ML19317D410

Ack Receipt of Identifying Certain Allegations by Former Employee Re Qa/Qc of Electrical Sys.Forwards 750716 IE Insp Rept Documenting Investigation of Concerns

ML19317D410
Person / Time
Site:	Oconee
Issue date:	09/19/1979
From:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP
Shared Package
ML19317D407	List: ML19317D406 ML19317D408 ML19317D409 ML19317D410 ML19317D411
References
750919, NUDOCS 7911270809
Download: ML19317D410 (1)

Text

,w UNITED STATES NUCLE AR ' REGULATORY COMMISSION -

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REGION il 230 PE ACHTR EE STR EET, N. W. SulTE SIS ATLANTA, CEORGI A 30303 AEP 19 S75 i

g Mr. Jesse L. Riley, President The Carolina Environnental Study Group 854 Henley Place Charlotte, 1: orth Carolina 28207

Dear Mr. Riley:

(

Thank you for your letter dated April 29, 1975, in which you identify certain CA/CC concerns relating to electrical systems at Oconce that were brought to your attentien by a for er employee of Duke Power Conpany.

The results of our investigation of the allegations identified in your letter are documented in an investigation repcrt, a i

copy of which is enc 1cced for your information. A ccpy of the investigation report has also been forwarded to your informant.

Should you have any questions regarding our investigation, we will be glad to discuss thent with you.

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Very truly yours,

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4 Norman C. Moseley Director i

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Enclosure:

IE Investigation Report !!o.

i-50-269/75-8, 50-270/75-9 L

and 50-287/75-9 i.

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If this report contains any inforration that you believe to be proprietary, it is nccessary that you sub-it a uritten application to this office requesting that such inforration be withheld from public dis c 1.ca ura.

If r.o proprietary infornatica is identi!' icd, a writ ten statement to that ef fect should be submitted.

If an application is subaitted, it must fully identify the bases for uhich infornatian is clained to be proprietary.

The application should be prepared so that infornation sought to be uithheld is incorporated in a separata paper and referenced in the application since the application vill be placed in the Public Document Room.

Your application, or written statement, should be sub nitted to us uithin 20 days.

If ue are not contacted as specified, the enclosed report and this lettar may then be placed in the Public Document Roon.

Should jou have any cuestions concerning this letter, ne vill be glad to discuss than uith you.

Very t ruly yours,

Terran C. Moseluy Director Encicaura:

IE Investi-ption Reoort Mos.

50-259/75-8, 50-270/75-9, and 50-237/75-9 cc r/ report:

J. E. Srith, S tation Manager P. C. ?c:: 1175 Seneca, South Carolina 29573 i

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50.269/75-S 50-270/75-9 50 -237/75-9 REGIO'; II S u'i

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Duke Power Conoaav, J

i Oconee 1, 2, 3 License ::as :

DPR-33, 4 7, 55 Docket s.,.os :

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An inves ci;;ation was conducted of statements t ransmittad to the US:;2C Regica II of fice cilegin:; that (1) qua'.ity control functions at the Ocor.ee !!nclear Station (O':S) reinted to instrtmentation rere hampered by the other organizaticas ;

(2) that the dr., win y fer the C:'5 instrunentation trere less than c.dequata and (3) that Die Power Company (DPC) had procured in1dequate equiacent ior 0:!b.

Period of Investigatior

'.ay 19, 19 75 June 3, 4, 5,19 75 I:

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nea.s.on For Inve.n t.i p.a t Lea-The Carolina Environ. ental Study Group (C'iSG) transnitted a lattcr to the Regio:1 II office suggesting that the Quality Control (QC) ONS ras subordi-nate to Design Engineerin3 The CESG contacted a former enpl yee of DPC and made arrange cents for ;nC investigators to intervicu hir.

The f or-er eup,tcyee provided t.ue investtgators uit.n a s.L gnec,. s ta t eme n t c :. t.nree allt.gu t ions (Attachnen: 1).

This investigation uns conducted to deternine the validity of the allegations.

,Sunna ry During the peried "ay 19 cnd June 3-5, 1975, an investigation ras conducted to determine the validity of allegations made by a forner enployee of DPC-pertaining to 0;S. Cn June 3,1975, the ' ?.C investigatocs ir.tervieNed tne forner enployee to cbtain iactual information that could be used as a basis for 'urther inves ti utica.

Subsequent to this, the ' TIC inves t ip tors con-t ducted an investigatica of DPC Charlotte operations on June 4, 1975, and a site investigation of 0::S i' nits 1, 2 and 3 on June 5, 1975.

The f orner employee had aupplied the :;RC uit.h a u -itten state. ent contalai,

three alle3ations-1.

Quality iucetir s at Oconee I;uclear Station, cre hrnr ad b.

thrir being centrolled by Technical Suy ert.

2.

~.) e8 i7n Lugin?eJiu?, pri aced a 1.e s s L'..au nd sc:. :a t t.

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becau',,. of povi enyineering practices, n: curacy of dr.Fnp co?

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Eq uip-e ut, unsuitable for the rpplicatica, has bean v. 21, and purebasa of the c'.uipment was ':a ;cd uoan f riead:0 ! s

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f acec rs carcincd ta the rec uir. nents nece:.sary foi r: par t

cperatic.n.

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..he cileget n s.a c. t t r i c u i :. : n identu ying w e t.. e t.o u. a a t n _ n o r,a r" > -

that could be investicated in dtsth and reat of cie equirc:en _ :.. a rr< te unn r.an-n a f e ty relatel, r.ach alle pcion uas inistiqued to :~

c::t e n t possible cad it was conclud2d that allegations 1 and 3 could

-st 's c s ub-stantinted.

Houever, allegation 2 uns partial.ly Q:. t an t i t:1. s. This 1:.

to tb finding that cen tra ry to 50.5'1(5) of 10 CTP. 59, a st~:::ca nafety ev nuatien uns not perf aned to determine the scfee af s nific y ~.ce a t naking chan.e3 to nafety relt.ted instru; entation avstem cithout u.:::vai as re--

cuired b,.

n.arna,ceph 13.5.2 ef the TSN1, and not inatalling in.:.runentatic, sya t u r.3 in accordance with para;raph LC.3.5e. of r % FS/J1.

E ecifically.

the 1v es t i; ato rs f o ur.'. that the de ta il ed drauin: - for tuo :-f2r rela.e?

instrenentation syn tcc ; dio not ref!cet the a Sailr status

. tha plaar an[. t!?.

[.0 3 sta?" 7 tat i0n

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Reactor Inspector l'ngineerin;: Section Faci.11 Lies Construc tion tranch Dates of Investigation: June 3,4.5, 1973 Reviewed by:.,h_'

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L. L. Beratan Date Senior Reactor Inspec tor Engineering Section Facilit.ies Construc tion Branch

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"ersons Contacted 1

Duke Power Ccapar" (?Q l

U. H. Oeen - V ic e Pr e =,,ident, En?,ideering J. R. UcIlc. - Co rp c n e QA

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C. 3. Aycoch - Cra s:.c. tion QA Manap,er C. J. Nylie - Ch;e f I-gineer. Elce trical R. H. i.'al tnan - Prt..:. n i I:rginee.r, Eige trical T. C. '.fe'teekin. Dis i

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'.:r a y rc R. J. Drack? t t - f.s g i. Sin t QA Engin eer

^'. S J. :.. Sni th - Plar.t.. ariatendent - 0?;5 K. U. Schnidt Ass :. ; te QA En;;ineer, Construction O. S. Eradhart - S t.: 3:.:;tendent o f ' aintenance: - C::S 4 m 6.

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1 Inves tication of Allenat ion 1_

i Allegation 1 The alleger, in a signed statement (Attach:ent 1) dated "2y 19,1975, alleged that quality functicas at ONS vere hampered by their being

" con troll'ed" by Technical Support.

Intervieu uith Allece-The NRC investigators interviewed the alleger on May 19 and June 3, 19?.

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 North Carolina.

He dce; not have any work experience in quality assurance (QA) or quality contral (QC) disciplines but has interf' aced with QA and QC on various assignments.

The alleger stated that he was not cssigned to QA or QC at OSS but reported to Steaa Production Department. He was not familiar with the Ql requirenents or or,ganization structure as s tated in the FSAR, Appendu.

13.

He stated that the Construction Departv.ent did not permit hin to t..=e the FSAR.

He also stated that he was not avare tha t a copy of the FSA?

uas availabt2 for his use at the public docuaent roc: in the ilalhalla County Library.

The allener stated he felt ec cas cubrervient en D ~.i n r-d T c5nimi S upr.o rt, and that QC had no teeth.

This concluaiaa va. bawl on his inter 2 acing wi.th QC at O'4S and his observa t ion that QC ceuld requast chaa3es but could be everrul2d ry Desi;p.

Upon interen nt'en he stated that of the cu3gestiens or requested chanyas. e.pproni atel: 20 percent vere related to pro')le=s and approninately U0 percant uere

helpf ul" sugges tions based on the individual re :ues toe 's e.:periance.

