ML20033H165

Investigation Rept 4-88-018.Noncompliances Noted.Major Areas Investigated:False Certificates of Conformance

ML20033H165
Person / Time
Issue date:	11/23/1988
From:	Driskill D, Hayes B, Van Cleave V NRC OFFICE OF INVESTIGATIONS (OI)
To:
References
REF-QA-99901101 4-88-018, 4-88-18, NUDOCS 9004180316
Download: ML20033H165 (35)

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Title:

PLANNED MAINTENANCE SYSTEMS:

F/LSIFICATION OF PRODUCT CERTIFICATIONS i

Licensee:

Case No.: 4-8B-018 j

Planned Maintenance Systems Report Date: November 23, 1988 1002-4 Main Street Mt. Vernon, IL 62864 Control Office: 01:RIV Docket No.: 99901101 Status:

CLOSED Reported by:

Reviewed by:

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0 Virginia ven cleave, Investigator Donald D. Driskill, Director Office of Investigations Office of Investigations Field Office, Region IV Field Office, Region IV Participating Personnel:

Approved by:

1 Joseph Petrosino, Inspector NRC Vendot :: ranch

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Donald D. Driskill Director

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0 i MENN C

Terrence Tinkel, Brookhaven Labs Ben W Hayes, Director

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Kenneth Sullivan, Brookhaven Labs Offic6 of Investigations v

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l WARNING The attached document / report has not been reviewed purso.nt to 10 CFR 12.790(a) exemptions nor has any exempt material been celeted.

Do not disseminate or discuss its contents outside NRC.

Treat as "0FFICIAL USE DNLY."

Copy 3 of 9

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Case No. 4-88-018 2

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v SYNOPSIS In April 1988, the Nuclear Regulatory Comission (NRC), Reoi an investigation of Planned Maintenance Systems, Inc. (PMS) on IV, requested to detemine if companyofficialsexecutedfalseCertificatesofConformance(CofC)to represent comercial grade items as nuclear grade items and then failed to 4

provide notice to the NRC as required by 10 CFR, Part 21.21.

The Office of Investigations (01) investigation determined that the owner of PMS knowingly and intentionally. prepared false C of Cs both on PMS and on third party suppliers' letterhead in order to certify what he knew to be commercial grade items as nuclear grede items.

PMS issued C of Cs falsely representing products as meeting Institute of Electrical and Electronics Engineers (IEEE) IEEE-323 and IEEE-344 standards in response to nuclear industry customers who imposed these requirements on their purchase orders to PMS. The PMS C of Cs additionally falsely reflect PMS compliance with 10 CFR, Part 21.

The owner of PMS initially made false statements to the OI investigator by saying that three C of Cs prepared on Westinghouse letterheads were received by PMS from their suppliers.

He subsequently admitted that he prepared the three C of Cs to make it appear that these products were nuclear grade items when he knew they were comercial grade items and,-as such, did not meet requirements for Class IE nuclear grade items as specified in purchase orders provided to PMS by the nuclear industry. Although the owner of PMS knew he was providing items to NRC licensees which deviated from the technical requirements included in procurement documents, he intentionally failed to notify the NRC or the purchasers about these deviations as required by 10 CFR, Part 21.21.

I Case No. 4-88-018 1

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ACCOLINTABILITY -

l The following portions of this Report'of Investigation.(Case No. 4-88-018)'

jl will not be included in the material placed in the PDR.~ They consist of pages~

2.through 34.

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TABLE OF CONTENTS

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Page SYN 0PSIS.............................................................

1 ACCOUNTABILITY.......................................................

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APPLICABLE REGULATIONS...............................................

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DETAILS OF INVESTIGATION.............................................

9

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Purpose of Investigation........................................

9 Background......................................................

9 Interview with Roger K. RILEY, Acting Quality Assurance (QA)

Meneger -Planned Maintenance Systems (PMS).....................

9 Interview with Karla BOLDREY, Secretary, PMS....................

10 Interview with C. E. (Chuck) BURKARTH, Sales Manager, National Electric Service Company (NES).................................

11 Interview with Rodney C. HANNER, President, PMS.................

11 Re-interview with Roger K.

RILEY................................

'3 Interview with Thomas J. SHEA, Branch Manager, Wesco............

13 Re-interview with Rodney C.

HANNER..............................

14 Ir.terview with Billie Edward ROBERTS, II, Fomer QA Manager, PMS 17 Interview with Gerald MAYS, $ ales Representative, Fairmont Supply Company (Fairmont)......................................

18 Re-interviews with Roger K.

RILEY...............................

16 Interview with Larry ERWIN, Field Salesperson, Westinghouse Electric Corporation (Westinghouse)............................

19 Interview with Dorothy (Crompton)................................

STIEBER, Accounts Representative, Crompton Instruments 19 Interview with Tony PITT, Product Manager, Crompton.............

19 Interview with Gary W. CAMPBELL, Manager for Total Quality, Relay Telecommunications Division Westinghouse................

20-Interview with Donald WHITTAKER, Distribution Center Manager, Westinghouse...................................................

22 Interview with Gary KLANN, Manager of Nuclear Qualification Division, Westinghouse.........................................

22

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Interview with William JOACHIM, Manufacturing Engineer, Westinghouse...................................................

22 Interview with Michael F. DORMAN, Plant Manager, Weschler.......

23 luterview with Mark O'KEEFE, QA Technician, Weschler.............

24 i

Interview with Dick BAKER, Electrical Engineer, Rochester Gas r

a nd E l e c t ri c ( RG & E )............................................

24 Re-i ntervi ew with Rodney C. HANNER..............................

25 4

Re-i ntervi ew wi th Roge r K. RI LEY................................

26 Documentation Analysis..........................................

27 Wi 11 f u l nes s / I n te n t..............................................

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Ag en t ' s Conc l u s i on..............................................

31 LIST OF-EXHIBITS.....................................................

33 l

Case No. 4-88-018.

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i Case No. 4-88-018 8

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APPLICABLE REGULATIONS l

Allegation: Falsification of Product Certification

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i 10 CFR, Part 21.21:

Notification of Failure to Comply or Existence of a Defect j

Title 42 USC, Section 2201(o) (Atomic Energy Act of 1954. Chtpter 14 Section161):

Required Reports Title 42USC,Section2273(a)(AtomicEnergyActof1954, Chapter 18 Section223): Violation of Sections Generally Title 42USC,Section2273(b)(AtomicEnergyActof1954. Chapter 18 Section223):

Violation of Sections - Construction or Supply of Components for Utilization Facilities i

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Case No. 4-88-018 7

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According to RILEY, HANNER was currently at Wyle Labs and was unavailable for questioning.

RILEY stated that HANNER took the order for fuses from WCNOC l

with him and a copy was not available for review at PMS.

RILEY said he was unaware of the circumstances surrounding this order.

However, he recalled i

that HANNER ordered the fuses from NES.

RILEY stated that PMS' basis for upgrading these comercial grade fuses to nuclear grade was a seismic test perfomed by Wyle Labs in 1986 in conjunction with an order. by Tennessee Valley Authority (TVA) for similar fuses.

RILEY conceded that the fuses ordered by TVA in 1986 were 15 amp fuses, not 20 amp fuses as ordered by WCN00. However, RILEY claimed the fuses were all manufactured by Gould and were of similar generic type.

RILEY conceded that, although PMS had a copy of the Gould report written in 1980 concerning Gould fuses, no one at PMS had i

contacted Gould to detemine if the manufacturing process and materials utilized for the fuses ordered in 1988 were identical to those for.the fuses ordered and tested in 1986.

Consequently, RILEY admitted that he did not know if anything had changed in the Gould manufacturing process from 1986 to 1988.

RILEY stated he had no knowledge of any problems concerning this WCNOC order.

He said that HANNER had recently told him there was a problem with the WCNOC C of.C, but HANNER hed not provided him with any specific information. RILEY asserted that he was unaware of any problems at PMS concerning possibly improper testing of equipment to Class IE standards or the company's comp-11ancewiththeAmericanNationalStandardsInstitute(ANSI)forthecontrol of items for use in nuclear power plants.

INVESTIGATOR'S NOTE:

Investigators presented RILEY with an 01 subpoena (Exhibit 3) for all PMS records related to sales to the nuclear industry.

RILEY subsequently contacted HANNER at Wyle Labs.

HANNER, according to RlLEY, said he had the WCNOC file with him and that he would return to Mount Vernon and make all remaining files available to NRC investigators on April 5,1988.

+

interview with Karla BOLDREY, Secretary, PMS BOLDREY was interviewed by Investigator Van Cleave on March 31, 1988, at her office at PMS, Mount Vernon, IL (Exhibit 4). BOLDREY stated she had been employed at PMS as secretary since the beginning of 1988..According to BOLDREY, prior to that time PMS utilized temporary office help and when she arrived, company records were in total disarray.

She stated she had little knowledge concerning the business, but HANNER was the primary individual-responsible for PMS.

BOLDREY recalled that on March "O, 1988, HANNER and RILEY held numerous telephone conversations with Wu,0C officials.

BOLDREY stated that on that afternoon. HANNER told her to " hide that' file and gestured toward the WCNOC file (WC-1109) which was on top of his desk.

BOLDREY said she was certain he was not serious, but when she later looked for the file it was gone. BOLDREY stated she had no additional information to provide to the investigator, and she was unaware of any alteration of any records or any false documents in the PMS files.

