ML19317D404
| ML19317D404 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/16/1975 |
| From: | Jape F, Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19317D403 | List: |
| References | |
| 50-269-75-08, 50-269-75-8, 50-270-75-09, 50-270-75-9, 50-287-75-09, NUDOCS 7911270774 | |
| Download: ML19317D404 (28) | |
See also: IR 05000269/1975008
Text
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A 50 269/75-t: ' ' 50-270/75-9
' 50-227/?5-9 . REGION I! Subj ec t : Duke Power Company Oconce 1, 2, 3 Liccuae ::os: DPR-33, 47, 55 Docket !!os : 50-269, 270, 207 Al leg a t ic .-- - An investigation was conducted of statements transmitted to the US::RC Regica II of fice alleging that (1) quality control tunctions at the Oconee ::iiclear Station (0: 3) related to instrtunentation ere b=pered by t'.ie o ther organf ra ticas ; (2) that the dr. wings for the 0:iS i: s trumentation :. ora less than adequate and (3) that L he rotor company (Drc) had procured inadequate equip: rent for 0::s. Period of Investigation: May 19,19 75 June 3, 4, 5. 1975 Ite es ti;'.a ta rs - 5. D . E:ane t.er , lenc to r Ins,ec to r En ;ia::t cin7, S ac tie : Facil:;tes cons.,uctinn t anch F . J 'pe , Reactor Inspect.c Fet c il.i t t e3 Section Facilities Test and Secrtup 3 ranch i R. C . ~ Parker , Re, ror :n .p 3c te.f !!ucler.: .agina.:ria; S.3c cien Facilities L:s t and S tar.:nn 7 rneh L./,/ '. . . . . ! , Prine.'.ral Inapector : T'. c <.. '/',q. // i' ' - - .- ,. , ._ ,, , . , , .-..._..r_.__ , _ , m e r. Ja p,a , Reac t o r in n q c .- ,r. - Fc:ilities sect;.,n ., . Facilities Te.it and Startup ure.neh ./ , , , R e :t et n J 'c:. : 6,s-].~ . f~ ([,-y . e v , 7 /h. ,'v ; - . , R. C. Lv.tiWSc: pr Reactor In:Ncter Date Facilities Section
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_ .. . . - - . . ~ - - . . . . -2- . . . ,4 Itenen For Invcatip tien The Carolina Environrwatal Study Group (CESG) transmitted a letter to the Pegion It office suggesting that the Quality Control (QC) ONS "as subordi- nate to Design Engineering. The CESG contacted a former empicyae of DPC and nade arrangenents for !;RC investigators to intervicu hin. The for :er euployee provided the inves ti ;ators with a signed statement ei three 3 allet;2 t ions (Attachnent 1). This investigation was conducted to deternine the validity of the allegations. --Su n tary . Dtiring th2 period ray 19 cad June 3-5, 1975, an investigation ras conducted to determine the validity of allegations cade by a forner enployee of DPC pertainin3 to ONS. On June 3,1975, the NP.C investigators interviewed the fomer enployee to obtain factual infomation that could be used as a basis for further investiption. Sub s equent to this, the NRC investi37 tors con- ducted an investigation of DPC Charlotte operations en June I , 1975, and a site inve-tigation of ONS Units 1, 2 and 3 on June 5,1973. The f armer caployee had supplied the UP.C vith a written state:-e:.t containin three allegations- 1. Qua!!t/ tuactions at Oconee Nuclear Station .4cre har7= rad by - tScir bning centrolled by Technical Suppert . . 2. Design fnyineerink; pro:iuced a less than adequate set :: J.rawi. m - c because ou paor enyincering practices, accuracy of drwimu ent,. usability of drawings. 3. Equip .eut , unsuitable for the application, has beca s.1, and purchasa of the equipment uns baaed uNn f ricadr'-ips *nd other factcrs unrelated to tae rr c.uiremen ts necec.sar./ fo: epCraticn. . renar t The clici;er n,d difficulty in iden:if ying s uelt ic Juu.. aut.. .L:n c.: h> - that ecaid be investigated in d2?th ned resc of the equirnen_ cd crr-f. te uns nan-saf e ty relat e.' . Each allegatien "a:. ir c:-s ticated tc ::. a en u. n t possibic cad it was concluded that alle;:aticas I aad 3 coul? not be sub- ctantint24. heuever, clic gation 2 cas partially etUs tuntina : . This led to t'u finding that cc,ntrar:/ to 50.59(b) of 10 CFr. M, a m ::ca af ety evalustica uc.s uct perfo med to deter.ine the safety sign'.fic, ice of nai.in cheny a to safety related instrunentation nystens cithout a- pr: val aa re- quired by para 3ccph 13.5.2 of the F3A'1, and ot i: at alline in.= .runentatic n syater.s in accordance with paragraph lc.3.5c. of the FS /.R . 5 ccifically. thc investi;ators found that the detciled dr = tars for tro ::f2t- relate? Instrm.-ntation aye.tes did noc ref!cc . the m 7:uilt Matus . the plaar and th- 'nstrur:ntation "a3 inatall;. M a man r t i d i d ti . cr.- trem O- . de ta '.1 d Jai.'iuI5, 'ri th r ut '. IM Opp'*av:l G. the .
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11 . . * * , , n . ~,~*> Prepared by: - " '. .. . ' /. . . - - , . . S. D. Ebneter Date , d Ecac tor Inspector Eng,ineering Section Facilities Construc tion Branch Dates of Investigation: June 3,4,5, 1973 , -- J.- Eevicued by ,.!. ? W . /'i __._- lls t._, / . _. W .- Ai . i . . . L. L. Beratan Dste Scnior Reac tor Inspf.c tor Engineering Section Facilities Construction Branch Details Pcrsons Contacte_d_ . Duke Pat cr Company C:- Q l 1 1 U. H. D. E n - Vice Pruident, Engibeering . J. R. Uells - Corpcrara QA >!anager C. 3. Aycoch - Cons: ;; tion QA :ana.o,er C. J . Hylie - Chief I zineer . Elec tric.11 R . H. L'al tm.an - Prin;'. -al Engineer , Elec trica l T. C. !fe:!eakin _- D;sirn Engineer i
.. - .... e s a. - v ee. . , .tg .we. a. u. u . . . . J. ::. Curtis Vend:: 'h uw - R . .i . !)r ekett - 1.s -C , in t Q.\\ Er.gineer - 0:S J. E. Smith - Plan: ;.serintendent . 0::5 . .. . . . . .. , :. a catnu t - ass n c.e Qa. -nngineer, vonstruction ,. . a. . . C . S . E rad'.un - Sun s: _ nt enden t of :Taintenance - C:iS . Alluer F 7r cr Employee o f 2 e Power Cor. car * . . , . . , . t r ,
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. h / 1. Investioation of !.11eration 1 Allegalion 1 _ The alleger, in a signed state: ent (A t t achment 1) dated Fay 19, 1975, alleged tho.t quality functions at 0:-;S vere hampered by their belug " controlled" by Technical Support. Interview uith Alleter -- The ::ItC investigators interviewed the alleger on !!ay 19 and June 3,1975, to obtain information and facts as a basis for further investigation. The alleger stated that he is a graduate electrical engineer and a registered professional engineer in the State of 1,' orth Carolina. He dcas not have any vork experience in quality cssurance (OA) or quality contral (QC) discipline's but has interfaced with QA and QC on varicus assignr-en 3. The alleger stated that he uas not cssigned to QA or QC at 0;S but reported to Steaa Production Departnent. He was not familiar uith the QA requirer ents or organization struc ture as s tated in the FSAR, Appen t:: l IB. lie stated that the Construction Departzent did not permit him to t.se the FSAR. He also stated that he vas not avare that a copy of tha FS/J. vas available fer his use at the public document recr- in the lalhalla Ccunty !.ibrany. The alleer stated he felt UC "as cuboervu nt to Ocni n 'n.i Tacho ice Supr.o rt , 2nd that CC 'and no teeth. Thin conclusi . a t$s ' a:wd on hie Interf acin3 'with QC at O';S and his obserca t ion that QC ceuid request chan3es but could be overrul2d by Design. IJpon interrn:at:ca, h ;. stated that of tee en3;asticas or recuested chanps. appro::ima tely 20 percent uere related to problems and approxim.tely SO percent nere " helpful" sug;;estians based en the individual reaues tor's enperience. In refeccace to this, the clieger proviced an apparent E?C internal doctaent (Attachment 2) vhich specifi::d the duties and res,ensibilitics of QC inspectora dated, Septemb-er 25, 1972. This docuent lic.tc ten responsibilities for El.:c trical cad Instru .antation qC :nmetars. Th+ allager st ted that this was the first fornal definition of 7 fu.ictier s and he felt that it tas helpful. The alleger related that numarous problems enta ted in the 033 instrune .- tatica but could not specificall:. identif y any sys teri as
- iu;; defic un; .
