ML20058E480
| ML20058E480 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 05/13/1982 |
| From: | Reiter R MIAMI VALLEY POWER PROJECT |
| To: | |
| Shared Package | |
| ML20058E470 | List: |
| References | |
| NUDOCS 8207280247 | |
| Download: ML20058E480 (16) | |
Text
. 7 AFPIDAVIT l#
h.
1;y name is Richard L. Reiter. Q;ad,7s,ub it%; this; af fidavit y
to evidence my direct knowledge of widespreac. inaccurate clueprints, drawings and records for traceability. of egtegg philthe design of the,"lilliam H. Zimmer nuclear power plant.
.I worked as a doc-ument reviewer from May 1979 to November ISEO,tahTilSh currently employed onsite.
I also found strong circEcst ntial evidence that some of the inaccuracies wer'e the result of deliberate falsifica-tion.
Finally, based on extensive discussions with reliable sources, I wish to suggest certain construction And-quati*ty~E6rIho'l issues that must be covered in the Quality Confirmation Program at Zimmer.
A.t the current pace, I question the reliability of the Quality Con-firmation Program as the resolution of safety-defects at the plant.
The utility is giving priority only to repairs necessary for fuel-loading.
Other safety-related re-inspections and tests are being postponed until the operating licence is'obtainep.
I am not con-vinced the utility realizes or accepts the magnitude of the re-test-ing and modification work that remains.
My vantage point at Zimmer gave me a unique perspective on design problems at the plant.
For about two years, until November 1980, I worked as a documents reviewer in the Quality Control pro-gram at Zimmer for Kaiser Engineering, Inc.
It was my job to re-view Isometric Drawings and their related documentation, such as KE 1 and KE 2 forms.
I tested the results under Kaiser procedures which must meet AS4E Code Requirements, and attempted to insure that the drawings reflected the as-built condition of the plant.
For the last two months, I have worked at Zimmer as a contract employee on records for the heat and air conditioning system.
Before working at Zim.ner, I had several years experience as a' pipe draftsperson/ designer.
I prepared blueprints and Isometric Drawings.
.I had never worked.as a document reviewer at a nuclear plant, however.
Although.I was comfortable with the language and agg concepts, I learned the trade and professional quality standards on
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! E the job.
My " instructors" were the other emnloyees on the Kaiser
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quality' control ctaff.
There was a wide gap between their instruct-o y
icns and explanations, and the results I found in the course of my h
job.
i.'ih e n I. firs t be gan, if I wasn't sure I would write a Noncon-7 formance Report ("UR") to learn just how strictly to apply the ccdes.
om No AlthCusi.
~1.~ade early lista2c5
'l OUC ETO C C U )
- 2l00 1CC".0 d.. li c?
PDge,2, deviations must be strictly enforced.
The issues which I am rais-ing reflect design and blueprint flaws too serious to ignoro.
One problem that,I found consistently was inaccurate and'in-complete drawings or documentation for traceability of materials.
A few definitions are necessary.
ISK's and PSK's are both construct-ion aids for installation of piping.
They are the Isometric Draw-
.ings that everyone works from.
ISK's refer to small bore piping 2 inches in diamoter or less.
The ISK is designed on-site, where the piping is also fabricated.
PSKs refer to large bore piping designed by the architect / engineer, Sargent & Lundy (S&L) and fab-ricated by M.W. Kellogg, Inc.
PSK's are used to assemble the Kel-logg* supplied piping spools, which is a standard purchaso quanti-ty.
PSK's are also used to keep track of modifications to these drawings.
In addition to those construction aids, there are also the large formal designs, known as "orthographicDprojections", main-tained by S&L.
ISK's and PSK's are more than merely the construction aids for installation of piping.
They are also the only comprehensive field weld maps.
They identify the welds, describe the location and space occupied by parts that hold the wolds together, and refer to the KE 1 forms that supply history and traceability information.
- Together, the entire documentation package is supposed to pinpoint the loca-tion and full history of each material, part, component or weld in the plant for items designated as non-essential.
