ML20077P546
| ML20077P546 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/30/1991 |
| From: | Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA, NATIONAL WHISTLEBLOWER CENTER |
| To: | Selin I, Taylor J NRC COMMISSION (OCM), NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| CON-#391-12075 2.206, OL, NUDOCS 9108190026 | |
| Download: ML20077P546 (21) | |
Text
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- a cam-ti g g,= % a u 4 0.t9 'f D =wh July 30, 1991 Hon. Ivan Selin, Chairman Mr. James M. Taylor, Executive Director for Operations United States Nuclear Regulatory Commission Washington, D.C.
20555 Re:
10 C.F.R.
S2.206 Request to Evaluate Material Filse Statements Made on Behalf of Texas Utilities Electric Company During Licensing and Construction Permit Amendment Proceedings held Before an Atomic Safety and Licensing Board, Docket Nos. 50-445 OL; 50-446 OL; 50-445 CPA I.
Allecatip_DH The National Whistleblower Center
(" Petitioner") hereby requests on behalf of itself and certain confidential allegers working with the National Whistleblower Center that the Nuclear Regulatory Commission ("NRC") determine whether Texas Utilities Electric Company ("TUEC") repeatedly submitted material falso statements to the NRC.
The intentional making of material falso statements to the NRC and intentionally hiding relevant information from a NRC Atomic Safety and Licensing Board ("ASLB")
demonstrates that TUEC did not, and does not, have the requisite character and competence to operate and construct a nuclear power plant.
Specifically, the continued safe operation of the CPSES
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a, s-cannot be guaranteed inasmuch-as high-level managers currently employed at the CPSES do not have the integrity needed to operate and' construct a nuclear power plant.
In this regard, Petitioner asserts that because CPSES managers were: 1) willing to submit material falso statements to the NRC in order to obtain a license to operate Unit 1 of the CPSES, and 2) in, fact, did submit materialffalso statements in order to conceal significant safety flaws in the design of the-CPSES pipe support system, then it stands to reason that those same managers pose a current safety threat inasmuch as they are capable of submitting material false l
statements in order to conceal significant safety problems at the CPSES.
Specifically, Petitioner makes the follows allegations:
1.
During the construction of Units 1 and 2, TUEC engaged in overt fraud and deceived the NRC about the method used to certify pipe supports; l
l 2.
During the construction of Units 1 and 2, TUEC submitted material falso statements to
-the NRC in order to cover-up and further an
' illegal practice used to certify CPSES pipe supports'in violation of 10 C.F.R. Appendix B requirements; 3.
The individuals responsible for and who assisted in covering-up the illegal certification process continue to be employed by TUEC andLhave played and continue to play critical engineering and quality _ assurance roles at the CPSES.
4.
Essential evidence in the CPSES Construction Permit Amendment proceedings concerning intentional conduct resulting in a delay in constructing Unit 1 of.the CPSES was intentionally kept from the ASLB by TUEC, CASE and NRC Staff in violation of a pending request by the ASLB to to kept informed of 2
II.
Facts In the late 1970's the NRC convened an Atomic Safety and-Licensing Board (ASLB") to adjudicate licensing issues related to TUEC's request to construct and operate the CPSES.
Parties to the ASLB licensing proceedings included NRC Staff, TUEC, and, eventually, a single citizen intervenor group by the name of Citizens Associated for Sound Energy (" CASE").
In 1982, CASE beaan to present the ASLB with testimony by two former CPSES engineers, Mark Walsh and Jack Doyle.
Messrs.
Walsh and Doyle advised the ASLB that TUEC had designed CPSES pipe support system in violation of NRC requirements.I
A major area of concern raised by Walsh/Doyle related to the organization and design interfaces of the CPSES pipe support design groups.3/
One of the concerns raised by Messrs. Walsh and Doyle centered around the organizational and design interfaces between the various pipe support design groups.
Specifically, they were concerned that a lack of coordination between the three pipe support design organizations jeopardized the safety of the CPSES pipe support design because the three pipe support design groups were using a different set of design criteria when designing the pipe support system.
