ML19292B836
| ML19292B836 | |
| Person / Time | |
|---|---|
| Site: | Catawba, Wolf Creek, Callaway, Comanche Peak, 05000000, Zimmer, Washington Public Power Supply System, Shoreham |
| Issue date: | 02/09/1984 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Gilinsky, Palladino, Roberts NRC COMMISSION (OCM) |
| Shared Package | |
| ML19292B837 | List: |
| References | |
| TASK-AS, TASK-BN84-006, TASK-BN84-6 BN-84-006, BN-84-6, NUDOCS 8401190048 | |
| Download: ML19292B836 (7) | |
Text
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NUCLEAR REGULATORY COMMISSION g
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February 9,1984 Docket Nos.: 50-483, 50-358 50-322 MEMORANDUM FOR:
Chairman Palladino Commissioner Gilinsky Commissioner Roberts Conunissioner Asselstine Commissioner Bernthal FRCM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
FALSIFICATION OF QUALITY CONTROL DOCUMENTS RELATING TO THE CONSTRUCTION OF SAFETY-RELATED HVAC UNITS BY THE BAHNSON CO., WINSTON SALEM, NORTH CAROLINA BOARD NOTIFICATION 84-006 In accordance with the NRC procedures for Board Notification, the following information is being provided directly to the Commission:
Menorandum from J. G. Partlow to D. G. Eisenhut dtd 12/29/83, "Reconmendation for Consideration of Board Notification of Falsification of Quality Control Documents Relating to the Construction of Safety-Related dVAC Units by the Bahnson Co.,
Winston Salem, North Carolina.
This information may be applicable to the following cases that are before the Commission: Callaway, Zimmer, and Shoreham. The appropriate boards and parties are being informed by copy of this nemerandum.
The attached meno from J. G. Partlow notes that an 01 investigation has been made of allegations that quality control documents were being falsified and that signatures of QC inspectors were being forged at the Bahnson Co.,
Winston Salem, North Carolina. The Bahnson Company has provided safety-related HVAC units for a number of nuclear reactor facilities which are identified in the enclnsure. The HVAC units supplied by Bahnson Co. may provide, among other things, cooling for the reactor containment building during normal and accident conditions.
84o1190048
2 The staff is currently considering the safety implications of this information and will inform the boards of the findings.
Among the nuclear rea; tor facilities listed in the Bahnson Co. letter (see enclosure) are seve al operating plants.
The only information presently available regarding the operating plants identi-fied in the Bahnson correspondence is that HVAC units were shipped to those plants. Whether the equipment has been installed is unknown. Also, it is not yet known whether QC records irregularities exist for this equipment. The staff is sending letters pursuant to 10 CFR 50.54(f) to the affected licensees in order to obtain more specific information, to include the current disposi-tion of the HVAC components, regarding the Bahnson equipment they received.
While the HVAC systems in general are considered to be Engineered Safety Feature systems, they do not rank high in terms of accident mitigation since they are not part of the reactor coolant pressure boundary.
HVAC systems are redundant in their active components. Although portions of the systems are manufactured to safety grade specifications, generally most of the material can be of commercial grade. Appendix B does cppiy to those portions of the system considered to be safety grade, and the appendix requires a certificate of compliance for the material and installation as called for in the design.
In addition, most of the HVAC systems at a plant are outside the primary con-tainment and are accessible during operation.
In case of failure of a system, it is highly unlikely that the systen as installed can fail such that it causes a more significant accident consequence. Assuming a failure did occur, the major concern would be overheating of the rooms and areas supplied by the HVAC systems, where safety systems are located. These areas of potential over-heating are detectable from the cutrol room.
It would be expected that over-heating problems can be alleviated by portable equipment which can be brought into the affected areas before the temperature could rise to the point where system failures in certain equipment could occur.
Moveover, assuming the failure of an HVAC system supplying the control room, it is not expected that the limiting dose to the 1nhabitants of the control room, considering airborne radiation, would exceed the allowable radiological dose of 5 Rem over 30 days. With air packs in the control room, even assuming a loss-of-coolant accident concurrent with a total loss of the HVAC systems, the exposure to control room personnel is not expected to exceed this allowable dose. A cursory analysis for one plant using the potentially (but as yet uncon-firmed) suspect equipment indicated a 30-day dose to the control room persnnnel on the order of 4 Rem for such a scenario.
The Commission Based on the above, until more specific facts are obtained that will confirm a technical decision regarding the continued acceptability of the potentially defective Bahnson equipment, the staff is allowing the affected plants to operate.
Note that although the attachments include 01 and OIA 'nformation, those Offices have now concurred in the release of this information in conjunction with this Board Notification.
%ID rre %.} 1senhu b 1
1 rector Division of icensing Office of Nuclear Reactor Regulation
Enclosure:
Memo DGEisenhut fn JPartlow did 12/29/83 Re: BN-84-006 w/4 Encls.
cc:
SECY (2)
ASLB For:
Callaway 50-483 (Gleason, Bright, Kline)
Catawba 50-413/414 (Kelley, Ca11ihan, Foster)
Comanche Peak 50-445/446 (Bloch, Jordan, McCollom)
Shoreham 50-322 (Brenner, Ferguson, Morris, Laurenson, Kline, Shon)
Wolf Creek 50-482 (Wolfe, Aaderson, Paxton)
WPPSS 1 (Grossman, Bright, Harbour)
Zinmer (Frye, Hooper, Livingston)
ASLAB For:
Callaway 50-483 (Rosenthal, Edles, Gotchy)
Shoreham 50-322 (Rosenthal, Edles, Wilber)
DISTRIBUTION LIST FOR BOARD NOTIFICATION ALAB/ASLB -Callawny Unit 1, Docket No. STN 50-483 ASLB -Catawba Units 1&2, Docket Nos. 50-413/414 ASLB -Comanche Peak Units 1&2, Docket Nos. 50-445/446 ALAB/ASLB -Shoreham Unit 1. Docket No. 50-322 ASLB --WPPSS-1, Docket No. 50-460 ASLB -Wolf Creek Unit 1, Docket No. 50-482 ASLB -Zimmer Unit 1. Docket No. 50-358 Mr. Vernon Adler Mr. John H. Frye III Ms. Marjorie Reilly Dr. George C. Anderson Mr. R. J. Gary W. Taylor Reveley III,Esq.
