ML20083G196

Affidavit of E Riley Re Termination of Johnson Controls,Inc QC Inspector R Wade.Certificate of Svc Encl

ML20083G196
Person / Time
Site:	Perry
Issue date:	01/06/1984
From:	Riley E CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20083G181	List: ML20083G178 ML20083G187 ML20083G196
References
NUDOCS 8401110167
Download: ML20083G196 (10)

Text

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a AFFIDAVIT OF EMANL'EL RILEY

• DOCkohkOkf0 PDR

4 January 6, 1984 UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the. Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, ) ,,

Units 1 and 2) )

AFFIDAVIT OF EMANUEL RILEY County of Lake )

ss:

State.of Ohio )

Emanuel Riley, being duly sworn, deposes and says as follows:

1. I, Emanuel Riley, am General Supervisor, Construction Quality Section (CQS), Nuclear Quality Assurance Department (NQAD), of The Cleveland Electric Illuminating Company ~(CEI).

My business address is 10 Center Road, Perry, Ohio 44081. A statement of my professional qualifications and experience is attached to my Affidavit, dated December 19,'1983, which was

. filed in this proceeding as an attachment to Applicants' Answer to OCRE Motion to Reopen the Record on Comstock Issues, dated December-19, 1983. I have personal knowledge of the matters set forth herein and believe them to be true and correct.

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2. I have reviewed the Amendment to Motion to Reopen

'the Record on Comstock Issues, dated December 8, 1983 (Amended Motion), filed by Ohio Citizens for Responsible Energy (OCRE).

The Amended Motion attaches an article from the Lake County News-Herald, dated December 1, 1983, discussing allegations by a former Johnson Controls, Inc. (JCI) quality control inspector, Richard Wade. The purpose of'this Affidavit is to address the health and safety allegations discussed in the three newspaper articles citied by OCRE.

3. As the General Supervisor of CQS, I have responsibility for CEI's daily oversight of JCI's QA/QC program implementation, including JCI's inspector indoctrination and training, program.

Since JCI began its safety-related work in 1978, CQS has monitored the development and implementation of JCI's indoctrination and training program, including inspector testing and certifications.

COS personnel are familiar with the details of JCI's program, and have found.the program to be comprehensive and effective.

CQS performed two audits of JCI's-training and certification program in 1982, and two audits in 1983. These audits demonstrated that-JCI's program is being effectively implemented. In addition to these overviews, CQS's in-the-field surveillance of JCI inspection personnel, including those JCI personnel receiving in-the-field job training, has confirmed the effectiveness of JCI's inspector training.

4. Late Wednesday, November 30, 1983, CEI was contacted by the author of the News-Herald article and questioned about

Mr. Wade's allegations, which were published the following day, Thursday, December 1, 1983.. This was'the first time CEI learned .

about Mr. Wade's allegations. On.the morning of December 1, 1983,' prior to the publication of the newspaper article, the NRC: Staff' met with Mr. Cyril Shuster, CEI's QA Manager, and rme, and informed us that Mr. Wade had provided the Staff with copies of some of JCI's open-book and closed-book answer sheets.

We indicated that we would fully investigate the matter and take the necessary corrective action.

5. On December-1, 1983, Mr. Shuster and I held several meetings with senior QA/QC and engineering personnel from the Project Organization'and JCI,-to discuss our meeting ,with the NRC and the newspaper. allegations by Mr. Wade. We confirmed that-the copies of test answer sheets given to the Staff were identical to some of-the closed-book and open-book answer sheets used by.JCI. The Project-Organization and JCI jointly decided to suspend certification testing, and tottake'a number of im-mediate corrective actions.- All of JCI's closed-book NDE certifi-cation exams were rewritten by JCI, with.the input and supervision of-three level III (the most senior qualification level) Project

, Organization inspectors. CQS-and JCI also decided to have JCI, undericlose CQS supervision, retest JCI's entire inspection and supervisory staff, with the commitment to re-inspect all previous work by'any inspector failing the NDE re-examinations.

(Although there were only three other inspectors participating

-in JCI's training and certification program with Mr. Wade, it a.

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was nonetheless decided to take the conservative approach of re-examining the entire JCI inspection staff.) All of JCI's inspection personnel, including supervisors, have since passed the re-examinations, re-confirming the competency of JCI's in-spection staff. JCI is also revising its open-book examinations with the close supervision and input of qualified CQS inspectors.

I would emphasize that all of these corrective actions were undertaken prior 'o completing our investigation into the validity of Mr. Wade's allegation that other inspectors had been given test answer sheets. Finally, JCI and CQS jointly re-inspected (and approved) the sixteen welds which Mr. Wade had inspected and approved during his two days as a certified inspeator at Perry. This was done because Mr. Wade's possession of test answer sheets called into question the validity of his certifi-cations, and because of Mr. Wade's claim in the newspaper article that he approved faulty welds.

6. Mr. Shuster and I tried, on a number of occasions, to contact Mr. Wade to follow-up on his published allegations.

When we were unable to reach Mr. Wade by phone, we went to his trailer home and were given a forwarding address in Louisiana.

We have not been able to contact Mr. Wade to pursue with him the basis for his published allegations.

