ML20082H370
| ML20082H370 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/26/1983 |
| From: | Mary Walsh Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20082H284 | List: |
| References | |
| NUDOCS 8312010132 | |
| Download: ML20082H370 (60) | |
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AFFIDAVIT OF MARK WAl.SH Q: Please state your name and address for the record.
A: My name is Mark Walsh. I can be contacted through CASE,1426 S.
Polk, Dallas, Texas 75224.
Q: Are you aware of .iy instances of intimidation, harassment, or threatening of employees at Comanche Peak? i A: Yes.
Q: Are you aware of any 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, O . 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: Employees are reluctant to report a problem because they are afraid they will lose their jobs, When they do report problems, those problems
- are ignored or written off. When your concerns are shot down, you're not going to continue to waste your time trying to do good work. You already ;
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know what the consequences are. Everything built is to be considered correct whether it is or not.
.Q: Are there specific instances you could tell us about?
A: There are problems which I should have brought to the Board's attention earlier, but I simply forgot; and it appears that these problems are not going
. to be addressed in the design of the pipe supports. One of these, for example,
. also has to do with intimidation. While I was working at Comanche Peak, I discovered a problem with the design of the NPSI supports that would reduce the section properties by one-half at the Richmond insert A307 bolt connection.
I immediately went to the NPSI design supervisor and he agreed with me but he was reluctant to take it any further because of other problems which we s had discovered which were shot down by his home office. One of those items that was shot down is a plate that is used to -attach supports to the liner plate. Tnis plate, when analyzed, was getting stresses four times the allow-able. He reported this to his supervisor and his supervisor in turn spoke with Gibbs & Hill; Gibbs & Hill instructed NPSI, who instructed the STRUDL group not to include those plates in the analysis in the future, and that's how the problem was solved. As far as I know, it has not been taken care of since then. The NPSI supervisor I went to about this was demoted as
~ group leader when I discovered the problem with the design of the NPSI supports.
I believe he was demoted because he was making wave: .
Q: Are there other specific instances which you have not already told the Licensing Board about in your previous testimony?
A: Yes. One of the ones which I simply had forgotten about was that O
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the dry wall in the control room is hanging from wires adjacent to the con-trol panel. I feel that this is not a seismically supported item and that in the event of an accident this could fall onto the control panel or onto an operator. The NRC Region IV office issued an inspection report which stated that the wires could hold it up. I believe that the values ~ used by the inspector in that report were about 10 times larger than the allowables for the wires.
Another which I had forgotten was that the HVAC is not properly supported seismically. The NRC Region IV office also issued an inspection report on this which stated that the HVAC is designed as rigid frames.
Since we don't have the calculations and assumptions they used, I can't refute it, even though I'm not convinced that what the NRC stated is correct.
-O 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?
A: Yes. I could show them the dry wall and the HVAC I mentioned above.
Q: Would you be willing to attempt to take the Licensing Board to those deficiencies and show them?
A: Yes.
Q: Do you think that the Licensing Board would be able to see such deficiencies with the naksd eye, or would any additional testing be necessary to prove that such deficiencies exist (and if so, what kind of testing would be required)?
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O A: They could see them with the naked eye, but I would need the calcu-lations and the assumptions that were used to be assured that it was designed properly.
There are other problems of which I am aware which I didn't think of when I was testifying which probably will never be addressed by anyone.
Q: Can't you go to the NRC and tell them about the problems?
A: You've got to be kidding. That's why I didn't go to the NRC in the first place. And look what's happened with the Walsh/Doyle allegations.
The employees still out at Comanche Peak that agreed with me and Jack Doyle read in the newspapers or in NRC testimony that the NRC disagrees with Jack and. me, so why should they go to the NRC? They get the feeling that it's jt.-t like talking to the utility to talk to.the NRC.
O Q: Can you give us further specific instances of intimidation or dis-couragement?
A: Another way the utility intimidates their cmployees is with the use of a newsletter called the Circuit Breaker. This newsletter is put out particularly during the operating license hearings onsite, and witnesses for CASE are chastised in that letter. Employees still working at Comanche Peak who knew the witnesses which the Circuit Breaker is belittling know they can't
- go to the hearings because they don't want their name in the Eircuit Breaker and don't want to be belittled also. Therefore, to get witnesses for CASE to go to hearings is almost' impossible. And to go to the NRC could be worse, because they might stamp it confidential and then mail it to everybody in the nation as in the case of Bill Van Meter's " confidential" letter to the NRC. (Attached to my affidavit are copies of the Circuit Breaker and the
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O VanMeterletter.)
Q: Why should the Licensing Board be concerned about such intimidation, harassment, threatening or discouragement of employees, or such deficiencies as you may tell them about or show them at Comanche Peak? What's the bottom line as far as the safety of the plant is concerned?
A: The bottom line.is that engineering is covering up problems by the use of intimidation and the consequences are that the designs are not adequate. The supports will not perfonn their intended functions under seismic or normal operating conditions, emergency conditions, or in some instances, even during hot functional tests (and they don't test for seismic in the hot functional -tests).
Q: Do you want to testify regarding these matters in the operating license hearings for Comanche Peak?
A: Not really. But I will if necessary.
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O I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
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On this the */ d day of *////A' 2,198j,personallyappeared O . m /,/f &l/ , xaown 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.
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CISCUD. d)f:00k05 September 14, 1982 COMANCHE PEAK HEARIrlG RESUMES: ATCHISON CLAIMS PLOT The Comanche ' Peak licensing hearing resumed Monday in Fort Worth with return engagements by several interver.or witnesses and the start of re-buttal testimony by the ccmpany.
1 The hearing, before an Atomic Safety and Licensing Board of the fluclear Regulatory Commission, began with resumption of testimony concerning the quality assurance program at the plant.
Testimony on quality assurance started during the June hearing session and continued in July. Developments involving witnesses for the intervenor -
Citizens Association for Sound Energy - Monday included:
-- Disclosure by fonner welding insoector Charles Atchison that a Department of Labor Investigation has resulted in an order to reinstate him in a job at a Louisiana nuclear project - a job from which he was fired after the hearing session in July.
-- A new claim by Atchison that he is the victim of " muck-raking,", " discrimination,", " financial duress" and other
" devious deeds" by Texas Utilities, Brown & Root and companies involved with the Louisiana project.
-- Cross-examination of a fonner employee, Henry Stiner, and ,
his wife, Darlene, presently a quality control inspector I at the plant, about allegations they've made concerning welding and the adequacy of flRC investigations.
-- Brief appearances by two other fonner employees - Mark Walsh and Jack Doyle - who have made allegations concerning use of computer progr&ms to analyze the strength of pipes and pipe supports.
Atchison.was hired by a subcontractor at the Waterford III nuclear plant,4being built by Louisiana Power & Light, at the same time the last hearint session in July began. He was fired after he returned to Louisiana from the hearing.
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U According to a Labor Dcoartment letter he produced Monday, the depart-ment's investigator concluded Atchison should be reinstated because he was fired after he testified at the Comanche Peak hearing. Under the law, he was - according to the investigator " engaging in a protected activity" for which he cannot be fired.
CASE Monday offered supplemental testimony by Atchison in which he claims Texas Utilities is part of a cec piracy against him. Among other requests in the testimony, he asked the licensing board to recommend that
" financial relief" be granted to him.
Outside the hearing room, TU officials told reporters Atchison's latest claims were " ridiculous," pointing out that neither TU nor any of the companies involved with building Cananche Peak would have any reason to care if Atchison is employed elsewhere.
"Neither Texas Utilities nor any member of Comanche Peak management had anything to do with Atchison being hired at the Louisiana plant, or with his being fired," said TUSI manager of nuclear services Homer Schmidt.
"We only know why he was fired from Comanche Peak, and that was because he was not competent to perform his job."
The board will rule on the admissibility of Atchison's new testimony
,_, Tuesday. Both TV attorney Nick Reynolds and the NRC legal staff objected to its admission, pointing out its irrelevance to the Comanche Peak licensing.
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The Stiners made a number of allegations concerning welding practices at the plant and also claimed the NRC had not invastigated their allegatiens adequately in the past.
Througn cross-examination, Reynolds pointed out persons might see what they believed were problems, but have the NRC decline to substantiate their allegations because it recognized the alleged problems did not exist.
In his direct testimony, Henry Stiner acknowledged he has a criminal record. Reynolds began cross-examination to get details from Stiner about his record, but.was stopped by ASLB chairman fiarshall Miller. Miller said the board would take under advisement the question of whether Stiner could be questioned about his record and said a decision would be announced Tuesday morning.
Also Tuesday, Jack Doyle is scheduled to be cross-examined further about his allegations concerning the strength of pice supports.
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l COMPANY WITNESSES REFUTE INTERVENORS -
, .1 Witnesses for Texas Utilities took the stand Tuesday during the '. '
Comanche Peak licensing hearing to refute allegations by intervenor witnesses, including former inspector Charles Atchison.
Testimony by a panel called to give evidence rebutting Atchison and other witnesses for the Citizens Association for Sound Energy (CASE) took most of the day, primarily because of tedious and repetitive cross- .
examination by CASE president Juanita Ellis.
L The hearing is being conducted in Fort Worth by an Atomic Safety - i' and Licensing Board of the NRC. ASLB chairman Marshall Miller several times asked Mrs. Ellis to speed up her questiening, saying at one point, "We're taking so much time that it seems purposeless."
The TU panel was made up of C. Thomas Brandt, mechanical / civil l
quality assurance-quality control supervisor; Gordon Purdy, site QA manager for Brown & Root; Raymond Vurpillat, power group OA manager for Brown & Root; Ron Tolson, site QA supervisor for TUGC0, and Randall D. Smith, who was Atchison's immediate supervisor.
After testifying, members of the panel said they felt their evidence refuting claims made by Atchison and others had been persuasive.
For example: ,
-- Linear indications alleged by Atchison to mean faults in welds were shown to be actually nothing more than '
cracks in paint on the welds. ,
-- Less than 20 percent of what Atchison had thought were indications of rejectable welds were actually rejectable, l and none has any safety significance.
i -- " Weave bead" welding, claimed by some intervenor witnesses -
l to be prohibited, is in fact permitted by the industry .
I for weld beads with a width up to four times the size of '
the rod used to make the weld.
