ML19309F777

Response to Houston Lighting Power Second Set of Interrogatories & Request for Production of Documents. Alleges Void Testing Program Violates 10CFR50,Part B. Certificate of Svc & Supporting Documentation Encl

ML19309F777
Person / Time
Site:	South Texas
Issue date:	04/04/1980
From:	Sinkin L Citizens Concerned About Nuclear Power, INC.
To:	HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8005010097
Download: ML19309F777 (141)

Text

{{#Wiki_filter:_ _ _ _ _ so4Mo 09 7 g ~ e p occx m o .c, Us:co UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I APR 41980 : n D,.*[gN[ & BEFORE THE ATOMIC SAFETY AND LICENSING P.0ARD q tmc. In the Matter of g g 4 HOUSTON LIGHTING AND POWER Docket Nos. 50-498 COMPANY, ET. AL. 50-499 (South Texas Project Units 1 and 2) 6 ANSWERS OF CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. TO SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION of t.0CUMENTS FROM HOUSTON LIGHTING & POWER. ET AL., APPLICANTS I. Interrogatories

1. Identify and produce each document contained in the " bundle of documents" which purportedly caused CCANP's answerr to the first set of interrogatories to be late-filed.

In the preface to CCANP's answers to the first set of inter-rog6 tories, CCANP stated as fact that the docucents referred to were received on December 16, 1979. In response to Applicants use of the word " purported" in this interrogatory, CCANP repeats for the record that this date is indeed the true and correct date on which these documents were received and that the receipt of these documents did in fact delay the CCANP response by five days. 1he majority of these documents were reproduced as exhibits in the CCANP answe rs to the first set of interrogatories. Those documents not submitted in answer to the first set of interrogato-rie; were either similar to those submitted or did not seem pertinent to the contentinns as best CCANP understood these documents. The remaining documents consist of:

1. additional pages of punch lists, such as those in Exhibit P of CCANP's answers to Applicants first interrogatories;

2. Brown and Root "SPECIAL INSTRUCTIONS FOR RESPONDING TO AUDITORS";

3. seven cadweld reports on various dates.

All documents in the bundle are available for inspection and copying by prior appointment at 116 V1111ta, San Antonio, Texas. [This answer applf es also to Interrogatory 26 and II. Production of Documents. Item 1. below.)

2. (a) Identify and produce every document received or provided by CCANP during its "Cooperat[ ton] in an investigation conducted by the Federal Bureau of Investigation".

In the FBI investigation of Brown and Root, et al., activities at the South Texas Nuclear Project, CCANP acted solely as a conduit for documents. None of the documents were retained or copied by CCANP. Subsequently, one of these documents, the depo-sition of Mr. Dan Swayze taken pursuant to the law suit Mr. Swayze filed against Brown and Root, did come into CCANP's possession. Various pages from this depo: tion are copied as exhibits in these answers. Those pages not copied are pages in which Mr. Swayze was questioned about his prior work experience, i discussions between the attorneys regarding the availability of certain employment documents, and discussions relating to charges made against Mr. Swayze by another employee of Brown and Root. The entire deposition is available for inspection by Applicants, though CCANP assumes the Applicants can secure their own copy from Brown and Root.

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2. (b) Identify each person contacted by CCANP during its parti-cipation in the above referenced investigation.

1 The participation of CCANP in the FBI investigation was done on a confidential basis. All contacts made by CCANP were made on this basis. CCANP, therefore, respectfully declines to provide the names of persons contacted.

3. (a) Identify and produce every document received or generated by CCANP during "its own investigatter to determine why the United States Attorney decided not to present his findings to a federal grand jury...."

CCAMP received no documents during its investigation of the United States Attorney's decision. The only document generated by CCANP as a result of this investigation was the Preface to the answers to Applicants' first interrogatories.

3. (b) Identify each person contacted by CCANP during the above referenced investigation.

The contacts made by CCANP during its investigation of the decision not to prosecute were made on a confidential basis. CCANP, therefore, respectfully declines to identify such persons. Howevir CCANP is now in receipt of the response of the Washington of fice of the FBI to CCANP's Freedom of Information Act request regarding the investigation by the FBI. The main conclusion of CCANP's investigation was that the regional office of the NRC had told the FBI that falsification of cadweld records would not be considered a criminal act by the NRC and that the FBI decided prosecution would be useless in the f ace of this position by the NRC. This conclusion by CCANP seems to be confirmed by the FBI response to CCANP's FOI A request. In the FBI report there is a copy of the interview between two special agents of the FBI and Mr. Karl V. Seyfrit. Director, Region IV, Nuclear Regulatory Commission. This document is attached as Exhibit 1. In this interview, Mr. Seyfrit is recorded as stating the following: "The documentation of cadweld locations at the South Texas Nuclear Project (STP) was not required by NRC prior to the submission of the original design by Brown % Root, Inc. (B8R). However, B8R committed to document the cadweld locations so the NRC is requiring that they stand by their committment. If they wanted to. R&R officials could have this documentation requirement re-moved by a simple procedure. E&R has not chosen to have this requirement removed. The NRC would not delay licen-sing if they learned B A R7aIf a l s i f y Gq~ the documEtation." (emphas W adW 3) - cadweld This statement by Mr. Seyfrit conforms to the information developed during the investigation conducted by CCANP. CCANP finds the position expressed by Mr. Seyfrit to be unusual, to say the least. 4 (a) State the f acts, the source of these f acts, and produce all documents which lead CCANP to believe that "the FBI, among other things, found extensive evidence of f alse documentation of cadweld inspections." CCANP considers all aspects of CCANP's cooperation with the FBI are part of the confidential nature of the CCANP/ FBI interac-tion. CCANP, therefore, respectfully declines to answer questions related to that investigation other than to provide, in various exhibits, information contained in the FBI response to CCANP's FOIA request. Page 2

l .1 r 4 (b) Have representatives of CCANP spoken with any personnel of the FBI concerning finding by the FBI regarding the falsifica-tion of " documentation of cadweld inspections"? See 4 (a).

4. (c) Identify each such person and describe the substance of each conversation.

See 4 (a).

5. (a) State the facts, the source of these facts, and produce all documents which CCAMP relies upon in asserting that " extensive, pervasive, and willful violations of 10 CFR, Part 50

[have been confirmed by) past NRC investigations of this plant...." In CCANP's answers to Applicants first set of interrogatories, a few of the NRC identified violations were noted. [See Interro-gatory 16, (3); Interrogatory 16, (7); and Interrogatory 19.] The NRC investigative reports on the South Texas Nuclear Project fill numerous volumes in the public document room. CCANP is attempting a comprehensive analysis of these reports to identify and correlate violations of 10 CFR, Part 50 found by the NRC inspectors. As soon as this analysis is complete, CCANP will forward a copy to the Applicants and the other parties.

5. (b) Identify each specific instance of which CCANP is aware in which NRC investigations have " confirmed" " extensive, pervasive and willfull violations of 10 CFR, Part 50...."

See 5. (a).

5. (c) Has CCANP spoken with any official of the NRC or any other person concerning any activity of HL8' and/or its contrac-tors for the STP project which CCAMP regards as part of "exten-sive, pervasive and willful violattens of 10 CFR, Part 50."

Identify each such person and describe the substance of each conversation. CCANP has spoken with Mr. Daniel Swayze on numerous occasions at great length. Recounting of these conversations would be unduly burdensome., The essence of Mr. Swayze's information regard-ing extensive, pervasive, and willful violations of 10 CFR, Part 50 is incorporated in the contentions of CCANP. To summarize Mr. Swayze's information, Mr. Swayze has stated he has seen " slab's for beer joints built better than the nuclear plant." Further, Mr. Swayze summarizes the construction attitude at the South Texas Nuclear Project as "close enough for 9Jvernment work." 6. (a) Describe the facts or occurences which CCANP alleges contribute to "a climate of fear at the construction site." To truly understand the working conditions at the South Texas Nuclear Project requires an understanding of the history of this particular project. First of all, of the four partners, Houston Lighting and Power Company is the managing partner with both on site construc-tion and inspection personnel. While the other partners are represented on the management committee. HL8P is the most directly involved in the actual building of the plant. The contract to build this particular plant was not awarded by competitive bids. HL8P gave the contract to Brown and Root on a negotiated basis. Page 3

/ r A Crown and Root has never been the architect-engineer on a nuclear construction project. As a result, the procedures, speci-fications, and design of the project were new to Brown and Root and developed as the project developed. This inexperience led to constantly changing procedures, specifications, and designs changes that created a climate of uncertainty in construction and produced some of the disagreements between the construction and inspection personnel. Additionally, the site for the nuclear plant Bay City. Texas - is a small town more than one hundred miles from the nearest large town. Personnel with the necessary skills to do the work at the plant were not readily available from a large pool of workers, so often inexperienced personnel were hired to do the job. The work force lack of experience led to poor con-struction practices. Construction personnel placed too great a dependency on inspection personnel for finding flaws rather than finding them before the inspection. At the same time. Brown and Root was fortunate enough to find some highly experienced and conscientious inspectors, such as Dan Swayze. Mr. Swayze was not the type of person to tolerate shoddy construction practice and made a habit of rejecting work which he felt was not in conformance with specifications, designs, or procedures. Even with quallfled inspectors, however, there seems to have been a continual problem with not enough inspectors to do the job. An example of this was given in CCANP's answers to Applicants first interrogatories, Answer 1G (8), which noted that there were no inspections of cadwelds at night. (See also Interrogatory 33 below.) The project itself is a massive construction job. Delays are very costly, ranging into the hundreds of thousands of dollars for each day's delay in a critical part of the construction. This mix of an inexperienced architect-engineer, inexperien-ced construction personnel, rigorous inspections, insufficient personnel to carry out the necessary tasks, and time / cost pressures j laid the predicate for a possible break down in the quality control / quality assurance program. It is just such a break down which constitutes the heart of CCANP's contentions regarding construction of the South Texas Nuclear Project. The parts of Mr. Swayre's deposition attached hereto as Exhibits 2 and 3 provide a glimpse of the kind of tension which built up between construction and inspection. As the project fell further behind more than four year behind now - and the cost sky rocketed more than tripled since 1973 the tension at the site increased. Finally, the ootnt was reached in 1977 where the physical assault on James Marshall led to inspectors deciding not to inspect, but rather to play cards for three or four months. (See Interrogatory 42 re: the card game.) In CCANP's answers to Applicants first interrogatories. Exhibit 0 is a Brown and Root Interof fice Memo dated July 27, 1977, to all QA/QC personnel from T. P. Gardner on the subject of " Construction / Quality Assurance Interf acing." Since this memo originates from the contractor and addresses clearly the problem of tension between construction and inspection, the memo is once again presented as an exhibit, in this case Exhibit 4 attached hereto. In his memo, Mr. Gardner speaks of the assault on a Civil inspector (James Marshall) and goes on to state: "It was discovered during both investigations that there existed an inordinate amount of friction between the Construction Concrete craft and Civil QC." A more comprehensive view of the problems at STNP is given by the Trip Report prepared by M. J. Meyer of Brown and Root. M. J. Meyer and B. J. Taivacchia of Brown and Root conducted Page 4

t interviews during the week of July 15, 1977 to determine the cause of a particular deficiency in construction. The resulting report is attached hereto as Exhibit 5. Among the fir. dings in this report are: T. K. Logan, Lead Civil Engineer, (HL8P): "2. 88R Construction personnel have a poor understanding of the word ' quality' and how it relates to inspec-tion prior to placement." M. M. Johnson, Senior Civil Engineer (HL&P) "1. 88R Construction is too schedule oriented." A. J. Hammons Civil QC Supervisor (B8R) "1. B8R Construction relies too much on the QC Inspector and does not try to catch problems before the QC 1 inspector does." ] D. L. Swayze Civil QC Inspector (B8R) "B8R Construction inspectors are too production oriented." One final item on the break down of QA/QC is the attitude taken toward deficiencies which are found. In the minutes of a telephone conversation between Pete Jordan of Brown and Root and R.L. Jacobi of HL8P, there is a discussion of voids in the reactor containment building, Unit

1. The text of these minutes is attached hereto as Exhibit 6.

These minutes contain the following passage: "There was also speculation that the contianment [ sic] polar crane could f ail in service. Second, B8R attributed the incident to a deficiency in construction and a breakdown in QA. Pete qualified the report by explaining that it was B8R's opinion that the failure of the polar crane would have occurred during the lif t of the RPV during construc-tion and therefore, the deficiency could not have remained uncorrected. He also pointed out that the deficiency would have been detected during preoperational contain-ment structural testing. I explained to Pete that the words in 50.55(e)(1): '...were it to have remained uncorrected...', were not meant to be applicable to this line of reasoning. B8R has used this approach on prior incidents and it was rejected at that time by the HL8P Incident Review Committee." A construction attitude that deficiencies will be "self correc-ting" in that a failure will occur calling attention to the deficiency is indeed not the concept of quality assurance.

6. Ib) Identify the source of the information in (a) above.

CCANP has conducted two years of research into the building of the South Texas Nuclear Project. From the beginning of this research, the problem of tension between construction and inspec-tion has been a major topic. Sources of information on this topic include Mr. Swayze, internal documents of Brown and Root, internal documents of Houston Lighting and Power, NRC investiga. tive reports, and conversations with persons who required a commitment of confidentiality before they would talk with us or who called anonymously to provide information. The Austin American Statesman reported on January 31, 1980, that Brown and Root had hired Time Lapse, Inc. of California to research attitudes of project employees, particularly inspectors and construction personnel whose work is subject to their approval. The article states that the study involved interviews with thirty Page 5

t five (35) employees and a questionnaire in which no names were required. The same article states that the NRC conducted a separate investigation in December which also examined the problem of tension between inspection and construction. CCANP trusts that the Applicants will make the Time Lapse, Inc. study ava1Dble to the Atomic Safety and Licensing Board and to the Intervenors and that the NRC office in Arlington, Texas will also make its report available to the Board and Inter- ) venors.

6. (c) Identify each person contacted by CCAMP who refused to provide information for fear of losing his or her job.

Believing those who have said that persons working at STNP who provide adverse information about the project risk losing their jobs, CCANP respectfully decifnes to jeaprodize the jobs of these persons by providing their names. Additionally, since CCANP did make a commitment not to reveal the names at the time the information was provided, CCANP considers itself bound by that commitment.

7. Identify each communication between Applicants and the NRC which CCANP relies upon to support its asserticn that the Mecha-nical Electrical Auxiliary Building is being constructed one foot short.

Notification SFN: V-0100 dated October 29, 1979 and further identified by the notation ST-HL-AE-384 This notification was sent by E. A. Turner. Vice President, Power Plant Construction & Technical Services. Houston Lighting and Power Company to the director of Region IV, Office of Inspection and Enforcement. Arlington, Texas. The notification states: "Due to a survey calculation error, the basemat of the Unit 2 Mechanical-Electrical Auxiliary Building was constructed one foot short on the east side of the building.

8. (a) Identify the "other parts of the plant," besides the containment shell walls, which CCANP asserts contains [ sic]

concrete volds. Applicants have misunderstood CCANP's statement in answer to Interrogatory 3 in Applicants first set of interrogatories. CCANP pointed out that the substantive information relating to volds available to CCANP covered only Lift 8 and Lift 15 of Reactor Containment Building Unit 1. CCANP had heard reports at that time, however, that there were volds in other parts of the reactor containment building shell walls. There may indeed, however, be voids in areas other than the reactor containment shell walls. The log of deficiency reports (DDRs) for the South Texas Nuclear Project records voids in the following areas: Fuel Handling Building, Unit 1 Mechanical Auxiliary Electrical Building, Unit 1 Emergency Access Shaft RCB 1 Base Mat, Reactor Containment Building, Unit 2 Secondary Shield Wall, Reactor Containment Building, Unit 1 Additionally, since more than 850 suspected volds occurred in Reactor Containment Building. Unit 1 and Reactor Containment Butiding, Unit 2, and since the voids occurred over a lengthy period of time. CCANP believes there is every reason to assume that concrete work in other parts of the plant during the same periods of time suffered from similar deficiencies. Page 6 l l l

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8. (b) identify the individual or individuals who have " told" CCANP that "Volds have been found in other parts of the plant."

Quite frankly, CCANP representatives cannot remember where these reports originated. The question is in part rendered moot by the report issued by HL&P regarding the location of voids in other areas of the containment structures for the two reactor units.

8. (c) Identify the documents of which you are aware which support this allegation.

As far as volds other than in Lift 8 and Lift 15 of the shell wall in Reactor Containment Building Unit 1. CCANP rettes i upon NCR #S-C 3461, attached hereto as Exhibit 7, and the blue prints of the confirmed and suspected volds developed by Brown and Root and referred to as the " attached 27 drawings" in NCR #S-C 3461. What follows is a partial summary of CCANP's examination of these blue prints: Reactor Containment Building #1 Reactor Containment Building #2 Confirmed Suspected Confirmed Suspected Volds 56 680 20 177 CCANP also relies upon Notification SFN: V-0530, dated February 8, 1980 and further identified by the notation ST-HL-Ae-419. This notification was sent by C. W.

Oprea, Jr.,

Executive Vice President, Houston Lighting and Power Company to Mr. Karl Seyfrit, Director, Region IV, NRC, Arlington, Texas. While the cover letter identifies the report as " Final Report on the Reportable Deficiency Concerning Concrete Volds in the Eighth Lift Of the Unit 1 Reactor Containment Building", the report in fact covers the corrective actions taken on all volds except for those in Lif t 15 of RCB 1. As to the voids in other than the reactor containment shell walls, CCANP, as noted above, finds various DDR's in the DDR log which speak of voids, to-wit: 5/31/77 S.0202 "FHB UNIT #1 Wall W-15 Void & honeycomb, patching repairs w/o engr." 7/7/77 S-0249 "FHB Unit #1 void areas under embedded crane rail channel supp" 7/20/17 S-0255 "FHB Wall pour fFH1-W19, 19A, 21, and 21A volds 3/4 length pour height" 8/10/77 S-0273 "FHB Unit-1 Wall FH1-W14, void & honeyconed [ sic] areas repaired w/o proc" 9/2/77 S-0283 " Concrete pour FH1-W8C Forms shifted 1 1/2" - Results volds" 9/22/77 S-0292 " Concrete pour FHB-52 discrep. - foreign material, consolidation, and damage" 11/1/77 S-0305 " Pour fMEl-W001-02 large area honeycomb A void underneath block out" 11/14/77 S-0310 " Pour Ct2-M9 volds and rock pockets along waterstop in emergency access shaft" 11/28/77 S-0314 " Pour #Cl2-M7 has rock pockets due to improper consolidation" [ examination of actual DDR re-port showed this was rock pockets and a void between the connecting base mats in Unit 2 Containment adjacent to east FHB 2 wall] 11/29/77 S-0315A "FHB-1 Misc large and small voids" 12/12/17 S-0321 "FH1 W45 honeycomb areas due to loss of mortar" 2/6/78 S-0335 " Pour CII-W18 and WIC, void underneath block out and void through thickness of north wall" [loca-ted in secondary shield wall] Page 7

I a 9 (a) CCANP alleges there is no " uniform, continuous process for testing for volds." State the specific parts of the void testing program which are deficient when evaluated against CCANP's criteria for " uniform, continuous process for testing for volds." The South Texas Project Specification Concrete Construction 2A010CS028 has been revised seven times. Revision D approved for construction in March of 1976 states in section 3.21: "The rate at which concrete is placed shall be consistent with form design, manpower, consolidation equipment, and in no case shall concrete be placed on a previously ETaced layer that has not been p r o p e rl y ~c o n s o l i d a t e d. " (emphasis added) Section 3.3 states: "particular attention shall be give'n to the consolidation of all concrete in Category I structures such that the concrete in place shall be practically free ~~ both of internal and external voids." (emphasis added) The same statements appear in Revision G, the most recent revision dated April, 1979. HL&P's final report on the volds to the director of Region IV shows that volds were found and repaired in: RCB 1 Lifts 1, 2, 4, 5, 6, 7, 8, 9, 10, and 11. RCB 2 Lifts 4 and 6. (Note: This report does not include the Lift 15 investigation.) All of these voids, except some of those in Lift 8, were identi-fied after RCB 1 had reached the 15th lif t and RCB 2 had reached the 6th lift. Volds exist because the lift was not properly consolidated. The pouring of further lif ts e.ter the pouring of a lift containing voids is a violation of Section 3.21 quoted above. The existence of the volds is a violation of Section 3.3 quoted above. Among the confirmed volds appearing on the blue prints examined by CCANP were: 1 void 47 feet long ranging in depth from 3 inches to 17 inches 3 voids 48 inches deep (wall depth 48 inches) S volds 46 inches deep 1 void 42 inches deep intersecting void on other side of wall The existence of these voids is prima f acie evidence that construction did not pay "particular attention" to the possible presence of voids as called for in Section 3.3. A 47 foot long void was not noticed when it happened and at least three holes all the way through the wall were not noticed. In fact, the extensive presence of voids - between 70 and 81 voids were filled - in so many different areas demonstrates that there was r.o real process for testing, uniform and continuous or otherwise. In answer to Interrogatory 8(c). CCANP noted twelve void reports in the period from May, 1977 to February, 1978. Thase void reports were only for areas other than the reactor containment walls. There were still other DDR's written on voids during this period, to-wit: 8/31/77 S-0281 " Concrete pour fCA2-W1 has honeycomb area" [ considered a void because S-0285 states "Ref. Page 8

4 DDR #S-0281 - Patching of voids w/o approval of design engr."] 9/13/77 S-0287 " Concrete pour CI2-M2, Forms moved out of t-arances - voids" 10/3/77 S-0296 " Containment wall CII-W15 has volds in concrete" 10/6/77 S-0297 " Concrete pours CI2-M2 through CI2-MS - poor consolidation a foreign material" None of the DDR's listed in 8(c) or in this answer were reported to the NRC pursuant to 10 CFR 50.55(e). The prior existence and detection of volds might have been expected to result in a comprehensive program of detection for future work. Indeed, when the volds were found in the secondary shield wall as recorded in DDR S-0335 dated February 6,

1978, this problem of repeated volds was addressed in the Observations Section which stated:

"When forms were removed from secondary shield wall after concrete pours #CII-W18 and W18C, a large void area was noted underneath the block out in the west wall and another completely through the thickness of the north wall. The deficient areas as noted are the direct result of 7 proper placement aTd conso1TJation techniques used and in violation of the above speci-fication and your recurrence control on a DDR." - - previous These 7 re sizeable voids. The void in the west wall was 7 1/2" deep and 20" wide; the void in the north wall was 30" wide x 24" high x 30" deep. The response to this problem found in the Recurrence Control section of this DDR is: "We underestimated the complexity of this placement. In the future, we will look at these placements with much more control in mind. We will continue to look at our preplacement planning more effectively. Also, we will ask for engineering resolution when we find it necessary." Yet shortly thereaf ter, volds were found in Lif t 8 of Reactor Containment Building, Unit 1. What follows is a closer examination of events related to volds in Lift 8 of Reactor Containment Building, Unit 1. The first identification of voids in Lif t 8 appears to have been on February 10, 1978. In Field Request For Engineering Action 1-C-0873 attached hereto as Exhibit 8, the section on Recommended Disposition speaks of the personnel air lock to be grouted as per FREA 0-C-0694 dated 2-10-78. On March 25, 1978, a pour was carried out on RCB 1, Exterior Shell Wall, Lift h. On the back of the Concrete Pour Card, inspector Suresh Shah wrote: " Voids observed at construction joints on each side of personnel air lock. Size and extent of voids are to be determined." (See Exhibit 9) On April 5, 1978 FREA 1-C-0873 was written apparently to address the volds found by Mr. Shah. For some reason, this FREA has an attached drawing (See Exhibit 8) which shows voids only on one side of the personnel airlock, though Mr. Shah said there were voids "on each side of the personnel air lock." Subsequently, voids were found in Lift 15 and reported to the NRC in October of 1978. Brown and Root also undertcok soundings of other voids lifts to check for volds. The NCR Log, item 2706A notes " RCBF 1 Lift #8 Liner - Voids in Conc." The log initially had this NCR as not reportable, and the initial date of issuance as June 13, 1979. Subsequently, the same NCR entry was changed to record the deficiency as reportable and the initial date of issue was changed to April 18, 1979. Page 9

.1 A May 1, 1979 Interoffice Memorandum of Brown and Root, attached hereto as Exhibit 10, stated: i "As a result of soundings taken on the Ifner in the i vicinity of lif t 8 of Unit 1 RCB, the client has requested that an Engineering evaluation of the potential voids be performed, The raw data submitted is inconclusive as evidenced by the results of the investigation of the 15th lift." On June 18, 1979 HL8P notified Region IV, NRC of voids behind the Ifner plate in Lift 8. On August 15, 1979, the Second Interim Report on the volds found in Lif t 8 was sent to Region IV. NRC. The schematic showing the location of the volds includes three voids at or near the personnel airlock. Voids 2 and 3 appear to be in the same place as the voids drawn as 1 and 2 in FREA 1-C-0873 dated April 5, 1978. Void 1 is under the airlock itself, an airlock supposedly grouted as per FREA 0-C-0694 dated February 10, 1978. Either the voids detected in Lift 8 during early 1978 were never fixed or the inspection and repair system failed to locate similar voids in the immediate area. Whichever the case, the void detection and repair system is called into question by the experience on Lift 8. There is one other deficiency that CCANP believes existed and still exists in the void testing program. Section 5.5.2. of the Concrete Specification noted above. Revision G, states: "The ' sounding' cf imbedded plates, liners, and so forth, shall not be applicable as a primary basis for detecting and defining volds. ' Soundings' may be utilized, however, to assist in defining potential voids if one of the following conditions is satisfied:

a. voids are visible in the concrete behind or beneath an imbedment, or b.

voids are suspect because of adverse conditions during the placement that may have resulted from inadequate consolidation, equipment problems, low slumps, and so forth." What this section seems to say is that tapping on the liner plate cannot be used as a primary method for detecting and defining voids, but can be used as a back up method if volds are either visually detected or the conditions of the pour were such that voids are suspected. The problem which CCANP raises at this point is: What, if anything, is done to detect voids which exist in the interior of a wall? If such volds do not open to the outside or inside of the wall, they will not be visually detected. If conditions of the pour were such that voids are suspected, tapping on the liner would not reveal an interior void. In the walls already examined in RCB 1 and RCB 2, there is no evidence to support a conclusion that there are no voids surrounded by concrete. Theoretically there could be a void 46 inches deep with one inch of concrete on the inside face and one inch of concrete on the outside f ace, and such a void would escape detection. To CCCANP's knowledge, the void detection process used by Applicants makes no provision for testing for internal voids. This process is, therefore, highly suspect, particularly in light of the number of voids which were detected. The conclusion of Applicants in their February 18, 1980 report to the NRC was: "it was determined that if lef t uncorrected, th6se voids could have compromised the structural integrity of the Containment shell in that the as-built configuration would not have met its design load and shielding criteria." There is the possibility that there still exist internal voids with a similar safety related impact. Page 10

l J 4 s 9. (b) Do you allege that the void testing program violates 10 CFR 50, Part B7 If so, identify the provisions thereof which are violated and the basis for such allegation. CCANP certainly does allege that the void testing program violates 10 CFR 50, Part B. The history of the void detection program at this construction site, a part of which was outlined above Indicates that voids are not routinely identified even when they are 47 feet long. It was not until the massive foul up in Lift 15 (See Exhirt 11 attached hereto) that an evaluation of the presence of vcids was undertaken. Had the Lift 15 problems not been so obvious and substantial, there may never have been a search, such as the one which turned up voids "that if left uncorrected... could have compromised the structural integrity of the Containment shell in that the as-built configuration would not have met its design load and shielding criteria." The violations alleged are as follows:

1. Criteria I was violated in that Applicants did not establish and execute a quality assurance program assuring that activities af fecting the safety-related functions have been cor-rectly performed.

