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I PP&L, INC.
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COftPORATE AUDIT SERVICES !
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WWESTN3ATM3N OF ALLEGATIONS THAT MANAGEtIENT i
MISREPRESENTED ALARM TESTINFORIAATIONTO -
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THE NUCLEAR REGULATORY COIAINSSION I
Job Number 738459 97 i
t DO NOT COPY OR DISTRIBUTE THIS REPORT WlTHOUT THE PERMISSION OF THE i
ACANAGER-CORPORATE AUDITSERWCES i
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M' M"'P -M.'?' M I
b Sr. AndIt Consultant:
To: Mr.W.F. Moses Id h d' M Audit Tessa Leedst:
14 2rmeses 9.'Wedfes m sy:.
<nseer:
a,a, m CC: ter.F. A.Long ter. R. S. Byrun
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RAr. R. J. Oser m
Ger. C. P. Pines Ber. S.T. Jones ter. S. J. -=wnstd
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99o2osoo69 99o329 m
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s October 15,1997 Cosporate Audit Services Auditing) cA +=d an investigation of circumstances ano events at the Susqueh(anna Steam Electric Station (SSES) n various issues all by a former Nuclear Plant Operator
). This report focuses on two of the former concerns. 'Be two concerns are: 1) ement misrepresented alarm test information in an April 9,1997 letter to Nuclear R*==Im Comminion C and,(2) the former NPO ge.estioned the reliability of computer data associated wi N
testmg of the Fagiaa~ed Safeguard System (ESS) Transformer Alarms.
y stated. pril 9 1997 letter (see Exhibit A for an excerpt from that letter In the A The NPO's the Com esel Building). Moreov(er, wefound nom a particu p
surves es and munds was evidence that these Assues wen wide (spread. " The former NPO alleged that this e q
rounds) in a specific location "E" was not true and that management knew or should have known egation,pnl 9,1997) to A the former about other alarm tests that were not performed. In makmg this NPO cited the following alarm tests as examples to illustrate his pomt:
Plant Control Operator PCO) testmg of the Control Room Annunciator Panels; and, Auxdiary Systems for (ASO) tesang of the Radwaste Control Room Offgas anel alarms.
(Corporate Auditing is currently the facts these two alarms and will issue a separate report on this maner.)
- fonner, alleged tint Nuclear Management was aware of other alarm tests not by canas an event whereby [
] allegedly told [
] that Os were not testmg C Room D
1 The former NPO also questioned the reliability of c+=+-- data associated c' /
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with NPO testing of the ESS Transformer Alarms. The Company supplied that cc; ^ -
data to the aforementioned [
]in February 1997.
The following m ats an interim report of our investigation into the above issues. The followns objectives are addressed in this interim report determine if(prior to the Company issuing the April 9,1997 letter
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to the NRC) Nuclear Management was aware of other alann tests not being F M f
determine if[ Annunciator tests; and,] about PCOs not perform h
] informed [
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e Control Room determine if NPO testing of the ESS Transfonner Alarms was e
perfonned as required and review the reliabilit, of==@*=d cr y- - - data.
See Exhibit B for a list of personnel interviewed in connection with this
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EXECUTIVE
SUMMARY
APRIL 9,1997 LETTER TO THE NRC AND MANAGEMENT AWARENESS OF G a rua.R MISSED ALARM TESTS We found no evidence that the Nuclear Department Manasement personnel involved in developing and reviewmg the Ayn'! 9,1997 letter to the NRC had knowledge of other massed alann tests as of Apnl 9,1997. Furthermore, the we obtained edicates that Management generally relied on a Nuclear Asse ement Services AS) Quality Assurance Surveillance of approvimately 125,000 individual tasks rmed by Nuclear
'ons, Maintenance, Fire rivi.ction, Securi and Health ics) to substantiate basis for making the two =tatemente made inE*e Apnl 9,1997 letter.
