ML20005F036

Requests Investigation of Telemecanique Re Possible Falsification of Certificates of Conformance

ML20005F036
Person / Time
Issue date:	02/21/1986
From:	Gilbert E NRC OFFICE OF INVESTIGATIONS (OI)
To:	Christopher R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20005F034	List: ML20005F033 ML20005F036 ML20005F038 ML20005F041 ML20005F042 ML20005F043 ML20005F048
References
FOIA-89-404 NUDOCS 9001120210
Download: ML20005F036 (33)

Text

F;;bruary 2.1, 1986 I

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l MEMORANDUM FOR:

R. Keith Christopher, Director Office of Investigations Field Office, Region I FROM:

Edward C. Gilbert, Operations Officer Office of Investigations

SUBJECT:

REQUEST FOR INVESTIGATION OF TELEMECANIQUE REGARDING THE POSSIBLE FALSIFICATION OF CERTIFICATES OF CONFORMANCE I-Please conduct an appropriate investigation pursuant to the enclosed request (with attached supporting documentation), dated February 5, 1986, from Victor Stello, Jr., Acting EDO.

Upon initiation of this investigation, please comply with the 30-day written notification procedure set forth in the ED0's memorandum of July 5, 1985.

Enclosure:

As stated cc w/o enclosure:

W.D. Hutchison i

Distribution:

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The Commissioners From:

Victor Stello, Jr.

Executive Director for Operations l

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ADVANCE NOTICE OF PROPOSED RULEMAKING " ACCEPTANCE OF Sub PRODUCTS PURCHASED FOR !JSE IN i:UCLEAR POWEp PLANT STRUCTURES, SYSTEMS AND COMPONEATS"

Purpose:

To obtain approval to publish the subject Advance Notice of Propesed Rulemaking (ANPR) for public conrnent.

The intent is to solicit public comment addressing the appropriate regulatory actions needed to assure that prnducts purchased for use in nuclear power plants will perform the functions necessary to protect the public health and safety.

BacLaround:

Recent experience has shown that some products purchased for use in nuclear power plant structures, systems and components are substandard, have falsified records or are otherwise misrepresented.

The recognition of the potential safety significance of these circumstances has led to the issuance of several NRC bulletins and information notices.

This was done to assure that licensees were informed and took actions to prevent inadequate products from being installed in nuclear power plants.

A generic letter is being prepared to inform licensees that an effective receipt inspection and testing program is considered

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necessary to enhance the probability that any product installed will perf as expected. The generic letter will also endorse processese icensees may use to dedicate connercial grade products for use in safety-related applications. The generic letter will direct licensees to certify to the Conaission that they have implemented such a program.

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i The Commissioners The Chairman notified Congressman Dingell in the response to the Congressional Subconuittee on Oversignt anc Investigations report "The Threat from Substandard Fasteners: 1s America Losing It's Grip?" that the Commission is considering publishing an ANPPfto obtain comments on enhanced receipt testing requirements at nuclear power plants.

This ANPPf atisfies that comittnent.

Discussion:

This ANP solicits public coment on a list of issues related to the procurement of products for use at nuclear power plants. The issues are posed in the form of questions. This is being done to elicit comments that may suggest the appropriate regulatory course of action.

This is the regulatory action necessary to enhance the probability that structures, systems and components installed in nuclear power plants will perform as expected. The performance expectation is that the products will perfonn their intended safety functions or that they will perform their normal functions in a manner which will avoid challenges to the plant safety systems.

c r1 ThisANPP[isstructuredtorequestcommentsontheactionsnecessary to satisfy the intent of the regulations with respect to assuring L

the quality of products to be installed in safety-related appli-cetions and for the dedication of commercial grade products to be I

installed in safety-related applications.

/1 TheANPP[alsosolicitscommentsontheendorsementofotheragency/

organization standards or programs.

The questions also solicit descriptions of alternative approacnes which may effectively provide the assurances needed for the Commission to find that the products purchased for use in nuclear power plants will perform to protect the public health and safety.

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The Commissioners..