That is the theory. In practice, almost all drawings that I re-viewed had some error.
They were either incomplete or did not ac-curately reflect what was in the field.
Routinely the drawings were far too sketchy.
I sometimos had to work for a week to trace paitsi
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because the drawings were horrible..cFor instance, a prevalent prob-lem was that'the PSK's were on up to their seventh revision, and Kaiser had failed to' keep the previous versions.
This is a basic, minimum requirement.
It is very difficult to have an accurate parts history without a full revision history of the PSK.
The general ap-proach of Kaiser supervisors was to write as cryptically as pos-sible.
I know, because I was 1cacrant at first and I watched my co-workers and supervisors to learn the metho'ds of operation.
Sometimes the errors were relatively minor, lihc mixing up the weld numbers.
But even these errors can lead to more cignifi-cant problems later, if the weld were: questionable.
L About 50) of the errors I observed were serious, however.
For instance, on many occassions, the drawings did not accurately reflect the size'of the installed piping.
Due to the improper recording of I
the history. for a pipe, 'the drawings might say there are thirty feet, while in fact there are 50 feet.
In effect, the drawings would on-ly reflect the ori6 nal piping installed and miss the inserts of i
new piping.
I would supplement the drawings with notes that piping had been added, but I only saw a small portion of the total records and it was not routine to fill in those gaps.
I believe that full revisions are maintained for drawings being made now at Zimmer, but all the earlier records are suspect.
Other. procedural errors involved KE 1s, the weld documenta-tion forms.
They were as sliet'chy and ' inadequate as the drawin'gs.
The problems are inter-related.
Certain p.ortions of the form are filled in by welding engineers, who depend on PSK's and ISK's.
e But if the drawings haven't been revised and fails to reflect new
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pipin6, for example,s the weld', documentation form inaccurately iden't-ified where the welds are located and the identity of the items join-ed by that weld.
The inspectors are supposed to verify the. identity of items joined by the welds.
But frequently the space was left blank or just filled in from the drawing.
I made corrections as often as possible.
But I. estimate that on a least 100 occassions, KE 1 forms were too vague to be resurrected.-
The description would say that an elbow was welded to a spool, but not provide the loca-tion or heat number, for example.
Most of 50ls significant errors were due to oversights.
'But some of the flaws were too basic to have been missed, and many may have been deli-berate'.
Most of my examples involve bir. Arch Lanu ham of Kaiser.
He had formerly worked as a' QC Inspector and sug-gested dispositions of NR's for construction during my employment.
Mr. Lanham worked up'to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per week and paid close attention to detail.
With regard to the accuracy of his work, however, the staff had a standing joke about " Archie's pipe stretcher."
I believe that the following six examples of inaccurate design and traceability records involve _cliberate falsif;ca:icn or manipu-lation.
I came across these examples during my last year at the plant.
I have specific identification numbers and scme documents to support my charges, which : wil:. share with acvtrrtent authori-ties ready to act on the evidence.
Most of these examples also in-
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,s volve Mr. Lanham, but they are only illustrative'and based on my direct experience.
I do not believe that Mr. Lanham was especially better or worse than other Kaicer conctruction management.
I also want to emphasize that'the evidence of deliberate falsification is all circumstantial.
One case occurred when I prepared an MPP-1 form on a spool incpected and approved by Arch Lanham.
Each MPP-1 form covers one piping spool.
They contain the history of the pipe and direct the reader to further information on part traceability, cuch as PSK's, KE 1 forms and history of the part, as well as the formal decign documents on which the part chows up.
Thic UPP-1 involved the WR (closed water cooling) System PSK in the auxiliary building.
In reviewing the drawing and document-ation, I saw multiple impoccible claimc and statemento.
For exam-plc, the welding hictory indic'ated there-were two "c1bowc", or joints, inctalled'in five different locations.
[ut two elbows can only be installed in two placcc.
The records must have been delib-erately falcified.
There was never an UR on thic drawing, because I was able to re-construct and correct the welding history.
