IA-85-799, Partially Withheld Package of Info Re Plant Investigation, Including Draft NRC Ltr to Aslb,Partial Transcript & Handwritten Notes
| ML20214R335 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/01/1986 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20214R294 | List: |
| References | |
| FOIA-85-799 NUDOCS 8612050435 | |
| Download: ML20214R335 (85) | |
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lpf J MI I I Peter B. Bloch, Esq., Chairman Herbert Grossman, Alternate Chairman = Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Dr. Walter H. Jordan Administrative Judge 881 W. Outer Drive
- Oak Ridge, TN 37830
/ In the Matter of Texas Utilities Generating Electric, et al. (Comanche Peak Steam Electric Station, Units I and 2) Docket Nos. 50-445/2 and 50-446/2
Dear Administrative Judges:
s On November 2, 1984, the Staff was requested to " advise the Board of its view whether all or parts of the 19 [0ffice of Investigations reports relating to Comanche Peak Steam Electric Station] at issue (as well as other in-process 01 investigations) are potentially relevant and material to the licensing proceedings, including issues of intimidation and of management comitment to quality." LBP-84-48, slip op. at 1. The Staff also was asked to explain the possible relevance of these materials "in as much detail as possible without After violating reviewing confidences each of the 243prOIrights to at reports personal property." Id. issue, it is the Staffs view that twenty (20) reports are relevant to this licensing proceeding. Specifically, in the Staff's view, nine (9) of the 01 reports are relevant to the issue of intimidation of quality control inspectors; five (5) OI reports relate to construction practices at CPSES; and six (6) 01 reports are relevant to the issue of Applicants "comitment
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1/ Actually, there are a total of 25 OI reports relating to CPSES. Copies of OI report Q4-83-026 (18 October 1983) and its February 7 1984 Supplemental, both of which relate to the "Lipinsky Memo," already have been made available to the Board and the parties. See Letter from Staff Counsel to Licensing Board (27 Nov mber 1984). fou-ss-79 861205043S 861201 cNDE8N99 PDR e 1
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- 2 to quality." In the Staff's view, four (4) of the OI reports An areindex not relevant to any of the issues in the licensing proceedings.con regarding its relevance is attached as an Appendix to this letter.
Respectfully submitted, Gregory Alan Berry Counsel for NRC Staff
Attachment:
As stated - cc w/ attach.: Service List e im.i---i..ii
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APPENDIX INDEX OF OI REPORTS RELATING TO CPSES .
- 1. OI Report Q4-84-011 (13 March 1984)
Re: Alleged Intimidation of Balance of Plant Inspector A former CPSES boilemaker supervisor reported to 01 that a CPSES . craft superintendent intimidated a former CPSES Balance of Plant (BOP) Dug inspector into accepting unsatisfactory welds on the condenser in Unit g jg II. The. BOP inspector was interviewed by 01 and advised OI that the welds in question had been repaired and reinspected by him and that no one at CPSES had intimidated or attempted to intimidate him. In the Med mdi Staff's view OI Report Q4-84-011 is relevant to the issues of intimi- 5T6A-dation and harassment of quality control inspectors and the adequacy of Applicants' welding activities. Co m %ds-pi
- 2. 01 Report Q4-84-037 (12 September 1984)
Re: Alleged Threat Against QC Inspector A former CPSES quality control inspector related to OI that a member of Brown & Root management warned him that his career in the nuclear industry would be affected adversely if he became a whistle blower or gave information to the NRC or Intervenor. During the course of the interview, the QC inspector stated that he did not perceive these remarks 4" ( as constituting a threat but rather as a warning of the possible conse- g c - /' quences if it became known throughout the nuclear industry that he had made allegations concerning CPSES. See Attachment 2 at 37-38. During M the interview with 01, the quality control inspector described several other instances of alleged harassment and intimidation directed toward .T D him by CPSES management. These instances of alleged harassment include: (i) the OC inspector's transfer from and subsequent reassignment to the N-5 Group; (ii) the promotion of less qualified QC inspectors at the QC inspector's expense; and (iii) pressure by CPSES supervisory personnel to sign off on an incomplete NCR. In the Staff's view, 01 report Q4-84-037 is relevant to the issue of harassment and intimidation of quality control inspector.
- 3. OI Report Q4-84-046 (22 October 1984)
Re: Suspected Harassment of QC Inspector Jame: Gagliardo relayed to OI information obtained by him from a y* L CPSES quality control inspector who was serving as his guide during a tour of CPSES in connection with the TRT's inspection of the facility. M A j' Statements indicated to Gagliardo that a QC supervisor systematically n tried to get rid of conscienHous QC inspectors, and that a QC super- wl/ wSM> 1 SSEf
i visor 'and ASME QA manager threatened to have QC inspector take a lie i detector test. QC inspector told Of that QC supervisor nor ASME~QA manager'had ever tried to intimidate him. In the Staff's view, 01 Report Q4-84-046 is relevant to the issue of harassment and intimi-dation of quality control inspectors at CPSES.
- 4. OI Report 4-83-001. (24 August 1983)
Re: ' Intimidation of Coatings QC Personnel Purpose of investigation was to determine whether a CPSES QC super-visor threatened his subordinates with termination if they continued to __ gN -
"OIidentify " nitpicking" non-conforming conditions during their inspections.])is rele- [ p concluded that he did. In the Staff's view, OI Report 4-83-001 vant to 'the issue of whether quality control inspectors were deterred or W ,
intimidated by craft personnel or QC management from reporting non-conforming a-s conditions.
- 5. OI Report 4-83-013 (3 November 1983)
Re: Alleged Intimidation of QC Personnel The' purpose of 01's investigation was to determine whether the firing of Charles Atchison served to discourage other QC inspectors from reporting 1 r. deficiencies. Sixty-two QC inspectors were interviewed, 61 of which said g 9 they were not intimidated by action taken against Atchison. view, 01 Report 4-83-013 In the Staff's h 'A dation of quality control inspectors. Q% is relevant to the issue of harassment and intimi M SSER
- 6. 01 Report 4-83-016 (26 July 1983)
Re: Alleged Discrimination Against QC Inspector Purpose of investigation was to determine whether alleged improper % termination of William A. Dunham for protesting lack of support for QC 1d M inspectors from OC supervisor personnel served to intimidate other QC wg4 ,; inspectors from reporting non-conformances. 01 found that TUGCO's action
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intimidated QC inspectors but did not prevent them from performing their ' ' duties properly. In the Staff's view, OI Report 4-83-016 is relevant to the issue of harassment and intimidation of quality control inspectors. bid / ads-ep
- 7. 01 Report 4-84-006 (7 March 1984)
Re: Alleged Intimidation of QC Personnel Purpose of OI investigation was to follow up on information provided hQ,_. by CASE relating to harassment, intimidation, and threats to CPSES person - nel . 01 interviewed 24 persons, 22 of whom were present or former CPSES f M ,m, u employees. Of these 22 persons,12 were craftsmen, 7 were QC inspectors, f _ and 3 were engineers. c'*'b FourteenofthisgroupstatedthatApplicantshad'}4gg,r[ intimidated or tried to intimidate them during their tenure at CPSES. y, / ,g n . .
Of these 14 persons, all but 6 previously had made known their concerns to the ASLB either through direct testimony, limited appearance statements, or affidavits introduced by CASE. Of the remaining six members of this group, only two subsequently have given testimony in the intimidation portion of this licensing proceeding. In the Staff's view. 0! Report 4-84-006 is relevant to the issue of harassment and intimidation of CPSES quality control inspectors.
- 8. OI Report 4-84-00'8 (9 July 1984)
Re: Alleged Intimidation of QC Personnel A former CPSES QC inspector informed 0I of several retaliatory' actions d L L - taken by. Applicants. According to QC inspector, Applicants' supervisory b cp
. personnel tried to intimidate and harass QC inspector for testifying c before, $3 -
l ASLB. In the Staff's view, 01 Report 4-84-008 is relevant to the issue of ; harassment and intimidation of CPSES quality control inspectors. G u% % : 9 01 Report 4-84-012 (14 August 1984) Re: Alleged Intimidation of CPSES Craftworkers W3
- Purpose of investigation was to look into alleged intimidation of d.
CPSES craft worker by TUGC0 managament. Since this allegation relatesM' to intimidation of craft workers, the Staff considers this allegation 4' CW-b tdieyondthescopeoftheproceeding. .