2. Criteria 11 was violated in that Applicants did not have a quality assurance program providing control over activities af f fecting the quality of the identified structures to an extent consistent with their importance to safety. Further, the absence of a testing procedure for internal voids does not take into account the need for special controls, processes, and test equipment to attain the required quality.

3. Criteria III was violated in that deviations from appropriate quality standards were not controllad.

4. Criteria V was violated in that the instructions and procedures were insufficient to prevent voids.

5. Criteria X was violated in that the program for inspection of JCtiVities affecting quality was not established of executed in a manner sufficient to prevent voids.

6. Criteria XI was violated in that the program for testing for volds did not detect that the containment walls would not perform satisfactorily. This criteria is further violated by the absence of any testing criteria or procedure for the identi-fication of internal voids.

7. Criteria XVI was violated in that measures were not established to assure that conditions adverse to quality were promptly identified and corrected. Identification of voids more than a year af ter they have occurred and correction more than a year and a half after occurrence can hardly be considered prompt.

Furthermore, the absence of any prograa to detect internal voids which could be adverse to the quality of the walls is also a violation of this criteria. CCANP notes in passing that in the answer to #5 in the Ap-plicants' first set of interrogatories, CCANP stated "[T]he large number of voids discovered to date suggests strongly that a uniform, continuous process of testing for hidden voids would have uncovered other voids and that more extensive testing for voids was required than was actually conducted." This statement was made prior to CCANP having access to information on voids in places other than Lift 8 or Lift 15.

10. (a) Describe the fact or occurence and produce every document CCANP relies upon to support the assertion that there has been

" improper pouring of concrete" in the walls enclosing the contain-ment butiding. See answers 8 and 9 above. Page 11

i 1 I (

10. (b) Identify each person with whom CCANP has spoken in regard I

to this matter. As CCANP has held press conferences on this matter and been approached by numerous persons desirous of examining documents, such as the blue prints, the naming requested is impractical.

11. Identify the exact " design specifications" which were violated by the " presence of voids."

Specification Concrete Construction 2A010CS028, Sections 3.21 and 3.3 as quoted in answer 9 above.

12. (a) Explain precisely why it is necessary to " relocate" cadwelds.

The current inspection of cadwelds at the South Texas Nuclear Project generates inspection records, location maps, and other permanent records. The purpose of these records is nnt only to check the quality of current work but also to provide traceability. If for any reason the quality or documentation of a cadweld is called into question, the only method of being certain that a cadweld was properly shot or actually placed where it was supposed to be placed is to go back and look at the cadweld. This trace-ability is precisely what CCANP means by the term " relocate. The quality of cadweld records is apparently of some impor-tance tn Applicants as shown in the Speed Letter attached hereto as Exhibit 12. Dated September 11, 1978, this memo calls attention to cadweld records " filled out improperly, some are incomplete' and others do not agree." The conclusion of the author is that "It is apparent from the amount of problems identified that a thorough review of cadweld records is in order." Non-Conformance Report #S-C 3518, which is attached hereto as Exhibit 13, documents 93 cadwelds for which no documentation exists. (The list of the 93 cadwelds attached to the NCR is omitted from the exhibit.) The Description of Deficiency contains the following state-ment: "This lack of adequate documentation renders the quality of these cadwelds unacceptable and/or indeterminate...." The absence of such documentation apparently would lead to a hold tag being applied to the cadweld until inspection could be completed because the Description of Deficiency also contains the statement: "No hold tags applied because cadwelds covered by con-crete."

12. (b) Explain precisely what verifications of quality are performed after a cadweld is " relocated."

Presumably, the cadweld could be examined visually, tested for strength, and its location checked to assure its placement in accordance with design.

12. (c) Identify the " verifications" explained above by citation to the appropriate South Texas Project Quality Assurance procedure and/or NRC regulation.

NCR S-C3518 (Exhibit 13) notes that the absence of documenta-tion for cadwelds violates 2A010CS028-Revision G 12.5.4 an? 10 CFR 50 Aprendix B, Criterion XVII. More comprehensive is non-conformance report #S-C3584, whi-is attached hereto as Exhibit 14. (The lengthy exhibits attached the NCR are not reproduced as they are merely a log of all t various cadwelds in question.) This NCR documents 2,056 cadwel having deficiencies, some with more than one type. Page 12 l

a l In an attachment to this NCR, the various South Texas Project Quality Assurance procedures and NRC regulations violated are delineated as: 2A010CS028 - Revision G - 15.3.2.8 15.3.2 12.5.4 95.3.2.2 10 CFR 50 Criterion XVII. In the referenced attachment, the wording of each procedure and regulation is given.

13. (a) Identify those persons with whom CCANP has discussed the assertion that taper ties were used to construct the containment exterior shell.

The inclusion of the containment exterior shell in CCANP's answer to Applicants' first set of interrogatories, #10, was an error. Taper ties were used in the secondary shield wall of the containment building, not in the exterior shell wall.

13. (b) See 13 (a).

13. (c) See 13 (a)

14. (a) State the facts, the source of these facts, and produce all documents which CCANP relies upon to support the assertion that the use of taper ties is "a violation of standard construction i

I practices." First of all, the statement quoted in this interrogatory is part of an entire sentence which states: "The use of taper ties in this type of construction [below grade] is believed by CCANP to be a violation of standard construction practices." Specification Concrete Construction 2A010CS028, Revision D, Section 4.2 states in part: " Ties shall be of the br eak back type, which when removed, will permit a minimum of 1 and 1/2 inches between the end of the rod,and the concrete surface. The same paragraph appears in Revisions E and F. In Revision G, however, the paragraph now reads: " Ties shall be of the type, which when removed, will permit a minimum of I and 1/2 inches between the end of the rod and the concrete surface." The words " break back" have now been removed. s 14 (b) Identify those persons with whom CCANP has discussed this i assertion. l Mr. Daniel E. Swayze. I 14 (c) Describe the substance of each conversation. CCANP's answer to Applicants' first set of interrogatories,

1. 10 sets forth the essence of what Mr.

Swayze had to say.

15. Identify the design engineer who " ordered all the holes to be filled."

At this time, CCANP does not know the identity of this engineer. Continued efforts will be made to identify this person and the name will be provided to Applicants as soon as available. Page 13

a

16. (a) !%ntify those persons with whom CCANP discussed the assert 10n that taper tie holes "have not been filled" or "were partially filled."

CCANP has discussed the tie hole problem with Mr. Daniel E. Swayze. The essence of Mr. Swayze's memory of the tie holes is found in CCANP answer #10 to the first set of interrogatories from Applicants and in Exhibit F to the same answers. In the same Exhibit, Mr. Karl Seyfrit, Director. Region IV. NRC states on October 6, 1979 that plugging of the *f e holes "is not a high-priority item, so it wouldn't surprise me to see it drag on for awhile." Since, according to Mr. Seyfrit in the same exhibit, the problem was reported to the NRC in December 1977, the " drag on for a while" statement would seem.to support the assertion that the holes "have not been filled." In further response to Interrogatory 10 in Applicants' first set of interrogatories, CCANP attaches hereto, as Exhibit 1$. DDR S-0325. This DDR deals with tie holes only partially filled. The attachment to this DDR shows that tie holes in Fuel l Handling Building. Unit 1; Containment Building. Unit 1; and Mechanical & Electrical Auxiliary Building, Unit I were not completely filled in violation of Construction Procedure A040KPCCP-

5. In fact, the hole tested in the Secondary Shield Wall of the Containment Building, Unit 1 showed only 1 and 1/2 inches of grout on the interior and 4 inches on the exterior of a wall noted as 48 inches thick. This finding seems to confirm the allegation j

that the holes were filled only partially. In CCANP's answer to Interrogatory 10, first set, CCANP i recounted that Mr. Swayze spoke of finding grout being used that crumbled under his fingernail. NCR #S-C 3126, attached hereto as Exhibit 16 also deals with the filling of taper tie holes. On the continuation page, the inspector notes: "a majority of the holes inspected had sand in them" in violation of 2A010CS028 Revision G - 7.2.3.1 and 7.2.3.2. Further evidence of tie holes filled only partially and with improper grout is found in NCR #S-C 2257, attached hereto as Exhibit 17 In this NCR, the inspector found tie holes only partially filled with grout improperly consolidated in violation of 2A010SC028 - Revision G - 7.2.3.1. Finally, in answer #11, first set, CCANP raised the problem of filling tie holes where the waterproof membrane and backfill are already in place. NCR #S-C 1258, attached hereto as Exhibit 18, is an example of just such a situation. The resolution of the problem in this NCR is to proceed with dry packing the hola according to Specification 2A010CS028-F-7.2.3.1 which statee in part: "Each layer shall be solidly compacted over its entire surface by use of a hard wood stick and a hamr.er. Much of the tamping shall be directed at a slight angle and towards the sides of the hole to insure maximum compac-tion in these areas." The problem raised earlier by CCANP was how this procedure could be carried out in a manner to assure complete filling since the backfill is in place, in a manner protecting the membrane from rupture, and in a manner providing for inspection of the membrane after packing. In this instance, the Proposed Disposition does not address any of these problems. Pecent actions by the Applicants could make this point moot. The Scuth Texas Project Specification Concrete Construction - Revision F - Section 7.2.3.1 contained the statement: "In gernal [ sic], dry pack may be used for repairs that have a relatively high depth / area ratio. Tie holes shall be filled solid with dry pack mortar after being cleaned and thoroughly dampened. When a repair is classified as structural, an epoxy binder shall be Page 14

? applied to the prepared surface and shall be tacky prior to dry packing." In Revision G of the same specification this passage now in 7.3.2.2 reads: "In general, dry pack may be used for repairs that have a relatively high depth / area ratio. When a repair is classified as structe.al, an epoxy binder shall be applied to the p re;,a red surface and shall be tacky prior to dry pacting." The statement that " Tie holes shall be filled solid with dry pack mortar af ter being cleaned and thoroughly dampened" is now removed. Thus, Applicants have removed the passage requiring break back ties and removed the requirement to fill tie holes completely. The problem of using taper ties and filling the holes left by removing these-ties is thus cured by removing the requirements which created the problem. On the other hand, these changes may have been made in recognition of an of fice memo of Brown and Root, Inc. to T. P. Gardner from M. B. Chan. The subject of this memo was "Clarifica-tion of Specification 2A0100CS028 Concrete Construction." The correspondence nunber is GM-12683 dated June 14, 1976. Referring to Section 7.2 repairs, the memo states: "The sentence in paragraph two of this section 'The method of repair proposed for the individual case shall be subject to the approval of the Design Engineer' is intended to mean that any repairs that cannot be effected by use of the ' dry pack' method as described by the Bureau of Reclamation shall be subject to the Design Engineer's approval. Dry pack as stated in the Bureau of Reclamation's Manual may be used for:

1. holes less than six inches square having a depth equal to or greater than the least surface dimension.

Minimum depth should be one inch;

2. cone bolt, she bolt, and grout insert holes;

3. narrow slots cut for the repair of cracks.

Dry pack should not be used for:

1. relatively sFallow depressions where lateral re-straint cannot be obtained;

2. filling behind considerable lengths of exposed reinforcement;

3. filling holes which extend entirely through the i

section under consideration." (emphasis added) The docement is stamped as received by Brown and Root on June 17, 1976. [The document itself is in the possession of CEU and the above text is provided via a telephone recording transcription. CCANP is requesting that CEU provide to Applicants and all parties a copy of this memo.] The Bureau of Reclamation seems to believe that dry pac: is not an acceptable method of filling tie holes. Perhaps three years after receiving this standard, Brown and Root, Inc. decided to accept the Bureau of Reclamation advice.

16. (b) Describe the substance of each conversation.

See 16 (a).

16. (c) Produce all documents upon which CCANP relies to support this assertion.

The only other document upon which CCANP relles to support the assertion that taper tie holes "have not been filled" or "were partially filled" is Nuclear Regulatory Commission investi-gative report 79-14 dated October 16, 1979. Allegation 4 investi-I gated during this unannounced visit was: i Page 15

i " Holes lef t in concrete wall of safety-related structures following removal of tapered form ties were not solidly filled with grout." The conclusion of the investigators was: "The allegation that holes left in concrete walls of safety-related structures after removal of tapered form ties were not solidly filled with grout was substantia-ted; however, this matter was previously identified and documented by the licensee. Corrective action was in progress." The FBI response to CCANP's FOIA request contains sworn statements relating to the tie hole problem, but as the identity of the person giving the statement is withheld and as the Applicants have their own copy of this response. CCANP does not rely on these statements at this time.

17. (a) Identify those persons with whom CCANP has discussed the assertion that the hole " grout is supposed to withstand significant pounds per square inch of pressure."

While CCANP did discuss this assertion with Mr. Swayze, South Texas Project Specification Concrete Conrtruction, Revision G. Section 8.2.5 states: "The compressive scrength of the grout, unless otherwise indicated on the design d awings, shall not be less than 6,000 p.s.t. at 28 days or earlier."

17. (b) Describe the substance of each conversation.

The discussion with Mr. Swayze mainly considered the question whether the grout used to fill the tie holes needed to be able to withstand significant pounds per square 1 ich of pressure. Mr. Swayze stated his opinion that it did and that this ability was required by the specifications.

17. (c) Produce all documents upon which CCANP relles to support this assertion.

The only document relied upon is the specification noted in 17(a) which Applicants already have.

18. Identify the exact location of the taper tie hole tested by Mr. Swayze by using " blunt steel rods."

Unfortunately Mr. Swayze cannot remember which of the hundreds of tie holes was so tested.

19. (a) Identify the exact location of the waterproof membranes which "were put on at night and never inspected."

CCANP is temporarily stymied in its investigation of the membranes.-Unfortunately, CCANP's contention I stated in part 4 that "There are membranc seals in the containment structure which are damaged...." Mr. Swayze's allegation pertains to the Fuel Handling Buildings and Mechanical Electrical Auxiliary Buildings. When CCANP requested documents related to the membranes placed on the Fuel Handling Butidings and the Mechanical Electrical Auxiliary Buildings. Appitcants refused such documents on the ground that the contention used the phrase containment structure. CCANP's argument that by "contains.ent structure" CCANP had meant the containment building and the two buildings attached to the containment building was to no avail. The answer to Interrogatory 19 will have to await either a change in attitude on the part of Applicants or submission of a revised contention by CCANP. Page 16

.i i l

19. (b) Identify the date the waterproof membranes identified in (a), above, were installed.

See 19(a).

19. (c) Identify the date Mr.

Swayze " attempted to have the backfill removed so that inspection could take place." Without the documents to refresh his memory, Mr. Swayze is unable to pinpoint these dates.

19. (d) Identify each inspection that was omitted for the locations of the waterproof membrane identified in (a), above.

Without the documents to refresh his memory, Mr. Swayze is unable to pinpoint these locations. l In the Nuclear Regulatory Commission Investigative Report 79-14 noted above, allegation 3 states: " Waterproofing membrane was installed at night on Reactor Containment Building (RCB), Unit No. I and Fuel Handling Building (FHB), Units No. I and 2 without proper QC inspection prior to backfill." In their findings, the inspectors state: "3. The allegation that waterproofing membrane was in-stalled at night on RCB, Unit No. I and FHB, Units 1 and 2 without proper QC inspection could not be substantiated. Five individuals interviewed by the investigation team stated that they had no knowledge of improper inspection of the membrane prior to back-filling. Review of QC records and the inspection procedure for waterproofing membrane was inconclusive and resulted in the identification of an unresolved item pertaining to the frequen y of inspections stated in the procedure."

20. Describe the damage which CCANP asserts has occurred to the membrane seals in the containment structure referenced in Conten-tion 1, paragraph 4.

CCANP concedes that Contention 1, paragraph 4 is poorly worded from the standpoint of what CCANP actually means to contend. The need for revising this contention is obvious and an effort will be made to do so in the very near future.

21. Explain precisely how the damage to the membrane seals violates the provisions of 10 CFR Part 50, Appendix B. Sections X, XV, and XVI.

See 20 above.

22. Explain precisely how the alleged absence of waterproof membrane inspections at night affects " safety-related functions."

CCANP uses a line of reasoning similar to the reasoning set forth in NCR #S-C 3518 noted above concerning cadwelds. The absence of adequate documentation on the placement of waterproof membranes renders the quality of those membranes not inspected unacceptable and/or indeterminate. The purpose of waterproof membranes is to prevent the entry of water into various buildings, such as the Fuel Handling Buildings, and Mechanical Electrical Auxiliary Butidings. Were water to enter these buildings, electrical equip-ment could be adversely affected and the safety of the plant impaired. Page 17

^ s

23. (a) Identify those persons with whom CCANP has discussed the assertion that "[ taper tie] holes are still not filled."

This interrogatory is identical to Interrc atory 16. u

23. (b) Describe the substance of each conversation.

This interrogatory is identical to Interrogatory 16.

23. (c) Produce all documents on which CCANP relies to support this assertion.

This interrogatory is identical to Interrogatory 16.

24. Identify exactly where besides "around the equipment doors" there are steel reinforcement bars " missing from the containment structure."

Pours CII-555; CII-58; CI2-W14; CII-W44A; CII-340; CI2 58; CI2-W17; CII-W44; CII-W24F; C!1-W29; CII-W450; C11-344; CII-W34; CII-355; CII-W99A; CSI-W37; C11-W205; CII-W76.

25. (a) Identify specifically each instance, and the inspectors involved, where missing steel reinforcing bars were not reported.

CCANP does not currently have the information necessary to provide an answer to this interrogatory.

25. (b) Identify the individuals who intimidated inspectors into "not reporting the omission."

The names of these persons are unknown at this time.

26. Produce those " documents which came to CCANP from persons unknown who apparently previously worked or currently work at the construction site of the South Texas Nuclear Project."

See answer to Interrogatory 1 above.

27. (a) Identify specifically which " applicable code" CCANP asserts was ignored in the cadwelding described in Exhibits G thru [ sic] G-4.

The code CCANP was referring to was the manufacturer's specifications on how cadwelds were to be shot.

27. (b) Explain precisely why CCANP believes that the code identified in (a) above is " applicable" for the cadwelds identified in Exhibits G thru [ sic] G-4 The staggered witness marks indicate a sleeve out of tolerance from the specifications set forth by the manufacturer.

[ Note: Exhibit G is merely a blank cadweld record book.]

28. (a) Identify specifically each instance where " corrective measures were not taken" after " staggered witness marks problems" were encountered.

Both Exhibits G-3 and G-4 show staggered witness marks with final inspection as "S" for satisfactory. Since these cadwelds were not rejected, the assumption is there was no corrective action taken.

28. (b) Identify those persons with whom CCANP has discussed the assertion that " corrective measures were not taken" for each Page 18

a instance identified in (a) above. CCANP has not discussed these assertions with anyone.

28. (c) Describe the substance of each conversation.

See 28 (b) above.

28. (d) Produce all documents upon wk!ch CCANP relies to support the assertion that "correctise measures were not taken" for each instance identified in (a) above.

Documents G-3 and G-4 are the only documents CCANP relies upon to support this assertion.

29. (a) Identify the cadwelds by number, if known to CCANP, or by exact location in the base mat of Unit I containment building, if know to CCANP, which CCANP alleges were " randomly assigned" control numbers. If CCANP does not know the number or location of these cadwelds, identify same by time at which CCAMP alleges cadweld " numbers were randomly assigned."

In pages 148 through 153 of his deposition, Mr. Swayze outlines the best information available to CCANP as to this interrogatory. The deposition pages are attached hereto as Exhibit 19.

29. (b) Idantify every QC inspector or other person allegedly involved in recording " knowingly inaccurate" cadweld numbers.

See Exhibit 19

30. (a) Identify specifically each instance where a "cadweld was approved despite its being in violation of quality assurance standards."

The only specific example CCANP can provide at this time is the one given in #16(3), first set.

30. (b) Identify those persons with whom CCANP has discussed the assertion described in (a) above.

Mr. Daniel E. Swayze.

30. (c) Describe the substance of each conversation.

l Mr. Swayze helped CCANP to understand the correlation between the void approved and the manufacturer's standard for such voids. j

30. (d) Produce all documents on which CCANP relies to support the assertion described in (a) above.

The documents attached as exhibits to the first set of Applicant interrogatories are the only documents relied upon.

31. (a) Identify specifically each instance where a " person preparing the Examination Check for the office record changed almost the entire report of the field inspector."

The instances noted in the answers to the first set of interrogatories are the only instances presently known to CCANP.

31. (b) Identify each person with whom CCANP has discussed the j

assertion described in (a), above. Page 19 i

J Mr. Daniel E. Swayze.

31. (c) Describe the substance of each conversation.

Mr. Swayze assisted CCANP in understanding the meaning of the difference between the field notes and the Examination Check.

31. (d) Produce all documents on which CCANP relies to support the assertion described in (a), above.

The documents produced as exhibits to the first set of answers are the only document upon which CCANP relies.

32. (a) Identify each instance where witness " marks were placed on the bars after the welI was shot."

CCANP cannot ident1Cy any single specific instance where witness marks were places on the bars after the weld was shot.

32. (b) Identify each peeson with whom CCANP has discussed the assertion described in (a) above.

Mr. Daniel E. Swayze.

32. (c) Describe the substance of each conversation.

As stated in the first set of answers. Mr. Swayze recounted that he used to go over to the site in tfo evening when he was not on duty. He saw witness marks which were obviously placed on the bars after the shot be:ause the witness mark was shiny when the shot would have covered the witness mark with soot and dust.

32. (d) Produce all documents on which CCANP relies to support the assertion described in (a), above.

The only document upon which CCANP relies in the NRC investigative report number 78-15 which CCANP assumes is already in the hands of the Applicants.

33. (a) Identify each person with whom CCANP has discussed the assertion that no cadwelds were inspected "from August I through September 10."

CCANP has not discussed this assertion with anyone.

33. (b) Describe the substance of each conversation.

See 33(a), above.

33. (c) Produce all documents on which CCANP relies to support the assertion described in (a), above.

The only document upon which CCANP re'fes in the NRC investigative report number 78-15 which CCANP Jssumes is already in the hands of the Applicants.

34. (a) Identify specifically each instance wr re (1) "the required inspection process" was abused. (11) workmanship was " shoddy",

(iii) inspections were not done, (iv) recorJs were " created on a false basis." When CCANP speaks of a break down 19 the Quality Assurance / Quality Control program, CCANP means there was a continual pattern over a period of years of the items Itsted in (1) through (iv). CCANP does not have a detailed break down of each of these items, i l Page 20

^ J but is continuing to research specific instances and will supply them to Applicants as they become available. Meanwhile, Applicants might do well to examine the more than 3,000 entries in the DDR and NCR logs.

34. (b) Identify each person with whom CCANP has discussed the particulars identified in (a), above.

See (a), above. 34 (c) Describe the substance of each conversation. See (a), above.

34. (d) Produce all documents on which CCANP relies in support of each assertion specified in (a), above.

CCANP has produced and will continue to produce all documents coming into CCANP's hands regarding the break down of QA/QC.

35. (a) Identify by number the cadwelds "which are not capable of being verified."

While CCANP is not certain how s?.haustive the work of Applicants to date in identifying such cadwelds has been, CCANP directs Applicants attention to NCR #S-C 3518 and NCR #S-C 3584 attached hereto as Exhibit 13 and 14, respectively. These documents prcvide the identity of 2,194 cadwelds which are not capable of being verified. CCANP would also notes that in CCANP's answers to Applicants first set of interrogatories, ctrtain documents were withheld. Later these documents were released to Applicants with a statement from CCANP that to the best of CCANP's knowledge the documents provided a list of cadweld records which had been forged. CCANP has had an opportunity to examine the documents in question at the construction site. Based on this examination, CCANP has concluded that the six page list attached hereto as Exhibit 20 is not a list of forged documents but rather a correct list of documents or entries missing from the vault. Since many of these FSQ packages have no records at all contained in them, CCANP I assumes that all cadweld placed in the areas covered by these FSQ's are also not verifiable. ]

35. (b) Describe precisely the " verification" process which CCANP asserts is required and has been omitted in regard to the cadwelds identified in (a), above.

The attachment to NCR #S-C 3584 does an excellent job of identifying the verification process required.

35. (c) Identify those persons with whom CCANP has discussed the i

assertion that the cadwelds identified in (a), above, were not properly " verified." CCANP has not discussed these NCR with anyone other thin CEU. the other intervenor.

35. (d) Describe the substanr2 of each conversation.

CCANP's discussion with CEU was an exchange of information regarding the substance of the NCRs.

35. (e) Produce all documents on which CCANP relies to support the assertion that the cadwelds identified in (a), above were not properly " verified."

Page 21

See Exhibits 13 and 14.

36. Identify by date, participants and sebject matter each conversation "between quality control inspertors and the design engineers [which] revealed that the design sngineers were being

'ied to by the construction personnel." CCANP is unable at this time to identify date, participants and subject matter supporting this assertion. As soon as such information is developed. CCANP will forward the information on to Applicants and the other parties. 37 Identify exactly that portion of the NRC regulations or South Texas Project Quality Assurance Procedures which CCANP asserts requires that " quality control inspectors verify that the engineering action taken in response to the field request for engineering action was based on the actual problem as it existed in the field." 10 CFR 50, Appendix B Criterion I states: "The quality assurance functions are those of (b) verifying, such as by checking, auditing, and inspection, that activities affecting the safety-related functions have been correctly performed. The persons and organiza-tions performing quality assurance functions shall have sufficient authority and organizational freedom to verify implementation of solutions."

38. (a) Identify specifically each design change approved by site representatives of the design engineering department "without submitting the changes to Houston."

CCANP does not have adequate information to answer this interrogatory. As further information is developed, this informa-tion will be forwarded on to Applicants and the other parties. Since changing of design by site representatives was a policy of Applicants, the number of instances may be quite large.

38. (b) Identify each person with whom CCANP has discussed the assertion set forth in (a), above.

See (a), above.

38. (c) Describe the substance of each conversation.

See (a), above.

38. (d) Identify exactly that portion of the NRC Regulations and/or South Texas Nuclear Project design control procedures which CCANP asserts were violated in the instances identified in (a), above.

See (a), above.

38. (e) Produce all documents upon which CCANP relies to support the assertion set forth in (a), above.

See (a), above.

39. Identify exactly what portion of the NRC Regulations and/or South Texas Project Quality Assurance Procedures which CCANP asserts requires that quality control inspectors are responsible for verifying that design changes conform to the purposes of the original design.

Page 22 l

In reviewing Interrogatory 22 in the Appiteants first set of interrogatories and the CCANP answer to that interrogatory, CCANP concludes that the answer by CCANP should have been "No". The quality cortrol inspectors are responsible for seeing that con-struction is carried out in accordance with design, not for verifying design changes. At the same time, quality control inspectors do have a responsibility to assure the design engineer i making a change is doing so based on accurate information as to 1 the existing situation.

40. Identify exactly that portion of the NRC Regulations and/or South Texas Project Quality Assurance Procedures which CCANP asserts requires that the " original designer" approve design changes.

Perhaps CCANP is confused, but this interrogatory referrices CCANP's answer #27 in the first set. Answer #27 in the first set says: "See 24." Answer #24 does not say that CCANP asserts that i the original designer approve design changes. Answer 24 asserts i that " verbal approval by on site personnel is not subject to design 4 control measures commensurate with those applied to the original design."

41. (a) Identify specifically each design change verbally approved by Mr. Doug Robertson.

CCANP does not have information at this time to give specific instances as requested.

41. (b) Identify each person with whom CCANP has discussed the assertion in (a), above.

Mr. Daniel E. Swayze.

41. (c) Describe the substance of each conversation.

The substance of the conversations is contained in answer

1. 29, first set.

41. (d) Produce all documents upon which CCANP re11es to support the assertion described in (a), above.