Conclusions /

I recommend that the Cumn41ssion approve publication of the advanced Recommenda-notice of proposed rulemaling, for connent, in the Federal Register, tions The ANPR is providt:d as Enclosure A and Enclosure B contains the NRC informationnoticesandbulletinsreferencedintheAMPP/'#The generic letter is Enclosure C.

Victor Stello, Jr.

Executive Director for Operations i

Enclosures:

1. ANPR/1

2. NRC Information Notices and Bulletins

3. Generic Letter l

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NUCLEAR REGULATORY COMM15510N f

10 CFR Part 50 L

Acceptance of Products Purchased for use in huclear Power Plant Structures Systems and Components t

' AGENCY:

Nuclear Regulatory Connission.

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l ACTION: Advanced notice of proposed rulemaking.

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SUMMARY

The Nuclear Regulatory Commission (Connission) is proposing to develop i

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'.' 4 g regulations requiring enhanced receipt inspection end testing of products purchased 1

' for use in nuclear power plant structures, systems and components. These regula-h iN k gS tions are believed to be necessary to provide an acceptable level of assurance that h! products purchased for use in nuclear power plants will perform as expected to' i

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protect the public health and safety.

ecent experience ha shown that some con-hI tra tors and/or subcontracto%have provided produc'ts for use in nuclear power s

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%q plant s uctures, systems and components that are substandard, have falsified f

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i recordgora otherwise misreprese Thisexperiencelendstoreducethe confidence of th Connission that curren't ustrypracticespkvideassurance that these structures ssystems and components ually satisfy t ational quirements necessary to protect public health an'd safety.

in Advanced Notice ofPropose'dRulemaking(ANPP is intended to solicit comments on the need for additional regulatory requirements and to obtain an improved understanding of alternatives to regulatory requirements that could provide assurance that struc-tures, systems and components procured for use in nuclear power plants will per-form as expected to protect public health and safety.

1 In order to inform the public, industry and other government agencies of this proposal and to solicit timely comments as it proceeds, the Coninission is l.

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promulgating this notice and' requests coments on the merits and substance of a ne

,, glc, or other requirements or alternatives, DAT E: The coment period expires (60 days after publication).

Coments received after this date will be considered if it is practical to do so, but assuranct.

of consideration cannot be given to coments received af ter this date.

ADDRESSES: Mail coments to: The Secretary of the Comission, U.S. Nuclear Regulatory Comission, Washington, D.C.

20555, Attention:

Docketing and Service Branch.

Deliver coments to:

11555 Rockville Pike, Rockville, Maryland between 7:30 a.m.

and 4:15 p.m. Federal workdays.

Examine copies of coments received at: The NRC Public Document Room, Gelman Building, 2120 L Street, N W., Washington, D.C. A) 6SI FOR FURTHER INFORMATION CONTACT: Max J. Clausen, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission, Washington, D.C.

20555.

Telephone (301) 492-0969.

L SUPPLEMENTARY INFORMATION:

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Background

l Appendix B to 10 CFR Part 50, published in 1970 (35 FR 10498), established the l

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Quality Assurance criteria for safety-related structures, systems and components fur nuclear power plants..The purpose of the Quality Assurance criterie in Appendix B 15 to provide quality assurance requirements for the design, procure-ment, receipt inspection and testing, construction and operation of nuclear power plant structures, systems and components. The requirements of Appendix B apply to all activities during the design, construction and operating phases of nuclear power plants which affect the safety-reldted functions of such structures, systems and components. The Quality Assurance criteria of Appendix B are gener-ally structured to confirm the quality of products, designed, purchased, inspected, tested and installed for use in nuclear power plant structures, systems and com-Procedures and actions by licensees and their representatives, confom-ponents.

ing to these criteria were intended to detect substandard and poor quality pro-ducts but were not necessarily designed to detect fraud or an intent to deceive.

However, recent cases involving apparently substandard, counterfeit and fraudu-lently marketed products for nuclear power plant structures, systems and compon-ents, have prompted the Commission to reconsider the adequacy of current regula-tions for detecting counterfeit and fraudulent products and assuring that such products are not used in nuclear power plant structures, systems and components.