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Case No. 4-88-018 10 7.,%,-

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a DETAILS OF INVESTIGATION

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Purpose of Investigation This investigation was initiated to detemine whether company officials at Planned Maintenance Systems (PMS), Mount Vernon, Illinois, executed false Certificates of Conformance (C of C) representing comercial grade items as.

nuclear grade items. A-secondary purpose was to determine if the president of PMS intentionally failed to provide notice f.9 the Nuclear Regulatory Comission (NRC) as required by 10 CFR, Part 21.21.

Background

On February 3,1988, Wolf Creek Nuclear Operating Corporation (WCNOC), an NRC licensee, placed an order.with PMS for 60 nuclear grade fuses and the appro-priate C of C.

An audit of PMS was conducted by WCNOC on March 18, 1988, following receipt of the fuses.

During the course of the audit WCNOC's auditor was presented with a Gould, Inc. (Gould) C of C certifying these fuses to nuclear grade. The auditor became suspicious that the C of C was a false document due to what appeared to be different type styles on the certificate as well as the appearance of " white out" in certain areas of the certificate.

The auditor requested a copy of this C cf C from Rodney HANNER, President of r

PMS, who purportedly refused to provide a copy of the document. 'The auditor subsequently contacted Gould and discovered that-comercial grade fuses had beenshippedtoPMSthroughNationalElectricServiceCompany(NES),

St. Louis, M0.

These fuses were then sold by PMS'to WCNOC as nuclear grade fuses. On April 5, 1988, the NRC Region IV Regional Administrator requested an Office of Investigations (01) investigation of PMS to detemine if company e

officials created false C of Cs to enable them to sell comercial grade items as nuclear grade items and subsequently failed to provide to the NRC a notice as required by 10 CFR,.Part 21.21 (Exhibit 1).

Interview with Rocer K. RILEY, Acting Quality Assurance (0A) Manager, PMS l

RlLEY was interviewed by Investigators Virginia Van Cleave and D. D. Driskill i

on March 31 and April 1, 1988 at his office at PMS, 1002-4 Main Street, MountVernon,IL(Exhibit 2).

RILEY stated that he had been employed by PMS since the company's inception in 1985 and had held his current position for approximately three months. He said the previous QA Manager was William E. ROBERTS.

RILEY stated that while ROBERTS was the QA Manager, he (RILEY)wasemployedastheengineerforPMSalthough'hedidnotholda i

college degree in engineering, i

RILEY stated that PMS purchased comercial grade items which they subsequently upgraded to meet nuclear grade specifications on each individual purchase-order (PO). According to RILEY, seismic testing was performed by Wyle Labora-tories (Wyle Labs) at Huntsville, AL and radiation. testing was perfomed by i

Radiation Sterilizers in Schaumburg, IL. RILEY further stated that occasion-ally PMS utilized other companies' test data in order to upgrade a similar commercial grade item to appropriate P0 specifications.

RILEY said that PMS prepared and provided its own C of C to its customer and did not provide applicable test data unless it was required by the P0.

Case No. 4-88-018 9

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Labs. HANNER said that they had subsequently sold similar fuses to TVA without qualifying the additional purchases.

i HANNER stated that he handled every sales quotation himself, assigned a number I

i to a file when PMS received a request for quotation, but did not maintain a logbook of file numbers.

HANNER stated that PMS retained every contract granted to them but might have discarded quotes and documents associated with quotes if the company did not receive the contract.

~

HANNER stated that PMS based their qualification and preparation of the C of C for 60 fuses ordered by WCNOC in 1988 on a previous test perfomed by Wyle Labs on similar fuses which PMS had purchased for TVA in 1986 (PMSP0TV-1043).

HANNER admitted that these tests were for 15 amp fuses purchased in 1986 and the fuses purchased for WCNOC were 20 amps. However, he claimed they were all manufactured by Gould, had the same: series -and were essentially the same product. HANNER said he had only. superficially " glanced at" the 1980 Gould report which he had obtained from WCNOC and which was referenced in their P0 to PMS. HANNER admitted that he could not be certain that Gould's manufacture of these fuses had not changed since he obtained the fuses for TVA in 1986 and further admitted that the fuses could.not have come from the same manufacturing lot since they were different amps. HANNER said.

that prior to a WCNOC audit conducted by Bob POTTER on March 18, 1988 PMS had shipped these fuses to WCNOC along with a C of C prepared by.PMS and dated February 15, 1968.

HANNER stated that during the audit or surveillance conducted by POTTER, he provided POTTER with the WCNOC file as well as several other files which POTTER asked to review. According to HANNER, POTTER said he was completely satisfied with PMS and "the way we handled our business."

HANNER stated that when POTTER requested documentation to substantiate PMS' C of C, HANNER showed him the Wyle test report from 1986 and PMS' qualification by similarity for the fuses.

HANNER claimed that POTTER did not ask for any documentation prior to leaving PMS, but he telephoned HANNER later and asked for a copy of a Gould C of C.

HANNER claimed that when POTTER requested the Gould C of C, POTTER meant the Gould report.

However, HANNER stated that WCNOC officials were "hardnosed and demanding" and, consequently, he refused to provide the requested documentation to them.

HANNER said PMS had received only one C of C from Gould and that was associated with P0 file TV-1043. HANNER stated that he had-never sent a i

written P0 to NES and that he >1 aced all orders to NES by telephone. After reviewing the P0 on PMS letterlead dated February 7, 1988, addressed to NES and purporting to refer to the WCNOC fuse order HANNER said this was only an internal de:ument and had never been sent to NES.

HANNER further admitted that PMS did not request a C of C from NES regarding this order, and he was unable to explain why the PO which allegedly had been prepared for internal purposes mentioned a C of C.

HANNER subsequently admitted that he prepared this PO for POTTER's benefit because " typically they don't like verbal purchase orders."

t Upon further questioning by the investigator. HANNER admitted to removing a Gould comercial grade C of C from PMS' files and "dumying it up" for POTTER's benefit to make it appear to certify the fuses to nuclear grade.

HANNER claimed he did not believe it would matter if he altered the Gould C of C.

He also admitted to preparing and backdating PMS' internal P0 to NES "just to clean up the files." HANNER atte 4 ed to justify his actions by Case No. 4-88-018.

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Interview with C. E. (Chuck) BURKARTH, Sales Manacer, National Electric Service Company (NES)

BURKARTH was interviewed by Investigator Van Cleave on April 5,1988, at his I

officeatNES,St. Louis,MO(Exhibit 5).

BURKARTH stated that as Sales Manager for NES, he reviewed all sales prior to shipment. BURKARTH said that l

PMS had purchased itemsi including fuses and other components, from NES since i

1986.

In 1986 PMS had an outstanding debt owed to NES and did not place any orders with NES for over one year.

In 1988, according to BURKARTH, PMS paid the overdue amount to NES and again began placing orders with the company.

j BURKARTH said that NES required that all orders from PMS be C.O.D.

According i

to BURKARTH, he had never received a written PO from PMS. He said all orders were placed by HANNER to NES over the telephone. Upon reviewing a copy of a l

PO which the investigator had obtained from PMS purportedly.sent to NES on i

February 7, 1988, BURKARTH asserted that he had never seen that P0 or any.

other PO from PMS.

BURKARTH stated that approximately 7'to 10 days ago, HANNER telephoned him and told him that he (HANNER) had previously requested a C of C when he placed an order with NES for Gould comercial fuses in February 1988, but that he had never received the requested C of C from NES.

BURKARTH stated that he told hat!NER that HANNER had not requested such a C of C and that was why NES had not provided one to him.

BURKARTH told the investigator that PMS had requested.a C of C on only one occasion.

This was associated with the purchase of over 1,000 comercial fuses in 1986 and the C of C in question certified the fuses only to comercial grade quality.

BURKARTH showed the investigator a log in which he said he. recorded every order including requests i

for a C of C.

The log did not indicate that HANNER requested a C of C when he placed his order with NES for 60 fuses on February 3, 1988. BURKARTH stated

?

that in 1988, HANNER. occasionally requested that NES send him one item out of a particular order for PMS' use for testing purposes, but BURKARTH said he was unaware of the type of testing conducted by PMS.

INVESTIGATOR'S NOTE: The investigator obtained copies of all sales invoices and C of Cs provided to PMS by NES, as well as a copy of the page of BURKARTH's log dated 2/3/88.

Interview with Rodney C. HANNER, President, PMS HANNER was interviewed by NRC Investigator Van Cleave on April 6,1988, at PMS,MountVernon,IL(Exhibit 6).

HANNER stated that he began PMS in 1985 upon leaving Nuthenn, a similar company also located in Mount Vernon which he had previously started. HANNER stated that he was the president of PMS and held a bachelor's degree in engineering.

However, he admitted that he had never completed the master's degree as shown on his resume. HANNER stated that he RILEY, and ROBERTS began working at PMS together. Although PMS had some work in 1986, they received few contracts in 1987 but in 1988 business s

improved. HANNER said PMS purchased comercial grade products, bought one extra of every product and had that extra item tested to meet the specifica-tions cited in the customer's P0.

HANNER stated that Wyle Labs and Radiation Sterilization, Inc, conducted all testing for PMS. HANNER stated that occasionally PMS purchased previously qualified items and qualified them by.

similarity. As an example, HANNER stated that PMS had an indefinite quantity contract with TVA for fuses which they initially had tested in 1986 by Wyle Case No. 4-88-018.

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1986.

SHEA said the P0 originally was for sleeve bearings and AR440 relays, but the order for the bearings was cancelled by HANNER. SHEA stated that although the PO from PMS requested a C of C. Wesco's policy was to ignore that i

type of request. SHEA said Wesco's charter stated that Wesco may not sell any i

nuclear grade products. All nuclear grade sales of Westinghouse products must go through the Pittsburgh, PA division.

