ML20080N799
| ML20080N799 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/16/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | |
| References | |
| NUDOCS 8402220347 | |
| Download: ML20080N799 (27) | |
Text
{{#Wiki_filter:. _ -._ - 2/16/84 UNITED STATES OF AMERICA 00CKETED NUCLEAR REGdLATORY COMMISSION . US?RC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .g ,
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In the Matter of APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR and 50-446
-AN OPERATING LICENSE FOR g COMANCHE PEAK STEAM ELECTRIC STATION UNITS #1 AND #2 ' '(CPSES) j CASE'S EXPECTED FINDINGS OF FACT FOR FEBRUARY 20-24, 1984 HEARINGS ,
Pur'suant to the Board's directives in its 12/28/83 Memorandum and Order (Scheduling Matters) (pages 2-3, item 5) and the telephone conference call of 2/10/84, CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Expected Findings of Fact for February' 20-24, 198/ Hearings As indicated in the telephone conference call on 2/10/84, CASE's Ex-pected Findings are not in great detail,' but are rather designed to summarize CASE's principal arguments and give the other parties fair notice of CASE's position. We are, of course, at this time unable to predict what information g may come out during cross-examination, voir dire, etc. Therefore, our Findings of Fact will need to incorporate such information when it is available. Our Expected Findings of Fact are attached. Respectfully sutmitted, -
' U> -
prs.) Juanita Ellis, President CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)
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g2ggKO I 4ks Da a, e as 75224 O PDR 214/946-9446 817/332-6900, temporary number (February 12-24) g
r . CASE'S EXPECTED FINDINGS - ' WELDING ISSUES l During the February 20-24, 1984, hearings, CASE expects to prove the following (it should be noted that some of this proof will come from past testimony or documents already in the record, not necessarily from actual testimony in the hearings themselves):
- 1. That the testimony of Darlene and Henry Stiner is correct, including but not limited to some of the following.
WEAVE WELDING -- HEAT INPUT
- 2. That one of the primary problems with weave welding is that it often produces excessive heat input.
- 3. That excessive neat input was one of the Stiners' concerns regarding weave welding.
- 4. That Applicants have not proved with documentation that weave welding is pennitted by procedures at Comanche Peak.
- 5. That Applicants have not addressed the Stiners' recollection that pro-cedures (specifically CPM-6.9, 11032, 11065, and Weld Parameter Guides) do not allow weave welding, in that Applicants have never produced those procedures which were in effect when the Stiners worked at Comanche Peak. If the Stiners are in error in this regard, the best evidence would be the documents themselves. Absent the documents themselves, the Board should give greater weight to the Stiners' testimony (since they do not have copies of the documents) than to the Applicants' witnesses' testimony (who do have the documents and could easily pro-ducethem).
m- _
c 1 WEAVE WELDING -- HEAT INPUT'(continued):
- 6. That even if weave welding over Four-core-wire diameter is permitted at Comanche Peak, there is 'still a problem because weave beading (or welding) over four-core-wire diameter is also done, and is in fact a comon practice at Comanche Peak.
- 7. That weave welding is only one of many facets of the problem with which the Stiners are concerned.
- 8. That Applicants have not-indicated that they have identified and/or checked all of the areas in which Henry Stiner worked regarding weave welding, since Mr. Stiner testified that weave welding and other problems occurred in every place he had ever worked. Further, since Applicants have only addressed the areas which require Charpy impact testing in this regard, there is no indication that they have identified or checked other areas where Charpy impact testing is not required for illegal weave welding over four-core-wire diameters. (See items 5 and 6 preceding.)
- 9. That heat indicating crayons or other devices to check the heat input are not regularly used at Comanche Peak.
- 10. That effective heat input was a problem identified by ASME when they made their survey in late 1981 which led to their allowing Brown &
Root's N stamp at Comanche Peak to expire.
- 11. That effective heat input is a continuing and major problem at Comanche Pea k.
- 12. That welding has been done at Comanche Peak without preheating when the temperature was below freezing.
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r-4_ WEAVE WELDING -- HEAT INPUT (continued):
- 13. That uncontrolled hot or cold temperatures when welding cause bad welds.
- 14. That another type of weave welding has been done at Comanche Peak --
taking a welding rod, beating the flux off, and using it to fill in bad fit-ups (too much gap) by placing the bare electrode into the gap and weave welding another electrode with the flux still on it over the bare wire, so as not to slow up production.
- 15. When considering maximum bead width, effective heat input must also be considered.
- 16. Excessive heat input could cause broadening and subsequent embrittle-ment of the heat affected zone.
1~. That heat indicating crayons or other devices to check the heat input are required to be used by Comanche Peak procedures.
- 18. That the preheat temperature or the interpass temperature is not usually checked at Comanche Peak.
- 19. That illegal welding practices are employed at Comanche Peak in order to speed up production.
- 20. Grinding down does not help correct weave welding; the weld underneath is still a weave weld, which is weaker because there has been no control over the heat input.
- 21. -The proper method to correct weave welding is to grind it completely down to base metal and reweld it with a stringer bead. A preferable method would be to cut the whole thing down and redo it, because you've still got damaged parent metal.
T WEAVE WELDING -- HE/.T INPUT (continued):
- 22. . Bad weave welds have been made at Comanche Peak which have not been p:operly corrected, in that it was not ground down to base metal but only the surface was ground off and capped so that it would appear to be a sound weld. It was covered up, not corrected.