He s tat: ' that the process instrumentatica sensing lines installation ~ criteria such as line slopes and routiras * tare not det. ailed on draw y:.. In general, '<han thusa deficiencies were datected and docuneated en Handon Inspection I!orh; heats (I'It!) and Variation ':oticcs (i.~ !) , carrw: :: actica uns initiated for th.it yccific deficiency but ha tated tha;. Cnly thCse that vere SpecifiCally docur.rnt03 *.rere C0rr0Ct2d. ThO i nves t i::ar.o rs queriod the alleger if estr.blished nr cedur u for o nc.x ef 'U".' and V':s ..ere fellcued to rasol"e n rd !crs . He ru ,c:. led i o. ha didn't kney ah'ut ti:e ".1:is F . ac <n m e vd " f did r ' . . '
stated that there &re no ina t runant Mr O cds -t m. t ; '. cly '.9 " , and that in.ipeCliva Of the in3 t ru'.en t I'. , r il' lti n e - r0 ' !de RQQR S'} " .
r i l , - - . - . - _ . - - - - - - - - --- w . . . -3- , . verify conformance to drawings thich were liuited in the a:=ount of detail. The alleger provided additional DPC documentation to support his allegations. In one of the docunents dated " arch 21, 1973, uhich t.as prepared by the alleger while ceployed by D?C, the allcaer made reference to an " investigation." In respcnne to questioning, the alleger stated that he una conducting an investigation of his own and cenpiling inforcation based on confidential intervicws tith construction and QC personnel. lie stated he vas assigned to the Stean Production Departnent and that he had no charter to, nor had he been authorized to conduct any investigation; it was strictly on his oun initiative. Inves tinatir.t and Interviews The investigators cet uith DPC personnel representing Desi,a Engineerin;; and Quality Assurance at various Charlotte offices on June 4,1975, and ~ discussed various aspects of the allegations. Appendix IB of the F3AR describes the DPC approach to QA and QC at Cconee. The organizaticnal structure as it existed at the tine in question is r.Nwn on Figure 1B-4 of Appendic 1p. and is further anplifiad by an or:;aniza:ional chart in NRC ffles titied "Oconee ' uclear Statien Crgaai:stion for Quality Centrol and Technical Lupport" dated .in3ust 17, 1972. In discussions eith DPC m reraannel, it uns stated that Technical Support and Quality Control vere the sanu . .r Uni:atir nr.1' ,2 :hr:2 u:4 ef re.= vsite _ :1., : ' i , ^c~ -! .
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' support. TN Q:: func t i n ins prinarily seccuolish.d by fuspeeters, the QA function by tha diacipline ficid en::ineer anf technical ot.p,;ert parnonnal. The technical support perscanel prinar ti;. parfor-e'. (121d engineering duties. This ty;m of QA orgnnizational structure uns f cirl:. comoa uithia tae nuclear inJustry in the late 60's M carly 7C's . In fact, the FSAR distinct;;. des crib es th i.s t*;pe of or,ceniza ti an in paragraph 13.2.': +:hich s:ates that "Du:ce's qualltv assurence progran ccn fu rn.s to the pr posed" Quali:y Ansurance Criteria . vi t'c. . . . . a ningle caneral excep;i n. The ~ nreposed cricer ta som tiaas s t_: ge s :: that quality asaurance functi_ns be perfomed 1;- n orgc.nicaticnal conpenent separate and istinct from the organica:icnal cenpenent havin; responsibility for an activity. Dtee cenfor w to this suggesti.;c uith respect to activitias perfor-ed by craf tsnen In the arcs . . . . of professicnal engineering as applied in desipa, conitruction, testing and operation, Duhe has :ntencionally assigned quality assurance reapen Mbilities to tha :a.ne or;;anizational components responsible f ar prof risienal en;ineerir . ec tivity." DPC personnel stated that conside rn'210 problens had been c m rirnced uith cone in:pectica personnel bypassing supervision and caking recenneni,- tiens or see.ing soluti .-s to prehlens by contac ting design e.~ inae s directly
- his u,a re e ncd by li.d tin ; telenhene access aad defictr',
the t a: mon;,15 tlitier of :'.c QC ins.m eter<. Tec intter defir;:1c of . ~ O sb
s a = = . ...Y en k ==1 6 - . 9 . . - .iu nliiti.d to the . - . ' . ~ P00RORG E .
.-.- : . . - . - - . . --- .... .-. . . - . _ . - . . . . - -- . . . -4- . . . , ' DPC personnel stated that there uas no fornal instrunentation installation criteria in the car'" 1T/O's but that stan !ards were developed and in,le- 1 raented h 1973. .runent installations vere inspected to drawin3 requirenents and the acceptance or rejection of an insta11ntica ucs based en the ennerience and judgenent of the inspector. Tha TSAR uas availabic in the Cons truction Departneat offices and van used by QC personnel. Discrepancies uere docunanted on "L:s or R1'Is. MC In.s pec t ions, The NRC (fornerly AEC) inapection reports of the 0::S during the late 1960's and early 1970's vere reviewed to determine if thin subj ect had been cov? red. Report 30-269/69-3 noted the need for electrical installation procedures and 50-269/69-7 identified a requirement for greater depth of QA and QC in electrical areas. Rc-port 50-269/71-3 spacifically cited neaknesses in th= construction QC due to transfers cf key people, resignations and peor tr,.ining. The identification of these deficiencies uas follcued by D?C corrective action "hich resulted in a con'.inucualy evolvino, QA and QC progran. , a Conclusion The alleyntion that QC uas subservien: to and controlled by Technical Support is considered to be a result of nisinformation. As nated above, th+ QC and technical suppert functions - era inte< rnted into e . . . . .
e o_w.m er an urren. ...ints uas r raarly cc or and ::c a tnaie appra n g i . .-m. , 11 tae 2ar.; 3v,u s. -2ne a icp r sta:e1,.ne as ne: u m ,ar u:tn tm . . 2 .. . Q/. des cri p tion in the ' S.'R .