SHEA stated that he had never dealt with any representative of PMS, and that Danny DIETRICH was the outside sales representative responsible for handling PMS' account.

INVESTIGATOR'S NOTE:

Investigator Van Cleave spoke briefly with DIETRICH who stated that PMS had received only one order from Wesco in St. Louis.

This was the order dated December 1986 for the 20 relays.

Upon reviewing the copy of a PMS PO which Inspector Petrosino had obtained t

from Sacramento Municipal Utility District (SMUD), SHEA said he had never receivea that PO which was #P-121286-1. SHEA also reviewed a copy of the C of C from SMUD's file pertaining to the order for 20 relays in December 1986 and purporting to come from Westinghouse Power. SHEA stated he had never seen the C of C, did not know an I CROWE (whose signature appears on the C of C) in QA for Wesco, and reiterated that Wesco had never supplied this C of C or any other C of C to PMS.

1 Re-interview with Rodney C. HANNER From May 9 to May 12, 1988, the NRC Vendor Branch, accompanied by Investigator Van Cleave, conducted a vendor inspection at PMS.

During the course of the inspection,HANNERrelayedthefollowinginformation(Exhibit 11).

On May 9, 1988 HANNER stated that RILEY was on a leave of absence and BOLDREY was working part-time because PMS' business was almost at a standstill.

l HANNER stated that although Revision 2 of PMS' QA Manual had been written to TVA specifications, it had not been approved and PMS was utilizing Revision 1 of their QA Manual dated February 28, 1986.

HANNER reviewed some PO files and conceded that the files were in disarray.

He stated that "we just give the utilities what they want."

On May 10, 1988, HANNER stated that he began operations at PMS on July 17, 1985, the date he officially resigned his position with Nuthem. HANNER selected PO file T-1003 and told the inspectors this file was a good example of the way PMS conducted their business of qualifying coninercial grade items to nuclear grade. He added that this PO for 400 indicating lights was the-first job received by PMS. He sau that PMS qualified these lights by simi-larity utilizing a previous Nuthen contract for similar items provided in-1982. HANNER stated he did not rewest a C of C from Fainnont Supply or from Westinghouse.

INVESTIGATOR'S NOTE: Although the original T-1003 file contained a C of C purporting to be from Westinghouse, the copy of T-1003 which HANNER reviewed to show to the inspectors did.not include the Westinghouse C of C.

A copy of the 1982 Nutherm/TVA contract referenced by HANNER was included in the original T-1003 file. However, file T-1003 did not include copies of Nutherm C of Cs, test data, or any substantiation for the apparent subsequent qualification to Class IE of the items included in this contract.

Case No. 4-88-018 14

\\

~

stating that WCN00 wanted the fuses quickly.

PMS had not requested a C of C from NIS so HANNER decided to falsify the document.

HANNER told the investi-gator that she could check all his other contracts and would be unable to find another false document because he had never falsified any other items.

HANNER stated that "what I did was stupid" because the test performed in conjunction with the TVA fuse order in 1986 was a valid test.

HANNER said he had panicked and destroyed the falsified Gould C of C.

HANNER said since he " thought it was a simple little order" and he was certain the fuses met nuclear grade, the alteration of the Gould C of C was an insignificant matter. HANNER said he repared it solely for POTTER's benefit because he believed it would be p' easier that way." HANNER said he had a Gould ATM20 fuse tested by Wyle Labs i

the previous week and the fuse tested out to all WCNOC specifications. HANNER i

reiterated he had never falsified any other documents and said he was solely responsible for the decision to provide an altered Gould C of C to the WCNOC auditor.

He said that neither RILEY nor DOLDREY was aware of the falsification of this document. HANNER prepared a signed sworn statement concerninghisfalsificationoftheGouldCofC(Exhibit 7).

i INVESTIGATOR'S NOTE: On April 11, 1988, Investigator Van Cleave spoke briefly by telephone with HANNER.

HANNER admitted that PMS was not incorporated and was operating as a sole proprietorship with himself as the owner. Additionally, on April 29, 1988, Investigator Van Cleave contacted the Registrar's Office at Elmhurst College..She was told that records reflected that HANNER received a B.S. degree from Elmhurst in 1974 in Business Administration, not Engineering as HANNER had previously toldtheinvestigator(Exhibit 8).

Re interview with Roger K. RILEY RILEY was re-interviewed on April 6, 1988, by Investigator Van Cleave at PMS, MountVernon,IL(Exhibit 2). RILEY stated that until the previous weekend he had been completely unaware of any alteration of a Gould C of C.

RILEY stated that everything he had previously told the investigators was true to the best of his knowledge at the time.

INVEST! GATOR'S NOTE:

From May 2 to May 5,1988, Investigator Van Cleave.

NRC Vendor Branch Inspector Joseph J. Petrosino, and Brookhaven Labora-tories Contractors Kenneth SULLIVAN and Terrence TINKEL conducted an l-exhaustive review of all records obtained by subpoena from PMS in April 1988. Three Westinghouse C of Cs found in PMS files T-1003.

T-1009 T-1015, and SM-1072 appeared to be questionable to the investi-gator (Exhibit 9).

Additionally, the files were in such disarray it was difficult to determine which P0s had been completed by PMS.

The investigator and inspectors listed pertinent questions concerning each file reviewed and decided to conduct an official NRC inspection of the PMS facility the week of May 9, 1988.

Interview with Thomes J. SHEA. Branch Manager. Wesco SHEA was< interviewed by Investigator Van Cleave and NRC Inspector Petrosino on May9,1988,atWesco,St. Louis,MO(Exhibit 10).

SHEA stated that PMS had been a C.O.D. customer of Wesco for approximately 2-1/2 years.

SHEA said employees at Wesco conducted a manual search of sales records to C.O.D.

customers and uncovered one sale to PMS, P0 #P-121286-2 dated December 12, Case No. 4-88-018 13

i INVESTIGATOR'S NOTE:

RochesterGasandElectric(RG8E)was telephonically contacted by 01, checked their records,.and stated l

this PO was for nuclear grade indicating lights. The P0 also required a C of C from PMS certifying the lights met IEEE-323 and IEEE-344 standards. The C of C received from PMS certif l

lights to these standards was included in RG&E's files. ying the j

5.

TV 1043 l

HANNER stated no environmental, aging, or other tests were performed on the items except seismic testing which was performed by Wyle Labs.

I INVESTIGATOR'S NOTE: A Gould comercial C of C. Wyle Test Report, and.PMS C of C which certified that these fuses were qualified in accordance with IEEE-323 and IEEE-344 were included in the file.

6.

P-1010 HANNER stated Public Service Electric and Gas (PSE&G) sent previously purchased comercial grade blocks to PMS for testing to IEEE-323 and i

IEEE-344 standards. HANNER stated that radiation testing was pe'fomed by Radiation Sterilizers, Inc., therm 61 testing was performed by ARDL, and seismic testing was perfomed by General Radiator on these items.

Certificates from Radiation Sterilizers and General Radiator were included in the file.

l 7.

NY-1071 HANNER stated that the only testing perfomed on these items was a vibration test. According to HANNER, since the P0 specified mild environment, no environmental testing was required although PMS' C of C certified the items to IEEE-323 standards.

8.

SM-1072 HANNER stated that this order was subsequently cancelled by SMUD.

He f

said SMUD had a Westinghouse report previously certifying similar relays to nuclear grade quality, but PMS never received a copy of the report.

INVESTIGATOR'S NOTE: A PMS invoice and PMS packing list were l

located in file SM-1072 which indicated that 20 relays were shipped via UPS to SMUD, Rancho Seco, on December 18, 1986.

PMS' file SM-1072 also included a Westinghouse C of C which certified 20 AR440 relays to Class IE and a PMS C of C which stated these relays were identical to relays provided to SMUD under Westinghouse order

1. SFU-55893 and were qualified in accordance with IEEE-323 and IEEE-344.

9.

T-1015 and T-1009 HANNER claimed that T-1015 was cancelled, but T-1009 for similar items was filled.

He said PMS had ordered Westinghouse meters but received Crompton meters because Westinghouse sold this division to Crompton.

HANNER said the order for T-1009 was filled without IEEE-323 Case No. 4-88-018 16

HANNEP. told Investigator Van Cleave that many orders supplied to SMUD were for replacement parts.

He said that since the original part must have been certified to nuclear grade at one time, he purchased the same item as long as it was the same part number, prepared a PMS C of C, and sent the PMS C of C as well as the replacement part to SMUD. Although SMUD P0s requested IEEE-323 and IEEE-344 certifications which HANNER provided to SMUD, HANNER admitted he perfomed no tests on the items to legitimately certify them in such a manner.

HANNER further admitted that-he had no way of knowing if the materials, the manufacturing process, or other items relative to the part had changed since j

the original part had been manufactured and qualified to nuclear grade. When i

asked by the investigator why the utility would pay him $4,000 to do nothing except sign a PMS C of C. he agreed it looked odd. He said he had recently become concerned that a utility might try to hold PMS and him liable should any problems arim because he issued a document stating that parts provided to the utility met 1EEE-323 and IEEE-344 when he did not conduct testing to assure the parts met these standards. He stated that he took some parts to j

Wyle t. abs for testing in March 1988. Although.he conceded this was after the fact testing, he claimed that all items, with one exception, passed seismic testing conducted by Wyle.

