ML20099D338

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Affidavit of Jj Lipinsky Concerning Trip Rept Job H8301 Re Coatings Program.Related Correspondence
ML20099D338
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/13/1984
From: Lipinsky J
OLIVER B. CANNON & SON, INC., TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20099D326 List:
References
OL-2, NUDOCS 8411200323
Download: ML20099D338 (10)
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- fAFFIDAVITf0FfJOSEPH7J.ILIPINSKY .  ;}

I Tam.Sediployed by: O.B.
  • 1 1 ^. . My name istJoseph JF Lipinsky.

. Cannon tilsons JInc.,J5600 Wood 1'and Avenue, Philadelphia', -

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Pennsylvania 19143.. '

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.2.- I: first ! visited o the : Comanche. Peak JSteam' Electric 4

^ Station.on July 26-28M 1983. : As1I; uriiderstand {it,10.B. . Cannon. had ,

beenretainedtoevaluatecertain.ashectsEoftheComanchePeak coatings program.

3.- During.the firstLtwo. days of:my visit to.the site.-(July.

'26~and'27),"I? spoke with several persons-regarding the coatings program and conducted-limited-tours'of the project to observe'.

activities relating to the coatings program.

4.. On July 28,,I participated in a exit interview in which I summarized my initial observations about the coatings program Later that day I returned based on my lim'ited visit to the site.

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'to' Philadelphia, which is my principal place of business. ,

5. After returning to, Philadelphia, I prepared Trip Report OBC ~ Job'No. H8301 (Comanche Peak Unit 1 - Glen Rose, TX), which -

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is dated. August R, 1983. This memorandum was intended for  !

internal *use by O'.B. Cannon only, was not intended to be l

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8411200323 841117 PDR-ADOCK 05000445 0 m PDR .

. 2-disclosed publicly, did not and does not represent the views of 0.B. Cannon & Sons, and simply reported my impressions based upon a very short visit to the ette.

6. I do not know how my Trip Report became public. I understand that the Nuclear Regulatory Commission has concluded that the Trip Report was " surreptitiously" takan by someone who provided it to tha NRC. I assume th'at the word " surreptitiously" means that it was stolen. If the Report was taken from me, it was taken without my knowledge or consent.
7. Since I prepared my Trip Report, I have conducted an additional site visit and have participated in extended -

conferences with site management to address the concerns identified in the Trip Report. These in-depth discussions have demonstrated to me that my initial impressions which were based on limited data, were incorrect. The Trip Report does not represent my current assessment of the coatings program at Comanche peak and should not be relied upon as my position or that of 0.D. Cannon & Sons, Inc.

. _ */h LS Jr J ~ s pg p ipispy Subscribed to and sworn to before me this fi# day of February, 1984.

. , $ (',,/.Q Notary Public '

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lOLIVER?BRCANNONg. , .S ON,yl NCb q

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iDEPARTMENTAL CORRESPONDENCE

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'QAD-84-0164 DATE[ MayL14,1 1984J T susMcT' H8301 Trip Report R'. 28. Roth,-R. A'.'Trallo, J.rJ. Norris j icc:

ny;) T '>H8301-QA Fil'e-lFnou s '

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jon May 9,71984,it5m writer met with McNeil Watkins II'(Bishop, Liberman,

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9 LCook,'Purcell &LReynolds)Yand;CJThomas 'Brandt-(EBASCO)', fin M. Watkins N ~_ Washington, D.C. office l(6'th floor conference room)'..

The .' meeting 1startsd .at approximately- 0930 ho rs' (EST) and ended at approxi--

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>mately 1315, hours (EST)l(working:.through lunch).

C. T. Brandt' provided-JJL' back-up ;information (to satisfy concerns raised l

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by ..JJL '(see QAD-83 -009_6 dated - August 8, 1983) . The information provided by C. T. Brandt was;along the lines of the information provided to 08C during-the~ November 10/11,-1983, meeting at the.H8301 site, and satisfied' concerns raised by the writer.