1/
NRC Staff responded to the Walsh/Doyle concerns by filing a Special Inspection Team
(" SIT") Report 82-26/82-14 on l
February 15, 1983.
The SIT Report was subsequently submitted into the record of the ASLB proceedings as Staff Exhibit 207.
2/
Up until 1985, three design organizations were, for-the l
most part, responsible for designing and certifying CPSES pipe supports; they were Nuclear Power Services, Inc. ("NPSI"), ITT-Grinnell ("ITT-G") and Pipe Support Engineering ("PSE").
3
.l During the ASLB proceedings witnesses appearing on behalf of TUEC and NRC Staff testified before the ASLB to defend the use of
-multiple sets of design criteria by the three pipe support design ll organizations.
One of the critical witness testifying on behalf of TUEC was Mr. John C. Finneran, Jr.3/
During the ASLB proceedings, Mr. Finneran testified as follows:
...The changes made (to the pipe support designs) will go to the oriuinal desian oraanization and they will review it and make all their own calculations for that change...I might point out that after the final review of these drawings, they are stamped and signed by an engineer with the oricinal desian oraanization...After all the field changes are incorporated in the drawing and the drawing goes through final review from the as-built loading, the drawing will-be stamped and signed certified by the oriainal desian orcanization...[E]ach organization that designs supports will be responsible for certifying that the support is good for the as-built loads...[These organizations) would be ITT Grinnell, NPSI...and my organization, Pipe Support Engineering.
ASLD Tr. pp. 4971, 4985-4986, 5013 (emphasis added).
The Chairman of the NRC ASLB panel, Hon. Potor B.
- Bloch, summarized his understanding of Mr. Finneran's testimony and the other evidence submitted to the ASLB as follows:
l l
... Staff was relying primarily on the notion that the l
major groups had to be properly coordinated...
(C]oordination is necessary so that each major design L
organization knows what it is doina, and what it is responsible for...We are talking about design interfaces, as I understand the interpretation of the Staff.
That is, places where the groups might be working on areas of the plant where they have to know how the work of one affects the work of another, but i
i l'
Mr. Finneran is currently employed at the CPSES as TUEC's Manager of Civil Engineering.
4
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where the responsibility is cigarly defined _thgrg_in 4
no necessity to talk about overy interface that occurs within the arouns...The responsibility _11D5195-_tha tagtilgony was clearly af.aigned to each of the three supoort eine ar_qupn_...They don't losq_,any I.esponsibility for the' accuracy of desian.
ASLB Tr. pp. 6985-6989 (emphasis added).
On December 28, 1983, the ASLB, relying upon the evidence presented by TUEC and NRC Staff, issued a Memorandum and Order
("M&O").
This M&O'specifically addressed the Walsh/Doyle concern regarding the impropriety of the organizational and design interfaces betwoon the different CPSES pipe support design groups.
Egg M&O Section IV(1).
The M&O explained its reason for dismissing the Walsh/Doylo concerns regarding the interface betwoon the three pipe support groups as follows:
An early decision was made by the Applicants that pipo support design would be contracted out to companion who are in the business of designing and fabricating pipo support components.
In order to satisfy ASME. Code
-roquirements...it was necessary to provide them with the overall design critoria to be mot.
The... document which accomplishes this objective was Specification MS-46A.
Contracts for the design of pipe supports at CPSES (Comancho Peak) were awarded to'ITT-Grinnell and NPSI.
In addition, Applicants created what became the PSE-(Pipo Support Engineering Group), which also utilized Upecification MS-46A.
Since neither Specification MS-46A nor the ASME Code dictato in detail thu means by which an engincor is to satisfy the design critoria, differences in engineering approachos occurred betwoon the three parallel pipe support groups. (Staf'f exhibit 207 [ SIT Report) at p.
12; Applicants' Exhibit 142, p. 9).
The fundamental issue for this (ASLB] Doard to resolvo is whether those differences in design approaches represent'a safety or engineering concern, or it they violate any HRC regulations, Staff guidance or other NRC-ondorsed standard...
