ML20154G208
| ML20154G208 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/28/1997 |
| From: | Letts B, Elizabeth Wilson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| References | |
| 1-96-043, 1-96-43, NUDOCS 9810130094 | |
| Download: ML20154G208 (30) | |
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Title:
MAINE YANKEE ATOMIC POWER STATION:
FALSIFICATION OF TEST RECORDS BY LICENSEE ENGINEERS Licen:;ee: Case No.: 1 96 043 Maine Yankee Atomic Power Company Report Date: October 28, 1997 329 Bath Road Brunswick, Maine 04011 Control Office: OI:RI Docket No.: 50 309 Status: CLOSED Reported by: Reviewed and Approved by:
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Ernest P. Wilson, Sr. Special Agent Barfy R. Letts, Director Office of Investigations Office of Investigations Field Office, Region I . Field Office, Region I -
Participating Personnel:
Dennis N. Boal, Special Agent Office of Investigations Field Office Region IV I$kO*$00 k N00 9 0
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e SYNOPSIS This investigat' ion was initiated by the Nuclear Regulatory Commission (NRC),
Office of Investigations (OI), Region I, on November 14, 1996, to determine whether two electrical engineers (EEs) of the Maine Yankee (MY) Atomic Power Company, working at the MY Atomic Power Station, Wiscasset, Maine, falsified separate test records in August 1996, which involved the electrical testing of equipment important to safety.
Based on the evidence de:veloped during this investigation, it is concluded that the two EEs falsified test records by deliberately violating technical specification required orocedures that controlled safety related testing.
Specifically, 01's investigation determined that the EEs failed to conduct an electrical test as written in an ap3 roved work order, initialed the test record giving the appearance that tie test was satisfactorily conducted as written, and failed to note the change in the test method that was actually implemented.
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TABLE OF CONTENTS i
EAg2 SYNOPSIS ................................. .
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- LIST OF INTERVIEWEES .......,................... 5 DETAILS OF INVESTIGATION ......................... 7 i
Applicable Regulations / Technical Specification ........... 7 Purpose of Investigation . . . . .................. 7 ,
Bac(ground ............................. 7 ;
Interview of NRC's Senior Resident Inspector ............ 8
' Coordination with Regional Staff .................. 8
- Allegation: Falsification of Test Records by Licensee .
Engineers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9- !
l 3 Evidence ........................... 9 i Review of Pertinent Documentation . . . . . . . . . . . . . . . 9 i The Questioned Documents . .................. 9 Review of Additional Documentation .............11 )
Agent's Analysis . . . . . . . . . . . . . . . . . . . . . . 23 '
Conclusion .........................25 1 i l SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . 27 LIST OF EXHIBITS ............................29 1
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j , LIST OF INTERVIEWEES I
i j Exhibit j
! BARRY, William F'.. Section HeH, Electrical, Instrumentation
- and Control, Maine Yanke Atomic Power Company (MYAPCo) . . . . . . 27 i
BICKFORD, Richard H., Lead Electrician, MYAPCo . . . . . . . . . . . . . 16 DeRUITER Norman " Hank", Electrical & Maintenance Plant Mechanic, MYAPCo . . . ..... . . . . . . . . . . . . . . . . 20 DONATELLE, Emery J. , Quality Control Engineer, MYAPCo . . . . . . . . . . 19 j GREENE, Linda L., Electrical Engineer II, MYAPCo . . . . . . . . . . . . 17 i KULP, David A., Senior Instrumentation and Control Engineer, Yankee Atomic Electric Co. (YAEC) .................25
- MARTIN, Thomas J., Electrical Engineer III, MYAPCo . . . . . . . . . . . 18
. . . 23 l SOULE, Eric D., Manager, Plant Engineering Department, MYAPCo . . . . . . 26 l
l TRACY, William H. Jr., Quality Assurance Supervisor, HYAPCo . . . . . . . 21 1
VFILLEUX, Michael, Manager, Maintenance Engineering, MYAPCo . . . . . . . 24
. . . . . . . . . . . . . 22 i YEROKUN, Jimi, Senior Resident Inspector, NRC . ............. 6 l
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DETAILS OF INVESTIGATION Acolicable Reculations/ Technical Soecification (TS) 10 CFR 50.5: Deliberate misconduct (1996 Edition) 10 CFR 50.9: Completeness and accuracy of information (1996 Edition) 10 CFR 50 Appendix B, Criterion V (Instructions, Procedures, and Drawings)
(1996 Edition)
TS 5.8.2 Written procedures to be established, implemented and maintained to control, among other things, activities concerning testing of safety related equipment (Exhibit 1).
Puroose of Investication This investigation was initiated on November 14, 1996, by the Nuclear Regulatory Commission (NRC), Office of Investigations (OI). io determine whether two Electrical Engineers (EEs nd of the Maine Yankee Atomic Power Co. (MYAPCo), B war ing a Maine Yankee (MY) Atomic Power Station, Wiscasset, Maine, falsified test records on separate occasions in August 1996, which inv ec ogic testing of equipment important to safety. Specifically nd ad initialed off on a Functional Test Instruction (FTI) of Orde )
which required that a volt ohm meter (V0M) be used to verify "open" circuit continuity: the'y allegedly did not use the VOM as required by t1e FTI (Exhibit 2).
Backcround On January 10, 1996, the NRC issued, to all holders of operating licenses, Generic Letter (GL) No. 96 01: Testing of Safety Related Logic Circuits (Exhibit 3). As requested in the GL, MYAPCo implemented testing of the logic circuitry of the reactor protection system.
An NRC s3ecial inspection was begun on August 11, 1996, to review, observe and verify t1e " actions" taken by MYAPCo to ensure that engineered safety features systems would function as designed. The " actions" involved the logic testing of safety related systems, and were in response to the NRC's Independent Safety Assessment Team (ISAT) finding regarding MYAPCo's inadequate safety system logic testing (Exhibit 4).
On August 24, 1996, the NRC's Senior Resident Inspector (SRI) at MY observed a discrepancy during licensee testing of the Safety Injection Actuation System (SIAS), at step 5.3.3 of WO #96 02929 00. Ste used to verify open circuit continuity ("open"p contacts) 5.3.3 required that a5VOM at contact 5c ofbe Relay 86 RASB 2. The VOM, however, was showing resistance in the circuit I '
o y.
Case No. 1 96 043 7 9 wp 4 e
i because, as learned later, an indicator light was wired in parallel on the relay in question. The SRI noted that two previous W0s/FTIs, at the same test step (5.3.3), had been signed off as satisfactorily completed, indicating that the contacts had been verified as "open" usina the V0M. The SRI also noted that the VOM could not ]ossibly have been used on the previous two tests to verify "open" contacts Decause of the indicator light wiring (Exhibit 5).
