Electric Company, an associate comnnr.y of Fishbach & Moore, Incorporated, a subcontractor of the Be_..tc1 Cceporation,
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the constructbr of the Davis-Besse plant.
He indicated that he had left because of dissatisfaction with the job.
He stated further that he had been ordered on one occasion to sign a certification for substation equipment and backdate the date of certificatica upon the direct orders of-the quality control manager.
He stated that subsequently in a hearing with the Ohio Bureau of Employment Services wherein he was attempting to apply for unemployment compensation the reasons for his termination were.
described and were attested to by other follow former employees in the same quality control department.
These were identified as Individuals
"B",
"C",
and "D".
He stated that individuals "B" and "D" had testified that they were present and had heard the supervisor order him to sign the false certification.
Concerning the substation equipment that Individual "A" stated that he had been required to backdate the certification for, he subsequently identified this as substation E6-F6.
He said that while he had possibly
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inspected part of this equipment he had not completed his inspection ( _,/
when he had been told by his supervisor, Individual "E",
to put his approval stamp on it and write the date of certification as May 5, 1974 Individual "A" stated that he was told to do this on July 25, 1974, the date upon which the equipment was received at the plant.
He stated that the reason given by Individual "E" for him to do this was to correlate the paper work since other documents concerned with the shipment had the prior date of May 5, 1974 Individual "A" stared that Individual "D" as well as individual "B" had been present when he had been 'old to do this by Individual "E" and that this had occurred in.the QC Inspectors room on July 25, 1974.
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Individual "A" made other comments concerning the quality of work and construction procedures.
He mentioned that whereas the cable trays had seismic supports,'the conduits leading from the trays originally did not have any supports designed for them, Subsequently, seismic supports for the conduits were later put in place.
He mentioned another instance wherein an electrical cabinet was designated on the blueprints to be installed directly over a floor drain opening in a diesel generator room.
Again, this was subsequently installed elsewhere in the room
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Although the QC inspectors a
had pointed this out to Bechtel, this complaint had fallen on.dcaf cars and finally, on the order of a TECO supervisor, the blueprint was changed.
Individual "A" also stated that Individual "E" would of ten rewrite the nonconformance reports prepared by the inspectors and that the procedure called for Individual "E" to review and approve their reports.
Interview with Individual "B" on Anril 29. 1976
This individual, a fellow QC inspector, said that he was present at the time when Individual "A" had been told to sign a certification document by I-dividual "E".
He stated that, he did not know what the specific document was, but that he was there when the order was given, and he stated that Individual "D" was also there.
He stated that the two of
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them noted the fact that Individual "A" had been ordered to certify the document.
They signed a statement to that offect and put it in their files, each one of them.
He said they had done this because they thought that some day this might come up, but he said that the files would have been destroyed by now.
Concerning the certification, Individual "B" stated that Individual "A" had been told to stamp it.
He said, that Individual "A" had been the one involved in the inspections, but as far as Individual "B" knew, Individual "A" had not inspected the item.
"A" vas saying, in effect, that it was okay when he wasn't sure.
Individual "B" said that Individual "\\" said either that he hadn't s
inspected it or that it wasn't okay, ot.1 or the other.
Individual "B" said he thought that "A" had been told 13 put a certain date on it, if
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he remembered correctly.
Individual "B" went on to say that one of the problems they had had in quality control was the manner of following procedures.
He stated that procedures were changed in the middle of the stream.
He stated there had been problems they had written up concerning the cable trays and then the cable trays were taken off the "Q" list, meaning that they were not subject to inspection.
As t1 whether he had improperly signed off on anything, he wasn't sure himself.
Individual "B" stated that on one occasion he had signed off on something that had originally been red tagged, when he was assured by his supervisor that the material was satisfactory.
He.did not recall what this item was or when the incident occurred.
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Interview with Individual "D" on Aoril 29, 1976
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Individual "D" was interviewed on April 29, 1976.
He indicated that he had appeared at the unemployment compensation hearing.
He stated that he had testified at the hearing, but he had not been c,uestioned about
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any allegation of falsification of a certification.
