ML20092P768
| ML20092P768 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/27/1984 |
| From: | Garde B TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Belter L BISHOP, COOK, PURCELL & REYNOLDS |
| References | |
| OL-2, NUDOCS 8407090354 | |
| Download: ML20092P768 (61) | |
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TRIAL LA\WERS FOR PUBUC JUSTICE. P.C. __,
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COUNSELLORS Af t.AW SulTE 611 2000 PSTREIT NORTHWIST , , , ,
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WASHINGTON. D.C. 20036' i '
no23 =3+mo i June 27, 1984 Leonard W. Belter, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W. g [,m p 'c -
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Dear Mr. Belter:
The attached information is provided in accordance with the agreements between the parties and the Board regarding the production of a final witness list and the identification of the incidents, examples, or results of harassment and intimidation known to identified witnesses.1 There are, as you know, outstanding document reque=ts which require resolution from your office. We have requested that you provide us with all the information in your possession relevant to the issue of harassment and intimidation. This was articu-lated in our discovery requests numbers 17 and 18, and further clarified in our April 7, June 4 and June 20, 1984 letters. You have represented that you have provided to us all information that could reasonably be responsive to the requests we have made.
That includes all documents regarding any incidents, examples, complaints, etc. as described in the clarification of Question 3 (attached) from TUGCO, Brown and Root, Inc. or any of its con-t r a c to r s . (It should be noted that we have not received any information from any of the other subcontractors at all, a fact we find curious since at least some of the potential witnesses worked for subcontractors other than TUGCO or Brown and Root at the Comanche Peak site.) At the June 25, 1984 meeting at your office you represented that all the information that now exists regarding these matters has been provided, although apparently there was or may have been other documents which would have been responsive to our request, that no longer exist. Based on this representation, which we want in writing, we will consider any f '
This agreement was first articulated in the June 14, 1984 pre-hearing conference, and has been discussed in detail among the parties subsequent to that time.
-o 8407090354 840627 PDR ADOCK 05000445 Q PDR
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documentation provided or introduced beyond this time period which is within the scope of our Question 3 as " surprise" and '
therefore a basis for delay.2 As you know the information and witness list attached to this letter does not in any way reflect the information which was made available to CASE at the Dallas QA office last week. That 1 information, approximately two feet thick, appears to have signi-ficant additional information regarding incidents of harassment reported internally as well as the results of a 1979 question-naire of the entire QA/QC department. Counsel for CASE has not yet been able to determinc whether or not the information ]
4 recently provided will require additional witnesses, discovery clarification, or any further responses. We intend to review the material as soor. as it is received from your client. It is our understanding from you that there are no further documents relevant to the 1979 questionnaire which your client or contractors can find and thus there is no documented response to the reported incidents of harassment and intimidation.
Finally, we expect that you will provide us with a summary, such as is provided here, as to what you are planning to question CASE witnesses on, as well as the names and a summary of the testimony of your affirmative witnesses not later than twelve days prior to the beginning of the depositions of each of these groups of witnesses. (This coincides with the number of days
" lead time" that you are being provided with by CASE assuming that depositions begin on July 9,1984.)
A problem still pending is the production of information which is now the basis of pending investigations by the office of Investigations (OI). As you are well aware the problem of the release of information provided to oI which is relevant to issues under litigation in other proceedings is currently facing at least three CASE witnesses in the context of their Department of Labor proceedings.3 A similar problem feces the parties in this proceeding. Although this was discussed during the pre-hearing conference, and it was addressed in briefs by the parties regarding the use of confidential information, the problem remains unresolved. We have identified those items whic.h are
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2 At this point every available hour of both of CASE's counsel's time is occupied with preparation for the depositions.
Any additional information produced will necessitate a delay to incorporate that information into our case, includ.ing possible -
call of witnesses at the hearings.
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Those cases are Hatley v. Brown & Root, 84 ERA-23; Orr v.
Brown & Root, 84-ERA-23; and Neumeyer v. Prown_& Root, 84-ERA-26.
d relevant to this proceeding, are admittedly subject to your discovery request, yet are apparently the basis of OI .investiga-tions. The OI policy to date hps been that information derived or obtained during the pendency of an investigation should not be l provided to the parties until af ter completion of its investiga-t tions. We understand that this applies to identified documents, as well as to testimony, which reveals the substance of the.
documentation. CASE wishes to use this information. Rather than release it without regard to OI's desires CASE prefers that the resolution of this matter include the Board. Thus on June 28th we will request the Board to immediately invite OI on the record to state its concerns, to allow the parties to express their views and to resolve the issue.
We have completed our contacts with all of those persons who GAP or CASE have contacted or had contact with in the past and have included in the list below those individuals who have information relevant to this issue and have indicated a willingness to testify through the evidentiary deposition process. Where there are restraints, or Counsel has been unable to get in contact with the individual, or there is some other
, problem, that is so indicated on our witness list.
4 We have not provided the information or included on the witness list those individuals who we have identified as craf t or whose testimony does not substantially bear on the implementation of the QA/QC program.
A very small number of witnesses have indicated they would ,
testify under the terms of a protective order and an affidavit of non-disclosure. We have modified slightly the documents used in the Byron / Catawba proceeding and submit herewith a draf t for your comments. As soon as an agreement can be reached on this matter we will provide the names /information relevant to those witnesses.
We note that in a few cases we have what appear to be unresolvable problems with witnesses. Those are explained on the witness list. CASE will continue to attempt to persuade those individuals to testify at least "in camera". Should we fail we will bring the matter to the Board for resolution. In all other a
cases where a witness refused to testify we have either foregone the information, or believe that the information is independently verifiable.
Sincerely,
- b h.
Billie P. Garde '
cc: Honorable Peter Bloch Stuart Treby '
Renea Hicks l
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The wording of Question 3 is clarified as follows.:
3.. Supply for inspection and copying .any and all documents between management (including supervisors, foremen, middle management, upper management, etc.) and employees regarding the following:
(a) Any and all management / employee disputes, complaints, differences, and/or discussions pertaining to:
(1) policy disputes, complaints, differences, and/or problems regarding enforcement, application, or interpretation of procedures, instructions, or regulations relating to the job or work of the employee or of employees under his/her supervision (including, but not limited to, overinspecting, " nitpicking,"
e tc.) ;
(2) intimidation, harassment, threats, pressure to meet production, or other kinds of pressure; (3) management directives (written or verbal) regarding the reporting of nonconforming conditions);
(4) and the like.