In refere0ce co this, the alleger prov;.ded an appamnt NC internal do ctr.e n t (Attachment 2) which 3 ecified the ducies w'

~ r: ens ibili tic s of QC inspectoca dated, Se-tember 23, 1972. This documnt lista ten responsibilities for Electrical and Instrumentatica qC 'na w etars.

T Y-alleger stated that this.ias the first fornal definitier ef Q:. functions and he felt that it ras helpful.

The alleger related that numerous problens enuted in the G S instrune;-

tatica but could act specificall,' identif y any s"nten as acing def icia.c He stateI that the process instrumentation sensing linas installat ica criteria such as line slopes and routings ware not de t ailed on.'ravinp.

J In general, when these deficiencias vere detected and d'c ud en Handon Inspaction Iorksheets (nr.:) and Variation :cticas OJ ;), correc. ::

actica uas initiated for that spacific deficiency but c'c atcLed that only thcse that vere specifically docunaated :.ere corree:2d.

Tha inve:4 t igate rr. queriod the alleyer if established e m' :rea f er contre.

ef 1H'.'s and Cs,ere follcued to rc:so!ra "rahLe.s.

He c ar:.l ad L.m h2 d i r.' r ' t hnc i amu: the ".L.ts end ac stmes m' th.,

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stated th:t there. ore no ins t rtmnt sta"d uda et 0"'

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't and that in.;pec tica of the ins trtmen t installatio w care a uie unl;. to 1

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E verify conformance to drawings 'chich were linited in t h e an.c u n t of detail. The alleger provided additional DPC docunentation to support his allegation.;.

In one of the docunents dated " arch 21, 1973, uhich was prepared by the alleger while employed by DPC, the alle3er rade ref erence to an " investigation."

In response to questionin,,,, the all2ger stated that he uas conducting an inves tigat ion of his cu, and conpiling infor.7.ation bas 2d on confidential intervicus uith construction and QC personnel.

He stated he was assigned to the Stean Production Departnant and that he had no charter to, nor had he be2n authorized to conduct any investigation; it ua, strictly on his oun initiative.

Inves t ic a tio.t and Inte riaws The investigatcrs net uith D?C personnel representing Design Engineering and Quality Assurance at various Charlotte offices on June 4,1975, and discussed various aspects of the allegations.

Appendix 1B of the FSAR describes the DPC approach to QA and QC at Oconee.

The organizati:nal structure as it exis ted at the tine in question is shown on Fi;ure 13-4 of Appendix la ar.d is further caplified by an organizational chart in NRC files titled "Ococ.ee

^;uclear Statica Orgaaizction fer Quality Control and Technical succort" datml 'm3uat 1~,

1972.

In discu n icas 'rith D?C T. rerscnnel, it t;ns stated that Tac:cnical Support and Qt.ality Control rere the sar-:

.r~:niza:ica v 1 al t.'rac nt:c c: :::.a p r= :..' '. :. :., -

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1 nun, ort.

The QC f unc-i r.,

las primarily suc'.nolis%d a ins e c ::: c.,

.: a QA fuaction by th.' discipl;.ne field eng inaer and c ec'.p;icc.1 < njert N rnonnel.

The technie n support personnel nri. aci.ly, arf o r :.

7.a i.

7 engineering ducies.

This type of QA organisational structure un-4.irl.,

connon uithia the nuclear indu3try in tim ir.te GO's and carl:: 70:s.

I: j fact, the FSAR distircti-, describes th is type of orgrnitati'n in p a rn ;r a ph w,,,. _.3.,. ra.ca z Jttes t.nat

, tv.e, r c ua u ty u.;urac.:,ragran n

4 confurns to the rr,c;ed" Quali ty Ansu:ance Cri teria

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a ningle renerell encep:

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The ~ prepose-i criteria sonn tL:es su ;est; t; it quality usutance f nctivns be cerfarn-d ly na orgm.nitrien21 cc: unent caparate ad ;utinct f rom the org.inization 1 cc n'enent h:n in; responsibility f:r an activity.

Duke confor:m to this

..gge :. t f

' lith respect to actititi :; carfor ed by craft men Ir the r.rm a f profess tenal engineerin.7, as applied in desira, cons t ruc ti.m, tes cir -

and operation, Duhe has :nteationally assigned quality assurance rencensibilities to tha t a

aaiuational conponents responsible

st p ro f easienal ene;ineerin: ac tivity. "

DPC personnel stated that considerable problens had been enperienc,d uith sone in;pectica personnel bypa.wsing supervisien cad Mig reemnd,-

ticas or see: 'n3 soluti:ss to prallers by extacttng design en-inae--

d i rt:C tl y Ztis. in. re-riicd by li;1i ti?^, t 01'.'91 a n ta aCCORS a cd d e fi r...' '

tV ra.gon,la;1 itis Of f.0 QC insp4. tor 4 Yba int L* : definit of c.

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{. y DPC personnel stated that there "as no formal instrumentation installation criteria in the early 1970's but that standards vere developed and irple-mented in 1973.

Instrunent installations.rere inspected to dreeing requirements and the acceptance or rejection of an installation uas based on the e:aerience and judgenent of the inspector.

The TSAR uas available in the Construction Departnant offices and uas used by QC personnel. Discrepancies vere documented on VNs or R1Us.

.NRC Inspections The 2:?.C (formerly AEC) inspection reports of the 0:iS during the late 1960's and early 1970's were reviewed to deternine if this subject had been covered.

Report 50-269/69-3 noted the need for electrical installation procedures and 50-269/69-7 identified a requirenent for greater dapth of QA and QC in electrical areas.

Report 50-269/71-3 specifically cited maknesses in the construction QC due to transf ers of key people, resignations and peor training. The identification of these deficiencies uas follo ted by D?C corrective action *:hich resulted in a continuously evolving QA and QC progran.

_ Conclusion The allegation that QC uas subservient to and controlled by Technical Support is c:nsidered to be a result of :isinfornation.

As noted above, the qC amt techa mi m.,,< e r t funct.icns *:cre intenrnt.:d inte a I

r e

.uag:e erp nz m en.

ints was a lairly cc non anu accentno2.c n,prt'ach p

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in the earl;. 1M0's.

The a i,pr stated he as not fr. ail:.ar rith :he QA description In the 75.\\R.

':o evidence cou:d le found 1.'c.st C - as sub se rvicn t :o Le.41Rn Enginearing.

The ?C in t ernal r.eno, <'. ted Septe:cher 25, 1972, (Attachment 2) uhich liste-1 ten QC respon>ib!Iities uns based on the entating organization structure and at signed f uac tima.

Tae nero content appears to be consic:t. int -ri ch the FSn d es c r f p t ion nd t u.-

allege: felt it.as helpful. The investigators noted that fcur af the respcasibilitiea cere uritten as neya ti'ce s tatene ts rath er rhan cositive. The respen;ibilities as definn nr2 thcse t t.' t are n,rnailj a.ssip.nad t: QC and ins::ction.

It appear, based on.ta tewt::. Twr DPC nnd t'e allerer, tha t inspectors cud otbars vere excealing :ae'r au thori t:: in interpretation of recuirenents and recolutf or af prebl<~s.

i la fact, the allepr stated he ras conj.ucting his cwn investi;2 tion uhich uns ret.rithin hia assigned duties.

The DPC rpproach to O.A and G.C at 0.':S ras.ks t one neans of strt.c turin,

o a QA/QC organication. This particular appr:.ach has proven to be difficult to control and, at the present time, is not censicered to b e the bes t. cpproach. As noted, the '.10 :nspeu tions identified areas uhere the Q.UQC progran at 0:;3 needed increvenent earlf in the con-structica pha=2 of 0::S.

These result ed in ci:ctions, 'thee a :plicabic, to~ D?C and suhr guent correctiva acti: c.

0 c.rther tw'2: i a '. i c t f

into this iten is planned.

P00R ORGE

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_Investi. cation of Allecgttion 2 i

Allegarfon 2_.

The alleger, in a signed statement (A t tachment 1), dated ::ay 19, 1975:

alleged that D?C Design Engineering produced a less than adequate set of drawings because of poor engineering practices, accuracy of drawin;;s and usability of drauings.

Interview uith Alle2er On May 19 and June 3,1975, the IGC investigators net uith the alleger to discuss the allegation and obtain inforcatica regarding specific

-inadequacies as a basis for further investipation.

The alleger stated that numerous errors were evident on drawinf s released to the field but he couldn't cive any nur;erical fimres e

of the extent of the problen. He stated that instrumant sc; sing line slopes vere not specified, the drauings lacked datail3 for inspection, and field changes uere not aluays incorporated on revised drawin;p.

The alleger could not provide specific details.rith regar-to roc?

cn;ineerin.3 draain; practices.

