ML12192A501
| ML12192A501 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/08/2010 |
| From: | Holland C NRC Region 4 |
| To: | Collins E NRC Region 4 |
| References | |
| FOIA/PA-2012-0010 4-2010-016 | |
| Download: ML12192A501 (17) | |
Text
CASE No. 4-2010-016
Ž V9 United States Nuclear Regulatory Commission Report of Investigation SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2:
FALSIFICATION OF QUALITY ASSURANCE DOCUMENTS AND VERIFICATIO OF ALTERNATING CURRENT ELECTRICAL CABLES Office of Investigations Reported by OI:RIV Information in this record was deleted in cgtorGdfl' withIIM A
4 4.
UNITED STATES
'~1 NUCLEAR REGULATORY COMMISSION 4
OFFICE OF INVESTIGATIONS FIELD OFFICE, REGION IV 0 612 EAST LAMAR BLVD, S UITE 400 ARLINGTON, TEXAS 76011-4125 9
September 8, 2010 MEMORANDUM TO: Elmo E. Collins, Regional Administrator Region IV FROM: Crystal D. Holland, Director Office of Investigations Field Office, Region IV
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 -
FALSIFICATION OF QUALITY ASSURANCE DOCUMENTS AND VERIFICATION OF ALTERNATING CURRENT ELECTRICAL CABLES (CASE NO. 4-2010-0161RIV-2009-A-0177)
Enclosed, for whatever, action you deem appropriate, is the Office of Investigations (01) Report of Investigation concerning the above matter.
Please note that documents may have been gathered during the course of the investigation that are not included in either the report or the exhibits. This additional documentation will be maintained in the 01 case file and available for the staff's review upon request.
Neither this memorandum nor the report may be released outside the NRC without the permission of the Director, 01. Please ensure that any internal office distribution of this report is controlled and limited only to those with a need to know and that they are aware of the sensitivity of its contents. Treat as "Official Use Only - 01 Investigation Information."
Enclosure:
cc w/enclosure:
R. Zimmerman, OE cc w/o enclosure:
C. Scott, OGC E. Leeds, NRR (Attn: G. Cwalina, OAC, NRR)
Septenber 8, 2010 MEMORANDUM TO: Elmo E. Collins, Regional Administrator Region IV FROM: Crystal D. Holland, Director Office of Investigations Field Office, Region IV
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 -
FALSIFICATION OF QUALITY ASSURANCE DOCUMENTS AND VERIFICATION OF ALTERNATING CURRENT ELECTRICAL CABLES (CASE NO. 4-2010-016/RIV-2009-A-0177)
Enclosed, for whatever action you deem appropriate, is the Office of Investigations (01) Report of Investigation concqrning the above matter.
Please note that documents may have been gathered during the course of the investigation that are not included in either the report or the exhibits. This additional documentation would be maintained in the 01 case file and available for the staff's review upon request.
Neither this memorandum nor the report may be released outside the NRC without the permission of the Director, 01. Please ensure that any internal office distribution of this report is controlled and limited only to those with a need to know and that they are aware of the sensitivity of its contents. Treat as "Official Use Only - 01 Investigation Information."
Enclosure:
cc w/enclosure:
R. Zimmerman, OE cc w/o enclosure:
C. Scott, OGC E. Leeds, NRR (Attn: G. Cwalina, OAC, NRR)
Distribution:
s/f (4-2010-016)
I(b)((Cc) pI:HQ DOCUMENT: S:\OI\FY2010CASES\Closed Cases OFFICE.. " ORIV OI:RIV "NAME ICHolland .
DATE OFFICIAL RECORD COPY
\OF
~OFitl AYTUE LY 01 IN STI ATIO INI 3M/ATi N
Title:
SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 FALSIFICATION OF QUALITY ASSURANCE DOCUMENTS AND VERIFICATION OF ALTERNATING CURRENT ELECTRICAL CABLES Licensee: Case No.: 4-2010-016 Southern California Edison Company Report Date: September 8, 2010 P.O. Box 128 San Clemente, CA 92674-0128 Control Office: OI:RIV Docket No.: 50-00362 Status: CLOSED Allegation: RIV-2009-A-0177 Reported by: Reviewed and Approved by:
Crystal D. Holland, Director i'-r Office of Investigations Field Office, Region IV Field Office, Region IV
,/fAARNINN DO NOT DISSEMIN E, PLACE IN O*
_BL-16ý RNOM, OR DtS/*USS THE CONTENTS 0 THIS REPORT 0 'INVESTI ATIONUTSID NRC itHOUT AUTHORITY OF T E APPROgVING FFICIAL OF T,&IS-fEPORT. A RI ED DISCLOSUREy Y RESULT VERSE ADMINISTRATIVE ACTION AND/OR'1' CRIMINAL PROSECUTION.
