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PP&L, INC.
CORPORATE AUDIT SERVICES (INTERIM REPORT) investigation of Anegations That Plant Control Operators Did Not Perform Certain Alarm Tests Job Number 739459-1-97 DO NOT COPY OR DISTRIBUTE THIS REPORT WITHOUT THE PERMISSION OF THE j MANAGER - CORPORATE AUDIT SERVICES 1 l
TO: Mr. C. T. Jones . Sr. Audit Consultant: /4/ 94m44 4. Dud 4 Audit Team Leader: /d/ 74em44 8. Rati Reviewed By: /4/ 7N4stus 7. 74t/4m Date issued: December 1.1997 .
CC: Mr.W.F.Hecht Mr. F. A. Long Mr. R. C. Byram Mr. R. J. Crey Mr. R. E. HIN Mr. C. P. Pinto Mr. C. J. Kuczynski h20 2 990129 ' /
SORENSEN99-36 PDR 7:f i
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December 1,1997 Corporate Audit Services (Auditing) conducted an investigation of circumstances and events at the Susquehanna Steam Electric Station (SSES) surrounding various issues alleged by a former Nuclear Plant Operator (NPO). This report focuses on
- one of the former NPOs concerns. More specifically, the former NPO:
l e alleged that at times Plant Control Operators (PCOs) did not perform required tests of the Control Room (CR) Annunciator Panels; and, e- indicated there were inconsistencies between some shifts regarding the testing ofInner vs. Outer CR Annunciator Panels.
Two other concerns raised by the former NPO were investigated by Auditing in an interim report issued on October 15,1997 entitled "Investy;ations of
! . Allegations that Management Misrepresented Alarm Test Information to t se Nuclear Regulatory Commission." Those concerns involved: (1) an allegation that management misrepresented alarm test information in an April 9,1997 letter to the Nuclear Regulatory
- Commission (NRC); and (2) a question related to the reliability of computer data -
l- associated with NPO testing of the Engineered Safeguard System (ESS) Transformer -
Alarms. Auditing is currently g f i d by the
- former NPO that at times Auxih,athering the facts regarding a ourth concem ra se tests of the Radwaste Control Room Offgas Panel alarms.
The objectives of our investigation were to:
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e gather the facts surrounding PCO testing of the CR Annunciator Panels; and, j
e determine whether or not at times PCOs did not perfonn required tests of the CR Annunciator Panels.
See Exhibit A for a list of personnel interviewed in connection with this l
investigation.
l EXECUTIVE
SUMMARY
l l PCO TESTING OF THE CONTROL ROOM L ANNUNCIATOR PANETS
[
i ,
l of[ ] PCOs w e interviewed indicated that they did test the alarms or to the[ b]est of the}ir knowledge they behes ed they tested the alarm the sample period January through June 1996). Another [ ] of the [ ] PCOs '
indicated that they believed they did test the alarm but indicated that it is possible that, at '
times, they may not have. Furthermore, the ins estigation did not disclose any &
documentary evidence that computer points exist m order to validate or disprove that at h ;
times PCOs did not test the CR Annunciator Panels as required.
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l The evidence also indicates that there were inconsistencies between shifts '
! regarding management expectations and the testing of CR Annunciator Panels (Inner vs l l- Outer). In July 1997, Nuclear Operations clarified the alarm test requirements to help l enable consistency between shifts. I The remainder of this report includes our action plan, background i information, and additional support for our conclusions. 1 I ..........................
ACTION PLAN In performing the investigation, Auditing took various actions including: ]
. interviewing the former NPO in order to obtain details relating l to his concems; e determining,whether or not there were computer points for the CR Annunciators; i e interviewing all current PCOs, e interviewing Nuclear 0 by the former NPO as m,perations dividuals Management having knowledge of PCOs personnel nam not testing the CR Annunciators; e reviewing available PCO Turnover Sheets for the sample period January through June 1996:
o researching the history of the PCO Tumover Sheet requirements for testing of CR Annunciators; e analyzing infomtation obtained; and, e developing conclusions.