Martin B. Ashare, Esq.
Mr. Stewart M. Glass Nicholas S. Reynolds, Esq.
Edward M. Barrett, Esq.
James P. Gleason, Esq.
Dr. Peter F. Riehm Ms. Nina Bell Mr. Marc W. Goldsmith Mr. Jesse L. Riley Lynne Bernabei, Esq.
Dr. Reginald L. Gotchy Ken Robinson, Esq.
Mr. Samuel J. Birk Herbert Grossman, Esq.
Alan S. Rosenthal, Esq.
Howard L. Blau, Esq.
Robert Guild, Esq.
Mr. Eugene Rosolie Peter B. Bloch, Esq.
Dr. Jerry Harbour Kevin M. Ryan Mr. Dan I. Bolef Mr. Bruce L. Harshe Ms. Mary Ellen Salava Mr. Donald Bollinger W. Peter Heile, Esq.
Cherif Sedkey, Esq.
Ms. Nora Bredes Mr. Timothy S. Hogan, Jr.
Ralph Shapiro, Esq.
Lawrence Brenner, Esq.
Dr. Frank F. Hooper Mr. Frederick J. Shon Mr. Glenn 0. Bright Dr. Walter H. Jordan Ms. Barbara Shull Mr. Earl Brown James L. Kelley, Esq.
Jay Silberg, Esq.
Herbert H. Brown, Esq.
Dr. Jerry R. Kline John M. Simpson, Esq.
Mr. Brian Cassidy Stephen B. Latham, Esq.
Lanny Alan Sinkin A. Scott Cauger, Esq.
James A. Laurenson, Esq.
Mr. Jeff Smith Kenneth M. Chackes, Esq.
Mr. Nicholas D. Lewis Mr. Gerald C. Sorenson Gerald Charnoff, Esq.
Mr. Gustave A. Linenberger Mayor Howard Steffen Ms. Wanda Christy Karen E. Long, Esq.
Mr. Robert G. Taylor John Clewett, Esq.
Mr. Harold Lottman Mr. Robert F. Warnick Hon. Peter Cohalan Mr. Fred Luekey Deborah Webb, Esq.
Mr. John T. Collins David Martin, Esq.
Howard A. Wilber, Esq.
Troy B. Conner, Esq.
Mr. Brian McCaffrey Mr. Donald R. Willard Gerald C. Crotty, Esq.
Dr. Kenneth A. McCollom Richard P. Wilson, Esq.
Andrew B. Dennison, Esq.
J. Michael McGarry III,Esq. Sheldon J. Wolfe, Esq.
James B. Dougherty, Esq.
Prof. William H. Miller John D. Woliver, Esq.
Mr. Jay Dunkleberger William J. Moran, Esq.
Mr. Robert G. Wright Mr. Anthony F. Earley, Jr. Dr. Peter A. Morris Gary J. Edles Esq.
Chris Nolin MHB Technical Assocs.
Eric A. Eisen, Esq.
Fabian G. Palomino, Esq.
Palmetto Alliance Mrs. Juanita Ellis Dr. Hugh C. Paxton State of Washington Peter S. Everett, Esq.
Mr. Spence Perry Energy Facility Site Mr.. Jonathan D. Feinberg C. Edward Peterson, Esq.
Evaluation Council Dr. George A. Ferguson Mr. Samuel H. Porter Lawrence R. Fisse, Esq.
William L. Porter, Esq.
Dr. Richard F. Foster David J. Preister, Esq.
Leon Friedman, Esq.
Dr. Paul W. Purdom Eleanor L. Frucci, Esq.
Mr. John G. Reed
DISTRIBUTION LIST FOR BOARD NOTIFICATION ALAB/ASLB -Callaway Unit 1, Docket No. STN 50-483 ASLB -Catawba Units l&2, Docket Hos. 50-413/414 ASLB -Comanche Peak Units 1&2, Docket Nos. 50-445/446 ALAB/ASLB -Shoreham Unit 1, Docket No. 50-322 ASLB -WPPSS-1, Docket No. 50-460 ASLB -Wolf Creek Unit 1, Docket No. 50-482 ASLB -Zimmer Unit 1, Docket No. 50-358 Atomic Safety and Licensing Board
~
Panel Atomic Safety and Licensing Appeal Panel Docketing and Service Section Document Management Branch 4
ACRS Members Dr. Robert C. Axtmann Mr. Myer Bender Dr. Max W. Carbon Mr. Jesse C. Ebersole Mr. Harold Etherington Dr. William Kerr Dr. Harold W. Lewis Dr. J. Carson Mark Mr. William M. Mathis Dr. Dade H. Moeller Dr. David Okrent Dr. Milton S. Plesset Mr. Jeremiah J. Ray Dr. Paul C. Shewmon Dr. Chester P. Siess Mr. David A. Ward
BN 84-006 Branch Service List CALLAWAY Mr. D. F. Schnell Mr. Nicholas A. Petrick Mr. J. E. Birk Resident Inspector Mr. Donald W. Capone Regional Administrator, Region III CATAWBA Mr. H. B. Tucker North Carolina McA-1 Mr. F. J. Twogooc Mr. J. C. Plunket t, Jr.
Mr. Pierce K. Skir:ner North Carolina Electric Membership Corp.
Saluda Piver Electric Cooperative, Inc.
Mr. Peter K. VanDoorn Regional Administrator, Region II Spence Perry, Esq.
COMANCHE PEAK Spencer C. Relyea, Eso.
Mr. Homer C. Schmidt Mr. H. R. Rock Mr. A. T. Parker SHOREHAM Mr. M. S. Pollock Resident Inspector Energy Research Group, Inc.
Mr. Janes Rivello Ezra I. Bialik Dr. M. Stanlev Livingstone
BN 8a-006 Branch Service List WNP 1/4 Mr. D. W. Mazur Mr. V. Mani Nicholas S. Reynolds, Esc.
Mr. E. G. Ward Resident Inspector Mr. R. B. Borsum G. E. Craig Doupe, Esq.