.INORMATL OFFICIAL USE ONLY- O61JESTLGATION
/ OFFICIAL USE ONLY - 6INVySTIGATIIN I* A7O SYNOPSIS This investigation was initiated by the U.S Nuclear Regulatory Commission, Office of Investigations. Region IV on December 21, 2009, to determine whether the printed name of an I(b)(7)(C) Iemployed at Southern California Edison's San Onofre Generating Station (SONGS), San Clemente, California, had been deliberately forged on quality assurance (QA) documents to reflect that the QA verification checks had been performed on electrical cords.
Based on the evidence deveLed .during this investigation, the allegation that the printed name of an (b)(7)(C) lemployed by SONG's had been deliberately forged on QA documents o refect that the QA verification checks had been performed on electrical cords was not substantiated.
JNOT+FgI4UB C DIS OS\RE WIT U PPROV OF ~LDOF JE D EC R, SFOFI;CEF 1I ESTIG TIO ,REGION I\Q t-E'\
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TABLE OF CONTENTS Page SYNOPSIS 1 TESTIMONIAL EVIDENCE ............................................ 5 DOCUMENTARY EVIDENCE ........................................... 7 DETAILS OF INVESTIGATION ............................................................ 9 Applicable R egulations ......................................................................................... ..9 P urpose of Investigation ....................................................................................... .. 9 Ba ckg ro und ................................................................................................... ..... 9 Coordination with NRC Staff ...................................... 9 A lle g a tio n No . 4 ................................................................................................... . . 10 A gent's A nalysis ..................................................................................... . . . 10 C o nclusio ns .............................................................................................. . . 12 LIS T O F EXHIBITS ................................................................................................................ 13
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O~*~IAL-USE - IOINv sTIYATION)NFO MATIQ TESTIMONIAL EVIDENCE Exhibit
___________________________Bechtel (b)(7)(C)
Corporation (Bechtel),
ban Unofre Nuclear Generating Station (SONGS San Clemente, California .............. 6 b)((C)
Bechtel, SONGS ......... 5 (b)(7)(C) ] ~~B e c h tel, S O NGS .............. . .. . ......
. . . . . .. . . . . . . . . ..8 (b)(7)(C)
FBechtel, SO NG S .........................
...................................... 7 (b)(7)(C)
IIBechtel, SONGS ........... 4 Case No. 4-2010-016 5 ._j o*F'CIAL-sE oX-I-Y'-,, INVETo , o TX-A-,10 P6-RMATION
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THIS PAGE LEFT BLANK INTENTIONALLY NOT FOR PUBLIC DISCLOS*,RE WIT TPO0 DIRT*R APPROVALF OF FILN OF
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Case No. 4-2010-01&
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OFIFICI'AL US'E ON.L~Y -1O ItEAG~ONJN4FO'MTOi \.
DOCUMENTARY EVIDENCE Exhibit Email from l (b)(7)(C)
SI '.... ........ I................................................................................................. 3 NOT FOR 'PUBC/bSCLOSR WP OVAL OFyfai,.p OFFICF 'CTOR *
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OFFICIAL S 0 DETAILS OF INVESTIGATION Applicable Regulations 10 CFR 50 Appendix B, Criterion XVII: (Quality Assurance Records) (2009 Edition)
(Allegation No. 4) 10 CFR 50.9: (Completeness and accuracy of information.) (2009 Edition) (Allegation No. 4) 10 CFR 50.5: (Deliberate misconduct) (2009 Edition) (Allegation No. 4)
Purpose of Investigation This investigation was initiated on by the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations (01), Reaion IV (RV on rh-r- 01'3 to determine whether the printed name of_(b)(7)(C) IBechtel Corporation (Bechtel),
employed at bouthem California Edison's (SCE) San Onofre Generating Station (SONGS), San Clemente, California, had been deliberately forged on quality assurance (QA) documents to reflect that the QA verification checks had been performed on electrical cords
[Allegation No. RIV-2009-A-0177] (Exhibit 1).