PCO TESTING OF THE CONTROL ROOM ANNUNCIATOR PANET Si
Background
Line #7 of the Offgoing Plant Control Operator Checklist (See Exhibit Bi provides a box for PCOs to indicate that all CR Annunciators were tested successfully.
The Offgoing Plant Control Operator Checklist did not specify acceptance criteria for 89-45 ) communication took place through performing tiis test. In 1989, a Hot which all PCOs at that time were informe Box (d of a ch.inge to the PCO Turnover Sheet requiring that all CR Annunciators be tested once per shift. The Hot Box documentation included the signatures of PCOs from each shift mdicating that they had been notified of the change to tae Turnover Sheet. In July 1997. Nuclear Operations clarified this recuirement by moving it from the PCO Turnos er sheet to the Unit I and Unit 2 System
& Equipment Status Sheets which listed each CR Annunciator Panel (including Inner &
Outer) that the PCOs are expected to test.
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-3 Q
Analysis of An Allegation That PCOs Did Not Test Control Room Annunciator Panels As Reauired ;
[
kl/
]
of ] PCOs we interviewed indicated that they did test /
the alarms
[
or to the bes]t of[their tested the alarms (during knowledge
]PCOs h" the b the sample indicated that period January they believed they through did test the June alarms1996).
but in Another [ dicated that t s possible, at b
times, they may not have.
Additionally, Nuclear Department personnel performed a review to determine whether or not computer points existed for the Inner Riag Panels. They concluded that no computer points existed. Thus, no computer data was available to indicate whether or not PCOs were testing the Inner Ring Panela.
- Analysis of Claim That There Were Inconsistencies Between Shifts Reenrding Testing ofinner vs. Outer Control Roam Annunciator Panels There was not a common understanding regarding which CR Annunciator Panels were required to be tested. The evidence indicates that there were inconsistencies between shifts regarding which CR Annunciator Panels iInner vs Outer) were required to be tested.
] of the [ ] PCOs we inten iewed indicated that their understanding [was that they were required to onts re ,t the Inner Ring Panels, ] [' whil of[h .
the Inner and Outer Ring Panels, and []
]oi[ '_ ] PCOs indicatedPCOsthat indicated their that the l/
bot understanding was to test the Inner Ring Panels, but they also noted that they occasionally h tested the Outer Ring Panels.
The[ ] tohl \uditing that at a minimum he expected the PCOs to test the CR Inner Ring Annunciator Panels. Furthermore, the l' ] told Auditing that the eyectations of PCO testing of the CR /f
[ fj Annunciator Panels (Inner vs Outer) were not clearls communicated to the PCOs.
- also indicated that the word "All" on Line #7 of the i)ffcoing Plant Control Operator d[j Checklist provided too much latitude to the PCOs. We Tilso ] told interviewed Auditing t [ hat he had about their expectations. [
expected the PCO]s to test the Inner Ring Panels but, since September 199
4 expectation was for PCOs to test both the Inner and Outer Ring Panels. The ]
we interviewed told Auditing that several years aSo (prior to January 1996) th[e hg' expectation was for PCOs to only test the Inner Ring Panels, but now the expectation is for PCOs to test both the Inner and Outer Ring. Neither [
communicating these expectations to the PCOs.
] could recall M{I Other
' We reviewed available PCO Tumover Sheets for the period Januaaf through June 1996. We noted that for all but one shift a PCO signed the sheet and annotated the Turnover Sheet indicating that the CR Annunciators were tested. At least two PCOs per Unit are on duty (total of 4 PCOs) and any of the 4 PCOs may perform the control panel alarm tests. Certam PCOs told us that the PCOs signing the Turnover Sheets at times delegated the performance of the test (or part of tie test) to one of the other PCOs on duty.