5
., _... _. ~
~- _ _ _ _
u 4
The evidence establishes that each of these threq oine suonort desian oraanizations has its own soecifiq scone _of responsibility since each has been assioned the responsibility for a soecific group of supports.
(Staff Exhibit 207, p.
13; Applicants' Exhibit 142, p.
9).
There is no need_for cross communication between the three aroups INPSI. ITT-Grinnell. and PSE1 sinc 2 they share no common. in-line desian resngnsibility...
The Board concludes that the Applicants have adequately defined and documented the responsibilities and paths of communications between...the pipe support design groups.
No NRC regulation has boen violated, and the programmatic objectives...have been satisfied.
(Staff Exhibit 207, p.13)
M&O at pp. 67-68 (emphasis added).
Although Section IV(I) of the M&O dismissed the Walsh/Doyle allegations regarding the design interfaces of the pipe support groups, the M&O generally observed that serious " doubt on the design quality" of the CPSES existed.
E22 M&O at p.
1.
In an attempt to resolve the doubts raised by the ASLB, TUEC began to submit a series of motions for summary disposition with the ASLB.
TUEC often repeated in the affidavits and text of these motions for. summary. disposition the same type of factual assertions which led the ASLB to conclude that the certification process being employed by the three pipe support groups.was acceptable.
For example, Mr. Finneran states in one such affidavit that:
As I previously testified...desian chances are subiect to
-review by the responsible desian orcanizations.
(Tr. 4970-71).
See Affidavit of John C.
Finneran, Jr. regarding Stability of Pipe Supports and Piping Systems, dated June 17, 198__ at p.
14 (emphasis added).
In another affidavit submitted in July of 1984, Mr. Finneran 6
4 (and other affiants) reiterated that he three design organizations (NPSI, ITT-Grinnell, and PSE) had "sperate and distinct responsibilities for the design of pipe supports" and all design changes are " returned to the original designer for correction and rechecking..."
EER Affidavit of D.N. Chapman, J.C.
Finneran, Jr.,
D. E. Powers, R.P.
- Deubler, R.E.
Balland, Jr.,
and A.T.
Parker regarding Quality Assurance Program for Design of Piping and Pipe Supports for Comanche Peak Steam Electric Station, stated July 3, 1984, at pp. 13, 36.
By 1985 TUEC's effort to design the CPSES pipe support system remained plagued with design deficiencies.
At this point in time, the construction permit issued to TUEC by the NRC to
. construct the CPSES expired.
When TUEC sought to renew its permit, the NRC decided to institute Construction Permit l
Amendment ("CPA") proceedings.
The contention admitted in the CPA proceedings was as follows:
The delay of construction of Unit 1 was caused by.
Applicants' intentional conduct, which had no valid purpose and was the result of corporate policies which have not bee discarded or repudiated by App 1!. cants.
- Ege 25 NRC 912, 919 (1987).
i In 1985, a former-senior pipe support design engineer L
stationed in the NPSI pipe support group, Mr. S.M.A. Hasan, met with CASE President Juanita Ellis and CASE attorney Billie P.
Garde and explained, inter alin, how pipe supports were being i
transferred between the various pipe support groups and were certified using multiple sets of design criteria.
CASE then
-agreed to represent Mr. Hasan before NRC Staff and arranged for a 7
_ _____. _.~,.__ _ _ ___
4 grant of confidentiality.
On January 10, 1986, Mr. -Hasan, NRC Region IV Staff, and Ms. Ellis met.
During this meeting, Mr.
Hasan raised a series of allegations, which were transcribed.
At this time Mr. Hasan stressed to NRC Staff and CASE President Juanita Ellis, that (contrary to what was stated to the ASLB regarding the process used to certify pipe supports in the various pipe support groups) pipe support design packages were routinely transferred between the.three pipe support groups and 1
certified using multiple sets of design criteria.6/
Mr. Hasan specifically alleged to the NRC at that time Mr. Hasan advised NRC Staff:
... Dave RencherIl took the package from us and got it passed in another group.