The writer did suggest to C. T. Brandt that Carboline be contacted to get a '

more up-to-date. evaluation of repair procedures to the coatings applied at the'H8301 project. .

M. Watkins indicated that JJL's comments to the NRC testimony can still be

-~ i ncorpo ra ted. '

- M.: Watkins stated that JJL's testimony will be c' hanged from a question and answer. format toan affidavit format.

Hopefully, OBC will not have to testify.

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in front of the ASLB. If testimony is required,' then in all probability only p

RATand/or[JJLwillbeLneeded. A rough c: 't of'the affidavit format will be

_ provided.to JJL for review and comment (as well as a copy of testimony _of i.

( - C. T. Brandt) .

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~WH8301fTrip'Repor.t. '

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- :H8301 QA File cc:f RBR,s RAT, LJJN '

. May_14,':19841 ,

"J.iJ. Lipinsky.

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Watkins -pointed out that,JJL :need -not be -concerned about: the facts or

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, ,, details behind statemsnts made by C.1T. Brandt.: . g .

y N.l S.: Reynolds-came in briefly'and talked 1.in general about- the~-stutus andi t

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progrees of.the meeting. Also,: N. -S. Reynolds . discussed with'C. T.' Brandt reports (by EBASCD and Gibbs and Hill) .that would dequalify:all deating: <

in ' containment. !Later JJL discussed lthis brieflyi with C. :T. Brandt and t M. Watkins.. -7 4 -

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. The writer has'~ advised 'all concerned about' thediscussi'on during .the1 course of the meeting, however if there are any questi,ons or nejd forf additional

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information, do not hesitate to contact the writer.  ?-

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OLIVER B. CANNON 4 SON. INC. WH

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- DEPARTMENTAL CORRESPONDENCE -

QAO-84-0210 M ,

m7g July 5, 19836 J y

M Telechone Conversation with McNeil Watkins If File cc: R. B. Roth, R. A. Trallo, J. J. Norris noeg' J.-J. Licinsky On this date at approximately 1116 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.24638e-4 months <br /> 'EST) the writer had a telephone -

conversation with Mr. Mc Neil Watkins~II (Bishop,;Liberman, Cook, Purcell,.

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'and Reynolds). The following was discussed:

- MW asked JJL if JJL had been contacted by GAP (Government A countability Project) or CASE. , JJL replied in the negative. -Briefly discussed GAP and its role in the H8301 pro,1cct.-

- A separate board (made up of two members from the licensing board) is looking into MIT's (Harrassment, Intimidation, and Throns) and JJL has been scheduled to testify.during the week of July 23, 1984.

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At this point the conversation was terminated due to problems with the -

phone connection. JJL tried repeatedly to reestablish the phone link with M. Watkins @ 817-897-2941 EXT 43 At 1135 hours0.0131 days <br />0.315 hours <br />0.00188 weeks <br />4.318675e-4 months <br /> (EST) phone company operators .

could net get through to above number. .

The phone conversation continued when M. Watkins called back. <

- This hearing would try to determine if JJL was harrassed, threatened and/or . intimidated. _

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/ * - GAP / CASE have about forty (40) witnesses scheduled and specifically l_ ,

want to question a Gordon Purdy and C. Tom Brandt regarding JJL. GAP / CASE have asked the NRC to make Mr. F. Hawkins and C. Johnson available (NRC's ,

failure to follow up on allegations). l 1

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.- JOL,lVEREBiCANNON' G SONi INC.:

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Filo; fJuly_ 5, 198l+ .

. :3UBJECT::: Telephone Conversation.with McNef t Watkiris II

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1-$ GAP / CASE should contact fJJL? today, 'tomorrbw or early next week at the

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-' W suggested thatlJJL: tell GAP / CASE that JJL would'be' happy to tell them

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- (GAP / CASE) anything 'thet they want, but JJL' would. prefer a ,supeona 1 (as'well as cash for. air; fare, ground; transport, mea'Is, lodging). N

, pointed out - that 08C would not be' reimbursed by_ H0301 for JJL testimony.

on ' behalf af GAP / CASE.