This is only one of many examples.
For two reasons, though, I now believe there chould have been come official record of the problem.
First, the improp-or initial approval chould be recorded.
Second, the example re-flects on the integrity of the whole cyctem, because the error was missed for so long.
At leact four or five QA people had reviewed the package an'd micced the error, which is not atypical.
The'QA ctaff were little better than temporary clerks who were mado avail-able for low wagcc but were not adequately trained.-
A second case came up on.a Friday in 1~979 Two inspectors and I saw that the heat numberc were ground off from flanges in the auxiliary building WR cystem.
I left my sketch and notec decerib-ing the problem on my deck over the weekend.
To remind myself to check on who had worked on the flange, I wrote "by" with an arrow pointing to a portion of my cketch.
This wac a cryptic note to myself to nelp follow throu.j.
.wl juut cer_co c 2.e.m e, anu it looked like "B'17".
The following Monday, I caw that a crude heat number that be-
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gan "BV7" had been center punched on the flange.
The number, which had not been there on Friday, was in the wrong location.
Most significant,,however, there is no such thing as a heat number code "BV7".
It doesn't exist and cannot possibly be correct.
It could only have come from my notes.
I suspect that someone had copied it off my sketch and stamped it in over the weekend, think-3 ing I had traced the flange.
This was another part originally and approved by Mr. Lanham. I do not believe the part has been traced yet.
j A third example involved a smaller piece of WR piping, 2i inches in diameter and four inches long.
An inspector and I look-ed over the piece.
There were no apparent markings but it was ac-cessible, so we scoured the pipe for a half hour.
Then we measured associated piping and elbows around it to see if the piece could have been cut from one of them.
Finally we wro't'e a [yog-conformanch report because the piping was untraceable.' Over the weekend, some-one took a white paint stick-a tooth-paste like tube that can ap-ply whi'te pain,t to mark almost anything in the field--and wrote fragments of an identification dumber on the piping.
The marks
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were similar but different in some respect from those on the draw-ing we had used Friday.
The same weekend those marks appeared, Arch Lanham turned in a new revision of the drawing for the pipe--
4 a " red line"--that contained the exact marks applied over the week-end.
The new " red line" drawing relocated welds and shuffled i-dentity marks in an attempt to " prove" where the short piping piece came from.
But there was no basis in fact for the changes.
It was not an ac, curate-reflection of the spools'.
i Further, it is improper to place marks such as these on a pipe l
after the fact of installation, and after the. identity of the piece has become indeterminate.
The identification cust be continuosly maintained in order to keep track of the parts.
I suspect that the red line was issued in order to provide consistent paerwork for the falsified marks added to the piping.
As I recall, the identity for the piccc in question subsecad cy the red linc and c. arkin 6s W&a impossible.
There was a small piece removed-from one of the spools but it was not long enough to be the piece in question.
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. A fourth example occurred after another inspector and I were reviewing eight inch diameter WR piping in the auxiliary build-ing.
We wrote an NR on an elbow when we didn't see a heat num-ber.
After we turned in the NR, a' construction crew ground'down arc strikes on the elbow.
Subs'equent to the grinding, someone placed new information on the elbow in an attempt to close out our NR.
The information hadn't been there before and was not supposed to be applied subsequent to construction.
They were warehouse marks.
The new markings were an orange stripe paint-
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ed around the elbow and a bright yellow number stamp.
The stamp and line were on the elbow when we next returned.
I knew they were falsified, because the markings were over the grindings for the are strikes.
Adjacent to the orange stripe you could al-so detect a small portion of the yellow paint left from a yel-.
low line, which had almost all been ground off.
I took Arch Lanham out to the elbow to di'scuss the new markings, where he identified the traces of the heat number we had missed.
I then realized we had missed the heat number orig-inally.
I was suspicious for two reasons:
He had disposition.
ed the NR by saying we had missed the markings.
This was al-so around the time of the "BV7" code marking.
Lanham denied ad-ding the new marking.
I believe the new marking was added in an attempt to discredit the quality assurance program.