L 23. Repair to the welds was not cosmetic. The weave welds discussed by Mrs. Stiner were discovered when she was inspecting the hanger for torquing; the welds were in the process of being made -- it was not an initial root pass or merely a cover pass for cosmetic reasons. Further, the hanger was cut down; one doesn't cut down a hanger for
" cosmetic reasons."
24s Weave welding in excess of four-core-wire diameter is being done at Comanche Peak by inexperienced weldesr and experienced welders; it is being done primarily for two reasons: due to inexperience or lack of knowledge of the welders; and in order to speed up construction.
- 25. This illegal weave welding is in violation of ASME and AWS codes.
DOWNHILL WELDINC
- 26. Downhill welding has been done at Comanche Peak by inexperienced welders who have not been qualified by the ASME or AWS codes as required.
- 27. One of the downhill welds with which Mr. Stiner was concerned was on the hanger which he referred to as the one he was fired for reporting the gouge in.
.28. The concern in 27. above was not even addressed by the investigators in the NRC report regarding the Stiners' allegations.
I ~ DOWNHILL WELDING (continued):
.29. Downhill welding has been performed at Comanche Peak because of limited access welds.
- 30. Downhill welds have been made at Comanche Peak not only on root and cover passes, but in the consecutive layers in between.
- 31. Limited access welds at Comanche Peak have been done improperly.
- 32. Welders at Comanche Peak have been instructed to get the work done fast in regard to limited access welds. This, coupled with the welders' inability to get the proper work and lead angle needed to make the re-quired bead,.has set up a bad situation.
- 33. One of the problems with downhill welding is lack of deep penetration, trapped slag caused by the molten puddle falling over the slag coating, which also causes lack of fusion.
- 34. On heavy plate 1/4" or more, upward welding is preferred.
- 35. AWS Dl.1 requires qualification or requalification of welders using downhill welding.
- 36. ASME reauires qualification or requalification of welders using down-hill welding.
- 37. Downhill welding as done at Comanche Peak is in direct violation of AWS and ASME codes.
, PLUG WELDING
- 38. According to Applicants' and NRC Staff's witnesses' testimony, plug welding is actually a different process than that mentioned in Henry and Darlene Stiner's testimony.
PLUG WELDING (continued):
. 39 . Assuming that 38. preceding is correct, the Stiners should more properly have referred to fillet welds of misdrilled holes rather than " plug welds."
- 40. Fillet welds of misdrilled holes (referred to as " plug welds" in the Stiners' testimony) have been done without proper quality control in-spections and without proper documentation.
- 41. Welding done as discussed in 40. preceding is in direct violation of the ASME and AWS codes.
'42. Welders at Comanche Peak make illegal " plug welds" under orders, in order to keep their jobs and to speed up production.
- 43. When " plug welds" are done, slag is entrapped inside the welded area.
- 44. Ill'egal " plug welds" are a pervasive and major problem at Comanche Peak which has not been adequately addressed by either Applicants or the NRC Staff.
WELD R0D CONTROL
- 45. The weld rod control system at Comanche Peak does not work.
.46. -The weld rod control system at Comanche Peak is inadequate to meet the requirements required by code, regarding such important items as lack of traceability, no heat verification on weld rods, etc.
- 47. One concern regarding weld rod control is that welders at Comanche Peak often leave their weld rod cans unplugged, often leave their weld rods j out of_ the can longer than four nours, and often use rods which have not been properly heated to begin with. !
WELD R0D CONTROL (continued):
- 48. NRC oversight regarding weld rod control ha been inadequate and too ~
trusting.
- 49. Welders sometimes keep rods from one hanger and save them to do repair work on other hangers.
- 50. After rods have set in a welder's tool bucket for two or three days, they absorb moisture and the flux becomes contaminated.
- 51. There is very little control at Comanche Peak over the stubs that are supposed to be turned back in.
- 52. Welders have even loaned rods out of their cans to others to do repair work, so the welder won't have to get rods issued from the rod shacks.
- 53. Even if nobody tells welders directly to engage in these practices,
-it is encouraged because nobody ever really checks on it or makes a big thing out of it, everybody knows it goes on. Workers do it for convenience, because they are under so much pressure to get the work done and get the hangers up that they try to do anything they can to speed up their work. Even if not directly ordered to engage in these practices, there is an understood, implied directive from superiors and management to the welders.
- 54. Mrs. Stiner has personally found bundles of unburned rods wrapped in a rubber band and put in an area for safekeeping and for future use.
- 55. If new welds were made on a support without the old weld symbols having been removed, QC would be likely to assume that they still had rods burned on the hanger, making it impossible to have rod traceability.
WELD R0D CONTROL .(continued):
- 56. When welds are made using rods contaminated with moisture, porosity results and inner passes containing porosity would be covered up. The weld is going to be as bad in the root or inner passes as on the cap.
- 57. Inspection is 'not done on the root and inner passes; therefore, the condition discussed in 56. preceding would be covered up. Surface examination would not show any inner porosity or anything else. This was confirmed by Applicants in their 7/15/83 Summary of the Record Regarding Weave and Downhill Welding, pages 12 and 13. (See pages!
21 and 22 of Stiners' testimony.) .
- 58. Lack of preheat and improper effective heat input is a problem which applies to all of the preceding, which exacerbates the problems.