L-JJL should feel free to mention that 08C/JJL still have a working relationship.with TUGCO. . Additionally, that JJL has been dealing with MW and mentioned law firm.: - -~~

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If GAP / CASE 'still want =JJL to testify then JJL could testify only on two aspects regarding harrassment, intimidation and threats. .

The first area would be hearsay as a result of JJL's trips to the site. .

. GAP / CASE would be able- tio call anyone JJL'says talked to JJL. The.

second area would be any harrassment, intimidation and threats against-7 c

JJL since release of JJL's trip report. ,

' MW told JJL that if GAP / CASE do not contact JJL then JJL has no respons'ibility to. appear for hearing. JJL woul.d not.get into trouble ifnotcontactedbyGAP/ CASE.

MW and JJL briefly. discussed a study prepared by Gibbs and Hill /Ebasco

, -that would dequalify coatings as a safety related item. This study I

i has been. submitted to the Nuclear Raactor Regulation (NRR) for evaluation /

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I f- approval. 'MW said that Jerry Ferte11 (Ebasco) felt that approxirra tely i

75% of the coatings will be eliminated. His reasoning is that the NRC

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would not eliminate 100% because of the politics involved.

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CLIVER Bi CANNON C, SON, INC,z .

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. July 5, 1984-

SUBJECT:

l Telephone Conversation'with McNeil Watkins; II

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- ^ JJL: revised affidavit is on " hold"_ unti! C. T. Brandt is~ happy with his testimony.

-- JJL shourd send coments to NRC regarding JJL.1/84 testimony before  :

the NRC.

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' SISMOP, LIBERMAN, COOM, PURCELL &' REYNOLDS w .

' saoo sEVENTEENTN sTNEET, N.W.- - IN NEW YoRM .,

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  • CONFIDENTIAL unea:

September l26'L1984 ,

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MrdJoseph J."Lipinsky-Oliver:B.: Cannon &, Son,-Inc..

. 5600. Woodland Avenue

Philadelphia, PA .19143.

Dear Joe:

I enclose <for your reviewithe following:

1. Copy of' executed- affidavit. of C. Thomas - Brandt, Lalong with Attachments -A through N.

2' The original of the affidavit of Joseph. J. Lipinsky.

o i- 3 Copies of a draft motion. for summary disposition and .

4 accompanying statement of material ' facts. .

Please review the.Lipinsky affidavit carefully'to ensure that all factual statements accurately represent either your it recollection.of facts, or your current: understanding. Where

! -appropriate, confirm that the. basis for any of your conclusions l appears either~ in. Brandt's . affidavit or in . the . attachments to -

his affidavit.- Keep.in. mind that..you cannot, and are not -

, expected to, vouch for the~ accuracy of Brandt's statements; l ha-will be responsible for that task, should it aris'e.

Please give a call when yotr have reviewed the affidavit.

We will need copies of your. current statement .of qualifications and a copy of your oricrinal trip report. .

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Joseph.7.jLipinsky- '

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. September ;26, ; 1984 .

1 Thank youifor your.l work on.this matter...

McNeill:Watkins II- ,

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. , - LOLIVER B.nCANNON Q SON. INC. .

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.'- 5600 WOOOLAND AVENUE

  • PHILADELPHIA. PA 19143 .

-[. < . AREA' CODE (215) 729 4600 Cwana&use+ ..

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.QWIP LOG SHEET To: McNeill Watkins,'II- .

Of:

Number of Pages following -

Cover Sheet:

From: J. LiP insky

'Of:

Date: 9/28/84 Qwip'f: '(215) 729-1670-

Subject:

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Tu.o p/As Ucesiod.
  • Operator: K. McMullen Company : 0.B. Cannon l

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NUCLEAR REGULATORY COMMISSION'-

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'BEFORE! THE ATOMIC SAFETY:ANDiLICENSING: BOARD

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?A M Th thel Matter ofs: ,

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  • TEXAS UTILITIES ELECTRIC.  ;)~ - Dockets-Nos. 50-4455and W , ' COMPANY, et al. :  :) '

50-446 F . .. . .