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- 10. OI Report 4-83-006 (11 July 1984) b ~ 95 Re: Alleged Falsification of QC b. cords Purpose of investigation was to determine whether NCR identifying cracks in concrete basemat of reactor containment building was altered A/M Ass, t (
or forged. In 1983, a CPSES QC inspector contacted OI to relate the r-substance of a conversation between the QC inspector and another identi-fied QC inspector. According to alleger, in this conversation the other QC inspector boasted that the reason CPSES management continued to em oy him was because he signed another QC inspector's signature "better th [that QC inspector] himself." The alleger reported this incident to 0 O{ ') because he sunnised that this individual may have forged a signature on an NCR involving cracked concrete in the Unit I reactor basemat. OI interviewed the person whose signature appeared on the NCR in question and learned that the signature on the NCR was genuine. In the Staff's view. OI report 4-83-006 is relevant to the issue encompassed by Conten-tion 5; namely, alleged cracks in the concrete basemat of Unit 1. u
- 11. 01 Report 4-83-011 (24 July 1984) Coh5 f k - m[
Re: Suspected Falsification of QC Records Investigation was conducted to detennine whether QC protective ~ AGi ~ f$ coatings records were alterer' or falsified by CPSES QC Supervisors to pass ANSI review. It was alleged that in the course of a document c.* 5 'i - pf
review' of protective coatings applied prior to April 1981. CPSES QC supervisors altered and falsified coating records to make them accept-able and eliminate the need to reinspect those coatings in connection with Applicants' backfit program. In the Staff view. 0! Report 4-83-011 is relevant to the issue relating to the adequacy of Applicants' QA/QC program. .
- 12. OI Report 4-82-012 (23 November 1982)
Re: Alleged Electrical Deficiencies Purpose of investigation was to explore four allegations of construc tion deficiencies in electrical department alleged to have occurred between p'g Asse.t
,= August 1979 and January 1980. These deficiencies related to the use of 1 improper lug nuts and cable splicing. Three of the four alleged deficien-
- cies involved non-safety related wiring. Subsequent to the receipt of the allegations, Region IV conducted an inspection of the alleged deficient items and found no irregularities. A review of non-conformance report (NCRs) generated during the period December 1979 through February 1980 revealed deficiencies similar to those alleged; however all of those deficiencies had been remedied by March 1980. Inasmuch as OI Report b
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4-82-012. relates to Applicants' construction practices in the electrical area (a subject not embraced by Contention 5), the Staff does not consider that document relevant to this licensing proceeding.
- 13. OI Report Q4-84-007 (9 February 1984)
Re: Alleged Violations of Construction Practices Former CPSES craftworker informed 01 that he disagreed with several statements regarding improper construction activity at CPSES alleged to g*g#7 have been made to media by craftworker's former supervisor. Craftworker disputed truth of statements attributed to supervisor concerning relocation of main steam line, posting of NRC " Notice to Employees" signs at CPSES, and unauthorized cuts in tube steel to accommodate hilti bolts. In the Staff's view, 0! Report Q4-84-007 is at best marginally relevant to any of the issues in this proceeding. c% hs,, _.
- 14. 01 Report Q4-83-011 (23 May 1983)
Re: Alleged Poor Construction Practices Report summarizes conversation between OI and fonner CPSES laborer g regarding the latter's concerns over the construction practices at bf CPSES. Alleger identified several problems involving the pouring of concrete in the Reactor and Safeguards Buildings but was unable to provide specific and detailed information. Consequently. 01 did not take any action other than refer the matter to Region IV. In the Staff's view, 01 Report is marginally relevant to the issue relating to the emplacement of concrete in the Reactor Building. e
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h Of Report Q4-84-001 (9 January 1984) - 3 [1 Ret Alleged Improper Constryption Practices ( b" - Report summarizes an interview given under oath to OI by a CPSES bil $ JLH craftworker, In the interview the craftworker described several instancesL9 55( of intimidation of craft by CPSES supervisor, disregard of procedures by electrical craft and QC personnel, and faulty construction work by elec-
} trical craft. Inasmuch as O! Report 04-84-001 concerns _ Applicants' e electrical activities (a subject not encompassed by contention 5) an_d the possible harassment of craftworkers rather than quality control inspectors. the Staff dnes not _cmsider thjs document relevant to any ^
of the issues currently before the Licensing Board.
- 16. 01 ' Report Q4-83-022 (2 November 1983)
Re: Alleged Improper Implementation of Technical Procedures s Report transmits correspondence from a former CPSES coatings Md Astpd
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y inspector which identifies several concerns relating to the procedures governing the testing and application of protective coatings and the sufficiency of inspection reports to document non-conforming conditions. In the Staff's view, OI Report Q4-32-022 is relevant to at least two issues in this proceeding: (i) the adequacy of Applicants' protective coatings activities and (ii) the adequacy of Applicants' quality control / quality assurance program.
- 17. OI Report Q4-83-009 (8 April 1983)
Re: Alleged Irregularities in "As-Built" QC Inspection Program
/V het t Report summarizes concerns of CPSES QC inspector concerning the adequacy of Applicants' "As-Built" program. According to alleger, QC pgg inspectors were required to conduct a complete reinspection of all piping A $ 54 1
and pipe hangers, including a material dimension examination. Because these inspections resulted in the identification of numerous discrepancies, it is alleged that QC management ordered QC inspectors to discontinue material dimension inspections and concentrate only on the general configuration of the pipe hangers. l Alleger also expressed concern over the procedure utilized to generate design change authorization (DCA) and Component Modification Change (CNC) inspection reports because there is no requirement to ensure that the hardware installed conforms to the DCA or CMC. In the Staff's view, 01 Report Q4-83-009 is relevant to the issues of Applicants' commitment to quality and the adequacy of Applicants' quality control / quality assurance program.
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- 18. OI Report Q4-82-025 (5 November 1982)-
~ .9 Ret Alleged Irregularities In Comanche Peak Radiographic Operations An individual identifying himself as " John" phoned the CPSES Resident "
Inspector to complain about certain practices of Radiography Shop employees. According to " John," Radiography Shop personnel: (1) changed the film auto-matic processor speed so as to get the correct film density; (ii) reamed "T-holes" in penetrameters to a larger size" to give the appearance of adequate file sensitivity; and (iii) " masked [ deflective welds) when shooting thin wall repairs." At 01's, request, Resident Inspector i contacted alleger to discuss his concerns. The alleger, however, denied
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he had as, ever contacted belonging to theNRC sameeven though person Resident identifying Inspector himself recognizedC-5b.deip, as John." According to Resident Inspector, alleger agreed to meet with 01 Region IV; I, however, alleger failed to appear. Consequently. 01 decided not to pursue any of the allegations made to Resident Inspector during first conversation with alleger. In the Staff's view, OI Report Q4-82-025 is marginally rele-vant to the adequacy of Applicants' QA/QC program insofar as it relates to Applicants' coatings and welding activities.
- 19. OI Report Q4-82-0011 (2 August 1982)
Re: Alleged Section 2I0 Violation Purpose of investigation was to determine whether a CPSES QC inspector had been terminated for attempting to write an NCR - f7 the improper installation of Hilti bolts. OI and the Department of Labor O/- concluded that QC inspector was tenninated for displaying a poor atti-tude and for being insubordinate, not for attempting to write an NCR. g 's Ao In the Staff's view, OI Report Q4-82-0011 is relevant to the issue of j y harassment and intimidation of CPSES quality control inspectors. % (./(-)u
- 20. Li Report Q4-82-0005 (2 August 1982)
Re: Alleged Welding Irregularities Former CPSES welder contacted OI to complain about welding practices,4 lack of welding training and experience on part of welders and inspectors.c and possible falsification of weld radiographs. Specifically, alleger indicated that during his tenure at CPSES from 1977-80, welders were not l trained adequately and that QC inspectors lacked sufficient technical expertise to perfonn their duties. In addition, alleger indicated that the " poorest quality weld rods are being used" at CPSES; that welders fail to make welds in limited access locations; and that welders do not j.) I i always comply with preheat requirements. Finally, alleger suggests thatb" lNT "if radiography of these welds was done, someone must have falsified the identification of radiographs." In the Staff's view, 01 Report Q4-82-0005 is relevant to issues relating to the adequacy of Applicants' welding practices.
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p 21.' O! Report Q4-83-021 (29 August 1983) Se:. Alleged Intimidation of Electrical Craft Electrical worker at CPSES contacted DI to complain about lack of dq training ,provided to electrical workers at CPSES. Caller informed OI ( 7thatelectricalworkersaregivenonedaytomaster 400-500 page manual h d M g j) 'and are discouraged from consulting manual in performing their duties. Caller also reported that electrical workers are subjected td' frequent hn14 pH a :
,/ harassment from Electrical Superintendent and are often threatened by him 3%
with termination., Inasmuch as DI Report 04_Abn21 retetes te nassiht. harassment of craftworkers rather than quality ' control inspectors, the Staff does not believe that this document itfeievant ra === -++- '=
' issue in, this pr6cfEtring.
- 22. OI Report Q4-83-025 (10 February 1984) .