- n evid ence cer id be f ound v.w t QC uas
sub se rvien t :0 .h ign Engineering. The DPC interna] ~.eno,ii cod Sc-p tcaber 26, 1972, (Attdennent 2) uhich listed ten QC r23ponsibilities vas based en the enisting organization strue:ure and assigneJ. functie u. The ner.o content .~.ppeirs to be consis tant -i:h the FS a descri'tica . :.d : w alleger falt it was helpful. The investiga:ars noted that fcur of ' the respensibilitia aera urittaa as nentive stcrc- er = r.etbar chan positive. The respcusib ilities as defined c r2 t'a c c e tha t are normally assigned :: G .and ins :ctior. It appe.ra, W e d c n s t a t c._-m . 3 Ew, 11PC cad the alleper, tha: insp2ctors and oth rcs vere e:m ee lir ; : heir authority in interpretntion of requirewnts an3 resol .: ion af proble s. In fact, the alle p t stated h w conducting hin own irvesti;ation tchich uns not eithir hia' ass gned duties. - The DPC cpproach to QA and QC at 0::3 . ras ;ust one acans of structurin-g
a QA/QC orpanization. This particular approach has provan to bc difficui: te cuntrol and, at the present t ic.e , is net corsicered to be the bes t approach. As noted, the UC inspections identified areas ' uhere the QA/QC pro 3ran at 0:;3 naeded inprovemnt early in th e con- struction Qase of 0::S. These resulted in ci::ticas,'her< av lica le, to DPC and cub 3 .nent correc tive ac t ion . .:o 'urther 1. N: . u'.ien into-this ite; .. p 10.n:te d . - P00R BRGE _
- - . - _ . _ . . . .___ _-- . _ _ . . . . . _ _ _ _ _ _ __ _ . _ . _ _ . . . _ . _ . - , -5- 2. Investif[ation of Alle p tion 2 ^ + ., ,, Allegation 2_ The'c11eger, in a signed staterent (A t tachme nt 1) , da ted !!ay 19, 1975: alleged that DPC Design Eng.neering produced a less than adequate cet of drawin3s because of poor engineering practices, accuracy of drauin;s and usability of drawings. .I.nterview uith Allener - _ - - - On May 19 and June 3,1973, the aC investigators met uith the allerer to discuss the allegation and obtain infornation regarding cpecific inadequacics as a basis for further investigation. The alleger stated that numerous errors were evident on drwinf s released to the field but he couldn't ive any nunerical figures c of the extent of the problen. He stated that instrunent sensing line slopes were not specified, the drawings lacked decails for inspection, and field changes were not always incorporated on revised drawiny. The alleger could not prcvide specific details uith regard to poor . engineering draving practices. In respensa to questions, he related that dravings are checked by a fellow desi.cner but not an in !c; endent . groun. !!c did not know if desir,a revia"s vere perforned. The allerer referred to the instruaunt greending svet e os o m i- Mi d or confora to dcmin3s c.al one uhich used c nf'uing t e:~ incl ~ 7 'i e ren.rred to drauings OEE-15, 0792, 0729, 317So and 2739 cad S +050-? as docenentatics that uas in error and could '.ubstentiate nia alle.u:.o. . DFC incpection of instrunantatica installation voz, made against design drrwin3s i:hich vere, in his opinica, inadequate and he stated th e ro instrunentation stan'ards *.ere available until ently 1973. iie furf er stated that ins trunentatica pipina ct tails chien represent ped enrinee;- ing practice were not alunys shoun en dra"ir ;s , bu t they .:culd be . inatelled by field engineers even ti . 4 -n - mec ified b:. des qa ca the details. He stated that, 02 an estin2:e, 'D percent o f th _sa chanz-:s
- ecra actual probians and arproninately E'; percent mre halpful si u=sti:n
based on the es.perience and judganent of the DPC inepecter or othee fiel- personnel. He achacwledged that none of the se changes cere in:crporatc; on the detail drawing by red lining and then transnitted to design. O th r.4 vere handled by a V:1, uhich is a for .al design chany.e notice used durin; the design and construction phase. S tatica '.tedifica tica Re;'er ts T') 5:ere used to eff ect a desi;;n >hnnga af ter the systens were turned ever :: Steam Prcduction. The alleger stated that spec ific problens , or rencen- ' for :ances , vere correcte;' uhen the;, *:ere identified and docunante . !!o.:cver, the general pec'clen rela t ed to the overall 0"5 ras not addresed by Design En :1- .*aring. The all +r rrccid"' the 7tC cith cortes of :mc internal ca e.nications 'hich ;u?per: the ec ut en ion t'u it
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rob le ' C.h ted uf..! 'h e Nneric aar . ::: .ee r e not coas' der >>. 4 P00R ORIGINAL
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., . ' l The alleger stated that an audit of drawing series 0-422 nis.ht verify his allegation. Inv_es tir.ation and Int _crvicus On June 4,1975, the :*RC investigators discussed design criteria, design control and design changes uit.h D?C Design Engineering and Quality Assurance personnel. DPC personnel stated that all ' rawings are checked by a checker prior d to release. The final release requires a three party si noff by 3 representatives f rea the Mechanical Division, Civil Division and Eicctrical Division. Subsequent to release, no design or drawing changes can be nade withcut prior approval of Design En3 neering. i The field has no authority to deviate frcn design drawings ~ or standards , without prior approval by Design Engineerin,t. The Variation Motice is the means by .hich design changes were accouplished. Instrumentation installations are specified on an instrument detail drawing which is a schematic representation of fittings, tubing, piping and valvas. The actual installation is done by " controlled field routin( as specified in Appendix 1C.3.5 of the FS?di. DPC personnel stated that instrunentation standards were issued in February of 1973, but pr.f or to that time no formal stendards existed. Decisions trere based en the experience of the f1 eld personnel. . On June 5,1975, the ::2C inves tigators inspectact ins tru,an tation re2 u e,. to the borated .cter storage tan'ts on Units 1 and 2 arJ the reactor building vautilction coolin3 nater systen for Unit 2. The inatniLn ior was inspected to verify conf ormance with DPC ins trun+r te tion s tandacds contained in Lchanical Instrumentation & Control, Instrumnt Stardards, Installation Field Practices and the design drnwings, series 0 422. The borated v'.ter stora3a tank level instrume itntion consists of tra redundant charnels aa.d is detailed on instrutent details O I.M :-13 and 0-422-n-2S. V:riations between the detail drcuings ned the installeu sy ; tea re:e note-' by the lavestigaw ca . For enacnle, tlalve V17 is she e on dravin; 0 '.22-:<-13 but is not installed. An iselation valve is installed batueen the c gulator ced instre. ent ::1'6, and cn isolation valv? is installed in the return air line., but' nei ther are shown on the detail. The detail shows the re3alator and a local indicator to ba installed cutside the protective box but both are installed inside. S tailar discrenancias were noted on t% Unit 2 horated water s torage tank level instru tents and the reac tor buildin; ventilation coolin; rater systen. DPC persennel accompanyin; the ::r investi3ators stated that all O' S instrucentation . as installed to the same criteria and that all syntcas uculd exhibit sinitar discrepancias betueen the detail dra :ings and the installation. The ac tun t insta'.la- tion fcci.11ta tes mainten m:e and calibration ac tivi ties - the ayatet, if installed in accordance . L th the drau tup , "cul t' not. . P00R ORENAL . ,(,- _
- , . . _ _ __ -7- . DFC personnel stated that instrutentation lines were field run and s. - the instrunent locations uere shown on drauingn. Isolation only valves, local pressure gages, air regulators and so forth nare net ! shown on the detail drawings and hence any change of these itens uns not the subj ec t o f a VN . The investigators had no questions concerning the field run inctallation of sensing lines and the lack of detall showing ells, tees, and couplings for these lines. 11ou- ever, concern fas capressed re3arding the lack of detail showing tha isolation valves, local pressure gages and installatien of air regulators. The inves tigators reviewed the grounding philosophy and cri teria used at 0:!3. DPC personnel stated that there vera three nain grounding systers namely, station ground, instrument ground and coaputer ground. Sone confusion e:cisted in 1972 about ground teaminology and DPC issued a ceco on June 27, 1972, to clarify this. Standardicing grounds terninolo;y and synbology is necessary to reduce the chance of improper interpretation of design drawings. DFC personnel stated that no major noise, interference or grounding problens had been experienced at 033. The inves tigators reviewed dravings OEZ-15, 0-903, 0-1903 and othar drauings related to the ground systea at 02:3. The ground systen uas inspected at selected points and ccapared to the drawings. Drawings 0-739-C, Revision 6; 0-1789-C, Revision 2; and 0-2739-C, 7ev t.sion 1 applicabL2 :o L'ni ts 1, 2 and 3, respectively were review $'.. Th=se ~ latter three drawings are for transducer tar,inal cabineta ai th2 lates c revisions ref errect to MM-n /-0. ina cirawing hac raerens eith:r to OE2-15 or contained notes definin3 the ground ternicolou The equipaent installation pas ccmpared uith the co21uaring dr. rem-: and the isolated ground traced f rom terninal alocks to cce cantral bus. No discrepancies ver2 noted. 5:1R-217-D uns a modifica tion to add a 250 oba resis tor in series *:ith FT 14? and power supol:; . Th e S? ' appeared to be complete and the documentation, including the draviacs, uere in agreement with the ins tallation. Sya-060-5, a statica modification ta add an additional cercuter alarn as an aid for operctors tn r. viewd and the investigatcra .cd nu questions. 5 :R-130-5 relatin; to the installation of Su ley Cah: net
- . 15 in the centrol roca was also revieued and no diser=panclea cere
-. Conclusion - .- - The inves tigation conducted at ONS on June 5,1975, appears to substar. 2: the allegation of the inadequacy of scne drawings. The :astrur. eat ticr ins tallaticas are rot, in all cases, in accordance ei th the d esi::n detc 1 . drawings. Since the instrumenta tica censing lines cre field run datai_; for cach tubing or pt;ing fitting are not required. Mcwreer, system conponents such as valves are required ca c tail der.um sa that :he true SyS tCM c9nfifuration is aVai}nble fer *cfer0Dce 3t the site Of ;- VISE, . in ' the W/ent V f an PCery;ency , Sny MJIyli3 0 ed CN f nr5 0 c u c i t .' in. trume:itatica drawings , cou3d be in 0: r 0 r n'?j could icac t :, c ' r .* J ,: r - CCOsequences. ^ P00R~0RIGild __ .