See (a), above. Pursuant to CCANP's contention that Mr. Doug Robertson is a geotechnical engineer, Exhibit 21 is the biographical information provided by Brown and Root concerning Mr. Robertson. Attached as Exhibit 22 is Quality Assurance Procedure, ST-QAP-5.3, Earthwork (cover page and pages 7 and 6A). Page 7 identifies Mr. D. Robertson as " Site Geotechnical Engineer." Page 6A shows the position of the Geotechnical Engineer in the organizational j chart for " Site Earthwork."

42. Identify by number, or otherwise, the pour cards or card CCANP alleges were falsified by:

(a? Mr. Rocky Crisp ] (bp Mr. Jack Duke e l Mr. Roger Forte d) Mr Allen Hammans ej Mr. Sam Horton (g)j Mr. Carl King f Mr. B. N. Kesarinath (h) Mr. Bill Lazear (1) Mr. Paul Pelingaris (j) Mr. Suresh H. Shah (k) Mr. Daniel E. Swayze Page 23

e = Based on further conversations with Mr. Swayze, CCANP believes the list of inspectors involved in the card game should be revised to read: a) Mr. Jack Duke b) Mr. Allen Hammons (c) Mr. Bill Lazear (d) Mr. Charles Singleton (e) Mr. Daniel E. Swayze (f) Mr. George Wilson The earlier list resulted from a misunderstanding on CCANP's part of a conversation with Mr. Swayze. As to the documents falsified by those who played cards over the four month period, CCANP is not aware of which pour cards were signed by wenich personnel. CCANP is, however, aware of some of the work that was going on during this period. What follows is a selection from the Concrete Pour Log kept by Brown and Root during the period of the card game. The selection was made on the basis of the size of the pour or the critical nature of the pour. Date Pour Cubic Yards 7/05/77 CA2-S1 RCB 2 Tendon Gallery 439 Main Access Base Mat 7/08/77 Turbine Generator 2 Circulating 310 Water Pipe Encasement Slab 8/03/77 Circulating Water Pipe Encasement 690 8/02/77 Cell Wall Circulating Water Intake 470 Structure Unit 2 8/04/77 RCB 2 First Lift of Base Mat 1200 Center Section 8/15/77 Cell Wall at Circulating Water 470 Intake Structure Unit 2 8/18/77 RCB 1 Primary Shield Wall 463 Elev. -11' 3" t o + 3 ' 2" 8/19/77 RCB 1 Lift 4 Exterior Shell Wall 725 Elev. 17' to 27' 8/23/77 MEAB 1 Base Mat 1002 8/24//7 RCB 2 Main Access Wall First Lift 338 -36'9" to -25'9" 8/24/77 FHB 2 Wall from Elev. -29' to 475 -13'3" Column T.5 3/29/77 Circulating Water Intake Structure 470 Unit 2 8/29/77 MEAB Base Hat 805 8/30/77 MEAB 1 Pour MEl-21 881 9/6/77 RCB 2 East Pcrtion of Base Mat from 1240 Elev. -31'3" to -22'3" 9/7/77 MEAB Base Mat 700 9/9/77 RCB 1 Main Access Wall 273 Elev. -l'3" to 10'9" 9/10/77 Steam Generator Feed Pump Ped. Oper. 425 Floor 9 Elev 83'0" 9/10/77 MEAB 1 Base Mat 1100 9/14/77 RCB 1 South Secondary Shield Wall and 83 Heat Ex. Area Walls E1. -11'3" to -4'0" 9/14/77 RCB 2 Lower Base Hat 1240 9/15/77 FHB 1 Mat from +14' to +24' 206 9/16/77 FHB 1 Elev Slab 21'11" 1325 9/19/77 Foundation Slab for Pumping Structure 1200 Elev. -19' 9/21/77 Auxiliary Bay Cell Wall at Cooling Water Intake Structure 1112 Page 24

9/22/77 RCB 2 South Secticn of Lower Base Mat 1240 i Elev. -31'3" to -2i'3" 9/26/77 RCB 2 Lower Base Mat, North Section 1240 1 Elev. -31'3" to -20'3" 9/28/77 MEAB 1 Mat Pour 850 10/4/77 TG2 315 10/4/77 FHB 2 East Exterior Wall 460 Elev. -29' to -13'3" 10/5/77 MEAB 1 Mat Pour 796 10/7/77 MEl-Mll Mat Pour 528 10/19/77 MEl-M12 Base Mat 708 10/20/77 TG2-E013 through E016 355 10/21/77 CSI-WS Exterior Shell Wall Lift 5 700 Elev 27' to 37' 10/25/77 MEl-M22 Base Mat 754 10/28/77 CII-W12 Primary Shield Wall 423 i Elev. 3'9" to 16'0" i 10/29/77 RCB 2 Reactor Base Hat Center Section 565 Elev. -22'3" to -13'3" To summarize this selection f rom the concrete pour log, more than 26,500 cubic yards of concrete were poured in the four month time period alleged for the card game. The allegation is that the vast majority of the pour cards signed off by inspectors on these pours did not result from any inspection. CCANP has gone to such great lengths in detailing these pours in part to establish the seriousness of the allegation concerning the card game. This detail, however, is also provided as substantiation for the charge now made by CCANP that the Region IV office of the Nuclear Regulatory Commission and Mr. Karl Seyfrit in particular did deliberately sabotage the FBI investigation of the South Texas Nuclear Project. J In the interview notes attached hereto as Exhibit 1 Mr. J Karl Seyfrit is recorded as saying: "The NRC conducted an investigation into the allegation that Quality Control (QC) Inspectors at STP were playing cards instead of making the required inspections. Their investigation revealed that during the period, construc-tion was almost at a standstill. Mr. Seyfrit stated he does not doubt t'Ee "i n s p ec t o r s killed time by playing cards, however, the construction during the period was-not of a criticaT~iiature." (emphasis adde'd'T-Combined with the earlier statement of Mr. Seyfrit, to-wit that the NRC would not delay licensing if they learned 88R was J falsifying the cadweld documentation, the statement quoted above, in the light of the list of actual construction work provided by CCANP, confirms CCANP's worst suspicions about the operation of the Arlington office of the Nuclear Regulatory Commission. For some time, CCANP has felt that the NRC Arlington office j was not really interested in exercising their regulatory function i at the South Texas Nuclear Project, but rather exercised a function I that can best be characterized as a cover-up of deficiencies. Reading the NRC investigative reports is a visit to Alice in Wonderland where forgery becomes cleaning up smudged documents and falsification of witness marks on cadwelds becomes an unresol-ved item with no further investigation to determine the extent of such falsification. These harsh words are not a pleasant task for CCANP, but the evidence has become too substantive to ignore. CCANP only hopes that the Atomic Safety and Licensing Board is equally appalled at the actions of the NRC Aritngton office and will take some action to correct the situattor. Page 25 I i

4 l l

43. (a) Identify all of the individuals known to CCANP to have been involved in the assault on Mr. James Marshall.

l The individual who assaulted Mr. James Marshall was Mr. Joe Bazor or Bazea. (b) Identify all of the individuals known to CCAMP to have been involved in the assault on Mr. Jerry Lacey. The individual who assaulted Mr. Jerry Lacey is believed to j have been M*. Gary May. l (c) Idantify each person with whom CCANP has discussed the allegations set forth in (a) and (b), above. Mr. Daniel E. Swayze and a secretary - name unknown - at the Nuclear Regulatory Commission. (d) Describe the substance of each conversation. In conversations with Mr. Swayze about the beating of James Marshall, Mr. Swayze spoke of this beating as the proverbial straw that broke the camel's back as far as inspection personnel were concerned. This assault led directly to the decision to play cards rather than risk a similar attack by carrying out inspection duties. Mr. Swayze called Mr. Lanny Sinkin of CCANP to inform him that he had heard Mr. Lacey had been beaten. Mr. Sinkin, in turn, called the NRC Arlington office and lef t a message with a secretary concerning the alleged beating. ] (e) Produce all documents upon which CCANP relies to support the allegations set forth in (a) and (b) above. Exhibit 23 is the Houston Lighting & Power Company file on the beating of James Marshall. CCANP takes note that on page 2 of this file, the person reporting the assault and related matters is three times referred to as a " informer." The use of this term indicates something about the attitude held towards those who come forward with adverse information about the construction of this particular plant. CCANP also notes the almost humorous attempt to minir.ize the assault found in the remarks of Mr. C. L. Crane on page 3 of Exhibit 23. While noting that a meeting was scheduled to discuss the " communication problems" between Q. C. concrete inspection and concrete placement supervision at about the time of the assault on James Marshall, Mr. Crane "would like to point out here that there is no evidence that clearly links the subject altercation to a general communications problem." Furthermore, Mr. Crane, on page 5 of this Exhibit, also refers to the person who reported the assault and related matters as "this informer." Exhibit 24 is the Brown and Root file on the Marshall assault, except for those pages which are exact duplicates of pages found in the Houston Lighting & Power file. CCANP is disturbed that page 2 of this exhibit seems to have information deleted. Applicants and Brown and Root have been less than forthcoming with these files. When CCANP's and CEU's first set of interroga-tories asked for the investigative file on the beating of James Marshall, the App 1tcants responded with a dental that either the Applicants or Brown and Root had such a file. It was only after CCANP answered the first interrogatories with an exhibit clearly demonstrating that such an investigation had been underta-ken did the Applicants supplement their response by saying that both the Applicants and Brown and Root had such files. Page 26

d When Mrs. Peggy Buchorn went to Houston and asked for the Brown and Root file on the beating of James Marshall, however, Brown and Root tried to deny the file to Mrs. Buchorn. Only af ter various telephone calls to Mr. Sinkin, to Washington, and to Houston did Brown and Root release the file. There was no statement made at the time of the release concerning any proprietary or confidential information, so the seeming delettons from page 2 are considered unsatisfactory by CCANP.

44. (a) Identify each person with whom CCANP has discussed the assertion that "Mr.

Larry Perry was fired after calling in the NRC on, among other things, the falsification of witness marks on cadwelds." Mr. Swayze has told CCANP that in early September of 1978 Mr. Larry Perry called the NRC to report what he considered violations of 10 CFR 50 and to ask for an investigation. On September 11-14, 1978, NRC investigators went to the construction site for an unannounced investigation. Their inves-tigation, Report 78-15, substantiated a number of Mr. Perry's allegations as noted previously by CCANP. The exit interview was held on September 14 at which time the licensee representatives were informed of the allegations and the findings. On September 21, 1978, Mr. Larry Perry was terminated. (b) Describe the substance of each conversation. See (a), above. (c) Produce all documents upon which CCANP relies to support the assertion set forth in (a), above. The only document CCANP relies upon is the NRC Report 78-15 which Applicants should already have a copy of and the employment records supplied by Applicants in response to CCANP's first set of interrogatories.

45. (a) Identify specifically each and every instance of "inti-midation" or " abuse" which CCANP asserts was " endemic."

CCANP should perhaps have said " epidemic." Identification of the victims of any epidemic is most difficult. The documentation provided in reponse to other interrogatories about intimidation and abuse show the pattern which CCANP asserts. (b) Identify each person with whom CCAMP has discussed the allegations set forth in (a), above. CCANP has held press conferences and addressed numerous groups on the subject of intimidation and abuse of inspectors at the South Texas Nuclear Project. The naming of these persons is impractical. (c) Describe the substance of each conversation. See (b), above. (d) Produce all documents on which CCANP relies to support the allegations set forth in (a), above. The documents produced in response to the first set of interrogatories and earlier interrogatories in this set regarding intimidation and abuse of inspectors are the only documents currently in CCANP hands, other than the FBI report, the relevant Page 27

pages of which are attached hereto as Exhibit 25. If more documents do become available. CCANP will forward them on to Applicants and to the other parties.

46. (a) Explain precisely how Exhibit P shows " pervasive construc-tion errors."

The documents in Exhibit P show that, in the words of T. K. Logan, Lead Civil Engineer (HL8P), "B8R Construction personnel have a poor understanding of the word ' quality' and how it relates to inspection prior to placement." As explained in the answers to Appitcants first set of interrogatories Exhibit 0, attached hereto as Exhibit 4, provides an insight into these punch lists in that "all items identified 1 on the punch lists were valid." l Finally, the term punch lists applies to those item written up by inspectors which are in error. The pervasive aspect is derived from the number of 1? s written up on one particular construction.

46. (b) Explain precisely how Exhibit P shows "the tension between construction workers and inspectors."

Applicants have misunderstood. Exhibit P read in the context of Exhibit 0 shows the tension causes and effects. I i

46. (c) Identify each instance in which CCANP asserts that i

" pervasive construction errors" caused " tension between construc-tion workers and inspectors." 1 CCANP is not prepared to provide lengthy detail on each Instance in which pervasive costruction errors cause tension i between construction workers and inspectors. CCANP believes that Exhibit 4 provides a clear showing of this contention, j

46. (d) Identify each individual with whom CCANP has spoken concerning the " tension between construction workers and inspec.

tors." Mr. Daniel E. Swayre.

46. (e) Produce each document upon which CCANP relies for the conclusion set forth in (c), above.

These documents have already been produced as either an exhibit to the first set of answers or as an exhibit to this set.

47. Identify each and every construction record, other than the

" pour cards" referenced in Contention 1, Paragraph d., which you assert has been falsified. Each and every construction record, including but not limited to cadweld records, signed by any inspector who played cards rather then inspecting.

48. Identify each person you intend to call as a witness at the Hearing to testify to matters relating to Contention 2 or any part of Contention 2.

CCANP has under consideration dropping Contention 2. If Contention 2 is continued, CCANP will call Mr. Dale Bridenbaugh. j i

49. (a) List all events which can cause reactor coolant pressure to increase above "specified limits."

Page 28

a l As CCANP was unable to reach Mr. Bridenbaugh regarding this contention, CCANP's answer will have to wait for another day. (b) What are the "specified limits" for coolant pressure. See (a), above. (c) Describe every sequence of events which will result in the failure of automatic pressure relief mechanisms, thereby allowing a pressure rise "to go unchecked." See (a), above. (d) What pressure will cause the " fracture or rupture of the vessel?" See (a), above. !!. Production of Other Documents

1. Produce for inspection the originals from which CCANP made copies for Exhibits G-Z, G-3, G-4, H-1, H-2, I-1, 1-2, J, K-1, K-

2. K-3, K-4, L, N,

0, and P attached to the " Answers of Citizens Concerned About Nuclear Power, Inc. to First Set of Interrogatories from Houston Lighting and Power Company, et al., Applicants, and to NRC Staff Interrogatories and Request for Documents." See Interrogatory 1 herein. 1 Respectfully submitted, CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. 116 Villita San Antonio, Texas 78 05 By: M r,.., ,/ r f<* Lanny AJah Sinkin, Co-Coordinator STATE OF TEXAS COUNTY OF BEXAR BEFORE ME, the undersigned authority, on this day personally appeared LANNY ALAN SINKIN, known to me to be a credible person, wto on his oath says that he 15 the co-coordinator of Citizens Concerned About Nuclear Power, Inc. and that he has read the foregoing Answers of Citizens Concerned About Nuclear Power. Inc. to Second Set of Interrogatories and Requests for Production of Documents from Houston Lighting & Power, et al., Applicants and knows the same to be true and correct. [? r.n p LANNY ApN 'SINKIN, CO-COORDIN ATOR SUBSQIBM AND SWORN to before me by LA Y ALAN $1NKIN on this the 3 / W ay of March, 980. 22= & (b hem y F u : : c i n Mid f o r Bexar County, Texas My Commission expires: Page 29

l 4 1 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING AND POWER Docket Nos. 50-498 COMPANY, ET. AL. 50-499 (South Texas Project Units 1 and 2) CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. ANSWERS TO SECOND SET OF INTERROGATORIES ) AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING & POWER ET AL., APPLICANTS" in the above-captioned proceeding were served on the following by deposit in the United States Mail, postage prepaid this 29th day of March, 1980. Charles Bechhoefer, Esq. Mrs. Peggy Buchorn Chairman Executive Director Atomic Safety and Licensing Board Citizens for Equitable U. S. Nuclear Regulatory Commission Utilities 1 Wasington, D.C. 20555 Route 1. Box 1684 Brazoria Texas 77422 Dr. James C. Lamb, III 313 Woodhaven Road Melbert D. Schwarz Chapel Hill, North Carolina 27514 Baker and Botts 3000 One Shell Plaza Dr. Emmeth A. Luebke Houston, Texas 77002 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Jack R. Newman Washington, D.C. 20555 Lowenstein Newman, Reis, Axelrad, and Toll Henry J. McGurren. Esq. 1025 Connecticut Ave., N.W. Hearing Attorney Washington, D.C. 20036 Office of the Executive Legal Director Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Panel Washington, D.C. 20555 U. 5. Nuclear Regulatory Commission Richard W. Lowerre. Esq. Washington, D.C. 20555 Assistant Attorney General for the State of Texas Atomic Safety and Licensing P. O. Box 12548 Capitol Station Appeal Panel Austin, Texas 78711 U. S. Nuclear Regulatory Commission Honorable Burt O'Connell Washington. 0.C. 20555 County Judge, Matagorda County Maragorda County Court House Docketing and Service Section (4) Bay City. Texas 77414 Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ) ut% fflA:. n 3f March E I, 1980 x s~ Lanny Alan Sinkin 116 Villita i San Antonio, Texas 78205 l l

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.p as= w a====se- ~ r ro l r, ._T i i Xarl Y. Seyfrit, Director, Region IY, Nuclear 5-Regul FRC), met with Supervis cial [. g,! ) 2 Agent and Special Agent c._ I [. at whi urnashed the following ornat ont p ~ g, The documentation of cadweld locations at the South $~ Texas Nuclear Pmject (STP) was not required by NRC prior to E. ? the submission of the original design by Brown g Root. Inc. f, -( BER). However,NBER couaitted to document the cadweld locationa so the NRC is requiring that they stand by their - / coar.itnant. If they wanted to, BER officials could have -= this documentation requirement removed by a simple procedure. Fc i 3-f BER has not chosen to have this requirement removed. The =E-NRC would not delay licensing if they learned BER was U f falsifying the cadweld documentation. G. 3 1.i . p. The NRC conducted an investigation into the E? allegation that Quality Control (QC) Inspectors at STP F were playing cards instead of making the required inspections. p 1[. Their investigation revealed that during.the period, con-ty.' b struction was almost at a standstill. Mr. Seyfrit stated p m he does not doubt the inspectors killed time by playing cards, [ U.;. however, the construction during the period was not of a b critical nature. NRC conducted safety reviews during the i; p period of the card playing and found nothing that would p$ materially affect the safety of the Plant. e E k* He stated that NRC is aware of the problem with ~ ~d anchor bolts at STP. 11ouston Lighting & Power (HLEP) is e looking into whether or not the bolts will have to be p {p replaced. NRC is closely monitoring HLEP's review of the situa-tion. g F-- .2 During the course of the meeting, W. A. " Bill * -- h Crosscan, Chiaf,. Projects Section, NRC, and W. G. " Bill" ]i. the discussion. Hubacek, Reactor Inspector, Projects Section, joined in b. if Mr. Seyfrit advised the NRC he.s conducted several NE- ,,,__8/71/79 m11.. v.v.. H0 166-1987 { e, p, 'Supervinov 8/23/79 r g RA TTC /..r. gene essenes kr 7tmo emessusas assue se mer: nee _ _ e mes esme= mens of see P90 B e se,seessey as em Pts ese a tasass to your assuy: /4 j e eies an emneenes og see en se seesemos eseese veue ogsas.'. i ~ f&. I? w i

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1 i, ('whereup n, the deposition resumed, i f? U l 2 purs uan t to the taking of the recess, I y.r.., N C,. ,p;.,. h 1 at 1:30 o' clock p.m.) s I ? d,s ; DAN SWAYZE ji:i'e i [ s,E,.. s3 the witness hereinbefore named, was examined and I ?,I [$*: { tes tifi ed further as follows : a , g; ( Lplu,p g,l t, DIRECT EXAMINATION (Continued) s { ('ty';..I. 8, s : s i ':i iBY HR. BROWN: 7}- i 3 p fp. g3 jQ Hr. Swayze, in any large operation like this you N ?.W ' \\ ? G. 10, are working with many, many people, are you not? , [*lT u. A Yes, sir. C.5 Q-it.

Q And there are bound to be certain people that you h 12 l

work with with whom you are quite friendly and is, d ' i4 others with whom you are less friendly, corract? ' c l is A Could you repeat'that scatement? l}- I se Q When you ari working with any large group of people, (.' ir like this, there are bound to be people, some 'S l peoP e with whor you are quite friendly and other is 5: i to people with whom you are less friendly. J A Correct. y g r; Q Would you identify those on the South Texas Projec t A ? 22 that you considered your closes t group of friends ? 23 A Personnel in the Quality Control Department. 24 Q All right. Who, for example? 2s A Well, I would have to rephrase that. I don't think-l l l Vis d,. ev

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I coulu call it so mtach a frie.t. 7 tyi:o relationship N 'l i i l as a work type relationship. i I y 3 Q Okay. tho would those be? I e 4 A Suresh Shah, Degamoudre K::sarinath, Sam !!orton. i. Paul Pelengaris, Pravin Shah, Al llammons, Jim .i .k[{., j s l' l Narron, Tom Schroeder, Terry Gardner. [ e ( l [, Q Now, those are the people on the project with whom .r i ( you were most friendly? j a l i e A I had a very good work relationship, I would say. io Q Well,.what about personal friendship? Did you ? t i consider them your friends? ,1, is (* 12 A We had very little contact of f the job sito. L

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., i is i Q All right. What about people in Construction? J l i. 14 A In what respect? I I [ is Q Who were your closest friends? 4 is A i had no friends in Construction. l f. ir Q Would you explain why that is? l-3 b Well, initially the adverr y type positioa.a veral i J.* is A

p in, coupled with the very evidvat intimidation that to started at the outset of my an.plo/ ment, it 's just so J'

ai not the kind of situatica you for.a personal 'b 22 f riendships. 23 Q All right. Vould you ca :laia this intinidatic,n k you are speaking of? u 24 I Ilarassment, verbal abuse, coastant atteiapts to 25 A ] i s f ~ $$qhi&m! E :,. T f 1: .y; ~t. .Rhq. >,y.. .i o, w v 'y .I: Q.. g of.. s s s f A k, =ae ^

~ ~ t I discredit me and other ins?.coorz witit our manag - i i l 2 ment lersonnel. l 3 Q And you say this started from the very beginaing l of your employment? 4 s A Yes, sir. s Q And so you would say there was a division -- i 7 A A very definite devision. [ e s Q -- between the quality control group, of which you l, were a part, and the construction group'? l e to A Yes, sir. j r ti Q Right? And a hostility between them? l f i2 A Yes. is Q And did you fce! hos* ile toward the people in the [ construction group just as they did toward you. 14 or you felt they did toward you? is ) is A I wasn't hostile toward them. I couldn't under-l I stand their position the majority of the tir.'o f r.m 17 the standpoint that they never would fully unde e-is - stand why we were there, what our function was I. ; l is ro quality control. And as a result of not under-standing it, they reacted in the manner they did. l 21 4 22 C Did the construction grcits undertake to do shoddy i 2-work, poor qual n, work and o') ject to your in. re-tion and correction of their work? l 24 t 25 A Constantly.

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I \\ y,,.e. 58 ry .,' (.j,,? Q And that applied to all the construction forces? $N, Q,".J A Civil discipline. n.,, fy.1 Q All of the civil discipline construction forces? h 'A Yes, sir. I ~ .[ '# Q Decause they are the ones that you dealt with? ,e 'A Yes, sir. Stt > l ' [ Q And there wasn't anybody in Construction, then, 5.e - j w 4; Q that you would except from that? i i -@ 6 {sdM; 'A Could you repeat that, please? 1 i k Q No one in the construction, the civil construction +ty. t .jy'st! group, that you would exclude from what you have ,e described as a hostile group who were wanting to j i j7 ? , 9. s ' do shoddy and poor quality work and objected to 8 l l -n. ]#j the inspection activities of your group? 1 H.ia' A I would exclude some of the craf tsmen at the craf t i 'O.: g l G.*M 4 leve l.

2. 4 R" r' 'ff, The craftsmen. But none of the supervisors?

!,L.y. Q - 4,,8 2, 'a No, sir. .s ' Q All right. All the supervisors were of that mind? if.,18;J, ]:.m A That I had contact with.

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Okay. And you had contact with all of the civil J.p[tB group, didn't you? '.. m : A Yes, sir. i 2; Q Okay. Was this a constant thing going on during 3 the whole time you were there or did it have its 's 1 p( (

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Through the, up until the time of my discharge. e sq Okay, llow did you react to this hostility? .} [F A We attempted to address the problem -- s

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management and see if we could be given some type i ),' n Q of relief from the abuse and harassment that was . r-jf.,y,e i every day occurring. I,j. Te Q I see. You spoke to your management about this

]M problem?

/. Is A Yes, s.;r. ).,a Q To whom did you speak? h in A Terry Gardner. c. Y ', # Q What did you say to him? .m A Basically that they were trying to prevent us from (, - a 'i doing our job through the use of harassment. When .a an inspector would cite valid discrepancies and +,. bring these to the attention of construction c a i,'( a a supervision, they would respond with verbal abuse and just general harassment. i M They would go to our management and f ~ s $ 4'%4WFAM / \\

l l m

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. 'ry,.../T 60 l ns. i' .fi attempt to discredit the items brought to their k>1t s' attention, and on many occasions we had to take y $'[3 our management personnel into the field, and they '.4f4 i l ,a would verify that the items were in fact in viola- ? s' ~f e tion of spec., procedure, drawing. m Q Did the construction people ever win any of these 3 disputes? ) 'G > t ,.O A Very seldom. i ) k: ? \\ [Se Q You were always right? y t

k. di-YI, Ninety-nine percent of the time.

} I yo A Q Okay. m A On occasion you would get into an area of vague t h.I,Me interpretation, but the procedures and the specs. d f{tM were pretty self-explanatory, f. ( g.r 'y 's Q Would you give me some examples of 1. .nssment? f, W A During the time I was inspecting or during the tiue I , lj.e A 1 was a lead inspector? I L S.'N Q Both. e-f A Sir? ,i v;

1. N/.m 4

First let's take the time when you were inspector 4, and then let 's c[me back and take the time when you h i a f'he were lead inspector. i ) ya A Performing inspection, I would cite the items that 1 bN 4 were in non-compliance. There would usually be a .e i r[215 A verbal discussion with the foreman, his general 3:~ ni.' < f W.. 2.;. m ,,, a a .1 ~ ' & W,.. a .3. % ' a.M:

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Yr foreman usually.

4. 7'y If it was a critical situation where they .,hy A wanted the pour to go that day or the next day, Q!.ge Q they would try to convince us that the items ?.+.z,. X(y A addressed were in fact in compliance. 9 -3', Q If we wouldn't concur is when they would +.- 28.'y A nomally bring in the supervisory level personnel. e. _'Ef.e. And a pretty typical instance is you would be in l N.,ub the field by yourself, or possibly with another 1 c.+ We Q inspector, and you would end up confronting any-U ' M+.: .- g where from three, six, eight construction supervisory s c.p s 4 personnel, and they would become very hostile, very belligerent. They just flat stated that they were

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• ]ifQu fed up with us delaying the concrete pours.

Fm Q Okay. And that's what you have described as n i Vm Q harassment? '... s A Sir? J. '. e Q And that 's what you have described as harassment? i %.t a 4 Yes, sir. p. ,a Q And what you have described to me sounds like i. pWra Q situations in which hey expressed disagreement c: W-a with your ruling -- J' l A In very strong tems. j {})s h ~ es Q -- on your inspection. l t

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In very strong terms. ,g4 Se? ~ g ; v ;;t &gt w p- =~ f f .p, y '" f 2 J.r.~a'& ^ 0 /. ~ d s we mn J./. 7/ ~ ~. w..,. ;. y l , _.g: ' s )\\ \\. sb ./ \\ . /46

1 l J ?.. 62 l . c.. ' Et,! Q In strong terms. ppr I.i' sy So it was protesting your ruling -- t h'.A A Yes, sir. .,s. R.V Q -- that you referred to as harassment? .$. t. \\ f,'j,g. a l A A Yes, sir. i .,si+. Q[ Q And what do you refer to as verbal abuse? i .N :"3 '? - A Quote, when you are called a " nitpicking mother ,;,[;,$r. fucker," and, "we are tired of your crap, and we 3 p

• V '.

j{p are going to do something about it."