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-- Torque seal, said by allegers to have been used at '
l sy Cemanche Peak by persons not qualified to possess and :.'
l use it, isn't used at all at many nuclear plant con-struction sites, and the control of its use is not ". , .
required.
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TU attorney Nick Reynolds also touched briefly on a finding in a -
- 1.u d 'd, S Department of Labor investigation that Atchison had been discriminated
- ".. against when he was fired from a job at a Louisiana nuclear project. " ' .3.j;j.hh,h Among reasons the Department of Labor gave for ruling that Atchison
'i. h"'I'h' should be reinstated was the fact that some Comanche Peak employees -
including Brandt - once worked at the Louisiana project and some '
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(..gp Louisiana employees now work at Comanche Peak. ,
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Reynolds established that Atchison himself had told the investigator Ni}.Ik that Brandt once had worked at the Louisiana plant. After Tuesday's . ;1(d.:-l session, Brandt said he not only had never discussed Atchison with any- '
4v one at the Louisiana project, but had never even been contacted by the :,w'p . ul@ 'l *.
Labor Department investigator. M" ..
"It is noteworthy to coint out," said TUGC0 1A manager Dave Chapman ;
after the session, "that during these proceedings we've been hearing from hd.i!!AQ ef a few individuals, most of whom are disaruntled and miscuided former employees. Not a single safety issue has been identified by any of them." . .,
. "For every one of these people, I can identify a hundred capable, . ,; f?','.-
hard-working, credible employees who are doing good cuality assurance ,'
- jobs every day at Comanche Peak," he said. 'i- , , -
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stress analysis area at the plart, Jack Doyle. Doyle admitted that, ,..;, "
until he talked to plant expert, while.giving his disposition for the y,ik hearing a month ago, he had not been aware that his group did not have f' the final word concerning pipe suoport safety. y"l,y
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He admitted he had not known that a series of reviews are done - -^".,*'i including the final stress analysis - to make sure the pipe supports are '
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sare. 4 A panel of witnesses for the company began testimony late Tuesday to refute the testimony of Doyle and one of his co-workers, Mark Walsh. .i .
The panel will continue Wednesday. '%'y.'
Mrs. Ellis said at least three people will appear when the session .4yiv 7d g begins Wednesday to make " limited appearance" statements opposing Comanche Peak. .
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%g wmSeptember 16, 1982 ~h ENGINEERING PANEL REBUTS PIPE SUPPORT ALLEGATIONS
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A young graduate engineer spent part of Wednesday's session of the Comanche Peak licensing hearing trying to prove the man who wrote codes ,
governing certain plant construction activities doesn't understand the codes.
Mark Walsh, who was employed in the frame analysis group at Comanche .,
Peak, was a witness for the intervoor during the July session of the hearing. Walsh himself conducted cross-examination of the panel of .
witnesses the company called to refute his allegations, which center M't around the strength of pipe supports. '
Tne panel includes Roger F. Reedy of California, chaiman of the '
Section III Code Committee of the American Society of Mechanical Engi- '
Os neers (ASME) and author of much of its contents. .
Walsh, who has had five years of professional experience, spent -
several hours Wednesday asking the five-person company panel questions designed to show the panel is uninformed, unqualified and does not understand the engineering codes which apply to construction of pipe .
supports and hangers at Comanche Peak. -
At one point, Walsh tried to indicate it was wrong for field engineers to make modifications to designs of pipe supports, subject to later approval by the support designers.
Reedy made note of his 26 y' ears of exoerience designing compo-nents for nuclear plants, and said, "I've been associated with at least 50 nuclear plant construction projects. This," he said of the field engineering procedure, "is how it's done."
At another point, Walsh cited a paragraph in the code dealing with a process for fonning steel components, and handed out a chart dealing with stress factors on steel.
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1 "I was the author of that paragraph," Reedy said, adding that -
the chart " appears to be out of an elementary textbook on materials."
Other members of the panel include Kenneth Scheppele of New s
Jersey, senior vice president of Gibbs & Hill (the plant's architect -
J engineer); Dr. Peter S. Y. Chang, chief engineer of the pipe support engineering group; John Finneran, Jr., TUSI project pipe support
- engineer; and Gary Krishnan, site stress analysis group superviso.r. ,. L
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Walsh's cross-examination on behalf of CASE was a repeat performance of Tuesday's session. On both days, Atomic Safety and Licensing Board chaiman Marshall Miller and other board members kept having to ask CASE president Mrs. Juanita Ellis to speed up.
Board member Dr. Kenneth McCollum told Walsh and Mrs. Ellis they were " blue-skying all over the West" in their questioning, and were not producing any testimony that would help the board.
kednesoay's session began with three persons making " limited appearance" statements on behalf of CASE. They included Betty Brink, a Fort Worth anti-nuclear and anti-utility activist, and two more fomer Comanche Peak employees. (A limited appearance statement is not con-sidered evidence and, since it is not made under oath, is not part of the official testimony.) -
The two former employees were a me:hanical welding insoector, Bob Bronson, who said he resigned tro weeks ago when he was placed under the supervision of people he said were less qualified than he is, and James Yost, an emoloyee in the pipe support engineering g,oup who said he had been laid off because he was " burnt out...tno old from the supervision point of view."
U,, Yost complained about " design criteria always changing," and Bronson charged the plant makes widespread use of unoualified, inexperienced and under-educated personnel.
Bronson made several personal attacks against key people at the plant.
Gordon Purdy, Brown & Root site quality assurance manager, prepared a statement in response, in which he points out that his organization staff includes managers and supervisors with in serage of 15 years' fomal education and 15 years' related experience, almost all., in nuclear quality assurance / control.
"The licensing hearing is public, and it provides a convenient forum ,
for a handful of former employees who have a grudge against management or their co-workers to air their complaints," Purdy said. "We can't I control what these people may say during these sessions, but we are taking the opportunities available to point out that Comanche Peak is being built i by people who are skilled, well-qualified and dedicated to making it a safe, reliable' plant."
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l September 17, 1982 LICENSING fiEARING MOVES INTO EMERGENCY PLANNING PHASE Testimony on emergency planning for the Comanche Peak. plant site and surrounding area began Thursday at the plant's licensing hearing before an Atomic Safety and Licensing Board.
Emergency planning and the quality assurance program for the plant are the only two issues remaining to be heard by the ASLB before it makes a recommendation to the NRC on an operating license.
Although most testimony o'i quality assurance was completed by Thursday, the issue apparently will not be considered resolved until the staff of the Nuclear Regulatory Commission presents rebuttal testi-many to allegations made by two former plant employees.
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( Another hearing session at a later date may be necessary for the staff to present its findings.
The NRC staff initiated testimony Thursday in which it supports the company's contention that allegations by former employees Mark Walsh and Jack Doyle are groundless. Walsh and Doyle have claimed that analysis of the effects of thermal stress on pipe supports is necessary before it l can be determined the supports are safe.
NRC witnesses Joseph Tapia, a reactor inspector, and Paul Chen, a stress analyst for the Department of Energy who provides technical assistance to the NRC, noted that sone of their studies of pipe support designs - studies which will provide information related to Walsh' allega-tions - are still in progress. And they said they have not yet started looking into allegations by Doyle, who only surfaced with his charges -
very similar to Walsh's - in recent weeks.
ASLB chairman Marshall Miller instructed the staff to continue its work and prepare new testimony, which apoarently would be presanted at a later hearing session. The NRC review to date supports the company's i position that the pipe supports are designed and installed safely. )
At the start of Thursday's session, company expert witnesses attempted I to clarify the issue of thent.al stresses on pipe supports and whether codes of the American Society of Mechanical Engineering (ASME) require 1 computer analysis of those stress effects.
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d Xenneth Scheppele,'vice president of Gibbs & Hill (the plant's architect-engineer), pointed out that Walsh and Doyle apoear to believe the supports holding pipes that carry plant cooling water could collapse or be " ripped out of the walls" because of expansion caused by temperature chares. . They believe the ASME code requires analysis of the effects of thersal stresses. This is not the case, said Scheppele and Roger Reedy, an expert on the ASME code and author of many of its provisions.
They, and other members of the company panel of witnesses, testified that the supports will not collapse or be pulled out of the walls under the conditions specified by Walsh and Doyle.
Reedy emphasized Walsh and Doyle are wrong in their belief that the ASME code requires analysis of thermal conditions for piping supports.
" Thermal stress is not required to be analyzed," said Reedy. "It states very clearly - extremely clearly - that thennal stress does not need to be analyzed for any kind of component support."
Comptny witnesses also have emphasized this week that the pipe supports undergo exhaustive reviews to make sure they are safe, reviews that Walsh and Doyle - who worked in one relatively small computer service group - did not know about.
q The first segment of testimony on emergency planning got off to a V fast start. The panel testifying about on-site emergency olanning was on the stand less then 30 minutes. This panel consisted of Dick Jones,
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TUGC0 manager of plant operations at Comanche Peak; Bobby Lancaster, TUGC0 radiation protection engineer; and Dr. Roger Linneman of Radiation Management Corporation.
I CASE president Juanita Ellis, more interested in off-site planning,
. asked the on-site group few questions. During the last half hour'of l Thursday's session, she began more e:ctensive ouestioning of the off-site group: Alton Armstrong, resource planning officer with the Division of
, Energy Management of the Texas Department of Public Safety; Clarence Born, manager of the Emergency Response Planning Progrrm, Bureau of Radiation Control of Texas Department of Health; Larry Skiles, emergency planning consultant; and Arthur C. Tate, environmental quality specialist with the Eureau of Radiation Control of the Texas Department of Public Health.
This panel will continue its testimony when the hearing reconvenes Friday morning.
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CIPm 3 bC80ker-September 20, 1982 HEARING SESSION ENDS; ANOTHER CONSIDERED LIKELY The latest round in the Comanche Peak operating license hearing ended at noon Friday, with indications that one more session may be needed to allow the Nuclear Regulatory Commission staff to rebut allegations concerning pipe supports.
Testimony concerning emergency planning was concluded Friday morning.
Atomic Safety and Licensing Board chaiman Marshall Miller set October 12 as deadline for all parties involved to submit briefs giving their opinions about what other material or infomation the ASLB needs before it makes its decision on the operating license.