In respcasa to questions, r.e rela.ed that drawing are checked by a fellow des!'- ter hat not an inh. en ' an-icaco.

He did rot know if desien re tie rs.:ere perfomed.

The allerer v

referred to tb ? instrtw n: grouniino svst e m one he M

• d i ri not conforn to d arings and one chich usad confusin: t c-~.in 'lo gy.

'ie rMerred to dre. rin as OEE-15, 0792, 0729,11709 and 2739 nnd s'"t-060.7 as docunentation that tas in errer cad could aubstanticte hi, allcratim.

DPC inspection of instrumentation installatica.ros made anains: desig:n drawings which vere, in his opinien, inadequate and he ste.ted that no instrucantatien standards *:ere atallable until early 1973.

de furt:ar stated that instrunentatirn pipinx de:aila :hich represant good en -inee r-inc practice eere no t cl..c.ys shown er dretu: m, but thav coul t' be la3:n1}cd b;- [ield unf ned:S ev e *' f.C M "O ? ".? e r i fi ed b, d ef> y n on th-i details.

He stated that, c.s an estin

e. "3 percent of thusa chanses ucre actual problers cad cm. t ron1ratel.> 0 n. ercent cere al.a fu.1 surpsti:ns based on the e.rerience and judgenent of the DDC inspacar or other fie. _

personnel.

de achacv12dpd that n=a of these changes mre in:crp: rated en the detail dr ving by red hning and then transmitte.d to design.

O i rs ucre handled by a C, uhich is a foral desiva change ratice eud durin; o

the desisn nnd construction phase.

S tatica '-todificatica Repor ts '3:'?.)

a desi ;n change af ter tne systers uere turned over te teere used to ef f ect t

Steen Prede: tion.

The alleper sta.ed that specific problers, or ncacon-formances, cere corrected vhen they :ere identified and docunented.

!b rever, tha ;;eneral prc'cica related to the overall M 3 vas not address =2 b: Design hn:twering.

The allepr trovide? the 2C ri th co-in c f :r'0 internal ec anications uhich i,u> pert the ec tention tb t m,

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cunct*It* 'is p e c t n Ver. nat C O M E '. J t* d d.

e P00R ORIGINAL

3 The alleger stated that an audit of drawing series 0-422 night verify his allegation.

Inves tigation and Interviews On June 4,1975, the SRC investigators discussed design criteria, design

- control and design changes uith DPC Design Engineering and Quality Assurance personnel.

DPC personnel stated that all drawings are checked by a checker prior to release. The final release requires a three party signoff by representatives f rom the Mechanical Division, Civil Division and Eicctrical Division.

S ubseque nt to relaase, no design or drawing changes can be nade without prior approval of Design Engineering.

The field has no authority to deviate fran design drawings or standards uithout prior approval by Design Engineering.

The Variatica notice is the ceans by ubich design changes were acconplished.

Instrumentation installations are specified 6.a~an instrument detail drawing which is a schematic representation of fittings, tabing, piping and valves.

The actual installation is done by " controlled field routing" as specified in Appendix 1C.3.5 of tha F3AR. D?C personnel stat 2d that instrunentation standards were issued in February of 1973, but prior to tha t time no Comal standards existed.

Decisions ucre based en the experience of the field personnel.

On June 5,197 3, the.:RC inves tigators inspected lustruuenratica reisue-to the berated ::ater storage tuaks on Units 1 and 2 acm tha reactor building vantilation eco'ing nater systea for Unit 2.

The instn11ation vas inspected to verify conf aruance ; i th D9C ins trener tc tion s tandacds contained in "echanical Instrumentation & Control, instrenent Stanlards, Installation Field Practices and the design drawings, series 0 422.

The barated water storage tank level instrunentatien concists of tuo redundant channals and is detailed on lastrurent details 0- o2:-x-13 and 0-422-x

.S.

Variations betweea the detail drcuinjs nra the c t.ne lavesty.;a u ca.

r c e e:.aap, e,,.,a e installec syc cr' "a

~-

sa V17 is chc'en en dra,*in3 0 '22-x-13 but is not instciled.

'.a iscictica valve is instnlled uetueen the regulater cnd instre -ant JT6, and cn isolation valve is ins tallad in the return air line, but'neither are shown en the d2: ail. Tha de ta!1 shows the re3ulator and a lecal indicator to ba installed cutside the protective box but both are installed inside. Similar discrepancies were noted on the Unit 2 horated water stera3 3 tank level instruments and the reactar building ventilation ecoling tater r sten.

DPC persennel accompanying the :7C investigators stated tb..c all 053 instrunen.ation cas instali.2d to the sano criterin and Caat all systccs uculd c hibit sinilar discrepancias htueen the detail drr:ings and the installatien.

The sctual installa-tion f ccili ta tes cr.intanna e end calib ra t '.en ac t iv i t i r a - ue syate...

if installtd in accordarca lith the drnvings,sPuld not.

P00RORIGlE 1

l i

a DPC pecsonnel stated that instrutentation lines were field run and only the ' ins t. enent locations uere shown on drauingn.

Isolation w

valves, local pressure gar;es, air regulators and so forth care not shown on the detail drnings and hence any change of these itens was not the subj ect of a V;'.

The investiga tors had no cues tions concerning the field run installation of sensing lines and the lack of detail showing ells, tees, and couplings for these lines.

How-ever, concern uas enpressed regarding the lack of detail showing the isolation valves, local pressure gages and installaticn of air regulators.

The investigators reviewed the grounding philosophy and criteria used at 055.

DPC personnel stated that there vere three rain grounding systens namely, station ground, instrument ground and computer ground.

Some confusion existad in 1972 about ground terninology and DPC issued a memo on June 27, 1972, to clarify this.

Standardi ing grounds terninology and syabology is necessar,-

to reduce the chance of improper interpretation of design drawings.

DPC personnel stated that no major noise, interference or grounding probleas had been experienced at 033.

The investigaters reviewed drawings OEE-15, 0-903, 0-1903 and other drawings related to the ground systea at OSS.

The ground systeu vas inspected at selected points and compared to the drawings.

Drawinc.s 0-739-C, hevision 6: 0-1789-C, Revision 2; an1 0-27G9-C, '.evision 1 applicable to Units 1, 2 and 3, respectively uere reviead.

These latter three drawings are for transducer terminal enbinets ani the revistom re: errer:

2.at es t to mu-zi/,D.

Th2 drawinga nad r-::eream e u,.h c r t o m.s......:. 3. 3 o r c o n t a T.n eu, notes ce:..

, a gr.* unc,..ern t oi e y.

t..

tnin:;

The equipaenc ins tallation wa-i ecmpared with the en?.ina trin. drawing and the isolated pround traced fraa terminal blocks to de central bus.

To d23crepancies ver2 noted.

5"R-217-D uas a r.odifica tion to add a 253 oba rais tor in series with PT 14? and power supnly.

Tae SN appeared to be conplete and the documencation, including the dravings, uere in agreement with the installatien.

S"?.-G50-S, a station nodificatian to add an cdditional ecmputar alan as an aid for operators wac. rs"imd 2nd ne inves tigat rs c:d no questiens.

SMR-130-3 relatin;; to the installation of Sa.:le" Cabint

!!o. 15 in the centrol roca was also reviewed and r.o discr-pancies ver:

n.

Co nc1 >:-t io n

- - ~ -

Ihe inves ti; ation cenducted a t ONS on June 5,1975, appe.>rs to substcc...ne the allegation of the inadecuacy of sone drawings.

The instr :.entnti -

installations are not, in all case.4, in accordance ei th the desi::n det-i_

drawings.

Since the instrcr.enta tion ecusing lines are Zield run datai..;

for each tubing or piping fittin ; are not required.

Ucwever,

/s ta components such r.s valves are require.1 en detail dr:nring u that the true sys ten configuratiun !;. available f or referexe at Ce ;ite.

Ott r-

.19, in the event o f an energency, 2ny a al;. - a

'cn a reur;te in. Or'fDentatica drawi? :i, COU2 d h e in Or ro r *'.I L.'U ld i C.'. t4 (M r.'. f.'

Con 31guenC?s.

P90R BRE R

r

- _ _ _ _ -. _ -.. ~ _

-..._..~.,;

-S-c 1

]

The DPC quality assurance prograu deacription is contained i.i Appendi: ';

of the FS.".R.

Paragraph 13.5.2 stntes that ' '.

all dra.:ings an.! proes-durcs for conatruction of the station prepared by Duke, consultants, or vendors are revie* ed and approved by engineering prior to releasa to the Constructico Departrent.

Any changes to these must be approved by tia Engineering Department

." This commitr ent appears te have not been fulfilled in that changes to the instrument deaign have not been docu-cented and current drcuings are not available.

Also, paragraph 1C.3.Sc of the FSAR crates ".

. All field engineered lines are schenatically shown either on a diagra:.natic, an instrumentation detail or a piping drauing such that mistakes in valving, connection termination points and naterials are virtually eliainated.