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. c, -8- . ' ' , The DPC quality assurance progran deacription is contained in Appenli: 'l ' - of the FS.'.R. Paragraph 10.5.2 states that ". all dra :Ings an.! procc- . . dures for construction of the station prepared by Duhe, consultants, or vendors are reviewd and approved by engineering prior to release to the Constructica Deparecent. Any changes to these nust be approved by the En;;ineering Department ." This cor.titrent appears to have not baen . . fulfilled in that changes to the instrument denign have not been docu- mented and current dt!.wi;gs are not availab le . Also, paragcaph 1C.3.5c of the FSA2 states ". . All field engineered lines are schematically . shown either on a diagra aatic, an instrucentation detcil cr a piping dra' sing such that mistakes in valving, connection termination points and naterials are virtually eliainated . ." For the tue safety . related sys te-s exaniued by the 1;RC investigato rs , this c:eniteent appears to have not been followed. Also, the investigators did not find any evidence that a *:ritten safety e/aluation uas perf ormed, as requiret by 50.59 (b) of 10 CFR 50, to ensure that the Inst 111ed changes from tha. described, in the FSAR do not involve unraviewed safety questions. Failure to conduct a safety evaluation of the saf ety significance of these changes and to obtain approval of the changes ao required by the FSA2 is considered an iten of nonceapliance w.ith 50.59(b) of 10 CFR 50. 3. Inves.icat!nn of Alleuatica 3 Allecation 5 i . . . , . . . . . .. _ w e a u eger preparea a s:.gaea staccuent. U m acs.. ens o , u s. t .. .a y n , - allaria;; that equtpacat, unsuitable f or the applica t ica , .s V .n u.r - and purchase of the equip:nent eas bnwd upon f rien.'shhs r! ctbo* fut.: unrelsted to the requirements r.acessary for proper operati,a. -In+ervien ulth A1 Leger The MC investigatars te t t.ith the alle er en ' ay !? end Jun . 3.1975,
to discuss the alh.3ation. iha inves ti;;2ta ca a t te >p .e.' te li atify specific equipreat iteus that could be traced thr x;h D: rec:rds as a ':ccia to estchlish tha ~alidity. cf t'>e allocatirm. O r '. th<. tec H '.c.. aupacts of the allegation were investic.ated. Tha alleber statal that DPC awarded contracts to supplier.< vith i no previous nucl.ar experie. tea. Ila referred to contract
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en Unit Electric Cr.npany, Orlando, Florida, for contr01 r. n equipment anl peneis at the 0::S . F.e sta ted tha t l'ni t Electric had no preeicus nuclear enperience but could nc t id en t i f'. ' ' specific deviations or inadecuac'.as related to this procun eat , either contractually or c;uipment related. In response to c;u es t ioning , the alleger said that he had not reviaccd the - .procuccuent contract, had not been involved la the p Np:'ratien o f L '.S p r4 Cu r eL'en t ?pOCificatiM' hnj n *' t re fin?2'I th0 'A . . . . , . .... , . . . . - , bi8)c 1. L 1 e a I CN ) n k c[. I. N . A s'd a 3. ., ( '. O # a,1 IIO *baI? b,.1a t 11 4 s . r a:dA a contracr to scrae e ch i i r u . 1. ' " ' - - ';! cu l - ' tile it%.len , t o hit i1J UHnelS Ond . dien h id s .th 2n lib cO" r ~ t.i s ."'nd POV3 3 t o [I"!I ' EI '? C t r la CU*' !'1r . P00R~0RIGINK
., - .:- . . . _- .- --,.4 - . - - . . . . ~ - .-- - - - .. -. .. - . ~9 - . . - , , The allegor s tated thct ceveral hundred ITF. Irperial J13P relays used ,
in 0::S control systen , required replacement. liis opinion tas that these relaya repreacateJ a neu design and vere purchased without any DPC tes tin;;. Me stated that he had not revicued or prepared the procurement specifit:atica or contracts. The aller,ar noted that - considorcble purchasing power resides at the principal en ;ineer level for procure =2nt of relays, suitches and cabinets. In his statenent, the allegor specifics that "grandf ather clauses" ef fec tively restrict the inclusion of t:cu vendors onto cpproved vandor licts uhile assuring es tablishad verders of virtual inclusion. He also noted thct quality control procedures end requirements are supposed to be najor areas of concern. Inven ti",1 tion and Interviews 3 On June 4, 1973, the :!P ' investi;;ators cet with DPC personnel representing Desir,n Engineering and Quality Assurance. The details of the procuranent cycle uere discussed and the specific procurenanta related to Unit Electri: Company and 1TE Inperial relays ucre revicued. DPC Procedures EPR-1, EPR-2, and EPR-3 were reviewed as these were procedures in effect during the time period in cues tion. E?R-3 titled, " Criteria for Qualifying Suppliera of Nuclear Safety Related Electrical 9;uipnent and Ihterials," required pre-award and post-auard evaluation of the su; plier. D?C records ve nade available fer the l'ait Elce t ric Co pany (U7.C) c mtract . A revie.; of these records shcus that MC conductel a pmmri curvey of L'2C o. 0:tner 2,19,70, .:hich in ineu- en:cd on an Erluntar an' J :.. es t i:;a tio n of Froposed Si'hter and Supplicr E scn. lim s u r*t : 2 - ,. .. 7 ruted t. .a t s t. s.3 tae n-.est to perfora auc_, car
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s, t, o pec i: tca tion t,a a .c. , . 03-3C9.-l for c~.=r;;en cy pouer a.eitching lo;;ic ranels conta !.a r ' Psie requirements and t:s t require ents. The reecrO inclu S docu untatlan of subnequent surveillance inspection and "itnessin3 o f f unctional tuts a t l'F.C . The en5 tnet.c vere seit. ically qualifiel by calculaticas in DeceSer of 1972, and subequent stianic tcstin; af cabinet cnd cor y ner:r by Uyle 1.r.beratories qualified then by te :t. . DPC perscanel statri that Ze r 0:G rait 3, c cen etitive bidaer las a.sardai a contract tpr uoneroi rocn pane, s c ,- acts. . . . , , ..m ,:Jer, tae t s cc:-paay did not neet ;chedules. The centract "s cancelled o'd subsequentif w arded to UCC, the second let.est bidder. ' OPC Design Engineering persennel stated that the ITs Inparial relay J1 ? uns selected by Desi:;n Engineerin:, based on d 2 sign criteria related te physical size, nunber of contracts and volt:ye. P r ev i<cu:4 e:.p e r: e a te uith other nanufacturer's reicys proved to ba disappointing and the 2:C r of the neuly developed J13P appeared to nect DPC recuiremen:s. The relays vere procured as a cataloy, item based on IT.". supplicd data. . e P00R ORIGINA , L
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m DPC perforced functional testing of the ITE relays including pickup f i time , voltage drop-out , and simulated circuit applicatiorn to f acili tate tes tin; of the caerr.cncy start circuit. A r.eco discussing the tests dated Augus t 21, 1970, included a recentendation to use the relay in the start circuit. The ITT. records package was revicued and extensive documentation uas . available as objective evidence of tests performed, audits conducted and action taken. . During functional tcsting of panels at USC in October 1970, several of the relayu failed or ralfunctioned. DPC, in conjunction with ITE and Wabash Ma3netics , conducted an in-depth f ailure caslysis, test and relay modification program. DPC audited ITE and Uabash Magnetics facilities and programs. In June of 1971, D?C concluded froa cyclical tests conducted la a dust environ =ent at elevated tenperature and humidity that the ITE relays vare not acceptable for the intended application. Cutler Hammer type 14 relays were selected as a replacenent and test i tens were subjected to cyclical operation under sinulated environmental conditions. 22 sed on the test results and additional Cutler Hamner data, DEC felt the Cutler licamer relays were qualified for the intended applica- tion. All of the ITE Imperial J13P relays : ere replaced at the O'.is and i*couee Station. Th'e replacement was accomplished in accordance uith a critten procedura, was Nitnessed 'cj a design en';!.neer and CC inupectors, and is fully docunea Li in OA fo3 der 03-C03. The investin cars ruie're? the 0.4 fold ar f or ed a.;uacy. As a final step to preclude irrtbar nrob'e.s, cenove C relaja h e.a DPC issued a htter dated ::cvena ar 13, Iw l , to s to ck . Tha ia'.usttjators celected several piecca of equi; 2nt !