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'(Comanche ^PeakLSteam Electric' ?)l

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~ Station,LUnits:1(and;2) f)- goperatingLLicense).

AFFIDAVIT'OF' JOSEPH"J.-LIPINSKY

s. q (My namefis" Joseph J.7Lipinsky> I am_ employedby;O.B.-

Cannon"& Son,1Inc.,'5600: Woodland Avenue,LPhiladelphia, PA 19143. A-statement of my educationalfand professional

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qualifications'is attached to this' affidavit.

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On July-26, 27'and 28, 1983,-I visited Comanche Peak.

Steam Electric Station.'to evaluate;certain aspects of the l

Applicants' coatings program. After.that short site visit, I prepared a Trip Report. - I understand that a copy of the o

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Trip Report'has been submitted'to the Board in'this

  • proceeding. Because the observatio'ns and conclusions in'the Trip Report no-longer represent my views or the views of 0.B. Cannon & Son, this affidavit will discuss in some

.datailleach of.the areas mentioned in.the Trip Report.

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! CIRCUMSTANCES OF'MY VISITJ -

TO COMANCHE PEAK' >

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. I' understand)that ApplicantsfretainedLOi8. Cannon; 2 iduring ithe ? summer of $1983 : to .eva12 ate , certain aspects - of J the '

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_ , ' Cbmanche )!Peakhcoatings ' programa L includingfobservation' and ;

  • analysisLof production;. work procedures,' scheduling, trainingian~d painter [ qualification, Equality' assurance,' .

's-t management, .LandEspecifications.-

Ingearly July, the:

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, presidentfof'O.B.fcannoni1-Mr.LRoth,..instructedLme 2 to become. ,

involved in' Cannon's~ efforts and to visit the site to -

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provide additional input. ,

My1 initial visit.to Comanche Peak.was July'26 through.:

Jul'y' 28, - 1983. . .On-July.266 I met'Mr..C.T.,Brandt and several.otheriindividuals involved-.with the' coatings

' program. We briefly* discussed the purpose of my visitsand I 3 described how we would proceed. I then proceeded to tour

~the site and observe various activities related to the

  • coatings program. I talked with several individuals to familiarize myself with the activities. We discussed the-

-job status, project conditions and. work activities. The majority of my time on July 26 was spent in the containment building for. Unit 1.

i On July 27, I returned to the site and continued with .,

my. review of the containment building for Unit 1. I.

i observed work'on the polar crane and dome. I then had about a 10-minute meeting with Messrs. Tolson and Brandt. ,

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h h On'. July 28,iI-met lwith Mr. John?Norris,,who'is:anLO.B.z- -

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l Cannon ~Vice'-President.in' Houston,.toLdiscuss:my.observa -

1tionsl.'-I'then. reviewed theLFSAR-Lcommitments and other; 'e ,

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  • documentation.' - Finally,- Ilparticipatetd Iin' an exit L' -

E interview. I' expressed'a'lfew concerns'.regarding material-storage,EpainterEqualificationi compliance!with[ ANSI-

requirements-and possible coatings integrity. Mr. Tolson~-

asked me to provide: specifics.onythese:' points,'and':I~ told him that I was-unable to do so.withouticonducting an,in--

depth r'eview.. The meeting.was thenLconcluded, and Mr.-

Norris, Mr.'Merritt and I met'withTMr. Joe; George, the TUSI. .

-Vice; President in charge of-construction.~ (I mistakenly identified 1Mr. George as'Mr. Church'in-my August 8 memoran-dum.) Mr. Merritt-summarized the exit interview for Mr.-

George.