Finally, Auditing also interviewed other personnel including certain Nuclear Operations Management personnel named by the former NPO as persons who knew, or may have knowledge, that PCOs were not testing the CR Annunciators. We interviewed the who stated that he ./
- had no knowledge of anyone not do[mg the test. We interviewed][ L who stated that he had no knowledge of the test not being done. We also intervi]ewed [is knowledge the] CR Annunci j[7 J. [
indicated that to the best of h every shift since the requirement was added to the PCO Turnover sheet. He also indicated includes the thatOuteryears Panels.ago only When the Inner Rin g[ Panels we askec. if hewere had anytested but now the test knowledge of the CR Annunicator Panel test not being perfor]med, he stated he l
sure it's been missed but not intentionall . We also asked [ ifhe l personally did not perform this test, and he stated that he was not sure anc that there
[ were probably times during [
] that he didn't do the test because he forgot or was distracted. He also stated: (1) that if he was unable to do the test he ,
,L would note it on the sheet; and (2) that if the test was accidentally missed he would havejust si t, f' &
V f
l-gned the sheet indicatmg it was tested. 5 e of[interviewec the test notstatedbeing thatdone. heHe hadalso] we /
no knowled stated the requirement included testing of Lnner and Outer Panels and that he had no knowledge of PCOs not testing the Inner and Outer Panels.
Conclusions (,
- [occasions when he did we inters iew ed indicated that there were no]t perform the test of the CR Annunciators
(
yet si ed the PCO Turnover sheet indicating the test was comp eted. ]g
- ] PCOs u e interviewed indicated that they
[did test the alarms or to the best of their knowledge they believed T-i they tested the alarms.
- PCOs indicated that they believed they d[id test the alarms but indicated that it is possible, at times, they may g . ip
- not have.
- The investigation did not disclose any documentary evidence that computer points exist in order to s alidate or disprove the allegation that at times PCOs did not test the CR Annunciator Panels as required.
J
k The evidence indicates that there were inconsistencies between shifts regr.rding which CR Annunciator Panels (Inner Vs Outer) were required to be tested.
. In July 1997, Nuclear Operations clarified the alamt test
- requirements to help enable consistency between shifts.
RECOMMENDATION Nuclear Department management should review the results of this report and take appropriate action.
ACKNOWLEDGMENT Auditing wishes to acknowledge the assistance that Nuclear Department personnel provided to us during this investigation.
D. A. Duda and T. C. Roth conducted this investigation.
Auditing requests a response to this report by December 31,1997, including your response to our recommendation. _
Ifyou need additional information or would like clarification on any items contained in this report, please feel free to contact Auditing.
Corporate Audit Services l-i L
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k' EXHIBIT A i
PP&L, Inc.
Job # 739459-1-97 List ofInterviewees Included:
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EXHIBIT B PP&L, Inc.
Job # 739459-1-97 PCO Turnover Sheet "Offgoing Pinnt Control Onerator Checklist" i
Attachmera 8 CP-AIM 03 Rowman 4 Page 77 of 36 OFFGOING PLANT CONTROL OPERATOR CHECKLtST:
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Title:
SUSQUEHANNA STEAM ELECTRIC STATION: . l FALSIFICATION OF PCO TURNOVER SHEETS INDICATING PERFORMANCE OF CR ANNUNCIATOR TESTS l
Licensee: Case No. 1 97 048 Pennsylvania Power & Light Company Report Date: June 24, 1998 2 North Ninth Street Allentown, Pennsylvania 18101 Control Office: 01:RI \
Docket Nos.: 50-387/388 Status: CLOSED '
Reported by: Revi wed and Approved by:
KefthG. Log
, Spe ial Agent 3(
Barry R./.etts, Director Office of Inve ions Office of Investigations Field Office, Region I Field Office, Region I WARNING D0 D INATE, EI W LIC E DISCUSS
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T R 0 FICI ISg i.f 1
ISC; MA LT I STRATT ON i IM PROSE UTION. j i
SYNOPSIS This investigation was initiated by the Nuclear Regulatory Commission (NRC).
Office of Investigations (0I), Region I (RI), on November 20, 1997, to ,
determine whether a Plant Control Operator (PCO) at Pennsylvania Power .and ;
Light Company's(PP&L) Susquehanna Steam Electric Station (SSES), falsified a PC0 Turnover Sheet entitled, "Offgoing Plant Control Operator Checklist."