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the original deaiaa incor,arated the J13? relays for fiel; inspection to verify that replaccuenc. had been accomplished. On June 5, 3975, the inves timtors insp?:ted P.couce Emer ;cncy Start Channels A and U at 0."S . Relay:, F.3, SIL . rnd ST33 in Channel B cabinet and reig s G, 51/. , and . 8"Sa uera Cutlec Uct.ner ralays and had bcea installed in c:cordance uith D?C doct. entation and records. [PC In,eecciens_ MC inspectica repor ts uere reviewed for parti". eat intar stion .-Lated to the J13? relay prebim. Reports 5C-269 /70 12 and .5%.M ! / /1-1. i.sce:> the relay failures. D?C reported the relay f ailure to 230 f or investi- ration into its possible generic inplications. j I co nclu s_io.n - The investigators could find no evidence to substantiate L:u cliegation i that equip .ent unsuitable for the applicati.cn brd been url . Ucr co tid any evidence be founl t.,r.uhatantiate the ch r;e that p : ' .c e- r.t c e n t t- .t. t s j vere cuardu ce fretors unrelated to technical requir m :t- o ther then j S tS th o u :,u ch a s co s t r m s ch e J u w t? t i ch are am illy :m : ' '. s - ' A*. lard in C[ COU'Jr3Ctd. At th9 tire D'JC ."Grd.2. L'r.C c0utr M w ,17t' i':td l y .. [ 1 1 10',' M . JOT DreV '.tnis O.9e'.* i 0 nc e in nr0Viding elLCt1'."'3 O('l i;;'". 3 n t '*. .
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. . . . _ _ .- -_ ._ - - - - _ . _ _ _ - _ _ _ , . - ~ - - _ . . . _ . _ _ . _ _ . t . 4 s 1 - _11_ 1 m.8 . . plants including Florida Power and I.ight, South Carolina Electric and Gas and Carolina Pouer and Light. In addition, UCC had canufactured equip-a '* such as control panels for the ::ational Aeronautics and Space Adninist?at[on ' under stringent qualLty assurance requirements. It una felt that QC uns cocr.ensurate with t'ae size of the company and that DPC vould have to k,rovida assistance in interpretation of IEZE-279 and Class IE requircuents. .everal other suppliers with previous experience, bid f or the work and considerin*" all factors, DPC selected UEC. . 0 9 i f - P00R ORIGIR ' ' r'-
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) I, A voluntarily give the followin3 statcaents to Frank Jape and Dick Parker, uho have identified theuselves to ne as representatives of the U. S. I;uclear Regulatory Com:aission. Attsched are. twenty (20) sheets of related information substantiating the following: 1. Quality functions at Oconee !;uclear Station were hampered by their being " controlled" by Technical Support. 2. Design Engineering produced a less than adequate set of drawings because. of poor engineering practices in accuracy, usability of drawings, training of personnel, and other reasons. 3. Equipment - unsuitable fo.r the application - has been used; purchaae of such equipment was based upon friendships, and other factors unrelat d to the requirements necessary for proper operation. . Signed: A _
- ay 19,1975
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. . - . . - . . - . . - . - - - . - - . . - - - - . - - - . - - -- .. .- -. .. _ .- -. - -.. .-.-. _ ) . . . m A Supplcmentary Information Duke Power Compaay entered the commercial nuclear power fie a three-unit station. Many serious field problans occurred in l' nit 1 fro initial constructir n through the transition (nysteas turnover) to an operational phase. They ranged from schedule disruption to catastrophic equipment failures. The source of those problems nas uudefined. L'a s equipment being utilized inproperly? h'as this inherent in nuclea- facilities? Could it be sabotaged? Thosa were some of the questions being a wed. ine steau Production Department requested assistance to loca e the source, solve the problems, and prevent recurrence in late- units. Design Engineering nanagament volunteered personnel for the tbsk assuming the fault originated elsewhere. Mr . 13, Chief Electrical Engineer se- h ed me 60 represent the Electrical Division in aa onsite inspection requiring coordination between Engineering, Construction, and Stean Production . Field c::perience demonstrated problems and errors were numerous and repetitive. A few thousand l'ait 1 changes were formall'y documen"-d- eSs a similar quantity were never documented. Analysis indicated th jo wereattributabletoimproperengineeringpracticesinDesignEnkineerik Poor drawing practices including failure of personnel to properl r itola E- changes, a casual attitude regarding the accuracy and checkin' c ' ~ and indifference for the drawin;s' utility were cuen; the 7.o S pre. em additional problem beginning with L'nic 2 was failu a causes. iT-E [o in E + - ' ,. cbanges on subsequent units. These proble m w-a discv.= sad uura.n< vist;3 to the Cnariotte office. - praalers created by Design Engineerin , When they real! zed tne e i:nituh c^: t h e.r b+~...>. a . u. n *m to t. .,ro..e - a. . . o --- e,ne s_, tuation. They insisted on neeting ccheduled , al: 3andothernewfossil, hydro,andnuclearsta[rie$ rc [n"C[-[[s,-~ l'.,g a ' d t'n- % Unit ion i of Design nanpower ror Units 1 and 2. Upon returning to Charlotte, for .. . C. Principal Engineer in char 33Iassumedthepositionofstaffen$d -in e e r~ of :lectrical Caatrol Instrumentation Design. One of my responsibilicies uas an ova all inspection et Oconae drawings before issuance to allcviate r,3;; 9 - M b I '4 *** s ' .i T. consh.ereu aecessary were to b+ enacred if i:Rua o 7... g L. a.. <. 3,,. .J j r----~.
. . . ;, - cna day's delay was observed in drawing issue e-nd if no at esy,n Group buparvisor raised an objection of a technical n .tura. I.msa Supervisors wera under e::tre'"e pressure to ralcasa drawin'e3 fo- neuer stations by a nanag.: ent that considered Oconee complete. Eve $ thouga.!. 3 nad assured ne the required authority accompanied the responalbility, Mr. C vircually ignored uy repeated requests for assistam a to cr set an c.:cassive workload and to avoid furchet- delcvs. The c -' ' uu- resultant ohjactions became purely arb!:rary because of tight, unrUabibbie ules estacltshed oy cana2enent. sc 'Ir . C preferred to avoia laterven;n, - in t.lsagreenents cetuean the Supervisors and rvself Instead ha . rollowed ':r. 3 alleged insistance that drawin[3 heissuedreg$rbssof thr!r concition. . . 1__ g
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The combination of factors - adequately reticuing drawinga, nanagement's attitude, and other duties -- created very unsatisfactory working conditicas during the next fourteen conths. Tha situation of having been assigned responsibility without reaningful authority led to my seriously considering outside'enployment. However, I felt a responsibility to alleviate as many of the problens as possible within the guidelines established, realizing they uould remain uncorrected otherwise. On October 10, 1974, during ny first work performance appraisal in approximately eight2en months, Mr. C requested ny comments. The points listed above were given uith the fact that had made a conscientious ef fort to itaprove employee capability, efficiency, and morale uhich would have resulted in better work performance -- both quantitatively and qualitatively. I requested treatment commensurate with ny performance and qualif' lans. - Because of unresolvable dif ferences of opinion, he suggested - cet Mr. B. My earliest opportunity to see Mr. B was preceded by h.. C's conversing with him. Mr. B was callous to ray viewpoint, accused te of disloyalty (insubordination?), and frequently stated that only his opinion counted and mine was unimportant. The only nossible question involving my loyalty is that of why I refused to blindly accept Mr. 3 directives and to "go along uith the crowd, and keep ny mouth chut." On October 11, I was fired by Mr. D, Vice President of Design ingineerin; following my refusal to resign. Sumaarining, my dianisual resulted frem a p;rsonality conflict arising '
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,% . , . .. . p y 7.y. .- 1 , .,3 p v.rin.; 7 ne : n.3,. , :12h 73ca . violating proEessional ethica in aatters involving public saf2ty. baagarant resented being asked to remedy those shortc.,nings, and rescated ay refusal ta resign. I have reason to believe that Duke Power Canpany rav give misleading infornatien regarding my work perforcance and/or cubsequent dinaissal. You may contact ny cther enployers tithout restriction, but M1 inf orr.ati n exenanged between you, L' uke Pcuer, and am.nts represea' 'n3 either organization must be *eritten; no verbal enchanjas are , emiaaible. 3:o unconditional release will be give:t ccacerr.i.y racy Beh Ps.se: nupf.;ed inio rma tion. I request that any decision concernin; ny empicyrant be based upon accurate and comple:e infornation; there bre, I till be pleased to answer any questions arising fran erit:en inCermation.
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, t . i - = . . . . D:-ar E, / ' Enclosed are two copies each of: 1. Mr. F's letter of November 20, 1972, on flow instrua:entation. 2. tir. G's letter of September 26, 1972, on QC responsibilities. 3. !!r. n's letter of October 5,1972, on instru.:ent installation practices. 4. Mr. I's letter of Novenbar 20, 1972, on preliminary instrument standards. ,5. Station Problea Report Number 94 of Januarj 20, 1973, on poor installation of instrumentation. 6. Instrument Standards of February 8, 1973.