Regional Administrator Nicholas D. Lewis Mr. Eugene Rosolie Nin, Bell WnLF CREEK Pr. Glenn L. Koester Mr. Nicholas A. Petrick Mr. Donald T. McPhee Resident Inspector Teri Sculley Regional Administrator, Region IV Mr. Joe Mulholland Regional Adninistrator, Region III ZIMMER Mr. J. Willictas, Jr.
Mr. Gregory C. Ficke Mr. Robert Burger Mr. John E. Dolan George E. Pattison, Esa.
Mr. Waldman Christianson "r. John Youkilis Regional Administrator, Region III Mr. Janes P. Fensten:1aker
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NUCLEAR REGULATORY COMMISSION e
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WASHINGTON, D. C. 20555
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DEC 2 91933 MEMORANDUM FOR:
Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation FROM:
James G. Partlow, Acting Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
SUBJECT:
RECOMMENDATION FOR CONSIDERATION OF BOARD NOTIFICATION OF FALSIFICATION OF QUALITY CONTROL DOCUMENTS RELATING TO THE CONSTRUCTION OF SAFETY-RELATED HVAC UNITS BY THE BAHNSON COMPANY, WINSTON-SALEM, N.C.
On May 12, 1983, the results of an investigation of allegations that Quality Control documents were being falsified and that signatures of Quality Control inspectors were being forged at the Bahnson Company, Winston-Salem, N.C. were provided by memorandum from the Director, Office of Investigations to the Regional Administrator, Region IV. This memorandum (Enclosure 1) stated, in part, that "In 01's view, the weight of the evidence developed by the investi-gation supports a conclusion that the signatures and/or initials of QC inspectors were falsified on QC documentation associated with the Bahnson HVAC units."
A copy of the Office of Investigations Report (Case Number 4-82-015) will be provided when released by 01.
Furthermore, the Office of Inspector and Auditor reviewed this report and provided the staff with the results of this review on August 29, 1983. A copy of this report was provided to Ed Case.
DIA referred this case to the Department of Justice on August 24, 1983, and was informed on October 18, 1983 that the Department of Justice had decided to decline criminal prosecution in this case based on the difficulty in proving the requisite criminal intent (Enclosure 2).
On October 19, 1983, the Director, Office of Inspection and Enforcement sent a letter to the Bahnson Company (Enclosure 3) asking for a complete list of nuclear facilities for which it had provided equipment and the dates when such equipment was supplied.
The response to this request (Enclosure 4), dated November 18, 1983, was routed by Document Control to a group within IE not familiar with the background nor significance of the information provided.
Due to the apparent delay in responding to the IE request, Bahnson Company representatives were again contacted on December 16, 1983 and a separate copy was provided at that time.
The nuclear facilities identified by Bahnson are:
Shoreham Nuclear Power Plant Zimmer Nuclear Power Plant Wolf Creek Generating Station TOfgo 0'
4 Darrell G. Eisenhut DEC 2 91983 Callaway Nuclear Plant WPPSS Units 1 and 4 LaSalle County Station V.C. Summer Nuclear Station Sharron Harris Nuclear Station Catawba Nuclear Station Oconee TVA Yellow Creek Palo Verde Millstone Comanche Peak Additionally, WPPSS and CP&L are listed as receiving equipment without a specific facility being notea.
This information has been provided for consideration of board notification of passible falsification of Quality Control Documents relating to the construction of safety-related HVAC units by the Bahnson Company for the listed facilities.
If you have any questions, please contact Ellis Merschoff (ext. 24572) of IEy staff.
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6 James G. Partlow, Acting Director Divisi on of Quality Assurance, Safeguards, andlInspection Programs Office of Inspection and Enforcement
Enclosures:
1.
Memo from 01 to Region IV 2.
Department of Justice Letter 3.
Letter dtd. 10/19/83 to Bahnson Company 4.
Response dtd. 11/18/83 from Bahnson Company
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MEMORANDUM FOR:
John T. Collins, Regional Administrator
. Region IV-n#
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FR0P c'n B. Ha'yes, Di r$c'to'r' N Office'of Investigation SUBJECi:
INVESTJGAT]ON OF ALLEGED FALSIFJCATION OF OUALITY CONTROL DOCUMENTS RELATING TO THE CONSTRUCTION OF SAFETY-RELATED HVAC UNITS BY THE BAHN50N COMPANY, WINSTON-5ALEM, N.C.
Attached is the Office of Investigations' Report of Investigation concerning the above case.
This investigation was conducted to determine the accuracy of allegations that Quality Control documents were being falsified and that signatures of Quality Ccntrol inspectors were being forged at the Bahnson Company, Winston-Salem, N. C.
Bahnson is a maker of heating, ventilating and air conditioning (HVAC) units for installation in nuclear power plants.
The investigation involved numerous interviews es well as review of QC and other documentation.
In 01's view, the weight of the evidence developed by the investigation supports a conclusion that the signatures and/or initials. of QC inspectors were falsified on QC documentation associated with the Bahnson HVAC units.
oreover, it appears that CTI-Nuclear which contracted with Eahnson for fabrication of HVAC units for the Washington Public Fewer Supply System (WFP55). plant recuired non-destructive examination (NDE} c'ocumentation which was "recor.structec" by Sahnson for units that had alreacy been snipped.
EE!SCO Services, Inc., the encineerine ccntracter fc-UU55, ; laced the recuirement cr CTI-Nuclear which in turn placed it upon Ethnson.
The ceccr.structed dct; mentation was not limited to.531 hicn was avaliable f rcm records Erd recollection of QC inspectors, h: eser (see e.g. Atta:Sent 20)
Ebasco anc CT: *.1 clear pers onnel were aware that sera dt:.mentat;cn woulc' have tc De ccr.structed.
Mcwe.er, the weight of it.e evicer ce, in our :;inier. cle s not c.upport a con:lusion that they were knowledgeable that ite rec;rstruction
..ent bevcrd data culled frcm other records cr the QC ins;ectors' recollection.
Cn the cther hand, Eahr. son supervisors. did know bf this practice.