Itc stated that there had been one occasion when for s me equipment he had to note a prior date for his inspection of an it2m that was accepted and-that Individual "E" had asked him to do it.
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I!c stated that one discrepancy he noted was for leakage rates for electrical penetrations which should be held to the plant design prototype which were 10~ cc ggr second accordit.g to the manufacturer's specifications. However, 10 cc per second was the field leakage rate permitted, and Bechtel said that clay would have to accept the higher leakage rate.
Individual "D" stata.. that none of the penetrations met the design requirements.
He sta ad that these leakage rates were part of the wackly pressure readings, and that they were brought to QC's attention either by an IR (Inspection Report) or an "CR (nonconformance report).
Individual "D" stated that another thing that he was aware of concerned the cable tray seismic support welds.
There was an under-cutting of one of them but this was later corrected.
Interview with Individual "C" on April 29. 1976
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Individual "C" was interviewed by te'ephone on April 29, 1976.
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"C" said that he had worked at filing, receiving and field work in the QC department.
Concerning the matter of Individual "A" having been ordered to certify something that he had not inspected, Individual "C" stated that he had been out in the field at the time that the incident allegedly occurred.
He added that he had subsequently heard Individuals
"A" and "B" talk about it, but he had no direct knewledge of the incident.
lie stated that he himself had never been ordered to certify something that had not been inspected.
Individual "C" stated that he had too much work to do in his job and he couldn't do all of it.
This was one of the reasons contributing to his leaving the company.
Individual "C" stated that one thing that gave him problems was the cable trays.
He said that one week they would be inspecting them and the next week the cable trays would be taken off the "Q" lists, and six to,eight weeks later the cable trays would be back on the "Q" list again.
Inspection at the Davis-Besse Plant The manager of the QC inspection department, Individual
"E", was inter-viewed on April 29, 1976.
He stated that he had no recollection of the alleged incident of falsification relative to Individual "A".
He stated that he had never ordered QC inspectors under'his supervision to backdate QC inspection certificates.
Specifically, he stated he did
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not direct any QC inspector to sign of f on a QC certification for Substation E6-F6 on July 25, 1974, or backdate any certificate to May 5, 1974.
Concerning thu matter of dating reports, he stated there was a monthly " inventory" report which was prepared to insure that equipment on hand and stored was kept at the correct humidity and thermostat settings.
This report had to go over to Bechtel by the 5th of every month.
He said that on two or three occasions some less experienced junior inspectors, Individuals "A" and "C", had " whited out"* an error in the date of the readings and the report had to be corrected as of the date of the readings.
In another instance " whited out" "Megger"**
monthly sheets on motors and diesel generators had to be similarly corrected.
He stated that because of these incidents he had issued a memorandum to all QC personnel on September 30, 1974, that no " white out" was to be used.
Records of the QC certification stamps for Individuals
"A",
"B", and
"C" were examined.
"A's" stamp Nc. 106 was taken out of use July 29, 1975, Individual "B's" on August 6, 1975, and Individual "C's" on May 30, 1975.
The stamps which were in locked storage were also excmined.
Individual "E" stated that, by procedure, inspection stamps once retired could not be used again until six n.onths had passed.
It was determined that the only equipment in the plant with the designation E6-F6 is a 480 volt Unit Sub Station, GE type AKD-5.
The following facts about it were developed from observation and records:
The substation is designated EF-6 but is made up of two buses (E-6 and F-6).
Each bus feeds three motor control centers (MCC) E-61, E-62, E-63, F-61, F-62 and F-63.
The substation and the motor control centers supplied by the substation are not safety related.
The " draw outs" (circuit breakers), installed in substation EF-6, however, are considered-to be safety related because they are interchangeable with similar draw outs used in substations which have a safety related function.
The serial numbers of the bus supply breakers installed in substation EF-6 at the time of the inspection were 256A6727-201-1 and 256A6727-201-2 and the bus tie breaker was 256A6727-202.
The serial numbers of the MCC feed breakers were as follows:
MCC Breaker Serial Number
.
E-61 256A6727-203-6
-
E-62 256A6727-203-2
.