An allegation review board (ARB) was held at NRC, RI, on November 13, 1996.
and it was determined that OI would investigate the potential that the SIAS test records had been falsified (Exhibit 2).
Interview of NRC SRI Jimi YER0KUN (Exhibit 6)
YEROKUN provided details of what he observed during licensee testing on a Saturday [ August 24, 1996]. On that day, licensee employees were conducting testing on WO #96 02929 00, step 5.3.3, when, using a VOM, they could not get appropriate readings indicative of open contacts. The licensee employees stopped the electrical test, as required by procedure, in order to research the reason the V0M was not showing infinite resistance (open continuity), even though the contacts being checked appeared to be open. A field change to the test was initiated to allow for visual verification of the open contacts. On this occasion, licensee employees correctly followed procedure by initiating a field change to the test.
YER0KUN knew that prior testing of separate trains on the same equipment had been accomplished. He requested to see the FTI documentation because he suspected that section 5.3.3 of the FTI had been signed off as completed, as described in the FTI, even though the VOM could not possibly have shown infinite resistance. YER0KUN found that the arior FTIs, in fact, had been initialed off as satisfactorily completed. T1e test procedure in question is required by Technical Specification (TS).
AGENT'S NOTE: After YEROKUN observed the discrepancy in the test procedure on August 24, 1996, a Minor Technical Change (MTC),
appropriate per TS required procedure, was accomplished by the licensee.
Coordination with Reoional Staff OI kept the Division of Reactor Projects (DRP) apprised of developments during this investigation. Specifically, Harold EICHENHOLTZ, Project Engineer, and ;
Richard CONTE, Section Chief, DRP, were provided periodic briefings on case i progress. ,
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Allecation: Falsification of Test Records by Licensee Engineers Evidence Beview of Pertinent Documentation A MYAPCo memorandum from C. D. FRIZZLE to All Employees, dated November 8, 1990, provides guidance indicating that strict adherence to approved written procedures was required, and that they should be considered management directives (Exhibit 7).
Procedure No. 0 05 1, titled, " Procedure Use and Adherence," was issued on February 2, 1996, and provides that deviation from approved, written procedures is prohibited [with some exceptions not relevant to this investigation] (Exhibit 8, p. 6).
Procedure No. 0 16 3, Rev. No. 10 (Class A), titled, " Work Order Process" (Exhibit 9), was issued on April 29, 1996. This Plant Operations Review i Committee approved procedure describes specific instructions to ensure that '
all departments initiate, plan, approve, schedule, perform, test, and review i for adequacy and completeness, maintenance activities in a consistent manner l (p. 1). The procedure also specifies the following: l That permissible corrections that can be made to an FTI are for l spelling, grammar, or purely editorial errors (p. 33); and 1
- That a MTC to an FTI must meet "all" the following criteria: The handwritten change requires no addition or removal of pages to the WO:
the change can be made in the body of the FTI using available space and is performed in the field with appropriate approval; and the change follows the flow of the WO (pp. 34, and 60 63).
A copy of the FTI for WO 96 02928 00 Rev 0, initiated August 17, 1996, specifically contains the following precaution: "IF any step cannot be completed as specified in this FTI, JTiEN contact the Field Engineer. Any i deviation from this FTI must be authorized IAW Procedure 0 16 3, WORK ORDER l PROCESS" (Exhibit 10, p. 2).
AGENT'S NOTE: This FTI was initialed as "NOT SAT" on August 17, 1996, and apparently resulted in Revision 001 to the WO, infra (pp. 9 and 14).
The same precaution about deviation appears on all FTIs in question.
The Questioned Documents
- 1. Routine WO No. 96 02928 00 Rev: 001, dated August 22, 1996, with the FTI attached, at step 5.3.3, directs, "At MCB [ Main Control Board], Section C verify open circuit continuity at 86 RASA si OM oss the following contacts: 5 5C." The initials are written on the document indicating the FTI s as sat y Case No. 1 96 043 3
I completed and the circuit continuity eas verified as open. This WO has
. red handwriting on the document, the words "using V0M" were crossed off from the FTI text, and the word " visually" was inserted as the manner in which the circuit continuity was verified as open. The handwriting includes MTC #4 and is dated August 28, 1996, as a "backfit " by DAK
[ David A. KULP] (Exhibit 11, pp. 1, 3, 6, and 16).
l The same WO, at FTI step 5.3.3, also includes, in red handwriting, the l following: "3 carallel oaths 2 red Jights 3/3c YP61s" and three separate MTCs initialed bygbefore, and after step 5.3.3 (Exhibit 11, pp. 8 18).
AGENT'S NOTE: oold OI he wrote the words about the 3 3arallel paths on e FTI during his research of the circuit, and le " inadvertently" put the words on the FTI (see Exhibit 23, pp. 33 39), YEROKUN told OI that the original FTI he saw on August 24, 1996, had no clarifyi riting at Step 5.3.3.
Therefore, it would appear that research occurred on or after August 24.
- 2. Routine WO No. 96 02929 00 Rev: 001, with FTI attached, dated August 22, 1996, directs that a VOM be used at the same step (5.3.3) of the FTI to verify open contacts, exa v as above in WO 96 02928 00 Rev: 001. This document has the initials signifying that the step was completed satisfactorily an ne contacts w e verified as open. This FTI indicates "UNSAT," with the initials of A HTC #4 was also backfit on this document on August 28, , w en the words "using VOM" were crossed off, and the word " visually" inserted, as the manner in which the circuit continuity was verified as open. The MTC was initialed by DAK [ David A. KU.LP] (Exhibit 12, pp. 6, 9,15, and 17).
AGENT'S NOTE: Apparently, due to the UNSAT finding by this FTI was reworked in its entirety as reflected below.
- 3. WO 96 02929 00 Rev: 1/FTI, dated August 23, 1996, is identical in its to use a VOM at Step 5.3.3. This document has the initials again signifying that the step was com31eted satisfactorily a ne co acts were verified as open. The same CC #4 was initialed by KULP on August 28, 1996, as above (Exhibit 12A, pp. 2 and 8).
1 AGENT'S NOTE: These FTIs were backfit by KULP after YEROKUN had
.found the discrepancy in the testing. KULP told OI that he put l the word "backfit" on the FTIs so there was no question that it was done after the fact. YEROKUN confirmed that when he observed the previous W0s on Saturday, August 24, 1996, the handwriting on the documents, indicating the change (MTC) from using the VOM to visually verifying open circuit continuity, was not on the documents in question. ,
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- 4. The relevant portion of the FTl dated August 24, 1996/WO No. 96 02929 00 Rev: 1, at step 5.3.3, contains a handwritten sentence indicating the circuits were visually insaected and resistance was 0.003 chms. The initials of LG [ Linda GREE 1E] indicate the test was satisfactory. The ha itten sen LG's initials were crossed off and the initials of were entered showing the MTC of August 24, 1996, to a low for visually verifying the open circuit continuity (Exhibit 12B, p. 8).