The flourescent yellow-orange markings were so bright that we would have had to been blind to miss them, if they had been there.
In April 1981, I checked and the elbow was still there as I de-scribed it.
A fifth example was sparked by an NR on a non-traceabl,g spool near a heat exchanger, serviced by the (y/ater service)[ys-But 'he piping was tem.
The spool was cut out to be replaced.
t too rusty, full of mud and generally deteriorated to put in new welds for the spool.
The inspector wrote an NR, because there have to be at least two inches available for inspection behind the weld.
The interior of this pipe was too corroded to inspect.
Rather t..an implementing the profucional code for clean-liness of Clacs B piping, however, Kairer.cngaged in a make-shift response.
Construction ground down the inside diameter of.
i the rusty pipe and then reinforced it with two inches of weld-s
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ing metal to " satisfy" the inspection requirements.
This maneuver might have satisfied the letter of the rule, but the effect was deceptive-and circumven'ted the intent of the require-
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ments.
The final example was discussed in the NRC report.
It involved NR E-2191, where a heat number appeared on a copy of a weld rod issue slip but not the carbons after I issued an NR for lack of traceability.
I had searched all available copies
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of the weld rod issue slips and none had a heat number recorded.
Mr. Lanham told the NRC that he obtained the heat number by tel-ephoninF the weld rod shack.
That would not be an acceptable method of tracing the heat number.
The infordation has to be con-tinuously recorded, not reconstructed.
Further,. the explanation is hard to believe because it is doubtful that the weld rod shack.would have the information so long after the original inspection, years earlier.
The weld rod shack was not a reliable source for the' data, and could. only obtain'it through a cumbersome random search.
The NRC findings on this issue were inconclusive.
Ihat is a mystery to me, since I spoke with them for an hour on this NR and
. told them of relevant witnesses.
The report does not refer to inter-views with these~ witnesses.
J These examples illustrate a systematic breakdown of the de-sign and traceability documents at Zitmer.
For example, there was a rampant problem of construction modifications being incorporated into the informal drawings before formal design modifications were tppreved.
The formal desicn is cupposed'tc ref1cet the plan "a7 built."
4 M
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Page/8 For a year betwoon 1979 and 1980, 1 prepared and reviewed NPP-1 forms.
At one point I had reviewed or prepared every NPP-1 for essen-tial piping at the plant considered to be valid.
The drawings and doc-umentation packages were so sketchy t' hat it was impossible to es-tablish unique identification and' traceability for all materials and wolds in essential piping.
The Authorized Nuclear Inspector (ANI) at Zimmer told me that unique traceability is required by Section III NB-4122 of the American Society of Vielding Engincors (ASME) code.
I felt that the lack of traccabili'ty forced me to make assumptions in preparing NPP-1s for c' mall boro piping that '
compromised my integrity.
As a result, on October 28, 1980, I submitted Surveillance Report (SR) 2819, requesting a written di-rective telling me to make those assumptions, as well as a re-evaluation of all small bore isometrics material traceab'ility doc-umentation.
(SR 2819 is attached as Exhibit 1) l SR 2819 essentially stated that the drawingsprovided over-l coneralized identification of the. materials pictured..
There-would be one identification for multiple items welded together, when I
there should have been a unique identification and parts history for each item.
As a result, you would have to, assume that the same heat number applied to a serics of different parts.
That was an improper leap of faith.
SR 2819 also challenged the Kaiser tradition of accepting lack of unique traceability for in-house ISKs, when that same 'de-fect in a PSK would lead to an non=comformance report.
The pro-foscional code does not distinguish between ISK and PSKs however, and neither did the Kaiser manual.
The training procedure at Zim-mer and the common routine was to accept a lower standard for the drawings done in-house.
The challonge of SR 2819 was fundamental.
It addressed all of the sm'll bore piping fabricated on-site--hundreds of draw-a ings, thousands of items and miles of piping.
Ylhon I wrote SR 2819, Mr. Phillip Gittings, the Kaiser Quality Control Manager, was so angry that he could barely speak.