Based on the evidence developed during the investigation, it is concluded that the PC0 willfully created false Turnover Sheets, which were maintained by SSES. l l
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C E ' e 6 Pkkkk'ONSf Caseilo. 1-97 048 1
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0FF ECT , FFICE NVE 'IO 1 10 Case %o.197-048 2
TABLE OF CONTENTS Page SYN 0PSIS .............................. .. 1
, LIST OF INTERVIEWEES ...-........................ 5 l DETAILS OF INVESTIGATION . . . ...................... 7 Applicable Regulations . ...................... 7 Pur>ose of Investigation ...................... 7 Bac(ground ............................. 7 l Interview of Alleger . . ...................... 7 Coordination with Regional Staff .................. 8 Review of Documentation . . . . . . . . . . . . . . . . . . . . . . . 9 Allegation (Falsification of Turnover Sheets by Keith DAVIS, Plant. Control Operator at PP&L's SSES) .............. 9 Evidence ........................... 9 Agent's Analysis . . . . . . . . . . . . . . . . . . . . . . 12 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . 13 SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . 15 LIST OF EXHIBITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 T
T. UB )ISC RE'WI /^
@FF y 0 ) , O C 0F ESTI IONS, ON i
CaseEo. 1-97 048- 3
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I LIST OF INTERVIEWEES l Exhibit i
I l DAVIS, Keith, PCO, SSES, PP&L . . . . . . . . . . . . . . . . . . . . 8 & 12 l
DVDA, David A., Sr. Audit Consultant, Corporate Audit Services, !
PP&L 4
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! FERNSLER, Grant, Shift Supervisor, SSES, PP&L . . . . . . . . . . . . . . . 5 i KENNY, Jim, Supervisor, Licensing, PP&L . . . . . . . . . . . . . . . . . . 4 l
ROTH, Thomas C., Audit Team Leader, Corporate Audit Services, PP&L .... 4 URBAN, Martin F., Manager, Corporate Audit Staff, PP&L .......... 4 l
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. DIR OR, I .T , RE l Caseio."1-97048 5 l
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Caseio.- 1-97 048 6
DETAILS OF INVESTIGATION Acolicable Reaulations ;
10 CFR 50.5: . Deliberate misconduct (1996 and 1997 Editions) -
.10 CFR 50.9: Completeness and accuracy of information (1996 and 1997 Editions)-
Puroose of Investication .
This investigation was initiated by the Nuclear Regulatory Commission (NRC),
Office of Investigations (OI), Region I (RI), on November 20, 1997, to determine whether Keith DAVIS, a Plant Control Operator (PCO) at Pennsylvania Power and Light Company's (PP&L) Susquehanna Steam Electric Station (SSES), ;
falsified a'PC0 Turnover Sheet entitled, "Offgoing Plant Control Operator '
. Checklist" '(Exhibit 1 and Exhibit 2, p. 8).
l Backaround -
L This investigation was initially opened as an " assist to inspection," wherein
! OI agreed to review a report prepared by PP&L's Cor) orate Audit Services (CAS) l . staff. PP&L reported that, during an interview wit 1 CAS, DAVIS admitted that,
'" prior to August 30, 1996, there were-occasions that he did not perform the l ~ test of the CR Annunciators yet ' signed the PC0 Turnover Sheet indicating the test was. completed (Exhibits 2, 6, and 7). Prior to receipt and review of the
! CAS' report. .Marty URBAN, Manager, CAS, telephonically advised 0I that DAVIS recanted his admission of falsifying the PCO-Turnover Sheet and attributed it to a misunderstanding by the CAS interviewers (Exhibit 3: see also Exhibit 2,
- p. 8). The OI effort was subsequently' discussed during the December 0I prioritization meeting, wherein it was decided that the " assist" would be-upgraded to'an investigation.
L AGENT'S NOTE:. The initial ISR ' indicates that a Control Room Log was allegedly falsified. In fact, the document was an "Offgoing Plant
. . Operator Checklist," which is prepared by a licensed operator (PCO) working in the control room.