I just ask_NRC, is this engineering?
Just because we could not qualify a particular pipe support package based on the criteria given us... [ Dave Rencher) said, ' Don't worry.
Give me the package back.
I will get it passed in another group.'
Because they were using another criteria.
And they got it passed, certified, and gone....Quite a number of times I got a package we could not qualify it, and we used to write a memod/ to Jay Ryan,' chief engineer [within the PSE group], telling him that this support is failing under NPS criteria... [a]nd they used to pass it.
Excerpts of the January 10, 1986 Hasan Interview are attached hereto as Exhibit 1.
il This allegation was germane to the CPA proceedings inasmuch as, if true, it establishes that between 1982 and 1985, TUEC had intentionally submitted material falso statements before the ASLB which contributed to a delay-in.the construction of the i
1/
Mr._Rencher was the CPSES manager of the NPSI group.
1/
Attached as exhibit 2 is a copy of one of the memos addressed to Mr. Ryan that were used to transfer pipe support p
packages out of NPS and into PSE.
i 8
-. ~.
Mr. Hasan went on to file a Section 210 proceeding against his former employer,-NPSI, and TUEC and Stone & Webster Engineering Corporation'("SWEC").
Sgg Hasan v. NPSI, __et_gl.,
86-ERA-24.
During the course of the HasaD proceeding, evidence in the form of testimony by Mr. Rancher and another pipe support manager, Mr. - George Chamberlain, demonstrate that TUEC was-involved in the intentional trannfer of pipe supports between the various pipe support groups and, as such, the testimony TUEC had repeatedly presented to the ASLB that pipe supports were not being transferred between the various pipe support groups and were not being certified using multiple sets of design criteria constitute material falso statements.
III. Evidence Establishing that TUEC Made Material Falso Statements before the CPSES ASLB On June 22-23, 1987, the Hasan Section 210 case went to hearing.
Attending the hearing were counsel to TUEC and Ms.
Juanita Ellis, President of CASE.
On July 8, 1987, Ms. Ellis notified the ASLB that CAL considered "some of the testimony in (the Hasan] proceedings of such potential significance to...the construction permit proceedings that Applicants should voluntarily provide copies of all pleadings, documents, etc., in that case to_the Licensing and CPA Boards."
Eeg July 8, 1987 Letter from Ellis to NRC ASLB, filed and on record in the ASLB proceeding.
The most significant evidence to be' aired during the Hasan proceeding concerned the practice TUEC was employing on site to design the CPSES pipe support system.
Specifically, the on-site 9
-. -. -. - - ~ -..-.
^
manager of-the NPSI group, Mr. David Rencher,-testified both at his deposition:and during the hearing that pipe supports were routinely transferred between the various pipe support groups and
. wore routinely certified using more than one set of design criteria.
In this respect, Mr. Renchor testified under oath in a deposition prior to the commencement of the linnan hearing as follows:
Q (Were you aware that) the NPS group was rejecting PSE supports during the certification process?
A Yes, I was aware of that.
Q Were you aware of that in 1983?
A Yes.
Q
...in 19847 A
Yes, sir.
-Q
...in 19857 A
YGs.
I
(
Q The NPS group was rejecting PSE packages during the certification process, right?
A Yes.
Q of these that were being rejected, were they over then recalculated under different criteria?
L.
A Yes.
Q And then they were certified after they were recalculated under different criteria?
A Yes.
Q Are you aware whether or not Mr. Hasan could not certify...some of the pt.ckages he was checking?
10 1
+
_.. ~..
.A
. 11 0 could not cortify some of the packages because of the NPS critoria on Richmond insorts, yes.
Q Did you take those packages to tho-PSE group for cortification?
A Those supports woro rejected to the PSE group.
O By 'rojected to the PSE group,' what do you moan?
A Well, he attached a memoll to it from my group to the PSE group saying the supports were rejected for the following reasons...
Q And would the PSE group then cortify the packagos...
A
...yes.