He emphatically inform-ed to that I v;ould not roccive the requested directi've to make the questionable accumptions.
- Ie ached me if I knew what I had written and inquired if I would like to rescind it.
I responded, "I know that report could cost a billion dollars, but you guys
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brought it on yourselves and it had to be written."
I was ex-aggerating about.the cocts, but they would be extremely signifi-cant.
He did not answer and I left.
Mr. Floyd Oltz, my cuper-visor, later orally told me to continue the old procedure.
But the SR was never returned to me with the required response for corrective action.
The utility night respond that if there is a problem with a heat number, repair crews could simply go back to every item with that number.
Besides failing to meet the unique identity and traceability requirements though, this would skyrocket the costs of.repairc later.
For instance, a vendor might Adentify a prob-lem with 1000 feet of piping that has a specific heat number.
Becauce the 1000 feet with that heat number were mixed in with 2000 foot of other piping, however, repair crews would have to reinspect all 3000 feet.
You couldn't pinpoint the defective piping, so blanket repairs would be nececsary.
This could be ex-tremely costly and dangerous if the crews were working in a rad-ioactive environment after an accident or when the plant is in operation.
SR 2819 did not imply that bad components or materials were installed.
What it meant was that we cannot specifically identify wha't has been installed and where.
Since I have not heard anything further, I assume that the utility is going to let the problem ride as a gigantic loophole in the new Quality Confirmation' Program, supposedly the final word on cafety problems.
That 'could be unfortunate.
I deceribed SR 2819 in detail to the IGC in;cc"..eatera and pr6 viced them with a copy of the report.
While the report referr briefly to SR 2819'
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0 y
however, it does not resolvet the issue.
In factie the NRC rh ;,
port does not even describe the substance of SR*2819 DuringthatlastsixmorNhsofthistimeper'iodIchal-
'p lenged another case of non-exii. stent traceability.
This time the failure involved small bore NX*, hangers which are clamped over thd small bore piping.
There are thousands of them used to hang the small bore lines.
Management did not realize that the han-d
!gers had to have traceable; material and that led to tremendous f
problems.
Y,/
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The NX hangers had material traceability when purchased,
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but were not union-made as required.
As a result they were thrown into a scrap heap and re-fabricated on-site, Mith union labor.
Unfortunately, no one kep.t; track of the heat numbers and trace-ability was lost permanen ly.
As a result, those hangces might
.I as well be garbage.
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I raised the tracea ility challenge at alineeting.
Mr. Black-4 wood, a top Kaiser constrdction official,' responded that my charge y
was " ridiculous ".
He said there were only caifew hangeEdSvith any problem and suggested that[I just look.
I fact, I had already looked at several hundred hangers, as well as the scrap Teap
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where the, hangers were piled before re-fab'rication.
He was wrong.
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r e
I believe that his answer was deliberately false.,
It istnot ap-propriatetoexplainitawayasidnorance,sinceIhadfirst raised the issue several weeks earlier.
Lack of traceability for the hangers was a' common topic of discussion.
l l
Although I only have direct kncwledye of desien pro w -s, many other employees whom : believe to be tredible witnesses have discussed other issues which I believe sheuld be thorcqhly ce;v-
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ered by any legitimate Quality Confirmn.ticn Frecr g.
In gsner 1, l
i the method of' operation at Zinmer was to make repairs informal-
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ly'/ but not to bother documenting the problem and creating rec-ords.
Problems can get overlooked that way.
All of these areas 3
sh'uld be investigat,ed thoroughly to prove that corrective.ac-o tio'n was properly completed:'for all informal repairs.
For instance, I understand that failure to-apply a hold tag 1
on questionable piping was an issue in the Applegate allegations l'e,
at Zinmer.
For around a year, after late 1978, hold tags were i
generally not used in practice at Zimmer.
The ommission was so routine, that I failed to issue around 100 when I wrote NRs.
I yv
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did'not apply hold tags in those cases because no.one had ever d /
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told me to, although I later learned the tags are required.