Fii.a l ly,
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the evidente cces support a conclusion that the Echtscn " ice-Fresicent in Charge of Manufacturing did hold a r.eeting attendec ty Q: pe rs tnr.el whi ch reascrably co;1c be interpreted as a threat da; QC erscr.nel uruld be replaced if the;. impeded the ccmpany's ability to meet a s hipment deadline.
This irvestigaticn has been closed by 01.
Internal access and distributier si:ul d be or, E. " nee d ar.d right to kr cw" basis.
This re;cri r.as tee. ; c. iced ic the Office of :r spector and Auditor to de:e rr.:,e. eSa r ic refer ine WO 9./
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John T. Collins May 12, 1953 i
matter to the Department of Justice.
Please note that this report has not been expurgated in any f ashion.
No portion of it may be disseminated outside the NRC without the approval of the Director, 01.
Internal access and distribution should be on a "need and right to know" basis.
At'tachments:
As stated ccw/att:si J. Dircks, EDO R. DeYoung, IE J. Cummings, DIA D
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LL:WCE:ihm-Worn. D.C 20 !C DCT 181983 Mr. Een E.
Hayes Director, Office of Inspections U.S. Nuclear Regulatory Comnission Washington, DC 20555 Re2 Eahnson Comcany Deer Mr. Hayes:
Reference is made to Mr. James J.
Cu-.~ings letter of August 24, 1983, concerning possible. Violations of 18 U.S.C.
5 1001 by employees of the Bahnson Company of Winsten-salen, Mort.h Cc.ro1Lna.
We havt cencluded cur review cf the investigative files and have consulted with Mr. James Y. Vorse of your agency concer
- 19 the alleged violations.
On t.he basis of this review we have decided to decline cricinal prosecution in this case.
This decision is based on a. number of f actors, nost significant of which is the significant practical difficulty in ' proving the recuisite criminal intent in the circumstances of this case.
The doceents involved were ef ten la.belec as reconstructions, and both CTI-Nuclear and IEASCO were apparently aware of the inadequate :ocndation en which they were based.
Moreover, since the recenstructions ve e appa ently based en a variety of sources, including old notes by inspectore, old repcrts, and verbal inf e=.stien frc-ir. spec crs, it v;uld be dif ficu.it to e s:Eblish the f alsity cf specific representations.
' Jour cencern in forwarding this. matter to 3 in
- .ppreciated.
9 Sincerely,'
LAk M CE LIFFI, Chief General Litigtnien and Legal Advice Section Criminci Division C
J' ye gfe gg'0 m Ln_. c. Br.oWu Ih t
'Attoney t
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October 19, 1983 The Bahnson Company 3
ATTN:
J. Thomas Brown, President P. O. Box 10458 Winston-Salem, NC 27108 Gentlemen:
A The Nuclear Regulatory; Commission (NRC) has continuing concerns regarding' the adequacy of safety-related heating, ventilating and air. conditioning (HVAC) units supplied by your company for installation in nuclear power plants.
During an inspection at your Winston-Salem, North Carolina facility on Septernber 7-10, 1982, it was found that the implementation of your QA program failed to meet certain NRC requirements. The specific findings and references to the pertinent requirements were identified in our letter to you of November 18, 1982. The NRC remains concerned that quality problems may be associated with HVAC equipment provided by your company to nuclear facilities.
Consequently, please provide me with a complete list of nuclear facilities for which you have provided equipment and the dates when such equipment was supplied.
Also, identify in each instance the nature of the equipment supplied and whether the equipment' was shop or field fabricated. To assist NRC in resolving its con-cerns expeditiously, please provide your response to me by November 30, 1983.
If you have any questions, please contact Steven D. Richardson, 301-492-9512, of my office.
Your cooperation in this matter would be appreciated.
If, huwever, for any reason you elect not to provide the requested information, please contact my office immediately so that we may take more formal action in this matter.
Sincerely, C?isinc11::s;:e ty:
Ikarcrd C. DeYoung, Di rector Office of. Inspetticn an: Enforcement DISTRIBUTION:
!E hies COASIP Reading TCDeYoung JMTaylor JFPartlow e
SDRichardson EHayes, 01 JLiebe rman, ELD DGEisenhut, NRR WJDircks, EDO NRC PDR
'See previous ORC for concurrence IE: 0A5]P IE: QASI P OELD IE:D/DIR H::Q
'$ Richardson *JGPartlow
'JLieberman 'JMievior R $Tobnc 10/17/83 10/17/53 10/18/83 10/17/83 ff/15/E3~
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11-1E-83 i
i United States 1
Nuclear ReEulatory Coc=ission i
Washington,DC 20555 ii At :: Richard C.
DeYoung, Directo-Of fice of Inspection and Enf orcenent
Subject:
Letter from R.C.
DeYoung to J.T.
Brown, dated Oct. 19,1983 Dee.r Mr. DeYoung:
l Tour letter of October 19, 1983 re cueste c The Eahnsen Cenpany to i
send yo; a list of EVAC units we have suppliec to nuclear power i
planns, their type, and the date shippec.
John Canup, Bahnson QA l
Manager, contacted Mr. Ste /en D. Richardsen, of your office, to verify the scope of the records you requestec.
At'that ti=e, Mr. Richardson stated you vere interested in a list of Nuclear Sa_,tey Related units supp,lec by the cannsen Cc:pany to nuclear pcver plants,..to close out the 1982 aucit referenced in your_
letter.
A::achsen: "A" is a list of these power plants,.. pec.
the nu ber anc tyde c:. units, anc t e cates t ese units were sn 1 o:
these units were built in the Winston-Salen,NC facility of Bahnson, e;x e c p: the tventy-one (21) units supplitc to the Cena.nche Peak Stea= Electric Station.
The s e un'i-s were natufactured by Eahnsen Service Cc pany, c~subsidary cf ~hc EsFnser Cenpary. which has a fabricatic: she; er the Ccnanche Peak Site.
'J e trus
..'-"e infcr=ation vill help in resc1ving your cencerns e.bcut EVAC equ:pnent nanufseturec by T h'e Earnser Cenpany. :f ycu have any futher c.:estions er c c n e n t s,..p l e a s e acvise.
