IR 05000373/1979030
| ML19253B479 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/06/1979 |
| From: | Danielson D, Marsh R, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19253B474 | List: |
| References | |
| 50-373-79-30, NUDOCS 7910160248 | |
| Download: ML19253B479 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEhT
REGION III
Report No. 50-373/79-30 Docket No. 50-373 License No. CPPR-99 Licensee:
Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name: La Salle County Station, Unit 1 Investigation At: La Salle Site, Marseilles, Illinois NSSS Supplier, and Licensee Vendor offices Investigation Conducted:
January 9 and 10 and August 21, 1979
}Y/ fd Investigators:
K. D. Ward
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.y Approved By:
D. H. Danielson, Chief
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Engineering Support Section 2 (Dafe)
h, CW b.E.Norelius (lfCf 7')
Assistant to the Director (Date)
Investigation Summary Investigation on January 9 and 10 and August 21, 1979 (Report No. 50-373/79-30)
Areas Covered:
Because of allegations regarding falsified qualification and certification documentation for selected subcontractor personnel performing nondestructive examinations (NDE) on safety related systems components, reviewed qualification and certification records, NDE work logs, and conducted interviews. The investigation involved a total of 23 onsite investigation-hours by two NRC investigators.
Results: Allegations of records falsification were basically substantiated.
Of_the three areas investigated, one apparent item of noncompliance was identified in three areas (Infraction - Falsification of experience, training, an eye test, failure to demonstrate as a Level I-UT and exami-nations not being complete for Level II individuals See Paragraphs 3.a, 3.b and 3.c of details).
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INTRODUCTION The Materials Assurance Company is one of several subcontractors supplying nondestructive examination services for the La Salle County Nuclear Power Station, Unit I site, under contract to General Electric, Installation and Service Engineering Division (GE, I&SE) Oakbrook, Illinois. The nondestructivt examination (NDE) services provided by the Materials Assurance Company to GE/I&SE are limited to liquid penetrant, (PT) and ultrasonic examinations (UT). NDE personnel are hired by Materials Assurance Company on a consultant basis and, following qualification and certification by Materials Assurance Company, work under the supervision of the GE, I&SE Quality Assurance manager at the construction site.
REASON FOR INVESTIGATION
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On Decem er 13, 1978 a telephone call was received by Region III in which b
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:
1.
Falsification of Certification Records - Testing 2.
Falsification of Medical Certificate (Visual Test)
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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 a nuclear power construction site (other than La Salle) which had utilized the services of the Materials Assurance Company. Due to inconsistancies noted in the certification records of the two onsite MAC employees (identi-fied as M-2, M-3), correspondence was initiated with selected past employers of MAC employees M-2 and M-3.
Attempts were also made to locate the-2-
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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 and corroborated the allegations as they pertained to that site.
On January 9 and 10, 1979 the investigation was continued at the La Salle County Nuclear Power Station, Unit One, Marseilles, Illinois. Additional irregularities were identified in MAC certification records which again required offsite investigative efforts to determine the authenticity of those records.
In some cases the irregularities uncovered were pertinent tp the investigation only as it addressed MAC operations at sites other than La Salle and therefore those specific irregularities will not be discussed herein.
On January 18, 1979, in a meeting with MAC representatives at the NRC offices, MAC management agreed to provide " corrected" certification documents for their employees. On February 5, 19'i9 MAC provided
" corrected" certifications for four employees.
These new ca.rtifications identified additional inconsistancies concerning previously submitted statements of work experience, training history, and the accomplishment of required eye tests.
The offices of General Electric / Installation and Service Engineering (GE/I&SE), 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 allegations was substantiated.
In those instances where substantial evidentiary
" fact" could not be obtained, a preponderance of circumstancial evidence pointed towards the truthfulness of the allegation.
CONCLUSIONS 1.
Allegation One (Falsification of certification reccrds - testing)
was earlier found to be substantiated. Additional examples of noncompliance were identified at La Salle in the form of improper certification records for MAC examiners M-1, M-5 and M-6.
2.
Allegation Two (Falsification of Medical Certificate (visual test)
for MAC examiner M-!) was found to be substantiated.
M-1 was found to pc<sess, by statement of the MAC President, a falsified medical certi.
ate (visual test).
M-1 was further found to be unable to satisiom torily perform at the levels for which he was certified (Ultrasonic examinations at Level I).
This falsification and failure to perform were identified as additional examples of non-
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compliance with NRC regulations cited above (Criterion IX).
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3.