(b) Any and all letters of resignation by employees and responses by manageme t in which such employees indicate concern or dissatisfaction with:
(1) the enforcement, application, or interpretation of procedures, instructions, or regulations relating to the job or work of the employee or of employees under his/her supervision (including, but not limited to, overinspecting , " nitpicking", etc.) ;
(2) intimidation, harassment, threats, pressure to meet production, or other kinds of pressure; (3) management directives (written or verbal) regarding the reporting of nonconforming conditions; (4) and the like.
( c) Counseling reports, termination reports, and exit interviews regarding (a) and (b) preceding.
(d) Any and all procedures, instructions, regulations, and/or management directives (including those s'upplied by ~
employees) involved in (a) (1) , (a) (3) , (b) (1) , ,and (b) (3) ,
preceding.
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I (e) Internal investigations conducted by management into such discu,ssions, disputes, complaints, concerns differences, or dissatisf problems, action, including those by the " ombudsman."
(f) An'y and-all internal files Applicants or their employees have on employees contacted by the NRC.
For purposes of your answer, the following definitions shall apply: .
The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, slides, internal memoranda, handwritten notes, tape recordings, calculations, and any other data compilations from which information can be obtained. (see item 8, page 2, of CASE's 3/14/84 Eighteenth Set) ,
The term " employees" shall be construed in the broad sense of the word and shall include Quality Control Inspectors, craf tspeople, engineers, and any other employees employed by Brown and Root, Gibbs & Hill, Ebasco, any consultants, sub- '
contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.
(See item 2, page 1, of CASE's 3/14/84 Eighteenth Set)
The terms " procedures" and " instructions" shall be construed to include, but not be limited to: the written or verbal procedures or instructions under which the employees work; the written or verbal methods of reporting of nonconforming conditions by means of nonconformance reports (NCRs),
inspection reports (irs) , component modification cards (CMCs) , design change authorizations (DCAs), nondestructive examination reports (NDERs) , field deficiency reports (FDRs), and/or any other method used for reporting nonconforming; conditions.
The term " regulations" shall be construed to include, but not be limited to: the Code of Federal Regulations (CFR) ,
especially 10 CFR; Applicant's Final Safety Analysis Report
( FS AR) ; industry codes and practices; industry standards; etc.
CASE's Motion To Compel Applicants To Provide Complete Answers To CASE's Seventeenth, Eighteenth, Nineteenth, -
And Twentieth sets of Interrogatories -
And Requests To Produce To Applicants
( April 16,1984)
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
TEXAS UTILITIES ELECTRIC ) ,
COMPANY, et al. ) Docket Nos. 50-445-2
) and 50-446-2 (Comanche peak Steam Electric )
Station, Units 1 and 2) )
PROTECTIVE ORDER counsel and representatives of the parties to this r
meeeding who have executed an Affidavit of Non-Disclosure in the form attached shall be permitted to " protected information"1/
upon the following conditions:
- 1. ,Only counsel and and one technical representative of the parties who have executed an Af fidavit of Non-Disclosure may have access to protected information.2/ All executed Affidavits of Non-Disclosure or copies shall be provided to the Appeal Board and the parties.
- 2. Counsel and representatives who receive any protected information (including any documents that contain or otherwise reveal protected information) shall maintain its confidentiality 1/ As used in this order, " protected information" has the same meaning as used in the Affidavit of Non-Disclosure, attached hereto. The provisions of this Protective Order do not apply to Nuclear Regulatory Commission employees; they are subject to internal requirements (see NRC Manual Appendix 2101) concerning the treatment of protected information.
2/ That representative will identify those technical issues, if ~!
any, which require resolutioq. and the name of such representative i shall be submitted prior to any disclosures to allow for objec-tions, if any. .
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as required by the attached Af fidavit of Non-Disclosure, the )
terms of which are hereby incorporated Lnto this protective order. /
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- 3. counsel and representatives who receive any protected information shall use it solely for the purpose of participation in matters directly pertaining to this proceeding and any further proceedings in this case and for no other purposes. Nothing in this protective order, however, shall preclude any party from moving the Appeal Board for the release of particular information for approrriate purposes, such as for use before another adjudicatory body.
- 4. Counsel and representatives shall keep a record of all documents containing protected infermation in their possession and shall account for and deliver tnat information to counsel for the staff in this proceeding in accordance with the Affidavit of Non-Disclosure that each has executed.
- 5. In addition to the requirements specified in the Affidavit of Non-Disclosure, all papers filed in this proceeding that contain any protected information shall be segregated and:
(a) served only on the counsel or other-representatives of each of the parties who have executed an Affidavit of Non-Disclosure; (b) served in a heavy opaque inner envelope bearing the name of the addressee and statement " PRIVATE. TO BE OPENED BY ADDRESSEE ONLY". ' Addressees shall.take all necessary l precautions to ensure that they alone will open envelopes so marked. ,
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- 6. counsel, representatives, or any other individual who -
has reason to suspect that documents containing protected informatio'n may have been lost or misplaced ~ (for example, because an expected paper has not been received), or that protected information has otherwise become available to unauthorized persons, shall notify this Board promp.tly of those suspicions and the reasons for them.
PETER BLOCH e
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1 AFFIDAVIT OF NON-DISCLOSURE ,
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, being duly sworn, state:
- 1. As used in this Affidavit of Non-Disclosure,
( a )'" protected information" is (1) information revealed in connection with in camera hearings in the Comanche Peak operating license proceeding, including particularly the names of and identifying facts about in camera witnesses, and any other
- related information, particularly documents, specifically designated by the Licensing Board; or (2) any informatiot obtained by virtue of these proceeldngs which is not otherwise a i
- matter of public record and which deals with the in camera hearings.
(b) An " authorized person" is a person who, at the invitation of the Atomic Safety and Licensing Board (" Licensing Board"), has executed a copy of this Affidavit. .
- 2. I shall not disclose protected information to anyone except an authorized person, unless that information has previously been disclosed in the public record of this proceeding. I will safeguard protected information in written form (including any portions of transcripts of in ecmera hearings, filed testimony or any other documents that contain such information), so that i t remains at all times under the control of an authorized person and is not disclosed to anyone else. -
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- 3. I will not reproduce any protected information by any means without the Licensing Board's express approval or _
direction.,, so long as I possess, protected information, I shall continue to take these precautions until further order of the
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Licensing Board. I
- 4. I shall similarly safeguard and hold in confidence any data, notes, or copies of protected information and all other papers which contain any protected information by means of the following:
(a) My use of the protected information will be made at a place of business.