- Now, t
I realize that_due to the oversight there is gesignificant pos-T sibility,that problems were over-looked.
Hold tags go on a 4
punch list and provide a permanent record.
There was a big con-1
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troversy about the routine, and now hold tags are applied.
But I am not aware of any effort to identify all the relevant causes 4
and locate the hardware for the hold tags omitted during previous years.
I Another issue that should be checked is the up-grading of non-essential components to essential status, which means the safe shut down of the plant depends upon their proper function.
ing..To illustrate the nature of the distinction, a 316 L Stain-less non-essential elbow is the same as an essential elbow, ex-1 cept the latter has been subjected to a Non-destructive Examin-l ation (NDE).
Therefore, it can be relied on in a critical situation.
I The NDE doubles.the' price, however, and'can only be done b?.ah l
d)
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approved vendor.
At Zimmer there were efforts to upgrade components on-site, to see how much the NRC'would permit.
It is seldom possible to upgrade a component legally, unless the vendor voluntarily is willing to supply the testing documentation for free.
I cannot supply specific examples.
But this practice was a common topic of conservation among plant em-ployees.
The Quality Conformation Program should address it comprehen-sively.
The distinction between essential and non-essential parts were sus-pect to begin with.
The differences were nebulous and poorly defined.
For instance, a heat exchanger system is essential, but the individual pipes carrying water as part of the system are non-essential.
The NRC report referred to purchases from non-approved vendors.
The author showed a talent for under-statement.
For example, one non-approved vendor was a junk vendor, which sells used steel from de-molished buildings or left over from other jobs.
The junk vendor sup-plied Zimmer with a quantity of steel structural beams in the primary containment.
I do not have direct knowledge of how many beams were in-volved.
But eyewitness employees told me that there were a lot.
That would mean at least a truckload, or up to 100 beams.
Those beams all should be cut out, and the QCP should re-inspect every item purchas,ed from a non-approved vendor.
l There are many sloppy or out-dated construction practices which should be covered in the QCP.
To illustrate, I was an eyewitness when l
a welder had a heavy fan on while he was applying gas to shield the weld 1
(
from oxidation during installation.
This was in the suppression pool. -
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I t may explain rn;. some steel pl n:r fell cui at thc suppression pool t
l after being welded.
One plate actually cracked and fell off.
I learned of ancther ine' -
thnt thou2c f': mc0 throufr frcr 5-four or five reliable sources, including a hydro-test engineer with
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g, a
N
' years of experience.
This incident involved the RPV-1 (Reactor Pressure i
Vessel) hydro-static pressure test.
The test was a major event that lasted a week.
In the process, some seals were blown and wat'er spew-ed out.
This violates a significant requirement on how fast the ves-i sel can be de-pressurized.
The witnesses did not think the incident was written up, however.
CG&E was fully aware of all the events surrounding the test.
Another area that must be covered involves seismic criteria for protection against earthquakes.
Over the years the hangers and electri-cal. conduit trays were re-evaluated as the critoria were up-graded.
Now, if trays are not seismically hung with adequate reinforcement, theymustbeseparatedbyminimumclearancecriNeriauptosixinches.
But many non-seismically hung trays are actually touching each other.
I have been informed at the plant that little of the re-work has been done, because most of the relevant trays have not yet been properly i-dentified.
This issue reveals the magnitude of the necessary re-work offort if CG&E is serious about the Quality Confirmation Program.
It could add 5% to the construction time to redo all the trays.
The only way that Zimmer could be 97% complete is if the rules are changed to eliminate seisdic criteria requirements.
The problem is almost too basic.for an l
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'NR.
.There should have been a 100% review after each revision of the i
criteria, bu't that hasn't occurred.
It would be difficult to miss if the effort were underway.
I estimate that it would take 24 people a -
year to reinspect the. seismic criteria once, and CGLE hasn't undertaken i
l that type of effort.
t As a final exauple, the QCP should thoroughly trace and double-check employee qualifications and' reinspect all work performed by those I
whose resuces are suspect.