-THE TRIP REPORT on July 28, I returned to my office in..Philndelphia and l drafted Trip Report OBC Job No. H8301 (Comanche Peak

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. Unit 1--Glen Rose, TX). - I provided' copies of the report to-Mr. Roth and Mr. Norris. This document was intended for use strictly in-house, by 0.B. . Cannon. To my knowledge, i.

t-Applicants did not become aware of the existence of my Trip i

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Report until mid-October, when Mr. Merritt called Mr. Roth and asked for a copy. Mr. Roth sent Mr. Merritt a copy of the Trip Report on October 12.

When I prepared the Trip Report, I was not aware that the Report would bo distributed publicly or that it would be submitted as evidence in hearings before the NRC. Had I been more aware of the pendency of this case and the ramifications of my Trip Report, I would have more carefully and aggressively pursued the concerns .I expressed in that report before memorializing those concerns in writing. I also would have been more assertive in my dealings with site management so that my concerns were known and addressed to my satisfaction at that time. Finally, had I known that the Trip Report might be considered to be my final views on the adequacy of the Comanche Peak coatings program, I would not have prepared the Report because I did not have sufficient information to make final judgments. In fact, at the time I received my assignment to visit the site in late July, I believed that three days was insufficient time for me to evaluate adequately the coatings program.

I do not know how my Trip Report became public. I l

unde'rstand that the NRC has concluded that it was

" surreptitiously" taken by someone who provided it to the NRC. I assume that the word " surreptitiously" taken means that it was stolen. If the Report was taken from me it was so taken without my knowledge or consent.

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i CURRENT 1 STATUS ' OF .- THE ', ,

. TRIP REPORT; l 1$ e 'Y

'Ilconducted an additional' site: visit:in -early November,

'atiwhich1 time,-11n' extended conferences, Applicants provided J me.with'detailedL'information:rel'ating to eachi fo the issues i

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that I had earlier identified?in;my August.8 Trip' Report.-

Applicants have-subsequently provided me1with' additional' information;.and documentation ~as-to those issues.- The

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specific' issues! identified in1my Trip ReportJare materials; ,

storage, workmanship, coatings: integrity,-and' inspector.

morale. Based'on the'information-that has'been presentedEto me,~I:believe~today that the concerns' expressed:in my Trip Report are unfounded, and am satisfied, based on my*

understanding of the situation, that the quality of the coatings program at Comanche Peak is. adequate.

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'Mais .

affidavit' discusses each of the issues and statements identified or contained in the Trip-Report.

MATERIALS STORAGE When I first visited the Comanche Peak site I was

'looking at certain things that, to.me, would indicate good materials storage-practices. I looked for such things as

. status indicator-tags (accept tags), reject areas and hold-i l . areas.. Reject areas are locations where coating materials I

l. that have been rejected are stored. Hold areas are
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locations where* coating materialsfof=ind'eterminate
quality iarefstored. 'ILsaw nolindi~ cations:o'ffthe usejoffstatus tags,-

'andlITsaw'no reject areas or-hold areas.: Further,:regarding

-the. control'oficoating. materials.inigene'ral,;I:saw no system-

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ofttracking1for.. control,of: mixed-materials.

I have reviewed the affidavit of C.' Thomas Brandt-4 regardingsthe Comanche Peak? procedures for; coatings' storage

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'and control. . Having reviewed.his' affidavit and supporting; ..

documentation, Ilam satisfied' that- the procedures at Comanche Pwakiused to.trackiand document satisfactory Jcoating materials satisfies the: requirements'of. ANSI 101.4

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and' Appendix'.B. /Had-I'been! familiar.with'these procedures at'the time of myfsite-visit, ILwould not have' criticized -

these aspects of materials 5 storage and traceability.in my

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. August 8 Trip Report.

Specifically, I now know that the reason that I did not 1 -

see reject areas or hold areas was because these areas are

, located at-the Receiving Warehouse, which I did not visit while on site. With respect to traceability, I now

understand that storage, mixing, and use of coating ,

I materials are fully overseen and documented by QC personnel.

.Again, had I been familiar with these procedures at the' time

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that I wrotefmy August 8 memorandum, I would have had no o

basis'on'which to criticize Applicants' methods of handling

' mixed coating materials. Based on my current understanding a

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Cof: thelComanche ; Peak Tstorage ' and1 traceability iprogram, l-I; .

have-Lno cr'itici'sms o'fEpracticesJan'd procedures utilized.by.