P*Es Q All right. And what do you refer to by attempt to .n. '6 m discredit? ' '7 ' g A 'They would attempt to 'go to our management and a e convince them that items that we cited were in fact C ' '.N q non-valid and we had no basis to cite these e findings. j i ~ 4 Q And by your management you are referring to the c., N .t QC supervisors? e J' 4 4 Through QA. i '};,, 4 Q QA supervisors. QA and QC supervisors. A QA-QC. 4.a O M Q All right. And in other words, they would appeal .;.3: a your cecision? ,y 1 4 A In a lot of instances they would. ' M Q And that's what you referred to as attempt to .) a discredit? ,2, i 1 ) r l o. e rH$,:?},$:liiYk.o.n:v h A 6 y q.:;L ~ -,,xc : y b . m ly.Ml..ISW ::'.3D: 0 ~ j "YZ$l \\ ';P, 3% % e-i 3 l m-i hf) p '.h " ,d 1Y'. r; 'I / y- 'M . *;y bd;.n.- ~ - . f ~ 7 j e' ,-: m ) 6 m --' ~~ - ' ~ ^^~

d 5 G3 . ;,1 .li A Well, on many occasions they would make the ~ 4 statement to our supervisors that we were lying l'.:s x3 A concerning the deficiencies, and on many occasions -.i Q it would reach a point where we had to take our 'I

j. ke We supervisor in the field and physically show him the p

N.p1 fs 'A discrepancy. l fN.r. Q It was a situation where they attempted ^;: 6".

• Je i

to convince our management that the inspector's .1v M.. _eQ word was basically worthless. h a Q And this was in connection with their appeal front ,fu l. your ruling, is that right? f ,e A I would say their position. I wouldn't say so much }.a an appeal. -l ', W Q Well, they were going over your head to your 7 superiors with their opf alon that your rejection ^ l a 1 of their work was not justified? m p A Yes, sir. a Q And that's what you are referring to as attempt to J ',m A discredit? 4. ,',a A Yes, sir, in the manner they handled it. (M Q And what about the manner in which they handled it h, a A are you referring to when you say attempt to l B 4 discredit? 'I. se A They would try to convince our supervisory personne L l 8 4 that we weren't competent and we weren't valid in 94. e v %

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1 r. 29 64 .g if2e our findings, our findings weren't valid. ., sk - W., y Q Okay.

6. T

/d3 A And they know as well as we did that they were. ft. jf.f[e Q Now, did your supervisors always agree and side 4'kg 4 with you? I-Jf;f.fy MV j A Ninety-nine percent of the time. ,g l Q Did they ever overrule you? y Egs' A Yes. ?,,g.r. o .s Q Could you give me some examples of the few times $f e Q when you wem overruled by your management? ~;{+y%s;n A The best that I can recall is that it would ga normally boil down to an, interpretation of the l p. c-a procedure or drawing or the spec. and the manner i .[ u 's it was worded. l .n .]![?m Q Can you give me an example of that? y: u A Not at this time. I would have to go back through i ka soce procedures. M. q; e Q You can't recall one in particular, then? l [,.. G m A No, sir. $g$ a Q All those that you can recall are ones that you j M.a won? e ,I a A Sir? x: .g n Q Where you were upheld by your supervisors. 4. . j,' m A I can't recall all of those. ) a Q No, but the only ones that you can recall are 1 ) g \\ ~ u.. ,w, I9- 'y ~. g, ,3 e e 'I '.f.?d ' ' .E / a . 4,. ' *-PT,"), J.,'*, ,Q,,,.'.* [ 3,

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i ( '[. 65 \\ cases where you won the appeal and were upheld by i l /,? lis r -s 1 { $3 your superiors, and you can't recall any of the l l

t'i instances when you were overruled?

i l hf4 A I can recall instances when I was overruled. 3 w '.k ?g Q Would you tell us about -- 2.M l e.;.Fs A, I can't be specific. l '$ 's. Q OkaY. x.- A d, w s Normally it dealt with an interpretation type c e n..,: i a,;. e problem. ,A j ? y/, u Q What do you mean by an interpretation type problem? .4 A yp.;se A Quote out of the procedure that I would possibly -+

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'2 m q interpret one way and someone else would interpret 1 g"@ u ,s another way. u if.y u Q What is the area for the exercise of judgment in f}, a a construing the plans and specifications to determinc .g.. (( r a whether the work has been properly done by the 'ij-r u construction people? l,. *['u C o-MR. SCIIUDIAN: Do you want a clarifica-a, $i's l. tion on that? .psc .& Tm C THE WITNESS: Yeah. I didn't really .?p-N.m A understand that question. a. JGJa MR. SCHUDIAN: Would you please rephrase g.7 ji

• a that?

9: g,' N .i MR. BROWN: Let 's see if we could read it .p. J.,, 8 I '5E Q back. . b[k l i vc j ) 4#- ' ;g.:.. It.id...',., $[ k-W *, = g ;;..: c :. '.- kt.t.C(

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A We weren't really allowed to use judgment. We just

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cited fact. s' F BY HR. BROWN: 1 t

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Okay. So you did not apply any judgment to the a .7,g,e A questions of whether work done in this fashion met u. gs Q or did not meet the plans and specifications? +4 m[i.s A We were instructed to quote the spec. or procedure In 1. verbatim and not use. Judgment? x;> !U$a Q What about the amount of tolerance? 6.5 L / *l:,' u A In what respect? '.Gl Q The dimensions. . :t;t M ~' ; m A If the procedure stated one-half inch was tho ,[',. s acceptable tolerance for a given item, and it was s. ' ';w five-sixteenths, it was not acceptable. ~*m Q What if it were 17/32nds? ,'Y x2*'s A 1?/32nds? .i a Q Uh-huh. ~.

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m A I would have to stop and think about that a minute. '. a 17/32nds would not be acceptable. a Q And you would reject it? 38 A Yes, sir. a Q If it called for half?

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m $t + 3 67 e i i. O A Right. 5: dy Q And if it were as much as a thirty-seconds of an .,:~ .'T 3 inch out of tolerance, you would reject it? qi;g e A Ye s, si r. .W.3-s -3 ,. ij s Q If the form, for example, were out of tolerance dt Mje from the oppJsite fom by 'such an amount, you would reject it? e r.?+ A Yes, sir. g We Q And is that what would give rise to a protest from m's.. '((a F the construction people? .yXn A That's one of the reasons. r U.s Q All right. And were there, were the construction 3"$ e people expressing hostility to so strict an inter-l ~' . n. v A pretation as that of the requirements of the l y*, M

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specifications? C.4 m l E(*h* w MR. SCHA31EN: I don't believe we can s i 0 determine from that question really how strict an j+:6,u l r- .q,4 interpretation we are talking about because --

c7'

.WM MR. BROWN: One as strict as 1/32nds of . fs. : t -M,,. a A an inch. t .j@t, MR. SCHARMEN: Well, when you are talking a 'l .P T M.3 about a fom. as you were discussing -- y 7. 3 MR. BROWN: Concrete forms in the civil k'. - Tj * ?. work. Ma '4 MR. SCHARMEN: Of what dimensions? l .,5 _s . y,E 1 t. M.r,38 ..,hC1' \\ ' ~.'

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~K3 to be poured.

t nh MR. SCHARMEN: Something as large as a 1.[r.; i = ~ \\ We hundred yards long or -- i pl. i

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THE WITNESS: I don't believe we had any cr M.'s pours of that dimension. ~.:. JO e BY MR. BROWN: .s. din Q No. Okay. Now take the pours ttiat you did have. l t y$e Is that the kind of thing that the construction [.'. ' s people were protesting? 2. M. 3 'u A Very seldom. The majority of the time it was very t. 4 M' measurable. You didn't have to get down to a j .fy.,e g.

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thirty-seconds of an inch. i;

• E,+ ' '.sQ But did they take the position that you were not I

1 [s being reasonable in interpretation of the plans i e and specifications? q-g;ise ra A On many occasions. '.if Q Now, were there ever occasions when you were crit- [ n g $.a icized for the manner in which you conducted yotr ,(I w- .,j..) a inspections? _w l. . Eb as A. Of the manner in which we conducted the inspections'? U g T. (f.[a Q That you conducted your inspections. <$l T I 3 l .hs 4 t l 3:g:., ^ m.. $;6 4 ~1,p g M l

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i 4 w-CU 69 in- $.). A Constantly. They were never satisfied. We either i .fa in';pected too fast or we inspected too slow, we m didn't give them all the items that were in non- ,, 3 $2.D~a conformance. Me Jie It was just a very hard bunch of people m!. sifg q to please. I,N[y Q All right. Now, were you ever criticized for this? 5 ' k::'s A Ye s. l d jf[e Q Were you ever criticized for this by your superiors il n 4#m in QA-QC? ',1 -{ 2iu A No, sir. g Q They always supported you? .[CY' A If it was out of specification, they supported our gm

fu position.

• R,.

J,s Q All right. Are you saying you were never spoken N in g to by your own superiors about the manner in which ,y x fp A you handled these matters? a s. u. ' IE A I can recall on one occasion Construction complaine i Q.' r ' ~ Ji ts l,, to our supervisory personnel that, well, on one . a.c ' /.j s q occasion, for a lengthy period of time during the A inspection process, we would verbally contact the h'3 m >, g construction foremen, construction general foreman.

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< w.- $[a whoever the appropriate person was, and inform him e. ,e d3 of the problems that they had with the specific ..;- 3e . ;if s item we were inspecting. h.- n?.

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w,.. d[$ 70 l .az,y .'(,h t 1 And it finally reached the point where l 'a".4 t ";;f's A Construction was trying to use the excuse of why 'i they didn't repair something, af ter it had been t c. A noted, that we didn't tell them, that 's when we 4

• '. 'S. 4 went to a punch list.

( ? q 1.@e Q And you are saying your superiors never criticized ,1 ) 4"; j

1. p you for the manner in which you did this work?

A They never criticized us. It was mentioned to us e 4 by u'em on occasion that Construction'had complainee, .%.is and tney would ask what is the problem, is there a g tu.m a w prc'alem, what do we need to do about it. E,h, [d 5-q l t.N e Q All right. Nobody ever spoke to you about the jl s er.. .[T.s 4 manner in which you were relating to the construc-l3 ll b4 if jrtt # A tion people? ,s (re(."s A Yes. a: l$ I jt - M.M Q They did? !W ; 4 J'J: N A Yes. }

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.(EJ' # Q Tell me about that. Who was this? ) e $7 m A As I just explained Tom Schreeder on occasion. 9x <i a Q All right. Tell me about what Tom Schroeder said. .m p 1 )d , ;;. n A There was a discussion at one time as to whether

• L.

?c a we were inspecting in a satisfactory time frame. 4 .V G~n and he questioned me about it, and I stated that ..g. .% M we were undermanned and we were doing the best we A .q- -a can. .r n t P ~ y. "* ~ -~..,- 1.; c s j, d vb, % [. g. ? - \\ i ~ m.k .,, j t/ j ,3 o .f f . m

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A I ~ 71 ,..I' Q All right. .a A And he said, 'That 's fine. " 6 3 Q All right. And he said that was fine, correct's .' 4 A Right. l .. e 4 There was never any occasion when Mr. Schreeder e criticized the manner in which you handled these r things? s A Not that I recall. s Q Was there ever any occasion in which any of your g: other supervisors criticized the manner in which se t you handled these things?

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A To me directly? Y u Q Yes, sir. t c is A No, sir. I r4 is MR. SCHUIJ1AN: Can we clarify that? Are .i is you referring to Mr. Swayze in private or as part I s' of the quality control or QA group? is MR. BROWN: Well. I wasn't irawing any u distinction. I thought he was part 01 the quality [ to t a control group, and I was asking whether he was ever i-zi criticized by his superiors with respe ct to the 't ) 22 manner in which he conducted his work. j 23 MR. SCHUUfAN: Do you understand the tii 24 general nature of the question? .;{ s, 25 TIIE WITNESS: Hight. I.vas never h h. En Y 3 A "=1 ; j, ROM;., O.. < - W.u n. r 9 p. . y ;. A -.f .!I, %.s(;h. /

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4 i 'l .W 72 i i @.h A criticized. I was questioned on occasion by my Mi %']~ 3-up by Construction. I would explain my position supervisors over an incident that would be brought .t

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4 x A and that would be the end of it. .R[s, BY HR. BROWN: - o. ? f 's Q All right. And was Mr. IIammons one of your super- .a y visors? vj. gg A Yes, sir. G7e Q Did Mr. Hammons ever criticize anything in regard i; ..h ~ +de to the manner in which you performed your servicos? u: %?n A Not to me. fja. i.Y a Q vour testimony is, then, that you were never told a.w a to oe more diplomatic? ^'l u A No, sir. v..n l " 'f u Q And you were never told that you had a big mouth? m A No, sir. Excuse me. By my supervisory personnel? e,E $l:' w Q Yes, sir. ,r .m A Or by construction supe rvisory personnol? , m Q By your supervisory personnel. a A Not that I can recall. .l 2: Q How' about construction supervisors? n A Sir? Q By construction supervisors. n 5 H A They were constantly making all kinds of comments. r ,t a Q Who? L.' 3 3 h w ' ~~ J 3.5 *)I('t i 1 &*g. \\ <46s. lg / g-L@W.. WEN / / .,y f.G g s s y '\\l

~ - - - ~ ~ ~ ~ -M. 73 a._. f$t A Jim Salvitti, Jim Honroe, Quinten Lindsay, Albert .p ,.'.;'h a Fraley, David Howie. 3.l a Q Salvitti, Nonroe. Who was the next one? .opia A Quinten Lindsay. i s 3/4.- i i %.p.+s l q Who else? 'V s A Albert Fraley, David Howie, Russ Sanford, who was i i Y~ ~ Afp S'.' ' construction engineering. l i Y.x e Q All right. gj's A I don't recall all the foremen over the period of a g.- . g ',a two and a, half years, but -- y g4f; a Q All of these poople spoke to you about the manner 4 :. l Qu in which you handled your inspections? t $2. ' 3.m A Yes, sir. csYu Q Did you do anything to meet their objections? ~' -{ m A I just continued my inspection in the same manner p.,. .O u I had. fa Q You continued your same manner of relating to .c= li . f. m these people? ~~; t j:. s A No, I continued my inspections in the same manner j .. :.Qm a I had in the past. f,' M Q Okay. But did you do anything to adjust the manner li .,4 in which you would discuss these things with them, i ,a u in the light of the criticisms they were making to )l, .. 's e. t !"'f' N you,of the manner in which you did that? t I. m MR. SCHARMEN: Are we speaking about .r i f l 4.iM ... _,, ~ ...? ' i. - Y*,' [.,. d _[. '.ph- ~ ? .4. k.. ? [g.~- ~ 0,,, f 4 t t z.: -]- s yk. l-W.m-I ~ .... s.c - ,' h %. p 'k ',". !* c ' !

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w F.,3 matter of personalities, yes, sir.

l $3;. l Nfe MR. SCHAIBIEN: All right. Did you under-I 5 C l' fs' stand him to mean that? up 3ie THE WITNESS: I believe I do. 4 M. ciy BY HR. BROWN: . 2s s Q As I understand your testimony, you are saying l Me 4 that your QA-QC supervisors never discussed with e ,V i Q[4,is you anything about the manner in which you con-4. 9.'. : n A ducted yourself in relating to the construction "*I f *

• ll, Mrs 4

people? %p.. Te A I don't recall. b% y}.'M Q I believe you said also that all of these construc- 's tion people that you have named did speak to you ' ',' s A about the manner in which you conducted your ' 'e a relations with them. m A That isn't the way I understood the question. ~ i " : :s Q Well --

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A I thought you stated in the manner in which we 7,y 9a performed our inspect' ions. t M. E.. a Q All right. Now that you understand my question. l a would you respond as to who. if anyone, spoke to , 'uld a you about the manner in which you handled your -k a relationships with the construction people? m ).. + I '$$e. i

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75 '.*g7 i k? ):je,s.A The manner -- Q 3, Your mannerisms, your manner of speech or what you Ig j., 3 would do or how you would relate to these people, these human beings. ~. I is' Did any of theit ever criticize your manner, i e 1 (g' your mannerisms, the way you conducted yourself? y' A I am getting a little confused between mannerisms lr " g' and inspections, how we performed the inspections. Q Your big mouth, did they ever accuse you of having 'be. {+n a big mouth? j dn' A I can't remember the words used specifically. { ~~ u Q Well, that's why I wanted to get something into a Di.'. t $s little more general language. Did these people t %f u ever criticize the manner in which you dealt with [ t s' n them? Y.:.

• l w

A Not directly. n Q No one spoke to you about that? N m A No. W}i j: w Q Either any of your own QA-QC supervisors or any of b t - these construction supervisors? l n,q a

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.43,^ 2: MR. SCilUll!AN: I believe he already 4'p$ ? - 6 i, a stated that it had occurred in Construction. i .n MR. BROWN: Well, I thought so. Then he Y I' 4 24 said he didn't understand my question. 4. '. q ? s TIIE WITNESS: I thought you meant in the i I

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L p. I [ 7G 5. $'s manner in which we inspected, was that changed. d63 MR. SCIIUI11AN: No. ,.y: 3 TIIE WITNESS: I didn 't understand. !l [o 4 MIt. BROWN: He just didn't understand the f A question so I am coming back. Now that he under- .fe '7.c {t[6 stands it, I am repeating the question. ) 'tyAt MR. SC11U11 TAN: I think you better repeat EUC l 'Ye it again, i. .f; ~ 9e BY MR. BROWN: + k,.,ie Q Did any of the construction supervisors speak to y' ~ n-you about the manner in which you conducted your i yi.'s relations with these construction supervisors? MO %:e A Would you consider manner being inspecting in too ew } 3du slow a fashion to suit their needs? i d.7 1 - r.- ,i <[,4 m Q Well, if that's the only thing they ever discussed q %,.i 1 r Q with you, yes. .+j m g;i[W Many occasions they would state that we were too ' y,y t.- slow and we weren't performing the inspections in es 4 .j Y' lu a fast enough manner. [. ,KKm Q They never criticized you for having a loud mouth? s-%a A Not that I recall. W i .y l;g a Q Or being arrogant? { g. 6 a ,&n A It was basically " mother fucker." I believe that 8 i ,g.. j g .'31 2 was Mr. Salvitti's favorite terminology. I' _ g} m j.;; Q All right. [ $J oe

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77 .;, p. ,']s A I don't remember anything along the lines of big U n'

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mouth. It was usually a little more vicious than ' :< :x. l'f' s that. i I pfa Q All right. How did 1tr. Monroc express himself? ' c. ,l ~ ( . ;. o A I had very little direct contact with Mr. Monroe k' f ~ A outside of a concrete pour would be late because of ..{, .d!$p our findings. It was having a serious impact on iES: 3[s Q. the schedule. The inspector, myself, my boss, ht.Y ' ge usually, his boss, Mr. Gardner, would be called into lI x, }.[a a meeting with Construction opposites, and it's ] f.7 - ij 1a normally where Mr. Monroe would be, would become i .f.'4 s .?f'[a 1 involved in it. l m'f n I can remember on occasion that he spolte 2 d, u to me that he was fed up with my nitpicking shit. ".( w And that was a favorite term that he used. i, It u Q Mr. Salvitti? d:3 u A This is Monroe. <c.,. a Q Monroe. All right. Anybody else talk to you like if

• 10 l

(A.;f -b. ' m that? ttf ' s A The list of people I read off to you, on different l W~ i is. 25 occasions all of them would use verbal abuse. Id i) h?. - n Q From the time you went out there you had this h t-n problem with all of these people, right? .{ w.. i@.s-i, m A Correct. "M a Q Did all of the QA-QC inspectors have that problem? l r{. l Y. Qu. ,y tro.. 3 e C Q .(. W l J.. {. n - + w /= +: s p y,. p / n n.. - .A,.q j *' r ' lf a v - ?M. Q -M. ' ,,[ '#,, j/ 1 f m~ \\g., s.- \\ '. \\.. A

r}.7 78 ..g._ Jl;s A The ones that I worked with did. Q3 Q Is that the people on this chart you have made, i c3 Exhibit No. 2? "dpa A Yes, sir. l v. '7[s Q All of those people had that problem? [' 1 We A Well, some of them might not have had such a severe g: t W7 problem vith it because -- e Q Do you have any idea why you had a more severe j 9,. ll l .M;' e problem than the others? '} 'is: j,$, e A I was the lead inspector. 4,* g' n Q There were other lead inspectors, weren't there?

• hI e A

When they appointed Mr. Singleton an a lead. That ..y.. 4; a was the only other one in the Civil Department. I f7 w Q Did he have that kind of problem? y .>i e A To my knowledge he did. He spoke to me about it .u quite of ten. s tu Q That they were using harassment? .'1 g-4 A Ye s. .q' u Q Yerbal abuse? t

p a A

Yes. j '[. n Q And attempts to discredit hin? 4' k ,' r -.. :..,, a A Yes. i -.;.' a Q Okay. Did you do anything to deal with this Il \\l

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as personality problem you were having with these a.4 I a peop7.e? I / a (',I k

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8 1 70 i i 's A I don't believe 1 was having a personality problem. s ~ Q I see. You didn't recognize that there was a .l i s s . "),3 problem causing this harassment, verbal abuse and -0 j " 74 attempt to discredit which was directed at you? 3 1ll:. 'i 1"; 6 & The problem was -- J M i; )

e llR. SCilUIIIAN

Would you rephrase that i

t question, please? )[2. a i HR. BROWH: Would you read the question? r ? >. l .Eo. '4 The preceding answer and then the question. }' .cr i su X:cn " )'. -j,j)n (The last answer and ques' tion were read { 1 (.lfs by the reporter.) 8 kJ.' M .y; ly.J# A I don't consider it a personality problem. The d U In problem was the majority of these individuals in 'a > ;: j, { l4 Construction could not build whatever they were y i .iG;f te responsible to build and meet specifications with-33 g 1 q,' j"# out us instructing them as to what was wroag. e, [i.f:

• And on many occasions four and five times 1

i -m we would have to reinspect and the same problem we c ~. j? fi cited originally, it had still not been corrected. 3. Tao.: a BY MR. BROWN: af.;c a Q I see. These people that you are referring to did Nl7, '

• • N not know how to follow the plans and specificationr"

~5 A It was very obvious to us. .{, 3 ?R.- i 'W: ^ ' %.* m ' g iL f i s.,.s..,. s0 l. '*'e ,;Q _ * .E h.?! AI ~ 1. '.. l n,w. - J0. j f u n.~.w e... l . y~ o.m

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Q, a 9W r,- 30 L f r, i Q I sec. [L,' i A If we could iind those problems, we could never a understand why they couldn't. They worhed under I',: ( '; i >; a the same criteria. L, e. [" s Q Hr. Swayze, are you the only one of the quality t.:, control people who those who criticized your work j ~. e 2 succeeded in running of f? [, ( t 2 s A Could you repeat the question, please? ('. e Q Are you the only one of the quality control ('- inspectors that those that you have described as so criticizing your work were successful in running si i e i2 off? s2 A No, sir. F is Q Who elce? h is A Jack Duhe. I ~. is Q Any more? s I i2 A Bill Lazcar. is Q Ilow do you spell that?

g is A

L-a e -a-r, I be lieve. e - 2e Q Who else? I 2: A Rocky Crisp. u. f 5 22 Q Ilow do you spell that? L h 22 A C -r-i-s -p. V ( 24 Q All right. Who else? L as A George Wilson. [ . g' [' q .~..

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Yes, sir. A*A c,;:,3 Q Anyone elr.c? ~; rg. I can't remember at this time the rest of the namec .,gi e A [a but basically every individual in the QC Department a that icit the job site left because of the conditio s 'r that were very evident. (s(;'/s Q Well, now, were these people discharged? o. W.e A None of the people on the list I just gave you, I Ml 0A ) . gu believe, was discharged. They all resigned. es Q Did they resign under fire? ' 's., o A Well, all of them that I talked to stated that they ,o f 83 were leaving because they weren't going to work J.9 ', 'j u under those type of conditions, and it didn't a[. appear that Drown & Root management was going to .[. s 9 ((,. is do anything to change them. Ui.; et Q Now, I guess you must be familiar with the regula- .o. 'I. # tions of the Nuclear Regulatory Commission witt. I c ..3 .. v.'i.' m respect to quality control on nuclear power plantc? .",y,. (ry as A Yes, sir. ..,I) 3 Q And part of your duties were to be thoroughly ~.... familiar with all of those regulations? ~7,a

• JB A

Yes, sir. [as Q Do those regulations require the reporting to the 73 a Nuclear Regulatory Commission of any discrepancies I ?2, 1 9 n,NiOb,. em }ijb-i

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,, T 82 4. e. H 't or deficiencies in the work perfunned? t ~ 4}'f,i A I would have to review the booklet again. It's .t.. C been a while since I have reviewed one of them. J Q What is your understanding about that? 6

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A I believe you are obligated to. e ~ fh..a Q Okay, llave you ever had occasion to report to the s 5.S*h Nuclear Regulatory Commission any discrepancy or ( c, &o 9,me' deficiency on the South Texas Project? 8 IM A Yes, I have, as far as my termination. M I:? e Q Your termination? ?M. yl'.'st A Yes, sir. .Q"a Q Besides your termination, anything else? 'd q;...f,.r o A I have spoken to them on the job site. gne Q Did you report to them any deficiency? if,), 's A I can't recall if I -- in what manner do you mean?

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}{as Directly called them? %v., w Q You said as a quality control inspector you are [a required by the regulations of the Nuclear .(. W[e Regulatory Commission to report to the N. R. C. any $, f t's discrepancy or deficiency that you have knowledge a t ? P 3s of. . a. : - y. 41 m A I would have to review the book again. I don't

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.f;a know if it specifically states the individual shall ~ ? r. ~ V ' as report to them or the individual shall report it. ,.? ". * *,_ a We were always instructed to report any .g a fI .Q.a. ~?M4 : v i J.g. [ w j%WN' Wl5?? . g :.; ; i

114 i Tl!E WITNESS: No. No, sir. 3 BY 11R. BROUN: '.T ?, 3 Q All right. I'escribe this occasion. Is A A gentleman f or Prescon Corporation, which was s handling the post tensioning on the job, was required to submit his inspection report to QC e t. p prior to our pour card sign-off. ~ t This gentleman had a bad habit of sleep-r e e ing until 11:00 and 12:00 on occasion when the pour was scheduled to go at 8:00. w a And this one occasion, as a result of n it them not being able to find this gentleman, the pour was delayed for three or four hours while is they looked for him. is is And Fir. Fraley stated to me that I was is chicken shit for holding up a pour of that magni-tude because this gentleman hadn't submitted his er is report. That they could always get the report is from him. L' {l 2a Q What did you say? e 2: A I just stated that it violates procedures and that 22 we can't sign the pour without the documentation b 23 being proper. } 24 Q And what did he say? rs A If I remember, e.t that time he walked off. b s k r, ,p 9, i C07: - Lkd6ol 3 g U.. , g APR a:.. 3, 'l

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m i' 115 y .p, t "i j g' Q All right. And this is what you describe as verbal s, 78 abuse? V, 77, 1 Yes, sir. s f ,Q Is that what you describe as intimidation? a s 1 j .ig -A Yes, sir. w: .yg Q And harassment? Si A Yes, sir. 3 .e Q All right. s A I wouldn't consider doing your job as chicken shit. 1 i yw MR. BROWN: Would you read that back for 3r y,g :: me, please? 6e "el,f u (Whereupon, the last answer was read by .;- u the reporter.) ,w BY MR. BROWN: ./ Q This is what you are saying or what he said? l.n; er ,'.' u A This is what I just said. "m Q Oh. You are not quoting him? .w ! a A No, sir. 6 @c $ 'I 2 Q Okay. On this occasion did he attempt to discredit if

1. / n you?