(b) I will keep and safeguard all such material in a locked f acility. ,
( c) Any secretarial work performed at my request or under my supervision will be performed at the above location by one secretary of my designation who will also execute an affidavit of non-disclosure.
(d) All mailings by me involving protected information shall be made by me directly to the United States Postal Service or by personal delivery.
S. If I prepare papers containing protected information in order to participate in further proceedings in this case, I will assure that any secretary or other individual who must receive protected information in order to help me prepare those papers has executed an affidavit like this one and has agreed to abide' by its terms. Copies of any such affidavit will be filed with and accepted by the Licensing Board before I reveal any protected information to any such person.
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- 6. I shall use protected information only for the purpose -
of preparation, including any 1,nvestigations which may be necessary, for this proceeding or any furth~er proceedings in this case dealing'with quality assurance and quality control issues, and for no other purpose.
- 7. I will avoid disclosure of protected information to the best of my ability. However, it must be recognized that in the course of conducting investigations in connection with this proceeding, certain protected information may be independently, discerned incident to that investigation which might result in the inadvertent disclosure of protected information.
- 8. I shall keep a record of all protected information in my possession, including any copies of that information made by or for me. At the conclusion of this proceeding, I shall account to the Licensing Board or to a commission employee designated by ,
that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this' proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board), together with all notes and data which contain protected information for safekeeping until further order 1
of the Board.
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Subscribed and sworn to before me
- this ,ay d of , 1984.
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Notary Public 1
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WITNESS LIST 18
- The parties are attempting to reach agreements on the facts involved in the harass-ment and intimidation testimony of these witnesses, and/or to reach stipulations or admissions on the same. Where possible the previous (or future) testimony of a witness will be agreed upon as a joint narrative by the parties as being the testimony for the .
, purposes of this hearing. CASE anticipates that these matters will be resolved shortly.
This effort will, hopefully, eliminate duplication or repetitive testimony of major wit-nesses surrounding events / incidents relating to identified deponents.
+ Information pertaining to the substantive allegations (i.e., hardware issues or wrongdoing issues) have been turned over to OI.
++ Detailed' information has been provided in confidence to GAP investigators and cannot be released without permission of the witness.
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APPLICANT
. WITNESS INCIDENT WITNESS NRC WITNESS.
Hcnry Stiner*- He will testify about the harassment and intimi- Larry Thompson Brooks Griffin j dation incident listed on page 28 of the OI Fred Coleva R. Taylor Report, and listed in his September 15, 1983 Doug Frankum statement to the NRC, incorporated as Callicut rf Attachment 7 to the OI Report (supra). Althoug h Liffert craft Mr. Stiner's harassment has been included Ronnie Johnson in this hearing by the Board.
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APPLICANT WITNESS NP.C WITNESS
- WITNESS INCIDENT Daricne Stiner* She will testify regarding the meetings with Tolson Ron Tolson Brooks Griffin regarding her pregnancy. The effect of the circuit Tom Brandt Breaker, the bus incident, failure of the guard to P.R.
protect Darlene, office moves, also those incidents employee re:
recorded in her September 15, 1983 statement to circuit Breaker OI, and those listed on page 26 of the OI Report Randy Smith and the results of the harassment and 7 =' intimidation as described in her affidavit filed in the CASE pleading 11/28/83.
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O APPLICANT
- WITNESS INCIDENT WITNESS NRC WITNESS Dillie orr Will testify that she was verbally and physically Tom Ippilito harassed and intimidated by QC craft " runners" and Brooks Griffin supervisors during her position as QC Document -
Control Clerk,'specifically she had a staple remover thrown at her and on other occasions was
. threatened with "getting fired" if she did not turn over documentation out of procedure.+
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. <i APPLICANT
- . jWITNESS INCIDENT WITNESS NRC WITNESS a
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Linda Barnes Document Cuality Control Inspector, will testify G. Purdy Tom Ippilito
'(Canfirmation of that on or about April 1984 she was prevented testimony from using proper procedures to complete document
.pending.) review, and that she was therefore in non-9 compliance with procedural requirements and that the pressure for her to continue to do document i
review in violation of procedures resulted in her having no choice but to leave the site. She will
. also testify as to her knowledge of other pressures to violate procedures in QC Document Review.
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' APPLICANT
' WITNESS INCIDENT WITNESS NRC WITNESS
- Witness A "T-shict incident", (facts to be stipulated) , John Collins (Raquires "in and the efforts of the employees to secure assistance Resident Inspe(
ctcera" presenta- from the NRC. (Unable to contact to this point. If tien.) unable to contact we will offer two witness who will
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testify as to what this witness told them regarding this incid en t.) ++
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. , WITNESS INCIDENT WITNESS NRC WITNESS Witnsas B* Will testify to the common knowledge among OC cordon Purdy Tom Ippilito
- (Hoc not yet employees in one department that refusal to go Brooks Griffin 4
tgrocd to testify along with instructions, even if a violation in c:mera, only of' procedure, will result in termination.
~ ex parte.) Will also testify as to the management attitude on the site regarding employees going to the NRC, GAP, CASE, or others with information of violations of procedures. Also would provide corroborative testimony for several other named witnesses. Finally would testify about personal actions taken, knowingly in violation of established procedures, for fear of loss of job.++
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APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS Witnoss C Has information regarding the use of harassment and Harry Williams
] (Hrve not been intimidation in the paint QC department which is not able to contact cumulative of the Dunham incident. Will testify -
ao of yet.) about a meeting on harassment and intimidation with
!, Harry Williams about being too picky.
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APPLICANT
' WITNESS INCIDENT WITNESS NRC WITNESS Witness D Will testify about the continuous attitude of Harry Williams (Only reached management to disregard the recommendations of QC l tedcy; will inspectors, also about a meeting at which Harry
.docide by Priday Williams said he would pull certification of y if will partici- inspectors who didn' t stop writing NCRs.
- - pato.)
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APPLICANT
~ MITNESS INCIDENT WITNESS NRC WITNESS
'Witnoss E Will corroborate testimony of Witness F and (Still' unable to provide further examples. .
cenfirm whether 3r not he will
[_ toc ti f y.)
