ML20090K747
| ML20090K747 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/15/1983 |
| From: | Ryan Alexander, Davison L, Dressler S DUKE POWER CO. |
| To: | |
| References | |
| A-037, A-37, NUDOCS 8405240377 | |
| Download: ML20090K747 (46) | |
Text
fsY APPLICANTS' B4 g ll1 W ny o
UNITED STATES OF AMERICA N
O NUCLEAR REGULATORY COMMISSION $
D
\\
bO BEFORE THE ATOMIC SAFETY AND LICENSIN' Er".a YvMght D.
EI:c n ac A
In the Matter of
)
4
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)
N DUKE POWER COMPANY, et al. )
Docket Nos.
50-413_ ___
-)
'50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
TESTIMONY OF SAMUEL W. DRESSLER, LARRY R. DAVISON AND RICHARD S. ALEXANDER REGARDING QUALITY ASSURANCE ALLEGATIONS RAISED BY MESSRS. MCAFEE AND HOOPINGARNER 1
Q.
STATE YOUR NAMES, BUSINESS ADDRESSES, PRESENT JOB 2
. POSITIONS WITH DUKE POWER COMPANY AND THE NATURE OF l
3 YOUR JOBS AS THEY RELATE TO THIS TESTIMONY.
4 A.
Mr. Dressler:
My name is Samuel W. Dressler, and my business Q
5 address is Catawba Nuclear Station, PO Box 223, Clover, South 6
Carolina 29710.
I am currently the Engineering Manager for the 7
Catawba Nuclear Station Construction Department at Duke Power l
8 Company.
In this position, one of my responsibilities is the 9
resolution of all construction related technical engineering problems 10 associated with civil engineering, mechanical engineering, electrical 11 engineering, instrumentation, and welding.
My professional 12 qualifications are attached (Attachment A).
13 Mr. Davison:
My name is Larry R. Davison, and my business 14 address is Catawba Nuclear Station, PO Box 223, Clover, South 15 Carolina 29710.
I am currently the Project Quality Assurance 16 Manager responsible for Quality Assurance (QA) during construction 17 of the Catawba Nuclear Station for Duke Power. Quality Assurance O
la activities durin, construction consist of inspection of actuai
- orx, 19 review of materials used in construction of the plant, review and g524oa77831115 0
ADOCK 05000413 PDR i
1 l
I approval of construction procedures and review and approval of 2
documentation generated in the above activities.
My professional 3
qualifications are attached (Attachment B).
4 Mr. Alexander:
My name is Richard S.
Alexander, and my 5
business address is Catawba Nuclear Station, PO Box 223, Clover, 6
South Carolina 29710.
I am currently Personnel Manager for the 5
7 Construction Department, Catawba Nuclear Station, Duke Power 8
Company.
In this position, one of my responsibilities includes 9
resolution of issues related to personnel safety.
As such, I have 10 been involved with resolution of concerns raised by Mr.
11 Hoopingarner.
My professional qualifications are attached i
12 (Attachment C).
I
~
13 Q.
WHAT IS THE PURPOSE OF THIS TESTIMONY?
i O
14 This testimony is designed to address all but two of the allegations i
15 of Messrs. McAfee and Hoopingarner regarding QA as admitted in 16 this proceeding by Board Memorandum and Order dated August 26, j
17 1983.
The allegations addressed are those related to electrical 18 cables (2a and If), quenching welds (2b), welding on scaffolds 19 (2c), communication with the NRC (2d), flooding of the diesel 20 generator rooms (2j), water on the control boards (2k and le),
21 pipes and relar on the floor (2n), pouring concrete in the rain 22 (la),
waiver of concrete pouring requirements (1b),
and 23 instructions regarding non-conformance items (11).
While the three 24 of us collectively sponsored this testimony, the initials of the 25 individual principally responsible for preparing the response for 26 each allegation is set forth in the margin.
27
P l
i 1
(S.W.D.)
- 1. TESTIMONY REGARDING MESSRS.
2-HOOPINGARNER'S AND MCAFEE'S ALLEGATIONS 3
CONCERNING PROTECTION OF CABLES (2a and If) 4 l
5 Q.
ARE YOU FAMILIAR WITH THE ALLEGATIONS RAISED BY MESSRS.
6 MCAFEE AND HOOPINGARNER REGARDING PROTECTION OF j
7 ELECTRICAL CABLES DURING CONSTRUCTION AT CATAWBA 7 8
A.
Yes.
I have reviewed the deposition testimony of Messrs. McAfee 9
and Hoopingarner regarding this allegation.
The deposition 10 testimony reflects that both Messrs. McAfee and Hoopingarner allege 3
11 that in many instances cables being pulled at Catawba were 12 subjected to abusive treatment such as being placed on the floor in 13 water with boards and pipes on them. MD Tr.,pp. 18, 88-90; HD i
14 Vol.1 Tr., pp. 20, 33-35 and Vol. 2 Tr., p. 67.
j 15 Q.
PLEASE EXPLAIN THE ACTIONS NORMALLY FOLLOWED FOR O
te Paorscrton or c^8ts-17 A.
Procedure M-41B, serial #9, in effect at the time of these 18 allegations, states that cable is to be protected from damage due to 19 construction activities and water.
With regard to construction l
20 activities, cables are stored in areas free from construction j
21 equipment and heavy traffic which could result in damage.
To 22 protect from water, the ends of the cables are taped to keep l
23 excessive moisture out.
24 25 Q.
DID YOU CONDUCT AN INVESTIGATION - TO DETERMINE IF j
26 ALLEGATIONS MADE CONSTITUTED VIOLATIONS OF THESE 27 PROTECTIVE ACTIONS?
28 A.
Yes.
I directed that a review of this allegation be made to 29 determine if there was any indication that violation of cable storage 30 requirements was widespread as alleged by Messrs.
McAfee and i
1 Hoopingarner.
As a results of the review of Nonconforming Item g
V 2
Reports ("NCis") and discussions with other inspectors, only a few 3
instances of failure to properly store cables have been detected, 4
and each of these were minor and corrected.
Thus, I can only 5
conclude that the allegations may illustrate isolated and minor 6
instances of violations of procedure, but are not reflective of a 7
major problem as implied in the allegation.
This conclusion is 8
supported by the fact that during this time, on two separate 9
occasions Mr.
Hoopingarner personally showed these alleged 10 numerous deficiencies involving many cables to different NRC 4
11
. inspectors, and, out of all the alleged violations made by Mr.
1 12 Hoopingarner, the inspectors found only one safety-related cable in 13 violation of procedures.
NRC Inspection Report 50-413/80-19, 14 50-414/80-19.
Corrective action, taken immediately, consisted of 15 simply moving the cable.
l 16 In this regard, when cable is being pulled, in virtually all 17 instances there are large segments of cable at the ends of the runs 18 which are not used and are ultimately discarded.
This cable, 19 ranging in segments from around 10 up to more than 30 feet, may 20 remain on the floor while the job is in progress.
Further, an 21 additional 1\\ - 10 feet of cable above that to be discarded is 22 stripped of insulation to facilitate connections.
In short, when 23 cable is being pulled, there is a great deal of cable at the ends of 24 the runs that will ultimately be discarded or stripped which is lying 25 on the floor.
This may give the appearance of cable which is 26 unprotected contrary to applicable procedures, but in reality is
'h 27 only normal and correct work practices.
(
1 It should be noted that personnel at Catawba who handle
.O 2
electrical cable are well aware of actions necessary to assure the 3
protection of this cable.
These individuals are well motivated and, 4
based on my experience, are diligent in doing their job. Further, 5
QA inspectors monitor plant activities to provide further assurance 6
that cable is properly protected.
7 Q.
EVEN IF VIOLATIONS OF PROCEDURES DID OCCUR, WHAT 4
8 ASSURANCE IS THERE THAT THIS WILL NOT EFFECT SAFE i
9 OPERATION OF THE PLANT?
j 10 A.
It should be noted that the cable Duke uses at Catawba provides a i
11 great deal of assurance that damage will not occur.
All j
12 safety-related cable pulled during the period of concern in the 13 allegation is interlocked or braided armored cable, which is 14 electrical cable wrapped in steel, or is protected in conduit.
The l
15 cables in the conduit cannot contact the ground and, of course, are i
1 16 protected by the conduit.
I should note that only six of the 17 safety-related cables pulled during this time were not armored.
18 These six were all in conduit.
Therefore, absent major abuse, 19 such as running over the cable with construction equipment, the 20 potential for physical damage is minimal.
t i
21 Further, the procurement specifications designate that cable 22 with filler material must be non-wicking (i.e., it does not absorb 4
i j
23 and transmit moisture).
Thus, the likelihood of water damage is I
24 remote even if the ends of the cables are left.untaped.
In this i
25 regard, it should be noted that neither Messrs.
McAfee or i
26 Hoopingarner allege that the ends of the cables were unprotected so t
O 22 as to give rise to concerns regardin, moisture in the cabies.
-s-
l j
i a
Q 1
In addition, it should be emphasized that when damage to 2
electrical cable has occurred or is suspected, the cable will be 3
inspected, and if necessary a megger or high potential test will be 4
done.
If either the inspection or test so indicates, the cable will 5
be replaced or
- repaired, as necessary.
The megger or 6
high-potential test performed when physical damage is suspected 7
will detect deteriorated insulation.
1 1
8 Further, other tests of cables and electrical systems, both i
9 before and after operation, provide further assurance of plant 10 safety.
For example, before fuel load, all medium voltage cables in i
11 the plant receive a high potential test to determine the integrity of 12 the insulation.
- Further, at the time of system
- checkout, 13 Construction Procedure CP-466 requires testing of all electrical 14 systems to insure circuit continuity.
This functional testing 1
15 insures the integrity of the circuits and the cables.
In addition, 3
j
' 16 during start-up and operation, periodic testing provides assurance 17 that electrical systems will continue to function as required.
In sum, the combination of protection afforded by inspectors 18 1
19 and personnel handling the cable, the cable itself and the numerous l
l 20 tests and inspections conducted on the cable and electrical systems 1
21 provides assurance that the cables in the plant will perform their 22 intended function.
1 23 Q.
WHAT IS YOUR CONCLUSION WITH RESPECT TO THIS 24 ALLEGATION?
25 A.
My conclusion is that for the following reasons the allegations does l
26 not raise a question of safe operation at Catawba.
First, as I I
27 explained above, the alleged activity is not common practice.