On May 11, 1988, the Vendor Branch team requestert that HANNER review several PO files pertaining to items provided by PMS to various utilities.

HANNER provided the following information concerning each file:

i 1.

SM-1114 i

HANNER had no substantiation for IEEE-323 or IEEE-344 certifications and had not perfomed an actual analysis of the item. HANNER said he prepared the C of C based on the Amerece test report referred to in the SHUD PO which he had never requested from SMUD and had never seen.

"$ MUD said to certify to this report so we did." Additionally, although SMUD i

was adding an auxiliary switch to the item tested by Amerace, HANNER decided this would have no effect on the seismic qualification of the item.

2.

SM-1113 HANNER had no substantiation for IEEE-323 or IEEE-344 certifications and had perfonned no testing or analysis on the item.

3.

SM-1110 HANNER had no substantiation for IEEE-323 or IEEE-344 certifications.

HANNER said he prepared a C of C based on a 1982 TVA report referenced in the SMVD PO which he had never seen but which reportedly qualified s

similar items to nuclear grade.

4 RG-1108 HANNER initially denied this was for nuclear-grade items and was unable

~

to provide the P0, C of C, or any documentation related to this sale.

Case No. 4-88-018 15

k t

gathered applicable documents to be bound in completed files in PMS' records.

ROBERTS stated that C of Cs issued by PMS were usually prepared by HANNER.

ROBERTS reviewed the Westinghouse C of C concerning indicating lights and l

stated he did not recall previously reviewing this C of C and said the C of C "looks funny to me.

He denied knowledge of any alteration, change, or forgery of any document, either prepared or retained at PMS. He stated that i

no one had mentioned any questionable documents to him nor had he personally t

changed any document.

ROBERTS said he had been inexperienced but tried to perfom his duties to the best of his ability. However, ROBERTS said that i

RILEY often became upset when ROBERTS questioned any work prepared by RILEY.

3 ROBERTS said he had no knowledge of RILEY, HANNER, or any other employee at i

PMS altering any documents.

l Interview with Gerald MAYS, Sales Representative, Fairmont Supply Company MAYS was interviewed by Investigator Van Cleave and Inspector Petrosino on May 12, 1988, at Fairmont Supply Company, Nount Vernon, IL (Exhibit 13). MAYS i

stated that he had a clear recollection of the sale of indicating lights to HANNER at P!'.S because HANNER still owed Fairmont over $1,000 on this order.

MAYS stated he did not recall additional sales to PMS by Fairmont. MAYS searched Fairmont's records and located a PO from Fairmont to Westinghouse in St. Louis, M0 for 400 indicating lights as well as an acknowledgement and shipping schedule which indicated the lights were shipped to Fairmont by Westinghouse on January 17, 1986. MAYS stated he did not recall seeing a Westinghouse C of C concerning these indicating lights sold to PMS and was unable to locate such a C of C in Faimont's files.

Several additional documents were located by MAYS which pertained to a PO by PMS for 8 Westing-house vertical scale indicators. MAYS stated he did not recall selling the indicators to PMS and that Fairmont had probably refused to conduct further business with HANNER until his account was paid in full.

Re-interviews with Roger RILEY 4

R1 LEY was telephonically interviewed by Investigator Van Cleave on May 16 and May18,1988(Exhibit 14).

On May 16, 1988 RILEY claimed that he had been unaware that the investigator wished to speak with him during her visit to PMS the previous week, RILEY stated he had been told by HANNER not to come to the l

PMS offices because he would be better served to look for another job during that time. RILEY denied that HANNER had begged him to return to the PMS offices and speak with the NRC representatives as was claimed by HANNER.

RILEY stated that he was not at the PMS offices and although he had some recollection of specific items sold by PMS, he did not have any records in front of him.

RILEY recalled that TVA purchased some pre-qualified indicating lamps in' PMS file T-1003.

RILEY alleged he was unable to recall seeing a Westinghouse C of C associated with this file. RILEY was unable to recall details of any orders placed by PMS for Westinghouse products. RILEY denied

.i knowledge of any alteration or falsification of any C of C from Westinghouse or any other sub-vendor other than the C of C provided to WCNOC which HANNER had altered approximately two months ago and told him about following the initial NRC visit. RlLEY said he never altered, falsified, or changed in any way any C of C provided by a sub-vendor. According to RILEY, HANNER was responsible for the final paperwork.

4 Case No. 4-88-018 18

qualifications and was subsequently " knocked down" by TVA from nuclear grade to commercial grade.

10. T-1003 HANNER said he " piggy-backed" nuclear grade certification for this P0 on top of e. Nutherm test and contract with TVA in 1982 for the same part number. HANNER admitted he never received nor reviewed the Nuthem test i

report referenced in this contract.

HANNER reviewed a C of C on Westing-house letterhead located in the original file and said he " assumed" it came from Gerald MAYS at Fairmont Supply but it could have been sent by Westinghouse. According to HANNER, the notation " Free of mercury contamination" on PMS' C of C probably came from this Westinghouse C of C i

because PMS had never tested for mercury contamination.

HANNER stated that at one time PMS owned an oven chamber which they planned to use to perfonn environmental tests, but they used it once and scrapped it.

HANNER edmitted PMS had perfonned IEEE 323 testing for only five P0s: T-1009, l

T-1015. T-1036. T-1046, and P-1010.

HANNER conceded that although he certified to IEEE-323 in conjunction with other orders, no testing to these standards in conjunction with these orders was ever performed. HANNER stated it was his understanding that if seismic testing under IEEE-344 had ever been perfonned in connection with the current order or a past order for similar items, he could automatically certify qualification to IEEE-323 for mild environments.

HANNER reviewed the C of Cs purporting to come from Westinghouse which the investigator had found in files T-1003, T-1009. T-1015, and SM-1072.

HANNER stated that to the best of his knowledge these were legitimate C of Cs.

He denied that he altered or falsified these or any other Westinghouse C of Cs to make it appear they certified P0 items to nuclear grade.

He further denied knowledge of any falsified documents in his files other than the C of C he had previously admitted to falsifying for the WCNOC order.

Interview with Billie Edward ROBERTS,11. Fonner QA Manager PMS I

ROBERTS was interviewed by Investigator Van Cleave and Inspector Petrosino on May 12, 1988, in Mount Vernon, IL (Exhibit 12).- ROBERTS stated he had been QA l

Manager for PMS from the company's inception in 1985 until approximately December 1986.

Prior to beginning employment with PMS, ROBERTS said he was an independent electrical contractor. He admitted that he was unfamiliar with the nuclear industry and spent a great deal of time studying requirements for nuclear grade materials.

ROBERTS stated that he checked all items received at PMS against the packing slip and the appropriate P0, then locked them in a file cabinet in the office.

ROBERTS stated that PMS initially maintained a QA data book on which each job t

number and company was recorded as well as' the status of each P0. ROBERTS stated he attempted to separate the duties of HANNER, R1 LEY, and himself, but the company was so small that " Rod and Roger were wearing too many hats."

When questioned about the sale of 400 indicating lights to TVA, ROBERTS stated he recalled that he sent the test procedure, the test report, the TVA P0 and the packing list to TVA along with the product. However, HANNER or RILEY Case No. 4-88-018 17

~ -.

t Crompton edgewise meters which were shipped to PMS on August 21, 1986.

PITT stated that Crompton did not send a C of C with this order nor was one l

requested by Wesco or PMS.

PITT stated that the C of C in the investigator's possession was unrelated to the PMS order and was probably inadvertently sent by Crompton to PMS instead of to Comonwealth Edison. However, PITT stated f

that had PMS requested a C of C Crompton would have sent them a similar C of C which certified only to ANSI C39.1 which had nothing to do with nuclear grade quality. According to PITT, Crompton never certified any products to nuclear grade or to IEEE-323 or IEEE-344 standards due to possible liability problems.

PITT stated that Crompton's vertical scale indicators were j

identical to those previously manufactured by Westinghouse prior to the sale t

of its instrument division to Weschler a few years ago.

Interview with Gary W. CAMPBELL, Manager for Total Quality. Relay

[

Telecommunica'iions Division. Westinghouse I

CAMPBELL was interviewed by Investigator Van Clean on Mty 23, 1988, at l

Westinghouse, Coral Springs, FL concerning three C of Cs purportedly from l

Westinghouse Electric Power Systems Relay and Instrument Division which were found in PMS' files (Exhibit 19). CAMPBELL reviewed the C of ts presented to him by the investigator and stated that all C of Cs were false documents.

He stated that currently the Coral Springs division of Westinghouse sold only one nuclear grade product, a relay. Prior to 1984, the Coral Springs division also' sold nuclear grade instruments, but in 1984 this division was sold to an independent company called Weschler, also located in Coral Springs.

CAMPBELL stated that the form on which the false C of Cs were prepared was a commercial C of C utilized by Westinghouse only for P0 specified comercial grade instru-ments prior to the sale of the instrument division in 1984.

CAMPBELL reviewed company records and stated that this C of C form, QAPf82 036, was initially l

written and placed into service by Westinghouse on September 15, 1982. The i

form became obsolete and had not been used since the sale of the instrument division to Weschler in 1984.

CAMPBELL stated that his division of Westing-house utilized three separate forms to certify specifications of a particular product. A Certificate of Compliance stated that the item was made in the Coral Springs factory and that it had been tested, measured, and calibrated to meet ANSI standards. A Certificate of Confomance certified that additional data was taken on the items and Westinghouse maintained records of these items. The third type of certificate was specifically for a Class 1E nuclear grade item. According to CAMPBELL, as of June 24, 1983, only the nuclear division of Westinghouse located in Monroeville, PA was allowed to provide a

+

nuclear Class 1E C of C to a customer.