Allegation Three (Suspected falsification in MAC examiner M-2's certification records) Previously corroborated as substantiated.
Additional examples of past experience / training, certification entries were identified for MAC employees with a work history at the La Salle (Unit One) construction site. These record falsifications were identified as additior.al examples of noncompliance with NRC regulations cited above (Criterion IX).
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The irregularities alleged were, as a result of this investigation, found to pervade the MAC operation to a greater degree than in the
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specific instances addressed by the allegers.
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DETt.!_T.S 1.
Persons Contacted Confidential Sources Individual A Individual B Individual C
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Materials Assurance Company (MAC)
- Peter K. Olsen, President Patrick W. Cox, Quality Assurance Manager Employees M-1 thru M-12 General Electric - Insta11atic; & Service Engineering (GE/I&SE)
W. Kozik, Quality Assurance Manager
- R. E. Spencer, Site Manager
- C. T. Brinson, QA Representative
- L. W. Wheatley, QC Supervisor
- J. Decker, NDE Supervisor
- M.
Hart, NDE, Level III Commonwealth Edison Company (CECO)
- L. O. DelGeorge, Nuclear Licensing Administrator
- T. Quaka, QA Supervisor
- E. R. Wendorf, Field Engineer
- G.
E. Groth, Start Up Engineer
- R.
C. Lescinski, QA Engineer
- J. R. Kodnick, QA Mech. Cond.
The investigators also ccntacted an interviewed other licensee and contractor employees.
- Denotes those present at the exit interview, January 10, 1979.
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 La Salle Unit 1 and other nuclear power plant construction 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,
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correspondence with selected past employers and medical specialists.
This investigation also addressed the appropriatenes
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of licensee and subcontractor managerial action where previous knowledge of these allegations was indicated.
On December 15, 1978 Individuals "A" and "B" were interviewed.
On January 4 and 5, 1979 an investigation was conducted at the construction site initially discussed in the allegations.
On January 9 and 10,1979 an investigation was continued at the La Salle 1 construction site, due to findings of the initial phase
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of this investigation that tended to corroborate the allegations.
On January 12, 1979 Individual
"C" telephonically provided the RIII investigators additional information corrobative of the allegations under investigation.
On January 18, 1979 a meeting was held with MAC management personnel at their request.
On January 30 and 31,1979 an investigation was conducted at a third nuclear power plant construction site.
On February 5,1979 MAC management provided RIII " corrected" certifi-cation forms for several e,ployees.
On February 7,1979 an investigation was conducted at GE/I&SE headquarters.
On August 21, 1979, a followup visit was made to the La Salle site to review corrective action taken by the licensee regarding the noncompliance identified in the early phase of the investigation.
At various dates throughout the investigation, correspondence was conducted with various firms and medical sources in an attempt to authenticate MAC certification entries.
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3.
Findings The following numbered allegations are those developed from infor-mation provided by Individuals "A",
"B", and "C":
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Allegation One:
" Falsification of Certification Records - Testing" Discussion Individual "A" alleged that qualification tests required by
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SNT-TC-IA (June 75 edition), Section 8, " Examinations" were never administered to him during the period of his tenure with i,::
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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 completed MAC Form 1
" Certification Statement" for Liquid Penetrant, 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
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"C" also alleges that written qualification tests as specified above were never administered during his tenure with MAC.
Findings During the investigation of January 4 and 5,1978 it was found 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".
It can be noted that Individual "C" had no identifiable work history at the La Salle site.
Review of the " current examinations" prceided by MAC management 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 heading
_(name, address, etc.) of each test appears identical for the series attributed to both Individual "A" and to Individual "B".
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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 statement 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 test dates but not near the locations identified by the President MAC as being the sites where the tests were administered. Further, Indi-vidual A states that the February 11, 1978 test date listed predates his first awareness / contact with any representative of MAC (approximately last week of March '78).
A review of the MAC supplied NDT Level II Ultrason -a exam, alleged to have been completed by Individual A, and the corresponding MAC Form 1 " Certification Statement" for Indi-
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vidual A reveals that although individual A is certified as a Level II examiner, only a Level I practical has alleged to have been administered.
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A further review of the MAC certification records conducted at the La Salle construction site disclosed similar discrepancies in the following instances:
(1) MAC employee M-1 was found to be certified as a Level II examiner in both liquid penetrant (PT) and ultrasonic (UT)
examinations, yet required records presented to the investi-gators documented only a Level I Practical examination in ultrasonic examination having been administered.
