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Category:AFFIDAVITS
MONTHYEARML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20086Q3931991-12-26026 December 1991 Affidavit of Case President J Ellis.* Affidavit of Case President J Ellis Re Motion for Leave to File Response to Portions of Motion of R Micky & Dow to Reopen Record. W/Certificate of Svc ML20154G7841988-09-0909 September 1988 Affidavit of Jj Macktal Re Oppressive Terms of Settlement Agreement for Addl Safety Concerns.Related Info Encl ML20207E6061988-08-12012 August 1988 Affidavit of B Brink.* Discusses Concern Re Operation of Plant.W/Supporting Documentation & Certificate of Svc ML20207E5941988-08-0505 August 1988 Affidavit of K Mccook.* Discusses Concerns Re Operations of Plant.Unexecuted Affidavit of P Reznikoff Encl ML19325D6431988-07-12012 July 1988 Affidavit of B Brink.* Expresses Concern That Operation of Plant Will Cause Loss of Health to Author & Family & Safety Problems at Plant Will Jeopardize Life & Property ML19325D6461988-07-12012 July 1988 Affidavit of L Burnam.* Expresses Concern That Operation of Plant Will Cause Loss of Health to Author & Family & Safety Problems at Plant Will Jeopardize Life & Property.W/ Certificate of Svc ML19325D6401988-07-12012 July 1988 Affidavit of P Reznikoff.* Expresses Concern Re Danger to Health & Safety Posed by Normal Operations of Plant & by Possible Accidents ML20197E3011988-05-23023 May 1988 Affidavit of JW Muffett.* Encl Review Issues Lists (Rils) on Pipe Stress & Pipe Supports Document That All Issues Closed by Cygna.Job Responsibilities of JW Muffett Stated. W/O Rils.W/Certificate of Svc ML20154E5391988-05-13013 May 1988 Affidavit of Ha Levin.* Related Documentation Encl ML20154E5281988-05-0606 May 1988 Affidavit of RP Klause.* Discusses Design Validation & for Large & Small Bore Piping Supports at Plant During Preparation of Project Status Repts.Author Statement of Training & Experience Encl ML20196B0751988-02-0101 February 1988 Affidavit of Rd Pollard Re Environ Qualification of RG-59 Coaxial Cable ML20236X2501987-12-0202 December 1987 Affidavit of Dn Chapman.* Discusses Mgt Analysis Co Audit Rept ML20236E0481987-10-23023 October 1987 Affidavit of Bp Garde in Support of Motion for Reconsideration.* ML20236E7501987-07-23023 July 1987 Affidavit of Jt Merritt.* Affidavit Discusses Mgt Analysis Co Audit Repts.Related Correspondence ML20236E7411987-07-22022 July 1987 Affidavit of JB George.* Affidavit Discusses Mgt Analysis Co Audit Repts.Related Correspondence ML20236E7551987-07-22022 July 1987 Affidavit of Eg Gibson.* Affidavit Discusses Mgt Analysis Co Audit Rept.Related Correspondence ML20211D0591987-02-11011 February 1987 Affidavit of Eh Johnson.* Responds to Statements in Case Motion Re Trend Analyses or Trend Repts.Trend Analyses & Repts Incorporated Into SALP Repts in 1980.Certificate of Svc Encl ML20212E8631986-12-26026 December 1986 Affidavit of Case Witness J Doyle Re Case 861230 Partial Response to Applicants 861201 Response to Board Concerns.* Certificate of Svc Encl ML20211J4721986-11-0101 November 1986 Affidavit of J Doyle Re Scope of Cygna Role.Supporting Documentation Encl ML20211J4141986-10-28028 October 1986 Affidavit of DC Garlington Re Irregularities in Plant Const or Operations Noticed During Site Visits.Emergency Lights Not Aimed & Locked & Trash in Diesel Room Noted in Monitoring Repts.W/Certificate of Svc ML20211J3551986-10-0303 October 1986 Affidavit of MD Nozette Re Events Concerning Participation as co-owner of Plant Between Nov 1984 & Feb 1985.Discusses Util Failure to Answer Questions Posed in Re Participation in Project ML20214L6911986-08-18018 August 1986 Affidavit of Tg Tyler Supporting Applicant Response to a Palmer Affidavit Re Case 860731 Response to Applicant 860716 Motion for Protective Order & Motion to Compel.W/ Certificate of Svc ML20214M4271986-08-0505 August 1986 Joint Affidavit of D Lurie & E Marinos Clarifying 860404 Joint Affidavit on Statistical Inferences from Comanche Peak Review Team Sampling ML20207E3071986-07-16016 July 1986 Affidavit of Le Powell on 860716 Re Estimate of Time & Effort