28
- Second, any safety related cable in question concerning the i
..._._.__,.m
,. -.. ~...
i C
1 allegation is armored or protected in conduit with non-wicking filler 2
material, which in itself provides inherent moisture protection.
3 Third, the ends of the cables are taped to provide assurance that 4
water damage does not occur.
Fourth, the cables, if damage is 5
suspected, are inspected and, as appropriate, tested.
If damage is 6
found, an evaluation is made and the cable is replaced or repaired.
7 Finally, as I explained, each circuit in the plant is tested and 8
verified numerous times before and after operation of the plant.
9 For these reasons, I conclude that this allegation does not present 10 a question of safe operation of the plant.
11 (S.W.D. ) II. TESTIMONY REGARDING MR. HOOPINGARNER'S 12 ALLEGATION CONCERNING QUENCHING WELDS (2b) 1 13 14 Q.
ARE YOU FAMILIAR WITH THE ALLEGATION RAISED BY MR.
15 HOOPINGARNER WITH RESPECT TO AN INCIDENT IN WHICH HE O
16 ALLEGES THAT HE OBSERVED A WELDER IMPROPERLY QUENCH A 17 WELD WITH A DAMP CLOTH?
f i
18 A.
Yes.
I have reviewed the deposition testimony of Mr.
19 Hoopingarner.
Mr. Hoopingarner alleges that he came out of the 20 penetration room one day and saw a welder who he said was Henry 21 Knox quench a " red hot spot" on a weld with a damp rag.
Mr.
22 Hoopingarner alleges that the welder told him that to do this was i
23 contrary to procedures, but that "he had to do [ft) to get the pipe 24 right. "
HD Vol.
1 Tr.,
p.
22; Vol.
2 Tr.,
p.
70.
Mr.
25 Hoopingarner further states that this was a weld on a stainless 26 steel pipe. HD Vol. 2 Tr., p. 71.
27 Q.
HAVE YOU INVESTIGATED THIS INCIDENT?
^-
'"- "" d ' "r d' " '" '" v" a " " ' " d "* d -
O 29 investigation showed that Duke has never employed a welder named
' i
- O 1
nenry xnox.
nowever, a weider named nenry ned,es worked io 2
the area where Mr. noopingarner alleges the damp rag was applied.
3 It was determined that while Mr. Hodges was apparently the person 4
accused by Mr. Hoopingarner, Mr. Hodges states that in fact he 5
did not apply wet rags to any stainless steel pipe while welding. It 6
should be noted, however, that welding inspectors at Duke in i
7 performing liquid penetrant, non-destructive examinations use a red
}
8 dye which, in use, may give the appearance of a " red hot-spot" on 9
the weld. This material is wiped from the weld using a rag.
I 10 Q.
IS USING A
DAMP RAG TO QUENCH A
WELD AGAINST j
11 PROCEDURES?
12 A.
No, not if prior approval is obtained for such a welding procedure.
{
13 If such quenching is needed, controls exist in the Welding Process 14 Specifications to assure Technical Support provides detailed i
15 information to the craft before they employ this technique.
16 However, absent prior approval, quenching a weld with a damp rag l
17 would be contrary to procedures. In this regard, welders at i
18 Catawba are required to perform welding in accordance with specific 1
19 procedures on which they are well trained and certified.
In j
20 addition, welding inspectors monitor the activities of these welders i
i 21 to provide additional assurance that these procedures are followed.
22 Q.
IF THIS INCIDENT DID OCCUR, WOULD IT HAVE HAD AN 23 ADVERSE EFFECT ON THE WELD?
24 A.
No.
To explain, the major concern regarding cooling of stainless 25 steel welds in the temperatures of concern is the possible formation 26 of compounds which would enhance corrosion.
Heating or cooling O
t i
27 stainless steel material in the range of 800*F to 1400*F causes 28 carbon in the pipe to precipitate out (mainly at the grain L
l 1
boundaries).
This carbon unites with chromium to form chromium -
10 2
rich carbides, which reduces the corrosion resistance at the grain 3
boundaries.
This is known as carbide precipitation.
The amount 4
i 4
of carbide precipitation may be decreased by promoting faster 5
cooling through this range of temperatures (i.e., 800 F-1400*F),
6 such as may be the case if a damp rag was used on the weld.
In 7
short, using a damp rag to more rapidly cool a stainless steel weld j
8 will not adversely affect the weld.
9 Q.
WHAT IS YOUR OPINION WITH REGARD TO THIS ALLEGATION 1
10 RAISED BY MR. HOOPINGARNER?
11 A.
We are unable to confirm that the incident occurred. However, if it j
12 did occur, as I explained above, the quality of the stainless steel 13 material would not have been compromised.
Therefore, I have 14 concluded that this allegation does not present a question with 15 respect to public health and safety.
16 (L.R.D.) III. TESTIMONY REGARDING MR. HOOPINGARNER'S i
17 ALLEGATION CONCERNING WELDING ON SCAFFOLDS (2c) 18 4
19 Q.
ARE YOU FAMILIAR WITH MR. HOOPINGARNER'S ALLEGATION i
20 REGARDING THE ABILITY OF WELDERS TO MAKE WELDS BECAUSE l
i 21 OF UNSAFE SCAFFOLDS?
r l
22 A.
Yes.
I have reviewed the deposition testimony of i
23 Mr. Hoopingarner. He alleges that because scaffolds were poorly i
24 built, welders were unable to properly weld when they were 25 standing on them.
Mr. Hoopingarner alleges that he was told by 26 welders that they just " filled a gap" while on these scaffolds,'which 27 Mr. Hoopingarner believes means that the welds are improper. HD 1
28 Vol.
1, Tr.
p.
13; Vol.
2 Tr.,
pp.
5,9,11-13. However, i
O i
.g.
1
, -.,.. ~ _.
. ~
4 Q
1 Mr. Hoopingarner is not a welder, and was unable to state if the 2
subject welds were improper. HD Vol. 2, Tr. pp. 13,61.
3 Q.
WERE YOU ABLE TO INVESTIGATE THIS ALLEGATION?
4 A.
Yes, but only to a limited extent for two reasons.
First, Mr.
5 Hoopingarner could not identify specific welders or locations 6
involved with his concerns; and, second the term " filled the gap" is q
i 7
not a common welding term and is not defined.
i' 8
Q.
WHAT DO YOU THINK " FILL THE GAP" MEANS?
l 9
A.
While the term lacks definition,
" fill the gap" is most likely used 10 by the welder as " slang" for completing the weld.
The use of the i
11
' terminology in this fashion could be misleading to a person not i
12 trained in welding and only associating with welders on an 13 informal / casual basis.
A statement such as this may have been a 0
14
" boast" by the welder indicating that he welded the joint quickly.
15 We believe this is probably the most likely interpretation to put on 16 the statement by Mr. Hoopingarner, i.e.,
that the welder was i
{
17 welding quickly so he could get out of an undesirable situation.
i 18 Q.
EVEN ASSUMING " FILLED THE GAP" COULD MEAN ANYTHING 19 OTHER THAN COMPLETING THE WELD, WOULD THERE BE A
)
20 DETRIMENTAL EFFECT ON THE SYSTEM?
21 A.
No.
All pipe welds are extensively inspected and tested. In order l
22 to place this in perspective, it must be understood that there are 23 five classes of safety-related pipe, Classes A through F, with Class 24 A being the highest class.
Each piping weld, regardless of class, 25 is inspected, with Classes A and B receiving the most inspections, 26 consistent with their station as more important piping systems.
A>>
O 22 Ciass A and H weids rec.ive a fit-u, ins,ection, a finai isuai 28 inspection, NDE-Penetrant Testing (PT) or Magnetic Particle I :
__ ~. _, _,
Q 1
Testing (MT), and, in addition, circumferential butt welds are 2
radiographed.
All Class C welds receive a fit-up inspection and a 3
final visual inspection.
All Class E and F welds receive a final 4
visual inspection.
5 It is also important to note that it is our practice to check 6
welders' qualifications during inspections for Class A, B, C, E, and 7
F pipe welds. Thus, qualifications of the welder to the appropriate 8
Field Weld Data Sheets (FWDSs) are verified for the weld being 9
made.
The welding inspectors selectively monitor the welding 10 process in their assigned areas to assure compliance with FWDSs 11 also.
As noted, the relative system importance is denoted by Class 12 with Class A being the highest class.
Thus, more inspections are -
13 performed for the more important and/or critical systems.
It also
,h 14 should be noted that following completion and inspection of pipe 15 welds, all such welds are extensively tested before being put into 16 service.
All Class A, B, and C welds are hydrostatically and/or 17 pneumatically tested before being put into ser-Ice.
Virtually all 18 Class E and F welds are also hydrostatically or pneumatically tested 19 prior to being put into service.
20 If Mr. Hoopingarner was referring to structural steel welds, 21 these welds are also inspected, with designated structural welds 22 receiving NDE.
Designated structural welds receive a fit-up 23 inspection, final visual inspection, and nondestructive examination 24 such as ultrasonic testing, radiograph testing, magnetic particle 25 testing, or penetrant testing.
All safety-related structural welds, 26 as a minimum, receive a final visual inspection. Also, all structural 27.
steel welding is subject to random in-process inspections.
Here 28 again the welding process is selectively monitored to assure the i>
1 welder is qualified.to make the weld and that he is welding in O
2 compliance with the FWDS required.
3 Q.
DO YOU BELIEVE THAT MR.
HOOPINGARNER'S ALLEGATION 4
PRESENTS A
PROBLEM RESPECTING THE SAFETY OF THE 5
CATAWBA PLANT?
6 A.
No. There are no grounds to substantiate the fact that the welders 7
meant anything by " fill the gap" other than the situation outlined 8
above.
In any event, the allegation does not present a hazard with 9
respect to public health and safety because all welders welding on 10 safety-related systems are trained and qualified to weld in 11 accordance with appropriate Welding Process Specifications (WPS) 12 and Field Weld Data Sheets.
13 Moreover, as explained above, Duke's QA inspection program 14 is designed to detect violations such as those alleged by Mr.
15 Hoopingarner.
Duke's surveillance program, both planned and 16 random, also looks for WPS and FWDS violations.
17 Q.
YOU HAVE REFERENCED WELDING PROCESS SPECIFICATIONS 18 (WPS)
AND FIELD WELD DATA SHEETS (FWDS)
IN YOUR 19 DISCUSSION.