AGENT'S NOTE.: This was the FTI and MTC that was accomplished properly in the presence of YER0KUN, When the problem at stea 5.3.3 crose, the test was stopped and the circuit was researcled to find why the VOM would not show open circuit continuity.
Review of Additional Documentation Corrective Action Request (CAR) No.: 96 036 0, initiated on August 29, 1996, as a result of this event, notes the deficiency as, " Work Order Technical Instructions Were Not Implemented As Written." The CAR further notes, that because a MTC was not written to the work package and the step was instead signed as being satisfactory, there was a violation of Procedure 0 05 1, PROCEDURE USE AND ADHERENCE. However, the CAR notes that engineering judgment may have been a factor in why the event occurred and that the deficiency of not following the step literally, by using a V0M, was not considered an intent change to the step (Exhibit 13).
Copies of pages from the Plant Engineering Department (PED) Log Book (Exhibit 14) for shift er on Aucust 25, 190 ontain the fo.llowing relevant notes made by and respectively, about th ssue: ;
At 0000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, wrote about the problems encountered on Au ust 24, 1996, and that circuit research to determine that paralle paths l exist . . . . Therefore not possible to use V0M MTC'd Step to allow ,
visual. Question why didn't we run into this problem before . . . I l believe prior attempts to measure / verify this open contact relied on visual exam because of the blatant / obvious fact that the contact was easily viewed with a wide ga) between the contacts. Step should have been MTC'd to address this c1ange in method earlier . . . it must have been overlooked . . . ."
At 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, wrote his response to indicating that the contacts a een visually verified i.
A color copy of schematic elementary diagram of the circuit in question, as ]roffered by uring his OI interview, contains various handwritten mar (ings, all i nk, with the exception of the words " visually open,"
written in black ink next to contacts 5 and SC (Exhibit 15).
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AGENT'S NOTE: The color copy of this document is being retained in the files of OI:RI.
Interview of BICKFORD (Exhibit 16)
BICKFORD has been em)loyed at the MY plant for 15 years. BICKFORD, a lead electrician, was wit 1 EE GREENE on Saturday, August 24, 1996, to conduct special testing at the MCB. The testing was required to ensure operability of electrical circuits that control ] umps on the reactor coolant system. The pumps are safety related (Class 1E) and the testing was required by the NRC prior to restart of the plant.
GREENE had the WO/FTI in her possession and called out to BICKFORD what needed to be done, step by step. FTI step 5.3.3, as written, called for the verification of open contact's using a V0M. At that step, BICKFORD got unusual readings with a V0M. The V0M reading showed some resistance. This reading did not represent open contacts, but rather, closed, even though the contacts looked as if they were open.
As indicated on the FTI, GREENE wrote a sentence depicting what they found, i.e., that the contacts looked open from a visual inspection, but that the V0M showed some resistance. At some point, she initialed the step as satisfactorily completed. BICKFORD said he told GREENE that it wasn't right to merely view the contacts as open because FTI ste) 5.3.3 specifically directed that contacts were to be verified as open ay "using a VOM." It is common knowledge at MY, and is constantly emphasized, that if a test procedure can't be completed as written, then you must stop and evaluate the situation.
GREENE stopped at that point, and together they called a field engineer responsible for the FTI. GREENE eventually crossed off the sentence she had written, as well as her initials that signified a satisfactory test, and initialed the cross offs.
BICKFORD said YER0KUN was in the control room on August 24th and noticed the problem they were having. YER0KUN was able to view the contacts and see that they appeared to be open. However, YER0KUN asked wh the same problem wasn't detected before. The previous FTIs/W0s were pulle te ,the step in question (5.3.3) had been initialed off by nd hasif satisfactorily completed as written. BICKFORD sai impossib for them to have successfully utilized a VOM to verify open contacts. BICKFORD knew it was impossible because after he and GREENE ran into the problems on August 24, 1996, the schematic drawing of the circuit was retrieved and it showed that wa ht bulb (resistor) wired on the circuit. BICKFORD opined that an ere required to stop at the point of step 5.3.3, investigate ne proble initiate a MTC.
After BICKFORD's shift ended on Aug 1996, M was briefed about the problem encountered. BICKFORD told in passing, words to the a "try to figure how your goi a get- f t11s one," in light of procedural non compliance. id not indicate to BICKFORD at ime F' PU' 'C .I 'C L U ,W :
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l th e neu about the light bulb wired on the circuit, or that he a air ady seen the schematic of the circuit in question, opined that some of what is written i CAR of August 29, 1996, is or example, BICKFORD does not believe had a " full unders an ina" ne circuit in question, as is written in t Res3onse, becaus i didn't act like it or say anything about it during the s1ift change on August 24, 1996. Also, there were no field prints or schematic drawings in -
the WO/FTI package that he (BICKFORD) and GREENE were working with until aflet they researched the problem on August 24, 1996. BICKFORD also doesn't agree with the sentence on the CAR that says, step 5.3.3 allowed for the " option" to verify open contacts with vision or a meter; as step 5.3.3 was written, there was no option available.
Interview of GREENE (Exhibit 17)
GREENE has been employed with MYAPCo for the last five years. GREENE has a BS ,
in EE. GREENE was involved with WO No. 96 02929 00 Rev. No.1, which included I an electrical test to prove operability of a pum). The test was conducted on l Saturday, August 24, 1996, by BICKFORD and was caserved by GREENE. The 1 Saturday test was actually a retest of the same train, but GREENE was not !
aware of the results of the previous test. j GREENE said that each step of the WO was completed before the next test step was begun. Step 5.3.3 required use of the V0M to verify open circuit continuity, but she and BICKFORD noticed abnormal readings on the VOM: it was not giving readings which verified that the circuit contacts were open, but rather, it gave readings indicating that the circuit contacts were closed.
GREENE and BICKFORD immediately stopaed the test and sought guidance, per procedure. She tele answered the phone. phoned KULP at t1e MY staff building, however, MARTINMA visually observed as open, the test step was satisfactorily accomplished and she could go on to the following step. GREENE then wrote on the WO, " Visually inspected & resistance with of [ sic] 0.003 ohms: SAT," and initialed the step (see Exhibit 12B, p. 8).
GREENE and BICKFORD discussed the issue further because step 5.3.3, specifically, required verification of open circuit contacts using the V0M.