The quality of work may be ac cuspect ac their resumos'.
A Kaiser piping field engineer illustrates how unquali-a
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1 ified employees might be in key positions.
This individual was super-vising employees.
But he was unable to distinguish between a logic diagram and a drawing }eflecting physical configuration.
I cannot i-magine how this individual's resume could be accurate, because this i
is a kindergarten level of knowledge for a piping designer or en6 neer.
i The engineer is still at Zimmer.
Similarly, in late 1980, the " shoppers", or contract Quality Control personnel, were all laid off.
This led'to suspicions about the-
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qualifications and reliability o-f their replacements.
The employees t
of (the shoppers) were highly trained and independent.
They were aware j
that Kaiser and CG&E employees were not their superiors, which is how it should be.
In general, I have observed that CG&E is using improved quality control for new construction and has made a top priority of repairs necessary for fuel loading.
The utility is also doing good work to 1
i repair many specific defects identified by the NRC report from last No-vomber.
But CG&E is not looking carefully at anything else, such as the 1
i general problems underlying specific examples or the massive inaccuracies 4
of the earlier drawings or blueprints.
In some instances, that will be impossible, since the records have been long discarded.
l For repairs other than the top priorities, the. standard ingtru,ction' is that we will repair or work on the problem after the fuel is loaded and the operating license is obtained.
In my opinion, all of the sig-nificant problems must be addressed now without waiting or procrastina-ting anymore.
The safety hazards are liable to get lost in the shuffle, and will only be acre difficult and expensive to repair later.
t I only signed one statement in the 1961 J'RC i'nvestigation.
There were two other detailed visits however,.where the NRC investigators took notes but did not preparc r rtatcment fcr ny c ";ture.
Mr. Jir
-_ ___ _ J_ __ _ _. _ _. _, -
~ur3cmrs 1-sDcCa'rton was the primary investigator for the first visit.
- r. Jim l Foster was the primary. contact for the second and third. interviews, which-were frou four to.six ponths after the 1~. arch 25 statement I signed for i
l'.r. M cCarten.
The URC investigators ashed for permlacion to record our last interview, a short phone interview, and send-it to the Federal Bureau of Investigation.
I agreed but have not been contacted by any law en-forcement officials.
The NRC report alludes to only a small portion of the information
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I provided.
It only discusses in-depth two NRs where I.could offer l
specific identification numbers.
But I told the liRC cverything in this affidavit and expressed my stron6 c'oncern a)out these issues.
To illustrate how much is missing, I wrote,soccwhere between 200 and 300 URs during my.last year at Zimmer, co'mpared to the two NRs cov-i cred in the report.
During the third interview I asked the URC invectigators how bad Zimmer is compared to other nuclear power plants.
One URC man said he had thought another plant was worse, "but after what we know now I'd say Zimmer is."
Another URC investigato responded, "I'd give them a D-minus for records."
In spite of these opinions, the NRC investigators d'id not ask me directly, or even vaguely allude to CGDE's knowledge or cocplicity in the' quality control violations and shoddy construction practices.
In.
fact, I couldn't have provided much direct information, because I on-I ly personally dealt with CGSE employees rarely during my time as a i
c3; docuuents reviewer.
Despite the lack of first hand kncpledge, I would bct my life that CGDE knew all about the quality control inspection, drawings and traceability problems.
Everyone else on-site.as aware of.the problems.
Pagp'16 C
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tocause they were extremely controversial.
I do not know if my understanding of these incuec is complete.
Kaiser management let me know that my efforts were not appreciated, and Mr. Lanham perconally reprimanded me.
However, no one ever told me I was wrong.
Similarly, I do not know the full cignificance of my information.
I' But if incomplete, inaccurate designec and, drawings are, important.,,
at Zimmer they are grossly bad becauce the licencee was, at boat, grocaly negligent.
I have read the above 16 page statement, and it is true, accurate and complete to the best of my knowledge and beliof.
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Richard L. Reiter j(b i:1L
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