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(2) MAC employee M-5 was found to be certified as a Level II individual in PT, but records presented revealed only a Levet I Practical examination in PT was administered.
(3) MAC employee M-6 was found to be certified as a Level II individual in UT, but, again, only a Level I examination (UT Practical) was found on file.
The above examples of incomplete certification are items of noncompliance with NRC regulations in that they are contrary to 10 CFR 50, Appendix B, Criterion IX which requires that special processes (including nondestructive examinations) are accomplished by qualified personnel.
In an interview at La Salle on January 10, 1979 of MAC employee M-1, who is certified as a Level I in Ultrasonics, M-1 failed to demonstrate to an NRC representative (a Level III NDE Examiner in UT) that he could satisfactorily calibrate, explain, or perform any type of ultrasonic examination.
H-1 declined to retake his Level I Specific or General knowledge tests for UT or to respond to verbal questions concerning his knowledge of UT procedures. A review of M-l's certification and test records revealed M-1 is certified as having scored 83 on his General (UT) Level II, and 90 on his Specific (UT) Level II tests in January, 1978. No explanation as to why a Level II series of tests were administered M-1 was provided.
M-l's Practical examination (UT) rt Level II was found to have been downgraded a total of 10 points for "d, 'ng or plan utilized" (-5), and
" safety, cleanliness, neatness" (-5) yielding a score of 90 for M-1.
The above is an addition:1 example of noncompliance with NRC regulations in that it is contrary to 10 CFR 50, Appendix B, Criterion IX which requires that special processes (including nondestructive examinations) are accomplished by qualified personnel.
These investigative findings at La Salle construction site, coupled with earlier investigative findings, are corroborative
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of Allegation One which is therefore cubstantiated.
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b.
Allegation Two:
' Falsification if Medical Certificate (Visual Test) for MAC examiner (M-l'."
Discussion Individuals A and B allege that the SNT-TC-1A required certi-fication of visual acuity (MAC Procedure MAC-77-026, Rev. 4, Para. 8.1.a and form IV, Jaeger Vision Test) for MAC examiner
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(M-1) has been falsified.
Finding When interviewed on January 9,1979 at the La Salle site, MAC employee M-1 advised the NRC investigators that he had acquired his eye test certificate in early 1978 from an optometrist in West Palm Beach, Florida.
M-1 stated that he was referred to this optometrist by a girlfriend who was a nurse.
M-1 was unable to provide any additional details regarding the identity of the eye doctor or his location. He stated that he could not remember the optometrist's address or the section of town or local landmarks.
It was noted that a new vision test certification for M-1 was present among " corrected" certification documents provided the NRC by MAC President P. Olsen, on February 5, 1979.
When questioned about the status of the original certificate for M-1, Mr. Olsen stated that it would have t<
be considered false.
A similar situation was noted for MAC employee M-7 who also had a questionable vision test certificate replaced on February 5, 1979 by MAC President P. Olsen.
Mr. Olsen also indicated M-7's original eye certificate would have to be considered false.
The above are additional examples of noncompliance with NRC regulations in that they are contrary to 10 CFR, Appendix B, Criterion IX which requires that special processes (including nondestructive testing) be accomplished by qualified personnel.
An interview on January 3, 1979 with MAC examiner M-3 also raised questions regarding the validity of M-3's eye certif-icate.
M-3 could provide only vague recollections on when and by whom his eyes had been tested.
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 his eyes checked "around Boston, Mass." just before he
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began work with MAC in July 78 at La Salle, Illinois.
Subsequent checks on January 4, 1979 witb the Bell Telephone Company for
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any listing (private or professional) in the Boston, Massachusetts environs with the name of the medical examiner listed on the certificate (or any similar name) resulted in a negative finding.
When NRC's inability to locate this medical specialist was discussed with M-3 on January 4,1979 he could prcvide no additional information and declined to make any additionsl 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)
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for M-3, dated January 11, 1979. When asked by the NRC investi-gator about the validity of the original medical certificate for M-3 provided to NRC on January 3,1979, !!r. Olsen stated that "some of the allegations you received must be considered as irne."
When specifically asked to comment on M-3's medical etrti'.icate he stated it "would bm e to be considered false."
A review of work records at the La Salle construction site revealed that MAC examiner M-3 had performed the following NDE, including those on safety related systems, during a period in which no valid medical certificate was available for him.