GREENE crossed off her sentence about visually inspecting the contacts, as we er initials. At or about the same time, the shifts were changing, was taking over the WO duties. GREENE e la ned the situation to she and BICKFORD then left. Apparently, 'nitiated a MTC after ecKing the' circuit drawings and finding that a resistor was wired in. The resistor made it impossible for the V0M to show infinite resistance.
During her discussion with BICKFORD, she retrieved the W0s for the previous tests and found that step 5.3.3 had been initialed off b as written, i.e., that open circuitry had been verified using the V0M. ENE said a MTC should have been initiated during the previous two tests.
1 Case No. 1 96 043 13 1
GREENE was interviewed by MYAPCo's BARRY for the Response to the CAR. GREENE had the following concerns with the way the CAR and Response were written:
(1) that " engineering judgment" was really not an issue for the test step in question because the procedure was soecific in its direction to use a V0M:
(2) that the V0M readings were not open to interpretation as was written in the CAR / Response: (3) that using the V0M or visually observing the contacts was not an option: (4) that it was mere difficult to visually observe the open contacts than it was to use the V0M in the cramped space at the MCB: and 1 I
(5) that the corrective action discussed in the response to the CAR was merely a routine meeting, not a special meeting to discuss the issue.
Interview of MARTIN (Exhibit 18)
MARTIN has been employed with MYAPCo since August 1992. He has a BS in EE. l The FTI in question should have accounted for a bulb wired on the circuit at step 5.3.3, which, as it turned out, was the reason for the aroblem verifying 1 the open circuit with the V0M. MARTIN opined that if a MTC 1ad been initiated at the first sign of the problem with the V0M, there would have been no need 1 for concern.
MARTIN said the Saturday test [ August 24,1996] was actually a retest of the same system. MARTIN's understanding was that this was the third attempt to complete the testing in question. Apparently, the V0M showed some resistance in the circuit when it was supposed to be completely open.
MARTIN said GREENE and BICKFORD had stopped the test and sought guidance, per procedure, which required Coraorate Engineering Department (CED) involvement, since CED wrote the FTI. GREENE telephoned KULP to seek such guidance, however, he (MARTIN) answered the telephone. MARTIN told GREENE that as long as the contacts could be visually observed as open, the test step was satisfactorily accomplished, if that was the way the previous tests of the circuits were done. He suggested GREENE retrieve the W0s for the two previous tests and find out how step 5.3.3 had been completed.
GREENE called MARTIN back a short time later and advised that a MTC was required. He was told the NRC SRI had arrived and was asking questions about the problems encountered with the test procedure, and specifically, why the problems were not detected during the previous tests. iARTIN learned tha 5.3 d been initialed as satisfactorily a e + e ., u the VOM, by an' "
GREENE turned the shift over to nd. then initi d the HTC.
MARTIN said a MTC should have been initiated for the previous two tests and failure to do so is an apparent violation of procedure. MARTIN does not recall seeing the schematic drawing of the circuit in question in the WO package on August 24, 1996.
MARTIN was not interviewed by anyone for the Response to the CAR. MARTIN expressed the following problems with the information in the CAR / Response:
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that engineering judgment was really not an issue because the procedure was specific in its direction: the V0M readings were not open to interpretation, as was written in the CAR / Response; and that using the VOM or visually a
observing MARTIN the knew contacts of no was disciplinary notbeing action an option meted out (asagainst the CAR response ar $w tes Interview of DONATELLE (Exhibit 19)
DONATELLE has a BS in Electrical Engineering Technology. He has been employed in the Quality Programs De3artment (QPD) of MYAPCo. at MY, since May 1990.
DONATELLE was involved wit 1 the general logic testing that, in part, resulted from NRC GL 96 01. The system in question is safety related, in that, it involves the operability of pumps on MY's cooling system. The test in question was actually a retest of the same system that had previously failed.
DONATELLE said he received a call from BICKFORD in the late morning hours of August 24, 1996. BICKFORD said that he and GREENE were having a problem with the testing at stea 5.3.3 of the FTI, i.e., the VOM was not showing open contacts. Later, 20NATELLE met with BICKFORD and GREENE, and by that time NRC's YER0KUN was in the control room asking questions. DONATELLE saw that BICKFORD and GREENE had retrieved the schematic drawing of the circuit in question to try and determine why the V0M would not verify open contacts.
Eventually, a MTC, per procedure, was initiated at step 5.3.3. The MTC allowed for the contacts to be verified as open by vision. DONATELLE initialed off on MTC No. 4 as the required QPD representative.
DONATELLE said that William TRACY, Quality Assurance Supervisor, QPD, asked him to put in the note at Section 5.3.3 of the FTI about "backfit" of the earlier tests; this was purportedly to complete the CAR. DONATELLE did so on August 28, 1996, with red ink. DONATELLE could not recall if the phrase about
" parallel paths," also in red, was written on the document at that time, nor could he identify whose writing it was.
Upon learning on 24, 199 ut the earlier Section 5.3.3 procedural non complia he told hat he was an " idiot" for not following or dure, gree that he sh d have done a HTC before August 24, 1996.
old DONATELLE t searched the circuit, behind and in front of the control panel, in his vestigation to try and find out why the V0M was giving abnormal reaaln . id not mention researching the schematic of the circuit.
Interview of DeRUITER (Exhibit 20)
DeRUITER attended two years of college been employed by MYAPCo for the past seven years. DeRUITER worked with n the WO in question on August 22, 1996, before, during, and after step 5.3.3. DeRUITER was aware that Step 5.3.3, as written, required the use of a VOM to verify open contacts.
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At step 5.3.3, DeRUITER use'd the V0M as M bserved. The contacts were visibly open but the V0M was showing "a TT1 tie bit of resistance." The contacts could not be verified as open using the V0M because, as they rned that day, there was a bulb wired on the circuit they were testing. and DeRUITER visually observed the open contacts as DeRUITER held a fl t.
DeRUITER recalled that SNOW had a stack of schematic drawing rious circuits they were to test that day. DeRUITER believes that ooked at the schematic of the circuit in question before h 'de it was sufficient to merely ver fy the open contacts by vim . They agreed the contacts were open and nitialed off on the test step as satisfactorily completed.
DeRUITER could not recall if wrote any words on the schematic drawing, or
, as they moved on to t test step. A MTC was not initiated by DeRUITER said it was esponsibility to initiate the MTC if he deemed it ne ary. ER was not aware if any discialinary action was taken agains as a result of not initiating a MTC. DeRJITER was not disciplined.
DeRUITER does not consider the test WO to have been falsified at step 5.3.3, even though he agrees the VOM could not have verified open contacts. He said open contacts were ultimately verified by vision. The intent of the test was to verify open contacts. The contacts were, in fact, open. In s pect.