The ASLB has told the NRC staff to continue its review of allegations made by fomer employees Mark Walsh and Jack Doyle, who claim that analysis of the effects of themal stress on pipe supports is necessary before it can be detemined the supports are safe.
To get the staff's report, "it seems obvious we are going to have a further hearing," Miller said at the end of Friday's session.
Texas Utilities attorney Nick Reynolds concurred that there is a high likelihood that another session will te necessary.
Reynolds said tne company's position - which will be reflected in its brief - is that all the evidence necessary for the board to make its decision is now in the record. However, he said he expects the NRC staff and the intervenor (Citizens Association for Sound Energy) to take the position that another hearing to get the staff's report is necessary.
Evidence presented by the company's panel of expert witnesses showed that Walsh and Doyle misinterpreted the codes governing construction of pipe supports and, further, that they did not understand the full scope of the review process designed to ensure the supports are safe.
Reynolds and nuclear services manager Homer Schmidt said Friday they felt the testimony during the week was persuasive in proving the company has a good quality assurance program and that superior emergency plans have been devised by plant officials, officials of Somervell and Hood Counties and the state of Texas.
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The panel on off-site emergency planning - which includes planning for an emergency planning zone (EPZ) about 10 miles in diameter and an EPZ about 50 miles in diameter - was on the stand Friday morning.
Members were Alton B. Armstrong, Jr. , resources planning officer for the Texas Department of Public Safety's Division of Emergency Management; Clarence L. Born, manager of the Emergency Response Planning Program, Bureau of Radiation Control, fnr the Department of Health;.
Arthur C. Tate, environmental quality specialist with the Bureau of Radiation Control; and Larry J. Skiles, an emergency planning consultant who helped draw up the county plans. '
They testified that responsible agencies had provided emergency plans with adequate personnel, communications and facilities for the 10-mile EPZ (which includes the area where protective action might be necessary in event of a serious accident) and the 50-mile EPZ (where any foods or liquids affected by radioactive materials would be identified and con-trolled).
Armstrong testified the communications system for use in an emergency was well established by existing state and local agencies. "Last year, we responded to more than a thousand emergencies using this communication system." Many, he said, involved radiation.
- He said procedures for Comanche Peak "will be no different from other emergencies we go through every day."
CASE, through its cuestioning, implied that the agencies had no experience with radiation. Armstrong pointed out that the DPS deals with radiation almost every day, primarily accidents involving vehicles carrying radioactive materials used by universities, research, medical and industrial facilities.
Tate said he felt Texas has more resources for responding to radio-logical emergencies than any other state. An official of the Federal Emergency Management Agency told Reynolds after the hearing that the panel of state witnesses was the best he had ever seen in any of the 14 states in which he had attended similar licensing hearings.
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g auc'e^a aeou'^Toav co==issio" WASHING 7 ON. D. C. 20555
%,....,[ - November 24, 1982 MEMORANDUM FOR: The Atomic Safety & Licensing' Boards for:
Callaway Plant, Unit 1 '
- Clinton Power Station, Units 1/2 Comanche Peak Steam Electric Station, Units 1/2
- Enrico Fermi 2 Midland Plant, Units 1/2 Palo Verde Nuclear Generating Station, Units 1/2/3 Shoreham Nuclear-Power Station South Texas Project 1/2 Waterford Steam Electric Station, Unit 3 William H. Zimer Nuclear Power Station, Unit 1, and The Atomic Safety & Licensing Appeal Boards for:
Offshore Power Systems, FNP l-8 Comanche Peak Steam Electric Station, Units 1/2 Diablo Canyon Nuclear Power Plant, Units 1/2 San Onofre Nuclear Generating Station, Units 2/3 O'_' Virgil C. Summer Station, Unit 1 Susquehanna Steam Electric Station, Units 1/2 .
William H. Zimer Nuclear Power Station, Unit 1 l FROM: Thomas M. Novak, Assistant Director for Licensing Division of Licensing, ONRR
SUBJECT:
BOARD NOTIFICATION - ALLEGED DESIGN DEFICIENCY (Board Notification No.82-105) t In accordance with present NRC procedures regarding Board Notifications.
the enclosed'information is being provided for your information as constituting new information relevant and material to safety issues.
- An alleged generic design deficiency in ASME Code Class 1 piping has been received by the NRC staff. The concern in this allegation is that the effects of local pipe wall. stresses, due to support loads introduced by pipe clamps, are not being , evaluated properly. _
This concern potentially relates to all plants (BWR and PWil) currer.tly under OL review. It is NRR's experience, as gathered from our own audits on NT0Ls and from the Independent Design Review Program, that the effect of support reactions on piping is being considered by system designers. Specific O support and piping design criteria are committed to by all applicants; however, i C/ the level of the NRR review does not generally address pipe clamp details J unless inspection during construction raises questions.
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Contact:
Suzanne Black, ONRR '
X29788
November 24, 1982
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The Atomic Safety & Licensing Board The. Atomic Safety & licensing Appeal Board The magnitude of the problem discussed in the allegation nature assessment.
of the alleger's concer.ns, we would not be able to make .
- in the interview of the alleger in the near future.
A complete failure to deal with the pipe support-pipe in and could affect prior NRC staff positions Furthertaken in Safety information willEvaluations be providedand upon other documents on a generic basis.
any significant findings by the staff.
Thomas M. Novak, Assistant Director for Licensing Division of Licensing, ONRR
Enclosure:
Q As stated cc: Licensee / Boards Service List e
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b WASHINGTON. D. C. 20555 Y [I$ September 30, 1982 si MEMORANDUM FOR: Darrell G. Eisenhut Director Division of Licensing ,
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FROM: Rfchard H. Vollmer, Director ,
- Division of Engineert'ng
SUBJECT:
ALLEGED DESIGN DEFICIENCY--POTENTIAL BOARD j NOTIFICATION ITEM i An alleged design deficiency in ASME Code Class 1 piping which is discussed in the . attachment letter to Chaiman Palladino was brought
.] to our attention by the NRR Director's office. The concern in this a allegation is that the effects of local pipe wall stresses, due to i support loads introduced by pipe clamps, are not being evaluated I -
properly. .
This concern potentially relates to all plants (BWR and PWR) currently
! under OL review, but to our knowledge it is not the subject of any con-l tention in any operating reactor hearing. It is NRR's experience, as l j gathered from our own audits on NTOLs and from the Independent Design I . Review Program, that the effect of support reactions on piping is being l j considered by systen designers. Specific support and piping design 4 criteria are committed to by all applicants; however, the level of the l
NRR review does not generally address pipe clamp details unless in-
] .spection during construction raises questions.
} The magnitude of the problem discussed in the allegation has not been assessed, and, in fact, without more precise infomation regarding the
-f exact nature of Mr. Van Meter's concern,.we would not be able to make such an assessment. We expect that we will be assisting the Office of
- Investigations in evaluating the significance of the allegation.
A complete failure to deal with the pipe support-pipe interface design issue, as implied in the enclosed letter, would be a serious matter
} if substantiated. As this infomation appears to meet the guidelines
~
of Office Letter No.19, 'we reconnend the licensing board be notified.
~
i
- - RichardH.VoIlmer, Director
Enclosure:
, As stated.
\
s _ __ -
s 415 Perkins St
. /-
, =.* .
Oakland, CA 94610 .
/# -*
CONFIDEAPIAL August 18, 1982
~ -
Mr. Nunzio Palladino Chairman NRC U.S. huclear Regulatory Commission
_ Washington, D.C. 20055 Statement: CONFIDENTIAL IhFO,RMATION
- 1. The information contained herein is furnished to the United States Auclear Regulabory,Ccmmission (hRC) under 10 CFR 21 as Confidential Information and is marked l . .as such. This information may not be disclosed without the written consent of William Van Meter; but,the
~
information may be used by the NRC, as a source, for '
obtaining information under their own powers.
En' closure 1: " Nuclear Power Plant Piping Legal Requirements", hotes by hilliam Van Meter, 8-13-82.
~
Subject Serious design deficiencies in nuclear power plants, concerning class 1 piping.
Dear Mr. Palladinos
' () It is with deep regret that I must inform you of the following deficientcies in nuclear power piping.
I consider these so serious, and which may undermine
- the U.S.A. nuclear program, that I must bring these matters directly to your personal attention.
- 1. I have spent the past 30 years in piping design work.
For the past 13 years I 4 ave been involved in piping desigh work for numerou nuclear power plants. For the past 4 years I have been employed by Western Consulting i
Engineers, 440 Grand Ave, Oakland, CA 94610.
- 2. Since seismic or other dynamic analysis of nuclear piping has been rather recent, i.e, since from about the -
year 1969, I am familar with the development history of the methodolgy of piping seismic analysis.
- At first, the piping support restraint seismic loads were small, and therefore there was not a problem local strain,s imposed in the piping with wall thedue additional to said loa,dii.
This was based on a judgemental evaluation, as , .
l there was not any good economical method to analyize the "
thick walled pipes.
Later, the piping support restraint seismic l loads became large, and in some dynamic cases they are herrendous.
~
e20 010001 se ," ' ==
- T r" r I & b .i T.ILt u
.- m . -- - -- - - - _ , - - - - - . - - - - . -
e....- . - - . . . .
nilliam van Meter
. . . - - - > er ,,..n,,,,
_,_)
' - Page 2 O..
/ 3. The' piping seismic analysis is 'ususly performed by personnel termed stress analysists and called "the stress group". The piping support design is usualy performed by personnel termed pipe support designers and called the " pipe support group"'.
A. The pipe stress analysis is performed by computer progr7m with the total load assumed distributed across the entire pipe wall cross section. This is because this method is built into the computer mathematical programs
. and is state-of-the-art. ,
B. The pipe support de' sign is u'sualy accomplished by human decision selection of pipe attachment components that will satisfy the pipe total load for the pipe support component portion only. .
- 4. The method described in paragraph 3 is satisfactory if the piping loads are small, which was true for early nuclear plants. However, the loads have increased substantia 1y in later plant seismic design, and the effects of local pipe wall loading are significant.
In addition, pipe clamps are used in a negligent manner that causes additional stress in the wall of the pipe, in the case of stainless steel' pipes. Hence, the (3 methodology of evaluating this problem practicaly and
() economicaly was never developed, and consequently no analysis is perfornod.(See Ref. Ic, page 45, line 10 Ref. Ib, page 30, line 10.)