- " whited out" refers to erasure by painting over an ink entry with opaque white correction paint.
- "Megger" - testing procedure to detect any shorts or defects,in installed electrical cables.
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Dj E-63 256A6727-203-3 V
F-61 256A6727-203-4 F-62
)
Breaker data tag inaccessible F-63
)
because circuits energized The following records relative to substation EF-6 were examined:
Bechtel Corporation (Bechtel)
TWX - from 'Bechtel vendor inspector, J. L. Southard to Mr. Stephen (Bechtel site project superintendent at that time) stating that sub-station EF-6 released for shipment September 27, 1974.
i Material eceiving Record - Substation EF-6 listed as being received on site.
Record was dated October 1, 1974.
Material Release Record No. C-14-388 This document transferred r ?sponsibility for substation EF-6 f rom Bechtel to Fishbach-Moore. 11e document was signed by both Bechtel and Fishbach and Moore representatives and was dated October 17, 1974.
The equipment was designed as non safety related (Bechtel non Q listed) on the fo rm.
(See note below).
TWX - from Bechtel vendor inspector, F. Zikowitz to Bechtel site
/"'
(N)
256A6727-01, 02, 03, 04, 05 and 06 for substation EF-6 released for project sup e rin t ender.t, C. L. Huston, stating breakers serial numbers
_
shipment October 18, 1976.
TWX -
from Bechtel vendor inspector, J. Madigan (for F. Zikowitz) to Bechtel site project superintendent ststing areakers serial numbers 256A6727-201-01, 02 and 256A6727-202-01 for substation EF-6 released for shipment December 2, 19 74.
(See Note below)
NOTE - It was not clear from Material Release Record No. C-14-388 if the transfer also included'the breakers (draw-outs).
This would not appear to be possible since six of the nine breakers were not released for shipment from GE until October 18, 1974, and the remaining three on December 2, 1974 A general review of receiving records for 480 volt breakers established that no 480 volt breakers were received between the
'
dates of January 3, 1973, and October 28, 1974, and the last 480 volt breakers were received on December 16, 1974.
Attached to the Eculpment (Substation EF-6)
Ready for Shipment Tags (TWO)
Both tags had the same information recorded except one was for units 101, 102, 103 and 104 and the other was for units 105, 106 and 107.
Information on the tags included:
.f
's
,
V)
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s S.O. No. (Shop Order)
912CA850 Reg. No. (Requisition)
382-52303 Date September 24, 1974 C/0 No.
Q1387C Fischbach and Moore (F&M)
.
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Storage Procedure Checklist for Substations
.
.
(Results documented on F&M form No. SP-7749-E14-5F.001, Pages 5 and 6 of the procedure.)
This procedure provides instructions for the monthly
,
inspection of substations.
The results of these inspections are summarized
'
in eight columns in addition to a column for the identification of the equipment and a column for the date the inspection report was submitted.
The eight inspection columns are coded as follows:
,
CIV - Corrective Identification Verified CPC - Contamination Protection Covered NVD - No Visible Damage MFC - Meter Faces Covered Pressure Level Checked PLC
-
LLC - Liquid Level Checked H0
- Heaters On
)
IP
- In Place
)
x,,/
IS
- In Side Storage )
Locations OS
- Outside Storage )
Each inspector is assigned a set of inspection stamps.
The stamps have a F&M symbol and an unique number assigned on]y to that inspector.
For inspection of substations generally one of tvu stamps would be used in each applicable column. A round stamp indicating the inspection was performed and all items met requirements or a "D" shaped stamp indicating the inspection was performed but one or more items did not meet requirements.
,
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When an item not meeting requirements is identified during the inspection, a second document such as a corrective action report, tonconformance report, inspection pickup, etc., must be made out to in'.tiate corrective
'
action.
The type'of number of this second document is cocumented on the checklist with a reference to the rejected item (s).
Storage procedure records were examined for all plant substations.
The first entry noted on these records for substation EF-6 was dated December 3, 1975, subsequent dates were December 30, 1975, February 3, 1976,
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w and Ap ril 2,1976.
No inspection stamps had been applied to any of the inspection columns for any of the dates except April 2, 1976.