DeRUITER believes ' hould have initiated a MTC, just as he nad done on August 22, 199 , a other steps of the WO.
Interview of TRACY (Exhibit 21)
TRACY has a BS degree in Electrical Engineering Technology and has been employed with MYAPCo since February 1981: he has been in his present position (QA supervisor) since May 1995.
1 TRACY was responsible for initiating the CAR to attempt to document what actually happened during the testing procedure in question. TRACY, and BARRY of the Plant Engineering Department (PED), interviewed various individuals that were involved in the testing to determine the root cause(s) of the i deficiency. Pages two ee of the CAR and Response were basically arepared by BARRY and/o Generally, they found that a violation of
)rocedure 0 0501 (Procedure se and Adherence) had occurred because the engineer did not write a MTC to the work package, but instead, signed the step as being satisfactory. However, according to the CAR Response, engineering judgment had been ap311ed, which led to the engineers being satisfied that the contacts they were elecking were, without a doubt, open. After satisfying himself that the Response to the CAR appeared to be reasonable and logical, TRACY closed out the CAR on November 18, 1996.
Throughout the CAR process, TRACY never became aware of any information which would indicate that any of the engineers involved in the testing intentionally falsified the WO instructions. TRACY opined that it appeared the test 5,
Case No. 1 96 043 16
procedure was not strictly adhered to, but the engineers had visually determined that the contacts were open, which was the sole objective of the specific test step. TRACY knows the engineers that were involved, and he 031ned that they did not deliberately falsify the test procedure. Further, t1e Response to the CAR indicates that one engineer's field prints had been annotated with the words " visually open." TRACY claims this is indicative that there was no effort to conceal the manner in which the test was conducted. TRACY believes the field prints referred to in the CAR Response are the actual drawings the engineer was working from while conducting the testing at the MCB.
Interview / Sworn Statement oi (Exhibit 22) said he pa cioated in FTI WO No. 96 02929 00 Rev. 1, which began on ugus 22, 1996. dvised that the V0M readings on the test ste) in question were obv m not consistent with open contacts. He said t1e testing was being conducted in tight space which contri ed to the difficulty in conducting the required testing of the relays. Whe nd hi technician could not get the appropriate V0M readings a 5.3.3 determined that it was not necessary to use the V0M again, be at contacts, as they both clearly saw, were obviously wide open. hought that it would be satisfactory to verify the cen contacts by gnt ly.
After agreeing that the contacts were open, e the decision that the VOM would not be used on that specific relay. denies that he intended to falsify the test record. As he rea he FT at tep 5.3.3, it was his job to verify that the contacts were open. claims he did that, and had a second person confirm that the contacts we in fact, open.
said he probably discounted doing a MTC because he did not believe that l was required by procedure. He believes the change [in how he verified open contacts] was more editorial, not technical in nature, because the contacts were definitely coen nd was proven as such by his sight and the sight of hi te b ician, had done MTCs in the past and was familiar with them. .laims e o10 not disregard the FTI or the MTC process.
has since learned that the test procedure for step 5.3.3 was not c ectly written because it did not take into account the fact that there was a light bulb wired on the circuit. He said he did not pull the drawings of the circuit before deciding that the mnbets would be visually verified as open, rather than by using the VOM. .dmitted that he di not have a full understanding of the circuit at tnat time. However, claims that because of his experience, he decided it was adequate to mereiy view the caen contacts as verification. There was never any question in his mind that t1e contacts at step 5.3.3 were open, despite the abnormal readings from the VOM.
Case No. 1 96 043 17
? .
said he never looked at the drawing of the circuit to see why the V0M i
was giving abnormal readings at step 5.3.3. Sometime after the fact, someone
- apparently had the same difficulty using the VOM at step 5.3.3 and had learned ,
! of the bulb being wired into the circuit. A MTC was then entered by someone l 1 else.
j \said he had CAR at or about the time it was prepared
( ugu t 2 1 as interviewed by BARRY for input to the CAR
) ld BARRY that he didn't agree with the notion that
, Response.
! a MTC sho been entered and because he didn't d a MTC, there was a
! violation of procedure or a procedure non com liance. laims he did not receive any disciplinary action as a result hissevent. s far as the 3'
corrective action listed in the CAR Response s fairly certain that the event was discussed in a routine PED morning mee ing in a " lesson: learned"
- atmosphere. He does not recall any special meeting being held, and is not i aware of any disciplinary action being taken against anybody involved in the i W0s in question.
1 I i claims he had nothing to gain by not following the FTI or the procedure no describes the MTC, and the bottom line contacts in question were !
- open. However, after further consideration, eknowledged that he can see how someone might construe that he viola test procedure because he j j didn't literally follow the instructions to the letter by using a V0M (which
^
couldn't have worked) to verify the open contacts, j claims it was not his intent to circumvent the test procedure by not I using the V0H. He reiterated that the intent of the test procedure was met.
I i
Although not saecifically mentioned in step 5.3.3, WYTAS believes it is !
i implied that t1e contacts could be verified as open through whatever means )
were available at that time.
Interview of .
(Exhibit 23)
! was nowledgeable that the testing in question was, at east in part, a resu of the NRC's ISAT findings and, irectly, a l greed that i requirement of GL 96 01 issued by the NRC (pp. 11 and 12).
! W0s drive the FTI one FTI in question was signed off on i August 22, 1996. ndicated that the WO in question was safety related, j class 1E, which with performing a nuclear safety function (pp.17 20).
i On August 22, 1996 as g with DeRUITER on WO No. 96 02928 Rev. 1, l that he had entered MTCs prior to i
when the steo they got to step (pp.3.3.
in question . 25- . aid they attemated to use the VOM at j step 5.3.3 to verify open contacts, as irected in the UI, but got a reading snewing some resistance, wh c' is indication that the contacts were not aid he viewed the contacts with a flashlight
- completely open. However, i F $ F C 0 ,
Case No. 1 96 043 18 i
. _ , . - 4. - . . . . . . . -
. . . . . . _ . . . . - . _ _ _ . . ~
and saw that they were clearly open; he claims he saw an air gap between the subject contacts (pp. 29 and 31) as shown (by OI) the original of the WO/FTI in question and was asked to comm nt on the writing in red on the document (see Exhibit 10). He denied that he crossed off the words o I "using V0M" or that it was his writing of the word " visually." dmitted that the words about the 3 parallel paths were his handwrit .