- 5. The need for analysis is recognized by the ASME Code, f
and is a part of the requirement of said code.
(See paragraph 3 of Enclosure 1)
- 6. If the effects of local pipe wall stress are not evaluated properly, the piping system is not lecal, which' consequently puts the licenses of the plant in-
- question (See Enclosure 1- hote this has been reviewed '
by the.NRC, except f or the technical sections, which are.
straightforward, see Reference 2.). .
- 7. Therefore, in view of the foregoing paragraphs, many of the nuclea.r power plants under construction and .
operation are in serious violation of NRC licensing regulations and could possibily be unsafe. ,
I trust that you will take positive action on this information, without delay, and you can expect my fullest cooperation in this matter.
Yours truly,. -
O Q' rn &
. WVM vvm ,- William Van Meter enc 1. . .
9
- 4. _
Page 3 o//., .
- x . .
.j . .
References
' 1. Van Meter vs Western Piping, U.S. Distric Court, Northern California, Civil Action No. C-81-2262 RHS:
a ) Deposition: Joe Majors, General Electric huclear b) Deposition: Javad Gangi Deneral Electric Auclear c) Depositions Henry Hwang, General Electric huclear
- 2. Letter from ' William 'Olmstead, NRC-Director and Chief Counsel, to d. Van Meter, 8-2-82.
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i e
e I -
O .
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. y
- r l
- Page 1 l 2-20-82: <.evised 8-13-82 .
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s huelea r Power Plant Piping Lecal Requirements .
gpr '
- by William Van Meter t
- 1. Nuclear power plant' construction, including design, )
and operation are controlled by the U.S. Nuclear Regulatory J
l Commission (NRC), an independent federal agency, established l
! . by the Energy Reorganization Act of '1974, 42 U.S.C. f l Article 5801 et sea. The NRC has the statutory responsibility l for prescribing licensing standards to protect' public health and safety and for inspecting industry's activities against these standards. The regulated industry bears the primary responsibility for the proper construction and safe operation of licensed facilities.
The NRC uses the " Code of Federal Regulation, Title 10. Part 50" (10CFR50), and in addition Parts 19
" 20, 21, 73, 75, 100 and Part 140 are also used to deal with reactor safety (either directly or indir'ectly), as the legal. establishment con,cerning nuclear power plant safety, and controls the plant construction and later, operation by issuing permits for these functions.
- 2. Prior to the commencement of the plant construction, the utility (permit holder) must furnish to the hRC, under 10CFRSO, article 50.34 " Technical Information",
by paragraphs: -
g paragraph (a ) " Preliminary Safety Analysis Report" (PSAR).
paragraph (b) " Final Safety Analysis Report" (FSAR), and by paragkaph (2) " Analysis Basis" which is included in the FSAR.
And stated in Article 50.55a." Codes and Standards",
by paragraphs :
paragraph (i) " Design to recognized Codes" paragraph (b)(1) "Section III of ASME Code" .
paragraph (d) " Piping"
~
paragraph (d)(2') " Construction Permits" '
paragraph (d)(2)(ii) *' requirements of Class l piping of Section III of AStiE Code."
a f
. 7
.. a.. rer american soclecy or necnanica A engineers soller .... i . ',
and Pressure Vessel Code",Section III (Rules for . '[:,, ...,
O,s *,.,
Construction of Nuclear Fower Plant Components), . , , ,~, '
Division 1 Subsection hB (Class 1 Co'mponents), the following excerpts.from the section .on Design- ha 3000, are given for Class 1 piping. .( Notes Class 1 piping has the higher order of subsequent . numbered classes, and is defined as those systems that through inoperation would compromise the saftey of the plant in preventing the exposure of radiation to the public.)-
paragraph NB-3624 (Page 118.1 ) : States the
" ... restraining effects of hah ers, supports { clamps],
[ J l and other localized loadings { local' stress to the
, pipe wal(]." ,
paragraph NB-3625 (Page 119): States the stress analysis shall be done for said loadings.
paragraph NB-3645 (Page 127): States the effect of a ttachments
' piping] shal[ lclamps) on pressure be checked retaining with stress members criteria. This 7ould We the effect of thermal constraint stress (Lock-up).
Al'so included is the reference from Class 2 L
piping, Subsection NC, on the same subject, which is more explicit in context: paragraph hC-3645 (rage 152).
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e
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. ... . ,,. ... . ,,..... ecx ine NH.3622.4 Relief and' Safety Valre Brust. De D
- wd!! thic'kness of the pipe shall be increased or,if this effects of thrusts from relief and safety valve loads
[O . . ' la impractical or would cause e.scessive local stresses, from pressure and flow transients shall be considered
'the superimposed loads or other causes shall be in the design of piping, pipe, supporu,' and restraints.
. reduced or climinated by other design methods.
See Appendia O.
. .s
- 1. .- NB.3620 DESIGN CONSIDERATIONS NB.362.3 Weight Effcets NB.3621 Design and Service Loadings p;p;ng systems shs!! be supported to provide for the
.t."
Re provisions of NB 3110 spply. efects of live and dead weights, as denned in the l . . .
. , fo!!owing subparagraphs, and they shall be arrsnged ~
or properly restrained to prevent undue strains on
, NB.3622 Dynamic EEcets -
g . . equip. ment.
NB.3622.1 Impset. Impset forces esused by either . .
external or interns! loads sha!! be' considered in the 623.1 Uyp Weigh De 12ve weight shall P8Psag design.
consist of the weight of the auid be, m g handled or of J the Buid used for testing or c! caning, whichever is
.- NB 3622.2 Earthquake. The etrects of earthquake grester. ,
- ', shall be considered in Ge design of piping, piping g,gg g g supports, and restraints. The losdmgs, movements . .
(earthquake anchor movements), and number of c ns st f the we.ight of the p. .ipmg, msutstion, and cycles to be used in the analysis shall be part of the ther losds permsnently tmposed upon the pipung. ,
..- Design Specifestions. De stresses resulting from -
. these carthquake efects must be included with weight.
pressure, or other applied leads when culing the N3 3624 Thermal Expansion and Contraction
, required analysis.. .
Loads . .
\ -
NB.3622.3 Vibration. Piping shall be arrant,ed and NB.3624.1 Loadings, Displacements, and R e-I supported so that vibrstion will be minimized. The straints. He design of piping systems shall tske into l
- i designer shall be responsible, by desipi and by I account the forces and rnoments resulting from observation under startup or initial service conditions, thermal e.tpansion and contraction, equipment dis.
for ensuring thst vibration of piping systems is within placements sad rotations, and the restraining efects of acceptab!e levels. bangers, supports, and other locahzed loadings.
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- ND 3000 - DESIGN N8 3624.3 NB.3630 i .',. ,
nestion rrisy be designed in secordance with the design *
., NS.3624.2 Analysis of Thermal Espansion and requirements of Subsection NC.
% Contraction ENects. The analysis of the efects of (2) Class I piping may be snalyzed in accordance therms) expansion and contraction is covered in NB. with the Class 2 analysis of piping systems in C 3672. Subsection NC, using the allowable Class 2 stresses and stress limits provided the speci6ed servicp loads NB.3624.3 Provision for Rapid Temperature Flue-for which Level A snd D Service Limits are designated
- tustion Effects.The designer shall provide for unusual meet all of the requirements stipulated in (a) through thermal espansion and contraction loads caused by gapid temperature Auctuations. (e) below. .
(a) Atmospheric to Service Pressure Cycle. The spcci6ed number of times (including startup and
~ Stress Analysis shut,down) that the pressure will be cycled from NB.3625 atmospheric pressure to service pressure and back to A stres's analysis shall be prepared in sufficient atm SPherie pressure during normal service does not t
detail to show that each of the stress limitations of* ***d ** "# # "Y'h '" .the 3PP csb!c li fatigue NB 3640 and ND.3650 is satisfied when the piping is curve of Figs. I.9.0 corresponding to an S, value of i d to be considered by three times the S,, value for the materist at service
.. subjected to ,,, the loadings requ re g3 temperature.
(b) Normal Service Pressure Fluctuation. The specified fuU range of pressure fluctuations during normal service does not exceed the quantity $ X NB.3630 PIPING DESIGN AND ANALYSIS Design Pressurc X (S/S,,,), where Se is the value
- CRITERIA obtained from the appl. cable design fatigue curve for the total specified number of significant pressure 'j I
(a) The design and anslysis of piping when sub. cuctuations and S.,,is the allowable stress intensity for l jected' to the individual or combined effects of th'e the materis! at service tempersture. If the . total i loadiogs deined in NB.3100 and NB.3620 may be Specified number of significant pressure Suetustions (
performed in accordance with this Subarticle. Desi;n
(
exceeds 10, 8 the S, value at # == 108 may be used. l for pressure loading shall be performed in accordsuce Significant pressure fluctustions are those for which l
! with the rules of NB 36s0. Standstd piping products the tots! excursion exceeds the quantity: Design that meet the requirements of ANSI Bl6.9 or ND. Pressure x 4 x (S/S,,,), where S is the value of 3, )
3649 satisfy the requirements of NB.3640, and only obtained from the applicable design fatigue curve for the analysis required by NB.3650 need be performed. ' '
- j (b) Within a given piping system, the stress and 10' cycles.
)' . (c) Tempercrure D@'erence - Startup and fatigue analysis sha!! be performed in accordsnee with Shutdown. The tempersture difference. "F, between i
one of the metfl ods given in NB.3650. ND.3200, or any two adjacent points of the component during Appendix II. Stress indices are given in ND 3650 for normal service does not exceed S/2Ea, where S,is standstd piping products, for some fabricsted joints, the value obtsined from the applicable design fatigue and for some fabricated piping products. Some piping curves for the specified number of startup-shutdown '
products designed for pressure by applying the rules of
, cy:les, a is tbe value of the instantaneous coefficient of NB 3649 enay not be listed in ND-3680. For such therms! expansion at the mean value of the# tempera.
- y products,' the designer shsU determine the stress
.. tures at the two points as given by Table I.5.0, and E Indices as required in NB.3650.
(c) When a design does not satisfy the requirements is taken from Table I.6.0 at the mean value of the of NB 3640 and ND-3650, the more detailed alterns. . temperature at the two points.