An inspector's acceptance stamp had been applied on the April 2,,1976, record for EF-6 on columns NVD, IP and IS but they were " whited out."
The F&M quality control manager stated that apparently the stamps had been applied in error and agreed that the use of white ink to blot out the inspection stamp was not the correct way to delete an entry.
(Procedure requires an incorrect entry to be lined out and initialed and dated by the person deleting or correcting the entry.)
\\
t A storage procedure record dated May 31, 1974, was examined in detail because the inspection stamps (No. 106) indicated that Individual "A" had performed the inspections.
The substations inspected did not include EF-6.
No evidence of falsification could be found.
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j Material Releaya Record No. C-14-388
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l This was a copy of the same record observed in the Bechtel files. The i
F&M quality control manager did not have a copy of this record in his
!
files since the equipment was not "Q listed."
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Other documentation reviewed at F&M includ'ed:
!
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Corrective Action Reports Nonconformance Reports Inspection Records Inspector Stamp issue and control records Toledo Edison Comoany (TECO)
j
Interim Release Sheet No. 5-2
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This is a form used to release equipment to TECO for functional testing,
]
calibration and initial operation.
Substation EF-6 was among the 480 l
volt load centers listed on Release No. 5-2.
The ralcase was initiated on October 18, 1974, approved by Bechtel on October 21, 1974, and approved by TECO QA on October 29, 1974.
Interim Release Sheet No. 6-7 l
-
{
480 volt MCC's E-61, E-62, E-63, F-61, F-62, and F-63 were included in j
this relcase initiated on December 30, 1975, and final accepted by TECO
'
on February.3, 1976.
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Interviews with current FSM Ouality Control Inspectors (m>
During the period June 2-4, 1976, Ind iv idual s
"F", "G", "!!",
"I", "J",
"K",
"L", "M",
and "N," all current F&M quality control inspectors, were interviewed at the Davis-Besse reactor construction site.
During a subsequent visit to the site, Individuals
"0",
"P", and "Q," also F&M QC inspectors, were interviewed on June 10, 1976.
The substance of these interviews was similar in that the following comments were made in each case:
.
1.
There was no knowledge of falsified reports and no pressure to falsify reports.
2.
Each individual stated that he knew of no problems relative to safety of the plant which he felt should be reported to the NRC.
(However, during the interviews several of the inspectors did mention problems previously identified by the NRC, including the fabrication and welding of seismic supports for electrical conduit and occasional difficulty in pulling cable in conduit.)
3.
The inspection workload was described as acceptable.
4.
Working inspectors were satisfied with the resolution of Inspeccion Reports.
5.
Final, typed versions of Inspectivn Reports are signed by the
'N Inspector who made the inspection, after checking the final
,/
report for accuracy.
s 6.
Inspection procedure books are removed when procedures are revised, but a procedure book is always available for reference, if necessary.
7.
In general, the revised procedures are more stringent or more detailed than the original procedures they replace.
'
Interview of Individual "D" on June 3. 1976 Individual "D" was reinterviewed on June 3, 1976, to clarify earlier statements, and to assure that the NRC was aware of any other items i
of concern.
Individual "D" stated that It.dividual "A" was hired in May, 1974, as a Junior Quality Control Inspector and that one of his first duties was to do inspections of equipment in storage.
Individual "D" indicated that Individual "E" had asked Individual "A" to date and
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stamp a report for pull-out breakers, when the breakers were not even at the site at that time.
He stated that this request was made in
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t'he Quality Control of fice of F&M, and that neither he nor Individual "B" were physically present when the request was made, although they were present when the report was dated and stamped.
Individual "D" indicated that he and Individual "B" had signed a 3x3 card attesting to the falsification of the report on the day that the report was signed, but that he no longer had the card, having loaned it to Individual "A".
Individual "D" stated that he was not aware of any other inspectors having been asked to falsify records, and that he had not falsified any records.
Record Review on June 4, 1976 On June 4, 1976, the IE:III Investigators were provided uith a copy of F&M Inspection Report No. 0587A, dated May 17, 1976.