Control Room Annun]ciators. Additionally, the [ denied that they had a conversation
[7
[
of April 9,1997) of PCOs not testag the Control Room] Annunczators.demed Clav ESS TRANSFORMER ALARM TESTS AND RELIABILITY OF COMPUTER DATA
'D reliably record the NPOs performance of ESS Transformer Alarm Tes[ts. Th]e The Unit I computer data supplied by the Company to did not computer monitors computer points associated with the ESS Transfonner Alarms at a
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slow speed, therefore, it did not reliably demonstrate NPOsperformance of the alarm tests. The Unit 2 computer provides a reliable record of NPO tests of at least two of the l
four ESS Transformer Alarms. A review of Unit 2 ---
^ - data performed by Nuclear indicated that h were testa' g at least two of Operations (and reviewed by Auditing)d January 1996 through July 1996. Due to the the ESS Transformers during the perio 2 computers inability to record computer pomas associated with the other two ESS Transfonners, we were unable to obtain conclusive evidence that NPOs tested those l
Alarms.
ACTION PLAN in performing the investigation, Auditing took various actions including:
intervi persons involved in the drafh'ng, reviewing, and e
issuing of April 9,1997 letter to the NRC; obtaining and analyzing computer data associated with the ESS e
Transfonner Alarm tests; obtaining and reviewing Nuclear Operation's report (and e
suppornas documentanon) on the reliabihty of ESS Transformer computer posts and associated c=-r+z - data; interviewing other relevant personnel including [
);
e analyzing information obtcined; and, e
developing conclusions.
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APRIL 9,1997 LETTER TO THE NRC AND MANAGEMENT AWARENESS OF ua es=R IW"ED ALARM TESTS Backaround g
l At the March 21,1997 NRC Enforcement Conference, the Com presented to the NRC its response to various events which occurred at SSES. pany The events meluded the 'E' Diesel Generator Misalignment, NPO Testing of the 'E' Diesel OC577E
_ ] performance of General Station Inspections, and performance of Alarm, [ ive Maineenane, Activities. The presentanon fo~=ad on[ the fu]ndamental Preventat causes and management issues associated with the events and the corrective and preventative actions to help preclude recurrence.
.b On April 9,1997, the Company issued a letter to the NRC containing a 9
supplemental response to violations associated with the afor-*ia==d events. In the letter, the Company indicated that no evidence was found which would indicate that
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certam issues pertammg to NPOspettern of behavior in the perfonnance of surveitimacee and rounds were widespread. A former NPO alleged that this semeenwar was not true and that management knew or should have known or to Apnl 9,19971 about other alarm tests that were not' performed. The former further alleged that Fuclear Management was aware of other alarms tests not being performed and cited an event where [
]
i told [
] that PCOs were not testing Control Room Annunciators.
Analysis of Statements Made to the NRC in an April 9,1997 Letter and Management Aware==== of Other M3==_ad Alarm Tests 4r.: relied on a Nuclear The evidence we obtained indicates that Man +f approximately 125,000 Assessment Services (NAS)
Assurance Surveillance o individual tasks (performed N
Operations, MaineramaceJire Protection, and Health to==he*=neuer the basis for making the two statements Security,he April 9,1 made in t 7 letter.
Auditing interviewed various Nuclear Department Management personnel
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includm, a [ NRC.] who were involved in the development and review of the letter to'Gie Each person interviewed told Audi '
that they had no, knowledge (as 19 1997) of other alarm tests not being perf The avesagation did not
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of Afose an, y dise evidence to indicate that the Management involved a developing
'r' and reviewmg 9 1997 letter had any knowledge of other missed alarm, tests.
We found no evidence that Company wrsonnel, performed a g review of individual tasks C
icy appm substantiate the basis for making the two statements made m the April 9,1997 letter.
q
] hat PCOs were not testag,who Auditing also separately interviewed [
=Il
- and [
)) denied that such a convers told t
fMversation ""&'[.
'[
] told Auditing th; at (as of Aprd 9,1997) he had no Roosa Ann
. Furthermore, [ ing the Control Room Annunciators.
took of PCOs not test know
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Ceecinaions We found no evidence that the Nuclear Depanment M --
Personnelinvolved in devel and reviewms the lener so the NRC had
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any knowledge of other aussed tests as of Apul 9,1997.