He claims he entered those words "several days later," after both tests (FTIs Nos. 96 02928 and 96 02929) had been completed-and he was reviewing the WO. He wrote the words to indicate the reason the VOM was not giving the indication of open contacts. He claims he " inadvertently" made the notes directly on the FTI as he was concentrating on the schema nt of the circuit to gather an understanding of it
"(pp. 33-39). laims he had a 3ersonal copy of the circuit print,
. . . in my pocKe . , . , the nig1t of the test with DeRUITER, and after the tests were completed and the NRC detected the problem on August 24th, he went back through the test to reconstruct what he di g 22nd. It was then that he made the notes on the FTI (pp. 39 41). roduced (for 0I) a copy of the schematic drawing that he claims he had on e night he did the test at step 5.3.3. The undated drawing has the words " visually open" written across the contacts in question: the note is also undated. He claims he wrote that on the drawing after he investigated the circuit to find the reason the V0M was not indicating open contacts (pp. 42, 43, and 80).
tated that on the night of the first FTI, he understood the condition of e circuit a is why he wrote the words " visually open" on the drawing (ap. 45 48). dmitted that he consciously did not initiate a MTC even t1ough Procedure . 0 '.6 3 directs that if a test can't be completed as written then a MTC should be initiated. He said he decided that it would be okay to verify the open contacts by vision because that was the intent of step 5.3.3. He knew that the FTI, as written ~, did not take into account the bulbs on the circuit, and further, a subseg ep of the FTI verified the function of the circuit in question. ontends that a visual inspection was an acceptable means to verify th pen' contacts. He admitted, in hindsight, that he shou a e done a MTC the first time he ran into the problem at step 5.3.3.< pined that changing the test method from using a VOM to verifying open contacts visually is not a strict editorial change (pp. 48 57, 86, and 87).
dvised that he relieved GREENE from a shift while the NRC inspector was esent in the control room [Aug 1996]. The problem with step 5.3.3, at that point, was a " big deal." xplained that GREENE had difficulty using the VO ep 5.3.3 and empting to learn the reason for the difficulty. tated that he "would assume" he explained to GREENE his understanding o e circuit conditions that prevented the meter from reading properly, since he had an understanding ircuit based on his review of the schematic drawing (pp. 101 and 105). new the SRI was present and H he was aware of difficulties encounter ith Step 5.3.3 (pp. 67 and 68).
aid he then did a MTC right away [on August 24,1996] and obtained the Case No. 1 96 043 19
required approvals, per procedure, because the FT estion was aart of a
" level 1" safety related work order (2p. 74 77). enies that le intentionally circumvented the FTI. ie claims h he intent of the test step and a MTC was not warranted because the change did not involve an intent change (pp. 89, 90, and 111).
aid.the procedural non compliance identified in the CAR was discussed wi his supervision and with QA, is not aware of any disciplinary action being taken against him o He said he might have been told that he had to follow procedures as wr1 pp. 115 and 116).
oes not believe he was consulted when KULP did the backfit for the MTC.
is not aware of any requirement to be consulted for the backfit, as long WLPto KULP, r' he condition of the circuits and the situation. If he did talk said he probably explained t what he knew of the technical situation using the field prints. Howeve was not certain if he had talked to KULP about the issue (p.140). elieves he would have shared what he knew about the c with YEROK August 24,1996] but he could not be sure that he did: wasn't sure he had the field prints with him on that occasion (pp. 142 1 .
In response to a direct question from OI concerning when he wrote t s
" visually open" on the field print next to the contacts in question after a private discussion with his attorney, responded, ". . . to t e of my recollection . . . " he put the words on the print the first time he ran the test, August 22, 1996, after he had a full understanding of the circuit in question (pp. 150 152).
Interview of VEILLEUX (Exhibit 24)
VEILLEUX has worked for MYAPCo since ' December 1978. He has a BS in Mechanical Engineering (pp. 7 and 8).
VEILLEUX stated, " Procedural adherence is procedural adherence. You don't have a choice. You do what the procedure says, or you get the procedure changed." He said that has been a major focus of Maintenance Engineering, of which he is the manager (p. 15).
Interview of KULP (Exhibit 25)
KULP has a BS degree in Electrical Engineering and has been employed by Yankee Atomic Electric Co. (YAEC), Bolton, Mass, for the last 16 years. He is a senior instrumentation and control engineer who 3rovides engineering support to the MY plant (pp. 3, 7, and 8). KULP was at iY for safety related testing that, in aart, was required as a result of the ISAT audit by the NRC and GL 96 01. T1e pumps that were tested were " Safety Class 1E," the highest electrical safety classification (pp.1012). KULP stated that he wrote the FTI in question. He added, "It was kind of a rush situation to bring the I C
~
(~
,J 'l iq i Case No. 1 96 043 20
,1
plant online." The intent of step 5.3.3 was to use a VOM to verify open contacts and to identify the VOM used by its serial number (pp.14 and 24).
KULP stated that he did the MTC No. 4 "backfit" on an FTI on August 28, 1996, noted it on the WO, and initialed the MTC. He crossed off the words "using VOM" and changed it to read " visually." The other writing in red on the FTI t not his (pp. 2123).
AGENT'S NOTE: at f ad that the additional writing in red on the FTI belonged to ur KULP advised that the first time the test could not be completed, as written in the FTI, it should have been sto with the appropriate ap3rovals (pp.pped 25, 26,and anda 52).
change KULP should does not have been an believe made intent change was made ]y visually verifying open contacts, instead of using a VOM, because, he opined, they can be used interchangeably, depending on the situation. However, KULP reiterated that a MTC should have been initiated the first time the test could not be run with the V0M (pp. 3133). He said the MTC required approvals of various departments before the next FTI step could be run (pp. 34 37).
KULP stated that nobody informed before August 24, 1996, that step 5.3. d not be completed with a V0M (p. 3 believes he had discussion wit on, or after, August 24, 1996, an robably indicated to him that h visually observed the open contacts. e contacts on the relay in question can easily be seen open (p). 42 and 43). KULP does not believe that anyone pulled from their pocket t1e schematic drawing of the circuit in question and offered an explanation as to the reason the VOM could not have worked at step 5.3.3. He thinks he and'DONATELLE pulled the drawing on August 24th to review the circuit in question. The drawings are sized at 21 by 36 [ inches] and are not typically taken into the field (pp. 49 and 50).
KULP has no knowledge that orh'ntentionally falsified the test results (p. 52). Howevar, L acknoTw edged that the FTI, as written, did not allow for the option of visually verifying the open con he , "I'm not sure there was an option." He is unaware if either had the drawings with them during testing, although they were avali et em
( 3. 66). KULP was not aware that there had been a schematic urawing that had t1e words " visually n" ri nereon regarding this issue of (p. 67).
KULP was not awar7 o or discussing the matter with anyone before deciding if ontacts sually instead of using the V0M. KULP believes nd at a minimum, should have spoken to someone form CED, and writ the W FTI what they had done to verify that the contacts were open (pp. 69 and 70).