BRIEFLY TELL US WHAT YOU MEAN BY THESE 20 TERMS?
21 A.
The Welding Process Specification (WPS) is a written welding 22 procedure prepared to give direction to a' welder or welding 23 operator using a particular welding process.
The Field Weld Data 24 Sheet is used in conjunctions with a WPS to specify the 25 requirements to be. met while making a specific weld, such as fit-up 26 requirements.
IAkg
! i
l l
O 1
9 WHAT IS YOUR CONCLUS1ON WITH RESrECr TO THIS 2
ALLEGATION BY MR. HOOPINGARNER?
3 A.
I have concluded that this allegation does not raise a question of 4
public health and safety.
5 (R.S. A.) IV. TESTIMONY REGARDING MR. HOOPINGARNER'S 6
ALLEGATION CONCERNING PRESSURE NOT TO 7
TALK TO NRC PERSONNEL (2d) 8 9
Q.
ARE YOU FAMILIAR WITH MR. HOOPINGARNER'S ALLEGATION 10 THAT HE WAS PRESSURED NOT TO TALK TO THE NRC?
11 A.
Yes.
I have reviewed Mr. Hoopingarner's deposition testimony.
12 Mr. Hoopingarner alleges that he approached the NRC Inspector on 13 the job site one day and asked if he could talk with him. After the 14 NRC Inspector had left, Mr. Hoopingarner states that he was 15 approached by his foreman and ordered not to approach or talk to 16 the NCR Inspector.
Mr. Hoopingarner states that, subsequent to 17 this order, he approached an employee relations person, told him of 18 the order, and a day later this order was withdrawn.
HD Vol. I 19 Tr., pp. 17-18; Vol. 2 Tr., pp. 6,8,70-71 20 Q.
WHAT IS YOUR KNOWLEDGE OF THIS INCIDENT?
21 A.
In 1980, I caused this incident to be investigated. I have reviewed 22 our files on this incident and they reflect-that on April 23, 1980 23 Mr. Hoopingarner came to Employee Relations Assistant John Turner 24 and was concerned because his General Foreman had told him he 25 could not talk to the NRC unless the NRC approached him.
26 Apparently this was precipitated by Mr. Hoopingarner stopping 27 George Maxwell, an NRC inspector, as he was walking though the 28 plant.
The General Foreman apparently saw this happen and told O
d 29 Mr. Hoopingarner.that he could talk to the NRC inspector if he was 30 approached, but he should not initiate the contact with the NRC,
w w-e-
O i
inspector.
Mr. H-vingarner t-k exception to this and questioned 2
John Turner from Employee Relations about this issue.
3 John Turner then spoke with the General Foreman who stated 4
that he had received the general instructions he gave to Mr.
5 Hoopingarner from Mr.
- Scruggs, the Builder Superintendent.
6 Turner then talked to Scruggs who said that the General Foreman 7
had misunderstood him.
Scruggs stated that he had told the 8
General Foreman that an employee could talk to the NRC Inspector 9
if approached and could approach the NRC in the work area.
If an 10 employee needed to talk at length, then an appointment should be 11 made.
Mr. Hoopingarner was informed of this misunderstanding, 12 but was still concerned about the " order" that he was supposedly 13 given.
Turner told Hoopingarner that if he considered it an 14
" order" then that " order" was rescinded.
Turner again told him 15 that it was a misunderstanding, and not a direct order.
16 Q.
WHAT IS THE DUKE POLICY WITH RESPECT TO EMPLOYEES 17 TALKING WITH NRC INSPECTORS, OR WITH ANY NRC 18 PERSONNEL?
19 A.
The Construction Department's policy on employees talking to the 20 NRC was clearly stated in an April 25, 1977 letter from R. L. Dick, 21 Vice President - Construction. This letter states that "any nuclear 22 industry worker who has concerns or questions about the nuclear 23 safety of any facility or activity licensed by the NRC may bring 24 these matters to the attention of the NRC Inspector of the nearest 25 NRC regional office, if thav cannot be resolved directly with his or 26 her employer".
The regional NRC telephone number is also listed O
27 in this letter which was posted at the project from that date 28 onward.
In addition to this letter, NRC Form 3 has been posted on.-
I from which it also dripped onto the floor and the control boards.
2 Significantly, inspection revealed no condensation formed on the 3
insides of the control boards.
Therefore, none of the contact 4
portions of switches or meters, or wiring underneath the control 5
boards were exposed to condensation.
This incident was reported 6
as a Nonconforming Item Report, NCI 4395.
7 Q.
PLEASE DESCRIBE THE STATUS OF COMPLETION OF THE 8
CONTROL BOARDS AT THE TIME THIS INCIDENT OCCURRED.
9 A.
At the time this incident occurred, the majority of the switches (all 10 of which were of the sealed type) were installed in the control 11 boards and wired to plugs inside the control boards.
- However, 12 only a few meters were in place, arid no chart recorders, CRTs, or 13 printers were installed. To put the completion status of the control Q
14 boards in proper perspective, the completed control boards will 15 include many additional pieces of equipment such as all other 16 switches, meters, chart recorders, annunciator alarms, lights, 17 indicating lights, computer type typewriters, and CRT screens.
18 The majority of these items have to be wired to plugs under the 19 board itself.
20 Q.
AS A RESULT OF THIS INCIDENT, WERE CORRECTIVE ACTIONS 21 TAKEN?
22 A.
Yes.
First, a number of space heaters were installed in the control 23 room to bring the relative humidity level down to preclude a similar 24 occurrence.
i 25 Approximately 60 of the switches located on the boards were 26 selected and given a megger test to assure that there was no 27 adverse impact. The megger test consists of running a higher than 28 normal voltage through the switch to determine insulation
'O 1
resistance.
Moisture would decrease the resistance of the insulation 2
which would be detected by the meggar test. All 60 of the switches 3
tested passed the test, which provided adequate assurance that 4
none of the switches potentially exposed to the moisture were 5
adversely affected by this incident.
6 Q.
HAVE FURTHER TEST 6 BEEN RUN TO SEE IF THE CONTROL 7
BOARDS ARE FUNCTIONING NORMALLY?
8 A.
Yes.
It should be understood that all the equipment on the control 9
boards potentially affected by this incident are tested / operated 10 many times for proper functioning during the installation process, 11 construction system testing and start-up activities.
Prior to 12 operation of the facility, the control boards will have been 13 exhaustively checked for functioning of each of the components.
In O
14 addition the controi boards are tested on numerous occasions 15 through individual system functional testing and two major 16 integrated tests (Hot Functional Test and Engineering Safety 17 Feature Activation System Test).
Operation of the integrated tests 18 are through the control boards and indications are monitored in the 19 control room.
Additionally, there are maintenance and calibration 20 procedures for the control board equipdent.
Further, during 21 operation, periodic surveillance testing will assure proper 22 functioning of the equipment.
23 Q.
WHAT IS YOUR CONCLUSION WITH RESPECT TO THE DECEMBER 24 1978 INCIDENT WHICH RESULTED IN CONDENSATION FORMING ON 25 THE EXTERIOR SURFACES OF THE CONTROL BOARDS?
26 A.
It is my opinion, for the reasons that I explained above, that when 27 this incident occurred appropriate evaluation and corrective action 28-was taken to insure that the moisture on the control boards had no -
1 adverse effect on the switches and other components that were then 2
installed.
Further, because of the extensive checks, tests and 3
functional operation of the equipment that occurs during the 4
installation and start-up of the plant, I am confident that if there 5
were any defects from this incident, they would not go undetected.
6 Therefore, I conclude that this incident has no effect on the public 7
health and safety.
8 (S.W.D.) VII. TESTIMONY REGARDING MR. HOOPINGARNER'S 9
ALLEGATION CONCERNING REBAR AND PIPING (2n) 10 11 Q.
ARE YOU FAMILIAR WITH THE ALLEGATION MADE BY MR.
12 HOOPINGARNER WITH RESPECT TO PIPING AND REBAR TOUCHING 13 THE GROUND OR LYING ON THE FLOOR?
14 A.
Yes I am.
I have reviewed Mr. Hoopingarner's deposition testimony 15 and have determined that this allegation is based on three specific O
16
- events, i.e., (1) that rebar was touching the ground in the rebar 17 storage area, (2) that three sections of stainless steel piping were 18 touching the ground at the piping fabrication shop, and (3) that 19-sections of the piping were lying on the concrete floor in the 20 auxiliary building. HD Vol 2. Tr., pp. 76-78.
21 I also am familiar with NRC Inspection Report 50-413/80-19, 22 50-414/80-19 which, I believe, addresses these concerns after they.
23 were pointed out to our NRC inspector by Mr. Hoopingarner.
24 Q.
WHAT ARE THE STANDARDS WHICH GOVERN STORAGE OF REBAR 25 AND PIPING AT THE CATAWABA SITE?
26 A.
The governing industry standard which Duke Power follows at t
27 Catawba in regards to handling and storage of materials is ANSI 28
- N45.2.2-1972,
" Packaging,
- Shipping, Receiving,
- Storage, and 29 Handling of Items for Nuclear Power Plants".
This document,
1 establishes a standard for general industry use that defines (Q_
2 requirements for the above activities.
The extent to which the 3
individual requirements of the standard apply depends upon the 4
nature and scope of the work to be performed and the importance 5
of the item or service involved.
The requirements are intended to 6
assure that the quality of items is not degraded as a result of 7
packaging, shipping, receiving, storage, and handling practices 8
and techniques.
Rebar and piping fall into stcrage classification 9
level D as defined by the standard.
Level D items may be stored 10 outdoors in an area which is well drained, preferably gravel 11 covered or paved, and reasonably removed from the actual 12 construction area and traffic so that the possibility of damage from 13 construction equipment is minimized.
Items are to be stored on 14 cribbing or its equivalent to allow air circulation and to avoid O
15 trapping water.
16 The standard also sets forth requirements for periodic inspection to 17 be performed to assure storage areas are being maintained in 18 accordance with these requirements.
19 Q.
HAVE YOU INVESTIGATED THESE ALLEGATIONS?
~
20 A.
Yes.
With regard to the item concerning rebar touching the 21 ground, as stated in the NRC inspection report (at p. 3), this 22 rebar was being stored at Catawba but ' designated for use at other 23 sites.
With regard to the two alleged incidents involving the 24
- piping, the NRC inspection report (at p.