Background
On November 30, 2009, (b)*(7(c) IOperations Branch Div so, , N]-) received an allegation from (b)(7)(c) 'Bechtel, SONGS, that the printed name of "(7)(c) een Torged on QA documents.
According torb)7)(c) name had been forged on documents to reflect that the 120 volt AC [alternating current] and-240 volt AC electrical cables had been verified and the QA checks completed. rc)(7)(c) ]advised that he askedl(b(C ýwhether or not
- rshe had sinnR the QA documents and she allegedly responded that she had not.
7 1( l i]related thatfb(G) . printed name had been forged "at least ten times."
The cables were allegedly ugea inconjunction with safety related work in the Unit 2 tendon gallery. [(jc) )0 J lindicated that he had previously observed poorly checked electrical cable failures while working, in the tendon gallery approximately 3 weeks prior to the discovery of the falsified signatures.
Review Board met to discuss/
On December 17, 2009, a RIV Allegation
)re tions and requested that 01 initiate an investigation to determine if (b)(7)(C) printed (9c(- _c had been deliberately forged on the QA documents to reflect that fe veficrtinn c cshad been erformed. The NRC technical. point of contact isI(b)(7)(c)
)7)(C) Division of Reactor Projects, RIV (Exhibit 2).
71OFFICF RP L.CISCLOSURE OP INVE!ITUT APP 0 L OF FIELMOFFI,-DtRECTR\O GTIGAOPPS', ,.E9
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- OFFICIAL'US ONLY Y-Of IN ITN Coordination with NRC Staff On March 25, 2010, Ol
- RIV met with I(b)T)(C)I NRC, RIV, assigned to SONGS, and tasked him to identify electrical cords throu h a representational review of docum ents dated l(b)( 7)(c)
(b)(7)(c) 1C I(Exhibit 3); specifically, wheredb)(7)(c) 1 - na m e appearedaat least ten times in a row on a designated form. On April 16, 2-01-0,1(b)(7)c) I advised that after conducting his review, he could only identify documentation whe (b)(7) name appeared at least ten times on one form 1(b)(7)(C) Ibut the of is review were from PC7 Fc) as documentation for (bW)(7C) not be (b)(7)(could located (E 3,p.90).
Alle-gation No. 4: Deliberate Falsification of Printed Name on Quality Assurance Document Agent's Analysis This investigation was initiated to determine if rinted name had been deliberately forged on the QA documents to reflect that the QA verification checks had been performed on electrical cords.
Dunnq the interview ofj)( by OL:RIV, he advised that on approximately 1(b)(b7)(C) Iduring the course of conducting inspections on electrical cables to verify that 120 and 20 volt AC electrical cables were proEl ins ected by Bechtel electricians, he identified what he determined Were falsifications of b)(7)(c) -a approximately ten times in a row on one document (NFI) during a peer check. (bj)(c)(C) advised that he brought the document to b 7 )(-)jor her review, and she firmed that her hand printed name on
-7r,.. the document was not her nandwriting. )(7c) Irelated that he was performing his peer check during the replacement of the stream generator and was located at the main missile hatch 7 door were the concrete had been chipped away in order to remove the steam generator.
1(b)( )(C) 9advised that the document in question would have been kept inside of the ecnitel conex boxes on the south side of Unit 3 in a folder marked "electrical checking" that housed other Bechtel equipment. r7c) as not aware of the present location of the document, but advised that it would haveL()(7)(c) hand printed name and his personal signature by her name (Exhibit 4, pp. 9-12, 25-28).