N i L n A Sir? i-24 Q Did he attempt to discredit you? I'a A Yes, sir, he took the matter up with Mr. Schreeder. I 9 kh 1 'Ay

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l' ' 9 * .38 3 k. 116 a y ,' ' [A QI Q And what did Mr. Schreeder do? 't h - 52 48i. A Hr. Schreeder informed him until such time as the r.. ,,a proper paperwork was submitted that we would not sign the pour. [ d$f 4 Q Okay. Go ahead. Was there another occasion when 7.' '5 l31 e he used verbal abuse? a { l. 7,. A Over a period of two weeks, I would say, secondary j

1. g shield wall, Unit 1 containment building, we made

) 'i 8 them tear all the forms down. f (gt n ,f,n,.W Q We? "i [N A We -- well, I did. I informed them that I wouldn't s '{W allow the pour card to be signed until the forms W were removed and the discrepancies corrected. (M Q What were the discrepancies? rw ff# A A multitude of discrepancies: rebar missing rebar i [4 out of tolerance, np Q llow far out of tolerance? kW A Out of the prescribed tolerance. ,c

• 28 Q

liow far? ti+. A Well, the bars that were missing were really far FM out. ~ M ', a Q You mentioned missing, and then you mentioned some g' B out of tolerance. .,g)8 A Yes, sir. E::8 y, Q !!ow far were those that were out of tolerance. hu.y { i.. 4 c_ L,.; f r. ,EU ' W.. _ :?; $ \\ ~.

P 117 i i far were they out? l A I don't recall specifically. Some several inches, 3 some a quarter of an inch. Q Is this the occasion you described in your petition 1 r s A I believe that it is. s Q When did that occur? A I believe it was early July,1978. s Q And is that the work that you say cost millions of a dollars? io A Yes, sir. n Q How did you ascertain that cost? x i A We were constantly infomed by llouston Lighting and is power management that every day's delay on the schec

4 ule would cost anywhere from $400,000 to $700,000.

l is Q Is that referring to the completion date of the f is plant? [ A They infomed us that any critical path pour that is was delayed, that as a result of that it delayed v is that building from being completed for a day. Q And is that because a delay of an item on the crit-no $r si ical path would cause a delay in completion of the h 22 plant? 23 A Would impact the rest of the plant, in that unit. 24 Q And cause a delay in the completion of the plant? {

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as A Yes, sir. 1 45. ' h??f @$~ kg: 1 6 a p-a-f. 2.

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.. ~ '.- 113 ' 'jg f,dMi Q And that 's the way they calculated the S400,000 to i e 1 + 4 q.v s/ {$j ' $700,000 a day? f w;i,nng That 's what we were inf omed -- t '1 - "?i% M:gfi Q Okay. 'ti l?4 5 A -- by 11ouston Lighting and Power. .: } Q l.5 .J, j9 Q Now, this information was not given to you in a j r f$ specific reference to the secondary shield wall, a '- 7 's was it? __ i). 7 . It was given to us in reference to almost any 93 A-4 " ;$ru .l;, os ' # 7e large pour that we would delay. p<;T

• 3*5!.,i

!,d. Q Yes, sir. Did someone make this statement to you se p

' Ik'SY-of the cost of the ruling that you made in discuss-

~ ajjg { ;:,,p. ing specifically the ruling on the secondary shield r y ctg wall? e .{ -lR Q:, A Mr. Salvitti mentioned the situation to me. 7 g :.'s 'g 4 All right. And he gave you this $400,000 to @)l',

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$700,000 figure? [,;"f[a A No, Mr. Salvitti stated that as a result of us d ~l a N demanding that the forms were removed that this 5 'U would cost millions of dollars and have a serious y ._i.._, impact on the completion of the Unit 1 containment ri J.js.. n building. l ~ Ih<(a Q Of that building? 5 p A Yes, sir. ui.d .m Q Not the whole plant? SW- ?hfE e v Q* {(ph ' i f. a .e E Z ,4 i, 1 6 '~ m l t

w. 1, t 119 I A Well, if you don't fluish that building you can't

+ 3 finish the rest of th-plant.

~ 'h - 3 ') Q Yes, but if you are delayed in completing that Jj ,. ('. s building, you may not necessarily be delayed in Zv:, completing the entire plant, isn't that true? ,,P t 'I e A I don't believe so. ), -f r -Q Do you think that if you delay completing that ? ',a building by a certain number of days that the entir e (.o plant is necessarily going to be delayed several, to the same number of days? Tn A Ve were informed that all internal portions of the i 1 .y[ is \\ t 9 reactor containment building, Unit 1, were on the .?..'I'u critical path schedule, and any delay in that .kJ building would result in a one day delay in com-is di s plet ion. i p.

{ is Q

Vell, do you know from your experience in construc-

• [ it tion that that doesn't necessarily follow, do you l

N t J is not? I Yb i$ A That 's true, t. [* 20 Q lluh? 2

30. ' 2:

A Yes, sir. 22 Q You do know that that does not necessarily follow? l

h. n A

Correct. .t' "K 24 Q O kay. j.f a A Not in all instances. l s.. ') e ) ( [I . 'i? ~ i

l l 19 g 2 l CV I Q Okay. Do you 1:now wh ther the : pecific ruling D g't which you made on the secondary shield wall will ~ i

• s.

" E, ' s or will not cause a delay in the completion of the C - [, Tile' plant? l 2Cc fy 6 A I was told that it would. Q I say in your judgment will it? p 7 A In my judgment? h +- i' s Q Uh-huh. x ,e A I believe it will. 9;,

• Q

!!ow many days will the completion of the plant be 1 $st delayed? o W 3 u A I feel the secondary shield wall delayed it a cd u minimum of eight weeks. ' Q,'

1. ,~.1 u Q

And that it has -- you said a few minutes ago that EU i ,f.w is that doesn't necessarily follow from the fact that f re an item on the critical path is delayed. fc (_ it A Correct. k 's Q So what are the circumstances that lead you to the 9 ,, ' It opinion that in this particular instance it will ,a result in a delay in the final completion of the e j3: plant? 22 A It delayed all internal p'ortions above that eleva-n tion for eight weeks.

f. 'h 24 Q All right, sir. Now, explain to us why that does t

a not necessarily follow. 7 't k[ - i O t I b; 3 l i i e

l 4 121 0; d.. I A Sir? dW 7.,0 > : 2 Q You said earlier that t does not necessarily follov , (h-j.) a that if there is a delay in an item in the critica1 A r4. f;X,' path that there will be necessarily a corresponding r,c, g o (M-s delay in the completion of the plant. i dEd 4 A That's true. p.,, e j ,M Q All right. Why not? 1 f. \\ rQ. s A Sir? %f }Q s Q Why not? [ ~ A They might have their manpower concentrated in to g.; n another area. s, ll' or Q Okay. And they can make up delays, can't they? 'h,,,[ is [g) *, A And they can make up that delay. .f < ($'if 14 Q All right. Now, why is it your opinion that it lp is will not be possible to make up delays in this E a.i.j is particular instance? 3 -, 17 A They were already many months behind when we were d.. is informed in early '78 that all attention would be j is placed on the Unit 1 containment building to 20 complete it in order to set the-reactor vessel L'2 2i before Christmas of '78. As a result of the EV. ' (;\\. 22 secondary shield wall, they weren't able to reach (7 ,.$ 23 this point in time. 7N g,"; 24 Q But that 's a long way f rom being the last thing to $.~ly' as be done in completion of the plant, isn't it? I(#; '*6 - r:C P. f;d "'!*f bn dL.Yy, c.-,. N:' l Tf .Q i l )

r u. 122 4 ' I A Correct. 3 Q Now, why is it that ou think it will not be possi-3 ble to make up that delay in the completion of the ~ 's plant? ,L y 'j. - s A Based on the activity on the job site. i s ,' '~ Q What activity do you base that opinion on? .s ) .,7 A The observations, the number of discrepancies. . }' [i,' s Q Well, now, you are talking about some other things }.)e that would have a bearing on it. ',' $$ m ( A If the work performance is still following the same u.- a}? is type of quality, let's say, as during my two and a half years on the project', they continually drop l

c

'f. is behind schedule. is Q All right. Then it is your testimony that in your i.i n is opinion as an experienced construction man, the ~ is fact that there was a two-week delay in the secon-f 17 dary shield wall as a result of your inspection t-is turndown, the completion date of the entire plant l k is will be correspondingly delayed for two weeks, is , f.y? m that what you are saying? s. .N!? 2i MR. SCHULMAN: Did he testify that there e5h ? 4t; n was a two-week delay? . 1;b R n BY HR. BROWN: \\ s.:. {1, u Q Did you not? g, yj a A I believe I stated eight-week delay. 1.b'i,. i }& * ^ q',e 'l 'QV -e%. +.. CCy 2 ,e I l 'I l l 4 --.-rp

1p;er-123 V:< i Q Eight-week delay? i.f, - ~ 3 A Yes, sir. i di 3 Q I thought you said two. Excuse me. All right. Then substitute eight for two' in that question. r 4 ? s A Yes, sir. ' 5.r 7 Q That is your testimony?

• ~ }f e

'( :4 A Yes, sir. R*, 'J! s Q Okay. Now, is there another instance of verbal is -, y,, abuse by Mr. Fraley? What was it Mr. Fraley said on this . m 1 yj,. n occasion? s .[.i. u A The secondary shield wall situation? .rT, n Q Yeah, uh-huh. i4 A When I first informed Mr. Howie, I believe, a t. 3. is general foreman, of the magnitude of the discrep-ancies in the secondary shield wall, he called

s is Mr. Fraley to our office and informed Mr. Fraley r

n r- $:k is that the forms would have to come down. And on that occasion Mr. Fraley once again became abusive. ?.

{.

~ is Q What did he say? m jE' A I can't quote the exact words. Basically along 3 o ' f' the same lines, that they were tired of my chicken a ne[k u shit attitude, and "we are going to put a stop to Q this crap," and as customary, he would contact [L 24 4 as Mr. Salvitti. ti

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%.}lW:- 134 L .. !C '[ .a Q So you are testifying that ht. cade this statement, . yt*:, r jMt use those words again, in connection with the ^: Wa %ys secondary shield wall? C'* y M'ca.:h:$A, Yes, sir. ~ .h 4 g;g;m, s Q All right. Another instance. 2 >i h;b A I can't recall specifics, but through February and . l?ft up until the time of my termination in '78, it was h e fairly constant because there were many, many major 3 U 7d.'s pours that were delayed because of our findings, l 4 ?p' e and they would respond in basically the same manner. .g g

• Wn Q

O kay. Did you make any effort whatsoever to deal

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- 4 'J..2 with this problem,of relations with these people h[i. 4, 2 is whose work you were inspecting? a> Yu A On many occasions. ~ ;p* is Q What did you do? } -g;;,..is Well, I had discussions with my superiors, and A j[ ir everybody was in general concurrence that if anyone , is disagreed, not to become abusive or verbal, and ^,.. is just report the situation to your supervisor. ' I f,- f ~ ga Q llow would you respond? What kind of language would f.. SM.h 2: you use when people used language that way to you? wd i 4 22 A I wouldn't cuss them. u di 5,P 23 Q What would you say? HY! 24 A I would just normally state my position in the ,h & N matter.

47. -

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125 l7 - [, t - ..a jf (). You would turn the other cheek so to speak? ' ~lAN On many occasions d" ring '78 we would just walk e. ?[,off. That was the instructions to the inspectors. g,. 8 l / y ga *.5 '*1 14 ' And you would just not say anything that could .E W - - i J 8;',. P,,. fuel such a situation? l 7? {:9iA Not in an abusive manner. y.f l e4 j E .Qc Vr j% 7%s 'q'. Well, in any other kind of manner? .Af $ ->. m ]s J !e [A Not that I can recall. 1.: 1 2- 2 ,[ s -Q.Okay. .h a , or ; )5, is 'A We were too outnumbered to be abusive. - l W ]", (F -Q What do you mean by that? 'er s A Well, normally there would be a number of construc-tr 6 i ".'s tion personnel speaking to you in a hostile manner. C' ty. l) 's and it wasn't our job to become hostile. And it i .; :.::nf 'ign wouldn't be a very smart thing to do anyway based on the numbers. L. ge

• 7, $... 'er Q

What was your understanding of the specific nature $ j: die of the statements that you were accused of making? "E:g\\. o A Could you repeat that, please? ,4. c p Q What is your understanding of the specific nature v: p m i 'I M'.,in of the statements which you were accused of making? a z y. .n A My understanding of the statements -- j- ? 5dn MR. SCHUlMAN: Can I clarify that for il ' 'i j l J. / m him? 7 .g l: % lr Tya MR. BROWN: Okay, f q.Q V yj.t-5.NE5. Mt.k ' ,.:? - .y. I' l l

l .. - i A b (f...;;,. 7-a7-n t (.. BrowncrRoot.tnc. INTEROFFICE MEMO g TO: All QA/QC Personnel DATE: July 27, 1977 FRm T. P. Cardner JOB No: 35-1197 $UBJECT: Construction / Quality Assurance Interfacing Recently we experienced an unfortunate incident in which one of our people was hurt. This occurred during a confrontation between a craf t concrete foreman and a Civil inspector over the support of a concrete pump slickline. Heated words were ex-changed and the craft foreman grabbed the inspector's shirt and forced him down on the reinforcing mat. The concrete foreman no longer works on the job and the in-spector has now returned to work. As a result, an extensive investigation was conducted by B&R into the matter. In addition, the Nuclear Regulatory Commission i became involved in a separate investigation of the insLdent. CD It was discovered during both investigations that thert existed an inordinate amount C of f riction between the Construction Concrete craf t and Civil QC. The NRC described the friction as a two-way street and 'bota groups were at fault for the friction. Our 19 main concern and the NRC's is inspector intimidation and whether because of intimids-tion that the inspectors would overlook quality aspects of the job. It was determined e 1 through interviews with the inspectors that they do not accept any unacceptable con-ccionM11 owed to contim4e, however, it is felt that it could 1 g-- ~. dicio,gsv. If tive, f r(?"tfiWo'r'.ki rg .,o-.. C ' [ e. T.. W J.( etf det "'t6iuTitty d.... g a s.... The steps that follows have been*taken to eliminate the friction between the two groups: i v* 1. Requiring all personnel (Construction and QA/QC) to assume a professional b. and businesslike approach when in contact with each other. CD 2. If it is apparent that either party is, becoming angry or beligerent in his attitude the other party shall immediately leave the area and report the C problem to his supervisor. The supervisor shall icaediately report the in-cident to the Site QC Supervisor'ot the Project QA Hanager. 3. Explain' to both groups what each others responsibilities are, i.e., Construc-tion is responsible for providing production, meeting schedules, and maintain-ing quality; QA/QC is responsible for ensuring quality is maintained and is obligated to report any deficiencies discovered during construction for proper disposition. 4. Stressing that whatever the circumstances, physical contact or verbal abuse is never a solution and shall not be condoned. The following practical considerations will be found helpful in maintaining a profes-sional attitude on your part and in securing and maintaining a working relationship with interfacing organizations and individuals: 1. Attempt to tell Construc, tion when they have donc a good job. A continuous negative approach tends to precipitate a negative attitude. \\ tA ,P CO D T-\\ y .L":.:n T APR ,1.,,a > - ~ ec Q % of ce f Decth;a g;m s ti-- s. R(. Il_ ; \\ : '- - EXHIBIT 4 7__

y y Brown (JRoct.!nc. ) 1 m'. 2. The approach to problems or discrepancies should be with the attitude i that it is a 8&R problem, not a Construction Engineering, and/or QA problem. As such, it is a shared concern. Use of the word, "WE", will La found helpful in promoting this attitude. 3. Try to avoid an impression of arrogance. The person (s) with whom you are dealing should be assumed to be competent and in any case is entitled to his own dignity as a human being. Talking down to him will not contribute I to the problem solution. Use of the words, "MR.", "PLEASE", and "THANK YOU", as appropriate,will assist you in this effort. Use of such words does not' detract from your own position. 4. Try to take advantage of any opportunity to improve your own technical com-potence. All of the above items shall be used as guidelines fo'. all QA/QC personnel in their C. association with Construction or any interfacing organization. II: O 1..... p. --. --=m }misf-Nha} tty } O, w n...,, T.,P/ Cardner . -/ J ~2. s '. j=ct QA.gnge g, j STP P TPC/ TBS /cim

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' 's 'm ; s % ces P. J. Karnoski N ~* N C. L. Crane l J. R. Honroe O R. A. Sanford o S. A. Viaclovsky (HL&P) F. D. Asbeck (HLLP) All QA/QC Personnel \\ FILE: -A450Q - General O I i }b 2 e-l l l {&W 8 Y% N p;.c H

~~% W IOC. ~. ' ' > 5 ..JUAllTY ASSURARCE DEPAR7 TRIP REPORT PROJECT: 62///r TotaS JOB NO.:CfCg2/ DAT E: 8/5/77 PAGE / OF PLACE VISITED: '5ca//i Texas Ca>3th c4m Ei/. DATE OF VISIT: OBJECT OF VISIT: Oc/c/m/48. C3#st af D OC //8. 82 E COPIES TO: G.R0,/erman ,' ACCOMPANIED BY: 8../. ~8s/r7Celia gj. y m,34,- "C//.comon PREPARED BY: d/d//cret-- y IM sd ofin/eWiew.s were eindsdd dowry He wede */ Ju& /f, /977. Ild NrJl.9) of is/emew.s ear caduckd a /de /hnder Ofr9ca by Nts nt/er en.My /Epd /9.~Tk acmd.se/ of m/ertiews was cadutd af Mr. Ts/rsaka vi,d Mu wnfer an July zo. th castruelior s,f ly Rans4s s&d&J t /ksa ideme.ed me nad. a u G/ Amu s,d add manne-m on honeden/ 6 AJp As xister de/e,mim tk ce%. ,r. or /4 SEamcy. Au inkwe,ved agua/J m/ /seir reimde Ix. - cens derd at_es cedicisms based a /ird lo'd 4J n poss<d/e weake.s n ik amusas/ syskar sweanky 4,.dw ara /iphr,, M a a 1.5.~.. :W :; Mide offr:e m/paa wee a E,&:.-: R f W R re lee, Senue pajad Spiuer -Sah(y (862) Wo k l%

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t i ,,,o k-- k-Il w sk epainu J Ps. 7?fuccha and as wdz rA d fic rewh ef ike alemead apu ciczfy wh v% cordwens ef //n ta schreedei a ca houd m Ge. M. &-03ses detd j 14 22,197z l 7 Esc.L//bje-thebi cmssde 4h 8 n M m a N I g i a r: o M F% 0 ~" U1 0 4 y saQ IE 3 qua ea g ~~ 1

2LUUg,ag allig X.. l,UWCT l 0&I.hlly. }w J s' 0 ~- ..e 110LI: T El'.ENIOr vi f.tt tJU TCS Coni ESPO.*;DrNCE v s.y, . PROJECT MANACLH l; Lit!AL touMUE H Hl.- 10 7 0 8 -' t w,-h echi f totJ, OEPT./DIVitlON PPECC/!!D ioxCL- *" t h Te m P ro i cc t DATE OF CAlt.- lO/19/ 70 n ficiency on con tainment Voids - Brown C Root Recommendati p,.r.n e r 3 bl e g gy_ e w(R PAR TICIPANTS:,UjjEg7$fUcu SUSJECT FILE NUf.101RS: PRIMAftY V AEin Pete Jordan - Brown & Root f SECONDAnY: ~ l l \\ PAGE 1 OF 1 Pete called to infohm me that DER's Incident Review Conani t tee had determined that the voids in the reactor containt:ent of Unit 1-were reportable to the !!RC under 10 CPR 50.55(e). First, they determined that the structural integrity was compromit.ed and that the containnent as-built could not meet the load criteria for which it w0s designed. There was also speculation that the contiamnent polar "cranc.could fail in service. Second, BER attributed the incident to a deficiency in construction and a breakdown in QA. Pete qualified the report by explaining that it was HER's opinion that the f ailure of 'the po.lar cranc uculd have occurred during the lift of t he id7 durin. conctruction anc tneref ore, the deficirney could not r i have remained unco;'rected. lie al:,o pointed out that the deficiency could have been detected during pre-operational containracnt structural t e:. t i ng. I exp1'ained to Pete that the words in 50.LS(e)(1): ...ucre it to have remained uncorrected...'?, were not meant to be applicable to this line, of reasonirig. BER has used this approach on prior incidents und it,was rejected at that tinae by the !!LEP Incident Revieu Con.rai t t ee. Pete also pointed out that these incidents were discovered due to she diligence and competence of the QA/QC inspector:;. LRJ/tll { l ec: 11RC Distribution ~ jff .[h J~). DR0Wil a B0@' v ~ oci w ! s'! ?- sT$G. 804 C l 'e 0 l'k Q f \\ t-p o G JP ,ecxtra 4$80)Y vem P APR

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_ Brown & Root Construction l 3.punenast omota no. a _2 l - 3/A e occumes 1 v.o6arso a a w. r a n E.n a* w s ovat a sot Teesca tec= =o. 2-C-02-1-C-1027-8 _& 2-C-02-7-C-10?7-2 6 sc"* =c. 7A010C$02a-c

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"*C' F.og sCasP rio8s o* of FTc.18.cv Voids have beed discovered in concrete behind the RCS I and R

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from El. -11'3" to 150'0" in RC5 I and El. -11'-3" to 47'0" in RC W correspondence ST-3R-HL-24846, Phase III, IV, and V. Reference I the area, and, location of verification holes (Ref. TRIA's 1-C-3661The extent of the voids.in {' See attached 27 drawings identifying results of the investigation. 4387, and 2-C-4391 toe.+ RC3 1 6 fi 1-C-3985

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a. oist aisutiom M. H. Smith

D. W. Janecke L. D. Wilson C. L. Parkey R. A. Nie ann . W. M. Noye

1. V. Peverley T. D. Stanley P. J. Bulten A. S. Coewey (2)

Constr. -DCC (2) D. B. Shumway File: AOSCQM --jy N c:, p gocgT". Y ' ust"'sB0 7 ~~ 4-t Ng a.swi CfC hhl J l. Ib 4 XHIBIT 7 m

-. r g 1 Nun $ ([dEk::y..[ / h SOUTH TEXAS Pi!OJECT c-08D _2 8tEUUEST DATE J NEED DATE FIELD HEQUEST FOR ENGINEERING ACTION 4-5-78 4-5-78 e occuMsNr NUMuEn s ooCuMENT is TLE 1-C-1023-8 RCB-1. Containaarnt Shell.- Developed Elev. Sheet 1 of 4 6DEscusPilON 'd There are two voids observed at the Construction joints behind the expanded metal at the personnel air lock. The locations of the voids are as shcwn in the attached sketch. apCEIVEy r I 4P4 07 iFd " *COM8 PPc APR 71978 l 'huTc$s~$lOnci "" %Un i V I a nECoMMENoto osseo: rioN pe,4tg a lioles are pn.nament in the expanded nietal for grout to run through. The voids will g be filled with grout while the personnel air lock area is being grouted as per FREA 0-C-0694 dated 2-10-78. $8 , m e. 5' ",,,.. Q b G> o Y f***UI D k y 484G4.*4)$i C% $ ENCR ACTION nEQO SCONST. COST EFFECT 10 CONST. SCM&Dutt EFFECT 0 Yt$ h No hpg po h) YOWf fff A D A I une/ 2 LE E O Clif E F ENC, % N l / U s 12 ntCElvED DATE/ TIME 14 AsslGNE0 Ty DATE lb EET. COMP. DATE / 14 0ahro;iitoN O aoaCo=*caMaaC' i= ^eaaovals oaTE OoEviatioN OoCN O Ct AaiFiCATio= Oo'sar riove Oofurn A.,// / 17 DI5CWESs0N -6, n- /b~ as ml' '/ DPE 1 / // / / rue EPM .I /J' / VEh8FIER la[eposesables / QA (e appl.causel / Cu t N T...., 19 oCC ACTION FILE NO. hV XMTED BY I/ DATEsTIME 20 CONhinuCTION Auf Ho DEW DATE i p 21 CONST RuCTION COMPLE TE oATE 40fsNEH N$T. $UPV R (G E R con 5f. CHIEF ENGd.) pfy/L . _ -l- 'mL... 9 CCCVJTt- \\< Utu j APR 41980 > cmn ens te.my &.y 2::. :. a.-au -q. s Ay /_ 4 EXHIBIT 8 Df ?Q 7 9 io d oJLd1jU a

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/ J Brown 0 xcot,Inc. O. NONCONFORI.iANCE HCPORT S-C121911 OATE I2*II'*7E tJCitf;O-

s. uusani.* A nuu

4. us.i n t.o.

a.6 u..u x u.6ui e. hu Brown (. l'uot Construction h 2 N/A 4.uocu.iLui vioLArty ut v. PAhA&MU.PH b.o1Hf H HR4 HilcAliON ho. G. SCfM g,g y. NucLtAn _ S r.ee. 7A010C$0M F ".l. 3 CSI-1;15 _1. on scuellu:J ul u.I scarucs As a resul t the detailed investigation of the reactor containancut exterior chall vall pour CS 4 5, the honey-coiabing on the outer surface, the vialbic voids on clu-top surface < ?.hc internal voids behind the liner plate are evident an follows: I (Continued) i s S. Shah f/./4./,.;,;//.e g./ / /'# /

• • "0'"'"'

H. Crair/ R. joienson7' rinath- *12-5-78 13 g, ge a 9, 12-6-73 fv'uaRuud.Un e i4 i.Leonir.cCL ale ici.:.dLil' ir 6.m Tfh6Tuvif.Vi g j C. \\l. Vincen, e,:7 ff.WM y2 CD vts c!) tono us. rHGrQ5tu nr.ro;.litp

16. Actiuse AL$h'.htu lo; l'

J. R. Honr.ic DA1E DUE 1-2-79 utWor4K HLPAin X ust AS 13 ScnAP , ConMCilVC ACliotJ Defective arcas are to be repaired in accordance with llouston Engineering Technical itcf erence Documant No. 2C801CQ002, "RCB 1 Shell 1.if t 15. investigation and repair criterJ: No'te: Repair of lif t 15 wi11 not be required prior to pouring succccsive concrete lifts nhove trrnOYAk su.DAlk / a II"I,,s pa n. iis7v'stw a. AcenovAL tal. uAl t U. cpu l passijcN e*t.V4LU C /71. car 9t G~ t;l-lC-2 3 Ifff)Gtllllh' u /rs'/)R; ~'4TA'[t_ ' ~ 3ke7h I.i s.iv a, Ae s'nov AL 24.uAIL ~2.e gi rit2fdit'OI.*gt VU*.9 r~ ' sin e5/ A L 2 4 E M. M.,24,[u 1. YD'/dk .2 7. uA l4LVu rs c. *v*rituvt.L .d .AL .,a W 4t } 2:e. A's la t e d. dJ'e*HoV AL X~ 2% VLusi icAIlufd OsAiisraciony O u c.aissrt.cicar {h l i

30. Alue vkhit ecAllwN 3 4. o Al k 32.OA/QO VLHai dAllufe JJ. D A 6 '.

NOTII Ir.r,g7g ogg,gg gg,, ggj k Sh70TtL il hC y sL'.d 4. b LObuH L 3#.uAIL i C/heyg*a/.Qtro //.b N 7Fo y . 1;Evit.W 8 A MOVAL DATL; h /A b d A hc<* & c-co.y hh7h 'MWA h t w W.*lQ =]0 P h f /) fc W f#y,' w.grwrArm vXc&bAlMc? /' *2. ~7h. W'* "'W 'M W'N s f Vf/MtG Mi4W%%ygd. f<,W.C /s M44?sy.gs)? Mv;;wsN;;

n. pu.u.u.u i no..