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.. . n APPLICANT
' *~ WITNESS INCIDENT WITNESS NRC WITNESS
' Witness F Will testify about failure of TUGCO management and (nEre will be QC in the electrical test group / electrical start-up
.provided) _ engineering during Spring 1984, and related incidents of harassment, intimidation, pressure to withdraw complaints and questions about STE/ ETG procedures. (Affidavit to be submitted to parties upon execution of a protective order and receipt of af fidavit.)-
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l APPLICANT WITNESS NRC WITNESS WITNESS NAME INCIDENT A. Vega Brooks Griffin Loator Smith Smith will testify that he was aware of employee R. Tolson Richard Herr intimidation at Comanche Peak. Instances of employees being discouraged. f rom doing work right were revealed by Mr. Smith in an affidavit to CASE.
- Mr. Smith will testify that instead of responding in an affirmative manner TUGCO QC head, Mr. Vega, questioned his ef forts and reacted negatively, leading Mr. Smith to the belief that QC was not interested in finding out about construction errors at Comanche Peak. Mr. Smith will further testify that af ter talking with Mr. Vega he becan;e aware that his termination was imminent as a direct result of his coming forth and that QCs' attempts to encourage employees to report faulty construction '
i was actually an attempt to identify those who might blow the whistle. See Lester Smith Affidavit, 11/18/83 and 10/26/83 De po s i t ion .
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APPLICANT WITNESS NAME INCIDENT WITNESS NRC WITNESS 1
Bsb Hamilton
- His testimony will reveal instances of harassment Jim Hawkins Brooks Griffin to both himself and others in the form of threats Harry Williams stating that unless Hamilton and others stopped t,
^ inspecting so meticulously and start " loosening up" specifically on QC coatings inspectors, he would terminate them (pp. 43 & 53). Furthermore, Hamilton's testimony will report general knowledge of various instances of harassment of other QC inspectors. In addition to threats of termination
- Hamilton's supervisor told him to stop writing NCRs. Finally Hamilton's testimony will reveal that the pattern of intimidation and job emascu-
- lation culminated in his procedurally improper termination for refusing to perform an exceedingly dangerous inspection (p. 8) while other inspectors who also refused were not terminated (p. 26).
i This only slightly expands the testimony of Mr.
Hamilton beyond his previously submitted testimony. ,
[ References to 7/16/82 testimony of Robert Hamilton before the ASLB.]
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- APPLICANT
. WITNESS INCIDENT WITNESS NRC WITNESS
' Stan Miles Stan Miles will testify that he was aware of Dale Bullard Brooks Griffin instances of employee intimidation through W. Simmons Robert Taylor threats of termination by foremen and super- R. Tolson -
{!, intendents. Personal witness to Chuck
- e. Atchison's harassment and intimidation and other techniques used to undermine and demoralize the conscientious employee.
See Affidavi" 11/18/83.
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t APPLICANT
- ,* WITNESS INCIDENT WITNESS NRC WITNESS Rabbie Robinson Robinson will testify that it is common knowledge A. Vega Brooks Griffin emong all personnel at Comanche Peak that when J. George
- someone goes to TUSI or Brown & Root or the NRC Larry Wilkerson
- with allegations of deficiencies and illegal work Wayne Mansfield practices they will be given a reduction of force i f (laid off). Robinson will testify that this intimidation is so pervasive on the jobsite that l even those employees who would normally report construction problems to QC refuse to do so because
- they know that their job and their career would be
- suddenly ter* (na ted wi thou t reason. Robinson was himself terminated at Comanche Peak after nearly
< nine years (almost 5 years as General Foreman of the Structural Fab Shop) after reporting to TUSI's
. Joe George and Antonio Vega about make-work, mis-use of materials for personal use, ordering and use of rebar eaters, theft of materials, etc. ,
See Affidavit 11/18/83.
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i APPLICANT
- WITNESS INCIDENT WITNESS NRC WITNESS
- Rob 3rt Messerly Messerly will testify that he was aware of numerous A. Vega Brooks Griffin
'; specific instances of employee intimidation inclu- D. Chapman Richard Herr 2
ding QC inspectors who have been threatened by M, Sanders R.- St.ewart Supervision for slowing down production with their H. Goodson inspections (p. 3) . Messerly will testify that D. Frankum e- after making a complaint to QC head Antonio Vega and then to Dave Chapman he was fired. Specific instances of intimidation are referred to in his Affidavit dated Nov. 26, 1983 (p. 2).
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APPLICANT
- - WITNESS INCIDENT WITNESS NRC WITNESS
. Jeceph Krolak Krolak will testify that he was aware of various Mark Wells instances of intimidation and of employees being Ilarry Williams discouraged from doing work properly. Krolak Tom Brandt will testify that QC Supervisor lic.rry Williams
- f caused many improper practices to occur through his instructions to inspectors and intimidated j his inspectors by threatening to fire them if they didn' t do things his way (p. 5 Af fidavit) .
Mr. Krolak will testify that although he was
- te rm ina te,d for refusing to perform an inspection on a narro'w rail without scaf folding he believes
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- inspections in accordance with OC procedures
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thereby holding up production in some cases.
(.30e Fazi wouldn't do the inspection either but he wasn't fired (see p. 7, 11/18/83 Af fidavit) .
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t APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS Charles Atchison* There is voluminous mat.erial available on this Thomas Brandt Robert Taylor witness in the context of both this proceeding and R. Tolson Don Driscoll the DOL proceedings. We do'not see a need to Lou Fikar John Collins present him separately in this hearing, except as Dave Chapman
.. to his testimony that the harassment and intimi-- Mike Spence dation that he was subjected to was widespread EBASCO at the site and had a native impact on the willingness of QC inspectors to do their job.
We will however question the named individuals regarding their knowledge of management's response to the specific harassment, intimidation and termi-nation of Mr. Atchison.
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s APPLICANT INCIDENT
-; - . WITNESS WITNESS NRC WITNESS
' R3bert Bronsont Mr. Bronson was a QC inspector. He will testify Mr. Snellgrove Brooks Grif fin ,
. (Mr. Bronson is to his experiences as a OC inspector at CPSES J.P. Patton D. Dr isco ll
. In transit and with harassment and intimidation and pressure. R. Tolson i has not yet been The testimony will be virtually the same as his A. Vega
[e cantacted by CASE. statement in the CASE 11/28/83 filing. Althoug h G. Purdy L- We expect to call his deposition will expand on the results of the hia.) constant pressure on his ability to be a good i QC inspector there will be no substantive addi-
!. . tion to his testimony.