Criteria 111, IV and Y11 of Appendix B to 10 CFR Part 50 provide the criteria for the control of purchased structures, systems and components for nuclear power plants. Historically, licensees and their representatives have purchased i

products with certifications attesting to their quality and have used the certi-j fications as a primary basis for accepting them. However, recent discoveries of j

L counterfeit and substandard products furnished to nuclear power plants by con-l tractors and subcontractors Jenonstrate that current product acceptance prdctices, l-l

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. including those based on Sole reliance of certifications and stated catalog specifications, have not been sufficier.t in all cases.

(See NRC Compliance Bulletin No. 87-02 and Supplements 1 and ?, NRC Bulletin No. 88-05 and Supple-ments 1 and 2 NRC Bulletin No. 88-10, and NRC Information Notice Nu. 88-19, NRC Information Notice No. 88-35, NRC Infortnation Notice No. 88-46 and Supple-1 nent 1, and NRC Information Notice No. 88-48 ),

in many cases, as in part discussed in the above referenced Bulletins and Infor-mation Notices, product acceptance practices have failed to detect such counter-feit or substandard products. Therefore, the Comission is considering developing regulations or seeking other methods that will provide an acceptable level of assurance that products purchased for use in nuclear power plant structures, systens and components satisfy requirements and specifications imposed to pro-vide confidence that these items will perform as expected and required to pro-tect the public health and safety.

The Commission's regulations provide two alternative approaches to assure that structures, systems and components satisfy requirements for safety-related appli-catiuns. A licensee may procure products to the applicable Code or standard for i'

the safety-related structure, system or component.

Alternatively, the licensee may purchase a commercial grade product and then using the appropriate procedures and satisfying the Commission's requirements, dedicate the comercial grade product for the safety-related application.

Procedures to upgrade comercial I These documents are available for inspection at the Comission's Public Docu-ment Room, Gelman Building, 2120 L Street, N.W., Washington, D.C.

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. grade items for use in nuclear safety-related structure, system and component applications are discussed in the recently published Electric Power Research Institute (EPRI) Report. EPRI NP-5652, " Guideline for the Utilization of Corr.

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mercial Grade items in Nuclear Safety Related Applications (NCIG-07),"2 which YY is the subject of Commission Generic letter No. 88_.2 The experiences that pf#

have been discussed in the bulletins and information notices previously refer-enced_ apply to products which were obtained using both of the approaches men-tioned in this paragraph.

The Commission is concerned about the quality of commercial products that are.

4 used throughout the nuclear plant including applications in the " balance of plant" structures, systems and components.

This concern stems from a recogni-tion that substandard structures, systems and components may not function as designed and may challenge safety-related systems unnecessarily or complicate the response to off normal events.

Recognizing this concern cocraentors are j

requested to consider the issues and questions in this ANPRfas they may relate to the need or desirability of more prescriptive regulations or alternatively a performance based requirement for safety-related applications and applications throughout the plant.

A broad spectrum of issues need to be considered prior to deciding on the scope and content of any proposed new regulatory requirements addressing the concerns 2 This document is available for inspection at the Commission's Public Document Room, Gelman Building, 2120 L Street N.V., Washington, D.C.

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. raised by the experience discussed in the referenced bulletins and information notices. The following questions are posed to raise the issues that the Comis-i' sion has identified, and are not to be considered to be complete nor intended to bound the scope of public comnent on this ANF The questions are structured in two categories:

1. Products Procured for Use in Safety-Related Structure, Systert and Component Applications, and 2. Dedication of Comercial Grade Products for Use in Safety-Re16ted Structure System and Component Applications.

Public comments are invited on each of the questions below. Each coment should identify the question to which it responds.

1.

Products Procured for Use in Safety-Related Structure System and Compon-ent Applications.

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The questions in this section are categorized in four subsections: General, V.etallic Products, Nonmetallic Products, and Components.

1.1 General a

1.1.1 Should the Comission establish specific requirements or per-formance based type requirements to ensure that products purchased for use in nuclear power plant structures, systems and compon-ents satisfy the operational requirements necessary to protect l

public health and safety?