Interview of SOULE (Exhibit 26)
SOULE has a BS degree in Mechanical Engineering and Technology. He has been emplo ed at MY for fourteen years (pp. 7 9).
0 Case No. 1 96 043 21
SOULE advised that he was a reviewer of the CAR and Response that was created as a result of the procedural non conformance regarding the failure to initiate a MTC, and failure to follow a W0 as written. He said, to his knowledge, the CAR and Response, are accurate. He said the Response to the CAR was written by BARRY. SOULE indicdted that it is a well known principle at MY that people are supposed to adhere to procedures as written (pp.1012, 15, and 25).
SOULE advised that when a V0M could not be used to conduct the FTI step as written, the testing should have been stopped and a MTC should have been initiated, in accordance with Procedure No. 016-03. He said that mistakes were made. SOULE said that the engineers used engineering judgment to meet the intent of the test, which was to verify open contacts: however, their arocess judgment was a mistake, because the step directed that a V0M be used.
de opined that since the engineers didn't use a VOM there was a procedural noncompliance. However, SOULE said the test result was valid (pp. 22 25, 27, and 28).
SOULE said that he would characterize the mistake by the engineers as an honest one, with no intent to falsify test results or records. He bases this assessment on his knowledge of the individuals (pp. 23, 37, and 42).
Interview of BARRY (Exhibit 27)
BARRY has a BS degree in electrical engineering and has been employed by MYAPCo for about six years. He is a professional engineer and the section head of Electrical and Instrumentation Contr P h reports to SOULE.
BARRY is responsible for the supervisi.on of nd GREENE (pp. 11, 13, 14, and 15).
BARRY acknowledged his involvement in the preparation of a portion of the Response to CAR No. 96 036 0. ~ He interviewed those involved in the deficiency and ty3ed the Response based on their input. As he indicated in the Response.
BARRY Jelieves the engineers had a full understanding of the circuits being tested, at the time they were being tested, which allowed them to deviate from the test instruction. BARRY based his conclusion on interviews he had with the engineers and his personal review of the circuitry in question (pp. 15 28).
AGENT'S NOTE: BARRY's statement abou nd aving a full understan the circuit at the time ,e test wa accomplished is suspect. dmitted to OI that he did noj; have a full understanding of the ci nd that he had only told BARRY that he didn't agree a MTC was warranted (see Exhibit 22, p. 5).
BARRY explained that a MTC requires various levels of approval before it is implemented, and before moving on to the next st p. 32 3 m RY stated that he was told in August [after the event] by that h ad a drawing of the circuit in question folded up in pocket. assumed Case No. 1 96 043 22
that h ad the drawing during the testing in question, but was sure if SNOW had actually reviewed the drawing as the test was being run, also had written the words " visually open" on the drawing, but BARRY cou ot say when the words had actually been written thereon (pp. 39 and 47).
BARRY had no information indicating that or , ad intentionally falsified a document, or desired to bypas 5.a.0 for any reason (pp. 40, 41, and 60). BARRY did not recall asking hy he did not enter into a MTC at the time of the test (p. 48).
BARRY conten ,i form of disciplinary action, he issued a verbal reprimand to nd s a result of the procedural noncompliance that was identifi he C BARRY said he gave the verbal reprimands individually, not in a group meeting (p 48, 49, 58, and 59).
AGENT'S NOTE: Neither ,or ere aware of any disciplinary action, including repriman s, be ng Tssued to them. GREENE acknowledged that the CAR, of which BARRY was a principle author, appeared to be an effort to " pencil whip" the problem away.
Acent's Analysiji It is common knowledge at MYAPCo and MY that strict adherence to written.
approved procedures is mandatory. This philosophy was reinforced in November
. 1990 by t1e then Chief Executive Officer, Charles FRIZZLE, in a memorandum to all employees (Exhibit 7). The memo directed that written procedures be strictly adhered to. All of the employees interviewed by OI were aware of Procedure No. 0 05 1 requiring adherence to written procedures. NRC's YER0KUN advised that the "0" series procedures at MY are required by plant TS 5.8.2.
MY interviewees, including 1 nd confirmed that the logic testing at issue involved safety related eq61pmen . 'They were aware that the testing was being conducted, at least in part, as a result of NRC GL 96 01, and more importantly, because of an ISAT finding regarding inadequate safety system logic testing and the subsequent identification 'ssi in a high pressure safety injection pump control circuit. n ere cognizant of the importance of the logic testing and the r ulrement here to l written procedures. Testimony indicates that the FTIs in question were a part of the WO, and that the W0s were controlled by'"0" series procedures.
nd dmit that they did not conduct the logic testing at stea 5.3.3 l FTI as ire .e., by verify open contacts using a V0i. On !
the occasions whe (one time) and two times) conducted the test at step 5.3.3, NRC's ROKUN was not prese observe the testing. When YEROKUN was present on August 24, 1996, GREENE and BICKFORD stopped the test and researched the circuit to learn why the V0M was showing results that were inconsistent for open contacts. It was discovered that due to the condition of the circuit (bulb wired in), it was not possible to verify the open contacts solely by using a V0M. The FTIs clearly and specifically direct R
Case No. 1 96 043 23
i that, "IF any step cannot be completed as specified in this FTI, THEN contact the Field Engineer. Any deviation from this FTI must be authorized IAW l Procedure 0 16 3, WORK ORDER PROCESS." In accordance with Pr a ure 16 3 a MTC should have been initiated (Exhibit 9, pp. 34 and 60). an in retrospect, admit they should have initisted a MTC. -
There is no dispute that a deviation from Step 5.3.3 occurred because the use l of a V0M, as directed in the FTI, was not capable of ng ircuit continuity. The deviation from the FTI occurred when and decided, on their own, that they would not conduct the test as wr1 ten i I, and gad, would only use vision to verify open contacts. Neithe nor Imade any clarifying marks on the FTI or WO to notify anyone ne change in le test process on the safety related equipment. They did not initiate a i MTC. They contend that even though they deviated from what was explicitly written in the WO/FTI, they still met the intent of the test step, which was to' verify open contacts, sserts that he had a full understanding of the circuit at the time that ie eviated from the FTI. He claims he reviewed his personal copy of the drawing of the circuit during his first attempt at testing and n the subject contacts the words " visually open." On witness, subordinate electrician, DeRUITER, told OI that did ha " of drawings with him, but DeRUITER was not a to hethe rote any words on the drawings on that occasion. .estified tha d his undated, personal drawing in his pocket.