Required to Prepare Responses to Questions 4-7 of M Gregory Set One Discovery Requests.Related Correspondence ML20207F7741986-07-16016 July 1986 Affidavit of Le Powell Re Discovery in CP Extension Proceeding.W/Certificate of Svc ML20197C1301986-05-0606 May 1986 Affidavit of M Walsh,Advising That Statistical Sampling Being Performed & Proposed for Facility Inappropriate. Applicant Reliance on Statistical Sample Will Not Identify Problems W/Pipe Supports.Certificate of Svc Encl ML20197C1051986-04-26026 April 1986 Affidavit of J Doyle,Addressing Applicability of Statistical Sampling to Facility ML20155A6851986-04-0404 April 1986 Joint Affidavit of D Lurie & E Marinos Re Board Concerns on Statistical Inferences from Comanche Peak Review Team Sampling.Certificate of Svc Encl ML20138B1711986-03-13013 March 1986 Affidavit of SD Mckay Re Likelihood of Reactor Coolant Pump Restart Due to Operator Error W/No Occurrence of Inadequate Cooling Event.Prof Qualifications & Certificate of Svc Encl ML20138B1071986-03-12012 March 1986 Affidavit of CE Mccracken Re Core Flow Blockage Due to Fine Paint Particles ML20138B1431986-03-12012 March 1986 Affidavit of B Mann Re Treatment of Operator Error in Licensing Process & Likelihood of Reactor Coolant Pump Restart During Inadequate Core Cooling Event.Prof Qualifications Encl ML20215E7171986-01-27027 January 1986 Partially Withheld Affidavit Re Allegations Concerning Drug Use & Distribution ML20138P5551985-12-14014 December 1985 Affidavit of Jj Doyle in Response to Applicant Changes to 1984 Motions for Summary Disposition ML20137X1831985-12-0505 December 1985 Affidavit of R Mcgrane Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits Only Recent Awareness of Rept.Related Correspondence ML20137X0201985-12-0505 December 1985 Affidavit of Dh Wade Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to May or June 1985.Related Correspondence ML20137W9971985-12-0404 December 1985 Affidavit of Nh Williams Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to 850625.Related Correspondence ML20137X2101985-12-0303 December 1985 Affidavit of R Siever Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits Awareness of Audit & Rept Preparation Through General Onsite Conversation in 1985.Related Correspondence ML20137X0881985-12-0202 December 1985 Affidavit of Rc Iotti Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge Apart from News Publicity & ASLB Documents in mid-1985.Related Correspondence ML20137X1291985-12-0202 December 1985 Affidavit of G Krishnan Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits General Awareness of Discovery Process Re 1980 Licensing Proceedings.Related Correspondence ML20137X0601985-12-0202 December 1985 Affidavit of Jc Finneran Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge Apart from News Publicity & General Onsite Conversations Earlier in 1985.Related Correspondence ML20137X1611985-12-0202 December 1985 Affidavit of P Chang Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits No Knowledge of Rept Prior to mid-1985.Related Correspondence ML20205H4071985-11-12012 November 1985 Affidavit of Rc Iotti & Jc Finneran Re Corrections & Clarifications to Affidavits Supporting Motions for Summary Disposition of Pipe Support Design Allegations. Supporting Documentation Encl.Related Correspondence ML20205H3501985-11-12012 November 1985 Affidavit of Rc Iotti & Jc Finneran in Response to ASLB Request for Info Re Variation of Field Configurations of Pipe Supports Utilizing clinched-down U-bolts.Related Correspondence ML20133F8221985-09-0909 September 1985 Affidavit of Aw Serkiz Providing Explanation Re Sser 9, App L,Per ASLB 850918 Memorandum.Certificate of Svc Encl ML20133F8161985-09-0909 September 1985 Affidavit of CE Mccracken Providing Further Explanation of Background of Sser 9,App L,Per ASLB 850918 Memorandum 1994-09-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
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~ AFFIDAVIT OF HOWARD J. ROBINSON Q: Please state your name and address for the record.
A: My name'is Howard J. Robinson. I can be contacted through CASE, 1426 S. Polk, Dallas, Texas 75224.