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1.1.2 What should the traceability requirements be for all products te be used in safety-related structures, systems and components including those procured commercial grade for subsequent upgrad.

ing to safety-related?

1.1.3 Should material traceability through all intennediary contractors.

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subcontractors and processors be required?

1.1.4 Should all critical characteristics e.g., materials, operations.

j functions, etc. be traceable?

1.1.5 Should there be any exceptions to the traceability requirements?

1.1.6 What should the requirements be for traceability, e.g., uniquely marking each part whenever possible, bagging, records, etc.?

1.1.7 Should product acceptances be restricted to inspections and tests or should product acceptances incluce, on a sample basis, destruc-tive inspections a'nd tests to verify chemical and physical characteristics?

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1.1.8 What types of inspections and tests (appropriate for the various l

types of products) should be required?

1.1.9 Should licensees, contractors and subcontractors be encouraged 1

to perform joint testing?

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!' 1.1.10 If destructive inspections and tests are determined to be necessary, whet should the samp11ng basis be (per vendor, per purchase order, per shipment, per lot, per container, etc.)?

1.1.11 Should sample plan testing be permitted for testing or should such testing be on a 100 percent basis?

1.1.12 What criteria should be used for allowing sample plan testing l

during product acceptance?

1.1.13 Should the shelf life of appropriate types of structures, systems and components be inspected and verified acceptable during pro-duct acceptances?

i 1.1.14 To what extent will an ef f ective vendor audit program and main-tenance of a qualified vendur list reduce the likelihood of ques-l tionable products being used in nuclear power plants?

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1.1.15 What are the essential elements e.g., team composition, depth of L-

_j audits, and approach that must be included in an effective vendor i

audit program?

i 1.1.16 What reinspection or reaudit frequency is appropriate to n.ain-tain confidence in those vendors on a qualified vendor list?

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t 9-1.1.17 How do licensees assure that Code Certificate holders and "N" stamp vendors are current?

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1.1.18 1s there an auditable method to demonstrate that licensees actually purchased the product from a qualified venoor, for example, a Code stamp holder certification?

1.1.19 Should negative inspection, testing, and audit results be shared with other parties?

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1.1.20 1s a ederal requirement necessary to permit this?

1.1.21 Are there restraint of trade, antitrust concerns or liabilities associated with these actions?

1.1.22 Should licensees, contractors and subcontractors be encouraged to make joint procurements and to share inspection / audit results of joint procurenents to eahance the effectiveness of inspections /

4 audits?

l 1.1.23 If joint procurements and inspections / audits are encouraged, should controls be imposed and if so, what and how should these controls be imposed?

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. 1.1.24 What'oudit and testing cocumentation should be required to provide traceability anc confidence to all participants in

-joint product acceptances?

1.1.25 Should the NRC establish and publish a' list of' approved vercors for various products?

1.1.26 If so, how should vendors be selected?

1.1.27 If an approvec list is established, who should be responsible-for maintaining this list?

1.1.28 Should licensees be restricted to making procurements from this list?

1.1.29 Should the use of a Certificate of Conformance in the procurement process either be prohibited or, if allowed, restricted to issue by the original equipment manufacturer for items that have remaineo under their direct control?

1.1.30 Should the furnishing or original manuf acturer's Certified Material Test Reports be made mandatory for procurements made of materials from intermediate endors?

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1.1.31 Should the transcribing of an original manufacturer's test 'det6 by intern,ediate vendors onto their own Certified Material Test.

Reports be forbidden?-

1.1.32 To what extent should licensees or their representatives be required to inspect the implementation of contractor product acceptance programs?

1.1.33 Should licensees be required to audit suppliers' an'd vendors' implementation of-10 CFR Part 21?

1.1.34 Should licensees be required to notify manufacturers, suppliers and vendors of licensee identified problems with vendor provided nonconforming products or programs?

1.1.35 What sort of statistical sampling during product inspection is adequate to provide confidence that the product has the requisite assurance of quality 1 1.1.36 Should licensee participation in a national data system for reporting equipment / component failures by manufacturer and application be required?