7. Mr. J's letter of February 9, 1973, listing questionable items of instrumentation. QC was unable to obtain a clear definition of their responsibilities prior to item 2 above. This was issued shortly af ter "r. C r :alaced
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Repeataj request; cf r fror. J produced na rasults. J repeatedly told '.e that QC ;as unable to lock at tha e , 0 s,,. u.,. 30 or ~co..., , - . , , .aa_. Ae _at. t u r t.aer in uu rale 4 t.oe a c u.enn .oy s .m . 2 u. , tech-support to prevent proper functioning of GC. Scon after mv first conversatlen with you approxima:aly one conth ago, I anked L to let 're 10 0 '.- at their copy of the two docunents. I aedtately ' sharing en o f fice with L hecame quite sensit tve and defens tva that anyone chould want to see the docunen:s. He quickly explained that one was a collection of "notherhood" statements, whleh would not provide ne much information, and that the other book .eaa available in pera:icna, Severtheless, both virtually refused to permit ne to view their a pies. I feet that a forecentioned parties in tech-support ar e deliberately trying to cover their assaa and rake it lock aa if there a a good QC pre?r:= at Oconee, in fact, QC is being uaed e< a front. to naka : ase M!orta look legitimte to the AF.C and anyona else concerned. GC's hacus are presen:ly tied because all QC work must meet cpproval of tech-aupport. 1 hava been :ald by you and others in Charlotte that QC in not supposed to be limited by tech-support. In reality, the opposita is true. Further, J told me of repeated efforta via Randen Inspection Work Sheets (RI'i) to get instrun-ntation problens solved. Inatead of correctin ; probicca, M sent the reauest to construction - who said tha: installation was acceptable - and then ' returned J 's RI'i's ulth. answers that lunerally neet the criteria. " Construe:Icn says it is chay, and that is the end of it. It is none of your busb' ass to pursue tha :t: tar further, "or that ! didn' t give a damn abou: correc:in:; :c e p robi .e.a . If a discrepancy c::isted bat reen the cn;Lnerrin nrin:s :.nd 10.4 tall.i tio n , than a variation notice followed to ch.mge the . . a tin ;s , P00R BRGM . .. . __ _..._m . . . _ _ _ _ _ _ . - . . _ . . - . . . - _ . . . . . . . . . _ . . . . . _ . m- w 4
. . - -2- , - . but seldom were the installations changed. This attitude of poor or no quality efforts in installatin is especially painful in the case of sensitive equipment, such as that which would be advernely affected by improper 'inatallation (ref letter of October 5,1972). Also, C, K's yes aan - has told QC that no ef fort uill be cade at naking the Instrument Staadards retroactive. Instead, anything urong util remain so until soneone. raises enough hall in the right placen. There are many areas of which I am totally ignorant uhich should also be ideal sources of information such as - but not linited to - construction departments. Because of the above and other leads,1 have and/or am pursuing., I feel that a completel:. unannounced freene of all variation notices, all RIU's (formally QC-55's), and a complete check by qualified people thoroughly farailiar uith correct instrumentation installation and all QC records on site vould identify many problems of which I feel are not in the best Jnterests of Duke. Further, confidential conversations uith nany individuals working on-site should identify tany other problaa areaa chich may not be documented. I :.iust stress the inportance that any information uncovered will probably be difficult to prove, and that heads of innocent vorhers in no uny responsible for thw ( decisi.ons vould cartainly roll if percons invalved even cusnected . such en invasti;ation was being hald. Please handle very confidearially all infornation you recalve because of this. J quit last Friday to warh for another firm out-of-atate. M fornerly of tech-support, replaced him. If I can be of further assistance, please do not hesitate to contact - me. - . Respectfully, , A Signature Furch 21,1973 ' 4 P00R ORBM - . -. }
r . - 1 J Y on April 21, 1975 (~) I have reason to believa that certain ludividuals in renponsible positions / of Duke Pouer Company Desi;;n Engineering Departmant and :4111 Power Supply Company-Duke's purchasing agent-are acting in their oun interests, to the detrinent of both Duka Power and the public. Let ne describe a bit of my cFpacience uhile at Duke Powar, prior to explaining the above statement. I began vorhing for Duke as an Engineer Associate in tha Clactrical Controls and. Instrumentation group on May 11, 1970. Duties includad the design of Keowee Hydro Station, Oconec Nuclear Station, and other plants as well as the cecasional investigation of special problems. O, another newcomer to Duke in early sunmer, 1970, and 1 uorhed under the direction P for several conths, in design and checking drawings on Keowee, the emergency pcuer source for Cconee. C began placing complete confidence in P decisions, and avoided trusting anyone else. If a difference of opinion occurred, P comments were those used by C. Knowledge and c:<periance vere discarded, a pattern used to the present time by C if P is renocely involved in a decision. ? experience prior to joining Duka in lata 19o9 or 1970 uas graduation from higa school followed by a tour in the U. S. Navy aboard a subrarine. I an uncertain, but it may have oeen a nuclear-powered ship. Under O'n directien, the complenity, equipment required, enf ottendant cocts of " nit 2 vera radeced by come fifty percent coaparad rith P dasi;n of Ecowe Unit I controls. I uill not elaborate, Sur cen ra;.Other inportant compart. sons can be cited rho crsons rapidly dininished until caly three of f&r tacal . were storking on Ocenee, tuo part or full tirc+ by nidwinter. The others be3an . corking on b leva Creek and other projects. F r.y o f tha errors dLcccvered duria; t Nse ch2cks uare ultimately los: cecauae a cajority of the drawings marked uith corrections uer.> lost or destroyed.
- s t of the remaining = ached drawings vera lert
isn Desi .. En3:.neering cavad to its present locatic: In the Chc.:'ct a 3 Trade 'Iart in sumner, 1972. , P00R ORIGINAL . .
.. .. . - - Q -2- > - . Ideally, Engiacering designs a systen, Construction installs and verifica that all equipment operates, motors and pumps rotato in the proper direction, instrumenation is operabic, uith liaison provided by Field Engineering to resolve problems, and finally a system is released or " turned over" to Steam (Operations) uith a list of those iters ' rdsslug, broken, etc. , required to complete the system. In prcctice, Cconee 1 systa=3 uere turned ovar to Steam in an incoaplete, and otherwise unacceptable nianner. Steam Department managers suspected rp.ny of the probleru inherited vere avoidable and should be reduced to an acceptable qusntity. They requested the loan of one representative cach from Mechanical and Electrical Divisions to work one year onstte to perform a special check primarily for the benefit of Steam. This consisted of identifying all the equipment in each systen, verifying its installation, identifying missing and/or damaged equipment, and tabulating any such equipment or other discrepancies. Enginearing would benefit from personal involvarent in checkout and the enperience gained. It should also provide a means for identifying good and bad features in their respective modus operandi. Q was selected to represent Mechanical, and 1 to represent the Eiactrical Division. In late February,1972 I crrivad ensite, zeith Q centnf, one nunth later. I vorhed for R, Supervisor of the Ins:rirnentation Department, , Genecall:, cpeakiur;, '<achanical designs the process systnas, c .d determi en the centrols necesaary for operation, as wellas instrur mation required for nitorlag. Maahanical deteraine:, size, J ocat!ca, an I t spe f or each valve, pump, pipe, and instrument, as well nu identifyin;; each devt;e.