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APPLICANT
- / WITNESS INCIDENT WITNESS NRC WITNESS
. Jock Doyle* Like Mr. Atchison there is extensiva material on Gary Krishnan Brooks Griffin
, the record of this case from and aoout Mr. Doyle. Doug Frankum Robert Taylor However, it is within the context of this pro- M. Spence John Collins ceeding that Mr. Doyle can first present the R. Tolson
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, harassment and intimidation which he received on P. Britton
. .the job, and subsequent to leaving the job as a result of the problems he identified. Mr. Doyle will also testify as to the inability of the QC program to ad,4uately identify the problems, and the inability of the staff to deal with complex technical issues at the ins-'ector level and the resultant " chilling atmosphece" this breakdown causes. See principally the affidavit submitted by CASE on 11/ 28/83; also 1/18/83.
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t APPLICANT WITNESS - INCIDENT WITNSES NRC WITNESS GOtrge Clancy. Former TUGCO inspectot. He will testify to the Robert Murray Brooks Griffin (Hcve not been breakdown of the QC department during the time of R. Tolson Robert Taylor oblo to contact his employment at CPSES (1977-1975). His testi- P. Clark ;
to confirm his mony will be essentially repetitive of the affi- '
continued davit submitted in the 11/28/83 CASE pleading
'. - willingness to (supra) and his interview with OI which was contify.) released in the or report on harassment and intimidation.
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O APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS
- Ern00t Hadley Investigators of the Government Accountability e
Tom Ccrpenter Project who have investigated allegations of wrongdoing by the.workforce at the Comanche Peak -
site. Their testimony will report the information
> brought to them by former employees at the site about fear of reprisals or " blackballing," their mistrust of the Nuclear Regulatory Commission, and their lack of knowledge of their rights under -
. Section 219 of the Energy Reorganization Act.
They will testify as to the truth of what they have been told by those workers they have con-tacted regarding harassment and intimidation.
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APPLICANT .
. WITNESS INCIDENT WITNESS NRC WITNESS
. Dobie Hatley* Will testify about atmosphere of intimidation and Frank Strand Brooks Griffin harassment from craft and OC supervisors to pressure H. Hutchison Paul Check document control clerks, including herself and her Ray Yockey supervisor, to violate existing procedures regarding e issuance of documents. She would also testify about the pre-notification au.dit rigging as a result of fear of the consequences of failing the audit.
Finally she would testify about personal information
. regarding harassment and intimidation of others on the site,, including employees being forced to use illegal drugs on the site by their supervisors, and the failure of management to take any action.
Ms. Hatley would also testify about her termination as supervisor of document control satellite stations.
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APPLICANT
, - WITNESS INCIDENT WITNESS NRC WITNESS
,' Frcddie Ray Will testify about his lay-of f following the A. Vega Brooks Griffin 4
Harroll reporting of information to Antonio Vega. See l Statement of 11/28/83. -
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APPLICANT
. -WITNESS INCIDENT ,
WITNESS NRC WITNESS -
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- Cardella Hamilton Will testify about Fall 1989 meeting in Jim Harry Williams Brooks Griffin Hawkins office in which inspectors were told Jim Hawkins to stop nitpicking. Also about the lack of support QC inspectors in Harry Williams .
'r department received. See pre-filed testimony of Hamilton, 7/16/82, and OI Interview (p. 18).
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.i WITNESS INCIDENT N NRC WITNESS Jorry Artrip PBASCO QC inspector, currently employed at South Harry Williams taxas. Will testify about harassment and intimi- Jim Hawkins dation in the paint department and the management '
attitude toward identification of problems by
. supervisors in that department. He will also testify about the results of such treatment on implementation of the QC program.
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. WITNESS INCIDENT WITNESS NRC WITNESS
. . Bill Dunham* Paint QC Inspector, who was fired for alleged R. Tolson F. Hawkins misconduct at a group paint QC meeting. His' testi- C. Kristemer L.D. Gilbert
< mony will be about'the attitude at the site T. Brandt regarding the raising of questions by QC inspectors, b His testimony, except as to the results of harass-J ment and intimidation throughout the site, l's con-tained within the Department of Labor record of his discrimination complaint.
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APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS Cue Ann Neumeyer Welding QC Inspector. Resigned in February 1984. Jack Stanford R. Taylor She will testify that she believes she was Fred Evans Broo.ks Griffin Dwight Woodyard harassed, intimidated and pressured into accepting work which was not acceptable, and in Ted Blixt some cases not legal, at times throughout the Bob Seever entire course of her employment at CPSES, and Gordon Purdy that personal knowledge that the NRC is not A. Vega interested in examples or evidence of harass- R. Tolson
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ment, intimidation, pressure. Also her M. Spence knowledge of the meeting discouraging workers to talk to GAP.+
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APPLICANT IWITNESS INCIDENT WITNESS NRC WITNESS COtty Brink Former Intervenor, currently reporter. Will Brooks Griffin testify regarding the breach of confidentiality by the NRC after providing names of workers to
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or representatives. sco Brink letter to NRC commissioner Palladino, May 1984.
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, , APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS-Dennis Culton Will testify that the NRC interview and inspection / Robert Stewart ;
(Hos not yet investigation process was so hostile and intimi- Dan Tomlison j cgreed to testify.) . dating that he wants nothing further to do with Richard Herr the NRC, and that his treatment, if known to others, would convince them not to turn to the NRC for help in raising or identifying a problem.
(See Culton Affidavit, 6/29/83).
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APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS Dichard Hubbard Will testify to the generic significance of inde-(Mr. Hubbard has pendent inspection efforts on a plant. Will also bOcn previously comment on the appropriateness of the Applicant's used as an expert response to the individual and collective problems in the South Texas raised by the CASE witensses. (Mr. Hubbard will preceedings about have to read the testimony of the CASE and B&R competency, in Applicant witnesses prior to being able to p:rt regarding present that testimony.)
their QA/QC -
pregram.)