1.1.37 What are the implications of any new Commission requirements on the Commission's endorsement of the ASME Boiler and Pressure Vessel Code in 10 CFR 50,556?

3 1.1.38 What is the best way to coordinate any new requirements with the ASME Boiler and Pressure Vessel Code?

1.1.39 Should those new requirements that relate to areas covered by the ASME Boiler and Pressure Vessel Code (e.g., SA material specifi-cations)'be handled through the Code committee system?

1.1.40 To what extent should each of the above items be required for other than safety-related components?

1.2 Metallic products (e.g., f asteners, piping, pipe fittings, weld rod, castings, forgings, bar stock, plate material, stampings, wire, cable,etc.)

1.2.1 Should chemical analyses of the products be required as part of product acceptances?

1.2.2 Should these analyses be performed by destructive (wet chemistry) or by nondestructive means?

1.2.3 Should tests of mechanical properties (e.g., hardness, tensile, impact, etc.) be required as part of product acceptances?

1.2.4 Should these tests be performed by destructive (lab, bench top) or by nondestructive means?

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. 1.2.5 When destructive tests are required, are test coupons (when applicable) an acceptable source of test materials for the chemical and mechanical properties tests or.should material samples be removed from actual products?

1.3 Nonmetallic products (e.g., lubricants, tape, elastomers, seals, paints, filters,etc.)

1.3.1 Should chemical analyses be required for lubricants, tape, elastomers, etc. during product acceptances?

1.3.2 Should these analyses be performed by destructive (wet chemistry) a or by' nondestructive means?

1.3.3 Should physical property tests (e.g., viscosity for lubricants, hardness for elastomers, efficiency for filters, etc.) be required during product acceptances?

1.4 Components (e.g., pumps,. valves, circuit breakers, controllers, electronic parts / assemblies and their replacement parts) 1.4.1 Should components be subjected to functional tests during product acceptance?

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. 1.4.2 Should components be disassembled, if necessary during product acceptance, to verify dimensional' char 6cteristics?

1.4.3 If not, what methods should be utilized to verify these characteristics?

1,4.4 Should'the chemical and physical properties of component materials be analyzed during product-acceptance inspections?

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1.4 so, what means should be utilized?

.2.

Dedication of Comercial Grade Products for Use in Safety-Related Structure.

System ano Component Applications The questions in this section are categorizeo in five subsections: General, Metallic Products, Nonmetallic Products, Components, and Others.

2.1 General 2.1.1 Should the Comission establish specific requirements or per-forraance based type requirements to ensure that comercial grade products being dedicated for use in safety-related nuclear power plant structures, systems and components satisfy the operational requirements necessary to protect public health and safety?

i 2.1.2 Should NRC regulations be revised to endorse and incorporate by reference, industry codes, standards,- or guidance documents for dedication programs of commercial grade products for use in safety-related structure, system and component applications?

2.1.3 What shuuld the traceability requirements be for all comercial products being upgraded for use in safety-related structures, systems and components?

1 2.1.4 Shoulo material traceability through all intermediary contractors, subcontractors and processors be required?

2.1.5 If item traceability is necessary, should there be any provisions for upgrading products whose traceability cannot be established?

i 2.1.6 If so, what should those provisions include?

2.1.7 Should the upgrading provisions be any different if the products l

are heet/ lot identified or not?

2.1.8 K' hat should the requirements be for traceability, e.g., marking, bagging, records?

2.1.9 Shuuld products intended for use in applications where products are normally required to meet a specific standard be inspected to verify that all critical characteristics are met?

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2.1.10 Should.the shelf life of appropriate types of products be inspected and verified acceptable as part of the upgrade inspec-tion process?

l 2.1.11 What types of shelf life controls should be imposed on products which are being upgraded for use.in s6fety-related structures, systems and components?

i 2.1.12 Should all upgrade inspections be restricted to inspections and i

tests or should they include, on a sample basis, destructive f

I inspections and tests to verify chemical and physical j

characteristics?