Re: Discouraging Use of NCRs Report transmits transcript of tape recorded meeting at which CPSES O Site QA Manager purportedly ordered quality control inspectors to document = non-conforming condition Staff's view, OI Report Q4-83-025 on inspection reports rather than NCRs.is In the relevant
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to.the m *issu f' the adequacy of Applicants' OA/0C program and to applicants' comitment to quality. k e,c _ qpf '
- 23. OI Report Q4-84-016 (11 April 1984)
Re: Alleged Improper Construction Practices OI. received call from an inmate at the-Texas State Mental Hospital 2 -Q q concerning safety problems at CPSES. Inmate, diagnosed as paranoid l psychotic, is a former CPSES electrician. Specifically, alleger indi-cated that: (1) bent steel rods had been emplaced in the " upper inter-nals behind a missle shield in the core'of the nuclear reactor"; (ii) the s i concrete pad at the bottom of the reactor core was cracked; (iii) the polar I crane on top of the reactor vessel collided with. hangers when rotated;'and (iv) festume cables located un the polar crane contained broken internal wiring. Inmate's concerns were investigated by Region IV and found to be without merit. In the Staff's view, 01 Report Q4-84-016 is relevant (. ~ m h' 7u to the issues relating to the alleged cracks in the concrete pad in the reactor core and the alleged damaged polar crane. ,
- 24. OI Report Q4-83-023 (20 September 1983) 4 _ i'^ '
Re: Alleged Poor Management Practices '
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Former CPSES electrician contacted OI to lodge complaint against CPSES electrical foreman and general foreman. Accordingtoalleger,j/ general foreman and foreman hired a pipefitter as an electrician and c,1 [g
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F:: . . - s.. .- - contin'ued his employment even though they were aware that he was incom-petent. A11eger said other electricians were assigned to make pipe-fitter's work acceptable. A11eger also complained that foreman refused to permit him to requisition materials from the Fab Shop or to provide him with the documentation for the work he was to perform. Last, alleger complained that the 60-70 cable tray hangers on elevation 810 in the Safe-guards. Building were not constructed in accordance with the applicable
. design change authorization (DCA). . . .. ,
Insofar as it' calls into question the ability of QC inspectors to detect deviaiions from DCAs, the Staff believes that 01 Report Q4-83-023 is relevant to the issue of the adequacy.of Applicants' QA/QC program. kd ni ',&}.kke - bdwdl.}Mkg s _ dp4-33 o 24 s 9 - 9 t -ol3 gq- h' O IY 4'M 4 9 m_f g-.u-oog 4- m-oso i l 1 l l l 9
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J. 94 J _ 1 TRT. The first item I would like to cover is under 2 category one. Involves allegations identified as AW-38 3 and AQW-24. The subject of this, and 4 I'd like to confirm this with you, is welding repairs 5 were performed out of procedure, and without 6 authorizing documentation, on a tube steel structural l 7 member on a diesel generator. Is that essentially 8 correct? e w 9 Right. That's correct. ' 10 According to TUGCO, it was a arc l 1 11 strike, with their lying, it was torqu , some arcs was 12 cut into it several places. 7
'13 MR. THOMPSON: Well, let me tel yo what the TRT l 14 did on this. When we started investigating, we s
15 determined that this related to an unauthorized welding 16 repair, as we understood it, of a base metal defect in 17 an auxiliary support skid, for one of the Dela Valley ' 18 emergency diesel generator systems in unit 2. 19 It was -- the work was performed 20 on account of a millwright did not use a torch. And he 21 made several cuts when he'was cutting a piece of steel 1 22 off. So they decided to repair it before someone seen 23 it. That was a cover-up, is what it was. l ~ 24 MR. THOMPSON: Are you taking notes on this, 25 Chet? Because I'm not taking notes from what Mr. GODFREY & AMES COURT REPORTING
l 95 saying. Okay. And your allegation stated 1 2 the incident occurred in August, 1982. That's the time 3 period we have got. I 4 How we related this' allegation to a TUGC0 NCR, 5 and which was reported by you. You're the - 6 , 7 originator of this NCR. 8 MS. GARDE: What's this number again, please? HR. TH0HPSON: Now this 9 10 NCR stated that during rework of the diesel generator !
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11 support structure, there was a structural steel 12 member. And it was identified on the NCR as item G,
**~~f 13 was damaged. And the damage which was called a base 14 metal discontinuity, was repaired by welding.
15 However, that the filler -- the weld filler metal 16 was not issued specifically to accomplish that repair, - 17 which violated the Brown & Root procedure, CP-CPM-6.9B, 18 which is weld filler material control. I think that
- 19 was all right in the NCR that you had originated. -
20 Now the TRT reviewed the history related to -- the NRC bistory related to the unit two support skids. And 21 22 there,was an NCR number M-8200581. Again, no revision, 23 which reported on May 13, 1982, that both of the unit 24 two auxiliary skids, which should have been to ASME , 25 brought on pressure vessel code, section 3NF component
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, 96 1 supports were not in fact NF.
2 And this NCR disposition, which was dated May 20, 3 1982, about a week later, specified in part that the 4 accessible welds not mee' ting a Brown & Root 5 specification -- or, pardon me, procedure, CP-QP-11.11, 6 revision 1, should be reworked, these accessible l 7 welds. Now the TRT was unable to find any 8 authorization for that. 9 Let me say this. My whole 10 complaint was -- my complaint was this. We tell our 11 people, do not work out of procedure on safety 12 meetings. These guys -- George Townley and_ Lee. Carne; 13 came by, that's the two high supervisors- of the 14 millwright department, and told these people, if they 15 didn't repair that before five o' clock, they better do 16 it or else hit the gate. 17 So my foreman called me on the radio, and said we 18 have got a problem on the diesel generator. So I came 19 by to see what the problem was. He told me, he said, 20 " Lee and George told me to repair this without 21 paperwork or else." 22 I . a'a i d , "He. told you or else?" 23 And he said, " Yeah." 24 I said, "Go ahead and repair it." 25 And you te said, "You have got to be kidding me." 4 GODFREY & AMES COURT REPORTING
97 n 1 Because I always told me to make sure -- I always 2 stood up for them. I said, "I'm going to Houston 3 anyway." 4 I was going to squirrel on these people. I said, 5 "Go ahead and do it. I'm going to Houston. It's time 6 for me to go on vacation." .I had already had a lot of 7 stuff to tell the people in Houston. 8 That was the whole purpose of this. All the skids 9 had been replaced and all that stuff. Even the piece 10 they welded on, they found cracks in it. They cut it 11 out and threw it away.
,, 12 MR. THOMPSON: Yes, that's correct. All right i
13 then we have essentially -- 14 The whole idea was just these 15 upper supervisors telling these people one day to work 16 by procedure, the next day tell them, either if they 17 don't, they're going to run them off. If they don't 18 work against them, they're going to run them off. 19 MR. THOMPSON: We found exactly, or essentially-20 what you have been saying. We found out that we in 21 essence have substantiated your allegation, we also 22 have substantiated that both of the auxiliary support 23 skids were scrapped, and are being replaced. So in 7 24 that sense, we find no safety significance. The . 25 hardware is being replaced. GODFREY A AMES COURT REPORTING
4 98 1 We did find some concern about the NCR being -- 2 the way the NCR's were handled, with respect to -- 1 3 have found no justification or documentation that said 4 that he could even make 'the repairs of welds that 5 existed. And there's been some t.ime lapses and there's 6 been -- I think on't of the things I got here is the 7 documentation of weld repairs continued for almost five 8 weeks after disposition to scrap and replace. 9 So we ha*ve some concerns about the NCR history. 10 And we're going to turn those over to the QA/QC group 11 for looking into. But -. 12 Okay. Then basically we have affirmed your 13 allegation, and we feel it has no safety significance 14 because it's going to be scrapped out and replaced. - 15 MS. GARDE: Okay. I have two questions. One, 1 16 when the SSER is written, wi'll the fact that it was -- 17 will it just say that there was no safety significance, i 18 or will it go through the history as you have just _ 19 presented it, and say that they have scrapped them, a'nd 20 therefore, there's no safety prob,lem? Is it going to 21 include that? 22 MR. THOMPSON: Unless something gets drastically 23 changed, this full history will be in here, yeah. l ~7 24 MS. GARDE: Okay. Now you say that you have not 25 yet referred to the QA/QC part of the TRT, your
110 1 The welder also stated that if he had a make an 2 attachment, they would use what they call an 3 electrician seat clamp to make such an attachment. So 4 no welding would be needed to adequately support 5 something. 6 So we found a single procedure dealing with it. j 7 We found nothing to substantiate the allegation, and no 8 evidence that the tack welding to rebar had occurred. 9 And that's the sum total of the investigation. 10 We're going to bring up new 11 allegations, and prove it. That's beside the point. A 12 different area, not this area. So let's go ahead. 1 13 HR. THOMPSON: Let's see. Where am I at now? 14 Charlie, let let me have 45. That's the fuel 15 transfer tubes. I'll c'over that one. Just give me the 16 SSER report, which you have got the graph there. I
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17 think I can work from that. Give me that one. 18 HR. RICHARDS: Stay put for you better. 19 HR. THOMPSON: This final item I have here is ' 20 category 45, allegation AW-65. Now this allegation 21 states that there were sua circumferential butt welds 22 made in the fuel transfer tubes of units one and two. . 23 And that these welds had incomplete penetration. 1 24 okay. Let me see if I'm at the start of this right at f 25 the first. Looks like it's here. GODFREY & AMES COURT REPORTING Metro 469-6100. (817) 460-2048
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o , 111 1 Okay. First thing I did in assessing this 2 allegation, I went into the fuel -- spent fuel pool, 3 and i went into one of the transfer tubes, and examined 4 the internal surface of it. And I established that 5 there's ne circumferential weld in the fuel transfer 6 tube. 7 The tube itself is made out of -- apparantly out 8 of plate stock. It's bumped around. And it has one 9 longitudinal welder. 10 You have got the expansion joint 11 going above it, where it comes to the wall and come 12 down? And you have got a weld up in here. 13 MR. THOMPSON: R i g h.t . That's what I thought you 14 might be talking about. The way it came through, it 15 says fuels transfer tube, but you were talking about 16 the penetration sleeve through the bellows expansion 17 joint. Right. Okay. We got into that, and we found 18 it. 19 All right. Let's see. Okay. You're in - 20 agreement that there's no circumferential weld in the
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21 fuel transfer tube. 22 Okay. What I determined here and they identified 23 these as with other weld numbers, weld 3A and weld 3c. ~l 24 These were on some other sketches. We figured you must 25 have been -- referring to what was originally described l I j gnnrorv i s ure cniint prennTTun
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. a 112
-. 1 as a circumferential weld between the expansion joint 2 assembly and the penetration sleeve.