4), noted above, 25 addressed these two items and stated that the allegation that piping 26
. was stored in the auxiliary building in violation of procedures was t
27 without merit.
However, the report (at p. 4) noted that the 3 28 sections 'of stainless steel piping which had been placed on the
(.
(
1 ground outside the piping fabrication shop should have been 2
elevated.
As far as corrective action, the report stated that the 3
normal flushing / cleaning required before any safety-system piping 4
is placed in service would be adequate.
An NCI was prepared on 5
this deficiency.
In
- short, from my investigation, incidents 6
involving unacceptable storage of rebar and piping to be used at 7
Catawba are isolated incidents involving minor deficiencies which 8
were immediately corrected.
9 Q.
WHAT IS THE SAFETY SIGNIFICANCE OF REBAR OR PIPING 10 TOUCHING THE GROUND?
11 A.
'While procedures require such material to be elevated to assure 12 cleanliness and minimize corrosion, prior to such items being placed 13 in service they are thoroughly inspected and/or tested to assure Q
14 acceptability.
For example, with regard to rebar, prior to making 15 a concrete pour a Prepour Form M-2A must be completed which, in 16 pertinent part, requires a signature verifying that rebar has been 17 inspected and is free from mud, dirt or other unacceptable 18 contaminants.
In a similar manner, piping is inspected and 19 inspection sheets must be completed verifying its condition and 20 cleanliness prior to use.
In addition safety-related piping. is 21 internally cleaned or flushed before plant start-up and specific' 22 safety-related piping receives. additional cleaning and tests.
In 23 short, there is reasonable assurance that the allegation of Mr.
24 Hoopingarner does not present a potential impact on public health 25 and safety.
O m
I 1
Q.
WHAT IS YOUR CONCLUSION THEN WITH RESPECT TO THE gs 2
ALLEGATIONS MADE BY MR. HOOPINGARNER?
3 A.
My conclusion is that this allegation presents no question of the 4
public health and safety at Catawba.
5 (S.W.D.) VIII. TESTIMONY REGARDING MR. MCAFEE'S ALLEGATION 6
CONCERNING POURING CONCRETE IN THE RAIN (la) 7 8
Q.
ARE YOU FAMILIAR WITH THE ALLEGATION RAISED BY MR.
9 MCAFEE WITH RESPECT TO POURING CONCRETE IN THE RAIN?
20 A.
Yes.
I have reviewed the deposition testimony of Mr. McAfee. He e
11 alleges (MD Tr., P. 72) that during the period between January 12 and March of 1978 in an area which he describes as one on the wall 13 above the interior dog house on reactor building one containment, 14 he 15 witnessed concrete poured in downpours of rain with no 16 rain protection. As I said, I was pre-pour runner. I 17 went up to the pour, the concrete on the Reactor O
18 Building One Containment. The concrete had too much 19 water in it by anyone's reasonable standards. It didn't 20 look like concrete. It had water floating on top 21 of the concrete, and I'll say here I am not a concrete 22 inspector, but reason should prevail. [MD Tr., pp. 12-13]
23 24 From this review, I have concluded that Mr. McAfee is concerned 25 because he witnessed rain falling on concrete which was being, or 26 had been placed.
27 Q.
PLEASE DESCRIBE THE STANDARDS FOR THE PLACEMENT AND 28 PROTECTION OF CONCRETE AT CATAWBA AS THEY RELATE TO 29 THIS ALLEGATION.
30 A.
The standards followed for placement of concrete at Catawba are 31 that safety-related concrete pours will not be started during times 32 of rain, sleet or snow unless there is adequate protective actions
.l 33 taken commensurate with the level of precipitation
( eg, 34
- construction of a shelter). However, if precipitation begins after a l
~29-
1 safety-related concrete pour is started, absent overriding technical O
2 concerns, the pour is continued until the secHn is completed to 3
avoid problems associated with cold joints.
Col
-'uts appear in a 4
concrete placement when a layer of previous a
, hardens or 5
sets to the extent that a newly placed layer ces n.
bond to it.
6 In effect, this would result in two or more masses
- concrete 7
separated by a joint where only one mass was designe.
ese 8
standards are consistent with Chapter 8 of " Specification ur 9
Structural Concrete for Building", ACI 301-72, except where 10 modified within the design concrete specifications.
11 Each safety-related concrete placement at Catawba involves a 12 minimum of three concrete inspectors trained in the requirements of 13 QA procedure M2, Design Engineering Specifications, and ACI 301.
14 In large pours more inspectors are involved.
Each of these 15 inspectors has the authority to stop a concrete placement or to 16 write a nonconforming-item report if a requirement is not met.
17 Q.
PLEASE EXPLAIN THE STANDARDS AND PROCEDURES FOR 18 PLACING CONCRETE IN RAIN.
19 A.
Unless adequate protective measures are taken, we do not plan to 20 place concrete in the rain.
Construction personnel associated with concrete placement monitor the local weather forecast and plan their 21 i
22 daily concrete operations accordingly.
A judgment on whether to 23 pour or not is made using the facts on hand at the scheduled time 24 of the pour.
With a high probability of rain, the initiation of some 25 pours may be delayed substantially while others may be started, 26-keeping in mind that each pour is unique.
I
+]
27 As to protection against precipitation, some pours may be 28 covered or protected more easily than others.
In some cases, a l l
c
-,y a
O 1
compiete cover such as a shed may he instailed prior to starting a 2
placement.
- However, a
number of factors enter into this 3
consideration, such as the size of the pour, its surface area (that 4
is, whether the pour is a wall or foundation), the mode of 5
transportation of concrete to the form, surface finish required, and 6
the importance of the concrete; for example, there are thousands of 7
yards of concrete at Catawba that are not structural concrete, or 8
part of a safety-related structure.
9 If during the course of a safety-related pour it begins to rain, 10 measures commensurate with the amount of precipitation and the 11 nature of the pour are taken to protect the concrete. However, as 12 I noted,
absent other overriding technical concerns, once a 13 safety-related pour is started it should be finished without any cold O
14 joints.
nuke has guidelines which it foliows in such a situation.
15 These guidelines, consistent with sound industry practice and 16 Chapter 8 of ACI 301-72, provide that in the event of sudden, 17 unexpected precipitation during placement or finishing of concrete, 18 the following actions should be taken, as appropriate:
19 1)
Use lower slump concrete by withholding as much mixing water 20 as possible while maintaining workability.
21 2)
Dry up or drain any ponding.
If possible, maintain the 22 surface of the concrete being placed at a slight slope so water 23 will runoff and provide for water drainage or consider 24 removing the water such as by pumping.
25 3)
Avoid working the surface of_ wet concrete.
26 4)
If a cold joint can be tolerated, consider stopping the pour.
O 27 Design Engineering may be able to provide advice if time 28 permits, but should, in any event, be notified if a pour is -
1 stopped long enough to form a cold joint before the pour is O
2 completed.
3 5)
If precipitation is so heavy that ponding cannot be removed or 4
drained (so as to affect the properties of the concrete), the 5
pour should be stopped.
Design Engineering should be 6
notified and a determination must be made on how much of the 7
concrete placed can be salvaged.
8 In short, in the event that precipitation begins after a 9
concrete pour has started, there are specific guidelines which are 10 followed to assure that structural integrity of the concrete will not 11 be compromised should the pour continue.
12 It should be noted that even without rain, a certain amount of 13 free water will form on the surface of fresh concrete due to j
14 sedimentation of aggregate particles or solids.
This water is called 15 bleed water and, while normal, gives the appearance of excessive 1
16 water in the mixture.
I 17 Q.
HAVE YOU BEEN ABLE TO IDENTIFY THE SPECIFIC POUR WHICH 18 IS THE SUBJECT OF MR. MCAFEE'S ALLEGATION?
19 A.
From the information provided by Mr. McAfee, the pour records 20 were examined for each pour in the. area described by Mr. McAfee 21 during the time in which he was a prepour runner (January -
22-March 1978).
From this review of the concrete records (Form 23 M-2D), for this period only two pours. (in January 1978) could 24 possibly fit the description of the allegation.
These are reactor 25 building No. I shell wall pours W82 (January 19, 1978) and W83 -
26 (January 25, 1978).
In each case, the weather conditions of " rain i
i Q
27 and cold" are indicated on the pour Form M-2D.
Thus, I have 28 concluded that the particular pour was a reactor building shell wan -
pour above the elevation of the roof of the interior dog house which I
2 ties into the side of the reactor building.
3 Q.
DO THESE RECORDS SHOW THAT PROPER MEASURES WERE TAKEN 4
TO AVOID THE PROBLEM OF RAIN EFFECTING THE CONCRETE?
5 A.
Yes.
In fact, it happens that a QA surveillance was perfonned on 6
the January 25, 1978 pour.
This QA surveillance report 7
(No. C-3-1-78) indicated that adequatc sngements were being 8
made (eg, plastic covers and pumps) to keep rainwater out of the 9
form area on wall pour W83.
With respect to wall pour W82, 10 nothing unusual or out of the ordinary was reported or recorded on 11 Form W-2D.
In sum, with respect to the two pours which I have 12 identified as being the possible subject of Mr. McAfee's allegation, 13 adequate procedures and protection were afforded so that the 14 presence of rain during or after the pours did not effect the O
15 integrity of the particular area.
Moreover, I have no reason to 16 believe that any concrete pours which may have occurred during 17 rainfall were done other than in accordance with procedures.
18 Q.
EVEN IF CONCRETE WAS POURED IN CONDITIONS WHERE SOME 19 RAIN WAS PRESENT (AS ALLEGED HERE), WOULD THIS HAVE A 20 SUBSTANTIAL IMPACT ON THE STRUCTURAL INTEGRITY OF THE 21 WALL?
22 A.
The likelihood of such an impact is very remote.
As concrete is t
l 23 poured, being much denser than water, it would displace the water
(
24 causing the water to rise to the surface.
On the surface, the
_25 water would have. no adverse impact while the concrete cured.
26 Indeed,.during the curing process water is quite often continuously
(
27 sprayed on concrete to assure proper curing. l
t]
1 Q.
WHAT IS YOUR CONCLUSION WITH RESPECT TO THIS SPECIFIC 2
ALLEGATION OF MR. MCAFEE?
3 A.
I do not believe that this allegation raises a concern with respect to 4
the health and safety of the public.
5 (L.R.D.)
IX.