2.1.13 What types-of inspections and tests (appropriate for the various types of products) should be required?

l 2.1.14 Should inspections verify all critical characteristics (e.g.,

j chemistry, physical properties, dimensions, special processes, etc.)?

2.1.15 If destructive inspections and tests are determined to be necessary, 4

how should samples be selected if products are heat / lot identified?

2.1.16 How should samples be selected if products are not heat / lot identified?

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, 2.1.17 Should sample plan testing be permitted for nondestructive test-ing or should such testing be on a 100 percent basis?

2.1.18 What criteria should be useo for allowing sample plan testing during upgrade inspection?-

2.2 V.etallic Products 2.2.1 Should chemical analyses of the products be required as part of-upgrade inspections?

2.2.2 Should these analyses be performed by destructive (wet chemistry) or by nondestructive means?

2.2.3 Should tests of mechanical properties (e.g., hardness, tensile, impact, etc.) be required as part of upgrade inspections?

2.2.4 Should these tests be performed by destructive (lab, bench top) or by nondestructive means?

2.2.5 If heat / lot traceable, is sample inspection (destrur.tive and nondestructive) adequate for confirmation of critical characteristics?

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1 2.'2.6 If not heat / lot traceable, should products be either sample or-100 percent tested (e.g., haroness) to establish uniformity And then destructively analyzed (e.g., chemical analyses, tensile tested. impact tested, etc.) to deterir.ine acceptability?

2.2.7 Should requirements in addition to these' included-in industry standards-(e.g., additional samples, etc.) be required?

2.2.8 When destructive tests are required, are test coupons (when avail-able) an acceptable source of test materials for chemical ano l

mechanical properties tests or should material samples.be removed-from actual products?

2.3 Nonmetallic Products 2.3.1 Should chemical analyses be required for lubricants, tape, elastomers, etc., proposed for upgreding for use in safety-relateo systems?

2.3.2 Should these analyses be performed by destructive (wet chemistry) or by nondestructive means?

2.3.3 Should physical property tests (e.g., viscosity for lubricants, hardness for clastomers, efficiency for filters, etc.) be required?

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2.3.4 Should critical characteristics be sample inspected or-should 100 percent inspection of. these characteristics be. requireci c+

2.4 Components v.

2.4.1 Should each ' critical characteristic be inspected before accept-anCe for use.in safety-related. systems?

s 2.4 2 Should the_ chemical and physical properties of component materials be analyzed during upgrade inspections?

.2.4.3 Where critical characteristics cannot be inspected on each piece,.should it be acceptable to establish heat / lot trace-dbility, establish uniformity of lot by sample inspection and thereby accept lot?

2.4.4 Should components be subjected to functional tests on a sampling basis or should they be 100 percent functionally tested?

2.4.5 If sample inspected, what should be the basis of performing only semple inspection?

2.4.6 Should components be disassembled, if necessary, to verify critical dimensional characteristics?

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2.4.7 Should this be done on a sampling basis = or should 100 percent inspections be required?

2.4.8 What should the basis be for performing only sample inspections?-

l 2.4.9 If components are not disassembied to verify dimensions, what-methods should be utilized to verify dimensions?

2.5-Other Questions 2.5.1 Are there any other agency / organization standards or programs that should be adopted for use in upgrading commercial grade products for use in safety-related systems?

2.5.2 Should these standards or programs be endorsed by. NRC regulations?

2.5.3 Are there other alternatives which could provide the r.ecessary assurances?

LIST OF SUBJECTS IN 10 CFR PART 50 Antitrust, Classified information Fire protection, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radia-tion protection, Reactor siting criteria, and Reporting and recordkeeping requirements.

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The authority citation for.this document is:

Sec.163, Pub.L.83-703,68 Stat.

948~, as amendeo (42 U.S.C. 2201); Sec. 201, Pub. L.93-438, 88 Stat. 1242, as,-

amended (42U.S.C.5841).

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i IsnC (Ones q UJ. NUCLEAR I.51ULATEGY COMMl210N INVESTIGATION STATUS RECORD pG,. 3 881STRUCT60NS: This form is to be completed wherever stificent activity hos occurred reistive to e case or et least ewry 30 days. If no change hos occurred during the 30 day reporting period. Indicate "No Ownes" in the status t@ek. Keep the originet with the case file end send one copy to Headquarters, Office of Innstigstions.