." For the tue sa:cty related sys tem.s exanined by the SRC investigato rs, this comnitnent appears to have not been followed. Also, *he investir,atars did not find any evidence that a uritten safety aluation was parforr W, as required by 50.59 (b) of 10 CFR 50, to <

are that the installt:d chang::s f r o't that described, in the FSAR do not involve uarevicuad raf ety questions.

Failure to conduct a safety evaluation of the saf et; significance of these changes and to obtain approval of the char aes

-ac required by the FS/a is considered an item of conco.uplianec-with 50.59(b) of 10 CFP. 50.

3.

Invenim. ilon of iUcuation 3

.p~ L,.. a, a t i c a..

',',6 e

lhe alleger premred a s r.gaen stetene.nt (m. c a c:s..e n c 1), cu e.

-ia y ir.

allniu;; that clu'.pneac, unsuitable fer th2 a, lica t ien, :._ :, been u., r -

and purChdS e o f tile e'{uipnen t *'as baWC upon fric.jship0.- V e c h*' *.' a d !. ;

unrelated to ti.e re ;uirements necessary for proper operati.a.

In terv_len ui th A'.tev er The F'?.C investigators re t t ith the allener on '?av 19 nr.d

'un. 3. 1973, to diacue,s c  : uile3ation.

E h.: inves tir,2 tor., a t t enp t e ' -- i d e..'. t C:.

specilic or,uipnea 1 c.3 : Pat could be traced : a r oc..J. m u rac ris.a a Sani; te estab!ich ts ~ + ' n' i t; ef t': e c1 W a t ir.,.

Or tha technir._

aspects cf the alicgation icre favesticated The alle;,er stated tha t DPC awarded contrac ts to suppliers vith no previcas nuclor experience.

IIe referred to ceatract a*arded to Unit Electric Cenpany, OrTr-do, Florija, for control r rn equipment am! eneis at the C::S.

F.e stated that Unit Electr ic hsd no previce.+ nuclear experience but could rc Identif:* ac.-

specific deviations er inade,uacies related to this r,rocurcreat, either contractually or equipnent related.

In response to cuestioning, the alleger said tha: he had not reviewed the procuremn t cont rnet, had not beer involved in t!.e prep'r tien of 'th 2 p;*o ctir c.Sn t p e c i f i t* a t io r. I' h hi S -' t POvito ad tM S peC'I.2 iCG t i.O n i n dep t!'.

T'> all: e a lc.o L a t.< thct D '

.a auard : a centract to nc::- e ta -

i rt.. s.hich he auld.a c:'l the nr.:es, to hu Ce p aa c 'u ca:1 6t.a ha! th m tN pggggg':lgl'ygt c m s. ; c

~ ~ _ _.

L_

a

'i

-9_

The alJc3er stated that several hundred ITE Imperial J13P relnys used

)

in O':S control syc ten:, required replacenent.

11is opinion ucs that i

these relats repreaented a ne.i design and '.zero purchased eithout any DPC tes ting. He stated that he had not revicued or prepared the procurenent specification or contracts.

The alleger noted that considerabic pu chasin3 pouer residca at the principal engineer level for procurenent of relays, suitches and cabinets.

In his statenent, the alleger specifies that "grandf ather clauses" ef fec tively restrict the inclusion of new vendors onto approved vendor lists while assuring established vendors of virtual inclusian.

I!c also noted that quality control procedures cnd requirements are supposed to-be major areas of concarn.

Investigation and Interviews On June 4,1973, the ::!IC investigators net uith D?C personnel representing Desi",n Engineering and Quality Assurance.

The details of the procurenent cycle uere di:.; cussed and the specific precurenents related to Unit Electric Company and ITE Imparial relays uere reviaued.

DPC Procedures EP%-1, EPil-2, and EP!1-3 uare revicued as these uere precedures in effect during the tiae pericd in ques tion.

EPP-3 titled, " Criteria for Cualifying Suppliers of Nuclear Safety 11 elated Electrical Equipment and !hterials,

required pre-ai. sed and post-award etaluation of the supplier.

DPC records *;ere.ade available f er the Uni t Electric Crpany (UCC) coatract. A reviets af these record 3 shocs t.h a t IFC cord :ctal a pre- ' urd rurvey o f "..C cn CatoSer 2,19,70. which is d.,cunanted cn an Ev.luatice c 2

In /as t !:;a t ion of Froposed Bidder and Supplier Fern.

rN ser.

noted

t..ois as :.n 2 rirst to perfon.i aucm, ear.:er...

Laat xt. d,,eciricattan 03-309 I fcr c crLency pr ter s.iitchin; lo;ic nanels can' : bud. alc O.'

2 requirenents and tes : require,ents.

The reccrh include dcennentation of subsequent surveillance inspection and uitness_n3 of functional tests at ITC.

The cchinetc vere seir.aically qualified by cnlculations in Dece:her of 197 2, and subsecuent sais.ic testing of cabinet end companen::

b.v '. vle Lchcra tories realificd then b" tes t.

t DPC perscanel.,tated that 1c r OZ Cai t 3,.. cc;.p e c itive hi _). r "as acarded a centrauc t,or central roen p.nela. a! w t?.

IL. Tr a.-

Lu

~

company did not meet :enedulex.

The contract eas cancell:) cJ subsequently ciarded to l'EC, the second - let a t bidder.

0?C Desian En.tineer icP persen*Tal stated that the ITI Inv! rial rela"/.Il3?

w s

uns select.d by Design Cn;ineering based on design criteria rel2:ed to ph sical sice, nur.ber of centracts and voltage.

Prew us r.p e ri ence f

uith o ther manuf acturer 's relays proved to be disappointin7 anc the deu -

of the nauly d2Veloped J13P appeared te nee t DPC requir.'nec ts.

The relays vere procure? as a catalog iten base ' on ITI suppli:d data.

P00R.0RIGINAL

2.'%

p

)

DPC perforr.ed functional testing of the ITE relays including pickup time, voltage d rop-ou t, and simulated circuit applications to facilitate testing of the caergency start circuit.

A nemo discussing the tests dated Aup,ust 21, 1970, included a reconnendation to use the relay in the start circuit.

The ITE records pschase uas revic*ied and entensive docunectation uns available as objec tive evidence of tests performed, audits conducted and action taken.

During functional testing of panels at UEC in Oc tober 1970, several of the relays f ailed or nalfunctioned.

DFC, in conjunction uith ITE and Whaah :ta3netica, conducted an in-depth f ailure analysis, test and relay codification prograa. DPC audited ITE and Uabash Magnetics facilitics and prograns.

In June of 1971, DPC concluded from cyclical tests ccaducted in a dust environment at elevated temperature and hunidity that the ITE relays uere not acceptable for the intended application.

Cutler Hammer type M relays were selected as a replacement and test i tens uere subjected to cyclical operation under sinulated. environmental co ndit ie ns.

Based on the test results and additional Cutler Hammer data, DEC icit the Cutler Hcr:rer relays ucre qualified for the intend ed applica-tio n. All of the ITE leperial J13P relays wre replaced :t the 0:!S and Ecowe Station. Ths replacc.nent "as cccomplished in accordance uith a uritten procedura, was Nitnessed by a deaiga engineer and C,C it:cpectors, and is f ully document rd in OA folder 03-G03.

'1he invest:.; cors reviered the OA foldac for alaquacy.

As.. final s tep to preclude ~ :tbr wohlm ;

DPC issued a lctter dated ::cvena ar 1M, n / 2., to camove 1.c.eia)

..e.

'hich s te ch.

Da investigators selected several pieces of equi:n2nt the original deat.;a incor, orated the J13P relnya for fielt. _nsp;ctian to verify that replacenenc had been accompliched.

On June 5, 3973, the inves tigators inspected Ke. uee 2:e :;ency Start C'.iaanels A.pd D nt OMS.

Relays F.3, SIS, cnd SE5il in Channel D cabinet end relays :.A, S I.\\, and CESA vera Cutler Hatr.er relays and had bcen installed in c.ccardance uith DPC doctnentation and records.

VRC Inwections E.C inspection repor ts *:ere revie.Jad for p er tinent in f o rra. t len r als ted to the J13P relay preblau.

neports 50-269/70-12 and 5%2f : /71-1 di ccr >

tSc relay failures.

PPC reported the relcy influre to : TC for investi-gation into its possible ;;aneric inplications.

Conclusica The in'restigators could find no evidence to substantiate tha r.llegation that equipment unsuitabic for the applicatlen hed been us.'d.

Tar cculd any ceidence be fcund to subatantiate the char ;2 that precurc~ent contr.c:s were aJarded or fcctor; unrelctel to technical requiren nt s o ther th,n thes a :uch as cost and schedu te d ch are nor. 9.1. canaidr'.. ir-th '

3'ta rt i n g o[ COD t rdC td.