Very truly y our s, The Earnsc: Ccnpany
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Thones 3rc'n Presicent End General P.anager
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PAGE NO. 0D001 11/IE/E3 EVAC EQUIP}ENT SUPPLID BY SAENSON FotE PLO.NT QTT / TYPE OF UNIT SEI??D EET G Shoreha Nuclear Power Plant 4 Air Handling Units Sept. '75 and May '76 er Nucl ur Power Plant
.16 Air Handling Units May
'76a$d 1977
' cif Creek Generation Station 4 Air Handling Units Oct. '79 and Nov. '79 Callaway Nuclear Plant 4 Air Handling Units Oct. '79 and Nov~. '79 W PSS Units 1 & 4 24 Evaperative Air Coolers 1977 anc 1978 LaSalle County Statien 12 Ceil Cabnet's 1977 and 1977 n
..v. C..ecrer h.uc2 nr Stat 1on el Air nantling U. its 19_/ /
and 19_/ e Sha. rcn Earris Nuclear Station 47 Air Handling Units Jhly '79 and Nov
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. u.:s u ca h.ut. tear Ster.cn
. Air nanc_,1ng L3n1ts vec.,se anc. Dec.,78 Ocenee 1 Air Handling Unit AuE- '81 End $ EPI 'El TTA-Yellow Creek 14 Charcel Adscrbrien Units Ma. 'S2 and Mar. 'E2 Maa:shar 8 Charcel Adscrbrien Units Feb. '52 and May
'E2 WP55 12 Curcel Adsorbtion Units. Aug. 'El E.nd Mar. '53 Fale Ve-de 6 Charcel Adscrtrien UnEts Sept.'El and Dec. 'El 2;E 6 Charcti Atscrbtien Units July 'E2 and Aug. '52 Mi'istent 10 Air Hancling Units Jan. 'E: and Let
'E2
.C:_anche ?cak 21 Air Es.ndling ~ Units 1979 and 1951 e"
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UNITED STATES y
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WASHINGTON, D. C. 20555 Febmary 9,1984 s
Docket Nos.: 50-483, 50-358 50-322 MEMORANDUM FOR:
Chairman Palladino Commissioner Gilinsky Conmissioner Roberts Commissioner Asselstine Commissioner Bernthal FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
FALSIFICATION OF QUALITY CONTROL DOCUMENTS RELATING TO THE CONSTRUCTION OF SAFETY-RELATED HVAC UNITS BY THE BAHNSON CO., WINSTON SALEM, NORTH CAROLINA BOARD NOTIFICATION 84-006 In accordance with the NRC procedures for Board Notification, the following information is being provided directly to the Commission:
Memorandum from J. G. Partlow to D. G. Eisenhut dtd 12/29/83,
" Recommendation for Consideration of Board Notification of Falsification of Quality Control Documents Relating to the Construction of Safety-Related HVAC Units by the Bahnson Co.,
Winston Salem, North Carolina.
This information may be applicable to the following cases that are before the Commission: Callaway, Zimmer, and Shoreham. The appropriate boards and parties are being informed by copy of this memorandum.
The attached memo from J. G. Partlow notes that an 01 investigation has been made of allegations that quality control documents were being falsified and that signatures of QC inspectors were being forged at the Bahnson Co.,
Winston Salem, North Carolina.
The Bahnson Company has provided safety-related HVAC units for a number of nuclear reactor facilities which are identified in the enclosure. The HVAC units supplied by Bahnson Co. may provide, among other things, cooling for the reactor containment building during normal and accident conditions.
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The staff is currently considering the safety implications of this information and will inform the boards of the findings.
Among the nuclear reactor facilities listed in the Bahnson Co. letter (see enc 10,sure) are several operating plants.
The only information presently available regarding the operating plants identi-fied in the Bahnson correspondence is that HVAC units were shipped to those plants. W:. ether the equipment has been installed is unknown. Also, it is not yet known whether QC records irregularities exist for this equipment. The stsff is sending letters pursuant to 10 CFR 50.54(f) to the affected licensees in orde.' to obtair. More specific information, to include the current disposi-tion of the HVAC components, regarding the Bahnson ewipment they received.
While the HVAC systems in general are considered to be Engineered Safety Feature systems, they do not rank high in terms of accident mitigation since they are not part of the reactor coolant pressure boundary. HVAC systems are redundant in their active components. Although portions of the systems are manufactured to safety grade specifications, generally most of the material can be of commercial grade. Appendix B does apply to those portions of the system considered to be safety grade, and the appendix requires a certificate of compliance for the material and installation as called for in the design.
In addition, most of the HVAC systems at a plant are outside the primary con-tainment and are accessible during operation.
In case of failure of a system, it is highb unlikely that the system as installed can fail such that it causes a more significant accident consecuence. Assuming a failure did occur, the major concern would be overheating of the rooms and areas supplied by the HVAC systems, where safety systems are located. These areas of potential over-heating are detectable from the control room.
It would be expected that over-heating problems can be alleviated by portable equipment which can be brought into the affected areas before the temperature could rise to the point where system failures in certain equipment could occur.
Moveover, assuming the failure of an HVAC system supplying the control room, it is not expected that the limiting dose to the inhabitants of the control room, considering airborne radiation, would exceed the allowable radiological dose of 5 Rem over 30 days. With air packs in the control room, even assuming a loss-of-coolant accident concurrent with a total loss of the HVAC systems, the exposure to control room personnel is not expected to exceed this ellowable dose. A cursory analysis for one plant using the potentially (but as yt t uncon-firmed) suspect equipment indicated a 30-day dose to the control room pe sonnel on the order of 4 Rem for such a scenario.
The Commission Based on the above, until more specific facts are obtained that will confirm a technical decision regarding the continued acceptability of the potentially defective Bahnson equipment, the staff is allowing the affected plants to operate.
Note that although the attachments include 01 and OIA information, those Offices have now concurred in the release of this information in conjunction with this Board Notification.
Originni signed by Darrell G. Eisenhut Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosure:
Memo DGEisenhut fm JPartlow dtd 12/29/83 Re: BN-84-006 w/4 Encis.