CASE NVetstm CATt00RY OF FICE O. 0PGRATING RE ACTOR I

• INDIVIDUAL LICEN$tt Q 1-86-005 c gg,oJaga

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" c' TELEMECANIQUE/ SUSPECTED FALSIFICATION OF Jerome A. Cullings CERTIFICATIONS OF CONFORMANCE (C0C) FOR MOTOR STATUS ($pecHy date. erdprovide e bnief dancr@tiert)

SUBJECT:

(con'd):

CONTROL CENTER (MCC) SUPPLIED TO VARIOUS NUCLEAR POWER STATIONS October 31, 1987:

Continued review of documents / notes.

ECD is November 1987.

1 Nu b 'tl November 30, 1987:

Continued review of documents / notes.

ECD is December 1987.

,,[ s December 31, 1987: No change fro th previous reporting period.

ECD is January 1988.

-January 31, 1988:

Case being downgraded anticipation of administrative closing.

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ECD is February 1988.

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February 29, 1988:

Case closed administratively and issued on February 12, 1988.

PRIORITY - normal lower l

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18tC FORM 305 UA NUCLEAR MEOULATORY C0884t886086 ' T 7~,

INVESTIGATION STATUS RECORD PG. 2

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INSTRUCTIOedS: This bem is to be completed wherwar s$ificent activity hee occurred reistime to e esse er et least every 30 deys. If no changs has occurred during the 30 day to pe

, indieste "No Change" in the status block. Keep the origina4 with the mes file end send one copy to Headquarters, CASE NUwetR CATt00 sty Of f tCE ji o. 0PERAT18s0 REACTOR 1 *188DIVIOVAt UCENSIE 1-86-005 v.g,oja,ga

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• vo'c' TELEMECANIQUE/ SUSPECTED FALSIFICATION OF Jerome A. Cullings CERTIFICATES OF CONFORMANCE (C0C) FOR MOTOR STATUS (Specl/r defe, erNf provide # brief duurrption)

SUBJECT:

(con'd):

CONTROL' CENTERS (MCC) SUPPLIED TO VARIOUS NUCLEAR POWER STATIONS January 31, 1987:

No investigative acti)(ity ue to higher case load priorities.

ECD is October 1987. \\

February 28, 1987:

Investigation reassigned to Jerry Cullings.

Investigation will commence week of March 1, 1987.

ECD is October 1987. g March 31, 1987:

Interviewed VIB inspection and SNH/UE&C personnel who had pertinent information relating to allegations against Telemecanique.

VIB Inspector Kamal Naidu (FTS 492-8340); SNH/UE&C Dave Lambert (609-474-9521 ext. 2160)and Ralph Branscord(ext. 2054 or3049).

ECDisOctober1987.p April 30, 1987:

No investigative activity due to higher case load priorities.

ECD is October 1987.

May 31, 1987:

No investigative act; i y due to higher case load priorities.

ECD is October 1987.

June 30, 1987:

No change from the previous month.

July 31, 1987: Nochangefromthepreviousmonth.b August 31, 1987:

No change from the previous month.

September 30, 1987:

Reviewed request and documents / notes.

ECD is November 1987.

f / / /' - /

ZRC F04ed SW -

U.S.19UCLEAR ESOULATORY connessacei INVESTIGATION STATUS RECORD MUCTIOe 8 This term is to be semp6eted sehenever siyWfloont activtry has escurred seistles to a esse er et least every 30 deys. If no chenge has occurred during the 30 day reporting period, kuisaste "Dio Change" in the status baoek. Keep the original ertth the coor flee and seruf one copy to Hee $ quarters.

Offeos of lavestegotions.

Call NVAdeER CATEGOny OF FICE O OPERAflNO REACTOR e.sesoay DUAL LectastEt 1-86-005 H v.gya 01:RI e.