Q: Are you aware of any instances of intimidation, harassment, or threatening of employees at Comanche Peak?
A: Yes.
Q: Are you aware of cny instances of employees being discouraged from doing work right to begin with at Comanche Peak?
A: Yes.
Q: In your opinion, have such instances of intimidation, ' harassment, threatening, or discouragement had an effect on morale of employees at the plant?
A: Yes.
Q: In your opinion, have such instances of intimidation, harassment, threatening, or discouragement had a detrimental effect on the quality of work at Comanche Peak?
A: - Yes .
Q: If so, what effects have they had?
A: The' fact that intimidation, harassment and threats have existed at Comanche Peak for years, plus the bad examples set by supervisory personnel ,
of Brown & Root, coupled with the obvious lack on the part of TUSI to rectify the situation, promotes bad work practices resulting in inferior work.
O 8312010120 831128 <
PDR ADOCK 05000445 G PDR
_2 Q: Can you give us some specific examples of intimidation, etc.?
A: I believe I was given a reduction of force (laid off) because I had reported bad practices to TUSI management. I had just been placed over some additional parts of our department, the material group and the expediting group within the steel fab and hanger department, at the time I was terminated.
And without prior knowledge of the potential of my being ROF'd, I was told by Martin " Slim" Rains, my superintendent, that he had to R0F me that day.
He would not give any explanation of why, nor would James Callicut, who was General Superintendent over our department. When I asked for Ken Liford who was at the time, I believe, the Assistant General Superintendent who had replaced Hal Goodson, his only explanation was that they had too much super-vision and that he had to cut down on it. That doesn't make sense; it's b' contrary to +he normal practice in that when people are cut back like that they are usually just cut back to the next level down or find some place in some other department. A general foreman suchas I was with nine years with Brown
& Raot normally would not just be terminated for reduction of force unless there were mitigating circumstances.
It is my belief that the reason that I was R0F'd was the direct result of my having written a series of anonymous letters to Joe George, Vice President of TUSI on site, wherein I had revealed to him many illegal practices within our department conmitted by supervisory personnel, which involved make-work practices, outright stealing of materials, fabrication within the shop of all manner of assenblies for the personal use offsite of superintendents within our department. I had also reported to Joe George that there were instances of gratuity taking by supervisory persons of our department from an off-site supplier of the so-called "rebar eaters," that I had made the initial purchase request for the rebar eaters for my cepartment
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and had made subsequent orders for rebar eaters within our department over a period of years. It has been revealed and acknowleged by TUSI spokesman Tony Vega in the newspapers that gratuities were furnished by the supplier of rebar eaters to certain supervisory personnel of Brown & Root. The rebar eaters were specifically purchased, as their n.ame implies, to cut through 1
'. ebar within the walls of the plant including the containment wall. At a .
later date, I was instructed to refer to them as drill bits and not rebar l
eaters because thewords "rebar eaters" inferred a "no-no" term, if you will.
I have to guess what actually happened, but it was obvious that one of the main supervisors that I had referred to in my letters to Joe George had a sudden leave-taking in October of 1982. Obviously Brown & Root manage-ment would like to ha've known who had blown the whistle on this particular pJ individual and it is my belief that they found out that it was in fact me who had written the letter to Joe George. .I have reason to believe that my identify was revealed and that I was given an R0F as a direct result of my letters to Joe George.
Af ter I left, Antonio Vega came to talk to me for a period of four hours and informed me, among other things, that he would hold a meeting with certain individuals on the jobsite to ascertain if my charges had any validity. He did, in fact, hold a meeting but it was mainly with the people that I had made charges against. To my knowledge, there was not one person at my level or below who was there who could corroborate the instances that I had related to him. The last contact I had with Mr. Vega, he acknowledged that all of the charges I had made to him over the four-hour pcriod were in fact true, but that since the head of our department ha'd gone, he felt like the biggest part a
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of the problem was over and that he had to be objective in overlooking the whole project and that he would not carry the investigation further and he intended to drop it at that point. He excused the participation of my imediate supervisor in all of these acts as being the result of just following orders.
This is a statement that I hold to be absolutely untrue and can prove.
I was terminated on November 5,1982. -
Q: Do you know of other instances of intimidation, etc.?