3 And indeed these were modified in their joint 4 design. There was diametrical mismatch between the 5 penetration sleeve and the expansion joint. I guess l 6 it's an end ring, like it's welded on to the end of the 7 bellows. And because of this this mismatch, it was B gross enough that they had to modify the joint. 9 And they made a transition with a washer type of 10 plate stock. They cut it out of a washer,.or out of 11 plate stock, a washer type of a material. And I think 12 you probably know how it went together. It was i 13 something on the order of -- in cross section, like 14 this, with the penetration sleeve coming in one side, 15 and the bellows joint c'oming in the other. 16 And there was a mismatch, so one was higher or l 17 lower than the other.
- i 18 All right. Again, my concern was i
19 I had a welder down there welding, had two welders. 4 20 All right. When a millwright needs something welded, 21 theresupervisorcomesan'dsay,lllll[Ineedtwo 22 welders tomorrow to do welding so and so.* 23 Well, my -- then he writes the ticket out, and l 24 sees what type goes. He writes out the writer ticket. , ; 25 Okay. T.he next day one of my welders comes and GODFREY & AMES COURT REPORTING u-... >> c n cann ro.es .ca aa.o
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113 - 1 tells.me, supposed to be a full pin weld. We're 2 welding a full pin weld. It's sucking together. We're l 3 making a partial pin. Butt, in other words. 4 He's checking the paperwork. Here comes the 5 millwright supervision. You need to get rid of that 6 man. He's trouble. All he wants to do is question all 7 the paperwork. I said, "Well, that's what I teach them 8 to do, is question the paperwork, so they go by 1 9 procedure." - 10 HR. THOMPSON: This is the will welder now, was 11 questioning the paperwork, you're talking about. 12 Yeah. Because the paperwork 13 showed a full pin weld, and it wasn't a full pin. But 14 anyway, to make a long story short, "The other welder 15 would go ahead and weld anything he wants to." 16 He said, "He's down there welding on brackets he
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17 didn't even have a rod ticket for it. You know, my 18 hand are tied, because I was getting ready to get run 19 off, because I kept on trying to get them to go rights 20 So this velder-was a super good welder, and they 21 was putting the pressure on him. So I took him and I 22 moved h.im away from the millwrights, and put another 23 welder in there, just so they -- he wouldn't get run
' 24 j off. And his name's Mike Ratliff. And I suggested NRC 1
l 25 might want to. talk to him. ..
- I nnnenry x aurn ensinT p r o n o T T u r.
114 1 1 MR. POSLUSHY: R-a-t-1-e-y? 2 Ratliff? Okay. His name's Mike 3 Ratliff two l's. And that was my whole problem there. 4 MR. POSLUSNY: And he was the welder -- 5 He was the welder that tried to 6 go by procedure. Most of them did. But them 7 millwrights not too crazy about going by procedures. 8 All they want is to something done, you know. 9 But anyway, the millwr_ight ganar=1 fqteman came 10 to me, and said, "You need to get rid of that man. 11 He's nothing but trouble. He wants -- every piece of 12 paper, he wants to question, even the travelers." i 13 Which I told them to. We told them at the safety 14 meeting every Monday morning, work by procedure. Go by 15 your whole point. Don't jump in a whole point." 16 And then Monday evening they're wanting to run 17 somebody off. So that was my question -- my problem 18 again there. l _ 19 MS. GARDE: Who was the general foreman? ' 20 The general foreman va Al Moore. 7 21 MR. THOMPSON: The -- now -- okay. You have got 2P all that dewn, and it's -- 23 Now Ratliff came to me and said,
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24 "We're -- that's supposed to be a full pin weld we're , l 25 welding on. It's not. We're -- it's sucked together, CODFREY & AMES COURT REPORTING
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115 1 and we're making a butt weld, which is partial pin, 2 just a cap. That's what he told me. My hands was tied. I was 3 4 getting to the point I couldn't get involved, because 1 5 knew I was getting ready to get the axe, you know. 6 HR. THOMPSON: Well, let me -- I can give you the 7 technical summary of those welds you're concerned 8 about. The other part here -- 9 If those are the ones he is 10 concerned about. I didn't know. He just told me. I 11 knew it was somewheres on the transfer tube. 12 HR. THOMPSON: There are sketches and DCA's, which 13 show how they accommodated this diameter. mismatch, 14 which I'll try to show you briefly here. Now'the s 15 sketches show them -- in one case, are single bevel 16 welds, I believe, which were supposed to be, I believe, 17 full penetration. 18 And I think that was on one -- in one case. And 19 in another case. I think they showed them as coming in 20 with just fillet welds. I did go in and examine behind
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21 two welds, at least two welds. It might have been more 22 than that, but at least two welds, where you could get 23 in behind the wall, and take a look at the. backside. U ' 24 One weld had intermittent penetration. In other 25 words, I could see that it had melted through in part, r.nn e p rv i Awr4 r.nll R T REPORTING
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' 119 l . 1 all. And then I had figured what -- his allegation and 2 concern, and then I looked into that.
MS. GARDE: Okay. 3 4 Well, here's what all of it boils 5 down to. I had one good welder who was all super good 6 welders, and a real good worker. He tried to go by 7 procedure. He got pressure on him. The other welder, 8 he was also a good welder, but he wasn't a good 9 worker. /i 10 He was, you know, hewasweldinga)ywayhewanted 11 tc. As a matter of fact he was standing there welding 12 on a -- that is what he told me. Said he's down there 13 welding on some attachment he don't even have a rod 14 ticket for. But the guy that welded anywhere they m 15 wanted him to, is a good guy, and the one that wanted 16 to go by procedures is no good. I need to get rid of 17 him. 18 MR. POSLUSHY: What's the name of the second 19 welder, the one who -- , 20 y nny Ziebo. As a matter of 21 fact, here a while back, they caught him going out of 22 procedure, and he had to sit in the shop for a week. 23 MR. POSLUSNY: Z-i-e-b-o maybe? And the other one i I 24 is Mike Ratliff? . 25 Yeah. GODFREY & AMES COURT REPORTING _ _ _ - _ - - - _ . _ ._- ._ _. : : 1:.
120 , 1 MR. POSLUSl;Y: Could you tell me the millwright 2 supervisor who was giving him the pressure? 3 Well, the most person giving the 4 pressure is Lee CEnn.es and George Townley. 5 MR. POSLUSNY: Lee Carnes? 6 Right. And George Townley. But 7 in this certain incident, I think the man's name was A1 8 Moore. 9 MR. POSLUSNY: Okay. 10 What he would do, Al would go to 11 Lee, and Lee would come to me. 12 MR. POSLUSNY: Okay. So we, safety -- his safety
~i 13 evaluation, you accept that's .
14 N Well, if it was supposed to be a 15 full pin weld, and it's a Q item, and it's not a full 16 pin weld, it was a partial pin -- 17 MR. THOMPSON: There may be a violation. 18 -- against procedure -- against a 19 print. - 20 MR. THOMPSON: -- of the DCA even, of the DCA 21 change. I looked into it', and I was concerned about it 22 until I realized,that the balance was so thin, and the 23 weld was so thick, that the -- the weld in. question.