(d) Temperature Defernce - Normal Ser.
tive analysis given in NB.3200 or the experimental l vice.:' The temperature di!Terence. 'F, between any stress analysis of Appendix !! may be used to obtain ~
stress values for comparison with the criteria of ND.
3200. **^d""' P
'I"' ' da'd ** r*i"u .hich an spaced feie than (d) The requirements of this Subsrtic!'e shst! spply the dmance 2 V AI from each other. where A and t are the mean to agg glass I piping except as exempted under (1) or ,,4w, .no ih,ch.ncsi, respecii,ctr. of the vesiet, ner.sk. naase. or other rornponent in which the poinu are located. l
. * (2) below, **'* *8 """* '* d' Aa'd 28 "" * ' h* ' Lh 'a''*** **d I O)
(1) Piping of I in. nominal pipe size or less which '"*'" """ '#'* ' " 8' has been classified as Class I in the Desi,n T SPeci. A Limits. Lesel D Limiu. or Tesung t.'imiu are desig
. 319 - l
. s !
. p .
. . s C'**, .;. =; .. ; .
. 2. .- .
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.. I a . . , . * . .
- s .,. . .. j .
. , s
- 1) . .
g g% ,
r'
- s e
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8* 1/2 angle betweeen
. . .. .o .ceni m.i.,.... .
.. ,^ w. . .
.. , s mine, no.c;n, a: e.ni., . .
sin.
) .
,. . FIG. NS-3M4(bbi MITER JOINT GEOMETRY
. . r . .... . . .. . .
. ' (b) De half width of the reinforcement zone for the discentinuity stresses that exist at thejunctic$
shall be limited as shown in Fig. NB.3M3.3(s)-3: between segments. The discontintury stresses are
., . . . . . . , reduced for a given miter as the number ofses:sents is
~
4.d '
- increased.
(b) The angle 9 in Fig. NB-394(b)-l shall not be
~
(3) Metal Availablefor Reinforcement. ne rein- more than 22's deg. .
forcement area shall be the sum of areasi A + A: + A 3 (c) The center line distance S between adjac:st deaned in (s). (b). and (c) below and she m2 in Fig. miters shall be in accordance with Fig. NB-344(b) 1.
- f. NB-343.3(a)-3. hietal counted as reinfore taent shall - (d) Stress indices and Se.tibility (seters sha!! be m
( not be applied to more than one opening.
(a) Area As is the arcs lying within the determined in accordance with the requirements of Appendix II.
reinforcement zone that results from .iny excess
- thickners availabic in th: wall of the branch pipe: - g N NB-3MS Artschment_s
. .*. ..: A = 2 La(T's - re ) .
(a) Lugs, brackets stireners, and other artschzinents
- * (b) Area As is the ares lying within the may be welded, bolted. or studded to the outside or-E reinfore: ment zone that results from excess thickness inside of piping. The effects of artschments in produc.
availabic in the lip of the extruded outlet: ing thermal stresses. stress concentrations, and re-straints on pressure retaining members shrl! be taken A.- 2r.(T. - T*.) into account in checking for cornp!Isnee with stress criteria.
)
(c) Area A3 is the ares lying within the (b) Figure NB.44331 shows some typical types of reinforcement zone that results from any excess acceptible attschment wc!ds (NB-8430).
thicknessin the rsn pipe wall: , ,
- A s = d ( T', - t,) N B-3 M Cosuru (a) Cosures in piping systems may be made by use of closure 6trings, such as blind Sanges or thresded or
. NB-3M4 hilters welded plugs or esps, either manufr.ctured in accor-Mitered joints may be used in piping systems under dance with standards listed in Table NB-31321 and the conditions stipulved in (s) through (d) below. used within the specided pressuro-temperature rat.
(a) De minimum thickness of a segment of a miter ings, or made in accordance with (b) below.
shall be determined in accordance with NB.3Mt. Tne (b) Gosures not manufactured in accordance with minimum thickness thus determined does not allow the standards listed in Table NB:31321 may be rnade
- ID
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.~.m..,,....c.,._..._.
- _ . .~ , m s
.. : y - ,
- x> .w*
. ay. N
- g. , m. , q Y :s ll.'inforrrmrnt of.tfultiple Openings. When sny .
/ . ,p'or more Adjacent openings are so closely spaced (d) The center line distance between adjscent miter' s S * *:hi at the reinforcement'rones overlsp, the two or more sha!! be in secordance with Fig. NC-3673.2(b)-l.
~
. L'f." i !
~
((, spenings sha!! be reinforced in accordance with NC- (c) Full penettstion welds shall be used in* joining? U 1 c '..*..:0 rniter segments.
} 3643.4, with a combined reinforcement that has a .
, Qdi y
- strengtIs equs!'to the combined strength of the
~
- a. c.gffp 5 %-
reinforcement that would be required for separate N-openings. No portion of the cross section shall be 5. J . O.lI iW.
NC3MS Attschments '*
^
-. , " [
. considered as applying to more than one opening or be ,
evalusted'more than once in s combined stes.
.. et' External and interns! sttschments to pipmg shs!! be ;
(h) Marking. In addition to the above, the Cer-designed so as not to cause f!sttening of the pipe,. . ; <
tificateRolder shall be responsible for establishing and **455I'* IOC*Nzed bending stresses. or hstmful ther ,
marking on the section contsining extruded out! cts, mal gradients in the pipe wa!!. It is important that, .
y ,..
, y , 4 :'
the Design Pressure and Tempersture and the Cer- such atischmen,ts be designed to marumaze stress : ',
titleste Holder's name or trsdemark. * "**"#" "5 ** 8Pplications where the number of
'.f ay4
, NC 343.5 Dranch Connections Subject to External stress cycles, due e. her to pressure or thermal c:Tect. is, it '
- M. ,
Pressure relatively large for the expected life of the equipment.: j ,,
~
(J) The reinforcement stes in sq. in, required for r ~%"..
branch connections subject to external pressure shsil
. , w '. A dkN -
l '
'?"' $
,'be 'O.54 (r,,,4) (d i ) (2 - sin a). See NC-3M3.3(c)(1).
NC3M6
'(b) Procedures established for connections subject Closures O
@N O .
tp lnterns! pressure shs1! spply for conri"ections sub;ect Th to, externs] pressure.
(a) Closures in piping systems shall be made by use of closure fatings, such as blind flanges or threaded or . i 9
, yy welded plugs or esps either manufsetured in accor. ' 34 L NC 3M3.6. Reinforcement of Other Desi;ns. ~he T 7,: %;.
adequacy of designs to which the reinforcement dance with standards listed in Table NC-31321 and 3 vsed within the specified pressure temperature rutings, g ' "'$ : ,
C, requirements ved by burst or proof of testsMC (NC-399)3M3 or made in accordance with (b) below.
cannot be applied shall be.
on scale (b) Closures not manursetured in accordance with _
.v M
- f .Jg.
, cis or on full size structures, or by calculations ..
the standards listed in Table NC-3132.I may be made. - "
f j [$ J
-previously substantisted by successful service of simi-r lay. design. in accordance with the rules contained in NC 3300 of .v -
this Subsection using the equation r,,= t + A, where .
'y e.
t,,,= minimum required thickness,in. . gs e. i.
' NC 3644 Miters t= Pressure design thickness. es!cu!sted for the ,,
, ]y
' given closure :hspe and direction of Josdmg , g,-;t . .
Mitered joints may be used in piping systems under
- using appropriate equstions and procedur:s ' ,W W
~ ' tha conditions stipulsted in (s) through (c) below. in NC 3000,in. > > '
(t) De thickness of,s segment of a miter shall be d;termined in sceerdsnee with NC-3MI.l. The re-A= sum of mechaniest s!!owances (NC-3613),'is.
(c) Connections to closures may be made by weld -
-[Q' '
quired thickness thus determined does not sjlow for ing. extruding or thresding. Connections to the th3 discontinuity stresses which exist at the junction , y,3 -
closure shall be in accordance with the lirnitations between segments. The discontinuity stresses are i provided in NC 3643 for branch connections. If the , pt reduced for a given miter as the number of segments is i/ J '.
size of the opening is grester than one half the inside' (ncreased. Dese discontinuity stresses may be ne-
- g)f ';
~
diameter of the closure the opening shs!! be designed i glecttd for miters in ncncyclic services with incom- 'm, .g as a reducer in accordance with NC 3M5.
, pressible fluids at pressures of 100 psi (639 kPs) and (d) Other openings in closures shs!! be reinforced in * *
. t und:r, and for gaseous vents to stmosphere. Miters to accordance with the requirements orteinforcement for -
be used in other services or at higher pres >ures shall ,, .
QM.
a branch connection. De tots! cross-sectional ares , 'g meet the requirements of NC.3M9 ' .
- (6) The number of full pressure or therthat cycles required for reinforcement in any p!sne passing y'f-QQ/gg .g through the center of the opening and normal to she
.. shall.not exceed 7000 during the expected lifetime of surfsee of the c!crsure shsil not be less than lthe J , a..Q :?f} l, 4 *;; c-
. the piping system.
quantity ord 3r, where
, (e) The angle & Fig. NC 3673.2(b).I shall not be d,= diameter of the finished opening,in.
%-M l
. .f) ,
7 more than 22V5deg. .
t= pressure design thickness for the closure, inf..
.n. e m e M..a g. .. ..
.%Qv 7
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wg }v; f ;tj g . *
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C't V
AFFIDAVIT OF B0B BRONSON Q: Please state your name and address for the record.
A: My name is' Bob Bronson. 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 any 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 discourageraent had a detrimental effect on the quality of work at Comanche Peak?
A: Yes.
. Q: If so, what effects have they had?
! A: I mentioned some of them in my limited appearance statement which I gave in the operating license hearing on 9/15/82.
Q: Are the statements contained in your 9/15/82 limited appearance statement true and correct to the best of your knowledge and belief?
O
.. - = - . . ---. . - - - - . - . _ - _ -
{
O A: Yes.. I had the statement which I had written for the limited appearance statement notarized at the time. I haven't looked it over in some time.
Q: Do you incorporate your written 9/15/82 limited appearance as part of this affidavit?
A: Yes, I'd like to, so I won't have to repeat what was said in it.
Q: Can you give us some examples of intimidation, -harassment, threatening, or discouragement of which you are aware at Comanche Peak?