Interview of URBAN.- et. al. (Exhibit 4)
..On ' January.6,1998,.0I interviewed URBAN at PP&L's Corporate Offices in
- Allentown, PA, to discuss the findings and review the supporting documents regarding the CAS investigation conducted at the SSES. Also present and partici)ating in this interview were: Jim KENNY, Supervisor, Licensing,
URBAN indicated that the CAS findings on the falsification of records issue L were presented-to George-JONES, Vice president Nuclear Operations. At that L tir , J0NES had responsibility for both the corporate offices in Allentown and SSES. The CAS report (Exhibit 2) is captioned, " Investigation of Allegations Casek.'l-97048 7'
...,.y -n u , - , -.g.
That Plant Control Operators Did Not Perform Certain Alarm Tests," and is numbered 739459 1 97.
4: It is URBAN's understanding that DAVIS was removed from his PC0 position based y,& .. upon the findings of CAS resort. He was advised by KENNY that JONES has had
.several conversations with JAVIS subsequent to DAVIS' removal from PC0 duties.
Of-lib
% URBAN noted that they would not routinely have released a copy of the Pf ^ pg:may have been shared with DAVIS. URBAN report provided to DAVIS, a copy of but believes a December 16,that their findings 1997, letter (Exhibit 3), which DAVIS sent to JONES, regarding " Clarification p(ofPC0alarmtest."
- e. s .
no the i ues concernin re o the attention A LCAS who raised the L
~ rns ugh h s et rney IR wit 1 the
- Horgan, Lewis and Bochius, Washington, D.C. In essence
.that~"PCOs did not test alarms as required," and there we istencies between. shifts w/ regard to testing of annunciators."
u.
Pa"nLDUDAinter During the interview, counsel for both Were'p'rese that DAVIS could substantiate the concerns Wairraising. ated that there was no indication that all the ciators wer ionally" not t stated that it was the ture at SSES to fill out paperwork. ndicated that expectations as theitesting of alarms were not clear was some disagreement as to her/both the inner and outer rings were to be tested, or just the inner
. 'DVDA indicated that their review showed that, at one point in time, the irement was only to test the inner ring.
Ab989 a communication known as Hot Box #89 45 (Exhibit 9) was issued, which formed all PCOs of a change in the PC0 Turnover Sheet; it required that all nnunciators be tested once per shift. The Hot Box documentation provided
. included the signatures of PCOs from each shift, indicating that they been notified of the requirement. This document advised the PCOs that
!were required to test all control room annunciators" as part of their presponsibilities(Exhibit 9).
$the CAS representatives, in July 1997 this procedure changed at SSES. OP-f003 Revision 8, eliminated the requirement that Offgoing PCOs check "All rol room annunciators tested successfully." The requirement is now luded as part of the Unit 1 and Unit 2 System & Equipment Status Sheets, 1.h list each CR Annunciator Panel that the PCOs are expected to test. Now i the inner and outer rings are to be tested as part of the systems ing. The new form includes a section for " problems & comments" with rd to those systems.
bination with Reaional Staff u,r
- t. On June 10, 1998, the facts of this case were discussed with Brad FEWELL, FRegional Counsel, Region I, NRC. -
_ Caselo. 1-97-048 8
r n, Review of Documentation 01 reviewed PP&L's CAS interim report, " Investigation of Allegations That Plant Control Operators Did Not Perform Certain Alarm Tests" dated December 1, 1997 (Exhibit 2). 01 also reviewed Hot Box #89-45 (Exhibit 9), OP-AD-003 (not attached), the handwritten notes of URBAN and DUDA (not attached), the typed notes of URBAN an DVDA (Exhibits 6 and 7), and the two letters from DAVIS (Exhibits 3 and 11). .
Alleoation: Falsification of Turnover Sheets by Keith DAVIS, Plant Control Operator at PP&L's SSES Evidence DAVIS was interviewed by OI on May 27, 1998. DAVIS was re) resented by Arthur DOMBY, Esquire, with the firm of Troutman Sanders L_P, 600 Peachtree Street, N.E., Suite 5200, Atlanta, GA 30308. DAVIS indicated that his current position is still that of a PCO, however, he is on a special assignment.