Date Examinat an Data Sheet Work Performed 7/26/78 EDS 50001 PT II I-MS-1003-1,LD,LV (Liquid Penetrant)
8/2/78 EDS 50008 PT II I-MS-1001-13LV-18 8/4/78 EDS 50011 PT II I-MS-1003-30 9/28/78 EDS 50033 PT II I-MS-1054-1 10/11/78 EDS 50035 PT II I-HP-1001-41 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 examinations) are accomplished by qualified pernonnel.
The investigative findings at La Salle construction site and other locations are corroborative of Allegation Two which is therefore substantiated.
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Allegation Three:
" Suspected falsification of certification records - experience and training."
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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 in UT and PT.
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Findings Correspondence with "past employers" specified by M-2's "Certifi-cation 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 training record of his having received "80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> 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 and before the above 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 in connection with an official investigation.
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 a similar manner " corrected" certification statements were received on February 5, 1979 for MAC employee M-1 deleting previous claimed work experience at General Dynamics / Electric Boat Division (UT & PT Level I) during the period 4/70 to 9/71.
Also deleted for M-1 were claims of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of UT training and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of PT training.
Additionally, it was noted that the details of when, where and how the required certification tests (General, Specific, Practical)
were administered differed greatly as provided by M-1 and MAC President P. Olsen.
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The " corrected" certification forms for MAC employee M-7 also exhibited the deletion of work experience originally claimed
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with Babcox & Wilcox (7/74 - 8/75) and training (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> PT, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> UT).
The above examples of apparent falsification (as sc identified by MAC President P. K. Olsen) of werk experience, and training certification records are all additional examples of noncompliance with NRC Regulation in that they are contrary to 10 CFR 50, Appendix B, Criterion IX which requires that special processes (including nondestructive examinations) are accomplished by qualified personnel.
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The investigative findings at La Salle, and other sites, are in corroboration of Allegation 3 which is therefore substantiated as true.
4.
Other Findings The follcwing results of the investigation as it addressed the~ role of GE/I&SE, although not specifically pertinent to the La Salle portion of this investigation, are included since they provide insight into the adequacy / efficiency of one of the licensees sub-contractor's quality assurance program.
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. Dykes description of the specific information received from individuals 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 tele-phonically provided to their management (Mr. W. Kozik, Quality Assurance Manager) at Oakbrook, Illinois " shortly" after they became aware of them.
During the Februcry 7, 1979 visit to the GE/I&SE facilities at Oakbrook, Illinois by the RIII investigators, Mr. Kozik confirmed
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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 allegations 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 evaluation 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.
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Other matters not pertinent to the La Salle portion of this investi-gation were also discussed.
In an exit briefing, limited at Mr. Kozik's j
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request to himself, GE/I&SE was advised that the NRC investigators viewed the response by GE to these allegations to be superficial; particuiarly so due to the nature of the NDE work being performed by this GE subcontractor on the reactor vessel internals.
5.
Followup On August 21, 1979, the NRC investigators returned to the La Salle site and while there reviewed the licensee's actions to clear the identified item of noncomplionce. The licensee's corrective actions
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are detailed below.
Corrective Action Taken and Results Achieved A complete reaudit of MAC certification documentation was
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accomplished.
Items checked included documentation on eye examinations, certifications, including copies of examinations, work experience, and training. This was completed February 15, 1979.
Inprocess Audits were perforced on all MAC KDE personnel by GE/I6SE
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Level III examiners with an additional 10% overview audit by CONAM and NDE Company and Licensee QA personnel.
NCR's were generated to reexamine all accessible work performed
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by MAC NDE personnel.
(Investigators Note:
GE/I&SE pe:sonnel indicated reexamination of M-3's work revealed him to te con-sistently over-conservative in his examinations with a resultant record of rejection of acceptable work).
Corrective Action Taken to Avoid Further Noncompliance Letters have been sent to all NDE subcontractors stating they
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must show proof of eye examinations, work experience, training, and certification including copies of the examinations.
GE Corporate survey and site auditing systems will be improved.
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Personnel involved in these systems will be instructed that the NDE company and their personnel reporting to the site must st.;w proof of documentation. This will include names and addres es of eye examiners, certification of prior work experience, proof of formal training (i.e. diplomas), and proof that certification examinations were performed by qualified personnel. This will be done on an individual case basis.
The Materials Assurance Company has been removed from GE/I&SE's
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Approved Vendor List.
All MAC personnel were removed from the La Salle site by
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February 28, 1979.
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Exit Interview The investigators met with site representatives at the conclusion of the initial phase of the investigation on January 10, 1979 and summarized the scope and findings of the investigation.
Paragraph 1 identified the meeting attendees. The licensee teknowledged the information.
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