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SECY (2)
ASLB For:
Callaway 50-483 (Gleason, Bright, Kline)
Catawba 50-413/414 (Kelley, Callihan, Foster)
Comanche Peak 50-445/446 (Bloch, Jordan, McCollom)
Shoreham 50-322 (Brenner, Ferguson, Morris, Laurenson, Kline, Shon)
Wolf Creek 50-482 (Wolfe, Anderson, Paxton)
WPPSS 1 (Grossman, Bright, Harbour)
Zinmer (Frye, Hooper, Livingston)
ASLAB For:
Callaway 50-483 Rosenthal,Edles,Gotchy)
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DISTRIBUTION LIST FOR BOARD NOTIFICATION ALAB/ASLB -Callaway Unit 1, Docket No. STN 50-483 ASLB -Catawba Units 1&2, Docket Nos. 50-413/414 ASLB -Comanche Peak Units 1&2, Docket Nos. 50-445/446 ALAB/ASLB -Shoreham Unit 1, Docket No. 50-322 ASLB -WPSS-1, Docket No. 50-460 ASLB -Wolf Creek Unit 1, Docket No. 50-482 ASLB -Zimmer Unit 1, Docket No. 50-358 Mr. Vernon Adler Mr. John H. Frye III Ms. Marjorie Reilly Dr. George C. Anderson Mr. R. J. Gary W. Taylor Reveley III,Esq.
Martin B. Ashare, Esq.
Mr. Stewart M. Glass Nicholas S. Reynolds, Esq.
Edward M. Barrett, Esq.
James P. Gleason, Esq.
Dr. Peter F. Riehm Ms. Nina Bell Mr. Marc W. Goldsmith Mr. Jesse L. Riley Lynne Bernabei, Esq.
Dr. Reginald L. CotcFy Ken Robinson, Esq.
Mr. Samuel J. Birk Herbert Grossman, Esq.
Alan S. Rosenthal, Esq.
Howard L. Blau, Esq.
Robert Guild, Esq.
Mr. Eugene Rosolie Peter B. Bloch, Esq.
Dr. Jerry Harbour Kevin M. Ryan Mr. Dan I. Bolef Mr. Bruce L. Harshe Ms. Mary Ellen Salava Mr. Donald Bollinger W. Peter Heile, Esq.
Cherif Sedkey, Esq.
Ms. Nora Bredes Mr. Timothy S. Hogan, Jr.
Ralph Shapiro, Esq.
Lawrence Brenner, Esq.
Dr. Frank F. Hooper Mr. Frederick J. Shon Mr. Glenn 0. Bright Dr. Walter H. Jordan Ms. Barbara Shull Mr. Earl Brown James L. Kelley, Esq.
Jay Silberg, Esq.
Herbert H. Brown, Esq.
Dr. Jerry R. Kline John M. Simpson, Esq.
Mr. Brian Cassidy Stephen B. Latham, Esq.
Lanny Alan Sinkin A. Scott Cauger, Esq.
James A. Laurenson, Esq.
Mr. Jeff Smith Kenneth M. Chackes, Esq.
Mr. Nicholas D. Lewis Mr. Gerald C. Sorenson Gerald Charnoff, Esq.
Mr. Gustave A. Linenberger Mayor Howard Steffen Ms. Wanda Christy Karen E. Long, Esq.
Mr. Robert G. Taylor John Clewett, Esq.
Mr. Harold Lottman Mr. Robert F. Warnick Hon. Peter Cohalan Mr. Fred Luekey Deborah Webb, Esq.
Mr. John T. Collins David Martin, Esq.
Howard A. Wilber, Esq.
Troy B. Conner, Esq.
Mr. Brian McCaffrey Mr. Donald R. Willard Gerald C. Crotty, Esq.
Dr. Kenneth A. McCollom Richard P. Wilson, Esq.
Andrew B. Dennison, Esq.
J. Michael McGarry III,Esq. Sheldon J. Wolfe, Esq.
James B. Dougherty, Esq.
Prof. William H. Miller John D. Woliver, Esq.
Mr. Jay Dunkleberger William J. Moran, Esq.
Mr. Robert G. Wright Mr. Anthony F. Earley, Jr.
Dr. Peter A. Morris Ga ry J. Edles, Esq.
Chris Nolin MHB Technical Assocs.
Eric A. Eisen, Esq.
Fabian G. Palomino Esq.
Palmetto Alliance Mrs. Juanita Ellis Dr. Hugh C. Paxton State of Washington Peter S. Everett, Esq.
Mr. Spence Perry Energy Facility Site Mr.. Jonathan D. Feinberg C. Edward Peterson, Esq.
Evaluation Council Dr. George A. Ferguson Mr. Samuel H. Porter Lawrence R. Fisse, Esq.
William L. Porter, Esq.
Dr. Rit.hard F. Foster David J. Preister, Esq.
Leon Friedman, Esq.
Dr. Paul W. Purdom Eleanor L. Frucci, Esq.
Mr. John G. Reed
DISTRIBUTION LIST FOR BOARD NOTIFICATION ALAB/ASLB -Callaway Unit 1. Docket No. STN 50-483 ASLB -Catawba Units 1&2, Docket Nos. 50-413/41 A ASLB -Comanche Peak Units 182, Docket Nos. 50-445/446 ALAB/ASLB -Shoreham Unit 1, Docket No. 50-322 ASLB -WPPSS-1. Docket No. 50-460 ASLB -Wolf Creek Ur it 1. Docket No. 50-482 ASLB -Zimmer Unit 1, Docket No. 50-358 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Panel Docketing and Service Section Documcnt Management Branch ACRS Members Dr. Robert C. Axtmann Mr. Myer Bender Dr. Max W. Carbon Mr. Jesse C. Ebersole Mr. Harold Etherington Dr. William Kerr Dr. Harold W. Lewis Dr. J. Carson Mark Mr. William M. Mathis Dr. Dade W. Moeller Dr. David Okrent Dr. Milton S. Plesset Mr. Jeremiah J. Ray Dr. Paul C. Shewmon Dr. Chester P. Siess Mr. David A. Ward
BN 84-006 Branch Service List CALLAWAY Mr. D. F. Schnell Mr. Nicholas A. Petrick Mr. J. E. Birk Resident Inspector Mr. Donald W. Capone Regional Administrator, Region III CATAWBA Mr. H. B. Tucker North Carolina MPA-1 Mr. F. J. Twogood Mr. J. C. Plunkett, Jr.