A: There's another instance which I was not directly involved in but which I saw and believe to be intimidation. This involved the short term of employment of Rose Klimist, who was appointed as head of Brown & Root
- QC onsite. She came into conflict with Brown & Root and maybe others almost immediately because of her attempt to have the QC function done according O
t V to the codes and procedures, and this brought her into direct conflict with Brown & Roat supervisory personnel and she was quite suddenly removed from her position and ordered back to Houston. I believe she was removed because f she was holding too tight reins on QC. She came into conflict with Mr. Tolson, i
and her desire to perform the QC function on the jobsite conflicted with him and others onsite. I believe that she was succeeded by Jim Hawkins, a Gibbs
& Hill employee, and I believe that he was actually loaned to Brown & Root from Gibbs & Hill to head up QC function on the jobsite. I'm not sure how that arrangement worked.
I believe that h'e was somewhat more lenient in his interpretation of the QC procedures to the point that where the QC people involved in in-specting pipe hangers in the fab shop of which I was General Foreman became very distressed at the laxity of the QC functions as dictated by Jim Hawkins, and at one point they refused to inspect fabricated hanger components within l
x the shop in preferance to sending them to the field for field inspections.
They did this because they were distressed at having their work overruled by Jim Hawkins. Mr. Hawkins had close relations with the head of the steel fab and hanger department and had secured employment for his son-in-law within the shop through the direct intervention of the assistant general superintendent of the steel' fab and hanger department. Mr. Hawkins' son-in-law came into the shop at the level of journeyman fabricator but in fact was not qualified to hold such a position. Over a period of time, he learned his trade well and became a very reliable and dependable worker and a hard worker within our department and was completely removed from any of the deficiencies, harassment, and intimidation referred to previously in this affidavit. However, at the time he came in, he was not qualified and did not have his tools with him, had come from a low-level job with low pay at Nuclear Power Services, Inc.,. in Austin,' Texas, and could not be considered as qualified for a journeyman's position at Comanche Peak at the time of his employment. He learned on the job.
Another example is J. R. Dillingham. When he appealed to Brown &
Root's Houston office relative to certain illegal practices of which he was knowledgeable at Comanche . Peak, he subsequently spoke with Mr. Antonio Vega who is actually a supervisor for TUGCO, who among other duties follows up investigations of allegations by dissidents. In later conversations with me, I discussed Mr. Dillingham's situation on the jobsite with Mr. Vega and specifically about Mr. Dillingham being relieved of field duties and being placed within the millwright fab shop doing largely menial duties, basically guarding a cage. The common saying around the plant was that they let him wJ e
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out of his cage twice a day for feeding and watering. It was taken as a joke, because he was at the time a general foreman and had been for several years prior to his revelation of deficiencies and illegal acts at Comanche Peak. Mr. Vega informed me that it was on his orders that Dillingham had been sent to the millwright shop to remove him from the field because he had been threatened for making revelation of the purported deficiencies and illegal practices. Mr. Vega stated that the relieving of Mr. Dillingham of his duties in the field was done through Doug Frankum, Project Manager for Brown
& Root, and at the insistence of Mr. Vega. He was offered a reduction in rank and transfer to the pipe department or given an R0F (reduction of force, laid off), which Dillingham has told me on the advice of his lawyer he took q the reduction of force and left the jobsite.
It is common knowledge among all personnel at Comanche Peak that when someone seeks relief by going to either TUSI or Brown & Root or the fluclear Regulatory Commission with allegations of deficiencies and illegal work practices, they will suffer the same fate that has been suffered by their predecessors such as Charles Atchison, J. R. Dillingham, and myself.
This is so strong on the jobsite until some people who .to my knowledge would reveal these deficiencies and illegal work practices refuse to do so because they know that their job and their career would be suddenly terminated without recourse. Too often they have seen the flRC Region IV take a pro-company stand when some person tried to reveal these deficiencies and illegal work practices, and that these persons were fired or relieved of their duties and many are no longer involved in nuclear construction as a result of their O
-a
r attempt to bring before some authority that would correct the situacion.
Q: Are there specific problems in construction or design at Comanche Peak which you believe currently exist (which have not, as far as you know, been.put into the process to be corrected) to which you could take the Licensing Board and show them? ' And would you be willing to attempt to do so?
A: From the position I held it would be difficult to pinpoint the ,
deficiencies in the field. My duties as general foreman over the fab shop consisted of fabricating items such as pipe hangers, cable tray hangers, and Q miscellaneous steel assemblies for subsequent installation in the field.