At th

• t i ic D P C P

'd r.' J : !YC cOM t r ' 2 D,

[*~C B id prQVJGG3 r4periOnce il

'r pi'id i n ? (1Cetric 1 cq'l

- 'nt U.'.

J" i l i t*f i

C" P00R ORIGINAL L.u_a

4

_11_

4 1

.i

/

-plants including Florida Pc.7er and Li+-ht,.9 u - Carolina Electric and Gas and Carolina Potier aad Li-h t u c ured equipmat such as control panehs for t$a

t 1

'I'IS'C 'i "

- under strinsent quality assurNn e r quircr

' CC "S 7'

We t provida cot.ensurate with the size c" t1 r1 requiretaent s.

Several

~

u s

.c assistance in interpretation of IE

~

other suppliers uith previous expNience. b c.

tte w rk and considering r

all factors, DPC, selected UEC.

6 l

P00RDIME G

i A

A achment 1 j - '}

COPY I,'A voluntarily give the following statements to Frank Jape and Dick Parker,.who have identified themselves to ne as representatives of the U. S. Nuclear Regulatory Commission.

Attached are twenty (20) sheets of related information substantiating the'following:

1.

Quality functions at Oconee Nuclear Station were haopered 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 drawin3s, training of personnel, and other reasons.

3.

Equipment - unsuitable for the application - has been used; purchase of :.,uch equipment was based upon friendships, and other factors unrelated to the requirements necessary for proper operation.

Sir,ned :

A

':ay 19,1975 P00R BRIGINAl.

2 l

1 u

)

>{

Supplccentary Information A'

u l

Duke Power Company entered the commercial nuclear power field with Cconee, a three-unit station.

Ibny serious field problems occurred in Unit 1 froa initial construction through the transition (systeas turnover) to an operational phase. They ranged from schedule disruption to Latastroph4.c equipment failures.

The source of those_ problems uas undefined.

Was equipment being utilized inproperly? Uas this inherent in nuclear facilities? Could it be sabotaged.? Those were some of the questions being asked.

The stea a Production Department requested assistance to locate the source, sc'.ve the problems, and prevent recurrence in later units.

Design Engineering management volunteered personnel for the task assuming the fault originated elsewhere, Mr. B, Chief Elactrical Engineer sel2cted te to represent the Electrical Division in an onsite inspection requiring coordination between Engineering, Construction, and Stean Production.

Field experience demonstrated problers and errors were numerous and repetitive.

A few thousand Unit 1 changes were formally documented; perhaps a similar quantity were never documented.

Analysis indicated the majority were attributable to improper engineering practices in Design Engineering.

Poor drawing practices including failure of personnel to properly impler+nt changes, a casual attitude regarding the accuracy and checking of drawin3: 4, and indifference' for the drawings ' utility were cuong the coro prominent An ad?.itional problea beginning with Unit 2 was failure to icplement causes.

che.nses on subsequent units.

These problem were discussad i.+. ny cupH m during visits to the Charlotte of fice.

Fhen tuey realized the magnitude ef problems created by Desi a En3 neering, they bacane reluctant to inprove -

d i

the situation.

They insisted on neeting scheduled priorities in designing Unit 3 and other new fossil, hydro, and nuclear stations - forcing curtailneat of Deaign ranpower for Units 1 and 2.

Upon returning to Charlotte, I assuned the position of staff engineer for Mt. C. Principal Engineer in charge of ':lectrical Control and Instrumentation Design.

One of my responsibilities was an overall inspection of Oconee drawings before issuance to alleviate past probleen.

.'.ny c ages 1 considered cecessary were to be enacted if a ca.:inun of ona cay's delay was observed in drawing issue and if no Design Group Supervisor raised an objection of a technical natura.

Thosa Supervisors vera under entre e pressure to release drasings for neuer ctation-by a nanagement that considered Oconae complete.

Even though Mr. 3. 2d assured ne the required authority accompanied the responalbility, Mr. C virtually ignored my repeated requests for assia:ance to cifset an e.ccessive workload and to avoid further delays.

The Supervisors' resultant _ objections became purely arbitrary because of tis'at, unrealis t ic schedules established by manage =ent.

Mr. C preferred to avoid interven ng in disagreementa between the Superviscrs cad nyself.

Instead, he i

folle'..ed Mr. B alleged insistance that drawings be issued rer,arliess of thei r condition.

9

,,6-a h rA = **

..gT

/

.The combination of factors - adequately revicuing drawings, nanagement's attitude, and other duties -- created very unsatisfactory working conditicas during the next fourteen months.

The situation of havieg been assigned responsibility without neaningful authority led to t,y seriously consi.derin; outside enployment.

However, I felt a responsibility to alleviate as many of the problems as possible within the guidelines established, realizing they would remain uncorrected otheruise.

On October 10, 1974, during ny first work perfornance appraisal in approximately eighteen conths, Mr. C requested ny contents.

The points listed above were given with the f act that had made a conscientious ef fort to improve employee capability, efficiency, and morale which would have resulted in better work performance -- both quantitatively cnd qualitatively.

I requested treatment commensurate with my perfarnance and q talifications.

Because of unresolvsble differences of opinion, he suggested I contact Mr. B.

My earliest opportunity to see Mr. B uas preceded by Mr. C's conversing with him.

Mr. E uas callous to ny vieupoint, accused te of dinloyalty (insubordination?), and frequently statad that only his opinion counted and nine was unimportant. The only presible question involving my loyalty is that of uhy I refuced to blindly accept Mr. 3 directivea and to "go along with the crowd, and keep ny nouth shut."

On October 11, I was fired by ':r. D, Vice President of Design Engineering follouing my refusal to resign.

Sunmarining, my disaissal resulted from a parsonality confl'ct arising

. -,,, o T

.t...s n,.-. pw 7.y.-..n.p...; r...

7 ;.. t n ;.,,. n i u, ; ;. c e violatin;; prof auianal ethics in 'atters involving public safety.

25ci32 cent resented being asked to remedy those shortc6.nings, and rescated c.y refusal to resign.

I have reason to believe that Duke Pcuer Company nav give uisleading infornatien regseding my work performance and/or cubeequent diraissal.

You may contact ny other employers ithout restriction, but oil infornacian e.: changed between ycu, Duke Pc rer, and agents representing either organization cust be written; no verbal enchanps are re-issible.

No incenditional release vill be given concerning say ub Tuse: aupplied in fo rma tion.

I request that any decision concernin3 cy emp:oynant be based upon accurate and complete inforcation; therefor 2, T teill he pleased to ansuer any questions arising fren eritten infermation.

t

=9

-.m

lu a r F.,

8 Enclosed are tuo cepies each of:

1.

Mr. F's letter of November 20, 1972, on flow instrumentation.

2.

Mr. G's letter of September 26, 1972, on QC responsibilitics.

3.

Mr. II's letter of October 5, 1972, on instrument installatica practices.

4.

Mr. I's letter of t'ovember.0,1972, on preliminary instrument standards.

5.

Station Problen Report Number 94 of January 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 ite=s of instrumentation.

QC was unable to obtain a clear definition of their responsibilitics prior to item 2 aeove.

tais was issued shortly iftar Mr. C relaced Mr.., as Head of Tach-Suppo rt.

Repeatel requests of :'. frou J produced no results.

J repeatedly told me that QC ',tas unable to loch at tha 1n. o c.s.,0, or...,t a r.s.

iaat te a,ar curt,ar ttu.%. cares.- tmetuos a-;

a tech-support to prev 3nt proper functienin; of QC.

.: con after

-v first conversation uith you appro::ima:ely one conth ago, I anad L to let ne 100% at their copy of the t.co documento.

Irmadiately." sharing an of fica with L became quite sensitive and de f ens Lva that enyone chould '.eant to see the documents.

He quickly explained that one was a collection o f "cocherhaod" statanents, which.could not provida

.2 much information, and that the'other book wa.4 available in :pe ra tiens.

l Nevertheless, both virtually refused te permit ce to view their m; Les.

I f.cet that aforeevntioned parties in tech-support are deliberately tr: ing to covar chair ass-ss and cake it lock as if there is a pod QC pre;r:n at 0:onee, in fact, QC is being used as a front to naha chose ef forta look ley.iti ate to the AEC and anyone el.4a concarnad.

IC's hands are presently tied because all QC vork rust neet cpproval of tech-support.

I have been toll by you and others in Charlotte that QC is not supposed to ba limited by tech-sspport.

In reality, the opposita is true.

Further, J told =e of repeated ef forts via.badca Inspection ork Sheets (RIW) to get instrumenta:Len problems solved.

J Instead of correctin; problems, M sent tha request to eonstruction -

who said that installation was acceptable - and then M returaed J's RI'.!'s uith nswers that generally ace the criteria.

" Cons t ruc t ion aya it is o! "e, and that la the end of it.

It is none of your busin2.is to pursue ths m tar further, "or that :: didn't give a da-.n about correctin; the p r.> a l e n.

