ML20091G911
| ML20091G911 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/25/1983 |
| From: | Wiktor D GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-09, CON-BOX-9, FOIA-84-96 NUDOCS 8406040403 | |
| Download: ML20091G911 (9) | |
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confidential source GOVERNMENT ACCOUNTABILITY PROJECT Institute for Policy Studies bb NOT O!Q 1901 Que Street. N.W., Washington. D.C. 20009 (202)2dd 08 -
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February 25,
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Wayne Shafer I'-12M D
4 United States Nuclear Regulatory Commission
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799 Roosevelt Rd.
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Dear Mr. Shafer:
i Enclosed is a copy of the Affadavit of Ronald A. Perry.
Sincerely yours, J7Ab(
Denise L. Wiktor Intern, Government Accountability Project 9
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My name is Ronald A. Perry. I am submitting this atatement of my own free will, without threat or inducement, to Mr. David Crow, who has identified himself to me as an investigator for the Government Accountability Project. From September S,1901 to February 20, 1902, i
I was employed by the Zack Company of Cicero, Illinois, a Heating, Ventila-i j
tion and Air Conditioning ("UVAC") company. I served as a quality assurance ("QA") engineer for the QA Documentation Team assembled by Zach to revicw purchase orders ("P.O.s") and supporting documents for materials supplied to three nuclear power plants ('41dland, Clinton and LaSalle). I was hired on a contract basis at Zack through the Quantum Technology, Inc., with the understanding that my position would be temporary, to last between three and six months.
?!y background includes 10 years with the U.S. Air Force as a l
_ quality control inspector in Uondestructive Examination ("NDE") of aircraft; and later at Ebasco Services. From June 23, 19S0 to until l
I went to work for Zack I had QA responsibilities, taught NDE refresher courses and performed audits /surveillances for Commonwealth Edison.
A review of purchase orders by the Zack investigation team revealed the followirg:
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" Alteration" of Certitied Material Test Reports (C!TRs) lacked properly referenced standard (s), and were missing an authenticating l
signature from the chief netallurgist. ASIM standards were typed onto f
an adhesive sticher, which was then signed with the metallurgist's name
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i and attached to the test report. The signature on these stickers differed in appearance from one sticker to the next. The individual responsible for these alterations was identified to me as Carl Eichstaedt.
Ifr. Howard McGrane, who also worked with the Zack team but who represented Consumer Power under a contract with PAC at !idland, described !!r.
Eichstaedt's role uhen I first came to Zack. Thesa document alterations were identified in the interim reports Zack supplied to the utilities for a significant event disclosure. I consider the term " alteration" too mild; a better description would be " forgery".
2.
Scattered and missing purchase orders and related documentation were continually included in the purchase order folders without being logged into the document control log book as required.
3.
Incomplete P.O.s including:
(a) failure to specify that material'was being ordered for use in a nuclear facility; (b) failure to reference specifications. In particular, i
vendor steel could not be certified to AST1 standards. CITRs were 1
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missing either physical or chemical analysis or both; (c) incomplete paperwork on small hardware. For exanple, nuts, boits and washers supplied by Delta Screw Company often bora no specifications at all. References to incorrect standards were also frequent.
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Inability of subtier vendors to supply missing information.
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j I myself sent out numerous requests to subtier vendors attempting to
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correct discrepant P.O.s through vendor records. At the time I left o Q ~~
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U.S. Steel responded, stating that (26) subject P.O.s had not been designated nuclear-grade; consequently, e
U.S. Steel's nuclear Verification and Testing program had not reviewed material supplied to Zack. The response concluded by declining to I
certify the equipment for nuclear use, as requested by Zack.
5.