The investigator reviewed each individual C of C located in PMS' files with.

l CAMPBELL. CAMPBELL stated that the C of C located in PMS file T-1003 for 400-indicating lights was a false and/or altered document. CAMPBELL stated that indicating lights were parts and not instruments, so a C of C would not have been prepared for indicating lights on a P0 specified instruments form.

CAMPBELL further stated that although the C of C reflected the Coral Springs location, indicating lights had never been manufactured in Coral Springs.

4 This C of C bore a signature which appeared to read " Paul Schmidt, QA

-t Inspector." CAMPBELL stated that Westinghouse in Coral Springs employed a Warren SCHMIDT as QA Manager until his retirement.in February 1986.

CAMPBELL stated that he had contacted SCHMIDT who told him he was unfamiliar with PMS and had no knowledge of the C of C in question.

Case No. 4-88-018 20 l

On May 18, 1988, Investigator Van Cleave received a telephonc call from RILEY who stated that he had reviewed some of PMS' PO files.

RILEY stated although file T-1015 contained an alleged Westinghouse C of C.-he had never previously seen that C of C.

R! LEY $tated he assumed the C of C was provided by Westing-house or Wesco but he had no actual knowledge of this order.

In fact, he stated he could not recall where the vertical scale indicators for TVA were purchased by PMS.

RILEY reiterated he had no knowledge of,any false documents contained in any of the PMS files.

Interview with Larry ERWIN. Field Salesperson, Westinghouse ERWIN was telephonically interviewed from his office in St. Louis, M0 by Investigator Van Cleave on May 16, 1988 (Exhibit 15).

ERWIN stated he had checked Westinghouse's records relative to a sale in January 1986 of 400 indicating lights to Fainnont Supply Company.. ERWIN stated that due to Westinghouse's policy of destroying all paperwork after one year on sales under $10,000, paperwork-for this order had been destroyed. However, he and Carol WEGER, Order Service Representative for Westinghouse, told the investigator that these indicating lights, which had been shipped from Westinghouse's distribution center in South Carolinn, would "most likely" not have had an associated C of C.

According to ERWIN and WEGER, only normal-orders for stock items were shipped from their warehouse in South Carolina, and an order with a request for a C of C would not be considered a normal order. ERWIN stated that Westinghouse's only operational manufacturing plant for indicating lights was located in Coral Springs, FL and, if-a C of C had been issued by Westinghouse, it would have been issued by that division.

ERWIN reiterated he was "99% sure" no C of C was provided by Westinghouse on this order.

Interview with Dorothy STIEBER Accounts Representative. Crompton Instruments STIEBER was telephonically interviewed from her office in Elk Grove, IL by Investigator Van Cleave on May 19, 1988, concerning vertical scale indicators ordered and received by PMS (Exhibit 16).

STIEBER stated that the customer account number CILWE1462 given to her by the investigator was assigned by Crompton to Wesco in Elmhurst, IL.

STIEBER stated that the indicators in question would have been shipped from Crompton to the end user PMS, but Wesco would have been billed by Crompton and would have billed PMS for the cost of the items.

Investigator Van Cleave read the C of C which had been found in PMS file T-1015 to STIEBER (Exhibit 17).

STIEBER stated this was a standard C of C prepared by Crompton which only certified the items to ANSI C39-1 and to nothing else.

STIEBER said that Ian CRANE, the name which appeared on the C of C, was at that time the manager of Crompton Instruments.

Interview with Tony PITT. Product Manager, Crompton Instruments PITT was telephonically interviewed from his office in Elk Grove, IL by Investigator Van Cleave on Ma 19, 1988, concerning vertic61 scale indicators ordered and received by PMS (yExhibit18).

PITT stated that he had checked Crompton records which indicated that order number DS-5105-7178 was placed by Wesco in Elmhurst, Il for a switchboard instrument. This instrument was shipped by Crompton along with the requested C of C on August 25, 1986, to Comonwealth Edison, Braidwood Station.

PITT stated that Crompton records reflected that order number DS-5105-7182 was placed by Wesco for eight Case No. 4-88-018 19 i

i presented to him were on Westinghouse Relay Instrument letterhead and the

.i C of Cs. consequently, could not have been provided in error from another i

division. CAMPBELL reiterated that none of the C of Cs were legitimate l

Class 1E certificates or legitimate commercial grade certificates provided by I

Westinghouse to PMS.

According to CAMPBELL, all of them were alterations of QAP82-036, a form used by Westinghouse to certify comercial grade only i

l instruments until the sale of the instrument division in 1984, i

l INVEST! GATOR'S NOTE:

CAMPBELL provided the investigator with copies of l

1egitimate certificates utilized by Westinghouse, i

1 1

Interview with Donald WHITTAKER, Distribution Center Manager, Westinghouse L

WHITTAKER was telephonically interviewed from his office in Spartanburg SC by j

Investigator Van Cleave on May 23,1908(Exhibit 20). WHITTAKER stated that t

the Westinghouse. Spartanburg, SC Distribution Center did not handle nuclear i

grade items.

However, it was possible that a comercial C of C might have been prepared and forwarded by the Spartanburg facility. On May 26; 1988 Investigator Van Cleave again contacted WHITTAKER by telephone. WHITTAKER stated that he had located the six shipment numbers previously given to him by

)

the investigator and that none of the documents associated with these e

shipments reflected a request for a C of C.

WHITTAKER stated that by Westinghouse policy, any requested C of C instructions must appear in the mark or style field of the packing list. According to WHITTAKER. if this notation did not appear in either of these fields no C of C was requested of or provided by the Spartanburg facility. WHITTAKER stated that the items in I

auestion, indicating lights and AR440 relays, were stock items or off the shelf promotional items, not nuclear grade items.

WHITTAKER additionally stated that if a commercial C of C had been sent from his facility, it would L

have been on Beaver. PA or Ashville. NC Westinghouse letterhead.

Interview with Gary KLANN, Manager of Nuclear Qualification Divisinn, Westinghouse KLANN was telephonically interviewed from his office in Fayetteville NC by Investigator Van Cleave on May 23,1988(Exhibit 21).

KLANN stated that the Fayetteville NC division of Westinghouse issued nuclear grade C of Cs for i

AR440 relays.

In 1986, these C of Cs were issued on plain white paper with the Fayetteville. NC address on top of the form. Additionally, KLANN stated l

he did not have an employee by the name of I. Crowe or Crane or any variation t

thereof in December 1986 or at any time since that date.

KLANN stated that if the packing list from Spartanburg reflected that the relays were shipped from 4

the Spartanburg Distribution Center directly to PMS. the relays were not nuclear grade relays because all nuclear grade AR440 relays had to be certified as such in Fayetteville. NC and shipped from that location.

l According to KLANN, the Spartanburg Distribution Center handled only shelf items.

KLANN said that commercial C of Cs for this type of relay would have been issued by the Ashville NC division of Westinghouse.

Interview with William JOACHIM, Manufacturing Engineer Westinghouse JOACHIM was interviewed by Investigator Van Cleave on May 23, 1988 at i

Westinghouse. Coral Springs. FL (Exhibit 22).

JOACHIM stated that from 1980 to 1985, he was,the QA supervisor responsible for certifying all nuclear Case No. 4 88-018,

22 i

1 i

i INVESTIGATOR'S NOTE:

The investigator reviewed a document provided to l

her by CAMPBELL bearing Warren SCHMIDT's signature.. The first name was clearly Warren and it did not appear to be in the.same handwriting as on the questionable C of C.

CAMPBELL further stated that the Westinghouse general order (GO) number on this C of C was not a valid Westinghouse GO number. According to CAMPBELL, 7

all GO numbers began with two letters which indicated the city in which the o

order was placed. The GO number on this C of C was only a six digit number.

CAMPBELL stated that the C of C located in PMS' file T-1015 was not a legiti-mate C of C and was a false document. According to CAMPBELL, this C of C had several items added to it which did not' appear on a legitimate Westinghouse C of C.. CAMPBELL stated it appeared someone had taken a connercial C of C and added these items to that document to make it appear to certify a product to Class IE. The additional items included the first line on the document and the last line on the document. Additionally, CAMPBELL said the date of the C of C was March 5,1986, which was after the instrument division was sold by Westinghouse to Weschler.

CAMPBELL said the vertical scale indicators shown on this C of C were instruments which had been manufactured by Westinghouse in Coral Springs prior to the sale of the division to Weschler in 1984. CAMPBELL reiterated that the C of C was a false document and said the correct Westing-house C of C form prior to 1984 for Class IE instruments was (QAP82-033.

CAMPBELL further said that Westinghouse never wrote "N/A" in the Westinghouse GO column and never sent out a C of C which was unsigned as was-this one.

CAMPBELL reviewed a C of C purporting to qualify AR440 relays associated with PMS file SM-1072 and s uted this C of C was a false document.

CAMPBELL stated that although the C of C was on Westinghouse Relay Instrument Division letter-head and the Coral Springs location was the only relay instrument division, these particular relays were manufactured and sold by the Westinghouse Ashville, NC division. According to CAMPBELL, after the sale of the instru-ment division in 1984, the letterhead for the Coral Springs division was changed from Relay Instrument Division to Relay Telecommunications Division.

CAMPBELL stated that several items ap> eared to have been added to an old commercial C of C to make it appear t1e comercial C of C qualified the relays to nuclear grade Class 1E. These included the first and last sentences on the form which, according to CAMPBELL, had never appeared on any Westinghouse C of Cs.