DAVIS stated that he was relieved of his PC0 duties and re assigned as a result of the CAS report and has yet to report back on shift as a control room PCO. In January 1998, he was placed in a responsible behavior program (Exhibit 8, pp. 3-6, 30, and 31).
As part of their audit, CAS reviewed PC0 turnover sheets from January 1, 1996, through June 30, 1996. All were completed exc'ept for one sheet. KENNY noted that the Turnover Sheet was the formal turnover process for the PC0 leaving the CR to provide information to the oncoming.PC0. The sheet was not routed
- through the Shift Supervisor (Exhibit 4).
Line 7 on the PC0 Turnover Sheet reads: "All control room annunciators tested successfully" (Exhibit 2, p. 8). URBAN indicated that, while on shift, Shift Supervisors (SSs) were responsible for establishing what "all" meant on line
- 7 on the back of the PC0 Turnover Sheet (Exhibit 2, p. 8). URBAN noted that some SSs required testing of both the inner and outer rings, while others required that only the inner rings be tested. It was clear that, at a minimum, everyone expected that the inner ring would be tested and that it was required. Dan B0YLE was one of the SSs who required the testing of both rings (Exhibit 4).
AGENT'S NOTE: During 1997, PC0 turnover requirements [ Turnover Sheet line 7] changed. The CAS investigation and the admissions made by DAVIS refer to the sheet as it existed in 1996 and is attached to this report.
DAVIS was interviewed by CAS immediately was interviewed.
URBAN indicated that they did not discus s with DAVIS and, I specifically, told DAVIS that they could m who they 3reviously d interviewed. They made their arrangements to interview DAVIS t1 rough Ken HILLNAN, Scheduler, Nuclear Operations. DAVIS asked to have Grant FERNSLER, SS, present during his interview. URBAN and DVDA agreed, although they found his request to'have another management representative present very unusual (Exhibit 4).
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Case %o.107-048 9
FERNSLER indicated to CAS that, at a minimum, he expected the inner ring to .
have been tested. URBAN stated that Dave STEFFENAUER, SS, indicated that he l recalled a verbal communication regarding the testing requirements, but had no specific recollection of the communication. He recalled that this became an issue several years ago, arior to January 1996, when there was scrutiny of the E diesel generators (Exhiait 4).
In his 01 interview, FERNSLER acknowledged that DAVIS knew ". . prior to August of 1996, that PC0's, . . . had, in fact, not tested control room '
annunciators, had . . . checked off [on] the turnover sheet that they had accomplished that testing, and had signed that that testing had been complete." While FERNSLER did not recall DAVIS admitting to being one of those PCOs, FERNSLER stated that, in his letter, DAVIS admitted that on two occasions he had not performed the test, signed the form, and gone home (Exhibit 5, pp. 8 and 9: see also Exhibits 3 and 11).
A document attached to Hot Box 89 45, relating to PC0 testing of control room annunciators, was signed by DAVIS on July 30, 1989 (Exhibits 4 and 9). The procedural change documented in the Hot Box #89 45 was presented to licensed operators and those in operator training (Exhibit 4). DAVIS indicated that he started his PC0 training in 1989 (Exhibit 8, pp. 5 and 8). DAVIS signed the Hot Box sheet indicating that he was familiar with the requirements of #89 45 ,
(Exhibit 9). During his 0I interview DAVIS acknowledged that the signature on the sheet was his (Exhibit 8, p. 9).
In a letter to JONES, dated December 15, 1997 (Exhibit 3), DAVIS indicated i that there were two instances where he " remembered not performing the Control Room alarm test the previous day, and that it was documented as being comalete." DAVIS advised CAS of this during his July 1997 interview (Ex11 bit 8, p. 35). In a January 5, 1998, letter to Kevin CHAMBLISS (Exhibit 11), regarding responsible behavior, DAVIS states that he "never knowingly violated any company procedure, requirement, or expectation "
similar to his denial of any willful intent in his earlier letter to JONES (Exhibit 3 and 11: see also Exhibit 8, pp. 35 37).