An Approved Vendors List (" AVL") that failed to reflect Zack's i
l purchasing practices. An internal audit performed by Zack's John
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O'Connell resulted in a purge from the AVL of vendors who were failing to comply with 10CFR50 Appendix B requirements. Although vendors not on the AVL were not supposed to receive orders from Zack, orders were placed with unapproved vendors nevertheless, and this after a review of P.O.s by the Zack QA Department. David Clkins, QA !!anager, did conpile a list of P.O.s sent to Delta Screw while it was off the AVL.
6.
Zack supplied material to three (3) sites (:idland, Clinton, LaSalle). The three site specifications were unique and a separate l
entity from the other sites (i.e. angle si::e for one site was different i
f for the other site (s); material type (A500 etc.) met one site but not the othor(s); documentation and test requirements differed from site to site (s). Yet the purchase order would read "LaSalle" and the natorial vould be sent to ":lidland" or any conbination of the three sites. In the early tall of 1901, Startin Skates remarked to me, "I vonder how Zack bills its clients."
The chaos I have described dominated Zack's paperwork. This nas well known to Zack managenent and to the utilities involved. The DO NOT M gggy og gm -
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- tl 0 5 SC_05 Documentation Team was hired explicitly to bring the situation under control.
Mr. McCrane continually requested that current site specifica-tions be provided to the " Team" so a valid and accurate review could be i
performed. Contrary to this Zack Upper Management never provided the
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requested documentation. Through the search of individual desks, cabir.ets, boxes and in a back room the " Team" located missing documenta-tion.
Current site specifications were never fully provided until Jan.- Feb. 1982, and even questionable ~at that time. Getting a perspective of the total problem was difficult enough. In addition, Zack management demanded that we review and correct the P.O.s in an impossibly short period of time. Interim reports were produced on a rush basis in order to show documented evidence that Zack was implement-ing corrective action and that the utilities' could proceed with con-struction. These interim reports were inaccurate and should have been continually revised to reflect an accurate status report.
Nevertheless, the basic types of problems we cited were valid, t
An October 9, 1981 report, based on my work at Zack, reported on (1) " altered certifications";
(2) " white-out used and retyped"; and I
(3) " heat numbers altered to agree with certifications". An October 23, 19G1 report accurately identified problems with material certifica-tions, improper access to docunents, and unauthorized document alterations.
It represented a review of 1,000-1,200 P.O.s.
At that time, at least g
1000 P.O.s were unreviewed and more were being discovered every day in de-k drawers and odd corners. The document control was so poor tra-ditionally that the records had been piled on floors in boxes. Even after the Document Control Center had been established, unauthorized
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personnel were removing " quality documents" without signing thy 9 tift.
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-s-Often, the next morning we would find " quality documents" slid under the door. The " Team" was intimated to let quality documents leave the Control Center without them being signed out, per established procedure.
Because of the volume of unreviewed P.O.s, Zack coenitments to the utilities could not be honored. The pressure to finish the LaSalle project was especially intense. Nevertheless, a Cornonwealth Edison i
demand for a final report by !iovember 13, 1901, was first postponed by 1
Zack to December 1, and then abandoned altogether.
It was not until January 9,1982, in a meeting with !!r. Calkins
-i and Terry Howard, Supervisor of the QA Team, that Zack was forced to confront the magnitude of the job. ?!r. Calkins urged us to continue to use the figure of 1,300 P.O.s as reported in the October 23, 1901 l'
interim report. Only when Terry and I insisted that the actual number vould turn out to be well over 2,000 did he decide to abandon the lower figure.
Because Str. Calkins continued to pressure us to turn out reports and ignored our experiences with continuing nonconformances and AVL inaccuracies, I decided to consult a friend, Robert Klinger, who worked with Corconwealth Edison as a QA supervisor at the Byron site. Around February 15, 1902, I called him to relate some of the continuing problems at ::ack, and my concern that neither the utilities nor the :tRC seemed aware of the enormous size of the difficulty.
>!r. Klinger advised me to call Walter Shewski, Corporate QA !!anager for Commonwealth Edison, and once my superior boss when I worked at Byron.