A: I remember on numerous occasions during the six months that I was at Comanche Peak that there were instances when I would find a dimension on a component which was not per the blueprint. I would return to see Mr. Snell-grove, the supervisor over the Mechanical Welding section, about it, and before I could get there, the craft foreman and/or general foreman or super-O v
intendent would precede me before I showed up at Mr. Snellgrove's office.
There were many instances where he said that no problem actually existed.
I was always on the defensive. He knew what the problem was in advance.-
There would be discussion and argument and finally I would just say to hell with it and throw up my hands and walk away and go ahead and sign off on the ,
item.
If you didn't go along with what they wanted you to do, the hanger engineer would come out with a blueprint change just on the spot. My past ,
experience at other jobs has been that when you change dimensions on blueprints you have to have it ' approved by engineering and it must come out in official fonn. But at Comanche Peak, some of the packages were 1/2 inch thick with documents that would go back 3 and 4 years, b
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J. Patton was making decisions; he had come from Glen Rose, and had no prior certified level 2 experience, yet his decisions were unchallengable. l I
One of my primary concerns has been with use of unqualified inspectors. I In my limited appearance statement, I stated that training documentation had been falsified about my own training time. I understand that the NRC Region IV office issued an inspection report saying that this was true but, it didn't matter since I could have qualified anyway. But had that entry in my folder been made for somebody that was not qualified, there could have been a problem there. I know of instances at Comanche Peak where people were certified but were not qualified.
When an inspector goes out to look at a weld, the weld is required to be cleaned as well as positioned for presentation to the inspector for visual b)
% examina tion. I would say 90% of the welds I looked at on those inspections were rusted over. Furthermore, they could be cleaned but they were required to be cleaned back 1" from the edge of the weld per code. This was one of the conditions which the crafts continually complained about; they thought that this should be acceptable. Mr. Snellgrove would kind of wink his eye at me and say something like, "You don't have to be so critical. Kind of back off, give the people a break out there." That's one of the things which caused me to decide that they didn't need me down there.
I quit at Comanche Peak September 2,1982. I quit because basically I continually had to prove myself. Every instance I had to prove myself.
Every NCR I wrote had to be initialed by Mr. Snellgrove. I tried to do
'! a good job and they labeled me as a troublemaker. They put me into a hanger O
group which was doing walk-down work and then they put me into an inferior or a non-inspection status. I was used as a last recourse inspector. If there were any other inspectors, including trainees (which came from' labor and the paint department), available at the time, I would be ignored. This was in the walk-down phase of Reactor 1 building, the piping and hangers, and the hydrostatic testing. Some of the trainees had only been in the depart-ment for maybe two or three weeks. This took place about the. summer of 1982. That's the reason they had all the stops pulled out; they were trying to get fuel loaded by the end of 1982. They were using people who were obviously unqualified and lacking proper prior experience for doing the jobs that they were doing. They were utilizing trainees who had come over from the labor category, carpenters, and the paint department.
J As far as being discouraged from doing the work right to begin with, I would count myself as one of those, plus some other people whom I know.
You had the craft on one side and then you had the supervisor on the other side.
Q: Could you tell us about some of the other people you mentioned who were discouraged from doing the job right to begin with?
A: There was one level 2 inspector named Richard Smith who worked at Comanche Peak. I had also worked with him at the South Texas Nuclear Project. He too quit because he became discouraged down there; he saw he was just spinning his wheels. He told me himself that he just wasn't doing any good down there and was just fed up.
And there was another inspector who works where I do now who quit Comanche Peak because he got enough.
O I'd say that the morale of the employees down there who were the favored few was probably all right, and they're probably still down there. But for those of us who felt.we had a job to do, we could not see where we were of any use. It's made some inspectors (myself included) buy off things they didn't think should be bought off.
Q: Are there specific problems > construction or dc';ign 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: Yes, there are two items which I could point out to the Board. One was using a butt weld procedure for a flare bevel weld when these two are not related at all. Mr. Snellgrove told me that it was in the procedure but was unable to point it out to me. There's another hanger which was Q (safety-related) but which lacked material traceability.
We would need to review the procedure in conjunction with the packages, but I believe I could go through them and identify it from the paperwork.
Q: Why should the Licensing Board be concerned about such intimidation, harassment, threatening or discouragement of employees, or such deficiencies as you may tell then about or show them at Comanche Peak?. What's the bottom line as far as the safety of the plant is concerned?
A: I believe Comanche Peak is using unqualified people into positions
.of responsibility'.for which they are not really qualified on a particular com-ponent or item, yet they would be signing off for it to be acceptable. And ,
their past experience, in my estimation, does not qualify them to do this.
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Therefore, they'are bogus in my estimation. I would challenge them and their experience against my experience as a mechanical welding inspector. This is the sum total of why I am getting involved in this. You have in effect people generating bogus paperwork and in reality what do we have as acceptable safety-related items? Because of these people who are unqualified, we are not really sure of proper welds and proper installation of Hilti bolts and other components being made per engineering blueprints. And the engineering department tells QC what to do.
Q: Do you want td testify regarding these matters in the operating license hearings for Comanche Peak?
A: Yes.
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I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
(Signed)
Date:
STATE OF COUNTY OF On this, the day of , 198_, personally appeared
() , 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 day of .
198__.
Notary Public in and for the State of My Commission Expires:
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AFFIDAVIT OF ROBERT HAMILTON Q: 'Please state your name and address for the record.
A: My name is Robert Hamilton. My address is Box 284, Route 1, Glen Rose, Texas-76043.
4 Q: Are you the same Robert Hamilton who testified in the July 1982 operating license hearings for Comanche Peak?
A: Yes, I am.
- j. Q: Other than what you have already testified to in the hearings,
-are you aware of any instances of intimidation, harassment, or threatening i- of employees at Comanche Peak?
i A: Yes.
j Q: Other than what you have already testified to in the hearings, are you aware of any 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?
i- A: Yes. .
Q: In your opinion, have such instances of intimidation, harassment, threatening, or discouragement had a detrimental effect on the quality of the work at Comanche Peak?
A: Yes.
Q: If so, what effects have they had?
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2-A: For a long time, QC Protective Coatings Inspectors were not on the distribution list to receive copies of NCR's; also, Protective Coatings was the only QC department as far as I know which did not have a filing clerk to help keep us up-to-date on anything that affected Protective Coatings QC. This meant that many times in the field the Inspectors didn't know about changes and the Paint Department personnel enjoyed pointing out changes that QC didn't know about. They would even go so far sometimes as to let us write an NCR on something, then whip out the change notice and say, "Look.
You're wrong. You don't know what you're talking about." When I took over in supervision, the former supervisor never mentioned anything about this problem to me, and it wasn't until I called it to the attention of Jim Hawkins that Protective Coatings QC ever got a filing clerk or was ever put on the distribution list to receive changes.
Right before I became supervisor in Protective Coatings QC, Danny Hash (my supervisor at the time who was training me to take over his position because he was leaving) and I decided we wanted to hire Cathy Gilbreath who was Quality Supervisor at Imperial Coatings (one of our vendors out of New Orleans) and she brought with her her personal copies of the ANSI standards.
-I had had a copy of the Steel Structure Painting Council (SSPC) manual but we never had the ANSI standards onsite. I thought the ' ANSI standards were what the engineers were working from, but when I showed them the copy of the ANSI standards, they jumped me and asked me what I was doing working from them and said that I wasn't supposed to be using the ANSI standards. But when they checked further, they came back and told me that I was definitely
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right and that we were supposed to be vorking from the ANSI standards. They wanted me to give them a copy of ANSI because they didn't have copies.
They had been working from a Brown & Root procedure; apparently there was some information from the ANSI standards contained in the procedure, but there was not a copy of the ANSI standards on the jobsite. The ANSI standards went into more detail than the procedures the engineers had been working to.
Right before he left, Danny Hash had been harassed a lot by our super-vision (including Jim Hawkins; I don't recall right now whether or not Harry Williams was there). Danny was very vocal with them when he left that last week. He told me he felt sorry for me but that he thought I was the only one who could maybe keep the quality system going. He had been harassed by his supervision's verbally overriding his decisions on various things such O
V as coatings preparation, curing times, and other decisions he had made.
I know for sure that they told him the same thing they told me later, that he could either do it their way or they would get rid of him. I don't know
-whether he decided to quit or whether they fired him.
When I was supervisor, the engineer for Coatings was Gordon McFail.
He and I conferred a lot on the specifications and he read the specifica-tions exactly like I did. He told me several times that he was intimidated by his boss into changing procedures and overriding his decisions on a lot" of things to accommodate production. He got very disgusted and very dis-couraged and quit.
When Gordon left, the engineering job was up for grabs at that time.
I had enough on-the-job training to become an engineer. They inserted an
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ex-Paint Foreman into the job of engineer. His name was Mark Wells. When he was Paint Foreman, we always had trouble with his work; he hated QC and was a smart alec. When he was a spray painter, we always had trouble with-the quality of his work. I t' ink n they made him foreman because he was such a smart alec and he couldn't paint. When he was a painter, he would always get too much millage or too little millage; he never could seem to get the knack of using a spray gun. Upon his taking over, we didn't have a lot in common and he definitely didn't like me. He informed me that he "had the haniner now" (he could change or do just about anything he wanted to do,-
because it was up to the engineer to make the final decision on question-ableitems). If there was something questionable in the field and I gave it a definite no, he was the only one who could override me. He told me that if I didn't agree with him that he would change the specifications.
In other words, he could put out a letter or a change notice to the pro-cedures any time he wanted to. It made a lot of my. decisions invalid.
A lot of times he would go to my supervision and tell them that it was right and my supervision would support what he said. There are so many thousands of questionable items it would be hard to pinpoint any one.
Every moment of spare time I had, I read the specifications and the
- , standards. When Gordon McFail was there, he and I studied together lots of times to try to get the best quality interpretation out of the the jobsite procedures, the ANSI standards, and the SSPC manual. I had been told before to stop using the SSPC manual, but I pointed out in ANSI where it refers you
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to the SSPC manual. I believe that Mark Wells even finally ordered him some copies of the SSPC manual. Mark Wells and I didn't study together the way Gordon McFail and I had; Mark Wells had his interpretation and I had mine, and most of the time they disagreed.
For a long time, painters were hired in three categories: helpers; brush painters; and spray painters. They were hired at different wage levels and in different categories because a good spray painter was hard to come by.