7. CQS has investigated Mr. Wade's charge, as stated in the newspaper article, that JCI officials provided Mr. Wade and otner inspectors with answer sheets " hoping to certify in-spectors who could not recognize faulty construction." We find absolutely no basis for the charge. As I have stated, CQS has closely monitored JCI's training and certification program and

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has found it to be an effective one. CQS inspectors are confident about the qualifications (and integrity) or JCI's supervision .

based on daily contacts, surveillance, and formal audits. CQS's standard reviews of JCI's inspector certifications have provided additional assurance of inspector competence. In addition, under Mr. Shuster's and my direction, CQS personnel have inter-viewed JCI management and inspectors concerning Mr. Wade's allega-tion. Based on CQS's overview and investigations, we do not believe JCI supervisors provided Mr. Wade or other inspectors with answer sheets, nor do we believe the other inspectors ob-tained or used answer sheets. The good results of the re-examinations of all JCI inspectors and supervisors provides additienal assur-ance that these individuals were properly certified.

8. Mr. Wade is quoted in the News-Herald article as claim-ing that "he approved thousands of faulty welds that could lead to a serious nuclear accident at the plant." The charge is false. Mr.-Wade only inspected (and approved) 16 welds, all of which were subsequently re-inspected and approved by certified JCI and CQS inspectors.

9. Mr. Wade is quoted in the News-Herald article as stating that "[w]orkers 'overwelded' thousands of joints on a hydraulic piping system-that pushes control rods into a nuclear reactor,"

and that "[mlore than twice the,needed metal was used in the welds, so the piping is excessively strassed and could break,

'which could lead to a total meltdown.'" ~ This charge is also

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' false. The= hydraulic piping system welds are under the juris-diction of Pullman Power Products, not JCI. The specific welds .

Mr. Wade is most likely referring to in the. newspaper article-are unequal leg fillet welds, which do in fact contain more weld filler material than is contained on most other fillet welds at'the plant. However, the welds in question have been specially designed for their location, and have been full'y evalu-ated by Project Engineering, as documented on a Project Organization Engineering Change Notice, dated January 4, 1982. Pullman Q'A/QC has fully' inspected, tested, and approved the welds. This.in-cluded 100% visual and PT inspection, and hydrostatic testing at 1.25 times design pressure. Thus, there is no bas.is for Mr. Wade's charge that the piping in question has been over-welded and excessively. stressed, and that the welds could break and cause a meltdown.

10. The-News-Herald article quotes Mr. Wade as stating that."he1 thinks he was fired for raising too many questions at 1 the plant." Mr. Shuster and I, and other CQS inspectors, have reviewed JCI's records relating to Mr. Wade's employment and termination, and have interviewed Mr. Steve Young, JCI's QA Manager, Mr. Tom Skidmore, JCI's second shift inspection

. superintendent, and other supervisors and inspectors who worked with Mr. Wade. Our investigation confirms that Mr. Wade was

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terminated on the merits, because of serious questions concerning his cond'uct and attitude during his probationary period as a new inspector with JCI. There is-no indication.that Mr. Wade ever-raised any safety concerns, or had safety concerns that

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he was afraid to raise, with his management. Similarly, the newspaper charge by Mr. Wade that JCI has fired other inspectors for raising safety concerns, or discouraged the raising of safety concerns, is without any factual basis, based on CEI's ongoing ,

review of JCI and our review of the facts surrounding previously terminated JCI inspectors. (No other inspectors were terminated by JCI during Mr. Wade's brief tenure ,at Ferry, and I am therefore unaware of any basis he might have for believing that previous terminations were improper.)

11. Pinally, Mr. Wade is quoted in the News-Herald article as alleging that workers have intentionally created construction ,

delays, and that plant security is " appallingly bad." No spe-cifica are provided in the newspaper story to support the charges, and I am unaware of any basis Mr. Wade could have for the alle- ,

gations. Based on my eight years at Perry, I believe that the QA/QC program has identified and corrected any significant construc=

tion deficiencies that have occurred.' I am not aware of any plant security lapses that might have caused QA/QC or safety problems to occur at Ferry.

ananuel Riley subscri d and sworn to before me this day of January, 1984.

NOTARY PUBLIC My Commission expiresy //- / J- / 7 / /

0%em) v 4kst SA 10/1f;E als ;;M3. Notary Public State of Ohio Lah County My comm. exp. licy.12,198g

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January 6, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of' )

)

THE CLEVELAND ELECTRIC ) Docket No. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear. Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer To OCRE Amendment To Motion To Reopen The Record On.Comstock Issues" were served by deposit in the United States Mail, first class, pos,tage prepaid, this 6th day of January, 1934, to all

'those on the attached Service List.

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. 9f f Harry H./Glasspiegel Dated: January 6, 1984

.s' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

Before the Atomic Safety and Licensinc Board

)

In the Matter of ) ,

) Docket Nos. 50-440 THE CLEVELAND ELECTRIC 50-441

)

ILLUMINATING COMPANY

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

SERVICE LIST Peter B. Bloch, Chair: nan Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Ccnunission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 20555 Washington, D.C. 20555 Washington, D.C.

Colleen P. Woodhead, Esquire Mr. Glenn O. Bright Office of the Executive Legal Atomic Safe'.y and Licensing Bozrd Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 20555 Washington, D.C.

Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt OCRE Interim Representative Appeal Board 8275 Munson Avenue U.S. Nuclear Regulatory Commission Mentor, Ohio 44060 Washington, D.C. 20555 Terry Lodge, Esquire Dr. W. Reed Johnson 612 N. Michigan Street, Suite 105 Atomic Safety and Licensing Toledo, Ohio 43624 ,

Appeal Board U.S. Nuclear Regulatory Commission

• Donald T. Ezzone, Esquire Washington, D.C. 20555 Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 Center Street Painesville, Ohio 44077 Appeal Board U.S. Nuclear Regulatory Commission John G. Cardinal, Esquire Washington, D.C. 20555 Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse Jefferson, Ohio 44047 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

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