~~' 24 MS. GARDE: Are you not going to follow-up on any 25 procedural violation? You're going to send it to 9A/9c.
GODFREY & AMES COURT REPORTING
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124 } t 1 MR. RICHARDS: Category 43 pertains to the 2 liners. And I will do category 45 first, pertaining to 3 the allegation number AW-60. I might note that this 4 particular review was done by another party. 5 Therefore, I would have no recall value. It is. 6 though, real short and simple. l l 7 The characterization of the allegation is that 8 there are defective welds on the steam generator top 9 head insulation supports. 10 That was -- okay. We can make it 11 real short and sweet. I reported that when I went to 12 Houston and went to TUGCO. r 13 Brown & Root, how they was going to solve the 14 problem with a bad welds, they had wrote a letter. Mr. 15 Brown -- I forgot his n'ame, Brown, engineer for Brown & 16 Root, one day t'old me, said, "Bytheway,llllllIhave 17 corrected the problem of the bad welds." - 18 He said, " Corrected it by writing Westinghouse 'a 19 letter by saying, 'In the future, have your 20 subcontractor ascribe for better craftmanship.'8 21 Okay. That's how he' solved the problem. When l 22 TUGC0 got hold of it, and went down and looked at it, 23 they seen the welds were bad. They took it all down, I
~~7 24 cut it down, redid it, and that's the end of it. ,
25 MR. RICHARDS: Okay. Well, the assessment here GODFREY & AMES COURT REPORTING
- - _. "-^*-^ __-- "#"r#'^^ "' "^^ '^^"
- 1 125 1 1 states that the codes and specifications, quality l 2 control, inspection reports and other pertinent 3 documents, were reviewed. Excuse me. I feel like this l 4 is not in the order of t'he -- in the same order of ihe 5 characterization. Okay.
l 6 It also -- we had to take it all 7 out, cut it up, repair it, and hot function. They was 8 getting ready the do the hot function, and they 9 couldn't do it without it. You can see why they got 10 more pressure on it. Cost a lot of time and money. 11 HR. RICHARDS: I doubt -- I don't see anything 12 here relative, necessarily, you know, totally relative 13 to what you're saying. The review is applied to 14 obviously several allegations in the same area, s 15 For the AW-60, the vendor drawings were reviewed, 16 and a nonconformance report, number M-8201178, which ' 17 was initiated by QC. And it states here that the 18 vendor drawings for mirror insulation to -- they 19 reviewed these vendor drawings to determine if full , 20 penetration veld joints were called for, as was the 21 concern. 22 And they found that these drawings called for 23 fillet joints, and partial penetration joints, and i 24 found no callouts on the drawings for full penetration 25 joints. . GODFREY & AMES COURT REPORTING
126 l .-- 1 The problem with them was, you 2 could stick a pencil through them in places, the weld 3 was so bad, and they welded downhill. But I got the 4 report where TUGC0 had already inspected them, and 5 redid -- took them out, took the weld out, rewelded all 6 of them. I can find it. 7 MR. RICHARDS: Okcy. So this review of, being 8 subsequent to that, they would probably have found no 9 bad welds or areas where that were void of welds. 1 10 They wouldn't admit it anyway 11 now. { 12 HR. RICHARDS: However in the meantime, those, I'm
-i 13 sure that those same drawing requirements, not calling 14 out of full penetration weld, they probably -- I'm sure 15 that they didn't make efforts to assure that it was a 16 full penetration weld.
17 All right. Again, the reason 18 that was brought up because I told -- I reported the ) _ 19 same material accident found. And I get a bunch of red 20 tags pulled on it. 21 22 ( l 23 I ~~i 24 4 25 f v s' GODFREY & AMES COURT REPORTING
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. 127 1 About three hours I walked in the paint shop, 2 there was the framework for the lagging. What it's 3 for, for the steam generators. I told them -- I walked 4 back and seen George. -
5 I said, " George, you better go get you a 6 handfull of red tags, and take them down there.8 I 7 said, "That weld looks like crap." 10 So we -- me and him went flying down there, and he 11 said, "Oh, my God. I can weld better than that." 12 So he went and got the mechanical engineer, and I i 13 told you the rest of the story. . 14 HR. RICHARDS: Okay. Now in the meantime, of the t 15 review of another NCR, M-820 -- no, that's the same 16 one. Revealed rejectible defects in accordance to the 17 AWS structural code, D-1.1. 18 And these as documented were arc strikes, 19 undercut, overlapped, weld splatter, lack of fusion.- 20 And it states that these were reworked per disposition 21 on that as -- on that NCR'. 22 MS. GARDE: ,AretheseNCR'sgeneratedbyllll 23 concerns? ', i 24 HR. RICHARDS: They don't say. However, these 25 NCR's were apparently found during the review, as a l l l nnnenev i eure ennnr neonevTun
i 128 __. 1 result of his concerns. And it states that.the NCR 2 was closed on August the 26th, 1982. 3 MS. GARDE: That was around the same time period. 4 Oh, yeah. See that's the report 1 5 stuff I reported when I went to Houston. 6 MS. GARDE: They went wrote NCR's up? 7 _ No. They just put -- they told 8 me they had already -- they already put it in place, 9 the lower ones, to go with. Okay. 10 When I reported all this stuff, and Brown & Root's 11 investigating team came down, they looked at it, from 12 Houston. And they said even though the welds didn't I 13 look good, and this and that, Craig Brown, that's his 14 name, the mechanical engineer, wrote a letter saying 15 ause as is." Okay. 16 TUGC0 went down and looked at it. And when they 17 looked at it, they tore up it up, carried it behind'the 18 pipe shop, threw it down there, cut it all out, and 19 redid it. , 20 MR. RICHARDS: Okay. At least from the technical 21 standpoint, and for the integrity of the welding at the 22 present, has been satisfied. 23 It has. It looks better. f'l 24 HR. RICHARDS: And that's the end of that one. , 25 That does call for full pin weld GODFREY..&....AMES COURT REPORTING
I 129 1 on that, but anyway. 1 2 MR. RICHARDS: Well, I'll take it upon myself -- l 3 Check -- I 4 MR. RICHARDS: -- to review that drawing. - ; Now the remaining -- ; 5 HR. RICHARDS: 6 The good ones. 7 MR. RICHARDS: -- the remaining concerns of this 8 session. 9 MS. GARDE: Off the record. 10 (Whereupon there was a discussion held 11 off the record.) 12 MR. RICHARDS: This SSER category number 43, 13 regarding concerns about the fuel pool liners, there 14 are several concerns. But for be talking in -- 15 particularly about four' different concerns. 16 Prior to identifying an individual concern here, 17 I initially made an attempt to review all of the 18 requirements applicable to the liners. 19 Firstly, the ASME Section 3 code, addresses , 20 requirements for those items whicb are classified as 21 safety related, category 'one. And makes mention of 22 fuel pool liners only to the extent to preclude them 23 from category one requirements. That is, s,eismic
' 24 category one requirements.
25 So you're saying the stainless. GODFREY & AMES COURT REPORTING
. 174 ._ 1 anyway. AQ-55. Our favorite subject, fuel pool. And 2 our man for the fuel pool naturally isn't here. I'm 3 sure you heard that same old story, but we're going to 4 address it anyway. .
5 I think the allegation we talked about here, we 6 had some statements here about the weld radiography not 7 being completed. And again, that has just been covered 8 by this other group, Mr. Hollonson, so we are deferring 9 to that. 10 The other write-up we had in there was alleged 11 that the fuel transfer canal liner documentation was 12 falsified. Is that yours? 13 Yes. 14 MR. LIVERMORE: And we have another one. It says hold ' 15 that whpkt points on in'spection travelers for the fuel 16 building were signed off improperly. We believe that 17 is part of it. And I think we have 18 already addressed that. i 19 - That's mine also. , 20 HR. LIVERMORE: It's yours also? 21 Did you find any false 22 documentation? 23 MR. LIVERMORE: Oh, yeah. Let me just go into [' t 24 there an'd and tell you about safety versus nonsafety. , 25 and there's something I will bring up now.
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175
-- 1 .The determination whether the fuel pool liner is 2 safety or nonsafety is being addressed by Mr. Noonan.
3 I think it was rather premature to say it's going to 4 end up as nonsafety, in that the -- what the other - 5 group just mentioned was an old memo from many years 6 ago that come out from IE. Did not come from NRR, et 7 cetera. 8 What has come out recently is a staff position 9 from one of the branches, one of the divisions. Now 10 that has to be reviewed by Mr. Noonan. And all those 11 involved, and then whatever the final position is taken 12 will have to be presented in letter form to the board 7 13 and to everyone else involved. That has,not taken
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14 place yet. 15 So until that is finalized, and does come out in 16 that position, it is premature at this time to say 17 whether it's safety or nonsafety. 18 As far as our group is concerned, my answer to 19 that is, as far as our group is concerned, it makes no 20 difference to us. The fuel pool, as far as we were 21 concerned, was built and tonstructed in a safety 22 related manner to appendix B, which is called out in a 23 Gibbs & Hill specification. It was constructed and
?'l 24 inspected under appendix B. And therefore we consider 25 it so. ,
GODFREY A AMES COURT REPORTING
. 176 .