- 59. Testimony of some of Applicants' and NRC Staff's witnesses is misleading, perahps to the point of constituting material false statements. We will be asking that the Board consider this possibility.
DESIGN; AND OTHER
- 60. Applicants have formed a bias which concludes that the codes are not required. Problems which could result in serious consequence and are contrary to codes are dismissed af ter the fact as insignificant. The blase attitude of supervision at Comanche Peak precludes conscientious attention to detail. If the Comanche Peak supervisi6n and management are convinced that violations of codes, laws and their own criteria
DESIGN; AND OTHER (continued)-
- 60. (continued): -
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have no adverse impact on the safety of the plant, they assume that there is no reason for them to jeopardize the schedule or incur further costs merely to correct or even admit to areas that they consider to be non-problems.
- 61. The test procedures conducted by' Applicants are not in compliance with standard test procedures and are actually conducted to justify an accom-plished fact.
- 62. Applicants' response to the Walsh/Doyle allegations is carefully designed to skirt the issues rather than address them in the manner they deserve.
Problems remain problems regardless of the weight of credentials which are marshalled to bury them. 63.. The testing procedures utilized by Applicants and indicated in their prefiled testimony do not consider all possibilities of weld design.
- 64. The Applicants, by using a panel approach rather than individual testi-mony, have attempted to indicate that non-engineering personnel (i.e. ,
personnel with no expertise on a subject) have expertise on the subject.
- 65. The panel which Applicants have presented is trying to dismiss an item which they correctly state and go into great detail regarding, but which is not a concern of Messrs.Walsh and Doyle or of the Stiners; that is, thy h artensite effect that pertains only to high strength steels, not low carbon steels.
- 66. In regards' to the comment from Omer Blodgett's book, the Applicants have misconstrued the actual content of the paragraph, or violates the code in the process of making a fillet weld. The portion of Blodgett's
DESIGN; AND OTHER (continued):
- 66. (continued):
book is in regards to the depth of a fillet weld to its width in a single pass, and when the depth exceeds the width of a fillet weld, internal cracking will occur.
- 67. CASE's Proposed Findings on the Walsh/Doyle allegations are correct in regards to the welding issues.
- 68. Testimony of some of Applicants' and NRC Staff's sses is misleading, perhaps to the point of constituting material false statements. We will be asking that the Board consider this possibility. This is especially noticeable regarding the use of statements based on a partial fact utilized to mislead the Board into adopting an incorrect conclusion.
- 69. It is, of course, impossible at this time to know what information may be derived from cross-examination, re-direct, or rebuttal testimony.
However, it is expected that additional findings will be made based upon such testimony, as well as upon any documents which may be used during such testimony.
- 70. It is also expected that testimony in the proceedings will supply addi-
, tional information for trending, which has been indicated to be a con-tinuing concern of CASE's.
- 71. It is also expected that testimony in the proceedings will supply addi-tional-information regarding the credibility and/or competence of Appli-cants' and NRC Staff witnesses, which has been indicated to be a con-tinuing concern of CASE's.
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DESIGN; AND OTHER (continued):
- 72. It is also expected that testimony in the proceedings will supply addi-tional information regarding Applicants' overall QA/QC program; intimi-dation, harassment, and threatening of employees; disccuragement from doing the job right to begin with; and other specific concarns discussed in CASE's 1/16/84 diarification of Issues in 12/23/83 pleading.
72a. The inspection report by the NRC regarding the concerns raised by Henry and Darlene Stiner was inadequate, did not address all of their concerns, all of the items discussed in the " sanitized" back-up notes of the in-vestigato were not contained in the report itself (and some have never been addressed in any NRC report), some of the information in the report itself is cor.tradicted by the investigator's " sanitized" back-up notes. 72b. The inspection report by the NRC regarding the concerns raised by Henry and Darlene Stiner cannot be relied upon as having resolved their concerns. 72c. A thorough, in-depth independent investigation should be made into the concerns of Henry and Darlene Stiner by someone outside NRC Region IV who has not been affiliated with the investigation in any way or with these licerising proceedings in any way.
- 13 -
t CASE'S EXPECTED FINDINGS OF FACT -- CYGNA REPORT
, ;During the February ~20-24, 1984, hearings, CASE expects to prove the following (it should be noted ithat some of this proof will come from past testimony or documents already:in-the record, not necessarily from actual testimony
.'in the hearings themselves):
'73. The CYGNA Report cannot be relied upon by the Licensing Board to allay
.the Board's concerns regarding the quality of construction or design at. Comanche Peak.
~74. The preceding (item 73.) is true because the report is fatally flawed,
.' as ' demonstrated in the following, e .
- 75. .The reviewers-did not find many problems and deficiencies which they should have fcund (including but not limited to concerns raised by Messrs.
Walsh and Doyle). i
._76. There is no indication that Cygna was ever supplied with a copy of-
. CASE's ProposedLFindings (Walsh/Doyle Allegations) or that they were even' aware of what Messrs. Walsh and Doyle's concerns were.
i.; ' 77. Cygna did not discuss any of- the Walsh/Doyle allegations with Messrs. i Walsh'or Doyle, although they apparently did have discussions with
" Applicants and perhaps with the NRC.
78.:-.When problems or deficiencies were found, Cygna relied.on the Applicants' statements or the NRC SIT Report in instances.to resolve their concerns.