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My/ August'.8 Trip: Report identified' workmanship as.;a problem'at. Comanche-Peak. ~The'onl'y basisDfor this. criticism was'.my observation of sags:-Jand runs in applied film.-.:What'-It ..

c .saw-was, however, really was'no different from what.I have

.seen at most other' job sites-involving c'onstruction of,.

nuclear; power plants.. . Sags;-and runs are typically

' encountered in cured films. They may be acceptable or unacceptable,. depending on khe requirements of the relevant t

-. procedures and specifications. .

I have reviewed Mr. Brandt's affidavit regarding the?

Comanche' Peak procedural requirements for dry' film thickness (DFT) readings. According to Mr. Brandt, areas that include

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sags and runs are routinely inspected by QC inspectors'for compliance with the. relevant requirements. if, therefore, a sag or run would cause' rejection of the coatings work in-l

, question, Comanche Peak procedures would require either r-rework or disposition by engineering as acceptable. I am

) .. '. satisfied that' Applicants have addressed any problems that t

L sags or runs might present in procedures.

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7 PAINTER QUALIFICATION-AND. '

INDOCTRINATION During my site - visit irr July) 1983,. Iiwas - told ' by one t

or/more QC inspectors that Applicants'did not qualify.

M painters by actually: requiring the application of_ coating _

.' material:as a test for competence. . This information,

~

however, was erroneous.. On a' subsequent-visit to Comanche Peak I observed:craftEpersonnel undergoing. testing by applying zinc primer to: test' panels. I have also. reviewed Mr. Brandt's affidavit.regarding1gualification of painters.

Based on-his discussion, I am satisfied.that my. original misapprehension'was without basis.

I was also concerned, when I prepared my Trip Report, that the QA/QC. organization did not monitor qualification ,

processes for craft painters. I now understand from Mr.

Brandt's affidavit that QC inspectors conduct visual examination of the test panels coated by the craft during the. qualification'and indoctrination program. I believe that this overview by-QC in appropriate and important because it L assures that the craft painters can apply the film in a manner that meets quality requirements.

In sum,-I am now satisfied that my original impressions regarding the qualification and indoctrination of craft painters was erroneous.

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1 ADEQUACY-OF-DOCUMENTATION-.

-^' D My
August?8[ Trip [ Report'also mentioned, documentation.

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y l'deficiencieslas zal problem.

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f The areas on;which".Ilhad focused were: painter 2qualificati'on, forms;and' Inspection Reports a .

(irs ) . .- In1 order to. meet.~-ANSI! standards,the program must; assure!that pertinent datafis-recorded regarding both painterlqualificatiqn and-.da,ily Linspections.--

Mycconversa-r, . V: w,.

-tionstwithTaLfew'-individuEls made_the; concerned that

[ l Applicants painter. qualification forms:-and irs-did;not '

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' provide-for a recording of-all' pertinent?information. I'do

'not recall whether this' concern was triggered;by actual

. review of these1 documents; my 'istpression is that this -

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observation was based on discussiofis with QC. inspectors.

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'I have reviewed Mr. Brandt' affidavit with respect to Applicants' painter qualification forms and irs. I have g also reviewed the. sample painter qualification forms'and irs attached to his affidavit. -I am satisfied that Applicants' use of both forms fully-~ complies with ANSI standards, and I

that my impression to the contrary, based on a very short ,

visit to the site without any in-depth review of this

' documentation, was ' erroneous.

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' COATINGS' INTEGRITY' n

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s:Myl August2 8 Trip: Report indicated possible_ concerns

.with coating. integrity. Myispecificl concerns are' listed in

. Paragraphs,E and F of Page 4 of the' Report, . whichEaddress Applicants' practice of power grinding CZ-ll, and applying a

new Phenoline 305 over old'Phenoline 305 without ext'ensive- .

surface preparation.. These observations were not. based on a a: study of the' specifications for the' coatings systems, and-

'were simply my observations l based upon what'I saw in'the. a field. :I now'understan'd--from Mr. Brandt's' affidavit that Applicants have raised each ofLthese issues with the coatings ~ manufacturer, and I^ note'that the manufacturer has r

approved these practices 16 writing. The manufacturer's approval.of these practices fully satisfies any concerns that I might have had.