If a diserapancy onisted between the e n,ineering n c;nts. nd it.s t. '. u cio n, than. variation notice followel to a m;p the. v :' ny,

-m,.

_2-but seldon vere the installations changed.

This attitude of poor or no quality efforts in installatin is especially painful in the case of sensitivo equipment, such as that which would he adversely affected by improper installation (ref letter of Oc*,ber 5,1972).

Also, C, K's yes can - has told QC that no ef fort will be cade at

~

making the Instrument Standards retroactive.

Instead, anything wrong util rc ain so until sencone raises enough hall in the right places.

There are many areas of which I am totally ignorant uhich should also be ideal sources of information such as - but not liaited to -

. construction departments.

Encause of the above and other leads,I have and/or an pursuing, I feel that a complet217 unannounced freeze of all variation notices, all nIu's (fornally QC-53's), and a complete check by qualified people thorceghly fanillar with ccreect instrumentation installation and all QC records on site vould identify nany problems of uhich I feel are not in the best interests of Duke.

Further, confLdentic.1 conversations uith nany individuals uoriing on-site should identify nany other probleu areas uhich ray not ba documented.

1 must stress the irportance that any inforration uncovered will probably be difficult to prove,

ind that hads of innocent teorhars in no "ny responsibic for tha

(

decisions w"1d cartainiv roll if narcans invclved even rurected such an inv esti;atica was being held.

Please handle very confidentialty all infornatica you recalve because of this.

J quit last Friday to work for another firm out-of-state.

U fornerly of tech-support, replaced him.

If I can be of further esaistanca, please do not hesitate to contact ca.

Respectfully, A

Signature March 21, 1973 P00R ORIGIM l

l

Y on April 21, 1975 I have reason to believe that certain Individuals in responsible positione T

of Duke Power Corpany Design Engineering Department and Mill Poser Supply Company-Duke's purchasing agent-are acting in their owa interests, to the detrinent of both Duke Poser and the pub'.ic.

Let ce descrl' e a bit of ny experience uhile at Duke Power, prior to explaining the above statenent.

I began vorking for Duke as an Engineer Associate in the Clactrical Controls and Instrumentation group on May 11, 1970.

Duties ine'.ule:d the design of 1:eowee Hydro Station, 0 enac :!uclear Station, and other plants as well as the occasional investihation of special problems.

O, another newcomar to Duke in early sunmer,1970, and I uorked u:tder the direction P for several conths, in design and checking drawings on Keo:su, the emergency pcuer source for Cconee.

C began placing conplete confidence in P decisions, and avoided trusting anyone else.

If a dif ference of opinion occurred, P contents were those used by C.

1*nculedge and enperience were discarded, a pattern used to the present time by C if P is re:'otely involved in a decision.

? enperience prior to joinina; Duka in late 19o9 or 1970 was graduation from high school followed by a tour in the U. S. ::avy aboard a submarine.

I a.n uncertain, but it may have ceen a nuclear-powered ship.

L'nder O's direction, the compicuity, equipment recuired, and attendant cos t a o f L'n it 2 uera raduced by come fifty percant conparad

'-h P d ulta of Keo ee Uni: 1 controla.

I *iill not elaborate, but revn. Other inportant commri. sons un be cited choving the c.,at t'. sts P thm..

perrous reLOUud, Laat Ut.OLuLe turce Vet s 8 a.1 userait V A trv J Oaj ec

ver, with auf fictaat abliity to succeadully ran4p a task or pre !act.

1 performed several engine-:rin;; taaks in cddition to :9, wee desv;n through cu=ner 1971.

Appro.dcately ::ay 1971, It uas diceoverad that Oconee Unit 2 t;as not a mirror inap of Unit 1 na Rk: hai t ld the ai-:C i c vould b e 6 the PSAR, an d '. ate r. aul.d be includ:-d in - :' a T S.u.

Civil..as the least asie ted En;;inaering DU;iaion by thia c'.un;,-:, often called the "A E L seap", or "buildt u roll".

In contraat,

'.e ':::hanical Division ms rctuired to make a substantic.1 netbar of cha :a s, and the fleet t wal Division cauait'arably cara.

Several paraca; cr -

involved in the sunmar and fall, 19 n c.aking :1.33: chaag2 2

che.kint thea in Elce:rical.

Late in 1771 approniratel; six to eight persons-incluains : nif-io i c ed those alread;. involved in a thorough recheck of Cait 2 drann p.

The number of persons rapidly diuinished until only three of fc r total ucre working en Ocen+a, two part or full tim by nidwinter.

The others be3an. corking en bleva Creek and other projects.

'--- of tha errors discovarad during those chach. were ultimately ' st becauae a tajority of the drawin p narked uith corre.tions were 10.-

ar destroyed.

os t of the re: tining marked drawinga vera let

..a Desi n EngLneering :av8d to its preamt 1ccr. ior in th2 C:" = : :::

3 Trade Mar; in cunner, 1972.

PDOR ORIGINAL 1

l.j j

Ideallf, Engineering designs a systen, Construction installs and verifica thr.t all equipnent operates, notors and pumpn rotate la the proper direction, instrumenation is operable, with liaison pravidel by Field Engineering to resolve problems, and finally a systen is released or " turned over" to Steam (Operations) uith a list of those items nisa. tug, broken, etc., required to complete the syste:a.

In practice, Oconea 1 cystema uare turned over to Steam in an inconplete, and otheruise unacceptable naaner.

Steam Departt.ent nanagers suspected nany of the problems inherited were avoidable and chould be reducad to an acceptable e,uantity.

They requested the loan of one representative each fron :!echanical and Electrical Divisions to work one year onsite to perforn a special check primarily for the benefit of Steam.

This consisted of identifying all the equipnent in each systen, verifying its installation, identifying missing and/or damaged equipnent, and tabulating any such equip ent or other discrepancies.

Enginearing uould banefit from personal involvenent in chechaut and the e gerience galued.

It should also provide a neans for identifying good and bad features in their respective redus operandi.

Q was selected to represent ::echanical, and I to represent the Electrical Division.

In late February, 1972 I arrived ensite,

'th Q coning cae nanth later.

I vorhed for R, Supervisor of the Inr:

'entr ian Depart-ent.

Generall-j up:ahu,;, ".:cbanical des t;ns the procese syst2m. n.

de ten!

the evntrols necessary for operat*ca, as wellas instru.w natic-rm;a.re.:

for v.onitoring.

nhanical deteraines size, locat ion, ea:: r' 'e f ar mc h valve, pu.ap, pipe, and Lastrunent, as well as identif y i a; each !evtce.

Mte that nay iteme supplieu in a pu: chased sya ten v ill N r. :-nt ified by systens ranufactucer, s.uch as that of a nuclear ;taan <;u,,pk.

3.< ten and will thecebf acquire duplicate identificatica.

A tbtzel,1.had af identification could and frequently dil ccet.r ;t 0:ana:

Steaa attcched its 1iantification to a davice.

Vircunily ev. cy 7,m it m et Oconae ac" ired either d:uble or triple identificacion.

d

..'ter

cchinical has ase.igned i ts cw set o f id:cnti h enH ' '.: jurchue syst:rts and included enly that inent ification on 'achanic.11 d c h :s.

the hey f or relating the tua Octs is discarded.

Sem ral.

...s latar E!.ectrical nutt extract infernation t-properly E ntify act

.:stee such t'w.t the eiactrical portion of the engineeric; packag> 'rr a plant can be draNn.

At thia tire the infor-ation decired by Ster.a cust be included on the cloetrical dre Luga.

I shall give crd it */hore h tith th!s point:

Steam naw agrees to u.e tha identificativa at tr e'.ed to n ite: by Engin+ erin 3, reducing confuslan considerci;,.

Ons c < 3aly hope

. :-. of thi.,, or a similar problem, uill not be rainvented thra-@ a :

c::perience, or other.:!;e.

P00RBRER

-g-l A nuclear unit has several hundred each of process, control, and instrumentation drauings with numerous ancillary drawings, tabulations, etc.

My three assistants-part tine employees uho were engineering students at Clanson University and I catalogued the power sources, centrol equip.nant, instrumenation, and all interconnectin3 cables required for each cysten.

An inspection taan comprised of one person from T&chnical Support, one froa our group, and a construction electrician verified in:.tallation of all equipment in each systen as thoroughly as feasible usinz En;;ineering drawings for a guide.

These inspections were e::pected to occur af ter systens vera considered complete, but prior to actual turnover.

These types of errors were observed on installed equipment, l.

Inco rrect field installation which disagreed with accurate Engineering drawings.

2.

Installation per erronious drauings.

o 3.

Installation corrected by construction, but drawings remained uncorrected.

4 Elec trical terainals unidentified by equipment -anufacturar, accurate drasings, installatica operative bu: different frer drawinza because a similar contact.73 3 used instead c? ih.d ludi ated n

~

c rau tags.

5.

Unaccepta' ole installation practices upheld by -erson(a) responsible for thair avoidance.