This report was made subsequent to an F&M record audit which was instituted to resolve record discrepancies noted during the initial NRC investigation record review. This report contains the suspected falsified report as an attachment, and indicates that it was known that units ES, EF6, and F5 were not on the site, but were included on the record for paperwork purposes.
Pertainent pages of this report are includcd as Exhibit A.
Interview with Individual "A" on June 9. 1976 s
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Individual "A" was interviewed again on June 9,1976, to clarify earlier statements and to assure that any items of concern that he might have, had been identified to the NRC.
Individual "A" indicated that there were a number of inspections that he refused to sign and his supervisor had signed.
(The signing of inspection reports by the supervisor is allowed by procedure.
In a sample examination of inspection reports no improper resolutions were identified by the MRC inspectors).
He stated that he knew no other inspector who had been asked to falsify a report. and that he had not been threatened when asked to falsify the rescre in question.
He was just tired of talking to him (Individual "E") he indicated, so he had " signed off to keep the paperwork correlated." He said that documentation was'the primary purpose of his work, and the company
'
wanted the paperwork to "all fit togethar."
Individual "A" was shown a copy of the suspected record, the "Q"
Draw-out Ascembly Inspection Record which showed inspections on
.
May 5, 1974, and asked if he could identify it as the allegedly
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falsified record. or comment on it in any way.
Individual "A" s
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could not posit'
ly identify the document, and refused to give a written stater.: concerning it.
He indicated that the record may be the vac in question-but that he only had to put his inspection stamp on it.
When ad'
.. that May 5, 1974 was a Sunday, Individual "A" stated that he had never worked on a Sunday, but that the date was correct, give or take a few days.
EF-5-6 had been added on July 25, 1974, he indicated, and he had been asked to sign and back date the inspection record to May 5, 1974.
.h stated that the report was a part of the monthly storage report that went to the Bechtel Corporction on the fifth of
>
each month, and that the inspections were donc, and the dates changed, so that the paperwork would correlate.
He stated that he had no idea a
why they should want him to falsify this particular inspection report, except for paperwork correlation, as stated above.
Quality Control Inspection Reports were deliberately rewritten in a confusing style by his supervisor, he indicated, but the basic facts were in the reports, or he would not sign the reports.
Interview with Individual "E" on June 10. 1976 Individual "E" indicated that he was the Quality Control Manager at the time the alleged falsification of a record took place.
He stated that he had no knowledge of any record falsification, and that the allegation
'g of record falsification had been a shock to him.
Individual "E" was shown the suspect record, the "Q" Draw-out Assembly Inspection Record showing inspections on May 5, 1974, and uas asked to comment on the apparent discrepancies as to date and equipment inspected.
Individua?. "E" indicated that this record was a "one-time item" and was used
.s a device to begin the accountability for the
equipment involved.
He stated that the lack of a number in the column for number ot assemblies reflected the fact that these assemblies were not on hand at that time.
,
When questioned concerning the Sunday, May 5,1974 date, Individual "E" stated that the date had to be in error, as no work was ever done on a Sunday. Monthly storage reports were required on the fifth of each month, he indicated, and this date may have been used in error.
'
Individual "E" stated that he did not remember asking Individual "A" to stamp and date this record.
The record itself, and the discrepancies it contains, he indicated, reficct " honest mistakes by the people involved" and " reflected the inexperience of the inspecter involved".
Individual "A" may have misunderstood the date put on inspections, he said.
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At the end of the interview, Individual "E" uas asked to make a l
written statement concerning the 1.nspection report in question.
This l
written statement is attached as Exhibit 11.
Interview with Individual
"O" on June 11, 1976 l
Individual "0" we.s Individual
's" immediate supervisor during the j
period in question.
He stated. hat Individual
"A" had not come to him l
with allegations of falsified records or items of concern over
.
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l electrical installations while employed.
Individual "0" denied asking j
l or pressuring any inspector to falsify any inspection report, and l
l indicated that all inspectors had been advised not to sign any l
l inspection report that they do not agree with.
!
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l Individual "0" indicated that Individual "A" of ten had problems with the dates on his inspection reports, and that Individual "N" who i
l reviewed the reports, often had to correct ice =s
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Attachments:
Exhibits A and B O
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w - . u.