MORALE PROBLEMS The basis for my concern that morale problems existed ,

at Comanche Peak was my discussion with several QC inspectors. Management at.the site acknowledged that morale was not high, and stated that they were taking steps to rectify the matter. I have no basis for concluding that -

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imorale!atYtheJsite'wasidetrimental:toiquality. I believeL c :.

s that l the ? most; importanti . thing j is e that management is : awarei of -

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MANAGEMENT'S COMMITMENT +

TO QUALITY 4

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F When ;I prepared: my August' 8 memorandum,- mylimpres's'ion : ,

was that Comanche ~ Peak management wasidisin'terested in

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quality:and actually.-attempted-to discourage _ efforts;to

$ report quality problems. - '.I have concluded. that my initiial'.

~

impression was based--on misinformation andlwas: erroneous..

I had a-brief discussion with TUGCO's;qualityjassurance .

manager, Ronald _G. Tolson,-on July . 27,:1983. :I attemptedi to-discuss-with him a few concerns regarding quality matters.

I' learned'later that he understood my comments to relate to licensing questions. Mr. Tolson stated that he.was not concerned with licensing questions,-but my impression was that he was expressing disinterest in quality matters. I was frankly very surprised with his comment (as-I then.

interpreted'it) but did not. pursue it with him at that time.

Subsequent. discussions with Mr. Tolson convinced me that my

_ original impression (as reflected in the Trip Report) was

. incorrect and that he is in fact sincerely concerned about the quality _of the project without regard to the licensing

, ,, proceeding.

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- 'My7 impression thatimanagement at1Comanchei eak' -

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n "discourged'offorts;to. report quality programsfwas?

. 4 i , principally based on my'understinding_'(from What^I wasitdidt  ?

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. . by-QC: inspectors)<thatLcoatingsLinspectorsjwer.e notl s j

permitted,to use non-conformance-reportsT(NCRs)~.; As l?noted" '

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above',; . I? further:sbelieved atithe7 time,thatlthe IRsfused at' Comanche Pekk5did'not-adequately documentLnon-conformance.0 I

. / conditions. . .I did notLreview~thel Comanche:. Peak 1guality. -

. 1 procedures to1 verify the" inspectors'iclaims'.' 'I now . x t' understand, -' however,:~ based on Mr. Brandt 's ; affidavit,1 that#

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inspectors are!not precluded.from?using'NCRs in appropriate- -

circumstances,-and further that the irs used~at'Comanchei j Peak are fully adequate tol. document'non-conformance In my juC 7ment, this approach.is-~ acceptable.

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- conditions.

3

. from a qilality _ assurance ' standpoint.

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.Indeed, O.B.. Cannon & .

.,a i Son uses a similar. program-in its work'at other nuclear-plants.

Based on my discussions with site management subsequent-to August.8, I now believe~that' management'i's concerned'and

j. dedicated.to' maintaining quality as to the project coating program and,that management encourages the reporting'of non-conforming conditions or any other quality concerns.

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. BROWN'AND ROOT'STE '

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WhenI
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. I-perceived that Brown---&

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w Root was hostile to the idea ofian: audit'and that no.actionf -

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.would be-taken by Brown A Root evenSif problems were p: .. . ., . 'i e.

Y .'Sde:tc;:ted Tin ; an-laudi.h Tn'is Impression. was'. largely. based on-y m s  ? . :

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- comments:made1by Mr. fo'isonLin an; exit: interview;on July 28, w .

M 1983, .duridg which he repeatedly' stated:that an audit by. ~

O.B.-Cannon'would'be' redundant.. I'took this(tb-mean that he

-was hostile to an at:dit. .