Solatina to the above problems varied, but usually followed thia ptrern, respectively:

I 1.

The Construction el:ctrician nade minor cerrections "on the s;;ot "

Laq. problev

• quirin; con-dination wi th oti er denart ua:s ere tabulated, and appropriata per3nnnel uere provyjeg a co7,

Canacruction mah modifications, and later inspections de: err.ined the ramainin3 peablens.

2.

Technical Support contacted the design supervlaor respensth:. fe--

that s"ste, and verbally described the problea,,roposed a r,elutien, l

nad received a verbal agre-:nent to the solution; other cise :he supervi.4or sug3ested an alternate solut on.

Tech Support then initiated a variation t oti:e (VN) to aler Engineering of the chands raquired and to pcrait Construction to take t quired changas eithout waiting for revised drawings.

t P00R BREM t

}

_4_

J l

The VN contrined space to identify which units (s) uere aficeted.

If Technical Support falled to indicate all the affected units, or if Engineering failed to make the tequired changes on all affected units, it became necessary to solve the same problen repeatedly.

The latter "if" occurred profusaly because Engineering ranagers always stressed the intent to get drawings to the flaid for the unit considered most needed shile choosing to ignore all other 3.

A \\W should have been uritten to cover this situation since it involved deviating fron Engineering drawings, even if it uns required for proper syst2ms operation.

C, my Engineering supervisor, and I had several lengthy and socet tres heated discussions regarding this issue.

He contended that aay daviation should-and uould-be cover 2d via '.*::.

C philosophy uns that probleas cculd not exist in the absence of a docunented account from the field, therefore, do not attempt to make corrections unless the field conplained loudly and frequently.

y experience at Oconee led na to beli2ve that many problets and resultant changes.eere concealed forever because of insufficient documenation.

!bny such losses resultad from soneone's forgetting to notify thuan responsible fer fello'eup of problems, but I feel that a substantial ; m.ntity t. era deliberataly overlookaJ because it would have required.woneone's tire ca effort to pr., par! y Mc m.m

• tha situation.

inother explantion.eas that \\".!'s and subsequen*. drawing chan::es were boia; prccessed, but ware currently una.a11a512.

This c;nditica was acceptable end neigher caused nor resulted from tha pro.-taus situatien.

4.

This type problan became less frequent than ceveral oth2rs furing Oconee's evolution because Enginearing issued standards for tientificaticn of equipnent terminala, cable color codes, e:c.

?nve rthela o s, several drawings uerc re rised caly becausa Cen3truction lastall:d equ;; tent incoerectly, verified.systen aceratice, and lastly notifisc ~~.;tneering af the problen.

Drawings were changed rather then argue ccer :'c.e tr:blen.

5 Prior to Oconea, Duke installed little or none of tha instrurentation required in its plants.

1tn outside firn uhase specicit: was :nstrumentc;ica provided those cervices.

Oconee instrunentation *zas ins:alled b;.

persons professing sinilar experience.

I:o Duke standards e::tated regarding proper lastallaticn until well into the construction pSase of Unit 3.

The installatien at best refle: tad those principlus learned on previous projecta in a tuititude of industries.

1 applied for en.olovnent as an instrue.entation specialist in Tef.nical Rpport at Oconee.

!!e eas refused enployneat easita and contac:2.!

aone in Charlotte.

That sane son +one instruc:ed Technical M art to er ploy M ir.nedict al:..

P00R ORIGINAL

~.. -,

a 4

m

)

4 h1 undesirable situation involving M occurred frequently.

Suppose Construction has installed an instrurent such that it operates improperly.

Piping for tha instrument nay be sized improperly; it could require additional outlets for purging; the slope of the piping ::ay be insufficient.

Most iuportant in the possibility that thick-ualled piplag, capable of withstandin3 elevated te,perature and pressure in a highly radioactive endreament, has been welded, radiographad, and considered cceplete.

Wl,ardless of the nature of an instrumentation problem, Construction o en contacted M, uho issued a V'; to change any drawings in disagreenent.

httached are copies of letters and neros relating numerous problens as viewed by hay personnel respcasibla for ::anagement of Cconee duria i both construction and operational phases.

Daring my residency at Oconee i becaba acquainted with rany perseas througheat the system in capacities ranging from laborers to dapartmental supervisors.

One such person was J uho nas ecployed in Qaality Control as an inspector for a few years.

In March, 1973 he resigned to accept other employnent outside Duke's service area.

J related may incidents such as that described above involviaq M.

Other incidanta. involved ::, who uas second in Ceraand in Techn.ical Suppo/t cnd reported to !..

At the time Quality tras actually controllad b:/

T m ied Sup, ort. rm, Mies s o f co,trary cl.,ies.

7ersons in % ality rapaat2dly requasted a :.ritten list af thair dut ies frau.i. since Ma v2.bal cor.nents were undescriptiva and ganarclly useless.

Tho.: e s r.w paraens repeatedly asked for and rare refused access to 10 Cpa 30, PS.\\R, Pfla, and other documents by K.

In lata sun er,1972 I contacted T. and raquestad to vieu a cop:. of 10 CH 50 and any document describin; general duties, respensibilitics, and authority of Quality relatcd personni1.

E,

.ar i n;: the offiee spaca uith i,, ic ::ediately became indi;naat bec au:,2 anyona itoul? tche ich a r2que c,

and sunaasted I view a copy availabla in the 1taan l'epart ent.

O

=.;hu lted ti.ose documen

:s cantain only "notherhood" statencn.a m d are r.o p,eneral (v23ue3 that little i~ any treful, specific inf arr.a'.ian can ba al tained f rom them.

1 concluded that J crate.~ents uere cerr,ct, and ::

was totally taconcarned regarding the true intent of Qualit2 Centrol.

C replaced E uhen the latter was proneted.

On Septerber 26, lH2, G iscael a t.cn-iten diractive listing

he of ficial interpretation of responsibilitics for ricctrical an-astr =entation QC Inspection."

The eaclosed ccpy shows that QC is _ :ndered incapable of m n in-; a bindin; dnision and is considered to function entirely subs,ervien t to cutside groups.

This impil'4 that QC

..*as exactly Aat had been su;cpected-a spineless, paper organization ehose sole purpose m. to ncuer /EC questians.

P0nf0RDlR

4

_ (3_

mi related Realizing the situation, I contacted E, the Director of Qualit;.

functions in Dealan Caginaaring's Electrical Division.

y letter of March 21, 1973, and all documents referenced therein vero pernoaally delivered to E.

L'a also discussed ny overall irpressien of the circurstances at Oconee.

I!e suggested letting hin pursue that natter further throusdt channels and inforcing hin of any further developments.

I agreed, and contacted hin,later to detarnine the results of that information.

lie stated that the proper persons vere vorking on it.

E is presently a Quality !!anager in the Electrical Division, and reports to b, according to sources uithin Duke Pcwer Corpany presently.

Uhile vorking at Ccenee, I maintained contact uith cy supervisor and B, head of the Electrical Division.

It was orphasized repeatedly that many problees could he avoided by adequately checking drawings prior to reissue, rather thar depending upon field personnel to find errors.

I had carried narhed copies of current drawinzs to C several tibas requesting his people transfer the information enactly as shown on the narked drawings.

Rarely did that informacion return to the field correctly.

During one of his tsid-summer visits to Cconea, 3 and I discussed ny future role in the Electrical Division.

I uould bu responsible for inspecting all electrical control and instrerantation dravin2s crier to th-ir issua or reissue for field asaye at Cecnee.

'!y askiny " Dees this raan i vill have th e authority to ?,et things done, or caly the respcasibility?"

ds ansv red, "1:u

L1 !.af..

t.;h rec: :rribility and auth:rity :Ter -? Mg. -

y nnnta, o r whatever".

Upon returnit.g to the of fice Septenher 3, i?73, I wa3 given r?.atively fre, reign in inspecting and improving the dravings tsaued by tha Electrical Controls and Instrumentation Design.

I was instructed to avoid delaying an?

draving rore than ene working day, r.nd -loing anythina 5:hich could af f ?ct th e safety nnd/or operation of the plant.

For the first feu ronr.ha T uu s m r' overicaded and requested assistance which n="r arriv=d ceat for two and ena-half nan-days help on corputer inputs.

I urote 3 a letter in nid:-m rer. 1973 contalaing 14 su:eestions Mr

.u latin-and irpraving the Electrical Division.

C and I discuased that 1ctrer in Octeh.r.

During the discussica I volunteered a comrent relatin't rv ?><liags that it vos rather ebvious that et least one, perhaps several, ^erson.,vera involved in arrangeneat with. a vendor, and I e:cpressed r.7 hone that he ta.-

not invclved.

I had no conclusive proof and readily ackc'uladoed it.

How-ver..

I refud ad to f urnich nanas as he had requested, but I did eerpare the situa n

u!.th Uata tgate with possible strin:ts going tevard the top of the Ce many.