- 79._ When problems or deficiencies'were found, Cygna at times concluded Ethat the problems were not_ important without adequate documentation,
- x. ,
L >- calculations, 'or other bases for their conclusions. I
'CYGNA REPORT (continued):
- 80. There is little or no documentation, calculations, or other supporting data included in the report.
- 81. The expressed purposes of the Report indicate built-in biases designed to prove that Applicants' nuclear plant has b':en built correctly, rather than being designed to ascertain whether or not it has been built correctly.
Its conclusions are a self-fulfilling prophesy.
- 82. Cygna's review was compromised in that advance notification was supplied to Applicants in advance of Cygna's review regarding specific documen-tation which Cygna would be looking at.
- 83. ' Applicants failed to inform the Licensing Board of the fact that pre-notification had occurred; in fact, to the contrary, Applicants repre-sented the Cygna Report as being completely independent, unbaised, and reliable, and have even urged that Cygna be allowed to conduct a more thoroguh review using the same independence and criteria. This constitutes a material false statement.
l 84. Applicants stipulated in the 2/15/84 telephone conference call between l the Board and parties that prenotification had occurred.
- 85. This prenotification regarding specific documentation which Cygna would be looking at calls the entire Cygna Report into question.
- 86. Although Applicants have indicated in public statements that advance lists (note that this is plurc1) "were provided only when large numbers
- of records were going to be used to evaluate plant procedures, and the l
advance notice gave the utility time to promptly assemble the records," l (plant spokesman Dick Ramsey, DALLAS TIMES HERALD, 2/14/84), the very l-l-
l- ' t , CYGNA REPORT (continued):
- 86. (continued):
fact that the documents were assembled in advance thwarted one of the intents of the Cygna Report (i.e., to ascertain whether or not the system was working correctly, which would include whether or not the system worked in a timely fashion). (See attached newspaper clippings.)
- 87. Although Applicants have indicated in public statements that "the lists"
-(again note that this is plural) "usually were not provided until the afternoon before the inspection, and thus the utility would not have had time to correct any problems before Cygna arrived," (plant spokesman Dick Ramsey, DALLAS TIMES HERALD, 2/14/84), (1) the use of the word "usually" clearly indicates that this is not always the case and that there is the possibility that some lists were provided well in advance of the inspections, and thus there would have been sufficient time to correct problems before Cygna arrived, and (2)~ supplying the lists the after-noon of the inspections would afford the utility sufficient time to correct problems before Cygna arrived (especially if the inspection was not done until the next afternoon rather than morning), since it is a well-known fact that the night shift works regularly at Comanche Peak. -(See attached newspaper clippings.)
- 88. Irrespective of the questions regarding independence of the Cygna Report, Cygna's review was insufficient to stand on its own. It would be impossible to conduct an independent. peer review based on the contents of the Cygna Report alone, without obtaining and reviewing additional calculations and other documentation.
--_________________________________________----------_____________------------------------__J
CYGNA' REPORT (continued):
.89. -Many important criteria were not considered in Cygna's review. . 90.. The Cygna Report overstates the extent of the inspection coverage.
- 91. While a review would be expected to find conflicts in assumptions in engineering judgements and few, if any, errors of fundamental substance, Cygna's-review indicates the opposite in that gross mistakes and errors were found -(although C gna concluded that everything basically was all right). The review lacks depth which would have resulted from independence.
- 92. The extrapolation from this review to the plant per se,is out of all reason and the sample was insufficient (for example, the review repre-
.sented less than 1/2 of 1% of the total supports).
- 93. Paramount among our proofs is the fact that although large numbers of non-conservative errors were enumerated in the review by Cygna, their conclusions were 1800 out of phase with reality.
- 94. Cygna's witnesses have no concept of the actual design which exists at Comanche Peak and cannot comment on technical issues adequately
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when confronted with technical questions.
- 95. Cygna was not . independent when arriving at its conclusions on pipe supports, pipe stress analysis, document control, and cable tray supports.
l 96. The cumulative effect of the errors identified will be significant. 97.. eThe testimony of CASE witnesses Jack Doyle and Mark Walsh will not be adequately rebutted in a technical manner by Applicants' or Cygna's i witnesses.
- 98. Although CASE has not had the opportunity at this writing to review some-documents just received on discovery, it is expected that some l
l L.
o , 4 CYGNA REPORT (continued):
- 98. ~(continued):
of those documents will be used to show that Cygna did not use proper engineering princip'es to arrive at their conclusions. 99.- On Wednesday, 2/15/84, late in the afternoon, CASE received some of the documents we had requested on discovery; however, we have not 'yet received approximately 40% of the documents requested, and we have been informed that the remainder will not be available until Friday, 2/17/84. As; of this writing, we have.not had the opportunity to review the documents requested, but it is expected that some of them will be used to. support the testimony of CASE's witnesses, to support CASE's
~ positions and findings, to cross-examine Applicants', Staff's, and Cygna's witnesses, to disprove some of the testimony of Applicants', Staff's, and/or Cygna's witnesses, and to further prove that Cygna's review was inadequate at a minimum.
100. In addition, it is not known at this time what other information may be derived from documents received or from Ltestimony or cross-examination regarding those documents, but we will. address this in our findings. 101.c The specific information contained in the testimony of CASE witnesses
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. Jack Doyle and Mark.Walsh will be ' proved correct.
l 102.- Although the.Cygna Report is virtually useless as far as being of assistance , sto the' Board in resolving. its concerns about the design and construction of Comanche Peak, it is very helpful to the Board in that it proves that: C L._ ,
CYGNA REPORT (continued):
.102.(continued):
(a) Cygna should not be considered for the performance of the more in-depth review desired by the Board. (b). Cygna cannot, at this point in time, conduct an unbiased, truly
. independent review necessary to allay the Board's concerns.