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1 APPLICANT
- WITNESS INCIDENT WITNESS NRC llTNESS
. Eddio Snyder* Eight QC employees in the electrical department Ron Tolson Site Resident Jack Pitts re po r ted to work wearing "T-shirts" that said " NIT Boyce Grier Bro.oks Griffin D.T. Oliver PICKERS PICK NITS." These employees were cour. dad A. vega John Collins A. Ambrose up and taken to the office of Ron Tolson D. Chapman e M. Ostfield where they were questioned by management, their M. Welch
-Len Davis personal materials taken from their desks, and Cruc3 Hearn then interviewed by the site ombudsman . Efforts Ron Jones to attempt to get the NRC to stop the detention Gorold Prior . failed. CASE will demonstrate that the T-shirts Jorry Staplin were worn as an expression of the frustration of site QC inspectors, that the response by management was oppressive, and that the lack of response by NRC was nonfeasence. Further that instead of there
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being no reprisal against those who wore the T-shirts the employees were first cut down to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week, some were transferred, some quit, and most recently some were laid off. of all the j inspectors only a few remain on the job.+
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APPLICANT WITNESS INCIDENT WITNESS NRC WITNESS
, J.J. Lipinsky He will testify about the pressure he was put under M. Spence F. Hawkins*
following the writing of the October 1983 memo G. Purdy (de posi tion) regarding paint findings. Specifically about the R. Tolson comments and information from TUGCQ/ Brown & Root T. Brandt
? management to him regarding the consequences of his writing the memo. .
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' APPLICANT
, WITNESS INCIDENT WITNESS NRC WITNESS Will testify that the morale problems, and subse-(An irdustrial quent lowering of the willingness of the QC force -
p2ycholog ist to identify problems and comply with procedures
, confirmation of which they are constantly undermined in becomes cur retention of fruitless. Futher he will testify about the effects thic cxpert is of " example discipline.*
peading.)
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APPLICANT FITNESS INCIDENT WITNESS NRC WITNESS faltOr Elliott* - These employees of the Paint Coatings QC Harry Williams D. Driscoll 23 Davis department testified in the Department of Labor Brooks Griffin
- t. Euline hearing of Bill Dunham. They will testify to the F. Hawkins
- Orcy Allen harassment and intimidation in the paint coatings rom Miller department, both as to their personal experience and as to the effect the Dunham incident had on them in the performance of their job.
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APPLICANT WITNESSES INCIDENTS REQUESTED TO BE NAME PREPARED FOR DEPOSITION REFERENCE Mike Spence CPSES policy regarding intimidation, Perry Britton harassment or threats, December 20, Lou Fikar 1983 The establishment of a CPSES " hot-line" The 1979 interviews of QA QC personnel The management response to the' August 1983 Report on Allegations of Cover-Up and Intimidation by TUGCO, Dallas Quality Assurance Communications with the NRC regarding problems at CPSES of harassment, inti-midation. Specifically surrounding the creation and implementation of the
" task force" in March 1984.
All management meetings or discussions regarding complaints of harassment or intimidation or lack of support of QC program at CPSSS Harassment and intimidation and Charles termination of Charles Atchison Atchison Harassment and intimidation and Jack Doyle blacklisting of Jack Doyle/ Mark Walsh Harassment and intimidation and Sue Ann pressure to accept sub-quality Neumeyer work on Sue Ann Neumeyer Harassment and intimidation and J.J. Lipinsky pressure of J.J. Lipinsky af ter Lipinsky wrote a 1983 memo re:
paint 1
(Generic items listed in Appendix A to Witness List) b
INCIDENTS REQUESTED TO BE NAME PREPARED FOR DEPOSITION REFERENCE Ron Tolson k His experience a,s QA/QC personnel management i
His performance ratings at TUGCO l l
His past job descriptions The 1979 QC interviews and reasons for and results/ recommendations thereof His interaction with craft supervision His speech given to QC inspectors Any other group presentations regarding QA/QC The Charles Atchison firing The termination of Dobie Hatley The resignation of Susie Neumeyer The termination of Bill Dunham The harassment of Lester Smith i
The harassment of Stan Miles
- The harassment of Darlene Stiner The harassment of Robert Bronson The harassment of Jack Doyle The harassment of George Clancy The reason for his removal as QA in February 1984 His new job description Any new performance ratings since the change His role in the "T-shirt incident" i
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INCIDENTS REQUESTED TO BE -
NAME PREPARED FOR DEPOSITION REFERENCE Ron Tolson His role in the preparation of response to the Eisenhut letters, re: harassment and intimidation issues His interaction with the cost and schedule for the plant -
His relationship with R. Taylor, NRC His relationship with the current NRC resident inspector His knowledge of the speech given in February by Gordon Purdy '
His knowledge of the use of NRC Form 3 at CPSES His knowledge regarding the development .
of the December 1983 policy on harass- "
ment and intimidation Any other information he has about inci-dents of harassment and intimidation and of management actions taken to cope with harassment and intimidation inci-dents or surrounding attitudes (Generic items listed in Appendix A to Witness List)
Antonio Vega His, experience in QA/QC management His experience as personnel management His performance ratings at TUGCO 1
His past job descriptions ;
The 1979 QC interviews and reasons for l and results/ recommendations thereof His interaction with craft supervision l
His instructions given to QC inspec- -
! -l tors regarding reporting of non-conformance '
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. 1 INCIDENTS REQUESTED TO BE NAME PREPARED FOR DEPOSITION REFERENCE ~
Antonio Vegs Any other group presentations regarding QA/ QC The Charles Atchison firing The termination of Dobie Hatley The resignation of Susan Neumayaer The termination of Bill Dunham His role in the T-shirt incident His role in the repeated pressuring of Bob Bronson His role in the harassment, intimi-dation and pressure of Sue Ann Neumeyer His role in the intimidation of Lester Smith, Termination of Robbie Robinson Termination of Robert Messerly ,
His knowledge of QC/QA problems in the paint coatings department The reason for Tolson's removal as QA in February 1984 His new job description Any new performance ratings since the change His role in the "T-shirt incident" His role in the preparation of response to the Eisenhut letters, re: harassment and intimidation issues His interaction with the cost and sche-dule for the plant i
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INCIDENTS REQUESTED TO BE _
NAME PREPARED FOR DEPOSITION REFERENCE Antonio vegh His relationship with R. Taylor, NRC His relationship with , SRI His knowledge of the speech given in February by Gordon Purdy His knowledge of the use of NRC Form 3 at CPSES His knowledge regarding the development of the December 1983 policy on harass-ment and intimidation Any other information he has about inci-dents of harassment and intimidation and of management actions taken to cope with harassment and intimidation incidents or surrounding attitudes.