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[
] and [
,] named by the alleger both denied that they, had a g h [/
conversanon PCOs not tesa'ns Control Room An==nciana s,
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1 ving any knowledge (as of Apnl 9,1997) of PCOs not testag the Control Room Annunciators.
ESS TRANSFORMER ALARM TESTS AND RELIABILITY OF COMPUTER DATA Backaronad On Sp =%T 3,1996, 1:equested that the C him with specific compuser data pertaining [ to the E55 Transfonner Alanns.
was involved in the l effort to obtam infan==*iaa for an arbitranon to termi==sian of f NPOs a 1996
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from the of the 'E' Diesel Generator 0C577E Alann). [ (due to issuesthe ES told A be knew the always tested
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a infonnamonin to illusasse Ibst
/T data ev ;.4 by NPOs did not have an aversion to testing alands.11m wA ES computer when an
].
M a log ofcomputer ints recorded by an SS MPO testdesch of the four ESS Tran[onner Alanns. Per OI-PIA 171, NPOs are required to test the four ESS Transfonner Alarms once per day during the set of reunds conducted from 7:00 PM to 1:00 AM.
Nuclear Operations supplied [
] with data recorded 1997,forementioned cc
_ poses son reviewing the data, h, In F the a by the Unit I computer
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noted that the computer sporadically recorded E55 Transfonner Alann tests and
[ hat the] data did not indicane all four Transfonners being tested on any paracular day.
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[
discussed his observations with [
] who in turn u' n'nated a review of the
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problem]s.
d various revi;; ions were is,aned. Thie"' pared a report of,the results of thei Nuclear C
'i= pre and ex]plained the rollowing to [
]: (1) the (dated Macs 5,1997) wida {
review indicated there was no eschecal basis to conclude that the c-_=, ^ poets were iNand
=Mida=al about the computer daea.
]
Auditing that be hadIcarned fkom h-told that not this
] that two computer poins w[as not hectioning,and be questioned why du,
^- points.
mrtissed a revww recorded two other cn'that b~e subseq[uendy] discussed Revision l
computer and told Auda ~
intodu (dated March 26, I with [
lat time [,
) indicated be asked
- ibe no aMiaaaal infonnation to tbat du saa[tter
] d be seeded as the afor=*ada=*d M-additional 3 advised [ ld Anib,a'ng that be did not pursue this ma
] an
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[ bitranon. [
ng l to the above course of" events, the fonner NPO learned about the computer data problems ar identified by [
].
l
-S-Anatmia Auditing interviewed [
who performed Nuclear Operation's review
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of computer poets associated with the four]ESS Transforme told C2/
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Auditing that Revision 3 (dated April 29,1997)d additional information explaining why been_ provided to [
). Revision 3 containe the Umt I computer data supplied to [
] sporadically recorded two computer points.
[
. ] told that in Revision 3 he concluded that the Unit I the Umt I c-==- momtors each ce= 'puter points I
D sporadically recorded com computer data (previ post.
due to the slow speed at Moreover, Revision 3 indicated that the Unit Icomputer recorded computer poets at a b
much faster thereby allowing it to reliably record those sane c -- c- - points.
O
[
vali this via a compenson of Unit I cosaputer data to Unit'2 computer data.
Auditin]g performed another compenson which confirmed [ Syst
] conclusions.
Furthennare, Auditing venfied wnh the Manamer-Computer e monitor the dor *=*ana=ad computer pouus. The' the Unit I and Unit 2 +btamed from the Manager <omputer Systems was en==imar with information Auditing o
[
] conclusions.
Nuclear Operations also reviewed a sample of 117 days.(Ra January 1996 and July 1996) of Unit 2 computer data for the two computer wees in question and noted no instances of NPOs not testas the two ESS Transfonner A' arms associated with those computer points. Likewise, Auditing ormed a minutar review and also noted that the data indicated that NPOs were testing two ESS Transformers. Due to the Unit 2 computers inability to record c+----= points associated with the other two ESS Transformers, we we w unable to obtain conclusive evidence that NPOs tested those Alarms.
Conclusions
" Die evidence developed during this investigation indicates that-tied by the Company to did not
/
onnance of ESS Transform [ er Ala The Unit I data
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reliably record NPOs e Unit 2 dataA' a reliable record of NPO tests of at least p
two of the ESS Transfonner Alanns.