(c) There must be very specific, very stringent criteria spelled out in detail by the Board regarding any future more in-depth reviews. (d) Applicants cannot be relied upon to select the organization to conduct future more in-depth reviews. There should be input from outside sources, including CASE, and a mutually acceptable organi-zation should be selected. (e) It is.more important that criteria be properly developed and care taken in selecting the. organization which will conduct the in-depth review, than for the review to be rushed in order to meet Applicants' alleged fuel load date. Otherwise, any future review will be of no more assistance to the Board than has been the Cygna Report. (f) A thorough, detailed, in-depth design and construction verification is necessary at Comanche Peak in order for the Board to be assured of the adequacy of construction and design. (This is indicated just on the basis of the problems identified, if not recognized, in the Cygna Report, as well as by other testimony, documents, etc.) 103. It is, of course, impossible at this time to know what information may be derived from cross-examination, re-direct, or rebuttal testimony.
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CYGNA REPORT (continued):
.103. (continued):
Further, it should be noted that on 2/15/84 Applicants advised that they are withdrawing the testimony of Marcus Bressler and that they will be supplying instead testimony of two additional witnesses. Since we have not yet seen such testimony, it is unknown at this time what it contains; we expect, however, that CASE witnesses Jack Doyle and Mark Walsh will be reoutting at least some of such testimony. It is expected that additional findings will be made based upon such testimonies, as well as upon any documents which may be used during such testimonies. 104. It is also expected that testimony in the proceedings will supply addi-
' tional information for trending, which has been indicated to be a con-tinuing concern of CASE's.
105. It is also expected -that testimony in the proceedings will supply addi-tional information regarding the credibility and/or competence of Appli-cants', Cygna's, and NRC Staff witnesses. This has been indicated to be a continuing concern of CASE's. 106. It is also expected that testimony in the proceedings will supply addi-tional information regarding Applicants' overall QA/QC program; perhaps i regarding intimidation, harassment, and threatening of employees; dis-couragement from doing the job right to begin with; and other specific concerns discussed in CASE's 1/16/84 Clarification of Issues in 12/23/83 Pleading, i-
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By Walter Borges _. ._ this year. . . . . . _ , , ... A spokesman for Texas Utill. staff unter of The News.- . . .. his. Hatley, who was a records... ties said the documents to which specialist. was bred by Brown &. his. Hatley referred were re.' A former employee of the coq. tractor building Comanche Peak' Root last Tuesday. Officials of quested by Cygns in advance as has said the contractor was told plant owner Texas Utahties Co. part of a study of design documen. which documents were to be re- said she was fired for "ooor job tation. viewed by a consultant studying performance. However.in the af. fidavit, h!s. Hatley said she was ..Those requests were in cases the plant's engineering design i red fer " failure to obey instrue. where pnor knowledge would not poor to the consultant's visit to affect the information - they tio the nuclear power plant. w nted," said Texas Utihues e 5500.000 Cygna study was spokesman Dick Ramsey.- Dobie Hatley said in an affida. commissioned after two former vit that officials of Brown & Root Comanche Peak design engineers But the president of the Dallas. Inc.of Houston.the plant general charged that pipe supports at the . based Citizens Association for contractor, told her to check a list. plant were poorly designed and Sound Energy, which opposes 11 of documents a day before Cygna that the designs had norbeen cor. censing for the plant, disagreed Energy Services visited the plant rected.. with the utility's interpretation.' last fall. The affidavit was filed Cygna issued a two. volume re. , hfonday with the U.S. Nuclear port in November that said the "The Cygna study was nct in. Regulatory Commission panel plant's designs were " adequate" dependent to start with," CASE
; , that will make a recommendation and had been " properly imple.' president Juanita Ellis said hfon-on Comanche Peak licensing later men ted." day.
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- _ _ .Juamta Ellis. president of the "4
Citizens Association for Sound En-1 ergy, a public interest group, said a11Cg . the list casts doubt on whether Cygna was as independent as it
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wes supposed to be during the
~ $500.000 study. The study was Panel told n1 y ant
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Generating Co., the consortium of k,new of reviews six utilities that owns the plant, afte,the u.s. Nuciea,Regulato,,
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Commission staff said it had By JACK BOOTH doubts about the plant's safety.
; gggf g.hter Mrs. Ellis said advance notice could have given the utility the
. A fermer documents supervisor opportunity to track down any at thp Comanche Peak nuclear missing documents before Cygna
' lant p inspectors arrived. The adequacy cials w,has charged ere given advancethatnotice utihtyofoffi. of the utihty's record keeping has which records a supposedly inde- been a key issue in the beensing pendent consultant would exam. hearings for the plant.
ine during a review of the plant's Plant spokesman Dick Ramsey safety, said Cygna provided advance lists i Dobie IIatley, who was fired of documents it needed, but only from the plant near Glen Rose on in cases where it was not con. Feb. 7. said her supervisors gave cerned about whether the records her a handwritten list the day be. were complete. The lists were fore the consultant arrived and 'Provided only when large num-told her to make sure the records ;bers of records were going to be were in order. , iused to evaluate plant procedures, The next day a consultant from :and the advance notice gave the Cygna Energy Services of San f utility time to promptly assemble Francisco " looked at those specifie ' the records, Ramsey said, dccuments and no others." Mrs. He.said the lists usually were llatley said in a sworn affidavit .not provided until the afternoen sent to the U.S. Atomic Safety !before_ the inspection, and thus and Licensing Board. which over. lthe u,tility would not have had sees work at Comanche Peak. . time to correct any problems be-
"It was obvious that someone fore Cygna arrived.