I believe it was in Reactor 1, they were painting the liner plate, doing sand blasting, etc., and we usually stayed out while they were sandblasting.
They had the whole floor level of platform built. They didn't have a lot of spray painters, so they let just about anybody spray paint. They had people set up to watch for QC and let them know if QC was coming. I know O about this because there were some people in the Paint Department who would secretly give QC information about this sort of thing. They knew we wouldn't do anything to blow their cover, and I instructed the Inspectors whenever they got information like that from anyone in the Paint Department not to ever identify the people who gave them the information because those people might be fired if it was found out. At the time they were doing that, they hired an ex-Paint Foreman from South Texas Nuclear Project. He hadn't taken his qualification test on the Comanche Peak jobsite at that time, so he was not a qualified painter. Richard Garrett (my lead inspector at the time) caught this man spray painting. An NCR was written. Needless to say, it cost them lots of time and money to try to figure out what to do. They finally had to have the coating he had put on completely removed. It cost n them about three weeks work. The quality of the paint might have been U
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perfect, but we had to write an NCR because the man was not certified to paint and they were letting him paint. There's no telling how many other uncertified people they had been letting . spray paint. I was a long time before we caught anyone else who was not qualified spray painting.
After that had happened, I told Cathy Gilbreath to start checking painters' qualifications weekly if we weren't certain of any of their qual-ifications, because they were hiring so many people at that time. It took quite a bit of time for her to do that, but as far as I'm concerned, it was worth it to keep those qualifications straight. She was steadily going to the Paint Department and telling them about different problems regarding the qualifications and papemork, to try to keep the records straight.
They got tired of her doing that and asked if I would object if they just hired everybody in the future in as a qualified spray painter. I told them not if the people could pass the tests, if they were qualified right. The test consisted of a short class on-quality aspects of paint to our specifi-cations, plus a short test. I attended the class and it was just the high-lights of everything, just a formality. It made the records look real good; you could go put your finger on anybody in the field and he was a qualified ,
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spray painter, but you could go and ask him to set up a pot and spray something and lots of them couldn't do it (a large percentage couldn't).
f The main specification change that I was concerned with that we had a lot of trouble over was the most important aspect of quality painting, the surface preparation. That's what's going to keep the paint on. It should have been and was in our procedures to have a one-to-three mil profile.
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O From a side view, under magnification, it's a one-to-three thousandths profile, kind of a zig-zag pattern. We had prepared a book to go by as far as surface preparation, a pictorial guide. Later on, sand kept getting into the pumps and getting into the reactors that they were ordered to stop all sandblasting or to build plastic tents around areas they were sandblasting in the reactor areas. They decided.to build tents. This got to where they thought it was taking too much time and holding up production, so Mark Wells changed the specifications to read power tooling. What they started using then was a -
rotary wire wheel and what they call a needle scaler. The needle scaler' had a lot of metal tips on it and it vibrated to create kind of a profile.
on the metal; it more or less beat the metal up. After my research in the SSPC guide, I found out that this was more or less driving the rust into the metal. In either the SSPC or the ANSI standards, it states that the vendors are to supply either a comparative block or like we had for the sand-blasting, a pictorial guide for us to go by to tell us it was a good profile.
We had no comparative blocks for the power tooling, so we were more or less comparing it to a sandblasting surface as close as we could. As far as I know, they had no pictorial guide (at least we didn't have one) f.or power tooling surfaces. I had disagreed with Mark Wells about using power tooling because I felt it wa's' more or less driving the rust into the metal and the wire wheel was real convenient -- it would hide any imperfections like delami-nations. They were real hard to find after they shined it with that wire brush. It's a good place for the paint to break down, because you can't see them. They weren't hard to spot at all when they were doing sandblasting.
After a lot of questions and a lot of fights between lC and the Paint Department
over whether the profile was good or not, Mark Wells normally agreed with the Paint Department, so they~ finally changed the specifications to read one mil profile minimum -- no maximum, which was really a joke. I told Harry Williams the way the specifications ' read now, they could go in .there with a ball peen hamer and beat it'up to make a profile; and he said, "That's what it means." So there was really no sense in QC going in there looking at the profile. So even though they were doing things according to the site specifications, they were doing them contrary to ANSI and SSPC recommendations.
But just to make it legal, Mark Wells would call the paint vendors and he would say, " Hey, will your paint stay on if we do this? Could you send me a letter to that effect?" And of course the paint vendor wanted to sell g paint and would send the letter; a lot of it would have testing infonnation v
attached to i t. I'm not fully convinced that the paint would stay on, for instance with a one mil profile minimum. I've never felt that it was the best surface preparation for _ the inside of the containment. I believe upon full study of the SSpC and the ANSI standards, most people would come to the same conclusion. They changed specifications to accomodate production.
I stirred up a bag of worms when I told my supervision that we were supposed to be recording what we used the calibrated tools on and it wasn't being done. I asked them if they had e'ver done it before and they said no.
I asked them if they were saying that.that had not been done since day 'one of painting on this jobsite; and they said, they guessed that was right.
It wasn't until the next day that somebody finally made the decision and called me in the office and told me, "You know exactly what it means. You're O
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the expert. You write the NCR." So I did. QC got control (back from the Paint Department, who had always had control of them before) of all the gauges.
All of these things were, I believe, part of what led to my being fired, along with two other good inspectors. We kept trying to see that the protective coating were done correctly and in accordance with proper codes and standards.
There are lots of other specific things I could tell the Board about.
Our firings and the firings of others at Comanche Peak have meant that people who still work at the plant are afraid to speak up now.
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
.)
(O Board and show them? And would you be willing to attempt to do so?
A: I might still be able to show the Board protective coatings paperwork which has not been done properly, even after all this time. If the Board goes to the plant to see problems with protective coatings, I could perhaps be helpful in testing or discussing those problem areas. I think it would be helpful to the Board to see for themselves some of the coatings and have some of the quality requirements' explained to them with the coatings there 4
for the Board to see.
Q: Why should the Licensing Board be concerned about such intimidation, harassment, threatening or discouragement of employees, or such deficiencies as you may tell them about or show them at Comanche Peak? What's the bottom line as far as the safety of the plant is concerned?
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'O A: The protective coatings are very important to the safety of the plant. This was discussed in my testimony in July 1982 (CASE Exhibit 653, page 2). As I stated there: " Paint helps hold in radiation. If it peeled off inside the containment, it might plug up different types of pumps and so forth. Raw steel must have some type of protective coating to allow decontamination because raw steel can absort radioactivity. After so many washdowns of the protective coating, it would eventually start absorbing radiation. " I've read the affidavit of Bill Dunham, and it appears that things aren't any better now than they were at the time I was at Comanche Peak, e~ specially regarding Protective Coatings. There needs to be some type of unbiased team to evaluate the supervision as well as the protective coatings at the plant.
Q: Do you want to testify regarding these matters in the operating license hearings for Comanche Peak?
A: Yes.
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I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
(Signed)
Date:
STATE OF COUNTY OF On this, the day of ,198_,, personally appeared
() , 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 day of ,
4 198__.
Notary Public in and for the State of i
My Commission Expires:
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. O AFFIDAVIT OF STAN MILES Q: Please state your name and address for the record.
L 'A: My name is Stan Miles. My address is 3824 Eighth Avenue, Fort Worth, 3
Texas 76110.
Q: Are you aware of any instances of intimidation, harassment, or-f threatening of employees at Comanche Peak?
A: Yes.
p' Q: Are you aware of any instances of employees being discouraged from i doing work right to begin with at Comanche Peak?
$ A: Yes.
. Q: In your opinion,-have such instances of intimidation, harassment, O threatening, or discouragement had an effect on morale of employees at the plant? ;
A: Yes.
l 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.
1 Q: If so, what effects have they had?
( A: I thought the world knew that poor attitudes generated by intimida-l tion produces poor quality construction. (I can list such instances.) -
And in some cases, it produces dangerous construction to workers inside the plant and hazards or potential hazards to the operation of such a plant.
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Q: Are there specific instances you could tell us about?
A: I can recall several instances of intimidation and threats by foremen and superintendents. Very few days, in fact, passed without such behavior.
On an average, I would estimate that I heard personally five such threats per week and sometimes more. I remember one such instance where all our welders were threatened in front of the entire assembled u on working craft. I was threatened by the Superintendent, Dale Bullard, to do something that would contaminate safety-related welding on stainless steel pipe. I have personally heard supervisors tell individuals that'if they did not perform such work that they (the supervisors) would make sure that the workers would be fired and would never work for Brown & Root or anyone else again. I know of many instances where welders and fitters abandoned reliable practices and over-
' heated welds and supporting iron because of the hopelessness of the situation.
This results in distortion and warpage of supporting' systems, rendering them at_ least' able to withstand less than the supports were engineered to withstand.
j I know one popular trend at Comanche Peak was to reclassify safety-l related structures to non-safety related structures. The purpose of this was
.to expedite and increase production. Then, at a later date, they would again reverse the classification, thus circumventing inspection of such structures.
This practice tends to dictate at least that no rework was ever done and no inspection was ever done. This is a common practice, it's not just one instance, it's plant-wide.' All of these instances I have related here were in front of witnesses and can be verified. There are many, many more subjects that I know happened and also the people involved in the work.
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It's my understanding that the polar crane has recently been derated from 425 tons to 175 tons (see CASE Exhibit 870, attached to CASE's 10/13/83 (1) Motion to Add a New Contention, (2) Motion for Discovery, and (3) Offer of Proof). I would suspect from this that, rather than have to inspect it where it would have to pass that 425 ton lift test, they derated it in
- order to circumvent that inspection and tests, as they've reclassified so many other structures in the plant. I figure that they've had trouble rotating the crane and that if they had to test it with lift plus rotation with the lift (which is what I believe they would have to do), that would accentuate the problem of its binding. This all goes back to my previous testimony about the polar crane. Of course, I don't have all of the details on this, but it's certainly something that ought to be looked into.