The CAS interview notes of URBAN indicate that " DAVIS stated he periodically, didn't test this alarm." The notes also indicate that, " DAVIS stated that -
there were times he (DAVIS) hasn't checked the alarm but checked the box" (Exhibits 4 and 6). DUDA's notes also reflect that DAVIS admitted not testing the alarm and still checking off the sheet (Exhibits 4 and 7).
DAVIS admitted signing the PC0 turnover sheets, indicating that all of the annunciators had successfully been tested, when they had not been so tested.
He indicated to 0I that, when he signed the sheet, he did not specifically recall that he had not tested the annunciators, and, therefore, he had not
" knowingly" made a false statement. He also indicated that when he did recall that he had not completed the tests (the next day), he went to the plant and did the tests, but did not notify management (Exhibit 8, pp. 19-23 and 35 37).
His recollection of later completing the tests is not reflected in the CAS report or interviewers' notes (Exhibits 2, 6 and 7).
[IE O j I S ION I Caseio. 1-97-048 10
DAVIS indicated that even though he completed a fem which contained a false statement, he did not have to report that to management. His response was that there was "no gain to report it to management . . . there was no avenue for management to take with it." He indicated that management could only have gone back to do the test, which he said he did upon returning to the plant at a later time (Exhibit 8, pp. 31-33, 35 37, and 42). -
With regard to the statements in his two letters, DAVIS indicated that they are consistent. He admitted signing for work not completed (Exhibit 3) and denies having " knowingly" violated company procedures. DAVIS said that his violation of the procedure, which required checking that the annunciators were successfully tested and noted on the sheet prior to turnover, was not done
" knowingly. " By this, he indicated that at the time he signed the sheets he did not recall that he had not completed the annunciator tests. However, he did acknowledge that he "made an error" (Exhibit 8, pp. 22-24, 35 37, and 46 48).
With regard to the CAS report, DAVIS said that, "at no time did I indicate [to CAS] that time did not permit me to perform the tests on certain days (Exhibit 8, p. 44). However, the CAS notes indicate that, at times, he would get " busy" at the end of shift and check it (line #7) off. DAVIS said that today he would just write "no" in the space (Exhibits 6 and 7). The CAS notes also indicate that DAVIS stated that everyone checks the box off to show that the tests were complete, and that he was justified in doing this to complete the paperwork (Exhibit 6).
DAVIS also indicated that he was aware of five NP0s who had not completed the alarm tests but signed the forms indicating that the tests had been done.
DAVIS is a sho) steward and learned this at the time of the CAS PC0 interviews. W1en asked if there were other PCOs who had signed the form without completing the tests, DAVIS stated that five PCOs called his house, and he discussed with them what would happen if they had not done the test.
They were worried about losing their jobs. They told DAVIS that they still didn't test the alarms. He told CAS that he would not reveal the names of those PCOs. DAVIS also refused to advise OI of the names of those PCOs: he stated that he was a union steward and refused to incriminate them (Exhibit 8, pp. 23 29).
AGENT'S NOTE: DAVIS also advised OI that the other PCOs were asked if they had failed to complete the control room annunciator tests between
" January 1996 and June 1996," whereas he was asked if he had "ever" failed to complete them and yet indicated that they had been done. He says he would have answered "no" to the question posed to the other PCOs (Exhibit 12)
Ricardo TOMASACCI and Timothy EBERT were interviewed as part of this investigation. They did not provide any additional relevant information regarding the falsification of records by DAVIS or others [their interviews are not attached].
Case *No. 1 97 048 11 l-
Aaent's Aaalysis This entire investigation is based upon an allegation made by an NP0, who was the subject of disciplinary action for his involvement in a wrongdoing issue, and the statements made by a PCO. Neither the CAS nor the OI investigative efforts were able to identify additional information regarding the Turnover
' Sheet falsification issue.
The allegation was investigated by CAS. The only substantive evidence that !
investigation provided against DAVIS was the statements he made to CAS and the subsequent letters he wrote to SSES management. DAVIS' statements to 0I were not entirely consistent with his statements to CAS. The CAS interview notes reflect that he stated he " periodically" did not test the alarms: this would be a more regular basis than twice.