Q And they could do that because PSE was using different criteria than NPS?
A Yes.
Ronchor Deposition Testimony Tr. pp. 78-81, 96-97.
During the Ungan hearing itself, Mr. Ranchor reitorated this testimony:
o Q
[W)ero you awaro whether or not Mr. linsan rejected Mr.
-Ryan's. pipe support engineering group [PSE) pipo supports whilo working in you group [NPSI]?
l A
There were' pipe supports that woro rojected out'of my
(
group,_ and I am certain Mr. Hasan had reviewed some of thoso.
O And they woro coming from Mr. Ryan's group?
A
-Yos, they were.
l.
Q
_(WJould liasan attach a memoDI to (the PSE packages he L
was rejecting while in Rancher's NPSI group]?
A Yes.
lb2 pan v. NPSI. et al,,,
lloaring Transcript at pp. 120-121.
Alag Z/
Egg Footnote 6, supra.
II San Footnote 6,
- Supra, i
11 l
l
_. ~,
+ ;
4 agg Tr. pp. 125, 130, 239, 275.2/
In essence, the evider.co elicited during the llaEAn Section 210 proceedings demonstrated that the interfaces between the various pipe support groups were not separate and distinct; rather, the pipe support groups were routinely transmitting pipe support. packages back and forth and certifying individual pipe supports by groups using different criteria from the criteria used when the support was initially designed (i.e. certifying individual pipe supports using nultiple sets design criteria).
IV.
Evidence Establishing that TUEC Intentionally Withheld Significant Evidence from the ASLB in Violation of ASLB InstructlanE_
During the course of the Hasan Section 210 proceedings, testimony from the on-site manager of the NPSI design organization, Mr. Rencher, from another manager, Mr.-George Chamberlain, and from two pipe support engineers, Mr. Hasan and 2/
A.lso see Rencher Depo. at p. 247 (wherein Mr. Rencher was-asked to comment whether it was true that "...if supports did not meet the appropriate design criteria using the NPS design specification, the supports were sent to another pipe support design group, such as PSE, and would be considered acceptable using different design criteria..." to which he answered with an unqualified "yes").
Alps see Deposition of george Chamberlain at p.
95, (wherein Mr. Chamberlain, a manager within the pipe support design area, was also asked to comment on whether
" supports were sent to another pipe support design group, such as PSE, and would be considered acceptable using different criteria..." to which he responded: "[S)ome companies did not have criteria addressing certain types of design.
For example, ITT-Grinnell did not have criteria addressing the Richmend insert tube steel design.
If [a pipe support] got redesigned that way, then we would typAsJer responsibility for that hanger from e
' Grinnell to the site engineering group (PSE]."
Indeed, Mr.
Chamberlain went as far as to refer to the practice of transferring responsibility of the various pipe supports as the "go around".
Chamberlain Deposition at p. 190).
12
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_.._.~.-., _ _-
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Mr. K. Ravada confirmed that pipo supports woro routinely being transferred betwoon tho various pipe support design groups betwoon 1982 and 1985.
Moreover, the record before the ASLB demonstrates that at no tino was the ASLD over advised of thin fact.
The record before the ASLB further establishes that although TUEC's counsel know it had an affirmativo duty "to apprise the Board of developments which boar on matters beforo-it...,"
ggg January 30, 1985 from TUEC attornoy Nicholas Reynolds to ASLD; niet.nca March 21, 1985 lotter form TUEC Robert Wooldridge to ASLB (noting a requirement that TUEC " comply' with the Board's request that Board members be kept timely informed of matters relating to the licensing" of the CPSES).3/
Without question, the testimony clicited during the course of the Hasan Section 210 proceedings barca directly upon the contention raised in the CPA procoodings ("The delay of construction of Unit 1 was caused by Applicants' intentional conduct, which had no valid purposo and was the result of corporato policies which have not boon discarded-or repudiated by Applicants").