.-- 1 And whether it turns out to be non-safety related 2 or not makes no difference to our QA/QC, in that the 3 things that we found that went on there, were 4 indicative of a QA/QC system in place at that time, and 5 the things we found certainly were indicative of many 6 generie problems.
7 And therefore we feel that these have to be 8 addressed by the company, in regards to generic 9 aspects. We identify these problems, and we say, "All. 10 right. They did take place in the fuel pool. What 11 about other areas? If this is the way their QA system 12 acted when they acted in the fuel pool, then we i ' 13 certainly have concerns _about how they acted in other 14 areas. 15 That's where we're' coming from, and that's what 16 our SSER on the fuel pool will end up addressing. 17 Now down to specific falsification. We did find 18 Mr. -- how would be the word? To call something 19 falsification is very harsh. To me that means intent 20 to falsify, intent to -- 21 It 'means in the present sentence 22 intentionally. 23 M'R . LIVERMORE: Intent to defraud or whatever. We
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i 24 found many -- how would you phrase those? 25 MR. LANGOWSKI: Suspicious -- GODFREY & AMES COURT REPORTING
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al 177 1 .M S . GARDE: Irregularities. 2 MR. LIVERMORE: Irregularities. Many, many 3 irregularities. We have many examples in here. 4 Brown & Root said there is jusi 5 one. They have been working at one seam for two and a 6 half years now, trying to straighten it out. 7 MS. GARDE: That's what they told him. Have you 8 read the whole report, or has your team members read 9 the report, which was Brown & Root's own investigation 10 into original allegations of fuel pool 11 liners? 12 MR. LIVERMORE: I don't know if I can answer 1 13 that. Does Tom want to get into this? Is this part of 14 the board testimony? 15 HS. GARDE: It was attached to one of our 16 pleadings. It was this document? 17 MR. LANGOWSKI: I would venture to say that we 18 did. 19 HS. GARDE: It was attached to our first ' 20 pleading, what we called cases evidence of quality 21 control breakdown. I men'n you may -- if you reviewed 22 those documents. .it was there. 23 If you didn't review the documents, it has been
~l 24 entered into the record in the hearing also. It's an 25 exhibit now in the hearing.
rno-o-. . ... . ....-- ---------
I 1 178 1 MR. LANGOWSKI: I feel certain we have. 2 MR. LIVERMORE: That's something Tom has gone l 3 there everything in the hearing. He made some 4 statements in here. - 5 The problem here, everybody 6 blaming QC all the time for all these problems, when 7 any time you have got QC and craft working together, 8 craft can actually buffalo QC just about any minute he 9 wants to, because QC is not there every second watching 10 you. 11 And a lot of this false documentation with Jim m _ 12 Cole. He was tricked into doing it. He didn't i 13 necessarily think he was doing it. But he was actually 14 tricked'by people putting them out there, telling him 15 that he mistold points,'or do this and do that. One of 16 them would be talking to him while he was trying to 17 eat, before he ever starts to work, and the others 18 saying, "Go ahead and sign it. You missed it last 19 night." . 20 And he'd be signing the paperwork. That happened 21 two years ago. He should'have been more alert and paid 22 attention to what he was doing. But a lot of this 23 stuff he didn't intentionally do it. Like they're i 24 trying to use him for the fall guy. 25 And his superintendent and all, they told the day GODFREY & AMES COURT REPORTING *
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. . e 179 ,
1 shift people, they couldn't get them to sign it >ff . L.s 2 So they had them, the superintendent and the clerk, 3 would get together with the night foreman, which the 4 foreman, and have him get Jim Cole in there, and he ' 5 said, "We got to buy off this new welds tonight, these, 6 and everything." 7 And I'd be standing there watching through the 8 door. And my superintendent tell me, "You get out in 9 the field wtih your people. It's about knock time." 10 And I said, "I got my foremans there," my people. 11 And I was watching Johnny Winham trick Jim Cole in v 12 to signing those papers. And he said, "You come on and FI 13 go with me." - 14 And he would haul me off, you know, "You get in i 15 the field with your people." 16 But in all these hearings, it's got Jim Cole did 17 this and-Jim Cole did that, like he was a criminal. 18 And then most of that stuff, he was tricked to 19 do it. I know he was in the early stages. , 20 MR. LIVERMORE: That's a per,fect example of what I 21 was saying, you know, a direct falsification of it. 22 Yeah. But these people that had j 23 him do it, was doing it intentionally. I~7 24 MR. LIVERMORE: True. The pressure was always 25 there. You'll find that all through construction. GODFREY A AMES CO'URT REPORTING
u a 180
, 1 There's always pressure.
2 You got plenty of other people 3 that was doing it intentionally. 4 HR. LIVERMORE: You.'ll find that in any plant 5 where quality isn't, say, on the same level of muscle, 6 so to speak, as construction. And it was -- certainly 7 this was evident in the fuel pool. 8 MS. GARDE: Well, Herb, don't you think the 9 example that he just gave you is an indication that it 10 wasn't just -- I mean innocent, usual, everyday 11 construction pressure? 12 MR. LIVERHORE: No, we never said innocent. We 13 just said that it's a result of that. I don't think 14 there was anything innocent there. It6s something you 15 can't pin down and say'the guy purposely did it. 16 MS. GARDE: But wouldn't DI? 17 MR. LIVERHORE: I don't know what OI would say.' 18 All I'm saying is this is the way -- we're very careful
- 19 in the QA's group --
t - 20 There's several hundred. 21 HR. LIVERMORE: -- falsification. All I'm telling 22 you is we have many examples of what you juct talked 23 about. And to get any more examples, just adds to l'~' 24 another myriad of it, and it really doesn't add 25 anything over,it. Doesn't help us. GODFREY & AMES COURT REPORTING
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. 1 181 c .. 1 .HS. GARDE: Doesn't help you.
2 HR. LIVERHORE: We have already made our findings, 3 and we have a basis of many examples of exactly what 4 you're talking about for.our findinga, We really dor.'t 5 need any more. 6 The problem is -- 7 HR. LIVERHORE: So we can add it in there. But it B doesn't change our outcome, because our outcome still 9 still says tha,t, " Hey, ther.e's meny irregularities." 10 If these people are a13 owed to 11 get away with it on this job, they do the same thing 12 worse on other jobs. 13 HS. GARDE: That's why I asked if it's going to i
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14 OI. Not that I currently have a whole lot of faith in 15 01 following this stuff up. 16 But if he's alleging what is, at a minimum, l . ( 17 material false statement, and certainly misconduct on 18 the part of supervisory management personnel, for all 19 you know, and you know because you have done the 20 investigation more than I do, the guy who had hic do 21 that is still there. - l 22 And 1 know that your conclusion pretty much ends i 23 with, "Did it happen or did it not happen?" But I
;7 24 think there is intent in the situation and his 25 situation, that should be looked at.
l l GODFREY & AMES COURT REPORTING l
P. l' ' ' 182 1 So I guess my question is, is it going to be 2 referred officially to 017 3 MR. LIVERMORE: Yes, you have just gave me a 4 specific that is on record here. And thot specific 5 will be reviewed and addressed. My immediate reaction e 6 would be intimidation. I'll ahip that off to Mr.jpdy (5f. 7 Leon 2cto, and let him address that under that 8 intimidation panel. Now whether we'll also send it to 9 OI, I don't know. Someone will decide on that. 10 MS. CARDE: I just remembered that GAP 11 independently asked for an OI investigation in light of 12 this. But I don't know if they announced this or not. 13 I don't know if they have one. But we did ask for one 14 I think in October. 15 MR. LIVERMORE: Okay. So I guess really the 16 bottom line there is that there many of these 17 irregularities, and you can say one of the many causes 18 of them, poor practices, inadequate inspection forms, 19 pressure brought to bear by construction. These will 20 all be addressed, and their various causal factors. 21 As I said before, yo'u add up the sum total of 22 this, we found that the construction practices in the 23 fuel pool were certainly subject to heavy question, and
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24 we would certainly, as a part of the further action 25 that the comp.any has to address this, and then make GODFREY & AMES COURT REPORTING
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183 1 sure -to us that this didn't happen in any other area. 2 So I guess really what I'm saying in regard to
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3 your allegation, y e arr2a. Whether we agree with 4 its out and out falsification or irregularities, we,"at 5 this time, we're calling irregularities. We'll let -- 6 I haven't seen any specifically that someone came up to 7 me and said, "Yes, I did specifically, with intent to 8 defraud, falsify this document." 9 HS. GARDE: Is that the kind of evidence you would 10 need to say it was? 11 HR. LIVERHORE: Myself personally, yes. 12 In other words, just about 13 anything goes in nuclear power? . 14 HR. LIVERMORE: No, I did not say that, no. I - 15 said we would --- you know, back up a second. 16 If people will get away with j 17 that, that's just about as worse as you can get. 18 MR. LIVERMORE: I understand that. We're not l _ 19 talking about letting them get away with it. We're ' l 1 20 addressing the whole problem in that respect. What I'm 21 saying is, before you accuse somebody of falaification, 22 you hav.e to reall,y understand what that means, by 23 virtue of the law.