A. l'. Ilo11. rook A. J. Cranr.cr A. S. coewy R. W. Peverley Constr. DCC 'IW# I.. IJ. Wilt.tna W. H. Hoye W. W. Ilu.lmn F J 1,': Au$0Q:t l NJ... e e-s9 tm -e. O [ p3 4N l e.gp'? } oop 9 3-- 9 m u c ~ Q l / mQQ Q l L., EXHIBIT 11 l l l ^ ^ ^-----*4 .m-m. .A. 2 m -a. a. .3 ..,,.g.,

i 1 I d h. 2 of 1:CR IS-Cl2198 i Iloney-combed areas of unknown size and cxtent at five different locations. (Exhib. A). ( Visible voids on the top surface of the pour'ncar the liner plate. l (Exhib. h). Internal voids behind the liner plate as determined by the sounding on the liner plate are idtntified on DWG. FSC-1409. m t. fubd d J). Xk) 1e . :, :\\t?Y ' , a@. a p*e, s..,, ah e s I I I i

wm Q U h s A preliminary inspection of the top surface of the concrete at' elevation 138'-0" re-vaaled veids in the following areas along the liner place. The forms have not been removed as of this date, hence the top surface of the concrete only can be observed. (1) At approximate azimuth 5' elevation 138'-0" N Length of void - 12" Vidth of void - 4" to 7h" Depth of void - 3'-0" to 5'-0" (2) At approximate azimuth 15* Length of void - 12" Wisich of void - 3" to 5" ^ Depth of void 10" to 14" (3) At approximate azimuth 16* -Length of void - 16" Width of void - 3" to 5" Depth of void - l'-0" to 3'-6" Concrete between vo:.d #2 and #3 is bad. Same needs to be removed Since the above voiets were observed, it was decidad to check for hollow sound, if I any, by tapping along'the liner place. Making use of the existing catwalk plat form around the liner at clovation 129'-0". we tsoped the liner plate. *The possibla void areas as indicat ed by M 11ow s'our.d are n.R * *..k : Refercnco Point Elevation Location 1. 326 129'-0" to 132'-0" Below bracket 2. 320* 130' 8'-3" towards 330 3. 335* 129'-0" to 132'-0" Below bracket 4. 330* 130'-0" to 132'-0" Belaw' bracket 5. 335' 131'-3" 2'-9" towards 34CT 6. 335' 132'-0" to 133'-0" 10'-0" to 13'-0" towards 350* 7. 350" 132'-0" to 133'-0" 2'-0" to 5'-0" towards 35G" 8. 350* 129'-0" to 131'-0" Delow bracket 9. 350* 130'-O to 131'-0" 2'-6" to 4'-0" towards 360* M O. 35(f 132'-6" to 133'-6" 6'-0" to 9'-0" towards 360* 11. 05* 132'-3" to 133'-0" 8'-0" to 9'-0" towards 360* 12. 05" 133'-S" to 134'-3" 6'-0" to 7'-0" towards 360* 13. 05* 134'-0" to 133'-O'5J) 4'-0" towards 360" 14. 05* 129'-0" to 132'-0" Balow bracket 15. 05* 131'-9" we 4'-0" to 5'-0" towards 10* 16. 0 $* 133'-6" to + d/-6" 10'-6" to 11'-6" towards 20 ,17. 20* 132'-6" 'J' h*' O,, 7'-0" to 8'-0" towards 05* 18. 20, 130'-6" 3'-6" to 4'-0" towards 05 8 19. 20* 129'-0" to 132'-0" Below bracket 20. 20* 131'-6" 6'-0" towards 35* 21. 2 0* ' 132'-6" to 133'-0" 9'-0" to 10'-0" towards 25' 22, 35* 133'-9" 3'-0" towards 20* 23. 35* 131'-0" 4'-0" to 6'-0" towards 20' 24. 35* 130'-0" 8'-0" to 9'-0" towards 50* 25. 50* 132'-0" 3'-0" to 7'-0" towards 35' O w G I D D" D 1 Lb g l l -l.

O 26.

• 5(.

130'-0" to 132'-0" At bracket 27. 65 129'-0" to 132'-0" Eclow bracket 28. 65* 132'-9" 7'-0" towards 80 29. 80* 129'-0" to 132'-0" Below bracket 30. 80* 130'-8" to 131'-6" Frota 80

• azimuth to 5'-0" towards 85 31, 80*

131'-6" to 133'-0" 6'-0" to 12'-0" towards 95* Sll

• 32.

95 129'-0" to 130'-0" 7'-O" towards 80* 2 i' 851~ 33. 95 131'-9" to 132'-6" 3'-6" towards 80* did 34 95* 129'-0" to 132'-0" Below bracket i' "'N 35. 95

• O.

131'-0" to 132'-0" 2'-6" to 3'-6" tow rds 100 ,e brack-36. 170 132'-0" to 133'-0" 9'-01*Ao,,12'-0" towards 185 50""" 37. 185* 132'-0" to 133'-0" 4'-3" to '6'-0"'towards 170-aracket 1 38. 185, cr =s 131'-6'ho.it s.* 3'-6" towards 170* 3 S kS * *' 39, 185 $ 129 '-S" to 130'-3""g 4'-3" to 6'-6" towards 200 40. 200*' s=a#A 133'-0" 8'-6"'towards 185* { 41. 200 O 130'-3" 7'-6" towards 185 i 42, 200* W 130'- 3" 3'-6" towards 185 43. 200* h 129'-0" to 132'-0" Beloe bracket 44 200* 131'-0" to 132'-0" 3'-8" to 5'-0" towards 215 45, 215* 129'-6" to 130'-6" 5'-0* to 12'-0" towards 200 46, 215*

• 131'-S" 3'-O ' to 6'-0" towards 200
• 47, 215*

O 129'-0" to 132'-0" Belov bracket 48. 215*

1. . d 131'-6" 3'-9 ' towards 230' 49.

230* 129'-0" to 132'-0" Beloir bracket ' 50. 230* @ 131'-6" 4'-0" towards 245 51, 245' @ 131'-6" 7'-0" towards 230' 52,

245, QC30'-3"to132'0" 3'0" to 5'-0" tov W a 53.

95 129'-0" to 134'-u" Lelow bracket 54. 245* 131'-0"- 1 3'-0" towards 260 55. 260* 130'-3" to 132'-0" 3'-0" to 5'-3" towards 245 56. 260* 134'-0" 2'-9' towards 245' 57. 260* 129'-0" to 132'-0" Below bracket 58. 260* 132'-0" 3'-0" towards 270* 59,

250, 131'-0" 7'-6*

cowa rde. 270 60.

275, 130'-6" to 132'-0" 7'-0" to 11'-0" towards 260, 61.

275 131'-6" 4'-0" toward:s 260* 62. 275 129'-0" to 132'-0" Below bracket 63.

275, 130'-0" to 131'-6" 3'-0" towards 230*

64.

290, 132'-6" 8'-0" towards 275 65.

290, 131'-6" 4'-0" towards 275 66.

290, 129'-0" to 132'-0" Uclow bracket l

67.

290, 131'-6" 4'-0" towards 275 68.

305.' 131'-9" 8'-6" to 9'-6" towards 290 ) 69. 305 129 '-0" to 132'-0" Below bracket 70. 305 131'-0" 2'-6" to 3'-6" towards 320 Since a proper scaffolding was not made availabic, it was not possible to investigate t up to tne top of the pour. the present Also, arrangements shculd be made to investigste belev from elevation 127'-0".in-place scaffold, ie. below cicvation 129'-0" since this pour ctarted { It should also be noted that this is only a preliminary repcrt and further investigation is required.to determine the actual extenir of the I voids. ---f.tbf..l.d B.N. Kesar E I, I r Q), C i i l p A g g =

e BrownJbt.!rc. [ =, 230 128'-0" 2'-0" towards 245 128'-0" 7'-0" to 10'-0" towards 215 128'-0" 12'-0" to 15'-0" towards 215 - 215 128'-6" 2'-0" towards 200* 128'-0" 5'-0" to 8'-0" towards 200* 200* 127'-3" Below bracket 128'-6" 2'-0" towards 215* 128'-0" 3'-0" to 8'-0" towaras 185' I 8 185 128'-;" 7'-0" towards 200* 128'-3" 5'-0" towards 200*# 128'-3" 2'-0" towards 200 127'-6" to 129'-0" Below bracket .128'-6" 5'-0" towards 170** 128'-0" 7' -0" towards 170 170' 128'-0" Below bracket j 95* '12 '-0" to 129'-0" Below bracket 127'-0" to 128'-0" 2'-0" to 5'-0" towards 105 -a 80 128'-0". 6'-0" to 7'-0".towards 65* 8 128'-6" . 8'-0" towards 65

• 128'-6"
• Below bracket 65 128'-6" Below bracket 127'-0" 4'-0" towards 80 127'-0" 5'-0" tow 2rds 80 The following areas from el. 127'-0" to 129'-0" could not be inspected due to obstruction.

1) From azimuth 20' to azimuth 50*

2) The, area in between 9'-0" from 335' towards 305* and l'-0" from 305* towarG 335.

O' & llG.fdk l$r4, B.N. Kesarinath = -D l ? e = '"l D D d DJLi e . A a l.

6 g s .. \\.. Speed Loiter. I , i To T. 11. Schrk h-r Frorn 9-a_ _ v4 winygy ee-A. 3. 15ru m at C-0.tG ubject ga.h.eleti ca I.nr* r*< e t i r i a 1 "i MESSAGE Da*

• "h" 15 2a.

Nrin.- the su-veillind of cadveldin ' activit ies, the follnuini' Jlserena :cies m:re obses %ese cadwold recorus were tilled out unproperiy. sor.as are inecon!cte tarvi cthers do :.ot 3 gree. Cadaald 4M:SD, 411122 n'id 30'!1'.3 s inw to be reicit s1 v :t tho Psn sh7un ag-buil t loc:ft cadwuld 35V423 ret'erenccs a NCa n.hica is not iucattituJ by a nur ber. Cadweld 46V91 and 4W/; thru 47V"'u do not indicato an ns-t.uilt <trawin? on caJt; eld inspection look. Cadweld !T.V24 in 1 listcJ as navine, wasatisfactory witness rurks tvithout any resolution or eorments in the restit section of the TC. Cm! weld 31V173 and others are duplicatoJ uith ti.o. tiff ** rent cidweld steg < lot nunuers and powder. los numbers..Tito remarks in the LC inJicato that thcy wuro checked 1 .. :rainst 'the"c.' e Mer r.ateg:L_ lee. 1 in addition. the nustar of each cadwold splico thich undergous final inspecti% Ly Civil ]

• 1. 1: r.ot Sai'i ' cn tered 1.1 t* u remrl.s sectlen of t'e FC u re-ulrel 1,y Cc?-1; 1.

,. 2.11. L i Production an.3/or sister test splices aro indicated as having been cut out and tho subs re isito t est reports are not filed'in tho CA vault. Sonc ov' these tests date as f.sr Mek as two txanths. Tno above discrenoncier. 'wcre noted frnn a tma.a_earm,line of cwtmlder fol..lerg ait11,$m repurtr. it is apparent tru.4 tho.nrant of proble.4 ittentific.i that a thorough re.icw ot cal c}d reenrJs is in order. Please tido annronrinu :.ction.md resnnnd on nr befuro Sointenber ;b.197a. d ,.ic-f

• 0" T\\.

M = IEPl.Y V Dato 19 - e c 4 O bU 7,..hn[meva.M*fPMdIUillmb6ta)my TU t. j g.... s P \\ occx:ra ,1 t.m \\;j D 'Y %( g,' t APR 4 ;980 ;> h m, y 9 9 D .Ig "I cracea zi. 3 L V bJ f,%q

• C ;

i D-V W EXHIBIT 12 i

j NvNCONFOL 4ANCE hlPO;.* j SOUTH TT XAS PROJECT 1/18/80 NCR NO. s.C3518 DATE c i 2.unir no@ i a ruacnast oncen s.o. i.oacanizatioN l lgg no. Brown & Root Construction _e oocu.ta r viosavao a s w. casacane i s on ta ion =risicar.om o 6 score 2A010CS028 C 2.5.4 l

• AS NOTED IN BLOCK #7 Q muc.6ean s.cascairvios os ossicit=c'
• 10CFR 50 App. B. Criteriun XVII

} Failure to furnish sufficient inspection reenrds which, as a minimum, identify the inspector or data recorder, the type of cbservation the results and the acceptability for the 93 cadwelds listed in Table I (ATTACH W). the cadwelds enumerated do not appear i nen inspection document in the vault. This 1sck of adequate documentation renders the l a quality of these cadwalds unacceptable anti /or indeterminate in violation of the above noted documents. l Yneir nn-Den 1 %9 No hnid eaes applied because cedwelds covered bv concrete ' e attuavaoer j jeoata e so caseanto m. ,$n < , in oats A. E. Schlaifer.t.Iffkxt.2821 1/17/80 l J. W ind 8'///# "*f' . /*/MN A is. cat a i ta. naronrants otriliaNcv tssur ro navian comunitesi sa. Arenowto sv,f C. T. WarnWu j f-j/.$ l C ves 60 mo as amoronto os5PL5ifioN e6. Action A55.GNto To U. D. Douelas oArt oue 2/6/80 connectivt actio, XXX Car #S-214 menons a Pain use Asis semap ,iJ. of Hka as e sn e mernuvaL te oATE 19 Co451 Auction REvi(W 3.~ &' PRoYAL 20 oAtt P

4. _..n.wi...

..ov.. .. o... ....o...-..i........ 25 Akt A4 Vite & AP9 Aow AL

26. D A T E

27. oA M(VILW. APPaoV AL JS oATL l

29 V&ReflCaficas O satisracionv O umsarissacroav ............c.,.o. ,,.o... ,, o._.... ic. i_ i..o... _ o....i.n. .s.o... .>._.......sm_. i i.... 1 r a p r0T hhp 0fmat= ion Bay as. oist nieutio" M. H. Smith R. A. Nie:1 ann D. W. Janecke O. L. Parkey A. S. CoeweyG L. D. Wilson R. W. Peverley Constr.DCC (2; W. M. Moye P. J. Bulten File : A0500. T. D. Stanley D. B. Shumway i

c....

WL*AE A marcr avsmv 4.v mmmmm.=m - urmum.z,ms-nra r umma. ,,4-, \\lb l g c::n-~ } .s gn C, b' e$ / m, - EXHIBIT 13 D**D

• D ~3 % A

_m o p 2.1 o e

De t. e;i v i e.A>L.lf E. NONC($N FO AM ANCE V'OR T SOU fH TEXAS PRO..CT 9,,,,

t. Q AGANi2 A fiOm l 2. UJh Y NQh (l3.PuaCHA5sOdCtRNO.

Brown & bot Coris truc tion f Q) N/A g s. Qr 4a.oistes.c Aracm hQ j6sco*E no, 4 oocust= r wiO6Arto a6v. pamacnavn 2 A010rS029 C 5.3.2/2.5.4 i N/A I c.uc r.cascnie riom Q* ospic.t=cv SIE ATTACIC"J.NTS ' Location iRCB #1, RCB #2. MEAB #1, MEAB #2, nta #1, HIB #2 No hold taes acolted lii.oast a neeQarto er e oara io. easeAato s, A. F. Schtsifer. Level II 2-28-83 A. J. Hammons @lu N u.--> 11-28 12.APPp vs v 13.0 ATE

14. ngpOATAgtg otPICiENCV t14NT TO AEvlin COMMITTE E 3 3 F' N '

C was La.Q C. . '. s n f x lb. PROFQi10 04VQ14 IBGN i6. ACliON A$$4GNto IC-U. D Douglas DAftove ht4-80 fitWORK REPain ust A$ as SCmAP Con AICTivt ACTaon 1 i L7.QIrii4 es&wite & A78RQwa6 18 QAft i9 cONsinvClaQN Advein & APPMQw AL 23 OAI 22 DAfi 23 inh 8hild'hu Atwitw a AP'dQv ah 24OAi 21.OTHER R(VIEW & APP AQV AL 2b Ah* A(vite & Ar#RQv A6 26 OATE 27 QA A E vite & A*vHQva6 24 OAI 23 v E Map sca t eQN O saTisP ACToav O v=sATiss ACroav 30 Ahs w t A*F.G A T eQN 31 OAI6 32 QAsOC w t Net sca r sQN 33 O A 3 34.QA REvitn & CLQsuME

35. O Af g 36 QTHE A at vita & CLosuMt.

g 37 oar '1 3a.ar4Anas

• .49 %.

,-e.W' ' h,\\o = 3wN}W *

• ff gs ',

g qs o G. I.. Pl[ key

39. OisT Risu TION D. W. Janecke M. H. Smith R. A. Niemann L. D. Vilson A. J. Cranger A. S. Coeusy G W. M. Moye R. W. Peverley Constr. OCC (;

T. D. Stanley A. L. Sch t.31 f e r File: A030QM a\\~ o,/ Q CCC.w.a o oo t= D o0 ,t T J} E APR 4 igg ) > 2o ,o 05:2 ef $3 C:::c ;,C h: hts 1 Lt.1:3 b'- Or - l EXHIBIT 14 l-

i l e A* TAC}Cc3T N NCR #S-(*'81. 1 Description of Deficiency: Attachment "A" lists a total of 19$6 cadwalds having deficiencies concerning lack of: 4-(JQ Material Traceability - *30 Deficiencies

• Some cadwalds have tore Ch*" *"* "IP* *I #*fi"I' A-(2) Unique cadweld LocatioE ~*192S Lefielencies A-(3) Record of Inspection ~ *46 Deficiencies A-(4) Duplicate Cadweld Nu= bur
• 11 Deficiencies Attachment "3" ' lists a total of 100 cadwelds which have been located but which had unreadable identification at time of locacian.

The deficiencies enumerated in Attachments "A" and "3" constitute violations of: A-fl): Paratresh 5.3.2.3 Documentation of Production Testing and Material Traceabilitv: The results of all tensile tests and otner pertinent data snall be documented. Traceability of all joints components, i.e., sleeves and filler cartridges, for each splice location shall be provided to permit investigation if, during production testing, a test failure is attributed to a particular material lot. 8 A-(2): Paraersoh 5.3.2 "...Tae location of 'all~ mechanical splices shall be docum*Med ice:luding raplace:ent splices at melt 1ccatia. and added splic.... p*emsted by the specifications. This requirement is independent of Section 3.3.2.S... A-{3): Parserach 2.5.4: 10CFRSC Aeo. 5, criterion X'/II Failure to furnish sufficient inspection records which, as a minimum, identify the inspector or data recorder, the type of observation, the results and the acceptability of the listed cadwelds. Required inspection to be covered by inspection records would include inspection criteria of paragraph f.3.2.3 of 2A010CS023-C: "... Visual Intpoetion: Cadweld splices shall be visually inspected to the f ollowing criteria and the re,sults of the inspection shall be documented. a. Preparation of the join't is in compliance with the requirement of Paragraph 5.3.2.2. b. The gap between the ends of the two rebars shall be 1/8 in. to 1/4 in. and the center of the gap shall be within 11/4 in. of-the center of the sleeve. These measurements shall be frai low stress reference mrks as recomended by the manufacturer ; gccd at a predetermined distance of 1211/4 in., from the end of each war. If the 12 in, reference cannot be achieved, other locati:ns less than 12 in. or 1 in. increments shall be used and shall te equally spaced from the erid of each bar. If the refer;suce marks must be unequally spaced, the inspector shall be notthed and shall witness the marking. (n hh.._.

1. "... O -h 7 1...k o.

.. m 9 9"T 99 s . S. a 5 1 I

......;......S c. a t w.w y. vn'tsa 1 c. I ends of all sle.ves shall be.spected f or circu=ferential low fill and spot voids. The acceptance of these items shall be in accordance with that established in Erico Products, Bulletin R35M-274 The requirements under (a) and (b) above shall be checked on a rar. dos l basis as the cadwelding progresses unless otherwise specified. Any visual condition which exceeds the limits established in (a). (b). or (c) above shall reject the cadweld. The rejected splice shall be j removed and replaced by an acceptable cadweld....". j A-(4)! Duplicate Cadweld Weber i Duplication of cadweld number is another form of lack of unique j traceability, as noted in A-(l) above. 1 B. Unidentifiable Cadwelds ~ I Cadwelds wich obliterated identification is another form of lack of unique tra;eability, as noted in A.1) above. 4 I e i e 'l 0 $'h9q] l,h*':D(a$..._ a _.. - d; e [3Ulb

sliuts y::

SUMMARY

E CADWELD DOCCfENTATION DEFICIENCIES f.ISTING The following infor=ation coverea the period of 4/13/76 thru 4/1179. Total cadwalds shots of 37,0JO were made during that time period. f AITACIL' tit A - LISTS CADVELDS WITH MATERIAL OR UNIQUE LOCATION DEFICICICIES TOTAL PACES - 190 TOTAL CA0 WELDS - 1,956 ATTACIDENT 3 - LIST 5 CADVELDS WITHOUT UNIQUE IDENTIFICATION TOTAL PACES - 10 TOTAL CADWELDS - 100 ATTAC102NT C - LISTS C1DWELDERS. TOTAL SHOTS (HORIZONTAL, VERTICAL, DIACONAL), TEST SHOTS & RESULTS1 b TOTAL PACE - 1 TOTAL CADVELDERS - 49 s l ls t TOTAL DEFICIENT CADWELDS - 2,056 7 i" j. T ', WHEN "X" IS SHOWN ON THE INSP. (INSPECTION) COLWei DIE CADVELD HAD BEEN INSPECTED ' AND DOCQ2NTED IN THE CADWELD INSPECTION BOOK. THE "*" CR ASTERISKS ARE EXPLAINED AT THE BOTTOM OF EACH PACE. e t e s l ,s e l g e I Lkbd d 4

l er v s..u e,,. n.a.w..v..,wi ci

• • • ,*M,b..g DEFICIENCY & DISPostTION RQ.M RECORDS RauTIN.

die. siaas prosgCT PARTI y 'f 1, u 2. ..t a,.o. A c*JCCm.3t y. .u...s a o 4 J' "* "'" 6 - OY to 5 e sitwa crown a.R00T OUALITY A$$UNANCE DATE: October 9, 1978 j)) Q /-O sv3JtCT: DDR No. J-01M COR R E S. NO. BC-09282 o si. cQQ&. DOa c00a-Rif a RENCE: N/A f.,,, f. .... g a e.o= v%. e e.o. eumc.. a vauare ao. .,r, enot (onstruction Os Qt N/A ........ e.os a s s o;

aa v.

,,aa n a,o nie o.,,

oa i a.

l ..a e r. Procedure A0&O'(PCCP-5 ? I ! 3.1. t.3 A. J. Ha-mons '12-2S77 i .... a..oa s - Construct ton Procedure A0aCKPCCP-5, para. 3.1.1.3 scates that af ter being cicaned and thoroughly dampened, tWs will be filled solid with dry-packed ce=ent grout. In-l vent!".Jtion of the tio holes 'Which JCillted the tapered fdra ties revealed tha' follo*J-in4 discrepancies af ter grouting was completed. E ($ee Attachment) <p I . v am r.a6 sc..s ouse.weac t. r are os oneicine.c r. nuoa ras a ca*. cia scv: e d R umustLv O vests r -. Q uarea 00*aecsouaat _ O rurs= Ma's.' 9*o g;j a n c... -..c.'a' r.o u g.,.,-.,g

un.-

w. e.,o... pe F]=uctsa.e .,[] mona.uc ss [.:. neuu.asu ! i war aeou =6o 7 C+ 3..pc.

t 7.ynt r a

l -voassse e s aeoudsrso to :r sara emar u os rms roav awo Haruam csure.trss ans*oase to s=ov. s aco- -.+ nueu r, m.,umamca av ass.cw. t.we uart m RESOLuftCM a.. sums. c66,s sou r s g.alaa es

oata O sat.seacroa* O saa asw--es Mcou*Lario O ***asuaa<s U. 0 -

L 2,' its.4 ?f e A f CUA at NCE CONTROL -...or... <.co4a ou r; .eoa r ac,+

a-

,.

O sarissacroav O sea =<va-<a O cou tsreo O aul asuaws REMARKS .~. f 0 T % n % n r., OlsTRiauflon VERY TRULY YOb'RS. t.. Crane S. A. Viaclovsky (hf AP) H. A. Paperno F. D. h'mk WP) A. F. Holbrook 4 ~~-r*~' , s.., y T. D. Stanley U..) R. IJ. Pcverlay

• H. L. Key (HL&P)

SEM0 0R1 GIN AL.0: 7 A. S. Coevey (2) QA V.i.. t t Conte. DCC (2) ,,,ry,g 3sym. gap b i ~ 7 m-9,_- ---x m, g I. \\. g 6 K ,i s DOCKETEs ~~ ut m a b .L gR 41900 u -l 31 Q cm et en tem.,. [N JRQ CCQtW11E ;W 'M EXHIBIT 15 {

. ?.,.

h Atte ene to DDR #S-0325 M , Browpt: Root.tec. CRotfr Til1CKNESS Butt.DINC 1,0 CAT!0N INTERIOR EXTERIOR Fuelgandl. Bldg. Unit 1 42" Wall W 71A East Ext. 12" 10" 10" 5" a containzent Idg. Unit 1 48" Wall Secondary Shield Wall North Side 1\\" 4" ~ Nech. & Elect. Aux. Unit 1 30" Wall MP 3\\" 1" n a ~ ys" Ig" O 36" Wall 121-v003_ 6 "' 6" to ~ v e Or O r+.0 - m N 1.e \\ ~ \\ ~ l O fy%*;5 Omf,y bh -= l i l l l i

~ ~ ' ' ~ '~ DTUWIIV IWUkHIG. r-ub fY QUALITY ASSURANCE DEPARTF EFICIEWCY & DISPOSITION REftf 0; A RMmM ROUTING -c = g SOUTH TEXAS PROJECT PART11 a{a t A p;. NIDIN 3. TO: OROWN ai ROOT QUALITY ASSURANCE sw 4, FROM: C. L. Crane DATE: Jaauary 18, 1974

SUBJECT:

DOR NO. S-0325 CORRES.NO BC-05378-ALS

REFERENCE:

BC-05245 h RfsOLUTION ' Plenss*onse s aeove=so is som was sesu-cwecevoi owa car at ossen,es action vaar was asam vazan to coaaser suusonara ossielENCV. PRoviot EvloENCE l-13-78 tuat suen actiom was esem cou,Lateo on viustasos son courtarios. maseoasai A prograra has been instituted to investigate all tie-holes in safety-related buildings and exterior walls. With full tir.e monitoring by the B&R Quality Control ITepart:nent, this program will assure that the procedural requirements are satisfied. M tn T j"'[g".Q'' l"d$/7g y#M '.Q'" l f/j/g ^*// % ^g lj))fyg O v O R ECURRENCE CONTROL @ taesconse is amouinto ir son was assn ChtCE Eol gg l osscnies causa os ospeciency amo action TMat was stam vanam To coNTRob RECURRENCE oP own oata: l-13-7R I ospicismev. raovios avioames vaat snem action was easm coua6ateo am tw"asta ron courtatica. ~f no om= ~ ~ In conjunction with B&R QC sampling verification that all future tie-holes arm filled solid, Construction Engineering vill identify on Pour, Cards, the type of CD form system used (Taper Tie or Inner Tie). esa a Gm. are ovata jont esa ons. are va6 l'oaraie1-S-2 8NA & hhl?s ans aernovah. N

s. Sh8 NA DISTRIBUTION VERY TRULY YOURS.