Nothing could prove this contention bottor than to be able to show that all the while TUEC was telling the ASLB that pipe supports were not routinely transferred betwoon pipo support groups,-the fact was that the pipo supports woro 3/
In this respect, CASE wont as far as to adviso the ASLD
- that TUEC was not complying witn its responsibilities to the ASLB-by its failure to notify the ASLB about matters raised in the Eqnns proceeding which woro "of extremo importance to both the operating licenso proceedings and construction permit proceedings."
geg July 8, 1987 letter from CASE President Juanita Ellis to the ASLD.
13
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routinely being transferred between the various pipe support groups.
This is the very allegation that had been explicitly raised-in the briefs submitted on behalf of Mr. Hasan.
Copies of those briefs were provided to TUEC's counsel, to CASE via Ms.
Billie Garde, and to NRC Staff.
The fact remains that the ASLB uns intentionally misled about this allegation.
With respect to the allegation of the intentional withholding of evidence from the ASLB, Petitioner hereby incorporates the facts stated herein with the allegations set out in a confidential letter dated October 5, 1990, set.to NRC Region IV Office of Investigations.11/
Petitioner respectfully requests that the identity of the alleger and the contents of the October 5, 1990 letter and attachments thereto romain confidential.
Nonetheless, Petitioner requests that this information be considered when rendering a decision with respect to this petitioner.
V.
Eglief Recuested WHEREFORE, Petitioners requests that licensing hear ngs be held to determine whether TUEC has the requisite character and competence to operate a nuclear power facility.
FURTHERMORE, P2titioners requests that TUEC be fined and otherwise penalized for-submitting falso statements to the NRC 11/
A formal confidentiality agreement was entered into covering the information provided in this October 5, 1990 letter.
Petitioners are willing to work with the NRC to provide much of the 3,nformation contained in the October 5, 1990 letter on a non-confidential basis.
14
i and ASLB.
FURTilERMORE, Petitioners requesta that an inventigation be conducted to determine whether 11RC Staff learned of the cxlutence of these material falso statements, yet failed to act upon this knowledge.
FURTilERMORE, Petitionero requesto that the 11RC determine which high-level managers were responsible for submitting material f also statements to the ASLB and llRC and ban these individuals from the CPSES and all other licensed nuclear facilities.
Respectfully submitted, Michael D.
Kohn KOllN, KOHti & COLAPI11TO, P.C.
517 Florida Avenue, 11. W.
Washington, D.C.
20001 (202) 234-4663 Councol to the 11ational Whistleblower Center Dated:
July 30, 1991 15
l
);
1 a :.
\\
(CONFIDENTIAI, treatment requested; agreement 2
signed.)
._m, 3,
3 J V 8
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- A-
)
i 4
EEEES3EEEE 0
l U.S. NUCLEAR REGUIATORY COMMISSION 7
and i
f.,
8 CITIZENS ASSOCIATION FOR SOUND ENERGY 9
January 10, 1986 10 11 Marriott Hotel, Seville Room 12
'F 2101 Stemmons Freeway 13 Dallas, Texas
?
14
'D0h0tDSCLOS1 is 16 17 18 19 20 f.,
j, 0% T "
21 REPORTER:
Sandra Harden 1
22 CENTRAL REPORTING AGENCY 2800 Buena Vista 23 Arlington, Texas 76010 (817) 640-1553 4
24 EXHIBIT -
?<
25 PAGE 05 9
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9-
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l
..1-11R. FERRAR2NI:- :Ir. the restrained direction,
N v
.J.-
2 okay.
n' 3
e 01R. DASAN:
Exactly.
i 4
MR. FERRARIU2:
Okay.
S 5
MR. HASAN:
Now, another coint from documenati 6
. point of view or.from engine'rina noint of view, we have cet I
e r ;
7 only one pro-ject, we should have only one procedure of dealir :
8 with one particular item.
Very ninole comnon sense.
i s
L 9 l I do the number at least one cice sumort fu).ng Jl 10 badly under the so-called NPS-criteria.
Dave Rencher tect ti r
I:
j'
.ll l packann fron us and got it nassed in nr.other aroun.
l.