CAMPBELL also stated that the C of C aore a signature which appeared

.to read "I, Crowe, QA".

CAMPBELL said he had been employed at the Coral Springs division since September 1986 and, although the C of C was dated December 29, 1986, he had never employed anyone in the QA division by the name of I. Crowe or any variation thereof.

CAMPBELL said that Westinghouse always typed the customer's name and address on the left hand side of any C of C forwarded to a customer, but none of the C of Cs he had reviewed contained a customer's name or address.

CAMPBELL also stated that, although one of the C of Cs presented to him by the investigator had a page number at the top, none of the authentic Westinghouse C of Cs had a page number on them. CAMPBELL stated that to his knowledge a Westinghouse C of C did not appear as an example in any catalog or other document accessible to the public.

CAMPBELL said he had reviewed his division's records and PMS was not and never had been a customer of this division of-Westinghouse.

CAMPBELL further explained that all three of the C of Cs 1.

Case No. 4-88-018 21 1

.,,._,,,..m_

letterhead. According to DORMAN, Weschler had never used a Westinghouse 1etterhead for such certifications.

DORMAN stated that when Weschler received a PO for a Class 1E order from Westinghouse, Weschler complied with all ssecifications on the Westinghouse P0 and prepared and sent three documents to tie end user along with the instruments purchased. According to DORMAN, the three documents forwarded to customers of Class IE vertical scale indicators were:

1) certificate of confomance, 2) quality control instrument test report, and 3) supplier quality release form.

DORMAN stated that there were two readily visible differences between comer-cial and nuclear grade vertical scale indicators. Weschler always serialized Class 1E meters and stamped these meters with an in-process inspection stamp.

Weschler also tagged all IE items with a tag stating " Class 1E Instrument."

DORMAN said that although the Westinghouse license /Weschler logo appeared on the face of the meter, it was often hidden and not readily noticeable.

DORMAN stated that it was possible that a Weschler meter might have been sold I

as a Crompton Instruments meter because Weschler sold commercial meters to a subsidiary of Crompton Instruments called Meter Master. According to DORMAN, instruments sold to Meter Master were scaled by Meter Master _ and might be labeled as Crompton Instruments. DORMAN reviewed the C of C associated with PMS file T-1015 and stated that it appeared to be a false C of C.

He further i

stated it had not been prepared by Weschler although it was dated after Weschler had purchased the instrument division of Westinghouse.

Interview with Mark O'KEEFE,' QA Technician, Weschler O'KEEFE was interviewed by Investigator Van Cleave on May 24,1988, at Weschler, Coral Springs FL (Exhibit 24),

O'KEEFE stated that he handled sales of all nuclear grade vertical scale indicators by Weschler. O'KEEFE stated that as of approximately April 1987 Weschler began utilizing a supplier quality release form to certify an indicator to nuclear grade.

O'KEEFE stated this form referenced a Westinghouse GO number which in turn referenced the customer's P0 number. O'KEEFE stated that although Weschler supplied the meters to Class 1E design specifications, the design and all modifications were prepared by Weschler but approved by Westinghouse.

According to O'KEEFE, a C of C was prepared by Weschler on Weschler letterhead which showed the Westinghouse name and Pennsylvania address on the left hand side of the fom. O'KEEFE reviewed the Westinghouse C of C located in PMS' file #T-1015 and stated that it was not a valid C of C because it was not prepared on Weschler letterhead and was dated after Weschler purchased the instrument line from Westinghouse, Coral Springs, FL.

Interview with Dick BAKER, Electrical Engineer, Rochester Gas and Electric (RG&E)

NRC Investigator Van Cleave spoke by telephone with BAKER on June 6,1988 (Exhibit 25). He stated he was the electrical engineer who placed an order

- for six nuclear grade indicating lights as well as a C of C from PMS.

According to BAKER, these indicating lights were manufactured by Dialco.

BAKER stated that he would forward copies of all documents pertaining to any purchases from PMS to Investigator Van Cleave.

Case No. 4-88-018 24

i

?

instruments at the Coral Springs division of Westinghouse. JOACHIM reviewed l

the three C of Cs in question and stated that the only one certifying an instrument was the one for two vertical scale indicators and it was a false i

document. The other two C of Cs did not relate to instruments, according to I

JOACHIM, so they were obviously false documents. JOACHIM said the instrument division of Westinghouse was sold to Weschler Electric, a separate company, in l

1984. JOACHIM checked his records and stated that the last C of C relating to

)

Westinghouse instruments was issued by Westinghouse in April 1985. Since the C of C in question was dated March 5, 1986, JOACHIM stated it could not be a_

1egitimate one. JOACHIM stated that this fom had several additions to it not found on a legitimate Westinghouse Class IE C of C including the initial line and the final line. Additionally, JOACHIM stated the form was unsigned and l

Westinghouse never sent out an unsigned C of C.

JOACHIM stated that only he i

and one other individual, Warren CLARK, were authorized to sign a C of C.

Although one of the C of Cs presented for review to JOACHIM. bore a signature appearing to read " Paul Schmidt" and the fomer Westinghouse QA Manager had been Warren Schmidt, JOACHIM stated Schmidt had not been authorized to sign and had never signed any Westinghouse C of Cs. JOACHIM said it appeared that i

a Westinghouse commercial grade C of C for P0 specified instruments had been e

altered by someone to make it appear to cualify products to nuclear grade.

JOACHIM stated that it was.his belief that Weschler did not issue-any C of Cs and relied on the Westinghouse Nuclear Division in Pennsylvania to issue such certificates. JOACHIM stated that Westinghouse always serialized any Class IE t

items which they manufactured and certified to in order to trace the items should it become necessary. However, the C of C presented to him for vertical scale indicators listed "N/A" under the serial numbers which JO/.CHIM stated was obviously a false entry. JOACHIM stated that he checked the Coral Springs records and found no record of any sales, commercial or nuclear grade, to PMS.

Interview with Michael F. DORMAN. plant Manager. Weschler DORMAN was interviewed by Investigator Van Cleave on May 24. 1988, at Weschler, Coral Springs, FL (Exhibit 23). DORMAN stated that he was a former employee of Westinghouse Instrument Division, Coral Springs, and had been plant manager for Weschler in Coral ' Springs since its purchase _of Westingbouse's instrument division line in 1984.

DORMAN stated the only product Weschler supplied which was qualified to nuclear grade Class IE was a vertical scale indicator number VX-252.

DORMAN stated this product was manufactured in Coral Springs and was labeled as manufactured under the Westinghouse name by Weschler.

DORMAN said Weschler only accepted Class 1E nuclear orders from Westinghouse Nuclear Division in Monroeville, PA and would not accept an order for a nuclear grade item direct'1y from an outside customer. DORMAN added that they did sell a comercial grade vertical scale indicator to outside customers. DORMAN stated that Weschler issued a comercial certificate of confomance for P0 specified instruments as well as a certificate of compliance. According to DORMAN, a certificate of confomance stated that Weschler had test data on file to substantiate the requirements and specifications shown on the C of C.

A certificate of compliance simply certified that the item met certain ANSI standards. DORMAN stated that although Class IE nuclear grade sales came through Westinghouse's Nuclear Division in Pennsylvania, the nuclear grade C of C prepared to substantiate this classification was on a Weschler Case No. 4-88-018.

23

qualified the relays to nuclear grade.- According to HANNER, although the relays were shipped, SMUD cancelled this order and stopped payment of their check to him for the order.

HANNER stated he believed SMUD had a problem with the Westinghouse C of C which he had falsified and submitted to them, but he was unable to recall exactly why SMUD cancelled this order.

HANNER stated that he believed he typed all the false C of Cs himself. HANNER said that if his secretary or anyone else had typed the C of Cs, it was definitely at his orders.

HANNER believed he had obtained a blank Westingnouse C of C form from a Westinghouse catalog but he was unable to locate a blank C of C in the catalog. HANNER admitted he was aware that he was falsifying documents but attempted to justify his actions by stating that he never falsified a C of C unless the part number provided by the sub-vendor was identical to the part number previously qualified in some test te) ort.

According to HANNER, he did not know how much RILEY, his QA Manager, (new concerning the sub-vendor C of Cs located in PMS' files. HANNER said he had no recollection of telling RlLEY that he was "dumying up" any document to place in the files, HANNER further stated he was certain that ROBERTS, the former QA Manager, was unaware of the false documentation in the files.

INVESTIGATOR'S NOTE:

HANNER prepared a signed sworn statement concerning t =

his falsification of C of Cs on Westinghouse letterhead (Exhibit 27).

Re-interview with Roger K. RILEY R1 LEY was interviewed by Investigators Van Cleave and Driskill on June 15, i

1988,atPMS,MountVernon,IL(Exhibit-28).

RILEY maintained..that he had no knowledge of any false C of Cs or any other false documentation located in l

PMS' contract files.

He claimed he had been unaware of any such problems until HANNER told him that he (HANNER) had falsified a Gould C of C associated with the sale of 60 fuses to WCNOC.

RILEY denied that HANNER told him of any l

other instance of falsifications of certifications or other documents.

I Following a review of PMS file T-1003, RILEY stated he recalled the contract but did not recall the C of C on Westinghouse letterhead located in the file, i

RILEY stated he had never questioned the authority of any sub-vendor C of C, j

and the C of C in question looked all right to him. He claimed he had never noticed anything questionable about the C of C such as the black photocopy l

line running down the side and/or the crooked typing of several of the lines.