Other than the statements puraortedly made to DAVIS, DAVIS was the only PC0 to admit his failure to follow t1e procedural requirements, as provided on the PC0 turnover sheet and station procedure. DAVIS alleged that there were five other PCOs who failed to complete checks, yet signed the turnover sheets attesting to their having performed the annunciator tests. DAVIS indicated that those PCOs knew that the checks had not been done. When asked DAVIS refused to identify which PCOs made those statements to him. DAVIS attributed the failure to perform the tests as a cultural issue at SSES, where management was more interested in paperwork than performance.
By admittedly failing to follow procedures, which resulted in false statements, DAVIS has placed his credibility in question. While he has stated to 0I that he did not recall that the tests had not been aerformed, at the time he signed the turnover sheets, he admitted that he close not to correct the turnover sheet records, after he remembered the tests were not done.
However, notes from the CAS interviewers reflect a more cavalier DAVIS, one who was willing to say it had not been done. The reporting agent does not equate " periodically" with "two times" and believes that the latter statement was made by DAVIS after contemplation of the consequences of what he said; tnis most likely resulted in ">eriodically" becoming "two." If "two" was correct, it would most likely lave been DAVIS' first response. DAVIS' explanation of being busy, saying he did it periodically, yet being adamant that it was not done after a particular date, leads the reporting agent to believe that DAVIS' failure to test was done willfully.
'Even accepting DAVIS' explanation that his falsification was not intentional at the time of the turnover, DAVIS made a conscious decision in failing to correct the record, a false record which was relied upon by the oncoming PC0 and any NRC or other inspector who may have reviewed that sheet at a later time. The fact that he may have performed the test at a later time would not remedy the problem of a false record, nor would it have provided notice to a PC0 coming on shift about the possible failure of an annunciator.
DAVIS' explanation for not advising management of the problem with the record he created was-that there would be "no gain." Other than his own statements, there is no additional evidence to prove or disprove whether DAVIS " knowingly" Caseio. 1 97-048 12
signed the PC0 turnover sheet, deceiving the next PC0 and further reviewers.
It is clear, however, that he knowingly chose not to correct the false record.
l From an NRC perspective, there exists within the SSES records at least two documents created by DAVIS, and most likely more created by DAVIS and/or other PCOs, which are false and inaccurate with regard to the testing of the control room annunciators at the time of shift turnover. However, at this time, there is no way to determine on what specific dates the testing of the control room l annunciators was missed.
' Conclusion ,
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, Based on the evidence developed during the investigation, it is concluded that I
a PC0 willfully created false Turnover Sheets, which were maintained by SSES.
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l- SUPPLEMENTAL INFORMATION On June 10, 1998, William P. SELLERS, Esq Senior Trial Attorney, Fraud Section, Criminal Division, U.S. Department of Justice, Washington, D.C., was apprised of the results of this case. Mr. SELLERS advised that, in his view, the case did not warrant prosecution and rendered an oral declination.
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LIST OF EXHIBITS
' Exhibit No. Descriotion .
1- Investigation Status Record, dated November 20, 1997.
2 PP&L CAS Interim Report " Investigation of Allegations That Plant Control Opsators Did Not Perform Certain Alarm Tests," dated December 1, 1997.
3 Memorandum from DAVIS to JONES, dated December 15, 1997.
4 OI Memorandum Re: Meeting with URBAN, et. al., dated January 6, j 1998.
5 Transcribed Interview of FERNSLER, dated January 7, 1998. ;
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6 CAS Interview Notes (typed) of DAVIS by URBAN, dated July 1,1997. ,
CAS Interview Notes (typed) of DAVIS by DVDA, dated July 1,1997.
7 8
Transcribed Interview of DAVIS, dated May 27, 1998. ,
9 Hot Box 89 45 and Associated Procedure No. AD-QA 303, with Transmittal Letter from URBAN, dated January 13, 1998. ;
10 Letter from BYRAM to HEHL, dated February 27, 1998.
Letter from DAVIS to CHAMBLISS, dated January 5, 1998. l 11 01 Memorandum for the Record, dated June 19, 1998. l 12 i
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