12 2 just ask NRC, is this enaineerinc?
. urt I
i 13 because we could not cualify a narticular nipe supoort nackage i-i-
-14 based on the criteria given to us,-it only looks the suonort is l;
y 15 in bad shane, it is failina.. Said, " Don i.t.erru._Giv.c._nc f e.
16 nackag.e_back.
I will cet Lit _na.ssed_in_another aroup. "_
Beca us 17 they vere usina another criteria._ _ _. _.. _..;.nd they cot it rassed,
.38
- cer tified, and gone.
H l
-19 MR. TERAO:
Do you recall what criteria--
c.r.
20 what - actually f ailed?
What criteria failed?
p 21 MR. RASAN:
Right 'now, no, because it was a 22
-very old package.
I cannot recall.
I believe, if I recall 23 correctly, I think it was Rietnand inserts.
If'I recal) 24 correct 1y, it was Fichmond inserts.
But I cannot tel] vou a 25 hundred percent certainly that, but was one of the items that EXH!B!T,,
'T DE P. AGE'Y
l 9'
3
'vas f ailinn bat ly.
l'e -took -it ava", and it uns masse:* by i
2 another aroup,,
3
'IR TERAO:
Dut do vou recall if it was a 4
ntress criteria, if it was a deficction criteria, if it was--
5
- 12. ESMu Well, I -just told you, if I recall 6
corroc tly, t.hc raain prublem was the aualification of 31chncr, 7
inserts.
We could not aunlify in our nroup uninn the ?:PS 0
critoria.
So, that nackaoc was taken away frcrn us, an c' it.;a t 9
qualified at that titne in another nrouti by the nane of pape 10 supoort encineering (;rcup.
11
,T n d that quv came to me and said, '" o o':,
12 could not salvage this package.
We got it passed."
i 13 I said, " Pine."
Because I could not de it.
14 And I can aive instances af ter instances li'T 15 this.
Eut NRC is not aware of the f act that there it o n <. o rm.p 16 who used to do the desian revieu.
bnd when we used to ec.t th 17 finM as-built load from the stress aroun, we used to do W li certification of the entire suonort.
18 19 ouite a number of times I act a nacknac,
.e 20 could not aualify it, and we used to write a memo to Jay Rvar.,
21 chief enaineer, telling hin that thin suncort is failing under
/
~
22 NPS criteria.
23 And those neonle used to complain to hiaher 24 authoritien:
T_ o o k, this ouv is writin ne nonos tellin* toe
\\
25 these supoorts are f a.11 i n n.
EXHIBIT RAGE '$ DE
/4
m
'.i 9
99 1
I 1
" MTt. HOU:
Lot ~me ask some nuestion.
I 2
'1R.
ilASM:
Yes.
3 yp, pou
.You nar'thnt nunport no asaicmed to 4
one croun of engineerinc,- and they.used a sot of criteria 5
and then find out it's not abic to vect.
And then vers it to
.another group...and they use dihferent kind; of criteria?
6 7
nn. UAS u;:
Txactly.
Tt,at's correct.
And the:
8 used to pass it.
i 9
MR. EnU:
Uh-huh.
10 MR-RASAP:
Anti thev used to say, as for our 11 criterin,--
(
12 1"R. POU:
Okay.
1]ow, can von be rare s;cc!fic 13 what criteria they used and what aroun?
14 MR. FASAN:
Richnond inserts.
As I ".u s t saic' 15 to hi:
16 MR. 900:
Which one use it?
17 Mr. TRA.nMrLL:
well, I know that none o' t'cre IB have been given to un in enough detail to really flesh it cut, t
19 but ':eep going.
You're doing fine.
Let's no on to the next i
20 issue.
I want to act then all.
l 21 MR. HASAU:
All richt, I will trv.
r i
l 22 The coefficient of friction.
On this cartieu!r' i l
23 project, coc"icient of f riction is being basec on normal load; '
l j
24 This means r'ead ucight nlus t enor.
That's i t. EXHIBIT for ouite soro M p},b' L
25 And in another croun
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