RILEY further stated he had no recollection of anyone at TVA ever questioning PMS' sub-vendor C of Cs. RILEY then reviewed PMS files T-1015 and T-1009 for vertical scale indicators sold to two different TVA plants.

RILEY stated he was told, he believed by HANNER, that the vertical scale indicators PMS received in conjunction with these orders were Crompton Instruments.

He-i stated that HANNER also told him that Westinghouse sold the division which manufactured these indicators to Crompton which continued to manufacture identical indicators.

RILEY claimed that although the files contained C of Cs on Westinghouse letterhead which apparently certified Crompton Instrument 4

meters to nuclear grade, he did not suspect there was a problem with the C of Cs and assumed Crompton utilized Westinghouse letterhead for their certifications.

RILEY reviewed file PMS SM-1072 and again claimed he had-never questioned the Westinghouse C of C located in that file.

RILEY denied knowledge that the C of C had been altered and was a false document and stated he was unaware of any false documents in PMS' files. However, he admitted Case No. 4-88-018 26

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INVESTIGATOR'S NOTE:

Investigator Van Cleave subsequently received a letter from BAKER which stated that the order for six indicating ifghts was the only order received by RG&E from PMS. BAKER also provided a copy i

of the PMS C of C which certified the indicating' lights to nuclear grade.

j Re-interview with Rodney C. HANNER HANNER was interviewed by Investigators Van Cleave and Driskill on June 15, 1988, at his office at PMS, Mount Vernon, IL (Exhibit 26).

l INVESTIGATOR'S NOTE: During a previous interview, HANNER told Investigator Van Cleave that he was unaware of any false documents in

[

PMS' files pertaining to T-1003. T-1009 T-1015, and SM-1072 or any other i

PMS file. The investigator had located C of Cs on. Westinghouse letterhead associated with these four project files.

When HANNER was questioned by Investigator Van Cleeve concerning these Westinghouse C of Cs on June 15, 1988, he admitted that he had actually prepared these forms himself to represent nuclear grade certification of commercial grade items. HANNER admitted that none of these C of Cs was prepared, sent, or provided by Westinghouse, j

HANNER claimed he had prepared these Westinghouse C of Cs "to fill in holes in j

the packages." HANNER initially alleged all these projects were " dead" or incompleted jobs but later admitted that items associated with the four f

projects were in fact shipped to the nuclear plant which had placed the r

orders. HANNER further conceded that the indicating lights ordered for job l

T-1003 were sent to TVA and this was a completed job.

He admitted that he prepared a false C c1 C on Westinghouse letterhead on which he signed a false name to certify that these indicating lights had been qualified to nuclear i

grade. However, he contended he did not send this falsified Westinghouse-C of C to TVA but retained it in PMS' files where it was available for review

)

by utility auditors and others. HANNER admitted that T-1003 was the first order received by PMS for nuclear grade items and by falsifying the C of C he "got off on the wrong foot."

Regarding T-1009 and T-1015 HANNER said he had ordered Westinghouse vertical scale indicators from Wesco in Elmhurst, IL but had received Crompton vertical scale indicators. As part of the supporting documentation for these l

contracts HANNER admitted he submitted an unsigned Westinghouse C of C to TVA which he had completed to make it appear-to certify the vertical scale indicators to nuclear grade quality. HANNER stated that TVA rejected the unsigned C of C and requested a test be performed on the indicators.

HANNER stated he was unable to recall when TVA made this request nor could he recall when the utility noticed that he had=sent them Crompton, not Westinghouse, meters. HANNER stated that while he was attempting to obtain additional information concerning the Crompton meters. TVA cancelled the order for T-1015

?

and downgraded the indicators received in connection with T-1009 to comercial grade from nuclear grade.

t HANNER stated that the order associated with SM-1072 was for replacement parts for Westinghouse relays which had been previously qualified to nuclear grade.

HANNER said he again prepared a Westinghouse C of C which he signed with a F

false name to indicate that the C of C originated from Westinghouse and I

Case No. 4-88-018 25

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L.

maintained by PMS, the entire file pertaining to PMS' sale of alleged nuclear grade fuses to Wolf Creek is attached as Exhibit 30.

Included in the. file is Wolf Creek's PO requesting nuclear grade Class IE fuses and the PMS C of C qualifying the items to IEEE-323 and IEEE-344 and certifying compliance with.

the provisions of 10 CFR, Part 21.

_j NRC Vendor Program Branch Inspection Report Number 99901101/88-01 prepared by NRC Inspector Petrosino at the conclusion of the inspection of PMS in May 1988 outlinesadditionaltechnicalviolationsbyPMSofficials(Exhibit 31). These.

include:

1.

Failure to provide evidence to substantiate certification of quali-fications of inspection, examination, and auditing personnel; 2.

Failure to correctly translate specifications and contractual P0 requirements into seismic test report requirements for sub-tier j

vendor IEEE-344 testing activities; I

3.

Failure to retain documentation which would identify and trace components procured by PMS; 4.

Issuance of C of-Cs which indicated components met various qualifi-cation standards without verifying that the certification basis was relevant and enveloped the qualification requirements applicable to:

the specific order; 1

5.

Failure to provide requirements for evaluating potentially 1

reportable nonconfomances and problems and for notifying licensees or purchasers of deviations in accordance with 10 CFR, Part 21, requirements; 6.

Failure to provide evidence that PMS invoked 10 CFR, Part 21, for purchase orders placed with subcontractors;-and-7.

Inadequate implementation of the test program requirements for IEEE-323 standards and issuance of C of Cs without adequate basis l

for issuance.

Wi11 fulness / Intent-l A.

A Wolf Creek auditor reported to the NRC that he might have been provided with a false or altered sub-vendor.C of C by PMS. This'C of C was pre-sented to the auditor as certifying fuses purchased by. Wolf Creek from PMStonucleargrade(Exhibit 1).

B.

The Sales Manager at NES stated that the fuses his company sold to PMS (which were subsequently sold to Wolf Creek) were commercial grade Gould-fuses and PMS did not request or receive a C of C from NES or Gould certifying these fuses to nuclear grade (Exhibit 5).

C.

The owner of PMS, Rodney HANNER, admitted to the 01 investigator that he had '? dummied up" a Gould commercial C of. C to make it appear to certify to nuclear grade 60 commercial fuses sold by.PMS to Wolf. Creek. He also j

admitted to preparing and backdating a PO to NES for these fuses which was never sent to NES but was prepared solely for the Wolf Creek auditor's benefit. HANNER stated there were no other false documents anywhere in PMS' files and that he was solely responsible for the i

decision to falsify a C of C to provide to the Wolf Creek auditor

~

(Exhibits 6 and 7).

. Case No. 4-88-018,

28 m

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that_at'this point he would'not be_willing to state there were no other false documents in-P W 9 1es.

Investigator W s C'em qctioned RILEY concerning PMS' definition of quali-fication-by s W lam ty 'RILEY stated that his basis for qualifying an~ item to nuclear' grede by m e birity was to do a visual inspection and compare the items to previss h Walified items.

RILEY claimed that if they were the same part number and looxed identical. it was logical to assume they were qualified by similarity. He was unable to provide any additional documentation received from sub-vendors to substantiate that neither the material involved nor the manufacturing process had changed since the original qualification of the

-items'to nuclear grade.- RILEY admitted that he was now aware there might be a problem with this type-of qualification by similarity, but he stated that at j

the time he believed what he was doing was correct.

Documentation Analysis Investigator Van Cleave reviewed records subpoenaed from PMS and prepared a list of potential sales by PMS to the nuclear industry by PMS' PO file numbers (Exhibit 29). The records maintained by PMS were in disarray which made it difficult to determine which files represented completed contracts and which contracts were not granted to PMS.

Due:to the disorder of the records, it is possible that PMS sold products to other licensees or other products to licensees listed. As Knolls Atomic Power and UNC-Hanford are Department of Energy (DOE) regulated facilities, information pertaining to possible sales by I

PMS to these locations was referred to DOE-IG Richland, Washington, on June 13, 1988.

y Records received from TVA indicate that PMS was awarded contracts on the following files:

T-1003, T-1008, T-1009, T-1015,-TV-1036,1TV-1043, and j

i TV-1073.

The items included in these files were purchased for TVA sites at j

Watts Bar, Browns Ferry, and Sequoyah.

i Records received from SMUD indicate that PMS was awarded contracts on~the i

following files:

SM-1063, SM-1072, SM-1110, SM-1111,:SM-1113, SM-1114, SM-1115, SM-1116, and SM-1117.- According.to SMUD records, contract SM-1063:

was cancelled and the items relating to SM-1111 had not been received by SMUD as of 7/1/88.

SMUD records also include additional purchases of Class IE nuclear grade items from PMS which were not' reflected in PMS records received pursuant to the subpoena by NRC. These purchases from PMS were.for relays l:

(SMUD PO#RQ-88-07-29357A), contact blocks (SMUD PO#RQ-88-03-14996), and fuses (SMUDPO#RQ-88-03-16257).

a Records indicate that sales of items certified as nuclear grade were also made i

byPMStoWolfCreek(WC-1109),RochesterGasandElectric(noPOnumber),and i

New York Power (NY-1069, NY-1070, and NY-1071). Records indicate PMS provided

~

certification to nuclear grade to Public Service Electric and Gas (PSE&G) for-items PSG&E had purchased as commercial grade (P-1010). Sales of items certified as nuclear grade were made to DOE regulated sites at Knolls Atomic Power (KAP-1106) and UNC-Hanford Station (UN-1044 and KE-1101).

Records detailing approximately 26 sales of items certified to IEEE-323 and.