,,,,,,y,,,,,, un ve=oon x.or en aa ' * * '

Unassigned 8v**c' TELEMECANIQUE/ SUSPECTED FALSIFICATION OF CERTIFICATES OF CONFORMANCE (C00) FOR MOTOR STATUS (Specify serve, aruf revndr a bref descrpelon)

SUBJECT (con'd):

CONTROL CENTERS (MCC) SUPPLIED TO VARIOUS NUCLEAR POWER STATIONS March 3, 1986: As a result of a November 1984 Vendor Inspection Branch inspection, infornation was developed indicating that the captioned facility M2^c supplied defective MCCs (and other components) to various nuclear power stations with falsified C0Cs, which certified that inspections and tests were performqd a the MCCs were free from defects.

10 CFR, Part 21 applies.

ECD is unknown g $

March 31, 1986:

Investigation assigned to Matakas.

No activity due to gher case load priorities.

ECD is September, 1986.

April 30,1986:

No investigative activity due to higher case load priorities.

ECD is September 1986.

May 31, 1986:

No investigative activity due to higher case load priorities.

ECD is September 1986.

June 30, 1986:

No investigative activity due to higher case load priorities.

ECD is September 1986.

July 31, 1986:

No investigative activity due to higher case load priorities.

ECD is September 1986.

August 31, 1986:

No investigative activity due to higher case load priorities.

ECD is March 1987. Consideration will be given to reassignment when resources become available.

September 30, 1986: No investigative activity due to higher case load priorities.

i-l ECD is March 1987.

October 31, 1986: No investigative activity due to higher case load priorities.

ECD is March 1987.

l l

November 30, 1986:

No investigative activity due to higher case load priorities.

ECD is March 1987.

December 31, 1986:

No investigative ac ivity due to higher case load priorities.

l ECD is March 1987.

g

,'/.

T0r Victsr Stello, Jr.

Acting Executive Director U.f,. l '.'l0 for Operatio'ns FROM:

Chester W. White, Director

I I l 0 I Office of Investigations Field Office, Region 1,

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' REGION REQUEST NO.: IE-86-02 DATE OF REQUEST: 2/5/86 Licensee / Vendor / Applicant:

Telemecanique Facility or Site Location Westminster, MD 21157 Docket No.

99901011 License No.

N/A I

X CASE INITIATED CASE NO.

1-86-005 Date Opened 3/3/86 TYPE OF CASE: I l

Assist (A)

Inquiri(Q)

ECD Sept. 1986 Investigation (I) l Case Priority High l__l XX Nonnal gow CASE NOT INITIATED:

REASON:

COMMENTS: September 1986 ECD due to other high priority case commitments.

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TELECDPY Nt2GLER:

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.l-STIGAT1YE. WORK PLAN (3.3.4. 01 iual)

CASE NUMBER: l-86-005 DATE PREPARED: J - //- gg

SUBJECT:

Telemecanique/ Suspected Falsification)NVESTIGATOR: / jf. //fggjJ of. Certificates of Conformance for

. Motor Control Centers Supplied to Various Nuc1 car Power Stations ID NRC VIOLATIONS: g g gj j.

I PROPOSED INTERVIEWS: N/ 4 Jjt/>ftercEl f N

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photos, surveillance, prints, etc.

t 00 NOT DISCLOSE I

l This document may contain information exempt froir public disclosure.

/

7

Ct!RONkUGibAk. RECORD OF" INQUIRY' OR lNVEdilGA110N j

CASE NO.: 1-86-005 OPENED: 3/3/86 CLOSED:

StJBJECT:

Telemecanique/ Suspected falsification of Certificates of Conformance for Motor Control Centers Supplied to Various Nuclear Power Stations DATE:

ACTIVITY:

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CifRONOLO..AL'RECO'RD'0F INQ(IIRY OR 'NVEST.

TION A

4 CASE NO.:

1-86-005 OPENED: 3/3/86 CLOSED:

SilBJECT:

.Telemecanique/ Suspected Falsification of Certificates of Conformance for Motor Control Centers Supplied to Various Nuclear Power Stations DATE:

ACTIVITY-if,lglf 7 wA a)/ M f

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