AGENT'S NOTE: Bechtel Corporation lost their contract with SONGS in early 2009 and has been replaced by WD Associates 1(b)(7)(C) was interviewed by Ol:RIV and confirmed that she had not written the name on the document presented to her byl(b)(7)(c) ladded that the document also did not contain her badge number and that it appeared her printed name had been falsified on the document. Additionally, (b)(7)(C) jadvised that the document in question contained the names of two other Bech e (b)(7)(C landbUc)(7)(c) oth of whom she had inspected electrical cor s wi nor to the l(b)(7)(c) I(b)(7)(C) ladvised that she was offi( c I[referrin t a ae se still had in her possession that still containener previous schedu le]. (b)(7)(c s shown a copy of Exhibit 3, pp. 9-10 as a comparison of ilsified document in question with her name printed 12 times (b)(7) land confirmed that the handwriting contained on this document [Exhibit 3, pp. ana rom (b)(7)(c) - were all her personal handwriting. L(c Idid IT APPROV L OF )WOF611E 11 nIGATI6NS. IAVFGI-N ~IV\
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not have any knowledge of where the document that had her falsified printed name on it was located, but advised that she recalled that the documents were kept in the Bechtel conex box.
1(b)(7)(c) -F ecalled mainly working with 1(b)T)(C) and FZ1- uring the time period in
-76 Iquestion, when the 120 volt household electrical cor werete*'eg checked, and opined that the sheet could have gotten lost and they (b)(7)(c) J and (b)() ould have rewritten the sheet.
said she discussing this incident Rn her concerns with her Bechtel l(b)(7)(c) l*b)(c) 'and recalled himi(b)c7)(c) /telling her not to "worry about it" as they were doing things differently now (Exhibit , pp- ,-17, 24-26).
(b)(7)(c) was interviewed by OL:RIV regarding a document [copy of Exhibit 3, pp. 9-10] and advised that the forms for recording the electrical cord ins ections had changed from the initial startup to the documents being presently shown to him. I(bT)(7) advised that the names [of the individuals oerforming inspections] were transferred over from the old document to a new form. [b7(c) lexplained that nobody falsified their actual signatures: they just transferred the Bechtel em loyee's printed name from one document to another [as with 1(b)(7)(c) iname].
However, 1( 7)(c) did not recallCF)7)(c) approachinr him regarding the document in question with a concern that her name had been falsified. )(7)(C) said if ib)7(c) had that concern, he was sure that he would have verified it and t en had it transferred over to the new form. 1(b)(7)(c) advised that he gave instructions to Bechtel employees to transfer information over from one document tP..anh er, and when questioned as to whether or not he gave instructions to)(7)() andl, he specifically recalled instructing them to move the datf ation over to another sheet. lb7)c) Istated that he never tasked (b)(7)((c) la nd kLb)l 0 falsify anything or to not inspect [the electrical cords], but once the electrical cords had been inspected the data on that inspection sheet could be transferred to the proper form in use at the time. OMMT(C) advised that he was concerned with safety, and would never have instructed someone to falsify a document and allow someone to get hurt. Ib)(7) c) advised that the first forms were logs that the employees made themselves by drawing some lines on a piece of paper, and then later the w re given a specific form [provided by SONGS] with descriptions and names. b)(7)(c) advised that, initially, the procedure for conducting inspections as identified 5y NSwas not ve ood but later the procedure changed and became more professional and meticulous. (b)(7)(C) advised that all the forms (b 7)(C) completed in the initial inspections of the elet lc5Ths were probably transferred over to the new form (Exhibit 6, pp. 9-16, 17-18, 23).
L2L~pas interviewed by OIRIV and advised that the verification of the 120 and 240 volt AC electrical cords started a little before (b)(7)(C) " She recalled that SONGS had a problem a week earlier when the electrical cords in the gallery had the hot wire switched with the ground wire. j*77 recalled that during the first day of inspections, she simply used a piece of typing pa r iWd'-wote down the type of electrical cords and w checked and inspected the cords. b aid there was a two person verification process. ()7 as shown a copy of Exhibit was 3, pp- the 0,form.
verifying and related dvised that this form was the third form that they used because security that there was no falsification of the actual forms was7(Cthe7(C form.
verifyer r7 and confirmed that she witnesd rf (7 nformation [previously
-f inspected electrical cables] from one form to the more ofcial Torm, but could not recall any detailed information (Exhibit 7, pp. 7-14).