TESTIMONY REGARDING MR. MCAFEE'S 6
ALLEGATION CONCERNING QA WAIVER OF 7
REQUIREMENTS ON CONCRETE FORMS (1b) 8 9
Q.
ARE YOU FAMILIAR WITH THE ALLEGATION OF MR. MCAFEE WITH 10 RESPECT TO QUALITY ASSURANCE WAIVING REQUIREMENTS ON 11 CONCRETE POURS?
12 A.
Yes.
I have reviewed the deposition testimony of Mr. McAfee. Mr.
4 13 McAfee contends that during the time he was a prepour runner, he 14 believes that the Quality Assurance Department inappropriately 15 waived requirements on concrete pour forms in order to let the O
16 Construction Department make the pours.
As the basis for his 17 allegation, Mr. McAfee relates an occurrence which he alleges 18 occurred one day when he was trying to get a pour signed off. He 19 states that the Construction Department was eager to make the 20 pour, but that one of the QA engineers was holding up the pour 21 because requirements had not been met.
Mr. McAfee was not 22 familiar with the requirements.
Mr. McAfee states that a person 23 who he believes to have been a junior QA engineer stated that the 24 requirements could be waived.
MD Tr.,
pp. 13, 73-74.
Mr.
25 McAfee did not know what requirements this individual referred to; 26 he did not know whether it was appropriate for the requirements to 27 be waived; and he was unable to recall either the area of the plant 28 or the individuals involved. Id. at p. 74.
O 34-n
, +--- _ -, -..
...,y g
1 Q.
PLEASE DESCRIBE.THE REQUIREMENTS SET FORTH ON THE
_O 2
" CONCRETE POUR FORMS" WHICH MUST BE MET BEFORE A POUR 3
IS MADE.
4 A.
Form M-2A, entitled "Prepour Site Inspection" (the "Prepour 5
Form"), is a checklist that sets forth requirements for concrete 6
pours.
(Attachment G)
Among other things, it requires all 7
involved crafts and inspectors to assure that items installed are in 8
accordance with the design drawings prior to placing concrete.
9 This form is used for both safety related and non-safety related 10 concrete pours.
It should be noted that while Form M-2A is used 11 for all concrete pours, non-s *ety related concrete pours do not 12
" require" QA attention.
13 On the Prepour Form, there are a number of blocks to be 14 signed off by the appropriate disciplines before the pour can be 1
15 made.
Signing off on these blocks is necessary for several 16 reasons.
First, before concrete is placed, either as a wall or floor 17 slab, it is necessary to assure that embedded systems, such as 18 piping or electrical conduits, are installed in accordance with the 19 design.
If not, then the structure might later have to be modified 20 to install the missing items.
Second, the form assures that the 21 necessary concrete forms and reinforcing steel are in place and 22 signed off before the pour is made. Finally, the form requires that 23 all necessary QA inspections be complete prior to making the pour.
24 Q.
WHAT ARE THE QA REQUIREMENTS WHICH ARE APPLICABLE?
j 25 A.
As required by Quality Assurance Procedure M-2, " Inspection of 26 Design Concrete," prior to signing Form M-2A, QA verifies that the l
I l
27 correct concrete mix has been entered on the form along with the 28
-approximate volume of the pour, and that all NCI reports that could
, l l
t
(]
1 effect concrete placement have been cleared.
- Also, Quality 2
Assurance Procedure M-2 requires verification that applicable 3
foundation compaction records, rebar cadweld records, and records 4
for installation, inspection and testing of embedded piping are 5
complete.
Furthermore, the Procedure requires that QA personnel 6
review the entire Form M-2A for completeness to assure all 7
inspections and signatures have been recorded and evaluate any 8
notes made by inspectors or civil engineering personnel that would 9
effect placement requirements.
10 Q.
WHAT IS THE PROCEDURE SHOULD ANY OF THE ABOVE 11 REQUIREMENTS NOT BE MET?
12 A.
If any of the crafts or QA Inspecto'rs identify a problem that needs 13 correcting prior to concrete placement, QA will not sign Form M-2A O
and the concrete P acement will be on hoid" until the Probiem is l
14 15 resolved.
Form M-2A must be forwarded to the QA Inspectors at 16 the prepour site prior to concrete placement.
If that form is not 17 signed by QA, then concrete placement is not authorized and 18 concrete will not be placed.
It should be noted that with the 19 exception of the structural inspector who finally determines when 20 the concrete forms are clean, QA is the last. signature on Form 21 M-2A.
22 Q.
PLEASE EXPLAIN HOW THIS PROCESS. WORKS IN ACTUAL 23 PRACTICE.
24 A.
Prepour Form M-2A is initiated for all design pours whether 25 safety-related or non-safety related.
The builder foreman, who is 26 responsible for installing the rebar and structural embedments 27 (such as structural plates) along with the formwork for the pour, 28 initiates the Prepour Form during the installation process.
That l
-s6-l
2
'O 1
foreman coordinates a schedule with other crafts and inspectors for 2
installing embedded items such as electrical cable conduit and 3
piping.
After the responsible crafts finish their required work in 4
the pour, a runner handcarries the Prepour Form M-2A to each 5
craft to sign to signify that work is complete.
The runner then 6
carries the Prepour Form M-2A to each inspection discipline who 7
inspects the items as required by QA Procedure M-2 and signs the 8
Prepour Form M-2A when complete.
If a QA Inspector finds that 9
work is not in accordance with the drawings or specifications, then 10 the pour is put "on hold" until the work is corrected or evaluated.
i 11 Q.
'ARE REQUIREMENTS ON THE PREPOUR FORM M-2A WAIVED? IF 12 SO, UNDER WHAT CIRCUMSTANCES IS THIS DONE?
4 13 A.
Yes, on occasions requirements on the Prepour Form are waived.
'O 14 ror exampie, if items noted en the Pregeur vorm cem, electricai 15 conduits or components) are not required by the design drawings, 16 the structural inspector who inspects the work enters an "NA" in 17 the appropriate area on the Prepour Form. This would occur when 18 he detennines that no work is required by the drawings for the 19 applicable craft or inspector.
4 20 As another example, should an inspector find work that is not 21 in accordance with the drawing, procedure, or specification, and is 22' not. '.dily correctable by either bringing the item into confonnance 23 or through a Variation Notice, he prepares an NCI. The resolution 24 to the problem is documented on the. NCI. Design Engineering will i
[
' 25 evaluate the problem and may accept the "as-built" condition or may 26 require corrective action.
This decision is documented in the 27 resolution to the NCI.
f i
p 1
In addition, circumstances exist under which the designated 2
technical
- support personnel can waive certain requirements, 3
assuming that the necessary procedures are followed and the 4
waivers are recorded on the Prepour Form M-2A by the designated 5
technical support individual.
The individuals who have the 6
authority to waive requirements are designated in writing by the 7
Project Management and approved by QA.
In this regard, there 8
are basically two types of waivers or evaluations that can be made 9
by technical support personnel.
The first type involves the 10 evaluation of dimensions and tolerances for clear distance to 11 concrete form surface for rebar. When some rebar is relocated from 12 specified dimensions to avoid interferences or embedments, the 13 required tolerances of rebar location may be exceeded. As allowed 14 by ACI code. and concrete specification for Catawba, variance from 15 specified dimensions and tolerances may be evaluated and accepted.
16 Designated technical support individuals are authorized to make 17 such evaluations and document them on the Prepour Form M-2A.
i.
18 A second type evaluation involves non-safety related pours.
19 In this area technical support personnel can evaluate discrepancies j
20 identified and handle them as they deem necessary.
QA has no l
21 official or procedural authorization to evaluate the discrepancies 22 identified in non-safety related pours.
23 Q.
HAVE YOU TAKEN ACTION TO TRY TO DETERMINE WHICH POUR 24 MR.
MCAFEE MAY HAVE BEEN REFERRING TO IN HIS 25 ALLEGATION?
26 A.
Yes.
To attempt to determine which pour Mr. McAfee was referring 27 to, we reviewed all the pours which took place while Mr. McAfee 28 was a prepour runner (January.1,1978 to March 30, 1978).
We
.38-
I reviewed all pours whether they were safety related or non-safety
'0 2
related.
This review included approximately 255 Construction 3
Concrete Pour Numbers which are composed of 344 Prepour Form 4
M-2As.
Several Prepour Forms may be assigned the same 5
construction concrete pour number when they are poured 6
consecutively with the same concrete mix and at the same pour 7
location. As a result of our review, we determined that all of these 8
pours were in compliance with procedures and all waivers were 9
properly granted.
In this regard, there were nine waivers granted 10 during this time.
Six of the nine waivers related to non-safety 11 related pours.
The three waivers relating to safety-related pours 12 involved spacing and location of.rebar and were each properly 13 documented and processed.
(-
14 Because Mr. McAfee was unable to identify the requirements, O
15 the individuals involved, or the area of the plant, it is not possible 16 to identify precisely which pour was the subject of his allegation.
17 Nevertheless, as I stated, the records reviewed reflect that each 18 pour was made in accordance with procedures, and that no waivers 19 of requirements, where they existed, were improperly granted.
20 Q.
WHAT IS YOUR CONCLUSION THEN WITH RESPECT TO MR.
21 MCAFEE'S ALLEGATION REGARDING QA WAIVER OF 22 REQUIREMENTS ON CONCRETE FORMS?
23 A.
My conclusion is that the allegation is without foundation, and 24 presents no question as to the health and safety of the public.
i l
O l l l
l-
1 (L.R.D.)
X.
TESTIMONY REGARDING MR. MCAFEE'S O
2 ALLEGATION CONCERNING INSTRUCTIONS 3
NOT TO WRITE NCIs (li) 4 5
Q.
ARE YOU FAMILIAR WITH MR. MCAFEE'S ALLEGATION REGARDING 6
INSTRUCTIONS NOT TO WRITE NCIs?
7 A.
Yes.
I have reviewed the deposition testimony of Mr. McAfee in 8
which he alleges that he "was told not to write NCI's although as 9
an inspector I was required [to] by law, I believe." (MD Tr., p.
10 23)
Mr. McAfee can only recite one instance in which he was 11 specifically told not to write an NCI. This issue has already been 12 resolved by this Board.
13 However, Mr. McAfee does discuss situations in which he 14 alleges that his supervisor suggested that deficiencies he identified 15 should be discussed with craft foreman, to have the craft correct 16 them, rather than writing an NCI.