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Are there any other specific instances of intimidation, etc. of which Q:
you are aware which are not already in the record? '
A: Yes. I believe my own firing was intimidation. I worked there for five years, so I know that the reason they gave for firing me (that I was loafing on the job) was not the real reason I was fired. It doesn't make sense to believe that I'd been loafing for five years (and if I was loafing, that's what would have to be assumed). My helper and my welder were also fired at the same time. My welder had 7 years with the company at that site; and my helper had 7-l/2 years. I believe we were fired -for one (or maybe both) of two reasons:
(1) I was instructed to build a platform and I did not have the prints to do so. I told them that I would not build that plationn without th'e prints for it, because it was grounds for firing to work without a print.
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Had I been caught building that platform without a print, I would have been fired (and the ones who told me to do it would not have supported me).
They asked me 3 or 4 times to build that platfonn. This was in the Turbine 2 area, with several witnesses present, including my helper, my welder, and myself. I was sent to erect some steel for the electrical craft and I was on that project when I was fired. This was, at the most, three days later.
(2) Also, the diesel generator was damaged some time earlier, and my welder, my helper, and I knew about this damage. The damage was classified as being sabotage, and of course, we knew that that wasn't so. Nobody knew that we knew about it; but the day before we were fired, we saw the individual who had damaged the diesel generator, and my welder asked him about it. The next day we were fired.
O d Q: Why didn't you mention this in your previous testimony?
A: It was my understanding that we were supposed to'be concentrating on problems in construction at the plant that we knew about. Also, I could not prove the reason I believe I was fired, and nobody seemed interested at that time in intimidation of employees at Comanche Peak except the Intervenor.
Q: Are there specific problems in construction or design at Comanche Peak which youe6'lieve 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 do so?
'A: Yes, to both questions.
Q: Do you think that the Licensing Board would be able to see such deficiencies with the naked eye, or would any additional testing be necessary
O to prove that such deficiencies exist (and if so, what kind of testing would be required)?
A: Some of the deficiencies can be seen and others would take from about 45 minutes to an hour to test, using the dye penetrant test. These would be pipe whip supports and pipe whip restraints which are warped, buckled, and quite possibly which have cracks in the welds.
Q: Why should the Licensing Board be concerned about such intimidation, harassment, threatening or discouragement of employees, or such deficiencies as you may tell them about or show them at Comanche Peak? What's the bottom line as far as the safety of the plant is concerned?
A: When you have severe morale problems generated by intimidation and QC Inspectors being fired and intimidated, you can't assume you have a safely
") built plant. I don't think it's been built correctly or can operate safely.
The greatest fear I have concerning Comanche Peak plant is that it will serve to contaminate the entire lower u .ershed of the Brazos River to the Gulf I
of Mexico and beyond. That's a firm belief I have -- it will leak. If it's possible, I would like to see a private company monitor radiation levels of Comanche Peak at Squaw Creek Lake. This would have to be a company that could not be bought off or bribed and could not be affiliated with the federal government, the state government, or Texas Utilities. And this radiation level should be started today, so they can't just say later that's background interference on the geiger counter.
I'd also like to have these people, supervisors and witnesses, be subjected to a polygraph test. Government and businesses do it all the time; wny couldn't it' be done on something as important as this nuclear plant?
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I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
(Signed)
Date:
STATE OF
, COUNTY OF On this, the day of ,198_, personally appeared
! O ,ke-a to me to he the person e se 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 day of ,
198_.
Notary Public in and for the State of My Comission Expires:
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AFFIDAVIT OF DARLENE STINER Q: Please state your name and address for the record.
A: My name is Darlene Stiner. I can be contacted through CASE, 1426 S. Polk, Dallas, TX 75224.
.i Q: Are you aware of any instances of intimidation, harassment, or threat-ening of employees at Comanche Peak?
A: Yes.
, Q: Are you aware of any 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, l
O threatening, or discouragement had an effect on morale of employees at Comanche Peak?
A: Yes.
Q: In your opinion, have such instances of intimidation, harassment, i~
threatening, or discouragement had a detrimental effect on the quality of work at Comanche Peak?
j A: Yes '. '
Q: If so, what effects have they had? .
A: When personnel at atiy job site are continually harassed, on a day-l to-day basis, they lose any respect they have for supervision and in pride in good quality work. Craft persons and supervision have no need to worry about whether or not their work will be accepted, because inspectors are being pressured and-intimidated and instructed to sign off the work, good or bad.
Workers lose sight of quality when pressured and rely on their jobs for survival. -
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, Q: 'Are there other specific instances which you have not already told
- the Licensing Board about?
4 A: Yes, there.are specific instances of intimidation and' harassment f by management which I personally experienced after testifying in the operating
, license hearings. -- This intimidation and haras'sment finally led to my quitting
. work earlier than I had planned to or needed to to have my baby. I quit -
right before Christmas, even though I had wanted to stay until after Christmas so that we would have some extra money coming in. When I agreed to leave earlier than' planned, I was literally in tears because of the continued pressure and harassment I'd been subjected to.
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,
> O been put into the-process to be corrected) to which you could take the
, Licensing Board and show them?
l- A: Yes. Some of those problems are discussed in the affidavit of j my husband Henry and me attached to CASE's 7/28/83 Answer to Applicants' F 7/15/83 Sumary of the Record Regarding Weave and Downhill Welding. One l of those problems we discussed'in our affidavit was about the effective heat input and the fact that temperature indicating crayons are not normally used h
- . at Comanche Peak to control the effective heat input; I'm net sure how we
{ could actually show the Board about that.
Q: Would you be will'ing to attempt to take the Licensing Board to those i deficie.ncies and show them?
i-,
A: Yes, as long as there is no requiremer.t for a pre-written list.
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Q: Do you think that the Licensing Board would be able to see with the naked eye such deficiencies which you might point out, or would any addi-tional testing be necessary to prove such deficiencies exist (and if so, what kind of testing would be required, in your opinion)?
A: Some deficiencies are visible; others would require examination of some documentation, and one example would require X-ray. Note: If we could go to Comanche Peak on a work day and be allowed to talk to other workers under oath, much could be learned.
Q: Do you want to testify regarding these matters in the operating license hearings for Comanche Peak?
A: Yes.
Q: Why should the Licensing Board be concerned about such intimidation, harassment, threatening, or discouragement of employees, or such deficiencies as you may tell them about or show them at Comanche Peak? What's the bottom line as far as the safety of the plant is concerned?
A: I feel that it's to a point now that so much money is involved that it is like a large snow ball rolling down a hill destroying everything in its path -- destroying or conforming to their ways , right or wrong. The Licensing Board is the last chance for something to be done before it's too late.
The welds are brittle due to no control over heat input, the documentation is every bit as messed up as the welding. Also, many other areas are bad and therefore the direct safety of the public is in great danger. Please allow further inspection and examination of the facts. It is a senseless and gross mistake if someone doesn't shut them down. It's in the hands of the Board. I couldn't live with my conscience if I licensed that plant.
P i 1
l I have read the foregoing affidavit, which was prepared under my personal direction, and it is true and correct to the best of my knowledge and belief.
I (Signed)
I Date:
STATE OF COUNTY OF 1
l g On this, the day of , 198_, personally appeared
, 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 day of ,
! 198 .
I Notary Public in and for the State of My Comission Expires:
I .f
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^
I l
o AFFIDAVIT OF HENRY STINER Q: Please state your .ame and address .for the record.
A: My name is Henry Stiner. I can be contacted through CASE,1426 S.
Polk, Dallas, Texas 75224.
Q: Are you aware of any instances of intimidation, harassment, or threat-ening of employees at Comanche Peak?
A: Yes.
Q: Are you aware of any instances of enployees being discouraged from doing work right to begin with at Comanche Peak?
A: Yes.
,s Q: In your opinion, have such instances of intimidation, harassment, threatening, or discouragement had an effect on morale of employees at Comanche Peak? ,
A: Yes.
Q: In your opinion, have such instances of intimidation, harassment.
threatening, or discou-agement had a detrimental effect on the quality of work at Comanche Peak?
A: Yes.
Q: If so, what effects have they had?
A: The inspectors are having morale. problems which hinders their ability i to inspect properly. A lot of inspections which normally would not be passed are,being bought off by some inspectors who are afraid they are going to lose their jobs. Craft persons ~do bad work because they arc rushed to get things
~
done; and if they do find some defect in the plant, they won't tell their supervisors because they are afraid they will get blamed for it.
r-(3 Ivl Q: Are there specific problems in co,nstruction or design at Comanche Peak which you believe currently exist at Comanche Peak (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?
A: Yes.
Q: Would you be willing to take the Licensing Board to those deficiencies and show them?
A: Yes, if we don't have to give specifics to the Applicants or anyone else before we go to the plant, since I feel the problems and defects would be covered up. And from the actions of the Applicants and NRC investigators in the past, I have no reason to believe otherwise, And I would like to show the Board because I feel they didn't com-(ahj .
L' pletely understand my testimony.
Q: Do you think that the Licensing Board would be able to see with the naked eye such deficiencies which you might point out, 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)?
A: Some of the defects might still be visible with the naked eye.
Some are not, which might require some tools; I 'think we would need a drill to remove Hilti bolts and something to remove paint from welds. Also, we may need some X-ray examination. In other words, there would need to be some destructive examination and some non-destructive examination done.
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Q: Do you want to testify regarding these matters in the operating license hearings for Comanche Peak?
A: Yes.
Q: Why should the Licensing Board be concerned about such intimidation, harassment, threatening, or discouragement of employees, or such deficiencies as you may.tell 'dien about or show them at Comanche Peak? What's the bottom line as far as the safety of the plant is concerned?
A: I believe we can show tha't through the lax attitude of management in the construction of Comanche Peak that such a system will not and cannot construct a nuclear power plant of this magnitude without having a big letdown in the entire quality of the plant. Therefore the safety of the public is not assured. A lot of the defects which Darleneand I reported to the NRC
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investigators were covered up and are no longer there or can no longer be seen. But! we forgot that had Darlene and I decided not to testify or report the defe. cts to the NRC, the defects would still be undetected.
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l I have read the foregoing affidavit, which was prepared under my personal
- direction, and it is true and correct to the best of my knowledge and. belief.
(Signed)
Date:
STATE OF COUNTY OF On this, the day of ,198_, personally appeared O, , known to me to be the person whose
., name is subscribed to the foregoing i :strument, and acknowledged to me that
- he executed the same for the purposes therein expressed.
Subscribed and sworn before me on the day of ,
i 1
198-.
l Totary Public in and for the State of l
My Comission Expires:
i
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