24 MS. GARDE: That's what I said isn't OI the ones 25 that have to do that?
GODFRF.Y A AMFR coliWT neonottue
1. E E *. 184 e - 1 MR. LIVERMORE: Well, I'm not sure. Like I said, 2 this will go up to lntimidation panel and up to 3 management and up to 01 if it's necessary. l 4 Cliff, do you want to add anything to to that? 5 HR. HALE: Well, only with respect to like the 6 falsification issue. An example that we identified, at 7 the plant, a gentleman predated a training 8 certification. And he admitted it. 9 Well, now that's falsification. So you can -- I 10 mean, falsification takes on many masks. And I think 11 the intent behind, it's an intent to defraud, then I
- 12 think OI and maybe even the Department of Justice gets 13 involved in the thing. And I don't know that 01.-- if
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14 you requested OI to be involved in this issue, they s 15 perhaps may already be now. 16 MS. GARDE: They may already be. I don't know if 17 they are or not. 18 HR. LIVERHORE: Well, they have been involved with 19 this whole fuel pool business. But in regards to your 20 specific detail one, we were talking about the specific 21 people pressuring this sp'ecific -- 22 MS. GARDE: Jim Cole. 23 HR. LIVERMORE: -- this name, that's something we
< . 24 will have to address, and pass that through. ,
25 HR. POSLUSNY: Just a background question. Cole GODFREY & AMES COURT REPORTING
o - 185 j e T 1 was a QA/QC inspector? 2 Right. 3 HR. POSLUSHY: And Johnny Winder? 4 He was my night bar foreman on' 5 the -- boilermaker foreman on night shift. And we was 6 having to -- well, we had all those travelers we had to 7 get signed off, several hundred of them. And day shift B QC wouldn't have no part of it. 9 HR. H ALE :- I think one area we were looking at in 10 this same subject area was that -- where there appear 11 to be some, p,erhaps falsification, in the sense that 12 someone filling in a date or signed -- made a i 13 signature, after the fact, was in the records review.
.' 14 And they were going through and reviewing the records 15 to assure that they were complete and accurate.
16 We found some -- I think we found some that 17 appeared to have been dated, you know, predated, or 18 dated back a year or something like that. But again 19 you get to the -- you're at the point that, unless you 20 find somebody that will admit that they did that, end 21 point to it, then you hav'e got a confession, all you 22 can do.is suspect that may have occurred. ( 23 HS. GARDE: Okay. I just want the record to be Tl 24 real clear that I think if you all, as -- even in the 25 QA/QC area, are making decisions on intent in this GODFREY
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[d t whole -- in all these proble=s, that we have a real e. 2 problem with that. Because, frankly, as much as I 3 adore all'you in QA/QC, and I think you're doing a 4 great job, I don't think that you're qualified as 5 criminal investigators. 6 MR. HALE: Well, I would hope that that wasn't the 7 way that I was -- that what I was saying was being , 8 taken, because we're not trying to psychoanalyze this 9 thing. 10 MS. GARDE: Yeah, it does come -- 11 MR. HALE: But what I'm saying is that we're 12 looking for falsified records, falsification in 13 records. And you can't -- you can't find that. 14 MS. GARDE: Well, what you find -- 15 HR. HALE: You can' suspect it, but -- 16 MS. GARDE: Well, when you find something that's
\
17 not true okay. If you find something that is not true, 18 something did not happen on a day something was signed, 19 things don't match. , 20 HR HALE: Okay. Then you can line something up, 21 and you can see an error.' 22 HS. GARDE: Right. And that's called a 23 material false statement, unless he can prove intent, i 1 24 right? , 25 MR. HALE; Or an error. GODFREY..&....AMES COURT ..._. REPORTING
187 . ei 1 .MS. GARDE: Well, that's true. That's why it's a 2 caterial false statement. The whole Midland plant was 3 built on an error. 4 MR. HALE: All right. It's an error. You're ~- 5 calling it -- you're prejudging it and calling it, and 6 calling it a material false statement. 7 When it is. In other words, what 8 you're trying to say, if you go out and rob a bank for 9 $10, and you go out and rob it for $10,000, there's a 10 difference. That's what you said earlier. When you 11 rob a bank, you rob a bank. 12 MR. HALE: Me? He didn't say that. 13 HR. POSLUSNY: We have turned things over to OI 14 that we have suspected in false statements. And we'll 15 check on this one. It's Vince's policy to do such. 16 And we think we have been responsive. 17 MS. GARDE: Okay. Well, I'm not saying you're 18 not. I don't want to happen what happened at Zimmer 19 where IE held on to things that ultimately ended up . 20 screwing up an FBI investigation. 21 And if there's thing's that should be referred -- I 22 mean, you all know what you're doing. You don't need 23 me to tell you what to do. But since I'm telling you i-'t 24 what to do anyway, if you have got that, I hope you're 25 referring.it.up. GODFREY a AMES COURT REPORTING
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*J' Draft 3 - 6/10/85 TABLE OF CONTENTS Pace ABSTRACT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .iii ACRONYMS AND ABBREVIATIONS. . . . . . . . . . . . . . . . . . . . . . . . .vii
- 1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
- 2. THE COMANCHE PEAK INTIMIDATION PANEL AND ITS ADVISORS AND CONSULTANTS.2-1 APPENDIX Q - Status of the Comanche Peak Intimidation Panel Evaluation of Allegations of the Intimidation and Harassment of QA/QC Employees at Comanche Peak Steam Electric Station, Units 1 and 2 . . . . . . . . . . . . . . . . . . .Q-1 4
v l l v . Comanche Peak SSER 13
.' Draft 3 - 6/10/85 1 INTRODUCTION On July 14, 1981. the U. S. Nuclear Regulatory ComTission (NRC) issued a Safety Evaluation Report (SER) (NUREG-0797) related to the application by the Texas Utiliti he Peak Steam l
Mes Electric Com details of the Comanche Peak Intimidation Panel's evaluation of each allegation l l and the panel's findings. 1 j The allegations of intimidation and harassment at Comanche Peak were part of the regulatory issues that remained outstanding as construction of the Comanche Peak facility neared completion. The Atomic Safety and Licensing Board pre-siding over the proceedings related to the CPSES operating license application had determined in March 1984 that it must address and resolve the allegations of intimidation and harassment to resolve the only remaining contention (Contention 5) in the proceeding. The Board began its proceedings on the intimidation and harassment issues in the summer of 1984. In July 1984, the Project Manager of the Comanche Peak Technical Review Team (TRT) directed a team of consultants to review the record of allegations of intimidation and the work climate at the CPSES site to determine whether a climate of intimidation existed among QA/QC personnel at the site. Their report, 1-1 Comanche Peak SSER 13
Draft 3 - 6/10/85 issued in September 1984, concluded that a climate of intimidation did not exist n - x 7 l Operations (EDO) issur:d a directive on December 24, 1984, establishing the Comanche Peak Intimidation Panel to provide findings on intimidation to NRC management. The study team subsequently became consultants to the Intimidation Panel. Attachment 2 to this Appendix is a listing of intimidation allegations reviewed by the panel and the study team. Attachment 3 to this Appendix is a supplement the study team's initial report and includes its evaluation of each alleged incident of intimidation. The Comanche Peak Intimidation Panel has reviewed the results of this evaluation and concurs with its findings. The recommendations of the Intimidation Panel are discussed in Section 5 of this Appendix. s Comanche Peak SSER 13
Draft 3 - 6/10/85 e Management and coordination of all the outstanding regulatory actions for Comanche Peak are under the overall direction of Mr. Vincent S. Noonan, the NRC Comanche Peak Project Director. Mr. Noonan mey be contactec by cailing 301-492-7903 or by writing to the following address: Mr. Vincent S. Noonan Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 . 1 Copies of this Supplement are available for public inspection at the NRC's Public Document Room at 1717 H Street, NW, Washington, D. C. 20555, and the Local Public Document Room, located at the Somervell County Public Library On The Square, P. O. Box 1417, Glen Rose, Texas, 76043. Availability of all material cited is described on the inside front cover of this report. l l 1-5 Comanche Peak SSER 13
., , . 5:
Draft 3 - 6/10/85 2, THE COMANCHE PEAK INTIMIDATION PANEL AND ITS ADVISORS AND CONSULTANTS inel Members Axelrad, J. - Enforcement Staff, IE, NRC Gagliardo, J. - Technical Training Center, IE, NRC Hunter, D. - Reactor Projects Branch - RIV, NRC Lieberman, J. - Regional Operations Enforcement Division, ELD, NRC Panel Advisors Griffin, B. - OI, Field Office, RIV, 01, NRC . Ippolito, T. Office for Analysis and Evaluation of Operational Data, NRC - Kaplan, B. - EG&G Noonan, V. - Comanche Peak Project, N'<R, NRC Scinto, J. - Hearing Division, ELD, NRC Treby, S. - Hearing Division, ELD, NRC The EG&G Study Team and Its Consultants: Andognini, G. - LRS Consultants Bowers, D - Rensis Likert Associates Kaplan, B. - EG&G Margulies, N. - Graduate School of Management, University of California at Irvine Rice, C. - LRS Consultants Stratton, W. - Idaho State University
; 2-1 Comanche Peak SSER 13
, Draft 3 - 6/10/85 APPENDIX Q STATUS OF STAFF EVALUATION AND RESOLU'i10N OF ALLEGATIONS OF IN,TIMIDATION AND HARASSMENT OF .