Jim Hawkins Threats to Bob Hamilton about over B. Hamilton strenuous inspections His knowledge of the QA/QC program requirements regarding identification of problems Any conversat.f ons/ meetings h: had with management regarding the Hami'lton incident His knowledge of the reputation of Mr. Harry Williams as an oppressive supervisor (Generic items listed in Appendix A to Witness List) .
J. George The termination of Robbie Robinson R. Robinson after his reporting "make-work," etc.
The statements and actions of Mr. Vega and himself in response to Mr.
Robinson's complaints. '
Any conversations with management '
regarding Mr. Robinson's termination E
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INCIDENTS REQUESTED TO BE NAME PREPARED FOR DEPOSITION REFERENCE His knowledge of the QA/QC program requirements regarding identification
, of problems Any conversetions/ meetings he had with managemeist regarding the Hamilton incidents .
(Generic items listed in Appendix A l to Witness List)
Robert Murray The testimony of Mr. George Clancy G. Clancy regarding his instructions to Mr. Clency l
l Any conversations with management l regarding Mr. Clancy's termination l
His knowledge of the QA/QC program .
requirements regarding identification of problems Any conversations / meetings he had with management regarding the Hamilton incident (Generic items listed in Appendix A to Witness List)
Wayne Simmons Termination of Chuck Atchison (Generic items .iisted in Appendix A to Witness Li st)
Mark Wells Ordering employees, along with Harry Williams, to disregard safety requirements (Generic items listed in Appendix A to Witness List)
Jack Stanford Harassment and intimidation and pres-
. sure to accept faulty work on Sue Ann Neumeyer (Generic items listed in Appendix A ~
to Witness List)
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INCIDENTS REQUESTED TO BE NAME PREPARED FOR DEPOSITION . REFERENCE l
Larry Wilkerson Termination of Robbie Robinson (Generic item: listed in Appendix A to Witness List)
Wayne Mansfield Termination of Robbie Robinson (Generic items listed in Appendix A to Witness List)
Doug Frankum Harassment and intimidation and Jack Doyle blacklisting of Jack Doyle and R. Messerly R. Messerly (Generic items listed in Appendix A to Hitness List)
Dale Bullard Harassment and intimidation and Stan Miles threatened termination of Stan Miles and others (Generic items listed in Appendix A to Witness Licc)
Fred Evans Harassment and intimidation of Sue Ann and pressure to accept faulty wcrk, Neumeyer put on Sue Ann Neumeyer (Generic items listed in Appendix A to Witness List)
Fred Coleman Ordering H. Stiner to perform impro- H. Stiner per melds in February, 1980, while Coleman watched for OC (Generic items listed in Appendix A to witness List)
Ken Liffert Threatening H. Stiner, R. Johnson H. Stiner and others with termination in September, 1980, unless that per-formed sub-quality melds quickly (Generie items listed in Appendix A to Witness List) -
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INCIDENTS REQUESTED TO BE NAME PREPARED _FCR DEPOSITION ,
REFERENCE Jimmy Green Instructing H. Stiner in July 1931 H. St$ner to make improper melds H. Stiner's subsequent termination H. Stiner (Generic items listed in Appendix A to Witness List)
Larry Thompson Ordering H. Stiner to violate pro- H. Stiner cedures re: I-beams in April 1981 (Generic items listed in Appendix A to Witness List)
Ronnie Johnson Threatened along with E. Stiner and H. Stiner others with termination unless they performed sub-quality welds.
Threatened by Frankum, Callicutt, Liffert, and Heabart (September 1986)
(Generic items listed in Appendix A to Witness List)
Callicutt Threatening Ronnie Johnson and his H. Stiner crew (including H. Stiner) with ter-mination unless they completed a . eld quickly (with consequent sub-quality standard) (September 1988)
His knowledge of pressure on QC Docu- L. Bamas ment Review / Document Control Clerks Dobie Hatley (Generic items listed in Appendix A to Witness List)
PR Dept, Production of " Circuit Breaker" and Darlene Stiner Represeatative inclusion in some of worker allegations and others l l
(Generic items listed in Appendix A to Witness List)
Randy Smith Harassment and intimidation of Darlene Stiner Darlene Stiner, especially during. -
and relating to her pregnancy (Generic items listed in Appendix A to Witness List)
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INCIDENTS REQUESTED,TO BE -
NAME PREPARED FOR DEPOSITION REFERENCE
!;nellg rove Harassment and intimidation and pres- Bob Bronson sure on Bob Bronson (Generic items listed in Appendix A to Witness List) ,
J.P. Patton Harassment and intimidation and pres- Bob Bronson aure on Bob Bronson (Generic items listed in Appendix A to Witness List)
Gary Krishnan Harassment and intimidation of Jack Jack Doyle Doyle (Generic items listed in Appendix A to witness List)
Dwight Woodard Harassment and intimidation and pres- Sue Ann .