C. F. Bierman P. J. Karnoski T* l. /* g/[,,, ": ': ":=1e, & t 11 0 l,l1111,d 0 11 u.O.m}j A. S. Coevey (2) C. L. Crane 8 S. A. Viaclovsky (HL&P) F. D. Asbeck (HL&P) Sr. Cogstruction Project Mgr. W. N. Phillips (HL&P) fM A J. R. Monroe CLC/EAS/ALS/dt J. M. b lvitti D. L. Kelley FILE NO. A050Q SEND ORIGINAL TO: Q T.m.cauem Q t.r.oanonsa oWallTV assWRamCS MamaGtR PROJECT Qa MANAGER emownamoor.inc. enow = 4 nooT. sac. p.o. som a r.o. som oss houstom.18Eas 77001 BAV CITV. Ttxas 77414 sT.oa493 3 ___,as.- i I a s A&%

/5 Brown JRoot.ince NONCONFOl{MANCE REPOR. SOUTH l EXAS PROJECT DATE August 30. 1979 NCA NO. S*U3I26 1.omoANa2AYeoN 2, Uspf NO.

1. PURCHASE ORotR NO.

B&R Construction G 2 NA

e. oocumeNr vioLArno nav.

PA9Agag/7 P s.orwen soaNr PicatioN No s.scoes %og 7 *. 2 '. .2 FH1-W70A;FH1-W71A NUCLEAA NUCLEAR 2Actocs028 C r.oeusereoN oP osPiciaNcv The above referenced par 36raph states " Dry Pack material shall be placed and packed in Layers having a compacted thickness such that each layer is solidly compacted through-out". Taper tie holes were packed with dry pack f rom the inside face only on valls

1. FH1-W70A & TH1-W71A. These are the East, West and South walls at the railroad area of THB-1, f rom elev. (+)30'-0" to (+L 50'-0".

Due to access the exact number of holes packed is unknown since some of the form ties used in these walls were she-bolts while (Continued on Pare 2 of 2)

s. maron rau se e oAre io PasPanao cy gi oarg Q, j.

, 3 pt,, 30 Jerry M. Lace,y L pt 8-30-79 C. M. Singleton ia.APPaovsoev g g W is. oArE N 14. REPoRTasts,osPicisNcv assNT,7j) REvitVW CoMMITith O. C. T. Warnics / 9g 79 g,, g%o pt is. P nososs o oesPosi tion / is. Actsom AssicNao to H. C. Dodd 9'II*I9 oAreous manoam a Palm uss Asis SCRAP connectiva ACTION

17. OrntR A6 vite & APPROVAL ig, o A T E is. con 5tRUCr40N REvite & APPRov AL 20 oait 31.oTHER REVIEW S APPROVAL

22. oA r t

23. ENGINE E RING Rivit e & APPROV AL 24 oart

25. ANI AEviEn & APPROVAL 26.OArt 27 QA RE ve&W & APPAoval 2s oArt is vaniPicariom O sArisP Acroav 0 uNsAvisPacroav

30. ANs vt AiFicar60N

38. oA r t

32. QAtoc v &RIPicA f eon 33.oA14

34. QA REvitW & closure 35.oATE Js.orMER REviin & CLOSURE

37. oAlt 2s. orstRisuTION

^*#* "N M

• • • d' R. A. Niemann L. D. Wilson R. W. Peverley A. S. Coevey (2)

W. M. Moye W. W. Hudson Constr. DCC (2) o'r T. D. Stanley D. D. Coppeler FILE: A050gM QA b.J s V 8 s1%d \\ "$*TNE D

• Q -[thk

., M., a EXHIBIT 16 g 4

1 e Anuaxta rY e inspecting the pre cure and clean up, it was noted that a majority of the holes inspected had sand in them. This violates the above two paragraphs. Four (4) Hold Tags Attached Location: FHB #1 l I a l I D 9 2. 2 AOm d, a e . j d r s ( 4 \\ g l l

Df'a;

(~ 9, m ~~ Brown &Rcot.!r.c. ~ NONCONFORMANCE REPORT OATE 5-18-79 bCA NO. 5-C2237

a. oacamisa r ew=

g 2. wm s =o. g2.,w%ea..wae.a r m & Foot Constraction I @ 2 I ag / A a.cocwmantwoo64rao ma <. amaasaasa g a.ornaa soamris.caric= no. g o. wsa a _ ,cm. a 2A010$C028 C 7.2.3.1 1 MEl '.'025-12C l @' d auctsaa r.osscairrio= os cap cianc' Taper ties were user.' for the form tie system for Pour fMT.1-WO25-12C, shown on drawing 1-C-4075-5. These tie holes were packed with The tie holes were filled dry-pack mortar from the south face of the vall only. The approximately half way thru the thickness of the vall with dry-pack cortar. interior surface of the tie holes revealed a thin film of the release agent that This is in violation of the above document thac / was applied to the taper ties. states, "Unless otherwise specified tie holes shall be filled solid with dry-pack mortir after Seine'elenned sed thereet51v d a er em ed. ' cae /? ) haSd

• • a
• --aaka' igcara9 5db a ratradio s, e.cara o

C. M. Sineleton h.@.,--,-y aasontao se r f rv *i. Lacev. Level II 5-17 79 is.marcaraaka cariciaNcv isaur 10 aavaan cemaa rTaa,

u. u r a u

now a av T-2,l ~lT C vas G ho . a,. i6. AcTIQN AMdGNao ro: it. p noPCg Qasac&a riC*d OATE ous 6-'a-79 J. it. Monroe Y use as is scaar coanscTivt action aswons nataan C# See Attachment #1. 5%* 7 as. oara 7

13. cGN. a N avsap 6 Ar* novas g22.oara

~ 67.oTMan nav6aa m as* v I 7 / ~% 7W 7-16-7 0 / /?-M//A t. N a.oara 2 qas c,aaviaa n anemova6

2. ca r a C. Jarde.

Ji ' nan py.naaAremov*6 MC - '7 /~7. *76 ~A / ~> '70 c, 22.oara '/ x Mata#*aoval. 7'l0 75 A a. Q AT a ' / 27.oa t 1s. ANa&vaa'n e arpnGwas RUA%ltd. NO. L.Y. 7*18 TO 2s. v a n.* eca rios y y g i y gj psarispactoav V Q unsatispacroav - Pcquacb. m . D 5 M.v '.W H))didH v.j, p.jas b jp 19. n uplo-l.s J YL 4~5 lmb.o ra,U u a.oc v aa.eica rio. ao. 4=. v a n. sca rica ai.oara hlA,0\\th. 7 IPi.~M a.o*.6 a ornia aavian a e was ai. oa r a % ) h v & Wj ,j

x. u aawan.66c u s to. It 73

/El Yim /0~/4'79 m. =*ans I y g j f)Opd1CO 0/J/*05#f/W AnMet/ad 7)D W7g DaJE Wllsl W/ 4. pos 7//7l7f i \\ V CATE DESIGN VUHFfCAT)Ces as. ois s ainw rio,. A. T. Holbrook A. J. Granger R. A. Nienann L. D. Wilson R. W. Peverley A. S. Coevey (2) W. W. Hudson Constr. DCC (2) IN NI V. & Moya T. D. Stanley D. D. Coppeler File A050QF. l u.sm \\ { bl / J ce~:-- s RR s 730 - .i** a~. K, a p/ 4 w 'J EXHIBIT 17 a j . i,,*:

v "

A P. NCR iS-C2257 Attachment #1 Repair Many of the cie holes have not yet been packed, those which have been were packed f rom the north f ace of the wall only. Inspection of the packed tie 1 holes revested approximately 2" to 4"~of improperly consolidated dry pack and traces of release agent which had been pushed through the width of the wall and collected in the south end of the holes. Repair will be made by removing improperly consolidated material out of the holes on the south face of the wall, cleaning the holes to remove release agent, pre-soaking holes, and,re-packing with dry pack. O e O C O N ~ m W D**~ " 5)~ ' Y{ o!. . OO O J For In"ormation Ont ~ k g t . h O s s e o 4 a y ,f. t...

L'.K L,*.Tt% #L O 05.'.'Ce tJONCONFOsiMAf!CE CEP0ttT II'13~78 N0ft NO.S.C12M

• DA1E

e. ox.Aw4 ism

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i.o. ,, c1.g;. s. o,.o no 4.ovo eis si vico ico ae v. sncit. i. .. di;;r;...t,a 3,3 th,,,3.~ 'C C P li-Z e7 .p, _n=t Juteei rm r. e N/A g; - .c o'.,0j,gg*-12 2 3.1.1 2 A,,dNec.6-P 1 Z. g] r D i E ttan ~ v.ctrc*.iesior: os on car e,cv Jim Exterior call pour HEl-WOO 5e a Tic Hole (Approx. EL. 16'-1") Located on 'A' linc and approximately at 5'-O North of Column Line'29' was not patched prior to the installation of water proofing and back fill operations.

8. f airDH l( D bV

19. Ot. l k iO.e'Hu Ae t o liv

_ fp f [, ' g,, jg 3,73 s li. uA to

y. C. eyles

) 11-13-78 S. Shah f u.u h i4.aumran dv'im rurC:w.rce.snrcr.i Trus.mtm.v 3 3 3 & 2 "*j T'II/t'-nl C vns & no i*s. PF s*05kD Di5rcesi10fd

16. ACiaord Ab3:Ct.tD 10:

J. R. !!orroc .DATeous 11-30-78 X narAlm use Asis SCHAP_ CO'IRECT,1Vis ACiloid ntr.onx Dry pack mortar thru entire 2' - 6" thickness of wall and in accordance with Specification 2A010C5028-Fo paragraph 7.2.3.1. = 17.Olhtii dikviitt er AP 'e QvAL id.DAIt i9. COf.*. I nuCI.G.4 f.s v lCa em Alvi.O v AL

20. C5 (

2i.o e 11 i V EYE AffliOVAL

22. D Al t 2

YOVAL he DA i v w ~ /Il$ _;lf;.s H - G -N 2's. Afdl HE vitW A APEHOVAL - 'f t it - Yt -}g 7y'/2 s

26. D A Tt 27.o4Hkv aW es AlefiOVAL

,/ / 2C. DA. E h/1

v'M r.

t-79 %pj. c, ? l.

n.s ani icAvion -. f'** }/, p f, if - ? *. *If Ei v tuis icas.on, ai.uA 6 n. .: vum icA rie. u.oAit NA'. '.Y\\ Q. 3 2.fa.99 & pr? a ess, 2.22-3-?; M TCTTKlitMTCHMUCI 7-T bIra . istV1X in r.t, cto:ve 6

27. uATt

_\\, Q 11 32673 dd We J.26 7/ i,:Ania yy .y l'Oif-i G"- ' ' ' ~ . 0$$$$0 h()ll & a 2. i..sion.,i w A. F. Wilbrook T. D. Stanicy VJ U. t$ufsoit Constr. DCC 2

5. A. V1.telovnky A. J. Cr/incer T. B. Schreeder F. D. Ar. beck R. W. rever1ry A. S. Coewy. (2)

File: AO' Ofl .~.m.. 1 - .u

a..

.....w.+...w .-a . ~.--..-.s:.ro uw.mv.s - N. gN g s s M g g ETED {[g30 > - D P*D 5 s e ; ./* 01h3 (I. l'* en 1 . 5%- W pt.S't

• W q

U k g 0 EXHIBIT 18 O L O y e S e..

~ l ep ~ ' p,,f

d. h,, E

"'.;:.s t attorneys, I would like to relcat ny question. i

4

' */ gb.~ 3 Do you hav any knowledge with respect a, :A M to cadweld problems? 3 ,e<,.< ' s e l ? P.3 a A Yes, sir. l .h f.r .+ L's Q Okay. What knowledge do you have? .q.- d.V E A Containment Unit 1 Duilding base mat, over fif ty i* A. s M percent of the cadwelds were not legible, and as g.?: a result you couldn't determine who shot the cad- .y! - s .3 ? lA e welds. 9 M T % to And Mr. Dick Duckalew with Construction ' OM and Mr. Jack Duke with QC, who was handling that $ { n at the time, falsified all the as builts for the "..M:$.. u u illegible cadwelds. } }yb } 0, Who did this falsification of records? i4 Q , F. * *. ,. 1{T ,3 is A Mr. Jack Duke and Mr. Dick Duchalew. 1 s' is Q When was this? 8 n A This was during the construction phase of the f o ,1 is Unit 1 Containment Building base mat. .i When was that? , ', ' d.- to Q q T *T 20 A Mid '7G, late '70. a v [ !( 21 Q What happened? .4 22 A The cadwelds were shot in the laydown yard, which J.j'

f 23 is on the hill, several hundred yards f rom the 5

24 containment building, and they had been in the ',{ process of shooting these cadwelds for about four ', 4! i' 25 Li L n ~ T

i I h8p ' I 'e 149 r yi l ~.{ lKffii to six months prior to their actual placement in f.f h,4 a 3 the structure. .3 And as a result of sitting in the weather u c. q l'y ~ they rusted. A lot of the markings deteriorated, j e M@j,,(. a I s and the majority of them were not legible. You f 4>- g4 could not determine who had in fact shot the cadwel' .pu ;e y j'" r Q And so did they make them legible? 4 d: .) . :p e A Sir? 7 j 'E e Q So did they make them legible? w A ' f-$.is A On the as built they did. e i h si Q Did they make them false?

p 2

A Yes, sir. f ,JA is Q You mean they put incorrect inf omation on them

• w

}14 when they made them legible? ) iff' is A Yes, sir. You could not determine what numbers s.3. c'. 1 ~ is were in the field. ai% i 45 1r Q How do you know they put incorrect information on 5.b ,,a ) ' 88 them? 1 91 is A Decause that 's why Dick Buckalew assisted Mr. Duke 1 .8L >l "gi 2e with the as built, which it was a QC responsibility j 36: 21 for Mr. Buckalew had a cadweld shooter's log that 1 ~ #[ 22 Construction maintained that recorded all cadwelds k d' l M.' n that had been shot, and from that log they trans- $)[.n 24 ferred X number of cadweld numbers onto the as _ y 25 built so it wc,uld show that all cadwelds in that l n q e. 9. I $M n.- i I '.( me en-

7 gr'- IN' 150l -\\ i pour had been inspert:cd and had been as built. Q Did they transfer ir e:orrect information? b. A Yes, sir. p a Q What was incorrect about it? j, h. A No one knows what cadwelds wem in that hole. You L g: i "i ~ s can 't determine it. 't H. ,} y, r Q You don't know, then, do you? n ...': M a A No, sir. 4: ~ k; e Q Ilow do you know that the information was incorrect?

i.,j:.,

vj to A We are required to as built the cadwelds. They are py ~ g a3 required to put the shooter's marking on the cad-Ti k. 12 weld for inspection purposes. th-e is Q Yes. w. [ Q,' 14 A And as a result of'these numbers being illegible,

f...

.,6. is no one knew who shot that cadweld. r/i: is Q But how do you know that the making of them legible M 5,s. 7 resulted in making them false? tf!4 rv 18 MR. SCllUU4AN: lie didn't testify that pi f., 7 they made them legible. Or did you? Did they make to .. ~ LN. e.,) i the numbers legible on the cadwelds, themselves? 20 f.h 21 Tile WITNESS: No. ' h.. '[Q 22 MR. SCI!UU4AN: No, that 's not his o,.g, y,i;, 23, testimony. J., ['.', [; - 24 BY MR. BRO',0;: { . 9v, g 25 Q What did they make them legible on? sa. ?nf * [' lge fm 'Q , ,W

PA*'. 151 h s;$j; *?.%: A Well, I am not saying vally, I guess, legible. >*{p, a They just filled in X iumber of slots on the as .{.:, i .:)' built and put numbers in there. ,M ' D "a. Q Numbers of what? y *? ' s .M

)

.-~ ;e A Cadwelds. ,s : F g's' Q Of the person who made them? 2. u l1 %ft A Sir? a .s j@ s Q Numbers of the person who purportedly made them? i .i A They just put down the numbers based on Construc- ,g e O M, as tion's record of X number of cadwelds that had a

1. Q been shot according to Construction's records, and 3

. cg - they placed this information on the as built record 2.a e ni k[Q: 12 Q What was false about it? 'l Su A Sir? j a. "II.i Q What was false about it? E ~ 3.' s y .. f is A No one knows what cadwelds those are. t' y ({ 1r Q And the numbers are false? 3 I is A Sir? i tu 3 is Q The numbers they put on are falso, is that what you -{S' 2o are saying? k' 0 ' ri A The numbers don't correspond to what's in the field. gel ' 22 Q llow do you know? -f,4 23 A Decause you can't determine what's in the field. f i 24 Q Then how can you determine it 's false? ari 25 A Sir? "h hi d l .(f*- .h

• . ?"

w? ,.,,a ~ m

• M,-~

? b, 152 %':.1,8, Q Then how can you det rmine that it's false? ' W t,n. 'f,~ fr[' i A Because Mr. Buchalew and Mr. Duke went back through . r ", -..; i;G.,3 the material log and stated they were just going to c .17 2 ,, F.. '.' 4 make the records reficct that X number of cadwelds '. ' hIf@. s~ had been shot, X number of cadwelds are shown on 3 s .y ,;h W, 'g, f 's this drawing. ,; p.m 7 Q All right. '. v.2J : s j 'l: A And in reality they didn't know what had been shot. 4,.. ..e Q I see. Now, has this matter been reported to the 4: y {: 'ne N. R. C.? . +, 7j. si J A I am going to still consider any of my conversation te. 't y it, with the N. R. C. as confidential. u. } gu Q But don't you know that this was a matter that was ] j known to the N. R. C. before you reported anything ' s4 h, is about it to them? >A 't+, jf; is A Sir? .;l, V: ',j.,d er Q Do you not know that this was a matter which was .T. (p,, is known to the N. R. C. before you made any report 9 .f '/' is to them? t 'A to A I didn't state that I had made a report. .- av-2: Q No, sir, but don't yots know that they knew about A; h.:N 22 this? ' [fi 22 A They had been involved in some investigations con-i - w 'y 24 corning cadweld records, 9? i ] 25 Q I see. There had been an investigation, and you 't n. 4, d ) c t;. b w w ,P[. t h f

s. 153. ,y I know that? 2 A Yes, sir, I saw the r-sults of the report. s Q Oh. All right. Now, so that what you are telling ~I me about is a matter which the N. R. C. knows about? I a ., y$'.s l A No, sir, I am not telling you that. r., ? Q e Q I thought you saw a report about it. 1,}. I I p. 7 A I saw a report concerning some caldweld deviations. I ( f ', fj s I am not stating that that report -- h'p[ s Q What was the nature of the deviations that were , f'd to dealt with in the report which you saw? , 7N., q A It was cadweld deficiencies, but I would have to go in JJ 12 back and read the report to cite the exact 4.. is deficiencies. 7 is Q Okay. Do you have any other knowledge of cadweld },p(, is problems? i-h is A During early '77 several of the inspectors assigned .Q to the safety related areas would partake in a ir ,7 card game the bulk of the day in the NDE lab and Ijf.f is EE-is not perform inspection in the field. . g

cre,

c F o Q Is that on cadwelds? f'C ' 2: A Cadwelds and concrete. fj .[ 22 Q These were the QC inspectors? ? 23 A Yes, sir. (4-j-l.f 24 Q Were these inspectors under your leadership as a .J 25 lead inspector? $;. W S fth* i 1 w , u k 4%:: \\ 'N, 3

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l 0 I). A. I i t!!ERTSON, P.E. Project Sito Engineer

SUMMARY

OF EXPERIENCE: Twenty-four years of engincoring experience including 2 yearr. as construction engineer, 8 years as hydroelectric engineer, and 4 years as project design engineer. lias worked as engincor with privato engineering consulting firms and as project manager for construction of concrete, piping, and structural stoel structurcs. Currently serving ns Projcct Sito Engineer and Site Design Engineering representative for nuclear power plant. i k EMPLOYMENT AND MEMDERSHIP Diploma in Civil Engineering, Sydney Technical College, Sydney, Australia, 1956 Fellowship in Earth Dam Design and Construction, U.S. Bureau of Reclamation Past Member, American Society of Engineers Past Member, Institution of Engineers, Australia Past Member, Texas Socicty of Professional Engineers REGISTRATIONS Registered Profossional Engincor, No. 30640, Texas No. 13516, Louisiana i EMPLOYMENT IIISTORY l Drown & Root, Inc. Since 1975 Ti ppo t t s - Abbe t t-McCa r thy -S t ra t t.on National Soils Servicos Inc. 5 yearn 1 year flarbert Durden Construction Co., Inc., Jamaica 2 years Southwestern Laboratories i Snowy Mountains flydroelectric Authority, Australia 1 year { 8 years NifP Steel Mill, Australia 2 years ~ \\ g. N Q. O. t:r O ..-y' 'p t i.? ~ ./ i citd d '/ s CCM EXHIBIT 21 p/.-/ f y -*g u ??r ' iX ..,5,$~<> .y.,

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l l R M. e l 1 1 9 i l t QUALITY ASSUPECE PROCEDURE l ST-QAP-5.3 ( EARTE*0RX b l t \\ ft E FE R E N G r' ROUTING l RIN QA R VIEV/ I-2 -- 0.00_O Q? ^ 4

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SOUTH Ti.XAS PROJECT HOUSTON LIGHTING & POWER COMPANY h l ffl h supanggDED -Recono cop, I' Y PREPARED BY: APPROVED Y:

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de mkg.,/ T. H. Canon REVIEWED BY: M. ?, M.-. D,. Brown'f5 Root.inc. ISSL-O PATE: hs ,,-,_s,. ,e,, 00 fuf

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1 Q =%... ~. ST-QAP-5.3 EAk flNORK l 7 of 9 5.3 DISTRIBUTION 3 See Attachment 6-8 for the distribution schedule. Distr'ibution addresses not provided elsewhere within this procedure are listed 8 below Mr. M. T. Luke Project Manager 10 Houston Lighting & Power Company 611 Walker Street l at Houston, Texas 77001 ,3 le Hr. D. G. Barker ts Quality Assurance s Houston Lighting & Power Company is 611 Walker Street ) is Houston, Text-77^^' J to 2' Mr. J. T. Mooney p l n 0 'T S h 2 Engineering Project Manager ,T 0 Brown & Root, Inc. Uj) i.i u l P.O. Box 3 Houston, Texas 77001 26 \\ 21 Hr. D. Robertson Site Geotechnical Engineer Brown & Root, Inc. 3, 3, P.O. Box 993 32 Bay City. Texas 77414 33 ~ 3e Mr. B. Pettersson 35 Project Coordinator d' 3e Brown & Root, Inc. <f M 38 P.O. Sux 3

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37 o W n y n so SUPERSEDEO. RECORD copy oo e.or nuncove Q A-C270 \\ t .j M s M k La s AKL 1 e 9 g

r. liou 'in Lightim, & Power C mpany i OFFICE *1D*'R ANDUM Te C L Crane July 5,1777 p,.. F D Asbeck ( ST.HS.BC-00563 J.hecs SO Cf TEXAS 5 0 JECT ALTERCATICTI CT JL:II 30,19TT In accordance with our discussion of this date, please prepare a written report to be sub=itted to this cifice no later than July 12, 1977 concerning the RC-Construction Altercation of June 30, 1977 The report should contain at a minimu=: 1) all pertinent background infor-nation leading up to the altercation of June 30, 2) the details of the l altercation including physical injuries, status of e=ployment, etc., 3) the results of the specific altercation,14) and the corrective action to be taken to reduce or eliminate the possibility of this problem in the future. l In addition, the report should address the e.llegations made to the !.'R0 on l June 30 (see attached) s.md the concern ex;ressed by Mr. Bob Taylor of the I h'RC. rm:db cc D G Barker H T Luke l G F Bier =an (BLR) bec: W H Menger I 'q 1 n S A Visclovsky g O f e f g

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Frank, Mr Taylor indicated that he had been contacted by an infor=er regarding an incident that occurred Thursday, June 30, 1977. This incident involved an alleged altercation between a MR Construction fore =an and a B!LR QC inspector during a concrete placement. In addition to this information, the informer alleged that this was one incident in a series of threats and intinidations by ER Construction against B&.R QC inspectors. In addition, the infczter i

indicated that a ER Constzvetion superintendent told his troops that any QC inspector writing DIR's during concrete place =ents would be fair game. Mr Taylor's concern was that these allegations could have resulted in an unacceptable level of quality of the work perfetted to date. Mr Taylor indicated that he might possibly be onsite Tuesday, July 5, to investigate the allegations. Bill Ibillips 7-5-77 t l Uwf.gNJ.@lN I9FsL o en o 70]"[. & ~ tj... L'h b ' m q. s....._ O, O c ~ .e a \\w u a;c

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9 1 0s.n . ~;..:. I s ~ Brown & Root.inc. % m.ce see m se, cay, re... 774iu ANs# Ms F. D. Asbeck DATE: July 8, 1977 TROM C. L. Crane JOB NO. 35-1197 i

SUBJECT:

June 30, 1977 Altercation CORRES. NO. f'T-BC-ES-0806-JRM between Q. C. Inspector & Concrete Foreman Prior to 'the subject altercacion there was evidence that connunication problems were developing between Q. C. concrete inspection and concrete placement supervision. This demonstrated itself primarily in, what ap-peared to construction to be, an ever increasing hassle to get pour cards signed off. This was not an alarming problem but one both construction and Q. C. had recognized and a meeting had been sheeduled to discuss it. i The meeting, however, f ailed to take place as scheduled, because of a problem that developed pertaining to Document Control that required io-rediera, attention of those per:ecncl that would have been t.t t'. ectir.g. l Before the meeting could be rescheduled this June 30th incident occured. l However, I would like to point out here that there is no evidence that clearly links the subject altercation to a general con:=unications problem. It appears that two (2) individuals made antagonizing consents to each other that resulted in the physical confrontation. This may or u.ay not have been avoided by a meeting. Pertinent statements are attachedt however, the following vill sucmarize I how the incident appears to construction: I 1. A. Watson, party chief, requested from Joe Bazea, concrete foreman, that slick line be lifted off of screed. Foreman's response was, according to Adrian, short and belligerent. ~ 2. Adrian proceeded to seek out the concrete general foreman. On his way he was stopped by J. Marshall and he explained to Marshall the slick line problem and it: plied that the fore-man was uncooperative. Adrian did not explain that he was going to get the general foreman. Harsha11, in his statement, said that Adrian requested his help; however, in an interview Adrian denied requesting Marsha11'.s participation. A,. 7 f s M 3'I D**D _d D A n q N

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4-w /.l.,'., Crown;7RooUnc. / July 8, 1977 ST-BC-ns-0806-JRH Marshall proceeded to where Joe Eateo was verking and re-3. Re-quested that the slick line be lif ted from the screed. ports are conflicting to Marshall's manner. Some say he was impolite and belligerent, vrile others would indicate he was polite and businesslike. In any case there is svidence that would support Joe Basea's testimony that he was verbally abused, hence provoked. (See attached statements). It is appropriate here to describa the conditions under which the concrete crev was working. This particular pour was being placed using a slick line that requires periodic breaking down and removing sections and man handling of a' long heavy hose at the end. The vertical devel congestion, the heat, and poor air circulation added to the difficulty. The pour began during the heat of the day and was approximately three (3) hours old when the incident occured. J. Marshall, to this point, had not been involved in the placement process, but had been at the truck discharge. It is unlikely that he was aware of the dif ficult working conditions the crew had been fighting for three (3) hours. Had he been with this crew from the beginning it is probat a that he would not have had the same sense of urgency cone ening the screed which would not be f actor for approximate./ two (2) hours. 4 Based on the' statements attached and interviews with other personnel it is our conclusion that both parties were at ( fault and disciplinary action should be taken; however, it should be taken equitably. Joe Bases, however, has quit. To prevent reoccurance of this type of incident we have held a joint coet-ing with Q. C. and construction supervisors and clearly explained what the procedure vill be for handling disagreements and what the results will be if this procedure is not followed. In addition the concrete department suparvisors has held meeting with all concrete personnel and explained This policy basically is that where disagreements .this policy to them. develop it will be reported through the proper chain of responsibility and handled in a businesslike manner. Failure to follow this policy will vill result in disciplinary action. Concerning the informer's statement to Mr. Taylor as recorded by Bill Phil-lips-the following is in replyt 1. " series of threats to insrector" - In investigating this the l inspectors are unable to identify the persons making threats. e l If identification can be made disciplinary action vill be ( taken. In any case we have instructed all personcel that thers will be no threats. Q .G.- 1 ~. W + g 2> W a l / / ?4 . pix. ?. 2,

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9..ssa Ho0Unc. ~ ' ST-BC-HS-0806-JRM July 8,1977 i 2. " Brown & Root Construction Superintendents that Quality Control Inspector was fair game" - Our investigation in-dicates this is an irresponsible allegation and should cast i a real questionable cloud of credibility on any statement j ande by this informer. l There were no apparent serious injuries although both men apparently fell after some shoving. See attached first aid report on J. Marshall. ( l /M C. L. Crane Construction Project Manager FILE NO.I A390K Attachmentst l 1 No. 1 Statement of J. Marshall No. 2. Statemer.t of C. Singleton n.