During his interview with OI:RIV, L 7 )C) reviewed Exhibit 3, pp. 9-10 and advised that this particular form was not used until the end of the inspection process as it contained numerous data fields (i.e. security tag number, description of cord, inspected by name/badge number, NOT FOR PUBLIC DISC,,L0'3URE WITHOIT APPWdVA4. OF FILU-OEFICE DIETOR,
. OFFICE..QFINVESf-GAT_*ONS, REGION IV Case No. 4-2010-016-,, 11 OFFICIAL USE ,OWtY,- 01 INVESTIGATION,41gJPRMATION
,0FF.ICIAl AL6SE ONIA 0'1 'NVEATIGA 1'N INF/R IATA verified by name/badge number, security officer, date), and was not the form that he started out using. 1(b)(7)(C) related that Bechtel employees had been directed to take the electrical cord caps apart and verify the polarity was correct and connections tight. Z(c(7)(c) jdvised there was a sense of urgency as some electrical cords had been found to be improperly wired, and it was not known if it had been a malicious act or an accident. L(¶,)(Cj) jadvised that the inspections were trying to eliminate the possibility of personal injury to any individuals that could result from improperly, wired electrical cords. (D)(7)(C) recalled that, initially, (b)7)(c) the inspections were performed in a haphazard way, were recorded on a sheet of paper with no specific form used and had very few data fields (i.e. name, number on the cord). I()(7)(c) Jsaid these forms were turned into the F377URcF (b)(7)(C) related that as new were developed, he questioned the process With (b)(7)(C) egarding how to handle electrical cords that had been previously inspected.
(b)(7)(C) tecalled being instructed Torm [previous inspected electrical cordsby J7)7c) to transfer the new'orrs. t(Df(C infniration from the old Jadvised that he was the one respnsible for writing 1 (b)(C) Jname on the new form when he transferred the data over. (b)(7)(C) :] indicaiat he did not try to copyr3b)(7)(C) ]hand wr way, but was only trying to keep track of electrical cords that had been inspected. I advised that he had previously worked withl(b)(7)(C) during the inspection of electrical cords and could verify that the inspections had been properly completed. [(b))(7) "advised that the reason for the re-inspections was due to a second electrical cord being found to be improperly wired and SONGS security got involved and required all of the previous inspections to be redone. ( Irelated that once he transferred the information sing (b (7)(C) name to the new form, the old form was most likely discarded. 1(b)(7)(c) ladvia no ill intent when he transferred the information from (b)(7)(C) form to the new form, and did not falsify any information (Exhibit 8, pp. 11-17, 19-24, 26-29, -35).
In summary, this investiaation determined that lwas responsible for ransferrin the data andl (b)(7)(c) name to the new formDUneo s at the direction of[F7)(c3 and with no in ent to talsity any documentation. The inspection of the electrical cords was an evolving process, and as forms were being devised, it entailed the transfer of the data.
Conclusions Based on the evidence developed during this investigation, the allegation that the printed name J(b7)(C) had been deliberately forged on QA uuoumeRns to renect tnat the uA verification checks had been performed on electrical cords was
.not substantiated.
NOT FC 4 aUseI r PROVA / ,FIELD0 FICE RECTO OFFIGCE F INVE TIGAlQJNS,$ EGI OIV Case No. 4-2010-0162 00 ILS ONLY
OFFICIA. USE ONN -"6 INVES N LIST OF EXHIBITS Exhibit No. Description 1 Investigation Status Record, dated December 21, 2009 (1 page).
2 Branch Evaluation, Plan, & Recommendation, dated December 15, 2009 (11 pages).
3 Email from 1(b)(7)(c) i (b)(7)(c) (10 pages).
4 Transcript of Interview with Jdated January 14, 2010 (46 pages).
5 Transcript of Interview with r)(7)C) dated April 20, 2010 (32 pages).
6 Transcript of Interview with7Z dated April 20, 2010 (25 pages).
7 Transcript of Interview with dated May 19, 2010 (19 pages).
8 Transcript of Interview with r )(7)(C) dated May 19, 2010 (40 pages).
NO4T FOR/PUBLICDISCLOSURE WITHOUT APPROVAL OF'FIELD-6FFICE'ý [PREC R,
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