sure to approve faulty work, on Sue Neumeyer*
Ann Neumeyer; meeting discouraging workers from talking to GAP (Generic items listed in Appendix A to Witness :.ist)
Ted Blixt Harassment and intimidation of Sue Sue Ann Ann Neumeyer to approve faulty work; Neumeyor meeting discouraging workers from talking to GAPI (Generic items listed in Appendix A to Witness List)
Bcb Sievers Harassment and intimidation of Sue Sue Ann Ann Neumeyer; pressure on Sue Ann Neumeyer Neumeyer to approve faulty work; meeting discouraging workers from talking to GAPI (Generic items listed in Appendix A to Witness List)
Hal Goodson Intimidation of R. Messerly R. Messerly -
Termination of H. Stiner H. Stiner (Generic items listed in Appendix A ,-
to witness List)
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- NAME -
PREPARED FOR DEPOSITION REFERENCE M. Sanders Intimidation of Messerly; intimidating R. Messerly Messerly into loaning out "re-bar eaters" withoat documentation (Generic items listed in Appendix A to Witness List)
Curly Krishner Termination of Bill Dunham Bill Dunham (Generic items listed in Appendix A to Wi tness List)
Boyce Grier His role in the T-shirt incident Eddie Snyder; i
Jack Pitts; His knowledge ot the incidents of D.T. Oliver; harassment and intimidation A. Ambrose; M. Berfield; l His knowledge of the sue Ann Lon Davis; i
Ann Neumeyer investigation Bruce Hearn;
} Ron Jones; His knowledge of the Dobie Gerald Prior; Hatley investigation Jerry Staplin His knowledge of other investigations -
His job's objective l
(Generic items listed in Appendix A )
to Witness List)
D. Chapman His role in the T-shirt incident Eddie Snyder; Jack Pitts; His knowledge of the 1979 interviews D. T. Oliver; A. Ambrose; His knowledge of internal investi- M. Barfield; gations in harassment and intimidation Lon Davis; Bruce Hearn; His interface with management on Ron Jones; harassment and intimidation Gerald Prior; Jerry Staplin Harassment and intimidation of Charles Charles Atchison Atchison Termination of Robert Messerly R. Messerlyt (Generic items listed in Appendix A to witness List) a
1 INCIDENTS REQUESTED TO BE NAME PREPARED FOR DEPOSITION REFERENCE M. Welsh His role in T-shirt incident Eddie Snyder; Jack Pitts; (Generic items listed in Appendix A D. T. Oliver to Witness List) A. Ambrose; M. Barfield; Lon Davis; Bruce Hearn; Ron Jones; Gerald Prior; Jerry Staplin Thomas Brandt Harassment, intimidation, and ter- C. Atchison mination of Charles Atchison Termination of Bill Dunham Bill Dunham Termination of Joseph Krolak Joseph Krolak Pressure and intimidation of J.J. Lipinsky J.J. Lipinsky Harassment and intimidation of Darlene Stiner Darlene Sriner, especially during and relating to her pregnancy (Generic items listed in Appendix A to Witness List)
Harry Williams Harassment and intimidation of Bill Dunham; effects of that harassment and intimidation on other inspectors Harassment, intimidation and termina-tion of Bob Hamilton Intimidation of J. Krolak, and orders to Krolak and others to do sub-quality work (Generic items listed in Appendix A to Witness List)
I Gordon Purdy Interference with Barnes' attempts to )
use proper document review procedure
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Lipinsky following Lipinsky's 1983 memo (re: paint) 9 m-. _ _. . w .-g a
INCIDENTS REQUESTED TO BE -
NAME PREPARED FOR DEPOSITION REFERENCE Harassment of Bob Bronson
' Harassment and intimidation of Sue Ann Neumeyer; pressure on Sue Ann Neumeyer to approve faulty work; meeting discouraging workers from talking to
- GAP ,
Gordon Purdy Knowledga of discontent among the QA/QC inspectors regarding use of NCRs (Generic items listed in Appendix A to Witness List)
Gil Keeley Report on Allegations of Cover,-Up and
. , e-R. G. Spangler Intimidation by TUGCO, Dallas Quality R. E. Kahler Assurance, August 19, 1983 I
(Generic items listed in Appendix A to Witness List) -
F. Strand The constant pressure on Document Con- L. Barnes H. Hutchison trol by craft and QC to issue incom- D. Hatley plete and incorrect packages (Generic items listed in Appendix A to Witness List)
Bill Clements Will testify about the preparation of TUGCO resp nse to the Eisenhut letters regarding egations, including harassment a d intimidation Should also be prepared to testify about items of which he has knowledge listed for Mike Spence, et al.
(Generic items listed in Appendix A to Witness List)
Ray Yockey Will testify about the termination policies and practices at CPSES, as well as the employee rights and responsibilities as contained in any relevant, employee manual .
(Generic items listed in Appendix A to Witness List)
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NRC STAFF WITNESSES NAME INCIDENTS REQUESTED TO TESTIFY ABOUT
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John Collins Requested to testify about the policy of NRC staff (all regula- regarding harassment and intimidation; the decision to tory actions issue a $40,000.00 civil penalty regarding Mr. Atchison's except OI on issues, the decision to postpone the fine; the attitude CPSES) of the NRC regional staff toward reports of harassment l and intimidation. I l Robert Taylor Requested to testify about the policy of NRC staff, also current regarding harassment and intimidation; the decision to esident insp. Issue a $40,000.00 civil penalty regarding Mr. Atchison's
, issues, the decision to postpone the fine; the attitude of the NRC regional staff toward reports of harassment and intimidation.
The T-shirt incident Harassment and intimidation of George Clancy Harassment and intimidation and pressure to accept faulty work on Sue Ann Neumeyer Harassment and intimidation of H. Stiner Harassment and intimidation of Charles Atchison Harassment and intimidation of Jack Doyle His knowledge of Sue Ann Neumeyer's cooperation with an NRC investigation into Henry's concerns The findings of the OIA Report His policies regarding her on the site that includes harassment and intimidation complaints His specific knowledge of the allegaton of harassment and intimidation by those CASE witnesses listed below.
The expectation of the NRC from an applicant about an QA/QC program D. Driscoll Requested to testify about actions taken in response Brooks Griffin to allegations of harassment and intimidation, his Richard Hers judgment as to the seriousness of harassment and Paul Check intimidation on the Comanche Peak site; his under-standing of the NRC's policies regarding harassment and intimidation; his investigation of the complaints of al) named witnesses. The release of, names provided by Bett)
Brink.
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F. Hawkins His inspection efforts into the allegations of J. J.
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Lipinsky and the allegations made by Bill Dunham Robert Stewart Interview of, Dennis Culton and h'.e interview techniques employed to determine Mr. Culton's allegatior Dan Tomlison Interview of Dennis Culton Richard Herr' Interview of Dennis Culton Tom Ippilito The ongoing " task force efforts", how the task force would deal with the problems resulting from the prevailing attitude of harassment and intimidation; the importance of harassment and intimidation; his under-standing of NRC policies regarding harassment and intimidation 9
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l Generic Items For Witnesses To Be Prepared To Testify About t
-- Basic background and experience prior to going to work at CPSES l (Provide resume if one exists) . 4
-- Work history at CPSES, positions, supervisors, duties, etc.
-- i The othe g'rcontractor
. tness' understanding of policies of regarding reporting of TUGCO, B&R, and non-conforming items.
Specific incidents of harassment and intimidation on CPSES site kr.own to each individual Any knowledge about management actions taken to cope with harassment and intimidation, pressure on QC inspectors, pressure to not write non-conformance reports or to ignore construction problems.
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Management procedures to insure that QA/QC programs are being implemer.ted.
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