LLE told OI tha ad mentioned to him, after the fact, that he had researched t e circuit at th rol board to find out why the V0M t producing expected results, but id not mention anythjng about g t1e schematic drawing, or of revi it, to determin roblem.
also did not mention the drawing to YER0KUN, even though estified when he came in to the contr on Saturday, August 96, the issue was a " big deal ." Further old OI that he assumed he mentioned his review of the drawing to GREEN o August 24, 1996, and explained to her th on for the problem. However, GREENE apparently was not told anything b ebout the circuit or the drawing. BICKFORD, a detail oriented e ia credible witness in the view of OI. Tv RD said he confront ith the procedural non compliance, and, t defend himself ,
ing BICKFORD what the circuit drawing showed; does not recall being confronted by BICKFORD.
Since this issue was a " big deal" on August 24, 1996, and YE was asking questions about the testing of the circuit. OI believes tha would have gone out of his way, at that time, to rovide his understan ng of the circuit to someone, particularly if he re d a copy of the drawing with the words
" visually open" written thereon. id not do so.
Circumstantially, OI believes tha researched the schema e awing after l YER0KUN made the previous tests an is e on August 24, 1996. laims he f
I Case No. 1 96 043 24
o -
" inadvertently" put the words about 3 parallel paths, etc., on the FTI, while he researched the circuit. YER0KUN saw the original FTIs on August 24, 1996, and there was no extra writin he document at step 5.3.3. 01 believes it is more likely than not, tha went back to the original FTI and put the words on the docum an e to ex < justify what he had done, after the fact. wn 1 to on August 25, 1996 (Exhibit 14), fails to m ion t at he had 11 understanding of the circuit condition during the prior tes ,
wrote that the test was completely redone [on August 24,1996] and ". . . circuit research to determine that perallel paths exist . . .," which led to a MTC. He did not write that he had dor,e the circuit research previously by reviewing his personal drawing, which he supposedly had in his pocket. He also included in the note his belief, not his declaration, that the prior attempts to test the circuit relied on visual exam and that a MTC must have been " overlooked."
Further, when pressed by OI as to when h rote the words " visually open" on his personal copy of the drawing after private consultation with his attorney, indicated that, ". . . t best f h' recollection," he did so when he first did the test on August 22, 1996. {
id not I affirmatively attest, without the caveat of "best reco ion," that he wrote i the words on the drawing when he first did the test and encountered the VOM problems (Exhibit 23, pp. 150 152).
l
. cknowledged that he did not have a complete understanding of the i YFrcu'it in question when he decided to verify the open contacts by vision. He I claims he relied on his work experience. He contends that he merely made an I editorial change to the FTI, and that was the reason he did not believe a MTC l was recuired. This argument, however, is weak, because the test process was changec from using a technical of equipment, a V0M, to visually verifying open contacts. Eve ndicated to OI that the change made to I
the FTI (from using V0M to visua is not purely editorial. Even if the change was' purely editorial, Procedure No. 0 M- equires that the FTI be annotated and initialed (Exhibit 9, p. 60). id no such thing.
The very real possibility existed that this test process deviation would have gone undetected had it not been for YEROKUN's presence in the control room on Saturday, August 24, 1996, since the previous tests of the same system had been initialed as satisfactory.
Conclusion Base e developed during this investigation, it is concluded that nd alsified test records by deliberately violating TS requ l proce ures that controlled safety related testin ifi OI s investigation determined that, on separate occasions, n ach failed to conduct an electrical test as written in an appro ,i ed the test record giving the appearance that the test was satisfactorily conducted as written, and failed to note the change in the method that was actually implemented.
Case No. 1 96 043 25 1
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SUPPLEMENTAL INFORMATION Given the involvement by the United States Attorney's Office (USA 0) for the i
- District of Maine on another matter investigated by 01 (Case No. 1 95 050).
OI:RI was asked to keep the USA 0 apprised of developments in this case. OI:RI
, did so. Upon completion of the field work, the USA 0 declined criminal prosecution in this matter in favor of administrative action by the NRC, as i deemed appropriate.
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Case No. 1 96 043 27 l
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- ' y LIST OF EXHIBITS Exhibit No. Descriotion 1 Excerpt from MYAPCo Procedure No. 0 06 2 Administrative Controls 4
for Prccedures and Procedures Changes, issued August 24, 1996.
2 Investigation Status Record, dated November 14, 1996.
3 NRC Generic Letter No. 96 01, dated January 10, 1996.
4 NRC Letter, dated November 20, 1996, to MYAPCo,
Subject:
NRC Special Inspection.
5 Allegation Receipt Report, dated November 12, 1996.
6 Interview Report of Jimi YEROKUN, dated December 12, 1996.
7 MYAPCo Memorandum,
Subject:
Procedure Adherence, dated November 8, 1990, to all employees.
8 MYAPCo Procedure No. 0 05 1, " PROCEDURE USE AND ADHERENCE " issued February 2, 1996.
9 MYAPCo Procedure No. 0 16 3, " WORK ORDER PROCESS," issued April 29, 1996, 10 FTI for WO No. 96 02928 00 Rev. 0, dated August 17, 1996.
. 11 WO No. 96 02928 00 Rev: 001, dated August 22, 1996, with FTI !
attached.
12 WO No. 96 02929 00 Rev: 001, dated August 22, 1996, with FTI attached.
12A WO No. 96 02929 00 Rev. 1/FTI, dated August 23, 1996.
128 00 Rev. 1/FTI Step 5.3.3 Initialed by Linda GREENE
, dated August 24, 1996.
13 Corrective Action Request No. 96 036 0, with Response, closed out November 18, 1996.
14 Handwritten PED Log Book entries for August 26, 1996.
15 MYAPCo Elementary Schematic Drawing, undated, with handwritten notations.
Case No. 1 96 043 29
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16 Interview Report of Richard H. B1CKFORD, dated March 18, 1997.
17 Interview Report of Linda L. GREENE, dated February 19, 1996, with Attachment.
18 Interview Report of Thomas J. MARTIN, dated March 19, 1997.
19 Interview Report of Emery J. DONATELLE, dated March 20, 1997.
l 20 Interview Report of Norman " Hank" DeRUITER, dated March 20, 1997.
i 21 Interview Report of William H. TRACY Jr., dated February 4, 1997, with Attachment, i 22 Interview Report of ,
ith Sworn St 23 Transcribed Interview of i
i 24 Relevant Portion of Transcribed Interview of Michael VEILLEUX, dated February 20, 1997.
25 Transcribed Interview of David A. KULP, dated March 20, 1997.
I 26 Transcribed Interview of Eric D. SOULE, dated M. arch 17, 1997.
! 27 Transcribed Interview of William F. BARRY, dated March 17, 1997.
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l Case No. 1 96 043 30
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