Mr. Pierce K. Skinner North Carolina Electric Membership Corp.
Saluda River Electric Cooperative, Inc.
Mr. Peter K. VanDoorn Regional Administrator, Region II Spence Perry, Esq.
COMANCHE PEAK Spencer C. Relyea, Eso.
Mr. Homer C. Schmidt Mr. H R. Rock i
Mr. A. T. Parker SHOREHAM Mr. M. S. Pollock Resident Inspector Enercy Research Group, Inc.
Mr. lemes Rivello Ezra I. Bialik Dr. M. Stanley Livingstone
EN 8a-006 Branch Service List WNP 1/4 Mr. D. W. Mazur Mr. V. Mani Nicholas S. Reynolds, Eso.
Mr. E. G. Ward Resident Inspector Mr. R. B. Borsum G. E. Cra'g Doupe, Esq.
Regional Administrator Nicholas D,1,ewis Mr. Eugene Rosolie Nina Bell WOLF CREEK Pr. Glenn L. Koester Mr. Nicholas A. Petrick Mr. Donald T. McPhee Resident Inspector Teri Sculley Pegional Administrator, Region IV Mr. Joe Mulholland Regional Administrator, Region III ZIMMER Mr. J. Williams, Jr.
Mr. Gregory C. Ficke Mr. Robert Burger Mr. John E. Dolan George E. Pattison, Esa.
Mr. Waldman Christianson Mr. John Youkilis Regional Administrator, Pegion III Mr. Janes P. Fensternaker
g.. f u.g'o UNITED STATES NUCLEAR REGULATORY CCMMISSION s
y WASHINGTON, D. C. 20555
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DEC 2 91983 MEMORANDUM FOR: Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation FROM:
James G. Partlow, Acting Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
SUBJECT:
RECOMMENDATION FOR CONSIDERATION OF BOARD NOTIFICATION OF FALSIFICATION OF QUALITY CONTROL DOCUMENTS RELATING TO THE CONSTRUCTION OF SAFETY-RELATED HVAC UNITS BY THE BAHNSON COMPAAY, WINSTON-SALEM, N.C.
On May 12, 1983, the results of an investigation of allegations that Quality Control documents were being falsified and that signatures of Quality Control inspectors were being forged at the Bahnson Company, Winston-Salem, N.C. were provided by memorandum from the Director, Office of Investigations to the Regional Administrator, Regicn IV. This r=orandum (Enclosure 1) stated, in part, that "In OI's view, the weight of the evidence developed by the investi-gation supports a conclusion that the signatures and/or initials of QC inspectors were falsified on QC documentation associated with the Bahnson HVAC units."
A copy of the Office of Investigations Report (Case Number 4-82-015) will be provided when released by OI.
Furthermore, the Office of Inspector and Auditor reviewed this report and provided the staff with the results of this review on August 29, 1983. A copy of this report was provided to Ed Case. OIA referred this case to the Depart'nent of Justice on August 24, 1983, and was informed on October 18, 1983 that the Department of Justice had decided to dccline criminal prosecution in this case based on the difficulty in proving the requisite criminal intent (Enclosure 2).
On October 19, 1983, the Ofrector, Office of Inspection and Enforcement sent a letter to the Bahnson Company (Enclosure 3) asking for a complete list of nuclear facilities for which it had provided equipment and the dates when such equipment was supplied. The response to this request (Enclcsure 4), dated November 18, 1983, was routed by Document Control to a group within IE not familiar with the background nor significance of the information provided.
Due to the apparent dely in responding to the IE request, Bahnson Company representatives wera again contacted on Decembe.r 16, 1983 and a separate copy was provided at that tirre.
The nuclear facilities it'ent1fied by Bahnson are:
Shoreham Nuclear P wer M ant Zimer Nuclear Power Plant Wolf Creek Generating Station
G.
Darrell G. Eisenhut DEC2 9 E83 Callaway Nuclear Plant WPPSS Units 1 and 4 LaSalle County Station V.C. Summer Nuclear Station Sharron Harris Nuclear Station Catawba Nuclear Station Oconee TVA Yellow Creek Palo Verde Millstone Comanche Peak Additionally, WPPSS and CP&L are listed as receiving equipment without a specific facility being noted.
This information has been provided for consideration of board notification of pessible falsification of Quality Control Documents relating to the construction of safety-related HVAC units by the Bahnson Company for the listed facilities.
If you have any questions, please contact Ellis Merschoff (ext. 24572) of my staff.
O W' i Jr.mes G. Partlow, Acting Director Divisi on of Quality Assurance, Safeguards, and' Inspection Programs Office of Inspection and Enforcement
Enclosures:
1.
Memo from OI to Region IV 2.
Department of Justice Letter 3.
Letter dtd. 10/19/83 to Bahnson Company 4.
Response dtd. 11/18/83 from Bahnson Company
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i May 12,1933 MEMORANDUM FOR:
John T. Collins, Regional Administrator
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Hayes, Direc' tor 1 w-;;j.,
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SUBJECT:
INVESTIGATION OF ALLEGED FALSIFICATION OF QUALITY CONTROL DOCUMENTS RELATING TO THE CONSTRUCTION OF SAFETY-RELATED HVAC UNITS BY THE BAHN50N COMPANY, WINSTON-SALEM, N.C.
Attached is the Office of Investigations' Rcport of Investigation concerning the above case.
This investigation was conducted to determine the accuracy of allegations that Quality Control documents were being falsified and that signatures of Quality Control inspectors were being forged at the-Bahnson Company, Winston-Salem, N. C.
Bahnson is a traker of heating, ventilating and air conditioning (HVAC) units for installation in nuclear powcr plants.
The investigation involved numerous interviews as well as review of QC and other documentation.
In OI's view, the weight of the evidence developed by the investigation supports a conclusion that the signatures and/or initials. of QC inspectors were falsified on QC documentation associated with the Bahnson hVAC units.
Moreover, it appears that CTI-Nuclear which contracted with Bahnson for fabrication of HVAC units for the Washington Public Fewer Supply System (WPPSS). plant requirec' non-destructive examination (NDE' -documentation which t
was " reconstructed" by Bahnson for units that had alreacy been snipped..