On February 13, 1902, I telephoned Mr. Shewski from the Document Control Center. I related all the concerns described above, and nad 30 N6" ISC _0S,,.:
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DO 30" 1SC 0Si it clear'thatTl was speakinE to him as a varning, because I felt he should know what was going on.
I did not vant to make a formal charge but only to request proper procedure. :-fr. Shewski stated to me that the problemswithZhchhadallbeenidentifiedinthe50.55ereport to the
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':mC through a )iidland audit and that he was not concerned. I veher.ently I
told him that Zack had serious problems and that he should be concerned.
Ir.nediately upon by, arrival the next morning, :tr. Easaiga of Zack
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told me that I had really screwed up (in cruder language) by calline, l
Shewski. He stated thnt f.hr.istine Zack DeZutel, President of Zack, and s
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the entire management of Zacle were upset. He also stated to me that the i
One or t'o days later, Mr. Skates told me that NRC had been notified.
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the Commonwealth Edison LaSalle Site Project !!anager and possibly j
another man stopped Skates.from @ avinh,the site and questioned him about 7
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i the charges I had made.
Comnensing on Feb. 17. 1902, an aud t team from Commonwealth Edison arrived for a three-day inyestication. Doug Brown was the lead auditor, with assistance from Druce l'ood u *hehdid not ask me to participate in N
an' entrance neeting.
I did however, observe the audit, and in ny judgment it was cursory.
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n in Oct. >19El ari audit van performed by Cocnonwealth Edison QA Departrent while I was abser.t, and Howard W Crane discribed the audit to ne as a y
farco. The auditohs:showed lit'tle ' interest in getting to the heart of the matter. Upon beidg requested,to attend the' exit interview, I asked
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Doug Brown if he had
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(1) read the LaSalle contract specs;
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r (2) read the previous audits and surveillances of Zack (Performed
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(Performed by Commonwealth Edison QA)
Uhen Brown said be hadn't read any of these, I decided the exit meeting wouldn't be very productive and declinel to attend. Further, I told Doug Brotm that he was the one who would have to live with the audit, not me.
I have not seen a copy of the report which that audit produced, nor have I ever expressed agreement or satisfaction with its cenclusions.
On Friday, February 19, my otm exit interview took place.
Christine Zack DeZutel, Dave Calkins, Joe DeZutel, !!artin Skates and Don.'!al:ahn -- most of Zack's top management -- were present.
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DcZutc1 began by assuring me that my concerns, as expressed to Zack I
nanagement personnel, would be looked into. Atter that, Dave Calkins
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asked oc to state my opinion ot the present situation.
"ot seeing any point to making serious charges to the group at that time, I did never-theless say that in my opinion, probices with the QA Documentation renained unresolved. Calkins pressed me further to say who I thought was responsible. I named Sir. Eichstaedt--which made tir. Calkins smirk
--and I stated that Eichstaedt seemed too production-oriented, and not quality oriented. !!sterial was being shipped out to the sites, I said, uithout regard for the state of documentation or specifications.
Throughout the interview, I felt very intimidated by the number of managers, the fornal atmosphere and the questioning. As a result. I kept most of my true opinions to myself, knouing that the next day I would no longer be responsible for anything that vent on at Zack.
Although I stopped work at Zack on February 20, 1902, I g W tCLOSE j
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in touch with Terry Howard since that time. I am aware that in May,
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he brought alle6ations of his own as well as mine to NRC Region III.
Despite my willingaess to speak with IEC investigators, I was not
. _' contacted until last weekend for any official investigation.
I have read the above 8-page affidavit, and it is true and
- complete to the best of my knowledge and belief.
meld 9.
L Ronald A. Perry
/D State of Texas Tarrant County
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'Ihis is to certify that Rcnald A. Perry appeared befcre me August 21, 1982, subscribed and sworn to me witch witness hand and soal of office.
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My ccmnissicn expires:
11-10-84 4
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