I was not involved in the field installation and therefore would not be able to go to a particular site to show where deficiencies exist. I did, over a period of about three years, engage in an ongoing argument with one of the V foremen within the steel hanger department whose duty was to install ' hangars in the field where he challenged the practice in the fab shop of drilling 1" holes in base plates to the cade allowable of 1-1/16" diameter for a 1" bolt. His stand had been that'we were allowed to overdrill the hole to a l
l-1/8" diameter. This is directly contrary to the ASME code and although I read it to him on several occasions over a period of many months, he stead-fastly refused to accept it and made the statement to me that he had been drilling them oversize all along and intended to continue to. If he in fact did drill these holes. oversize, and I believe that he did, one must assume that any subsequent QC in'spection failed to identify this. This man has now to my knowledge become foreman in charge of the Drillco rebar eaters and lt Drillco drilling equipment within the steel fab and hanger department.
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I am knowledgeable of make-work practices involving hundreds of thoIJsands of hours of overtime work at premium pay within the fab shop that was not justifieu oy the work at hand. Morale within the fab shop was a .
problem that I was forced to deal with daily due to having been ordered by my superintendent and the assistant general superintendent of my department to fabricate numerous steel items and assemblies for subsequent personal use offsite by the assistant general superintendent. We were ordered to install used automobile air conditioning systems on various superintendents' pick-up trucks, oftentimes on days when we were on overtime at premium pay.
We would be ordered to park the trucks on the " patio" in order to hide them from general view while they were being worked on. This involved having good and Christian workers performing known illegal acts as ordered by their
(-) superintendent through me and this had a detrimental effect on their morale and was a constant problem that I had to deal with each day. Brown & Root had previously been cited by the Nuclear Regulatory Conmission for the general low morale of their employees at. Comanche Peak and the resultant poor work-manship performed by the people as a result of their low morale. Specifically, within the fab shop, it was an ongoing task of .mine to attempt to keep the morale of the workers at a high level when in fact they knew that they were oftentimes working on projects that were designed and fabricated for the personal use of the supervisory people of Brown & Root and oftentimes huge assemblies thus fabricated were removed from the jobsite to be utilized on their personal property. The triggering incident that caused me to decide
- to contact Mr. Joe George and to reveal to him some of the incidents that e
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_g-O were happening within the department came about as a direct result of one of my foremen expressing dismay at having to fabricate some items that were destined to be removed from the jobsite for the personal use of the assistant general superintendent. This foreman came to me very discouraged and asked me how long would we have to put up with the stealing of the superintendents.
It was at this time that I made the decision to contact Joe Geor 7 through anonymous letters ~ revealing the facts we have spoken of.
Q: Do you think that the Licensing Board would be able to visually see t
such deficiencies as you have mentioned with the naked eye, or would any additional testing be necessary to prove such deficiencies exist (and if so, what kind of testing would be required, in your opinion)?
l A: Some things they could see with the naked eye. A small gauge would be needed to measure the oversize bolt holes. An ultra-sonic tester would be needed to identify another problem, short bolts and bolts welded to the back of base plates.
Q: Why should the Licensing Board be concerned about such intimidation, harassment, or threatening or discouragement of employees, or such deficiencies What's the bottom as you may tell them about or show them at Comanche Peak?
line as far as the safety of the plant is concerned?
A: I feel like the morale of the people has a direct bearing upon the quality of their work and any low morale such as existed and still exists
.at Comanche Peak will ultimately have a bearing on the quality of the plant itself. In the light of the low morale of the employees out there and the poor quality of the workmanship, I have an uneasiness about the overall safety or the 91 e#t iteeir.
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- Q: Do you want to testify regarding these matters in the operating license hearings for Comanche Peak?
A: Yes, providing that supporting witnesses can be subpoenaed before the agency holding the meetings to support allegations made.
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O I have read ths foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
l (Signed)
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Date: Wco, 2Z/N3 STATE OF 7EXAS COUNTY OF -3 M .A.4 7
, On this, the 177/ day of d' /4#4E8 ,1983 personally appeared h g it) 4 G d [odM/ sod , known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed.
Subscribed and sworn before me on the f 7_dday of d'b 6541BE4' ,
198 3 a.a/5$$ $ $
Notary Public in and for the State of i zE- M S My Comission Expires: /, 8/ 0 t
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