Se subject uns never again discussed between C and myself.

t!y erpicyrent uith i: uke Power ceased October 11, 1974 vith C cer nts. D concerrence, and D givin;; re a choice of resi;:ning or being fired.

I refusef to resign.

P00R ORIGINAL e

~7-

"N f

The following lists the individuals, firns, and other infornation describing the situation in which I suspect Duke Power Company's supervicors are involvtd cuch core than is acceptable in a legittate buainass relationship:

Several hundred ITE Imperial series J13P industrial control relays used in Kccuee and oconee control systems required replacenant in uhole or in part three :1res.

Those relays represented new des-irn, and vere purchased without any form of Duke testing, but with the encouragement of S, Principal Engineer uupervisor of Electrical Centrol and Instrurentation Syster.s.

I believe this was ITE's first attempt to produce such a relay.

Consider the fact that virtually all the centrols for Keouee end Oconee Unit 1 vere installed and operative during the exchanges.

It uss connon knowledge that Iarranged fishing trips for the benefit of its custoners.

n definitely exarcir,ed undue influerce and poor judgerent in selecting this particular equiprent, and possibly recaived other favors frcm ITE for their actions.

Approval for a purchase requisicion' varies depending epan the value, but it pernits considerable purchasing power at the id/els of principal and Chief Engineer, especially if the purchase is pieceneal.

Typical of this situation is the purchase of control relays, switches, and cabinets.

Larger acquisi:icns are influenced by an Engineering evaluation of the b id de rs ' facilities, quality control program, prices, and any other infornation considered necessa.

One inportant criterion is how " closely" the vendor uorked uith Duke in past centracta.

Grandf athec clauses e T fectively restrict the inclusion cf n cv senders onto approved vendor lista uhile casurin2 estchitsaad vcadors c.'

vir tual inclusion.

tuality Centroi nrocedures cad cemitrerents n e-s uy o,,-d to be rajor creas oZ conden. "ill Pouer evaluates the pac-:nce cad awar23 che contract to the succesafel bidder.

Uni: Electric of Maitland, Florida has been the cuestiennble recipient c:

several Duke contracts for building control panels, consolas, etc during the past three or four years.

Unit's first nuclear experience - as at C:onee, with little or no changes nada f rom their previous nea-nuclear povec plaat destgns.

Uni t cr.n new clain extensive experience in, ucinar 5.igns ci t 2_.:

qu2stion.

In in opinien S, E, C, nn.' T.. d cther T rinely 1 21cct-ica' r ;ineer, uith U cf 'till Pewr are deeply involved.

n The cforc entioned individuals as cell c3 othe "ngineerir : r e p re a e n ce c i ve.-

rara visiting Uni: en a Thursday 'nd Friday in ".ay or Jew,1973 :or tra purpcs" of inspecting control boards.

S,D, C, an? T vere :ct inspecting equiptent as alleged ; rather, they we re elsesbere.

Eaductu; from their invita:1en which V declined to accept and other m ple'n observations, t h e.t rerained in Florida af ter Thursday fer a combinntion fishing cnd/or boatinte excurs ton complete with faninine ccrpaaiens.

I feel it could he reasonnile to state that other " inspection " trips were equally fictic Laus.

P00RBRER

-c-J m

I V, a l' nit representative located in Charlotte, hosts S, II, C, T and U to lunch at least once each veek.

Ocasionally other persons have been invited uhen so.me of the above are absent.

U conversationa imply that the luncheon is usually non-business related.

I realize the above infomation is brief, but it is a collection of ebservations by es self and others.

So far as we know there util be no written proof anywhere as all arrangenents were surely handled in person or via telephone.

l l

1 P00RBRENR

~

)

1.:.otes of General Prchlars Observed Uhile C Oconee__

i Proble.ts observed at Oconee and discussed with E and/or C ucre numerous,

. frequent, and repetitive.

Basically, Design Engineering personnel *. ere careless in their checking of centrol drawings prior to reissuance to the fic1d, or vere conpletely ignoring the true neaning of "cheching' a drawing.

Another major problen uas Design's attitude that "any coincidence between released drawings and their usefulness to field personnel uns unintenticnal."

Many tines 1 have heard C and others in Design say the rest irportant thing is to get drawings to the field, and concern ourselves uith finding and correcting errors at some later date, i.e. drawing revision.

Each time this was expressed, it uas attributed to B initiation.

In reality, the field (construction) personnel were the ones who found and corrected the treriendous quantity of errors on each unit.

Variation notices were the nethod nos of ten used by field personnel to notify Design of errors on problens which vere solved or changed to facilitato usaga, and required a drawinz chang.e to acknowle ge thora codificacions.

I contend that acurrate drawings do not require complate and repetitive checks to asstre their correctness.

My f raquent requests for irtproving accuracy ant usefulness of drawings was essentially ignored by C and others.

Itects uith chich I diaagree in part or in uhole uith C - Sur.ner 1974.

1.

C's refusal to try to correct all_ 3rou.v.'ing n'wtcaes on dvgs, "hile bdug repeatedly cognizant of the problems in the f.ield due te poor

< s t,w

a ; n r~

. e :1 ! -.~ e n n ' ? H :, u inc a,- m - v.

'w.=.?

+ ' - n= d n

, e - u - ' - -

(1) Ve rbal, (2) Is.tter, (.0 9'tRC-60-D.

~

?.

n a spite an ab clous 2nd enpras,;ed need for ull-tine cuint.'nce

.- 'ota provided caly one hal.I vaak c.f it vi X duria? the veek prior :o 1

Christnas. 1973.

I t war, c:areins ed that co puter an:: all otS 2r 3.r a s ef string chech. uculd b e perf orced, ya t enl t'.cse relatina iractly to the cenputer ere given any checks.

3.

Merarding uj le t:er of stn*:er, l'r73 to D de f erring sena l' arau that

...o u u u. ae iastuv

,s c.it i

, waa 2 a. e one

.ga, t n the c a r.,. z

. n,,..

dic cuss ir.;; t.cs e t ieni.

Sinc 2 : hen no ether discuasior has asud,

and it is quite -bvious tha; any of the point; nentioned c ic. no nanner being acti aly improved on future stations.

l 1

P00R~0RIGINAL i

I e

j I

i J

_ ~._

Attachraent 2 v~

c.. t u.. r.,. os,

0, 7>

m Effec:ive ir.cdirtely, the foll: wing is the officiil inteip*.~tatica of the recpensibilities for Ele:trical i.nd Instrunontctica QC Ins pec-tion.

1.

The QC Inspecticn group is not directly responsible for th e c.'n-tcnts of 10C7230 or the FSAR.

All interprc aticas of these tue decur.ents sh:ll be obtcined f ro2 the Field Engineer.

2.

The accunt, cost, or tine spent on rework is not the responsibility cnd shcIl not concern QC Inspec: ion.

3.

Unless noted on prints, the serviceability of equipment installed

• is not the responsibili:- of QC Inspection.

Questions as to the serviceability or the recovel of equipment for calibratien er repair vill be submitted by Operations to Design Zagineerin3 4.

It is net the respcasibility of QC Inspection to revicv or ques-tion the design of a system er instruzen: loop.

The responsibility of QC In;pection to the Cons:ruction Depart :ent is to sec that the equipment is installed according to cpplicable prints.

The design of a sys:ca is the responsibility of Design Engta:> erin 3 n

en-

, e -

n....,.:. ;.... ;.e.

<.,. n. n..,u. a

.c,.., e..,,

---..,.,.n.,c...,,-..-.,..,~..,,we Operat ons wil. suo=:t a r-quest to usi~n unqinee rin a co ':v ec una 3

design changed.

No technical questiona vill be subni::cd to:

Construct,en iccanica, dupport or rny otner c.epar: cent.

L 5.

Ther, vill be no suggestions to field forces as to the bes: :y f

to install any equip:en:.

Dicdrepencies cay be pointed cc: to 1

field forces.

If discr:pancies are not corrceted af:2r heir; pointed out, a Random Ir ne: icn Ucrksheet should be uri::en.

6.

Obvieu3 erro rs on prints, cerails, CM d r:wir.gs, ','ariation ::o ti ces,

o. p.... u 4.. 2.. 3...w.-..

4,o.

, --- -..._=.,,.. -....-,

v--- --so...:..,...,

i--4

.r 44,

o n a

,:a,.,a,.

j 7.

The use of the RIU uill be limited as stated in paragraphs 5 and 6.

No suggesticas or requests will be noted en this for=.

t-

8. _ ny ansuers received frc= Technical Support or Design Engineerin; A

will be final and no: quastioned a second tiae.

9.

Suggestiens ray be submit:cd through acrral channels, bu: en ei: hew blank sta:icnery or co:.pany starienerj, and only per::ining :a :re i

QC progren.

10.

The issui.s of s:andards for Ccnstru:: ion and QC vill be drne b:-

Design Eng.n ering,

.-. c Tf@DMhd

~

i s,..

e A

1