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. . i . DES CH I T'!'I Ob'/D 7".C3 E *: ^ C f( C t 3 ".-' / . I T !.:" - - .. .. _.. - - - - m- . -,.u ... m ;.... t:C Y /,D.,I,.S. m?.CS. I.T..I.m._, ,.m._, ,.1,,..., _,.....,_...u ,
........ ..m . I , , .. , .. . .1- , 1.
, "Storat.c Renort...for Month of Anril,..." should have been "... for I ' ' .- !. Month of May,...". ' , .
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- 2 2(c')'he Ecchtel Welding Engineers' initial
- on the Wcld Call.Tecet do not
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signify acceptance of the '. cid joint.
His initial: cn the can chect j ' on.ly r,can that he has reviewed the call chcot for eccpletenc : and he , j found it acceptable.
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a l3 (b Touy-off" chould have been "by".
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. ! , cc: P. Britncil (3cchtel Q\\) W. Columbia J. H.rrie , l J. Heaton (Ecchtel (C)
' F. Kollin
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l J. Lenardson (TECo QA) I' l Q. Waite P B. Wilber ' , I ] , , I , > ~ gr.% - %.,). )
De ,. ' , N UM' j.. -... 4.. o.... .. ,..u.,4w r,, ...,u ,2w..w. ue:. ec w.v. c.c :.v m,,. u.u.,..v., u.a.,.. n.. r...: y-vr v..
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.FI S C II r..i c it.,\\ N 1)..M o u it i. 1.s s. u r r v i..t i r. i e i i., a i t u i i.; i 4 - - h N ' t.'t' 76 - .4 D * " * ' * . i .P l.. ) : _ C O I.G.\\ N C !. I.c T i; 1 C 0 M l',\\ N Y, 1 N C. n -- rI L
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E:UlIDIT "B" . - , A-C i (Previcuciv decinr.nted Q-ochi) :Inted M ::0'/ 7 7, : h In-licunc !:CR: I i - I d i.
L b . PV 1
O.blA l \\ l,n, v?. ,E- = ) s Concurrence c.
' d.
ilciding in pector w a s s
e / (i 3 E:CEDIT "C" ',l i "Q" Draw-Cut A :cmbly Incpection Record Fern QCD/77h9 Lh. Rev. O, 15 ATR 7k I s '{ [ (a) To perform initial inspecticn of all "Q" Draw-cuts a: directed by Bechtel [ (Attach =cnt-5), Sub-Station: E5, EF6 cnd F5 ucre also listed on the data [ chcot thouch not received at the time.
In keeping with the purpose of the p document ( Attach 2cnt-6)., c aterisk: were used by the Inspector (I'o. IC6 ' ?.ca Che:tnutwood) to denot that no "Q" Draw-cut: ucre kncwn to have been rcccived at that time.
I (.b) Non-Q Cub-Staticn EF6 with Drau-outs as then r:ceived by Ecchtel en C1 CCT Th ! with acceptance buy-cff Field Engineering (Ed Rubec) on 17 CCT 7h ( Attac'r.cnc-7; r
l (c) An oversicht a: to Sub-Station EF6 not beinc in pected has been ude in ] i recent monthly storace reports.
All Draw-out; arc'noV Creen tOCged.
Interita Relcace Sheet (Forn 1) turnover approval took place on 25 oCT yh ' by TECo ( cc Attachment-8).
/ L. / . $,,, Concurrence of Exhibit "C" (a,b): Q V h / Q b 2d.__'.>., ./__6_?_R?'.'/ K -. Data Coordinator Concurrence of Exhibit "C" (c): ffi [/ /,- .-, s'..p',, / /~' O.-/'.. 7 /.
1luterial C:o t..:ir.a tor a G . a b=----.-----.,_,,,_s,_.,__m,_,,,,,,,,,_,,_.c,,,,,,,,,.,_,___, .. ., .. . . -... EXilllll T A
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- i 4 o i t. v i i u i s
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- . _ I;G E : Each of the above involved docun.cnt cither have been or will be corrected as appropriato before final docu:.entation turn-over to Ecchtcl. A final stamp has been propoced by Rev. II of the QC Manual to accure accurate completion of docu::.cnts.