3. ' - Statement 6f C. ~1 616.on No.

4 Statement of D. Johnson i No. 5. Statement of J. Cox l No. 6. Statement of R. Reedy No. 7. Statement J. Padille No. 8. Report cn J. Marshall's injuries l eb M omnwy _ J).X 2 I T 1Rf0filiat,10D yLY O "). 1 ly- -- c e w., ,., %,. m r;. aw. r v - 2i- ..<-x,rwc- . ' - - '..vt= w - n r.. r au S I 4 y e a l < ' ', ', ', f, , $.) a, e,1, l \\ l 1 P

l- = "On June 30, 1977, around 2:30 p.m., I relieved Steve Schlumpberger on the placement of a concrete pour. L' hen I f' rst vent in, Adrian (Field Enr.ineer) asked me to ask the forenan to move the slick line because it was interfering with the proper elevation of grade. I went over to speak to the concrete 'foteman, Joe B. and asked him when he had a chance would he move the slick - line because it was interfering with the grade. He turned to me and said if I wanted the slick line noved, to pick the fucking thir; up myself because he only had six men working. At that time Chuck Singleton valked up to me and Joe asked him why he had to move the line and why he had to do this and that. Chuck said he didn't know because he just got there. Joe then turned to me and said, "Did you call me a son-of-a-bitch?" I said, "r;o, I didn' t call you anything." He then grabbed me by the shirt and said, " Yeah, you called me a sen-of-a-bitch'" He was pushing me and I had a hold of his arns trying to hold him of f hoping the guy would calm devn. He continued pushing and Chck Singleton was trying to get him to turn Icose. Ho con-tinued pushing and forced re to lose my balance and I fell down into the rebar kith him on top of me. Then Chuck Singleton got hold of Dan Swayze and Terr > Cardrer to Cet some help down inside the reactor containment pour. The 6bove statenents are true to the best of my knowledge, rYi,r ? / ~ .I J*s's,% y./ 7-, 7 7y / $1GNAI6AE DATE e D W D bb LJ d a A ln b rul' HudIh NOII p 2-ma 0 e s W g F i e p* k' a .....r%.... .;.CO-

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I, Jackie Cox, on June 30, 1977 witnessed the following incident in reactor No. 1 between 3:30 and 3:40 PM at the South Texas Project: I looked up from my work and saw Joe (concrete foreman) and a QC man (bronze hat) hsiding each other and struggling with each other angrily. I saw Joe push the QC can down onto a steel rebar mat - still fighting.-ith each other for about two minutes on the mat. Both men were a tive against each other in the fit,ht. I did not see either of the= take a punch at each other, I just saw them struggling and h:1 ding each other back. They then released each other and then Joe said don't put your Mother Fucking hands on me any more and walked away from the scene. Then there was a man helping the QA man out off the rebar sst." f Mfas', Y P'*/ {l. lfs' e.:?#. + EITI4ESS ['/ / WI IeSSES SIGNATURE

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strownCTRoot.Inc. I, Ron Reddy, on June 30, 1977 witnessed the following incident in reactor Ko. I be:. ween 3:30 and 3:40 Pl! at the South Texas Project: To the best of my knavledge, the QC can said "I have to have this shit done right and turned around, then the foreman came around and said keep your mother fucking hands off me and don't call me a sonof abitch any more, and the QC man said you're out of your mind, and then the foreman grabbed the QC man and ran him to the nat." k ?. [A4La = m ms,eC s 3 muss

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t lr TO: Mr. James Monroe TROM: Charles Bishop Safety Inspector subject: Tighting incident June 30, 1977 Date: July 8, 1977 l-On June 30, 1977 at approxicately 3:40 P.M., Two Q.C. eeployees came into the Safety Office and ask-d ce to go with them because there ) was a fight going on in Unit No. 1. I rode with them to the site of the incident. When I arrived inside the containment, no fighting was going on. Mr. Salvetti and Mr. Lindsay were discussing the incident. I talked to Mr. Salvetti and he told ce that tri concrete hand had already l 1ef t the job, and the QC hand had gone to First Aid (The two con that were involved in the incident). a When the QC hand arrived at the First Aid offica, he was very excitable and coep1'ained of pain in his lower back. He was in the First Aid offico approximately one hour. He requested that we send hi= to a doctor. We then transplanted him by a=bulance to natagorda General E= err,ency Room. He was seen by Dr. Daughtery. No admission diagaosis was made, but XRays were taken. The XRay repare ~ *d as follows: AP & Lateral af 1..L...dttibrae reveals bonen w L. in..u t, no evicence of trauma. He was released from the hospital on limited activity fer two days on July 2, on Thursday, July 7, 1977 he returned to work on light duty. He was to work as long as he could take it, and is to return to full duty July 11, 1977. Doctor diagnosis received July 7,1977 disclosed injury to result in Lumbar Muscle Spasm. -L O jf /m ' /' Charles Bishop, CB:bj s I P f es a h

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~ ~ ^~ N /Y .,W \\ s l 9 Q ka = ++ 9 'T w:. g }, {\\ Jy '(g 9 D } Ho 46-1987 D 3 g 2 6 .j p i P p "O M 1977 refused to sign E[ a grout card approving the grout ng of a base plate for T a structural column in the Fuel Handling Building f1. I 5 construction personnel did not cceply with the reqEire-2J ments of CCPl7 steel erection. When s' questioned by who was a QC inspector, th - the structura steel oreman did not have knowledge of y' b CCPl7 requirements or the paperwork required under CCPl7

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no quality control inspection procedure he into n R. of eroutine issu y 25, 1977. ( iscussed wi e Oc super-Q i?c x vs.sor, the failure of construction to meet e structura stee requirements and the fact k m f( there was no AC procedure for the inspection of grout. We took the position that we could not sign off on the isr. i5 grout pour. At this point the CC supervisor became d jf abusive and ordered us to ignore the CCPl7 requirements. t i. f}. He stated he did not care about the lack of QC procedures E 'or grout inspections and we were to sign the Goddamn" !5' f In fear of our jobs we complied by signing S[. card or else. t i_ that the requirements were met when in fact, they were l h t not met. The QC supervisor, who had no civil engineering background or experdence in this area, made many arbitrary B 4W decisions such as this during his tenure on the project. U [. on some instances we were able to secretly inform upper 3 manage:ent of his decisions, however, they were reluctant !;4. ) ia-1 [., to act because the QC supervisor.was a close personal friend of the President of the Quality Assurance (QA) organizaticz {pi e b "During July, 1977 a concrete pour was to take place. Hevever, prior to this particular pour we had experienced s. quite a bit of rain. In fact, on the day of the pour it U appeared if it might rain. The specificatiens are such ER l that ycu are not to pour concrete in had weather without

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"About June I was told by QC M Us 4 that he witnessed con- $9: i ? epresentatives bending embedded anchor bi bolts at Waste Monitor Tank Pad A and Condensate I-~ Polishing Regeneration Waste Collecting Tank Pad [Si r 'n the Mechanical Auxiliary Building, Unit One. [K... The bending was being done by several workers using G '- a " cheater" pipe. As a result, a large area of +- concrete in Tank Pad A was fractured. This action z.i also resulted in possible damage to other areas such ,.s-F as fractured concrete or the breaking of the bond f. betueen the contrete and the anchor bolts below the k"Z..: surface. r 4-fai~-~ _.. ::h.. \\ p iN.N E^..~ _.'. 1:'{. _..L

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~'. ;.. 2'.9;J :~:.Q W g:. Q RJP. W.:;;::.$ ','s L:.',~$.". c: u;., 7_. g 2. 7 -- .y. it-p .. ~.. is v? y is only one example where QC management suppressed the W attempts of a QC inspector to report deficient conditio... E-J Cn many occasions were told not to pursue a problem b.;. when it became necessary for them to request technical [4-i y assistance from upper manacer en*. management personnel b,. L. cade the statement in meetings that any f inspector making a mista e on an nspection would be M f terminated. This tended to create a situation where a i an inspector might not report what he might censider is a violation for fear of possibly being wrong and sub-ti sequently being terminated. FI Prior to April 18, 1979, the QC inspectors would report to the Design Engineers if they found structural .M steel or other design items had been lef t out by the '~ { construction people. The inspectors felt it was necessary .T_ to do this because sometimes the Construction Engineers U wocid report less items left out of a project. For E = 6 I.. {. s.- ,e '.' 0 * ~ l;&;-W / s. s ~~, ~ \\ ......:.rw* v. . si' #.,e ,c.<> y,. ;' - ?. -* -..3 3 i s

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Inspector would talk to a Design Engineer. I would Jr_r. like to point nut that we had previous memos to this effect but we continued to contact the Design Engineers 7, M-directly without letting our supervisors know about the M' s contact. 5f-t _+A "Af ter about the first four or fivo months of (_@ my employment, the on-site construction began to fall El behind schedule. The further behind schedule the M-- i construction fell, the more the pressure was pla.:ad on FM-the employees by management to increase production fjF which in turn reduced the over all quality. This E.h a attitude by management placed pressures on the construction C; F supervisors to the point that they wer 4 5p.9 : their ebs cem 1

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r l Y .. _. m _.'C l p f .) t q g y c, [ EO 46-1987 12 1 TJ 0 IN ,b O F [f ggh hbl DL E-t i h fr Another area of inte e was e support given to F ~; f" the QC inspectors by the QC Supervisop. In my opinion, the F QC Supervisor does not comunicate the ideas of the QC Manager DF to the inspectors. Also, the QC Supervisor will make a t=y k decision without proper explantion to the inspector. This appears to-the inspector that the supervisor is willfully p{Z _t violating a specification or procedure to progress with the i r y-construction. This point was discussed with the QC Supervisor. i gj It would be beneficial to do a resurvey of these fkk e areas in three months. It is recommended that an outside 6 person representing construction also be involved to make i-@ suggestions on possible arcas of improvement. L-In sumary, the QC inspectors were adequately per-P2, J ^ forming their duties. All items on the punch lists were i;=;0 legitimate in regards to specifications and procedures. A ?.;(( ) major area of concern was Constrv' tion Managements' attitude gg toward the QC staff and their purpcse. Better comunication %-i between the QC Supervisor and inspectors will possibly improve MM the jcb conditions. The QA staff function needs to be redefined W ? to the field inspectors." Q[ t EL i This interoffice memo has been stamped "no action EC required." A copy of the me=o was sent to P.O. Bussolini. fp also provided numerous copies of cadweld (* re which list the inspector as being A.E. Schlaifer. Ljp-stated that Ichlaifer copied many cadweld reports o er, h' - er they were given to him by field inspectors. Many times, he EU 41-would change the reports to reflect the cadwelds were satis- .y factory, if they had been marked unsatisfactory by the field inspectors. At times Schlaifer would write the initials h_,& t( ef a field inspector down indicating that the field inspector ~".; d the cadwelds when in fact they were not inspected.

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tated that some of the times when Schlaifer would ~~ E I c ange a cadweld report from unsatisfactory to satisfactory, g d he would indicate he had reinspected the cadweld, when in fact E+ b he had not done so. Other times, he would go to the cadweld

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j site, look at the cadweld and state that in his opinion, the Tsf cadweld was okay. igg E.- ~. = = ',. b K". g k~ nc b.h = =. ~n ~ a O .f \\. \\ t g t e r* i t,, ,4 p y;. 0; s,'. :.. 'e - w.. . gh * *; * **,* *.*

- ~ ~ %ijn~n . ygt ,;[* p. i.. O. .. L _g- ' FEDERAL sUREAU oF INVisTIGATaoN EC wm {b9 w t-9/6/79 y ..1. b5 gm j was interviewed and Ofi: furnished the fol. lowing information h9 ft. t ll-t-i Li t e Be recently saw another erAng ano er cadwe ds which were'not accounted for. pg i r E".24 Art Schlaifer was recopying cadweld inspection 13J reports and throwing the originals away. When supervisory Eph-T QC people at the site found out what Schlaifer was doing, i i: he was reprimanded. The QC supervisors then had the original W. inspectors do new reports with the correct initials. Some of ?.=:: [,i-the inspectors would not prepare new reports since the ori- .5 h'- ginals had been thrown away. He does not know what was done t 'g about these. g g.v_e About October 27, 1978 or December 18, 1978 EA Schlaifer actually changed an Exanination Check (EC). The 7 ') i.. IC is the docurant cocpleted by a cadwald inspector at the 151. E time of this inspection. Esp.. C' W-The inspector, Mark Ewald, had marked a cadweld irf= (J as unsatisfactory and Schlaifer on his own changed the Er-- cadweld to satisfactory. ' This particular cadweld was re-EJ ~ 1 [y jected because the cadwelder had not marked his number on it. hk j ~ W D Nk {. 75 L 62.. V2.1 NP-itm ) I i \\ 8/9/79 M Texas RO 46-1987 h _( [ 8/15/79 k: o.. e I... l l ti en ..a.., .s.. .u w esi. = in s. , w v. rso w e i w i. v =r. F = =

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y-- -.._..r . '..,....-.'y- -c ^ 4.e p e - - '- - ' a.~_; .7- .a _ l pg. ~. D About he inseeeted the placement of U a pour in area of M He thinks he Ef was inspect ng tne Aast two ifts of this pour when he was Ff l unable to verify consolidation for about the first six feet of fi LE e /1/.79 .'30 us-19a7 8/7/79 o...... .i =. -, i..........-i.v.......--....u.-...+.3 - e ia. e si. e. i. ia. -..m r e i~. s.... =.. i. r~..-m m. c. ...................in.....a..r...... r .. 13. -

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1 retar cengestien and the darkness in the area of the conso-I E;c- - i lidation. He wrote these facts on his inspection report which I y >2P ~ he sent to the document vault. Later he went to the vault and EM c: saw that his had been hltered. There were two statements added iE~ i *. to the card, one of these statements indicated the area he could E4.. f. i not see was inspected by another inspecto '~M" gh R-portholes at a lower elevation. He think 7-W the individual who al d1y made the inspection. Mt I does not know if did the inspection, but if he a tne 5-i re

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. = - econc statement sal at was added to the card has left BER and is working somedhere in _73.. 1 said changes made to these cards are N [ suppcsed to e Anztzaled and dated. One of the above two g-changes was not initialed or dated and he has no idea who made => p-t-h the char.ge to his card. lj- ;} l' O 1979 - 5. re fus ed a =1m i 7,.- 'v a cenerete.lacement s c; w.. .y.. ~.,,. - .....,. ~, - ,.,..m- .::/... w : - ~m . _w y :7.:,.:-

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,t: The reason he would not release this placement ~ was because of water standing up to 3/4" deep in places where the cencrete was to be poured. The specificatiens re v 4 slab to be free of standing water prior to the pour. quire the ~ f Had he released the pour in the :enditicn the slab was in, he would 2 1 ? have been in violation of the applicable specification which w i / ( was 2/C0CS0028-T, paragraph 3.2.8. i i= 3 ..-..y..g m. ~.... .l.5 ..i [ r.t,2 ". - < - ",.., e i, L. -...f "**~'r~L' Z g .. 's.. -- l-. 7.,.. _ '.:.. Q - : T_. ' ' ' ^ %. ; m,.,.@.' ' ., - -.; y..l. ~. " k 7 - - -- .l3.-. '}^'7 , g ~: , ;L. -== 7..:

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- -.. p h. Q f f. n. .w v =.-y g. 3 tm 1 H0.46-lS87 hr J, k w.. sho was a QC inseecter and b-l were wit.. _s .c --.4--4,*--. { l . 1. E. .. ~ W r=Y' i 7 fi t _: g.=.

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g. Yik P As recently as July 30, 1979, stop work notice #14 !=; 4 was in effact as a result of NCR S-M1551 which is still open P9 ? (as of August 1, 1979). This stop werk notice involvas all of E P the enchor bolts embedded in concrete since the begirming of 17. censtructien. The notice was issued because sece material If Y (A-5ESA-1-93) received from a certain vender, for usa as. Ik Y' - ancher bolts failed to tensile and hardness test. Vendor's 4 are required to certify the hardness and tensile streagth of their =aterials. Since the tested material did not be the ,,p standards as certified to by the vendor, it made all of this C-5 particular vendor's r.aterial questionable. This r:aased the f.F. 7 NCR te he written and a stop work notice was issue? because C1 ( it ceuld not be deter =ined what caterials on site t.r c deficient. M A;parently there is a possibility some of the deficient material i g'. has been released for construction resulting in stop work notice ~ ' being issued. N Ah 79 E super-U visor, te about the st 'M notice and the l~!. O NCR. Cn told g there il was ' tart:.el release o ne s op work notice. t. ever, when / ent to the files to verify th: release, he c u r.: a re. ease had not been issued. The QA mantal Section ~ 2.7, requires the stop work notice has to be signed off by i field engineering and approval to resume work be given by the i site (A canager.' ..,., n j'_f," sy ' 's~ ~. / _..... - v'_:- l ;... ~ _

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~ + ' wrote en b j .ae mac.< o. tne eur card that he was signing at er under the =" directica of even though the stop werk notice was still 5 in effect. Ei i=0 c. ! l'. Y. f' .== i,1..........___. .___t M 4 i e I 1 l P*D D 3~kh l bc W r "Ah t } t a .r- -, ;.-ci. ;.. . :, QCys* q. n

{ ~ .k.**. m_ 9 A g [m; i t m l N0 46-1987 t.i ( i? - p F-4 On one occasion he saw a document of his that had been t-9 altered by his supervisor. The alteratien occurred when his R -1 b supervisor added a statement to the document. The changed b .documea* d 4*a* 4 in the

• ke corners of some walk N

a The pieces of angle j ) iron were suppose to be bolted to the wall every 24 inches, ~~ however, these were bolted to the wall every 18 inches. &#J v The change probably increased the strength of the attachment, f however, the different method of attachment was not documented t.E f, I E-according to set procedures. At various times he was cursed E by different construe 1 .. J._.j _;,. :. +. -..,..: ; -};.q _ :_ _. ; -

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Currently cadweld records are being revie.'ed at l the site. Dale Sewell is in charge cf reviewing the cadweld Pa. j documentation and is being assisted by Al He.: mons' son, F i ., Jimmy and a Tom (last name unknown). Mest of the people I work in the vau?.t on records are attempting to get the (J-T records computerized. He does not.think they are changing p-any records.

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t { =- j On April 30, 1979, Roger C. Terte, Lead QC Inspector, T wro 1emorandum to G. T. Warnick, Site Quality Assurance i (QA) im. eager, regarding a deficiency he found in Lift 5 Z. RCB f2, CS2-W5. Copies of the memo were sent to Chuck W. ?!. Vincent (Project QA Hanager for BER in h*custen),*Doug D. Fj; Coppler (QC/QA Ingineer Supervisor), Den Shu-. cay (QA/QC f l Shift Supervisor), Check Singleton (QC/QA Civil Su A l and Gary T. Iwert (QA/QC Surveillance Su;ervisor).pervisor) A copy of this is attached. After v1Piting the above memora.dum Terte was plai:ed on probation for 90 days. This prcbatica had to D.. have.been ordered by either G. T. Warnick or Chuck W. Vincent as these were the only individuals receiving a copy of the memo with enou 5 authorit to ' re -te -e74 _~ - j ;;z.:, i b ;;;. ;

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.x ~ o [ ".~." M. ' ~ ~ ~ ~g (. BrOWnfSROOlinC. Post owe Box 9h3, B.y Cry, Texas 77414 SOUTH TEXAS PROJECT 5-e ELECTRIC GENERATI,HG STATION 2h W 5 n.:: %zu TO: G. T. Warnick DATE: April 30, 1979 a J R. C.*. Forte JOB N0: 35-1197 !!h FROM: 7 5 "b 9 J

SUBJECT:

Lift 5. RCB f2 Elf ( CS2-W5 iniQ 1 a.s --Ms .~ a ~ 1 hd. e h Brown & Root Inc. South Texas Project Construction Procedure V' 'Prepour Activities A040KCCP-3, Rev. 10 para. 3.30.3 states in F.,- h total: "When concrete is to be placed on the surface, the sur- ) f ace shall be fre: of all laitance and loose and foreign matter". W4 3rown & Root. Inc. South Texas Project Specification " Concrete EMY T' ' Construction, 2A010CS028-F para. 6.1.1.1 Construction Joint Pre. FQ j paratien states in part: "When concrete is to ne placed on the h g surf ace, the surf ace shall be f ree of all laitance and loose and lJe.- foreign

• matter".

CS028-F also references American Concrete In-F" stitute, Specification for Structural Concrete for Buildings M' ACI-301-1972 Edition. Paragraph 6.1.3 of the aforementioned spe-5 / cification states: "The surf ace of the concrete al all joints 46 g shall be thoroughly cleaned and all laitance removed prior to f/f g placing concreto". y h The Proposed Ser. tion III, Division 2, of the ASiiE Boiler and Pre-h } ssure Yessel Code for Concrete Reactor Vessels and Containcents, Mi*. subsection CC-4252 states in part: " Specific attention shall be j-2.-' r given to ensure at before concrete is placed against a joint. i all. debris, wate and ice are removed f rom the space to be occupi(?E fir.i:. by the concrete. The joint preparation shall include removal *of Er t. all laitance and other unsound material from hardened concrete sub?- ?. faces..." The South Texat Project Units 1 and 2 Prelimincry Saf M ?. Analysis Report, sub. paragraph 3.8.1.2.1 Desien Codes specificalpg-t. states the applicable portion of ASPE-ACI-T59, Section III, Divism-C. 2 and the ACI Hanual of Standard Practice, "for the construction.ht. E i'nspection, catcrials, testing, etc. of the containment.structurc5= [ shall apply. $I r ELT+. (F The final Safety Analysis Report fo r the South Texas Project. Unin 1 and 2 subsection 3.8.1.2 states that the basic code for design i=i ASHE-ACl-359 and that ACE Itanual of Standard Practice is being usgn i. for " construction, inspection, mat'crials, testing, etc., of t.ht is-. 9 Containment structure".*'. E. v. W. YF E u y v 2. a. 2 . = =. .. =. = \\ D" T L .c . < g~;.; - -m

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P_ ~ ~ j i s. l s ,e L... And finally, @the U.S. A.E.C., Regulatory Guide 1.55, Co e ~ e y-E_ Preplacenent in Catecorv I Structures, paragraph C 3a states: E Cleanness -assuring cleanness of formed area prior to and during h. .q - . concrete placement, including access provisions for inspection and ciaen out operatio.ns". ~>7E w: Contrary, to the' aforementioned procedurer, specifications, codes, E

• standards and guides, placement CS2-WS,(Lift 5) was signed-off M

l A by C. M. Singleton on April 27,1g7.9 in a less than acceptable 1 E: { k, conditions. Pravin Shah, Cudapah Guruprasad and I came to work iL _ f, at 6:00 a.m. on 4-27-79 in order to make a final inspection on ~ y lif t 5 in RCB f 2 for placement at 7:00 a.m. While Shah finished v 6 his paperwork, I got a flashlight and a mirror and went to the RCB ? f* - f2 to begin clean-up inspection with Guruprased, he being out-X f side the wall and I inside. Working my way down to the constrution4a p. joint; I found it to be covered in several large areas with sand, 4 mill scale and rust from the rebar and liner, cadweld slag, paper, my cigarette butts, candy wrappers, tie wire, etc. The paper, cigar-JJ ette butts and wrappers were in a few isolated spots, and by no L j means en the entire joint, but the sand, mill scale, rust and N ^ slag was covering close to 90", of the joirt. f In addition, the lowest horizontal channel approximately two to three inches higher i_i than the construction joint was in was in some spots filled with J. 3'7 sand and beneath the channel, sand was piled against the verticle f d angles welded to the liner plate. .Af ter entering several areas, and crawling arcund I deternir.ed tha-1- ~ the entire construction joint still needed cleaning at the hari-2 zental channel. It was also determined that the verliical angles J 4 needed cleaning. This was brought to the attention of Joe Webb, v. Chet Scutelle, B.N. Kasarinath, Ross Peabody and several con-b ( j struction general foremen. I also explained ?e condition to k Herb Casanova, Se'nior Lead Civil QC Inspector he had been sent M. A f down to the placemett area to see what the prcblem was, and why k; b. had I not signed the pour off. 7; [:.. Chet 'Scutelle then asked 'me to make a final inspection of place-P. ment C12-W64B on the inside of RCB (2 so that they could be p i something while craf t clean'ed up CS2-W5. After inspecticn of C12-U643, I signed the pour card and went back outside to see if r-C;. d cleanir.g had been completed on CS2-WS. At this time, I was asked T... by constructio'n to pinpoint each aree that needed cleaning. 1 =~ 'k' stated that this was not our function as inspecters but w:vid do it ever. though it could take us three to four hours.to co:plete, b h Chet Scutelle later talked to me alone, and he asked what was wren; --- with the pour. He said that it was in no worse ccndition than E G l(: other pcurs made on the'shell. I stated that he was wrong, that b I had seen pours that were cleaned right, and I had inspected the. p myself. Boutelle than stated that he woud try to'ge it (the pour) 7-off my hsnds. P2

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^ I _O .,0 s e. w u c= 2 .n i h;' v s During our inspection, Chuck Singleton, Civil QCE Supervisor, $L . arrived at the placement and was looking at one of the areas into M 3 which I had gone through. This area had just had water sprayed b

• s on in from the tcp with no blowing with compressed air. The E

area had al'1 cf d the aforerientioned clean-up problems and no one ) had been into it to clean it af ter.I had cotten out. Singleton E-h. -claimed that the only thing that ne'eded cleaning was the lower M horizontal channel which, he said had very little sand in it. n I th had seen, prior to his inspection, that the channel was nearly fit f. full of sand as far as 1 could. see both ways. After going into f2 one more area;'*he said*'the same was true, a6'd the sand on the P3-5 construction joint would not be detrimental to the quality of the F 4 concrete. I shook my head, left the placement area and went back f& i.- to my.' field office. Es l g. ht- ~ 4 Approximately fifteen minutes later Singleton ca'11ed me on the '1 radio to say that.he needed me at. the pour card box. I returned (h. to the placement area and he told me that he would assume the C responsibility for the clean-up. 1 said, " Fine, sign it off ", b l t which het did. He then told me to sign the bottom line of the pourg. G card and I refused stating that I did not agree with his decis.icn W and I would not sign it. y He then stated that he would sign it, y=" i t and get with me later, to which I said "You do that, get with me if ( p later". The placement was finally, signed-off around 11:00 a.m. [._ k (- In my opinion, placement.CS2-W5 was sig.ned-off even though, it 55;

-s was not cleaned sufficiently. Whereas, I had been into between Pr-

.h 10 to 15 places and Singleton had been into only two, he could

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I y' have had no conception of the magnitude of the clean-up pecblem E. that was involved. He erred in his judgement to sign the pour h-off prior to his. complete inspection of the area, and he could not have gone into some of the areas that I had, because of our physical differenees and the difficulty encountered by me in d[r.- tryi.ng to perform a th rough inspection. b a m-

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