- !ote that nay itenis supplied in a purchased systa.a util be iaantLliad
by systens ranufacturar, cuch as that of a nuclear steam suppl:. systen and will the eby acquire duplicate identification. A third t1;ho:' of idsntification could and frequently did cccur -2 C:ence ,'in Steam attached ita 1lentification to a device. Vi rtually >very 3, neb itm s Oconee w, tired eithar double or triple identilicacion. , 1 .urch uei Mter Mechanical has csaigned its esrn set of identificat *cn t o
syatcms and included enly that identifiention on :Uchaaical drc .Ings, the key for relating the tua sets is discard 2d. Several cea*.hs later Electrical cust extract information to prcperly identify each e. ice such t*mt the electrical portion of the engineerin;; package .~or a plant can ha drawn. At this tire the inforratica desired by Siena .u,t be included on the electrical drawings. I shall give credit tharc due . tith th!s point: Stean now agrees to use the identifica.ive attarh;d to en iten by Engineeriu3, r..ducing conf usion censiderab!: . One ec. only hape . this, or a similar proble:a, vill not be reinvented through a i .O of c::perien ce , or otherw!;e. , P00R BREW - - }
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. , (~$ A nuc1 car unit has several hendred cach of process, control, and j .' instrurentation drawings uith numerous ancillary drawings, tab ula t ions ,. ' i etc. ! My three assistants part time employees who vere engineering students at Cleusen l'niversity-and I catalogued the power sources, control equipcent, instrumenation, and all interconnecting cables required for each cyaten. An inspection team comprised of one person from Technical Support, one ' from our group, and a construction electrician verified inatallation of all equipment in each systen as thoroughly as feasible using Engineering drawings for a guide. These inspections were expected to occur af ter systems were considered complete, but prior to actual turnover. These types of errors were observed on installed equipment. L. Incorrect field installation which disagreed with accurate Engineering drawings. 2. Installation per erronious drawings. 3. Installation corrected by construction, but drawin3s remained uncorrected. 4. Electrical terminals unidentified by equipment manufacturar, accurate drasings, installation operative but different frca drawings ! b2conce a similar contact was used instead of that: indi.tced on drawings. 5. Unacceptable installation practices upheld by per.gon(a) responsible for thair avoidance. Solationa to the above problems varied, but usually followed this pattern, respectively: 1. The Construction electrician nade ainor corrections "on the syvt." Large problems r9quirin; coordination utth cther depar:=en:s cere tabulated, and appropriate pecsonnel were provided a copy Construction nade audifications, and later inspections de:ar Lned the recaining problems. . -2. Technical Support contacted the design superviaor responsible for that system and verbally described the problea, preposed a solutien, and received a verbal agreement to the solution; otherwise the supervisor suggeated an alternate solution. Tech Support then in itiated a var tation notice (VS) to alert Engineering of the changes raquired and to permit Constructica to make required changes tithout waiting for revised dra:ings. P00R"0 RENA " .. - - A
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. -; -4- - , , . . . = . - / , , The V s contained space to identify which unita(s) unre af fected. ' If Technical Support failed to indicate all the affected units, or if Engineering failed to make the required changes on all af fected units, it 'occate necessary to solve the sane problem repeatedly. The latter "if" occurred profusely because Engineering canagers always stressed the intent to get dravings to the field for the unit considered cost needed uhile choosing to ignora all other 3. A VN should have been uritten to cover this situation since it involved deviating from Engineering drawings, even if it una required for proper syntams operation. C, ny Engineerin3 supervisor, and I had several lengthy and somet tres heated discussions regarding this issue. He contended that any deviation should-and would-be covered via VN. C philosophy was that problems could not exist in the absence of a docucented accoent from the field, therefore, do not attempt to take corrections unless the field complained loudly and frequently. My experience at Oconee led na to believe that many problems and resultant changes were concealed forever because of insufficient documenation. Ihny such losses resulted fron soneone's forgetting to notify those responsible fer follo.eup of problems, but I feel that a substantial gaantity vera deliberately overlooked because it ;ould have requirad someone's tire an effort to prnp^rly encument the Situation. Another explantica .cas that C's and subsequent draving cha ges ucre being processed, but were currently unmiallabla. This canditica nas acceptable and neigher caused nor resulted fron the previous situatien. 4 This type problan becane less f requent than se'reral others ?nring Ceonee's evolution because T.ngineering issued standards for identifi;ation of equipment tarcinals, cabla color codes, etc.
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drawings were revised caly be:ausa Ceu>truction Instal _2; e.uf, ment incoerectly, verified systaa operation, and lastly notiflac _~';anwaring o ' the problem. Dravings rere changed rather then argue ccer t'..e trSblea. ' 5. Prior to Oconee, Duke installed little or none of tt 3 ina tru- .ent a t ic a required in its plants. An cutsida firn uhase special: 1 vas ansmrur.entatio.1 provided those servicas. Oconee instrumenta: ion was testalled 5,. persons professing sinilar experience.
- o Duke staadarda entated
regardia:; proper installation until rell into the const ruction phase of Unit 3. The installation at best reflected those principles learned on previous projects in a cultitude cf industries.
- appliad for enploynent as an instrumentation specialist ir To:r.nical
S :pport at 0:enee. He was refused employnent ennite and contact;d m cone in Charlotte. That sane someone instructed Techni H. E m act to employ M inmediately. . P00R ORIGINAL .
, . - , - -5- - - . i.' ) . J . An undesirable situation involving M occurred frequently. Supposa Construction has installed an instrument such that it operates impreperly. Piping for tha instrument nay be sized improperly; it could require additional outicts for purging; the slope of che piping may be insufficient. Most ingertant is the possibility that thick-ealled piping, capable of withstanding elavated temperature and pressure in a highly radtoactive environment, has been welded, r2diographed, and considered complete. Regardless of the nature of an instrumentation problem, Construction often contacted M, who issued a V.'; to change any drawings in disagreement, httached are copies of letters and cecos relating numerous problens as viewed by hay personnel responsible for management of Oconee during both construction and operational phases. During ny residency at Cconee I becab.e acquainted ~ vith many persons throughout the system in capacities ranging from laborers to daparrtental apparvisora. One such person was J uho was employed in Quality Control as en inspector for a few years. In March, 1973 he resigned to accept - other employment outside Duka's service area. J related ray incidants such as that described above involving M. Other incid anta involved X, who was second in Connand in Technical Support cnd reported to L. At the time Quality was actually controlled by Tverm? cal Support , ru ctrdless of co trrary clois. ?cvsons in A"111ty repeatedly requested a uritten list of thair det tus from I* since his rathal connents utre undescriptiva and generally useless. Thosa same persons repeatedly asked for and uere refused access to 10 :r2 50, ?3A2, F3A2, and othar documents by K. In late sanner,1972 I centacted L and requested to vicu a copy of 10 CFR 50 and any document describing general duties, responsibilitics, and authortty of Quality related personnel. I:, sharing the offi;e space uith L, ictediately bacane indignant because anyone would rake such a request, and suctested 1 view a copy available in the Staan Department. Ha enfaasized tLose documen:s centain only "rotherhead" stattnenca mnd are so p,eneral (va3ue?) that little if any useful, specific i.for..ation can ta obtained from tham. 1 concluded that J statenents were correct, and :: uns totally unconcerned regarding the true intent of Qualit;. Centrol. G replaced K uhen the latter was pronoted. On Septerber 26, 1972, G ' issued a ten-item directive listing "the official in erpretatio1 of responsibilitics for Electrical and Instrumentat tr.a QC Inapection." The caelosed copy shows that QC is rendered incapable of =aking a bindin;. decision ad is considered to function entirely .,ubaervient to cutside i groups. This irplied that QC uas exactly what hud h2en sustpected-a spineless, paper organization whose sole purpose uas to answer AEC Que301J33. 1 l
n_ _ _ _ _ _ _ . -6- t . - . < . . . , m,