. had been given information about l Befor.e allowing the stt dy to
' whien~ specific documents Cygna , Proceed, the NRC staff laid out ould reviewing," said Mrs. -*
g ,T m % 2 9 ar __ _d
. . . . . .m e .
- c tlh.ty warned or reviews, ex-employee says y 's PLANT - From Page One ..' orth on the harassment issue. Artrip said the ; that he was warried by an angry supervisor to specific rules for keeping aim of the transfer appeared to be to make it stop seporting the defects on formal reports
" corr.munication between the consultant and di!!icult for the six inspectors to appear at the required by the NRC.
' the utility to a minimum, including the provi- Fort Worth hearing, because they were not
, '.90% . t During cross-examination. Dunham ad-sion that all correspondence between the two Ri ven paid days off to attend the hearing, myr niitted he served a year in prison af ter a 1974 groups would have to be kept on file for NRC wne their tipveling expenses paid. They said review. nly the six mspectors who were subpoenaed eviction for burglary, and he said he re-ceived a suspended six-month sentence in 1977 The licensing board called the study su- were approached about transfers.
perficial af ter its completion. saying it lacked a for a conviction for breaking and entering.h s Both men said they were not needed at 4 means of determining how thorough the con- the South Texas plant, and EUiott saH tie was sultant's inspectors were. even assigned to a different type of work be- ; The NRC suggested Dec. 28 that the util- cause no openings existed in the paint ity order yet another study. Two weeks ago, department. TUCCO suggested a more extensive study by During the harassment hearing Monday Cygna. At the same time, two former engi- in Fort Worth, William A Dunham, a former neers at the plant charged in affidavi's to the supervisor of paint quality control inspectors. licensing board that the first Cygna report was testified before U.S. Labor Department Ad. , biased in TUCCO's favor. ministrative Law Judge Robert Feldman that ,
? '. In another development, two former qual-he was fired last Aug. 2G for complaining that ity control inspectors at Comanche Peak said inspetors were being harassed, and twause j Monday that they were persuaded to transfer he reported the situation to the NRC staff.
! to the South Texas Nuclear Pauject near 11ay Dunham, now a supervisor at the South LCity af ter it became obvious that they would Texas project, said the main supervisor for the
'bc called to testify in a hearing about alleged paint department sepeatedly tried to pressuie
- harassment of inspectors at Comanche Peak. inspectors to overhok defective work so that
. Jerry Artrip and Walter Elliott said they, construction schedules could be kept.
along with four other inspectors, were told in Ile said the incidents of harassment in. January that they had the option of transfer- cluded a meeting in which supervierr. said ring to the Seuth Texas nuclear plant or face they were thinkiiig of firing Elliott, the in- - probabic layoffs in 120 days, if they stayed .si spector who now works at the South Texas Comanche Peak. plant, because Elliott was reporting defects. They said the transfer question was raised Dunham said he suwessfully convinced them the day af ter hearings were scheduled for Fort not to fine Elliott. Elliott said in an interview a
15.*_ _.
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attacked! . i - Continued from Page 13 ing detailed information about which drawings and documents would be requested.
"The next day Cycna came and looked at those specific documents and no others. It was obvious that someone had been given advance information about which specific cocuments Cygna would be revieu-JOr.T W3F.TH STAR-TELE ,iRAM tag." she said.
Geor.co Hedrick, a Fort Worth spokesman for Texas Electric Ser-Vice Co.. one of the utihties in the NOTE: Mrs. Hatley TtJESDAY EVENWG, FEBRUARY 14,1984 consortiurn of plant owners, de- did dot talk to fended the inspection. r.eporters regard-We deny that there was any in-tent to identify in advance where Ing her prefiled they were going to be looking for testimony. She any ulterior motives." Hedrick said. did not State that "We don't believe Cygna would do anyone " rigged" anything to compromise their pro-anything. Her im f essional opinion. -
.L.pm.,
g g nw g w air {
&& Cygna. under a $501000 contract prefiled testi-
" with plant owners, was conductin; mony, which has q= an independent design review of n0W been W1'thdrawn, 4
- t"g pipe supports and the fuel buildin?
N M
'rt awe The review, ordered by the licens. 5 peaks for itself.
" ing board in July, also was to deter- Any other infer-gy mine whether proper documenta- ences did not Come tion procedures had been followed.