Mr. McAfee states that on one 17 occasion, he inspected 27 cable tray supports, and found that 7 18 appeared to require an NCI; but, he was instructed to try to 19 resolve the matter with the craft.
MD Tr., p. 26.
Mr. McAfee i
20 states that on another occasion, involving cable tray support grids, 21 he was encouraged to discuss and resolve the matter with the craft j
22 foreman, rather than to write an NCI.
MD Tr., p. 29.
- Finally, 23 Mr. McAfee references an instance in which he was encouraged to l
24 discuss cable tray hangers and supports with a craft foreman 25 rather than to write an NCI. MD Tr., pp. 29-30.
26 Q.
WOULD YOU _ EXPLAIN THE METHODS OF DOCUMENTING AND 27 CORRECTING DISCREPANCIES IN CONSTRUCTION WHICH ARE AND 28 HAVE BEEN FOLLOWED AT CATAWBA?
O 2$
^-
Ta a= titF
^===r ace Prarr== 5a
- d=riar ca==tractiaa t
30 Catawba has had several means available ' to correct' discrepan~cies,
~. -.. - +
v..
.g,
'n..n.-,
w-
I that are discovered by Inspectors. There are four basic methods Q
2 available, three of which do not involve writing an NCI.
3 (1) The first, which is sometimes referred to in some of the 4
procedures as the " hold point" method, consists of an Inspector 5
making the craft aware of a deficiency, the deficiency being 6
corrected to the satisfaction of the Inspector, and the Insp'ector 7
signing off the item.
In this method, the item is not signed off 8
until all necessary action has been completed, and the Inspector is 9
satisfied.
In the inspections of cable tray supports, hangers, and 10 grids that Mr. McAfee refers to, the work is inspected upon its 11 completion.
The Inspector then documents his inspection and, of 12 course, if he finds no deficiency he tags the support as having 13 been inspected and accepted.
14 However, should the Inspector note a discrepancy in which the O
15 necessary corrective action is clear from design drawing, and no 16 Engineering evaluation of the discrepancy is required, it is 17 standard practice for him to contact the craft to have them correct 18 that discrepancy.
Following such correction, the Inspector, if he 19 is satisfied, signs off on the work.
This " hold point". method 20 (i.e., contacting the craft, making them aware of what is wrong, so 21 they can take corrective action to fix that item, and then the 22 Inspector verifying that it is correct, and completing his inspection 23 after he has done that) is a comn:on one that has been in uce at 24 Catawba throughout construction.
25 (2) The second is the " process control" method, whereby the 26 inspection report itself provides the means to document a repair.
l 27
- This method is used primarily in welding. where, for example, a 28 final visual inspection might detect defects which would be recorded
(
1 on the inspection form.
The procedure for the inspection and for 2
making the weld would provide instructions for how to correct that 3
item (or that defect) and then provide instructions for reinspection.
4 All of this would be documented on the Process Control Form, which 5
serves both as a documentation of the work and the inspection of 6
that work.
7 (3) The third method is use of the Deficiency Report Form, 8
commonly referred to as an R-2A.
There have been several 9
different procedures available to Inspectors under this method. By 10 this method,
the Inspector would document the problem he 11 identified, and send the document to the Engineering Group for 12 construction at the site to determine necessary corrective action.
13 If such action involved the craft redoing work, it would go to the Q
14 craft to be done.
The form would then be routed back to the 15 Inspector who would reinspect the work and, if satisfied, sign off 16 on it.
17 (4) The final method that is available is the Nonconforming Item 18 Procedure, Procedure Q-1 in the Quality Assurance Program Manual 19 at Catawba.
This method provides for the Inspector to identify the 20 discrepancy, which is then reviewed by supervision and by Quality 21 Assurance.
The NCI is then sent to the appropriate party to 22 resolve the discrepancy, eA, Design Engineering, Construction 1
23 Department, or Quality Assurance.
Evaluations are reported and 24 documented.
The NCI is reviewed for reportability under 10 CFR-25 Parts 21 and 50.55(e).
Once the resolution documented, it is 26 approved by the technical person in the group that is responsible
'. O 27 for the resoiutio2 and is subject to Qi review and a,,rovai. The 28 actions to be taken as a result of the resolution would be identified 1 '
I on the report and assigned to specific groups for implementation.
O i
2 Once those actions are completed and signed off, the form would i
3 then be sent to QA who would conduct a final review to be sure 4
that all of the actions have been performed and properly verified.
5 Q.
WHICH OF THESE METHODS APPLIES TO THE INSTANCES 6
DESCRIBED BY MR. MCAFEE?
7 A.
The three instances described by Mr. McAfee fit within the first, 8
or " hold point" method.
An examination of each of these instances 9
confirms this.
In each of the three instances, Mr. McAfee states 10 that he was " discouraged to write NCI's...[and) encouraged to 11 find other means to solve the problem." MD Tr., p. 23.
12 In the instance of the 27 cable tray supports, Mr. McAfee 13 explains he spoke with the craft foreman, that the foreman agreed 14 to, and did, correct the seven discrepancies identified by Mr.
15 McAfee, that Mr. McAfee subsequently inspected these seven items, 16 and that they were corrected to his satisfaction.
MD Tr., p. 27.
17 With respect to the cable tray grids, Mr. McAfee states that he 18 identified discrepancies to the craft, the discrepancies were 19 corrected, and Mr. McAfee was satisfied.
MD Tr.,
p.
29.
A 20 similar situation existed with respect to cable tray hangers and 2
21 supports in the auxiliary building.
Mr. McAfee identified some 22 discrepancies between the work and the print, discussed these 23 discrepancies with the craft, the craft corrected them to conform i
24 with the print, which was Mr. McAfee's concern, and Mr. McAfee 25 was satisfied.
On reinspection, Mr. McAfee signed off on the 26 work. MD Tr., pp. 29-31.
Q 27 From Mr. McAfee's description, then, these incidents fit the 28
hold point" method.
1
~
43-rn,-
,,n,.v,.-----,-+---,
,r.,n
i 1
Q.
ARE THESE THE TYPE -OF INSTANCES IN WHICH THE " HOLD 0
2 POINT" METHOD IS PROPERLY USED?
AND WAS IT PROPERLY 3
USED IN THESE INSTANCES?
4 A.
Yes. As Mr. McAfee himself stated:
5 As it turned out, in some cases it was much more 6
effective as far as getting the problem resolved to go talk 7
to the craft foreman because in some instances he would 8
go correct the problems without going through the paper 9
work of the NCI.
[MD Tr., p. 24]
10 Indeed, this,is the purpose of the " hold point" method, to handle 11 situations in which an Inspector finds a discrepancy where the work i
12 has been done incorrectly and the only action required is for the 13 craft to redo the work to make it comply with the specifications or 14 the drawing.
In this situation the normal method in use is to O
15 notify the craftsman, let him make the necessary change, end 16 reinspect the work to see that it has been corrected.
Upon 4
17 completion of the corrective action, assuming that it was acceptable, 18 the work would be accepted by the Inspector.
This process has 19 been in effect since the beginning of construction at Catawba.
4 20 Q.
WOULD THE FACT THAT MR.
MCAFEE'S SUPERVISOR 21 ENCOURAGED HIM TO FOLLOW THE " HOLD POINT" -METHOD 22 INDICATE THAT MR.
MCAFEE WAS DISCOURAGED FROM 23 CORRECTING DISCREPANCIES HE IDENTIFIED?
24 A.
Absolutely not.
As I have already explained, the " hold point" 25 method is a common procedure which. has been used at Catawba 26 since 'the beginning of construction.
Mr. McAfee admits that in 27 each instance he cites he was satisfied.
Mr. McAfee alludes ' to 28 consultation with his supervisor to seek his opinion in some of these l -
p 1
instances.
MD Tr., pp. 23, 30.
There is certainly nothing O
2 improper with the supervisor giving directions in such an instance.
l 3
I would note that Mr. McAfee was a certified QC Inspector for a 4
period of only 4\\ months. It certainly would not have been unusual 5
for a supervisor to help a new or less-experienced inspector choose 6
the appropriate method of documenting and resolving a discrepancy.
7 Q.
WHAT IS YOUR CONCLUSION WITH RESPECT TO THIS 8
ALLEGATION OF MR. MCAFEE?
9 A.
It is my opinion in that procedures were followed and Mr. McAfee 10 was satisfied with the results, this allegation does not raise a 11 potential public health and safety concern.
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6/9/83 Attachment A SAMUEL WILLIS DRESSLER j
112 BENFIELD AVENUE YORK, SC 29745 TELEPHONE:
SUS. (803)831-1513 HOME (803)684-2494 I
FORMAL EDUCATION Virginia Polytechnic Institute - BSME,1963 ADDITIONAL TRAINING:
System Safety - University of Southern California Air Command and Staff College - U.S. Air Force Code Section lli Class 1 and MC Nuclear Components - ASME Advanced Management Development - Duke Power Effective Management Program - Harbridge House O
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Registered Professional Engineer - North Carolina South Carolina
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Member - American Society of Mechanical Engineers (ASME) 1
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Systems Command, Major, U.S. Air Force Reserve WORK EXPERIENCE FROM TO TITLE PROGRAM COMPANY 8/82 Present Engineering Catawba Nuclear Duke Managcr Station Power Responsible for civil, mechanical, system testing, piping support / restraints, electrical, instrumentation and welding' engineering site activities, plus surveying, facilities, computer operations, document control, and office administration functions. There are 450 engineers, technicians, and clerks in the organization performing these activities with 145 of the personnel managed through.a matrix organization structure. The primary functions Include performing technical support for all site organizations, interfacing i
with design engineering and quality assurance to satisfactory meet technical requirements.
P
= = = -
SAMUEL WILLIS DRESSLER RESUME PAGE 2 JUNE 9, 1983
( '*
WORK EXPERIENCE FROM TO TITLE PROGRAM COMPANY 5/77 8/82 Senior Construction Cataba Nuclear Duke Engineer Station Power Respons1bilities included civil, mechanical, electrical, welding, system testing, and instrumentation engineering activities, plus surveying, facilities, computer operations, and document control functions. The organ'ization was com-prised of 275 engineers, technicians, and clerks.
Functions included providing technical support for all site organizations, developing systems test logic, j
managing contractors, coordinating schedule activities, and interfacing with regulatory agencies, design engineering and quality assurance.