.- Realizing the situatica, I contacted E, the Diructor of Quality related { functions in Design Engineering's Electrical Division. My letter of March 21, 1973, and all docuaents referenced therein vere personally delivered to E. 1.*a also discussed ny overall irpression of the circunstances at Oconec. He suggested letting hin pursue that ratter further through channels and inforcing him of any further developments. I agreed, and contacted him later to deternine the ecci4ts of .that information. He stated that the proper peraons were working on it. E is presently a Cuality Manager in the Elmetrical Division, and reports to B, according to sources uithin Duke Pcuer Conpany presently. While working at Oconee, I taintained contact uith cy supervisor and 3, head of the Electrical Division. It was erphasized repeatedly that many prcblecs could be avoided by adequataly checking drawings prior to reissue, rather than depending upon field personnel to find errors. I had carried marked copies of current drawin2s to C several tihes requesting his pecple transfer the information exactly as shown en the narked drawings. Rarely did that infor:a:for return to the field correctly. During cne of his nid-surrrer visits to Oconee, 3 and I discussed ny future role in the Electrical Division. I uould be responsible for inspecting all electrical control nnd instrurentation drawings prior to their issue or reissue for field usage at Cconee. My asking "Does this nean I will have t'ra authority to get things done, or caly the responsibility?" uns answered, "'.:n vil'. havi hath reap;nsibility nd cu:hcrir; for na.ine an chan:u_. i.1p r ; . . - . rmnts , or uhatever". . . Upon retuntina to the of fice Seoterher 3,1973, ! vas given rM.atively f re. reign in inspecting and improving the drawings issued by tha Electrical Controla and lnstrenentation Design. I we.s instructed to avoid delaying en.' drawing rnra than ene working day, r.nd '.oing anythin3 uhich - 13 af fect t'r e , safety and/or operation of the plaat. For th? first feu conf I uas a fvur2 . overleaded and requested assistance which never arrived exce,t far tuo and ena-half nan-daya help on computar inputs. I urote B a letter in rldsuncer.1973 containing la sugecatiens for assistir r and inpraving the Electrical Division. C and i discussed that letter in Octohar. During the discussica I volunteered a cenrent relat ina .:y feeling; that it was rather obvious that et least one, perhaps seferal, .arsend v era involved in arrangement with a vendor, and I expressed my hopa tha: he ras not involved. I had no conclusive preof and readily acPaculedged it. How-v-r,. I refused to furnish nanes as he hcd requested, but I did cervare the situa _en with Uatergate with possible strings going tcuard the too of the Canaany. 'ne subject uas never again discussed between C and tyself. My erployrant uith Duke Power ceased October 11, 1974 vith C cer -nt s, D ccacurrence, cnd D giving re a choice of ral;ning or beira find. I re h, . .: . to resign. --
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. . - Q' s The following lists the individuals, fires, and other infornation describing !j the situation in which I suspect Doac Power Company's supervisora are involv:d . much more than is acceptable in a legitnate basiness relationship: Several hundred. ITE Imperial series J13P industrial control relays used in Keouee and Oconee control systees required replacement in whole or in part three times. Those relays represented- new design, and core purchased without any form of Duke testing, ,but with the encouragement of S, Principal Etnineer supervisor of Electrical Control and Instrunentation Systems. I believe this uas 1TE's first attempt to produce such a relay. Consider the fact that virtually all the controls for Keovee end Cconee Unit I were installed and aperativa during the exchanges. It was concon knowledge that Iarranged fishing trips for the benefit of its customers. B definitely exercised undue influence and poor judgement in selecting this particular equipment, and possibly recalved other favors from ITE for their actions. Approval for a purchase requisition' varies depending upon the value, but it permits considerable purchasing pcwer at the levels of Principal and Chief Engineer, especially if the purchase is piecemeal. Typical of this situatica is the purchase of control relays, switches, and cabinets. larger acquisitions ' are influenced by an Engineering evaluation of the bidders ' facilities, quality control program, prices, and any other information censidered necessa . One important criterion .s how " closely" the vendor vorhed wi:h Duke in past centracts. Crandfacher clauses e f fectively res t rict the inclusion of nen vendors onto a preved vendor lists while assuring established vendocs of virtual inclusion. L.uality Control procedures and requiraments nra suppo,c-d to be najor creas of conden. Mill Pouer evaluates the pan'<are and awards the contract to the successful bidder. Unit Electric of Maitland, Florida has been the cuestienchle recipient of several Du'<e contracts for building centrol panels, consolas, etc during the past taree or four years. Unit's first nuclear experience cas at Oceaet, with little or no chany.es :aade from their previous non-nucler.: p ner plant destyns. Unit can new clain extensive experience in nuclear d ? signs withou: question. In ny opinion 5, P., C, and T and other Principal J.icct ricci
- Engineer, uith U of Mill Pruer are deeply involved.
The afore entioned individuals as cell as other En3 aeeries repreantativas t acre visit.n3 Unit on a Thursday and Friday in May or Jun a , 1973 for the 4 purpos e of inspecting control boards. S , 3, C, and T ucre not incpecting equipment as alleged; rather, they care elseshere. Deducing frca their invitattan which V declined to accept and other people's obsercations, they remained in Florida af ter Thursday for a cor.bination fiching omd/or boating excursion complete with feninine conpaaiens. I feel it could be rea:,cnable to state that other " inspection " trips uere equally fict ic tous. . - . & _a
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. ' U, a Unit representative located in Charlotte, hosts S, B, C, T and U to - . lunch at least once each week. Ocasionally other persons have been invited when sore of the above are absent. ti conversations imply that the luncheon is usually non-business related. I realize the a';ove info nation is brief, but it is a c !.lection of cbservations hy cyself and others. So far as we know there will be no written proof anywhere as all arrangenents were surely handled in person or via telephone. . 0 5 a P00R BREM e _
. . .- ! - , f. a . . m e ,) i;otes of General Problems Observed Uhile C Oconee I .. 4
Problems observed at Oconee and discussed uith B and/or C ucre nune rous , frequent, and repetitive. Basically, Design Engineering personnel vere careless in their checking of control drawings prior to reissuance to the field, or were co pletely ignoring the true meaning of " checking" a drawing. /.nother najor problen uas Design's attitude that, "any coincidence betueen released drawings and their usefulness to field personnel was unintentional.' Many times I have heard C and others in Design say the nost inportant thing is to get drawings to the field, and concern ourselves with finding and correcting errors at some later date, i.e. drawing revision. Each time this uns expressed, it uas attributed to 3 initiation. In reality, the field (construction) persennel vere the ones who found and corrected the tremendous quantity of errors on each unit. Variation notices were the methed nest of ten used by field personnel to notify Design of errors on problens which vere solved or changed to f acilitate usa 32, and required a drawing change to acknculedge thora codifications. I contend that acurrate drawings do not require completa and repetitive checks to assure their correctne.ss. My #requent requests for improving accuracy and usefulness of drawings was ess..ntially ignored by C and others. Itens uith uhich I disagree in part or in whole with C - Stener 1974 1. C's refusal to try to correct all grauc. din ; ;k..tenes on dugs , *.hlla being repeated 1.y cognizant of the problems la the fi21d due te parr t ,inymn M nn n.A!:s c c o f 1 ' e a vr 1 n Fm--a r s .
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'e- c (1) Verbal, (2) letter, ( 3) S'1RO-60-D . , 2. Despite an obvicus rmJ c::pr23 sed need for Tull-tine us.;is traca , C ' as provided only one half naak c.f it via X during the ucek prlo-
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Christmoa. 1973. It aas expressed that cce.put e r and a ll o ' ' n- srNs - . . . , .
., r2 3 0!1n3 CdeC;*s 'O u., d ,J e p' rI O C"le O , vdC OnlV t. node r 012 t '..r 73CO,M. to the CC*'. peter Uere given 4tny Checks . . 3. R ry.r: ding ny letcer of s=mer,1973 to 3 C3f erring swe li arens that should be i.ap t u v - l . E c.id i . r.:ed late one n; sat in the snel: 7;l; discussing thes e i te r.s . Since ic.en na ether discuasior Fas , sued, cad it is quite obvious tha ,any of the point ; tentioned are in no canner being actital;. 12 proved on future stations. i 1 ~ \\ i i - . h W h ._.
etteckrrnt T ~ " . . I ~ . . . . _ _ . d.- h c _.t. . a__. , o_6 , _e o, ,i _ . c, . u. .. ._ . , . _ . , ' .. I 1 - . . ' Effective 5c..cdjately, the following is the of ficici indesprEtttion of the respcnsibilities for Electrical and Instrutentctica QC Inspec- tion. 1. The QC Inspection group is not directly responsible fer the con- tcnts of 10C?230 or the FSAR. All interpretaticas of these two docunents shcil be obtained froc the Field Engineer. 2. The : count, cost, or time spent on rework is not the responsibility cnd shall not concern QC Inspaction. ,. A 3. Unless noted on prints , the serviceability of equipment installed , is not the responsibil4:y of QC Inspection. Questions as to the serviceability or the recoval of equipment for calibration or repair vill ba subaitted by Operations to Design Engineering. - 4. It is net the responsibility of QC Inspection to review or quas- tion the design of s system or instruz.ent leop. The respcasibility of QC Inspection to the Ccnstructica Departcent is to see that the equipment is installed according to applicable prints. The . . .. . desi~n or a systcu is t.ne resnonslotlity . . Desle.n enctnaerine. . or . _ . . e . . o o If fer any rect:n a systen dees not perfern its intended function, Oparations will suhair a r-quest to I)esign Endneertug to hava ne , design changed. No technical questicas vill ha subni:ted to: . Constructica Technics.1 Support or any other departmen:. . l 5. There vill be no suggesticas to field forces as to the best : y to install any equipment. Disdrepancies c2y be poin cd cut to field forces. If discrepancies are not cor cc ed af tar being pointed out, a Randon Inspection Ucrksheet should be uri cen. , 6. Obvicus errors on prints, details , GM drcwings , Varic:ica Notices,
l . or pertaining to the installe:ica ef equipnent, vill be vri::en up on a Kl'a'. I' 7. The use of the RIU uill be lini:ed as stated in para _ trac.hs 5 and 6. Ilo suggestions or requests will be noted en this f or=. L L. 8. _Any ansuers received f rom Technical Support or Design Enginecting will be final and not questioned a second rice. , l 9. Suggestiens ray be submitted through noc al channels , but en ei:her
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blank s:ctienery or to:.pany stationery , and only pertaining :: :h e i QC progren. 10. The issuins of standards for Cens:ru::lon and QC will be dene by Design Engineering. . -, 3 i P00RBRGH% . . . l ) }}