Q g Q,( Plant opponents last week at- from her-tacked the Cygna report asinsuffi-I By BRUCE 311LLAR cientand biased.Thethree member Star Telegram Writer licensing board is expected to hear Anofficialatthe ComanchePeak testimonyon the report nextweek. nuclear power plant rigged a docu. Before she was fired Feb. 7. IIat-( ley supervised 23 employees in the i ment inspection by an outside con. sultmg company hired to conduct plant's document control section. an independent review of the She had worked for Brown & Root plant's design, a former supervisor for fiveyears.Shesaid she was fired at the plant alleges, because upper management and l c nstruction supervisors objected A spokesman for the plant's own- to her vigilance in following docu-ers denied the accusation. mentation procedures. Dobie listley.a former documen- Comanche Peak. under construc-tation supervisor for Comanche tion near Glen Rose 43 miles soulh-Peak's generalcontractor, Brown & west of Fort Worth. is owned by a Root Co.,said thaton theday before c nsortium of six utilities, melud-l the Novemt'erinspection, Brown & ing Texas Electric Service Co. - l Root Project Control 3fanager Hay-wardliutchison handed heralistof in anotner development on 51on-documents that hesaidCygna Ener- day,a formerquality controlinspec-gy Services Inc. representatives tor, who has accused the plant's would request. builders of intimidation. testified at In written testimony before the a U.S. Labor Department hearingin U.S. Atomic Safety and Licensing Fort Worth that he lied about his Board on blonday,llatley said that criminal record on job a pplicatio ns. l liutchison told her to make sure all Tlic revelations of formerinspec-the documentationwascorrect.giv- tor Bill Dunham followed his accu-Please see Inspectior.on Page gl . sations that he was fired from his
$13.95an hour job because he had told U.S. Nuclear Regulatory Com-mission officials that plant inspec-tors were being harassed,intimidat .
ed and threatened. ..
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- NOTE: Mrs. Hatley did not talk N
ya y to reporters regarding her prefiled testimony. She did not state that anyone " rigged" anything. Her prefiled testi-
'Q((hMhN g mony, which has now been with-drawn, speaks for itself. Any
.. other inferences did not come
!e! g g I from her.
J,dV . NasP
; Comanche Peak k P.; Y 03 accusation denied 7.* y.*r B'y BRUCE MILLAR l
ng$
- o ster.Tenegram unter A former supervisor at the Co-g
...] manche Peak nuclear power plant
- r.k alleged Monday that a top plant offi-
- cial rigged a document inspection
# by an outside consulting company
' ({4 -
hired to conduct an inde;.,.ndent l iA
'i[ F review of the plant's design.
Dobie llatley.a former documen-tation supervisor for Comanche t- Peak general contractor Brown & i - Root Co..said that on the day before
-+ .. the Novemt.er inspection. Brown &
M Root Project Control Manager llay-f{ .. ward Hutchison handed hera list of documents thst hesaid Cygna Ener-j - _g.m p gy Services Inc. representatives
- cs I would request.
l
! 6% 2 Ilutchison told her to rnake sure d [*[i ;.'g7 ~~}c ,/ l ll the documenution was correct.
;a
'. w .
~
lgiving detailed information about
%p4 N J
.." g, m
b which drawings and documents would be requested,llaticy said in i written testiniony submitted to the w, 3 i C). S ' U.S. Atomic Safety and Licensing
,,0.3 i . Board.
CD 0 l **The next day Cygna came and Ek va ecs 5 22
. looked at those specific documents i and na others. It was obvious that
$f y Q -
l someone had been given advance information about which specific 7,.y g;id)djf'>d-?g, E '! ! documents Cygna would be review-
~
^
o 1 ing," she said. l y Cygna, under a S500.000 contract l with plant owners, was conducting r
- ., 1 an independent design review of pipe supr' orts and the fuel building.
l
- The review, ordered by the licens-
! e . ing board in July,also was to deter-5-
.t i mine whether proper documenta-I ,.Y ,- ' tion procedureshad been followed.
-{ .
Plant opponents last week at- ' j g/L . tacked the Cygna report as insuffi-
, - . _ _ _ . . . - cientand biased.The three-member licensing board is expected to hear I testimonyonthe report nextweek.
l
.
- Please see Ex official on Page 14
+
svo4 row s wu,c He df Ad-llLEGR APA B 1UtSDAY tAORNING, itBRtt 1Y 14,1984 I Previous whistle blower hid recordi -
~
a
.t -
1 By BRUCE Mll.LAlt sm.teierrem wru" ity assuranec policies and practices at Comanche Peak," officials of % J N'
- I *
- 2' A former quality control inspec- plant operator Texas Utilities Gen-tor who has slleged intimidation by cratingCo.saldinapreparedstate .Ex-orriciai ll ca s inspechon 3 .-
builders of the Comanche Peak nu- ment. . . ,, cicar pow plant testified Monday Last September, a I, abor Depart- . : that he has a criminal record and mentinvestigatorsaid Dunham had I gl1 1 1 lied about it on job applications. been fired because he had reported f 8
% i
. . . 'd;-
Therevelationsof formerinspec. to management that qual?tycontrol . .. tor Bill Dunham followed his accu. Inspectorswercharassedandintim . Continued from Pege 13 George lledrick, spokesman for b sations that he was fired from lus idated from reporting deficiencies. Before she was fired Feb. 7,llat- Texas Electric Service Co., one of '-
$13 Man-hour job because he had . ,A US Nuc! car Regulatory Com ley,43, supervised 23 employees in the utilities in the consortium of Iold UX Nuclear Regulatcry Com- mission investigation of the protec- the plant's document control sec- plant owners. defended theNovem b."