2/73 5/77 Field Engineer Catawba /Oconee Duke Mechanical Nuclear Stations Power I '
Responsible for mechanical technical support activities involving 45 engineers, 3
technicians, and clerks.
Developed construction procedures, resolved field pipe / equipment installation problems, performed field design, issued process i
s j,
control, and developed material control processes.
i Q
5/71 2/73 Associate Field Oconee Nuclear Duke i
Engineering-Mechanical Station Power i
Provided technical direction to craf tsmen, technicians, and inspectors for auxiliary building construction. activities. Approved process control, prepared i
construction procedures, ordered materials, and initiated field design ct.s.,3es.
Performed quality assurance functions in area of responsibility.
1/67 5/71 Air Force Officer Cape Kennedy United States Florida Air Force Staff Development Engineer for Titan III missle launch operations. Performed as test conductor for prelaunch combined system testing and leader of post launch test data review teams. Responsibilities also included writing and reviewing test procedures for assembly, check out, and launch operations.
l 9/63 1/67 supervisor-car Mechanical southern Rail-inspection Depa rtment way System Af ter completing 12 month training program, initial responsibill'tles included Inspection, scheduling,'meterial take offs, and development of repair techniques for several production programs involving extensive modification of rail cars.
Later, assigned responsibility for company-wide direction of inspection main-tenance and modification of all rail automoblie rock carriers.
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ATTAODENT B RESUME LARRY R. DAVISON EDUCATION:
Graduate of Georgia Institute of Technology (Georgia Tech)
Bachelor of Science in Mechanical Engineering,1967 Completion of U. S. Naval Nuclear Training Schools Six months, nuclear theory Six months, nuclear application (prototype)
Completion of U. S. Naval Submarine School Six months, submarine systems and operations Welding, Theory and Application, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, University of Tennessee Radiographic Film Interpretation, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, Magnaflux Corporation Duke Power Company Management Training j
Lake Hickory Training Center Effective Management i
Registered Professional Engineer in North Carolina (8856) and South O
c rotia- (74se)
EXPERIENCE:
G U. S. Navy 1967-1971, Ensign - Lieutenant 1
years schooling on nuclear systems and operation and submarines 24 years assigned.to an operating Ballistic Missile Nuclear Submarine, USS Nathaniel Greene.
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Served as Aurnkry Division Officer, Damage Control Assistant and Communications Officer..
ih Qualified in Engineering Plant as Engineering Officer of the Watch (EOOW) l One year in the shipyard undergoing major overhaul, conversion and nuclear refueling.
Duke Power Company,1971 - Present 1971 - 1973 Assistant Field Engineer, Oconee Nuclear Station
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Worked in the Construction Department Technical Support l
welding area.
Writing welding construction procedures and reviewing and solving welding problems.
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1973 - 1974 Associate Field Engineer, Oconee Nuclear Station Worked in the Construction Department Technical Support welding area.
Responsible for welding visual and nondestructive testing (NDE).
1974 - 1981 Senior Quality Control (QC) Engineer, Catawba Nuclear Station i
i Worked in the Construction Department QA area.
Responsible for all QA inspection in construction work at Catawba.
1981 - 1982 Quality Assurance (QA) Manager Projects, Charlotte General Office Responsible for all QA activities at three nuclear sites under.
construction, McGuire, Catawba, and Cherokee.
1982 - Present Project Quality Assurance (QA) Manager, Catawba Nuclear Station Responsible for all QA activities at Catawba Nuclear construction site.
Includes inspection, documentation review and filing, review and approval of construction procedures and deficiency reports.
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Attachment C RICHARD S ALEXANDER (D
G PERSONAL: Home Address:
114 Forest Drive Belmont, NC 28012 Telephone:
704-825-9419 (Home) 803-831-1512 (work)
FORMAL EDUCATION:
Clemson University - BA 1966 ADDITIONAL
' TRAINING:
Effective Management - Duke Power Company Advanced Management - Duke Power Company Various ASPA Seminars WORK EXPERIENCE:
FROM TO, TITLE COMPANY 11/78 Present Personnel Manager Duke Power Company Manage the human resource function at the Catawba Nuclear Construction site to provide effective employment, employee relations, training, safety, security, and payroll activities for a peak workforce of 4,200 employees. Administer all salary programs, including exempt, for the site. Provide expertise to project management in all aspects of human resource management, such as policies and procedures, organizational structure and increases / decreases in workforce.
5/76 10/78 Personnel / Safety Duke Power Company Supervisor Supervised the personnel and safety activities of a construction maintenance group which numbered 800 at peak. Handled all phases of personnel area including.
hiring, testing, training, and safety. Provided guidance for management in policies, procedures, and OSHA regulations to ensure all requirements were met, j
7/70 5/76 Safety Supervisor Duke Power Company Developed, implemented, and coordinated all safety, fire protection, and first-aid programs for the construction site at the Belews Creek plant. Supervised three safety assistants and one RN.
Conducted daily inspections.of the Jobsite to minimize hazards and maintain compliance with OSHA standards.
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RICHARD S ALEXANDER PAGE 2 O
WORK EXPERIENCE:
(continued)
FROM TO TITLE COMPANY O
6/66 6/70 Program Representative State of South Carolina Developed programs through local health departments and private physicians to encourage early 'hildhood immunization. Scheduled and conducted mass immuni-c zation clinics throughout South Carolina.
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ATTACHMENT D
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April 25, 1977 Ue-expect our employ es to express any concerns they may have about 'the quality of work to their supervisor or any level of Company manage.mont.
In addition, we have voluntarily agreed to post the folicwing Nuclear Regulatory Commission cocraunicatlon.
R L Dick
~
Vice Pres.ident Construction Rt.D:eJw Any nuclear industry worker who has concerns or questions about the nuclear
- O cafety of any fac!!!ty or activity IIcensed by the Nuclear Regulatory s
='
r n = v 6 cine ts tt r t
is att ntran r n "ac in a ctar r
~
the nearest NRC Regional Of fice if they cannot be resolved directly with his or her empicyer. The NRC'wlll treat the identity of a workers as a confidential source,if the worker requests that his identity,not be disclosed.
In order to improve channels of communication between NRC and Nuclear ' Industry workers, the NRC is making two proct.' ural changes:
- 1.
HRC inspectors will soon be wearing identifiction bedoes and. In some cases, safety hats identifying them as NRC insoectors.
2.
HRC Regional Offices will ac'ent collect teleo' hone calls from c
nuclear industry workers who wisn to sotak witn an NAC recre-sentative concerning cuality of wo.-k, radiolonical safety or safeguards preolems.
The teleonone numoer of tne soorcoriate NRC Regional Office for this croject is 404-221-*503.
~
These changes will be reflected in a revised NRC Form 3 posted to meet i
requirements of 10 CFR Part 19 and a revis. ion of proposed 10 CFR Part 21 (both of which are in preparation).
Until these revisions are published, all workers at NRC-licensed facilities or activities should be aware of 1
these improved channels of co..sunication with inspectors.
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ATTAOMNT E UNITED STATESNUCLEAR REGULATORY COMMISSION STANDARDS FOR PROTECTION AGAINST RADI ATION IPART 20); NOTICES. lNSTIUCTIONS ANO rig'*
Washin'gton. D.C. 20555 The Nuclear Ragulatory Commensaan (NRC) in its Rules and Reguistions: Part 20 lias esiahhshed standards REPORTS TO WORKERS; INSPECTIONS (PA*.T C); EMPLGYEE PROTECTION ih for your protection against radiation huwds troen radeoactive material under license eesued Spy some NRC; T
Tl T
- 7. @
M P"PT I *
,d W W
d Part 19 has estabhshed certaun provisions for the options of workers engaged in NRC heensed acssestaes;
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Parts 30,40. 50, and other pwts contaaruns prowtuons relased to employee protecteoa.
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. POSTING REOulREMENTS Copas of this potsce must lie posted ist a sufficient naamber of places in y **ee*/
every establishment where actsvities licensed by the NRC are rad arn=d to persuist eneptevees to sheerve a
_'-.m_
' copy on the way to or from their piace of employment..__,._
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IR EMPLCYER*S WHAT IS COVERED BY report i8 you eceve en esposde leas enved shwoundw.or me ierms and shaa whee escamnauon has SABOTAGE OF NUCLEAR PONSISILITY THESE NRC REGULATIONS
- eacus of any appleca4 howt as of me empMyw's hcene adh regard occurred assue an order provunng FACILITIES OR FUEL asi sorm en ere reguiasons or m the no radiologecalworkano conee.ona m eshel to the employee d reiset as not De amended Amnuc Energy Act. m empsoyw as sequered to -
- 4. Lunate on eaposwa no ra&ateon
. sicense. T ne oas.c hmus for es-meagh me worker is enoaeed.may provided by other means of seteement.
$",*,' n*N,'*" "* ** '"."
- ppropriate Unded States Nuclea,*"$'"$"gw'*"$*onN'e PROTECTION OF
'ny "
'sensenser
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Nw'ic
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a in urue d areas; m ce INSPECTORS and wiusuey destroys or causee 2 asuswessobesamenasserac-20.104 of the Part 20 regulanons Imymcaldamage.m anempu mde to.
No*,"o'nw.,se*,u* a.,"iawe e---
-- Regenal Of-The amended Alomac Energy Act.
cad *ata8 p
uws-ne=ro**'*;
These se ca.ons specuy mda on
.Regu.latory
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wn-m.p oewi.nere est n m. o.dese,ien.n.
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.on a,,d es.
o ou, c, me,m re,ula.
80s tec% hcset unda N E and equipsnent; posus e to a;cacentrataons of snust set forth the specalac grounds for penalues a(aanst any in&vidualwho
- s. Isce S. and opentang
--ynuagua ; enma
.. c.u ons as.
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,ad we,,a,e, ai,.
me not.co. and st.e s.,n.d.,,,,e h.,s.,os, a au,,s.,esis,s. op.
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'*omm m8w'och equ'9"*a'-
2 u you =oru =nere persoaael warker or the eopaesentaieve of the poses. impedes. enuniideaea or ari-
.ou p eng,ged and u pia
- 5. Esposwe records and roports,.
mondoring es requeed pusuans workms. Dwine anspuhans. HAC torfwes wah any puson who performe
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- s. Opueser orkerereend*0 to swuon 20 2o2; enspeciars may consa prammy wah any inspecuans which tu we remed as s n Hoa.cs of v.ataan avoewme o
NaC vispunes.
saa youmpioya snost give you a e,o, mms, and may warsw may bree io any acuvay or sacmay scenud by me aecios.cas.ormaae coa *noas.