- . . . d . . . , l - ' - . l . . s l - t
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- l-cc: P. Brituell (Ecchtel QA) - ' W. Colwr.bia
i J. Itarris J. Hecton (Bochtel QC) - - . , l F. Kollin - J. Lenardson (TECo QA) . . i . . ! Q. Waite h] . B. Wilber , (. . - . ,- , - 'WWWmert.ramrea# ee emingsmusawwqspam 4 we.eammutartenscuestmJ = = ma-t a u se*Lemmm mmmmy .gg , - < . . f - ~ -_ _ _
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p - ( 2. $. (. . ( Poil Offke Cox 449 ,, % -
- hl[6./M P :: Chnion, OMo.t3157 "QM C L' ~ Pl.ono 417-878 2761 _ W C.
. January 31, 197h E. R.
FLlh LOO q T'[f- & [k @l $ - . , Picchbach "corc/ColCan Electric 7f( f" 6 O- ?.0. !!ox 639 Port Clinton, Ohio h3hS2 ~.., _ =.. _. . --=- Attention: Vr. If, MacLeod Davic-Ecsse Nuclear Power St'.tica The Toledo Ediscn Cocpany Contract No. 7TL -14
- . Electrical Iactallatica Newly Designate:1 "Q" Equipment Reference: [a] Pechtel letter FL1h-329, dated Dece:ber 17, 1973 [b] F&.'! Ictter lhLF212, dated Janua f 3, 197h . I ,- . Y.. ' Centleren: s . / ,eg
^--~ 3 / Reference [a] above hsc further identifierl equ.:.prent to be treated as C',\\ j Clacs lE.
Co:.nneing eith the date of thin letter, rou are directed <- - a# to i n, r ect n.nd d.c""- n.c : n e '. n c an, in c: sten in ec:/ sr<c:._ic'.;;cn3 Quality Cnntrol ' nua.1 or : e ciner 2n-hcr.ble ricc u e ;nti on. .ine n . ..ctor Centrol ~ documenting the urav cu; unit: in.;tallec in ac:1 Cl ts: 12 - Centers, vc rcquest that you identify the as "all drav cut unit: in Motor Centrol Center X:C'" uith no reference to the structure itself.
Further, no serialicatica er tracibility is required for an. of the Motor Control Center draw out units.
Tracibility back to Frecurement . Specification is naintained by Ecchtel and cen:cquently all parts are in terchan geabic. . . Many referenecc h:tvc been retdc in the past to the "Q" List; you have been given "Infor:.c, tion Only" copics of the lis t and you cre not contract-unlly bound by it.
Thcrefore, /ou should ma'.c no further refercnce to . the "Q" Liat.
Very truly ycurc, j . , ' DECHT C PO'.'ER CC;iPORATIC:! . e.V.
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I, Individual "E," make the following voluntary written statenent to' l James Foster, who has identified hinself as an Investigation Specialist , ! of the "ucicar Regulatory Ccemission.
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Regarding the "Q" Draw-out Assembly Inspection record for Sub Stations manufactured by Cencral Electric, which bears the inspection stamp No. 106 which was issued to Individual "A," and the dates May 5, 1974, on QCD For= 7749-44 Revision 0, 15 April, 1974, page 1 of 1: This record was generated for stcrage documentation purposes, in accordance with instructions from Ecchtel Power Corporation. With the i exception of items FS, F6, E5, E6, an actual inspection of the equipment was done. As May 5, 1974 was not a workday, the date is in error and may have been selected to coincide with the date of the monthly report.
Items i FS, F6, ES, E6 were not on site, a fact reflected by the lack of a number ) in the column for number of assc= blys. These items were added to begin l storage documentation.
I, Individual "E," state that I have read this statement and it is a i l true representation.
Individual "E"
Signed 10 June 1976 . j Uitness: D. W. Haves j Signed June 10, 1976 i i l i
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i EXHIBIT 3 Page 1 of 1 .
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