QA/QC PERSONNEL AT t COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 Comanche Peak SSER 13
~
Draft 3 - 6/10/85 TABLE OF CONTENTS Pace
- 1. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . Q-1
- 2. Allegation Review Process . . . . . . . . . . . . . . . . . . . . . .
2.1 Definition . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2 Documentation Reviewed . . . . . . . . . . . . . . . . . . . . . 2.3 Review Format. . , . . . . . . . . . . . . . . . . . ... . . . . 2.4 Panel Review and Discussion. . . . . . . . . . . 1 . . . . . . 2.5 Interaction with Study Team. . . . . . . . . . . . . . . . . . .
- 3. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.1 Study Team Conclusions . . . . . . . . . . . . . . . . . . . . . 3.2 Events and Documents Not Reviewed by the Study Team. . . . . . . 3.2.1 Discussion . . . . . . . . . . . . . . . . . . . . . . 3.2.2 Intimidation Panel Conclusions . . . . . . . . . . . 3.3 TRT Findings in Those Areas Where Intimidation Occurred. . . . .
- 4. Managment Implications. . . . . . . . . . . . . . . . . . . . . . . .
4.1 Climate of Intimidation. . . . . . . . . . . . . . . . . . . . . 4.2 Management Style . . . . . . . . . . . . . . . . . . . . . . . .
- 5. Action Recommended. . . . . . . . . . . . . . . . . . . . . . . . . .
Q-iii i Comanche Peak SSER 13
.' Draft 3 - 6/10/85
- 1. INTRODUCTION As construction of the Comanche Peak Steam Electric Station was nearing coraletion, issues that remained to be resolveo prior to t*e consiceration of issuance of an operating license were complex, resource intensive, and spanned more than one NRC office. To ensure the overall coordination and integration of these issues, and to ensure their resolution' prior to licensing decisions, the NRC's Executive Director for Operations (EDO) issued a memo-randum on March 12, 1984, directing the NRC's Office of Nuclear Reactor Regulation to manage all necessary NRC actions leading to prompt licensing decisions, and assigning the Director, NRC's Division of Licensing, the lead responsibility for coordinating and integrating the related efforts of various offices within the NRC.
The principal areas needing resolution before a licensing decision on Comanche Peak could be reached included: (1) the completion and documentation of the staff's review of the Final Safety Analysis Report (FSAR); (2) those issues in contention before the NRC's Atomic Safety and Licensing Board (ASLB); (3) the completion of necessary NRC regional inspection actions; and (4) the completion and documentation of the staff's review of technical concerns and allegations regarding design and construction of the plant. To evaluate and resolve the technical concerns and allegations regarding design and construction of the plant, a Technical Review Team was formed. On July 9, 1984, the TRT began 10-week (five 2-week sessions) onsite effort, including interviews of allegers and TUEC personnel, to determine the validity of the technical concerns and allegations, to evaluate their safety significance, and Q-1 Comanche Pe n SSER 13
Oraft 3 - 6/10/85 to assess their generic implications. The TRT consisted of about 50 technical specialists from NRC Headquarters and NRC Regional Offices, ar.d NRC consultants, who were divided into groups according to technical ::isciplines. Each pecup was also assigned a group leader. Of the contentions before the ASLB, only one (Contention 5) remained unresolved in the CPSES operating license application proceeding. Contention 5 alleges that: The Applicant's failure to adhere to the quality assurance /.- quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construction practices employed, specifically in regard to concrete work; mortar blocks; steel; fracture toughness testing; expansion joints; = placement of the reactor vessel for Unit 2; welding; inspection and testing; materials used; craft labor qualifications and working conditions (as they may affect QA/QC and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility. As a resul+ ission cannot make the findings required by 10 CFR S ecessary for issuance of an operating license for Comanche Peak. Q-2
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- a. On January 15, 1985 the Comanche Peak Project Director forwarded to l the Intimidation Panel a portion of the deposition of Mr. Houser, a former CPSES QC inspector. (The material was forwarded to the panel
, at the suggestion of the Chairman of.the ASLB.) In the deposition, Mr. Houser stated that he had informed Mr. Tolson (TUEC QA Manager) as to how he and his fellow workers were going to review and verify individual DCAs (Design Change Authorizations) and CMCs (Component Modification Cards). Mr. Tolson became upset and told them, "No. That's not the way I want it done." Subsequent to this meeting Mr. Mouser and his supervisor went back to Mr. Tolson, I Q-12 Comanche Pc2.. SSER 13
Draft 3 - 6/10/85 who agreed to allow them to do the review as they had originally l proposed. This incident does not constitute an act of intimidation, because Mr. Tolson's statement was not likely to have caused a rea-sonable individual to do somethin .that was contrary t'o existing requirements. Further, Mr. later changed his position at the urging of his employees.
- b. On January 28, 1985 th,e Comanche Peak Project Director forwarded i to the intimidation panel a portion of Mr. Houser's deposition in l
which he alleged that an NRC OI investigator had apparently disclosed confidential information to TVEC employees. Nothing in this alleged incident linked any CPSES employees to any improper actions, and thus this event does not constitute an act of l intimidation. 1 I
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_ 3 ad% W ks k h b b\k Sol Is te 5 N 'l OL As a) w e H Q 4 ,s mdc,_ W u Add 4 h eted y'sq Name, position and duties of person subject to intimidation l d.9 3 R. A , b) Name, position and duties of person alleged to have intimidated; c) Names and positions of other persons either subject to or involved in the incident; hd N85'*^ b ' Ed3^9C d. %.h (S.,ms'y*E EG;As to Ca Et 4C n5( J. 4LM ee a 9c. E d) Areaofworkinvolved-welding, coatings,ehc.; Qg i(g 6 e) Date and place of incident; E Q A q 10( 1 3 g, 7,w .fg)g,% ggge g c, 3 y l oN s'g ' 0 (
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, . 'l Government Accountability Project 1555 Connecticus Avenue. N.W.. Suite 202
, Washington. D.C. 20036 (202) 232-&$$0 muie Garde Duaw. Enwonmenut %deblower Choic December 3, 1985 FREEDOM OF INFORMATION ACT REQUEST FREEDou orgnpogy,,, '
r_*, Director ACT REQUEsy Office of Administration Nuclear Reg'ulatory Commission
, pg .pg ryg Washington, D.C. 20555 d24C d M-6-$
To Whom It May Concern: Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. {552, the Government Accountability Project (" GAP") requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diariea, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, any other data compilations, interim and/or final reports, status reports, and any and all other records developed by the harrassment and intimidation panel report issued November 4, I985. This request includes all agency records as defined in 10 C.F.R. 99.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980) whether they currently exist in the NRC official, " working", investigative or other files, or at any other location, including private residences. If any records as defined in 10 C.F.R. {9.3a(b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s). S I e ,
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' GAP requests that fees be waived, because " finding the !
information can be considered as primarily benefitting the ' general public," 5 U.S.C. 552(a)(4)(a). GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens Clinic is currently assisting several citizens groups, local governments and intervenors in Tennessee concerning the construction of the Watts Bar nuclear power plant. We are requesting the above iniormation as part of an ongoing monitoring project on the adequacy of Region II and the NRC's efforts to protect public safety and health at nuclear power plants. For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withhold. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir. 1973), cert. denie'd, 415 U.S. 977 (1974). days. We look forward to your response to this request within ten Sincerely, W.XL) Billie Pirner Garde Director Environmental Whistleblower Clinic t
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