L 68"""** ~8'***8 8'**"* 8,,
=rlitea report 08 your eadiahon ene anonuon as meinspecio,e any past commisman. and (2s ere cwried out so isoposed unposa.on as c=4
- d""p*'"*'"*'*"8*8".
aposu'n uponir= swnuna-or pmsent conduen which he tmumes uusiy requWoments under me Alomac
' enmanand crows.
is 0*
- neon of your empaoyenent si contributed to or caused any v6osassori Ener0y Act orlander any other Fedwal tefrasa front escramenMory aCis unpaoyas-hoeasaeaamea,
you seq ni u. and a duc,ined move.
se. covenab me us.iy ne uc.ns.d
- ,ga,n, e,,,,io,en.ho p,ow,de
- neo,,naanio,,nc.
protected stuvads; in) your empeorw musiadvise EMPLOYEE PROTECTION ma,e,iaa. n'"e ga auc,,u.d ano,'e
- *dd *D*d**'*'
V O. idenussea me Depanment of Labor you annuany yow uposure IXESPONSISI u a source os reuer an the evens os sondinon.m you requeu se.
m an empsoyee menen man macrun.
me c,iming no, on,y a asen ga,nu
.LWOIKE2 macaminalen. and
'"*'** "" ***""ed due m enosoine anspecuan pusonnes.ho we weaeed INSPECTlONS 80 8*'at*d **"**-
enthe" pros ctedacumun uus in me p,m,% g,,cn u pg,,
,no,ie s
,ae,,, sed.,m
. spremasonsof oneNRCrseusa-REPORTS ON YOUR As acan,ases under me acense are sub-empaoy.smay.warun30dayaosshe dunes. but Ws.s u uken acaenu enspec.
.and me oportung orocedwee RADIATION EXPOSURE 8*"'"****'*""'""****""*"'
"""*'* t. 8a a como'*'a8 *an man pueenne on acountas euen
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. s appey to me worm you ne on-HISTORY r*p'***"t*"'*08"orks.ho
$sasidards Admin'airasson.wa0e and
< d en. You snovad ooserve nheir esons for your own protoceson and 1.
The NAC regusanons reeuwe snas beheves that there is 8 veotanon of the Hour Densen. he Depwunent of ecuan of your co workers.
Four etap8oy*r Olve you a written Alonuc Ener0 y Act of 1954. she reguta-Labor shat conduce en invesugataan UNITED STATES NUCLEAR REGULATORY COMMISSION REGIONAL OFFICE LOCATIONS A representatsve of the Nuclear Regutatory Comerusse~en can be contacted at the tonow ng addresses and teaephone numbers. The Regennal Of f ace w 88 accept co4 lect se.ephone calls fresa empseyees who weeh to soapsier<ompiamts or concerns acout s *i ranweeken, conditens or other snatiers seenreng untei Cossumasson rules peut reestas.ons.
l Regional Offices i
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-h REGIO 84 ADontss TELEpteoneE
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's u s esus e seemassary comma n.n
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I asCO n e ae 216 337-6000 so De4 "ad[es*r n**.*a
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ATTACHLfENT F O
Thi's federal statute, Section 210 of the Energy
- Reorganization Act (42 U.S.C.55851) (1978), provides that no employer (including an NRC licensee, an applicant for an NRC license, or a contractor or subcontractor thereof) may discharge any employee or otherwise discriminate against an employee because of the employee's participation on behalf of any party in an NRC proceeding.
More specifically, no employer may take any action against an employee because the employee (1) has commenced, caused to be commenced, or is about to commence a proceeding under the Atomic Energy Act of 1954 Q.e,., an NRC proceeding);
O (2) e stifi or i= ado =e to
- eifr i= a===c proceeding; or assists or participates in any way in an NRC proceeding.'
(3)
Any employee who believes that he has been discharged or otherwise discriminated against by his employer for one of the reasons listed above may file a complaint with the U. S. Department of Labor within 30 days of the occurrence of
...beievent.
The. Labor Department
$11cthen investigate..
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' the charges and, if it determines,
,ftthistypeofunlawful$g 3
discrimination has occurred, will order the employer to stop the unlawful discrimination and reinstate the employee to hir former position along with hack, pay, terms, conditions and privileges of employment.
Compensatory' damages and expenses related to bringing the complaint may also be awarded to the i:
employee.
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LJO 4265851 FUBUC HEALTH AND WE!EARE 206 I ass 1. a m,ser m pecesess.
esi Dessreminenise asalms aspieree No employer, Imeludlag a Commission Esassee, as applienst for a Commissies Esense, er a oestra.:ter er a enheestasstar of a t'aa-r-zan lleensee er applienet, may -
discharge any employeeir otherwise discriminate agslart any employee with nopect to his esmpensaties, terms, eseditions, er privileges of employment beennes the employee (or say pereen actlag persuant to a request of the employee)-
(1) esamenced,==naar' to be --- -- '. er is shoot to esamesse er easse to he commenced a presseding seder this aba er the Atomie Act of i
1954, as amended [42 U.S.C.A. $ 3D11 et seg. er a pr==marfNg for the ties or enferoomsat of any reguirement ander this chapter er the Atomic Energy Act of 1954, as amended; Q) testified er is aheat to testify is any seek pressedtag art
-?,
)
Q) assisted e?partialpated or is sheet le assist er partiapate la any maamerla pg auch a,.- :"*== or la any other manner la such a presseding er la any other j
to se this er the Ateaue Energy Act of g
.I c t.t.
d t
- 0) Any empleree who he!! aves that he has been discharged er ederwise diserimi.
i mated assinst by~asy parasa la vietation of subseedes (a) of this aseties mar, withis thirty days after such violaties esaurs, ids (or have say porosa fDe sa his behalf) a ese lafat with the seestary of Labor (herelaatter la tids subesetles referred to as the aHeging snah discharge er diner 8=i=adaa Upse reesipt et sash a eemplaint, Secretary shad setify the pensa named la the eseptalat et the iBing of the.eemptalat and the Commission.
Q)(A) Upsa' receipt of a sempialat fDed seder paragraph (1), the shan O
senduct sa tavestigaties of the vietaties aDeged la the semplalat. With!a days of the reeefpt of such esmplaint, the Secretary shen semplete such and shall notify is writing the essplafat (and any perses acting la his behalf) and the person a!!eged te have sommitted such vietation of the results of the is-d-as8==
1, esadseted pursuant to this su Withis sleety' days of the resolpt alsush
.T.
esmplaint the Secretary shall, salens preeneding en the semplaint is terminated 4
by the Secretary on the basis of a esttlenest entered late by the and the persen ausged te have seemitted such violatism,imus sa enter either the
-t relief presenbod by subparagraph (3) er denying the semplaist As order the 4
Secretary sha!! be made en the record after acties and ty for public hearing.
3 The Secretary may set enter late a settlement ting a pressedlag en a J,.
esoplaint witheet the participaties and esament of the - 7 Yp (B) If, la to a seaplafat fDed seder paragraph (1), the Secretary ester.
mines that a tisa of subsecties (s) et this section has esserred, the Saaretary
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shad'erder tbs a who sentaitted seek violatism te (T) take affinsative mass =m to e;
abate the viels and ( relastate the sempiatamat to his former together with the esapeanaties uding back pay), terms, esaditless, and of his M.
employeest, and the tary may seder sash person to esapeamstery 5'.I damages"te. the sempialamat.' If an. order is bound this perngraph, es TJ Secretary, at the resoset of the1_ _ / r*"to the aggngste amount of as seses andshaR asses 8
whom the order is lassed a saa egea
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==f===== Qaeledfag atterseys' and espart witnese fees) --__"---: far, er la osaner'dsa with, ese,
"- hisurred, as
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'-- _ by the Secretary, by the
,bringlag of the essplalat spes whisk the ieder.wme bassi
. 44 Boview
- 0) Any person adversely affected er noveleved by en order bened seder embeesdes (b) of this secties may obtain review Ethe order la se Unned States esert of for the airenit is whlek the violation, with respeet to whiek the ender was y seenriod. The petitles far review mest he fDed withis sisty espe bem the of the 3eerstarg'p order. Review shaR esafenn to shapter f of
. Title A. Thasommeness set of ysseedlage seder this sehparagraph shaB aet,emians ordend by thsesert, opers.te a+ a stay of the Sesetary's esder.
i O') As orier of the Se'cretary with respect to whleh review esul(h basa j
t other ev0 pnosedlag.yk (1) shaR est be sumject to jedleint seview l obtalse*. sneer parage rialanter
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- 'rusuC BEALTH AND WELFARE 4265851 liste 3 40 Jertedleesse Whenever a pereen has faded to sempty with as order immed ander sakenedes (bX2) of this meetion, the Secretary may file a eivD action is the United States dietnet eeurt for the district la which the vaistion wee found to escur to enfores such order.
In setless brought under this esbescties, the district enorts shall have jartsdseties to great a!! appropriate relief incleding, het set Emited to, hijaastive relief esmpense-tery, and esemplary damagen, es) '*------* et entsen (1) Any a es whose behalf an order wee Issued under paragraph (I) of asbeertlos ) at thle section may esamenee a civG acties agalast the person to whom such order was leeued to require semplisses with such order. The appropriate United States district esort shall have jen'edicta'ea, witneet regard to the aseest is sentro-veer er the =8+f==My of the parties, to enfores such enlar.
O) The esort, is fascing any floal order ender this h may award esets of Ntigation (laclading seasonable. attersey and espart vitasse fase) to any party whenever the esort determians such award is appropriate.
(f) Eminessent sendisere duty imposed by thle seetles sha5 be enteresshie is a i
me pressedag gat mader secties 1M1 of Title B.
(s0 Desheroes etsimalene Subseetles (a) et thle section chan set ty with respect to say esoployee who, acting without direction from his or her em yer (or the employer's agost deliber-atefy amanes a vietation of any requirement thne chaptar er of the A Ehergy Act of 1964, as amended (42 UMA. t 211 at seg).
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14 15 Richard. S Alexander 16 17 Sworn to apd subscribed before me 18 this 14" day of September,1983 19 20 21 D YA ^ tw no 24 Notary Public 25 26 Commission Expires Af,2 h, f 7hI I
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