EEASCO Services, Inc., the engineering contractor for WFF55, placed the recuirement on CTI-Nuclear which in turn placed it upon Eahnson.
The reccnstructed dccumentation was not limited to that which was availatie from records and recollection of QC inspectors, however (see e.g. Attachment 20)
Ebasce anc CTI-Nuclear personnel were aware that sera docuter.taticn would have tc be constructed.
However, th'e weight of t.5e evidence, in our cpinien, does not sucport a con:lusion that they were knowledceable that.tne rectnstruction
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. Ent beyord cata culled from other records or the QC inspectors' recoilection.
On the other hand, Bahnson supervisors did know 'of this practice.
- Finally, th.e evidence coes support a conclusion that the Eahr. son " ice-Presicent in Charge of Manufecturing did hold a meeting attended by QC personnel which reascrably could be interpreted as a threat that QC ;ersonnel would be re;15ced if they impeded the company's ability to meet a shipment ceadline.
This i.nvestigation has been closed by 01~.
Internal access and distribution should be on a. "need and right to knew" basis.
This re;crt has bes. ;-tvicec to the Office of Inspector and Auditor to determine i.hethar to refer the
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John T. Collins i
-2, May 12, 1933 matter to the Department of Justice.
Please note that this report has not been expurgated in any fashion.
No portion of it may be disseminated outside the NRC without the approval of the Director, 01.
Internal access and distribution should be on a "need and right to know" basis.
Attachments:
As stated cc w/att:
J. Dircks, EDO R. DeYoung, IE J. Cumings, DIA e
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I II:WCB: ibm-henverton. p.c 2csso OCT 181883 Mr. Ben E. Hayes Director, Office of Inspections U.S. Nuclear Regulatory commission Washington, DC 20555 Ret Bahnson ComDany
Dear Mr. Hayes:
. Reference is made to Mr. James J.
Cu:=ings lotter of August 24, 1983, concerning possible. violations of 18 U.S.C.
5 1001 by employees of the Bahnson cenpany. of Winston-salem, North Carol %a, We have concluded our review of the investigative files and have' consulted with Mr. James Y. Vorse of your agency conce. *g the alleged violations.
On the basis of this review we have decided to decline criminal prosecution in this case.
This decision is based on a. number of factors, most significant of which is the significant practical difficulty in 'oroving the requisite criminal intent in the cire=tstances of this case.
The documents involved were of ten labeled as reconstructions, and both CTI-Nuclear and IEASCO were apparently aware of the inadequace foundation en which they were based.
P.oreover, since the recenstructions Vere apparently based on a variety of sources, i=01tding old notes by inspectors, old reporte, and verbal informatien frc inspec:crs, it would be difficult. to establish the f alsity cf specific representations.
Your concern in forusirding this. matter to us is appreciated.
Sinc erely,'
LAWRENCE LIPPE, Chief General Litigatien a.d Legal Advice section Criminal Division By:
, ILLIM C.
BROWN W
Attorney
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.f, October 9, 1983 The Bahnson Company' s
ATTN:
J.~ Thomas Brown, President P. O. Box 10458 Winston-Salem, NC 27108 Gentlemen:
The Nuclear Regulatory Comission (NRC) has continuing concerns regarding' the adequacy of safety-related heating, ventilating and air. conditioning (HVAC) units supplied by your company for installation in nuclear power plants. During an inspection at your Winston-Salem, North Carolina facility on September 7-10, 1982, it was found that the implementation of your QA program failed to meet certain NRC requirements. The specific findings and references to the pc.tinent requirements were identified in our letter to you of November 18, 1982.
The NRC remains concerned that quality pr' oblems may be associated with HVAC equipment provided by your company to nucle'ar facilities.
Consequently, please provide me with a complete list of nuclear facilities for which you have provided equipment and the dates when such equipment was supplied.
Also, identify in each instance the nature of the equipment supplied and whether the equipment" was shop or field fabricated. To assist NRC in resolving its con-
~
cerns expeditiously, please provide your response to me by November 30, 1983.
If you have any questions, please contact Steven D. Richardson, 301-492-9612, of my. office.
Your cooperation in this matter would be appreciated.
If, however, for any reason you elect not to provide the requested information, please contact my office immediately so that we may take more formal u. tion in this matter.
Sincerely, Oris;i r.1 sasce, ty:
Ja:Trard C. DeYoung, Di rector Office of. Inspection and Enforcement DISTRIBUTION:
IE Files DOASIP Reading
.RCDeYoung JMTaylor JFPartlow t
SDRichardson EHayes, 01 JLieberman, ELD DGEisenhut, NRR
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11-15-83 United States Nuclear Regulatory Commission Washington,DC 20535 Att : Richard C. DeYoung, Director Office of Inspection and Enf orcement
Subject:
Letter from R.C. DeYoung to J.T. Brown, dated Oct. 19,1983
Dear Mr. DeYoung:
Tour letter of October 19, 1983 recuested The Bahnson Company to send you a list of HVAC units we have suppliec to nuclear power plants, their type, and the date shipped.
John Canup, 3ahnson QA Manager, contacted Mr. S teven D. Richardson, of your office, to verify the scope of the records you recuested.
At'that ti=e, Mr. Richardson. stated you vere interested in a list of Nuclear Saftey Related units supplied by The.3ahnson Co=pany to nuclear s
pcver plants,,to close out the 1982 audit ref erenced in your-le::er.
A::achsen: "A" is a list of these power plants, the nu=ber and type cf units, and the dates these units were shipped.
All of these units were built in the Winston-Salen,NC facility of Eahnson, execpt the twenty-one (21) units supplitt to the Cc=anche Peak Steam Electric Station.
The s e uni-:s were z a n u f a c t u 'r e d by Iahnson Service Company,- c~su~:sidary cf The Zahnsen Cenpany. which has a fabricatien shcp on the Cenanche Peak Site.
Ve trus: this infer =etion vill help in resolv ng your concerns abcut EVAC ecuipnent canufactured by Tht 3ahnsen Cenpany. :f ycu have any futher questions or ce==ents, pleas e e cvis e.
.t Very truly y ours, The Bahnson Cenpany
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