IEEE-344 standards and/or'the reporting requirements of 10 CFR, Part=21, are retained at the NRC Region IV OI office. As an example of the type of records 1

Case No. 4-88-018 27 j

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A field ~ salesperson at Westinghouse-stated that, although applicab1'e paperwork had been destroyed, he was "99% sure" no C of C was provided by a

Westinghouse for the sale of 400 indicating lights to PMS because the lights were shipped from a warehouse where only stock items were maintained (Exhibit 15).

1 N.

The Product Manager for Crompton Instruments stated commercial grade-vertical scale indicators (PMS file #T-1015) were shipped to PMS by Crompton.

Crompton did not sell nuclear grade products and-never certified products to IEEE-323 nor IEEE-344 standards. He stated the.

Crompton C of C in the investigator's possession had inadvertently ~been sent by Crompton to PMS instead of Commonwealth Edison'.

If PMS had requested a C of C, a similar one would have been sent~to them which certified the items only to ANSI C39.1 and had nothing to do with nuclear grade quality (Exhibits 17 and 18).

O.

Westinghouse officials in Coral Springs, FL stated that the three C of Cs on Westinghouse letterhead shown to them by the-investigator were all false documents and had not been prepared or-issued-by Westinghouse. The form, QAP82-036, on which these false. C of Cs were written was a commercial grade C of C form which had been utilized by Westinghouse =for P0 specified commercial grade instruments prior to'the sale of the l

instrument division to Weschler in 1984.

PMS had never been a customer-of the Coral Springs division of Westinghouse, and that division never

{'

provided PMS with any C.of Cs-(Exhibits 19 and 22).-

P.

The Manager of Westinghouse Distribution Center stated his facility did j

not handle nuclear grade items. The items shipped from that facility to 1

PMS, indicating lights and AR440 relays, were stock items and not nuclear grade-items (Exhibit 20),

y Q.

A manager at the Fayetteville, NC division:of Westinghouse stated his facility certified and shipped all sales of nuclear grade AR440 relays.

Since the relays in question were shipped from the Spartanburg Distribu-tion Center to PMS, they must have been commercial grade items j

(Exhibit 21).

R.

Weschler officials stated that the C of C' associated with PMS file T-1015 was a false document.

It was dated after the sale of the Westinghouse instrument division to Weschler and was not on Weschler letterhead.

Weschler accepted orders for' nuclear grade items only from Westinghouse i

NuclearDivisioninPA(Exhibits 23and24).

i S.

After initially. denying knowledge of any-falsified Westinghouse C of.Cs, HANNER subsequently admitted falsifying Westinghouse C of Cs forLindica-l ting lights, AR440 relays, and vertical scale. indicators to substantiate that these connercial grade items had been qualified ~to nuclear grade I

when, in fact, they had not been so qualified. HANNER admitted.he had been aware that he was falsifying documents but attempted to justify.his 1

actions ~by saying he never prepared a false C of C unless the part number on the order was identical to a part number previously qualified in some-report (Exhibits 11 26, and 27).

i i

Case No. 4-88-018 30 j

D.

HANNERadkittedthat,contrarytoPMSletterhead,-thecompanywas;not incorporated and was operating'as a sole proprietorship with himself as the owner. HANNER admitted he had never received the master's degree from Webster University as shown on his resume (Exhibit 6.).

E.

Elmhurst College officials stated _ that HANNER received a B.S. degree in Business Administration, not Engineering, as he had told the investigator (Exhibit 8).

F.

RILEY denied knowledge of any falsification or altsration of any documents in PMS' files (Exhibit 2).

G.-

Wesco Branch Manager stated his company sold 20 commercial grade relays to PMS (PMS file tSM-1072) but did not provide a C of C to PMS. Wesco's-charter states that Wesco may not sell nuclear grade products.

Upon._

reviewing the C of C.found,in PMS' records, file fSM-1072, the Branch Manager stated he had never seen that C of C-and that Wesco had never -

supplied any C of C to_PMS (Exhibit 10).

H.

HANNER stated "we just give the utilities what_ they want."':He said if an-original part had been certified to nuclear grade at one time,ias long.as the replacement part he purchased was-the same part number, he certified the part to IEEE-323 and IEEE-344 without_ performing tests on the items.

-HANNER admitted to sometimes preparing-C of Cs based on past3 test reports issued by third parties which he had never obtained nor reviewed.,He:

admitted he had no way of knowing if the materials, the. manufacturing precess, or other items had changed since the original part had been manufactured and qualified to nuclear grade (Exhibit-11).

I.

HANNER claimed PMS had performed IEEE-323) testing-in connection with five P0s(T-1009, T-1015,-T-1036 T-1046, and P-1010); but he admitted he issued certifications to IEEE-323 standards on many other orders.

He said he believed if he had seismic testing performed-under:IEEE-344',-he could automatically certify. qualification to 'IEEE-323' for mild environments (Exhibit 11).

J.

HANNER reviewed three Westinghouse C of Cs located.in files T-1003 T-1009, T-1015, and SM-1072, stated they were legitimate C of;Cs, and denied that he had falsified them to make.it appear'that=they' certified comercial items to nuclear grade.

He further denied knowledge 1of any false documents in PMS' files other than thelC of C he falsified ~in connection with the sale of fuses to Wolf Creek (Exhibit.11).

K.

Fomer PMS QA Manager, ROBERTS, denied knowledge of any alteration, change, or forgery of any_ document in PMS' files. HANNER subsequently told the Investigator he was certain Roberts had no knowledge of.the false documents in PMS' files (Exhibits 12 and 26).

L.

AsalesrepresentativeforFairmontSupply)statedtheysold400 indicating light a Westinghouse C of C in connection with this order and was unable to locate a C of C in Fairmont's files (Exhibit 13).

Casc No. 4-88-018 29

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'RILEY denied knowledge of.the falsified Westinghouse C of Cs.and said heL never noticed such questionable items on the C of Cs-as crooked-typing

-1 and black photocopy lines down the side.- He claimed he assumed Crompton j

Instruments utilized Westinghouse letterhead to certify their vertical i

scale indicators to nuclear grade because HANNER told him Crompton bought I

thatdivisionofWestinghouse(Exhibit 28).

j l

j Agent's Conclusion I

Rodney HANNER, the owner of PMS, knowingly and intentionally prepared false

'sub-vendor C of Cs for. items sold by PMS to the nuclear industry in order to make it appear that commercial grade items =had been certified to IEEE-323 and:

IEEE-344 standards and were Class 1E nuclear grade' items.- HANNER knowingly and' intentionally prepared false PMS C of Cs on which.he stated that IEEE-323 and IEEE-344 standards had been met when he knew he had not perforned necessary testing to meet. these standards.

~

HANNER-knew he was providing false C of Cs to.the-nuclear industry to meet requirements on their P0s and~ knowingly and intentionally failed to provide l_:

notice of potentially defective components to the NRC as required by 10 CFR,-

Part 21.21.

l l

HANNER knowingly and intentionally made false statements to the NRC investi-gator on April 6,.1988, when he told her there were no. false documents in PMS' files and that he had not prepared any false C of Cs other than the one shown to the Wolf Creek auditor.

He subsequently made additional false statements

/to the NRC investigator on May 11.,1988, when he~ told her;the Westinghouse C of Cs were legitimate and that he.had not-falsified:or altered these or any other Westinghouse C of Cs.

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Case No. 4-88-018 32 4

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n LIST OF EXHIBITS Exhibit No.

_ Description 1-Region IV Regiorial Administrator's Request for Investigation dated April 5, 1988 2

Report of Interview with RILEY dated March 31 and April 1,1988 3

Office of Investigations Subpoena dated March 31, 1988

[

4 Report of Interview with BOLDREY' dated March 31, 1988

~

5 Report of Interview with BURKARTH dated April 5. 1988-6 Report.of Interview with HANNER dated April 6,1988 7

Signed Sworn Statement by-HANNER dated April 6, 1988 8

Memo of Conversation with Elmhurst College dated April 29, 1988 t

9 Westinghouse Certificates of Conformance.

10 Report of Interview with SHEA-dated May 9, 1988 11 Report of Interview with HANNER dated May 9 to May 12 1988 12 Report of Interview with ROBERTS Jated May 12,~ 1988 13 Report of Interview with MAYS dated May'12, 1988 14 Report of Interview with RILEY dated May 16 and May 18, 1988 15 Report'of Interview with ERWIN dated May 16, 1988 16 Report of Interview with STIEBER dated May-19, 1988 17 Crompton Instruments Certificate of'Conformance 18 Report of Interview with PITT dated May 19,'1988=

L

- 19 Report of Interview with' CAMPBELL dated May 23. 1988 j-20 Report of Interview with WHITTAKER dated May 23, 1988 L

21 '-

Report of-Interview with KLANN dated May-23, 1988 i

22 Report of Interview with JOACHIM.dat'ed May 23,'1988 23 Report of Interview with DORMAN dated May 24, 1988.

24 Report of Interview with O'KEEFE-dated May 24,~~1988 I

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Case No. 4-88-018 33 L

25 Memo of Conversation with BAKER dated June 6,.1988 26 Report of Interview with HANNER dated' June 15,1988 27 Signed Sworn Statement by HANNER dated June 15. 1988-3 28 Report of Interview with RILEY dated June 15, 1988 29 List of Sales by PMS to_ Nuclear Industry 30 PMS PO File WC-1109 31 NRC Vendor Program Branch Inspection Report #99901101/88-01 dated August 22, 1988 t

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34

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