mission officials that plant mspec. tive coatings quality control where *^ *0 N tors were being harassed. intimidat. Dunham formerly worked resulted Root tion. She had worked for fiveyears.Shesaid shefor was Brown"We& ber inspection. deny that there was' ' any in d. i" Dunharn lio was fired by dap o d 40 in a sin fired because upper management tent to identify in advance where p , and construction supervisors ob. they were going to be looking for + contractor Brown & Root Co. Aug. plant owners.The fine is under ad- jected to her vigilance m following anyulteriormotives"liedricksaid. h; 2fi. also testified that he had been ministrative appeat documentation procedures. We don't believe Cygna would do I.. to!d by his supervisor not to Issue ComanchePeak underconstrue- "Whenever I caught something anything to compromise their pro-[ forma reportsof constructiondeft- tion near Glen Rose 6 miles south- that was wrong, I would yell and fessional opinion." y w Fort Worth,is owned by a scream about it.The other reason,I IledricksaidCygnaomelaisoften [ a fired for brin ' to light ns rtium of six utilities. Includ- feel, is that I did start to voice my would request documents a day ! . problems, for daring i utter the C 35 C C e C c nec ns ab ut the safety of con- ahead of time.saying they wanted f . words ' harassment, intimidation. Under cross-examination 'by -struct[ ion in certam areas where I to review certain plant systems. ' j ; aloud." he said at a US Labor De- *'I'l'.cre was no way we could i partment hearingin Fort Worth on plant owners' attorney Bruce Dow. felt thatIhey were trying tocoverit ,' his request for back pay and rein, ney, Dunham said he served one up mstead of makingit right."Ilat- change tems priorthe to documents their looking or at the sys (. them."$ statement. year in the Oklahoma State Ref or. ley said. . Texas Utilities Co. officials have he said. "And if there was some- *t , Utility officials said Dunham was mrtory af ter his 1973 conviction of~ proposed hiring Cygna fora second thing wrong.no onewants to know i i fired forinsubordination toGordon burglary.Ile was given a six-month Purdy.senio. qui.fity controlsuper- suspcnded sentence following his reviewof theadequacyof pipesup. more than Texas Utilities Generat- U t 1973 conviction of breaking and en. port designs.That proposalcamein ing Co. .. n . v .* + l visor at comanche Peak'me to the tering. . response to a Dec. 23 board order. TUCCOis theoperatorof Comany j "You'll have to take ~ expressing doubts about the design che Peak. which is owned by six [. gate..because I won't cheapen my !!c testified that -he ' twice
' attitude on quality," Dunham testi- concealed his criminal record on and proposing ent review. a further Utility independ-officials utilities.near could struction TheGlenplantRose is under cou -
ln Somer@ s fied he told Purdy. Job app!! cations to Brown & Root n t estimate the cost of the addt. vell County, O miles scuthwest of i ., Dunham'sallegations giveanen- and Munday Industrial Service irt tional stndy. tirelywrongimpressionofourqual ' Deer Park. , Fort Worth. . .e .pt 3.; _ ~.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COP 91ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
- APPLICATION OF TEXAS UTILITIES GENER4 TING COMPANY, ET AL FOR '
Docket Nos. 50-445
-AN OP DATING LICENSE FOR and 50-446 i .COMANCh2 PEAK STEAM. ELECTRIC .
STATION UNITS #1 AND #2 (CPSES) I'
~ CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of
, CASE'S EXPECTED FINDINGS OF FACT FOR FEBRUARY 20-24, 1984 HEARINGS have been sent to the names listed below this 16th day of February , 198 4, by: Express' Mail where indicated by
- and First Class Mail elsewnere.
** Hand delivered if possible; otherwise, sent *.
- Administrative Judge Peter B. Bloch Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Comission Atomic Safety and Licensing Appeal Board 4350 East / West Highway 4th Floor ,
U. S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D. C. 20555
- Dr. Kenneth A. McCollom, Dean Dr. W. Reed Johnson, Member Division of Engineering, Atomic Safety and Licensing Appeal Board r
Architecture and . Technology U. S. ~ Nuclear Regulatory Commission Oklahoma State University -Washington, D. C. 20555
- Stillwater, Oklahoma 74074 Thomas S. Moore, Esq., Member
- Dr. Walter H. Jordan Atomic Safety and Licensing Appeal Beard 881 W. Outer Drive U. S. Nuclear Regulatory Commission Oak Ridge Tennessee 37830 Washington, D. C. 20555 -
** Nicholas' 3. Reynolds , 'Esq. Atomic Safety and Licensing Appeal Panel
-Debevoise & Liberman U. S. Nuclear Regulatory Commission
- 1200 - 17th St., N. W. .
Washington, D. C. 20555 Washington, D. C. 20036 Docketing and Service Section (3 copies)
* . Geary S. Mizuno, Esq. Office of the ' Secretary Office of Executive Legal Director, USNRC U. S. Nuclear Regulatory Comission I
Maryland National B'ank Building Washington, D. C. 20535 I 7735 Old Georgetown Road - Room 10105 [ Bethesda, Maryland 20814 l
. Atomic Safety. and Licensing Board '
. Panel p U. S. Nuclear Regulatory Commission i Washington, D. C. 20555 l
bi
e , Certificate cf Sgrvice Page 2
- Renealidlis, Esq.. :c.
Assistant Attorney General Environmental' Protection Division' Supreme Court Build.ing. Austin, Texas 78711 John Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Conmission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Lanny A. Sinkin 114 W. 7th, Suite 6:0 Austin, Texas 78701 R. J. Gary, Executive Vice President Texas Utilities Generating Co. 2001 Dryan Tower Dallas, Texas 75201
- o h ff/D
( ~r .)'Juanita EITi~s, President l i E (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 I r i t
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