NPOs inseed at least two of the ESS Transformers during the sample period between January 1996 and July 1996.
ACKNOWLEDGEMENT Andising wishes to acimowledge the assistance that Nuclear Department personnel provided to as during this investigation.
D. A. Duda and T. C. Roth cc +=t=' this investigation.
If you need additicaal information or would like clarification on any items I
ca=eminai in this report, please feel fires to contact Auditing.
We do not expect a response to this report.
Corporate Audit Services
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E G DDIT A FFAL Inc.
Job # 739459 97 Exceret from Antil 9.1997 Letter to the NRC (Himbushted Sentences Art the Sentences in Ouestion) 2.
Mamanenset Centrols D
PPE behaves that the apparest notanons do not comssames a weimspnad banlabwa in cannot of q
hommand assmnes and that the noisnoms should not be incrumsed in sevenry for that reason.
Ds6casst,, L
- by NPCs was idenn6sd tr acavens h wish the "E" Dessai and by
[
] and [
] in commmenon wink Gameral Semnom W (GSIs). Wish respect to NPO
,, L - =. PPE W prevennve acnoms in response to NRC Infonmanen Nasus (IN) 92-30 that were onasmusst with adustry mones, nedadog bnenmes for monom persommel, l
servedlemas d looped sumiss, survedlances of operaser nummis and andas of operssor legs.
Akhough thess acceso were==Ma==
in Imadacht to pamde sorty duesceos of to NPO l
survmuenos and rounds asses, esy were reasomshis precommons at es time. c NRC W wswed UE's ~ ;*
' ofits asif<nommonsg prognum is response to 25 92-30 as accapsabis Aasr PpE s thorough avancomons revenied es NPO mavaEmmas and remads a senes of acnoms wue tales to doesraans the scops and masse W the issmus. SpecdlanDy inna==
we mesesd'ad operanons mammenases overaght l
conducend QA muvausmens compissed independet Safety Evminsnom Serwcas (ISES) C
'- Survensmos madeced QA mv=ws or asseney anna versus " logs (inchuhms mourny, hakh phpics and See prosannon) ands a senms ofimprovammes to make assamamma pracnoss mom inwumve and sehente f"W;[7:% } }
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yy s ~x ~ z (.m m y gg,,g sysend,. Tnssesmand someannsopsumesrooms atssESwouldsupport taas
- De visimmons wue asif edusdied badme a plant event consned. The waismens did not munit in the imability of satty symamms to perdures emir issended sedwy Semnoms. Boommes PPE took presannons tus wem comsmaust wish undsstry monas and adBassa to prochads a wedsspand probina, these is ao basis for Gedias a breakdo a in mammemaan oosnais and l
l mennens the seveney of vicishams for est mesom.
Wisk sesyma to the partemmam of the alsna test by NPCs, our invasaganon svented that somme d (-
l NPCs appened to undermand es rupamment but Suled to ameply wi6 it on ammerous occamass.
06er NPCs dd mas partsnm es met imanny but anos tsy commassend tesnes,*they perfonsed wiR8d /
commmmmer. whas constadas est es condas by boe smops of NPOs
-== did amt sad may evidemos et deliberuns aussondmot. Wie aspect to the osts the of NPO mands, we somshmied est no.[
] or [
] messed in withi aussendmet.
,[
] and ainnmar [
] demommemand poor judgiaant win raged to the
] and a endere to anst managemeset's empassaiens soaps ofihmir essnesion mennend as a [
wish respost se parteming es apphsmids requiremssus and isr this reason esas im6vuk severed toss amploymous. To ths omsat NPO survedimesa or alans tus moonis wue immoo taas immonuncias rendeed tous the annons of"non-hcomess ad5 canis" j
Pahoy.
were properly pi-8
,,g and.s, are mot m.as o,. w mp.e.d remis i mem.-- -
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EXHIBIT B i
i FFAL,Inc.
Jeb # 739459-97 i
I.Jst ofinterviewees
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s W#****23 FM 01/14/98 3:
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