~ ~

m I-should explain, first'of-all, that $ was under the

-impressions at the-time that Mr. Tolson was employed'by' Brown

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&' Root. .I now ynow that he.is employed by TUGCO. - Thus,

, T s, references to.Broyn.& Root should have been references to.

'TUGCO, with respect to audits.  %

- . I now understand more fully the basis and intent of Mr.

Tolson's statemento,that an. s audit by me or by O.B. Cannon

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, you1d not'be productive. He has reconfirmed his view to me

~

.as recently as November'10, 1983. The basis for his belief, I now know, is the fact that during the period 1981 to 1983,-

the Comanche Peak QA/QC program.has been subjected to repeated inter.nal and external audits. In particular, as s.

discussed in detail in Mr. Brandt's affidavit, Texas I

l. Utility's corporatb'QA~ department has conducted several i

( . audits, and the ppogram has-been audited further by external

~

agencies, including the NRC itself. In view of these audits

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-andlongoingiNRCfreview ofithe? coating;progra $ 1 agreeiwith. i M

. Mr.--Tolsonthat.an'addiEionalaudit(atthispointLwouldI.be. -

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a - redundant landlunne'cessary. 2 l k

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COUPARISONIOF COMANCHE

. PEAK TO ZIMMER:

-My August.8 memorandumTstated that "to somefextentia, parallel':1 can be drawn;with ComancheTPeak and Zimmer."',ThIs 4

-: unfortunate observation was my feeling /at-the~ time,--based'on myEliniited familiarity with the program, that. Comanche-Peak-1

-might.be developing-into:a Zimmer-type-situation. The' poor-
quality of the-coatings at ZimmerLwould have required a-2

.-complete 1 rework of that plant's coatings'. Based'on the 4 .

i. information with which I have been provided by site

~

, personnel subsequent to my August 8 memorandum, I believe that,enis conclusion was in error. Based upon my L

<1 understanding of the program and the procedures in' place at

' Comanche. Peak I now believe that there is no parallel O

between Comanche Peak and Zimmer and I regret having made j such a comparison. My current belief is that no rework 1

activities.are necessary as to the-Comanche Peak coatings

. program. My concerns have proven to be unfounded _and_I am

p satisfied, based on my current understanding of the program, that the quality of the coatings at Comanche Peak fully satisfies the requirements of ANSI and Appendix B.

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.. . MISCENANEOUS' CONCERNS l

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'MyjTrip Report stated,that "ifEquality. work is putfin;

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- place':then th'ey will'.be.' a-- long way' to resolving Leite problems."- That; statement;simplyLreflected my. belief that-if ' craft? is carefullin -its: application of coatiings-. then(the -:

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LQC inspectors' job 1 becomes routine:and simple. If. craft:is s

carelesse then the-inspectorE?: job becomes.moretdidficult.- .

Obviouslyi the more desirable-approach is to have;th'e craft

~

. apply coatings in: a quality-consciou's manner. = I'did:not- '

intend for-this statement to imply that the practices at; c

Comanche Peak are;not compatibla ..

with my philosophy,'nor,did.

l the; statement'implyLthat coatingsat1ComancheLPeak have been-improperly . applied or appifed without regard to , quality.

F My, Trip Report also referred'to a'"no win" situation on.

site..between craft and QC inspectors. My impression wasi that the craft and inspectors were not functioning as a. team-

~

but rather each seemed to be doing its job without-regard for an integrated approach. My philosphy is that craft and in'spectors should work together in a harmonious relationship

+

to, accomplish the-objective. I questiened whether that l-L objective was-being; met at Comanche Peak based upon my b

[- assessment at the.. time that the morale of the inspectors was t-j; Llow.and that the attitudes of the craft and inspectors were L

p iin" conflict.

As I noted above, I expressed this point to L

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~s ite management!, which acknowleged that' moralo .was not high1 ,

and stated that they1were taking. steps'to rectify the

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' matte r. -

7 My Trip; Report-also discussed air. supply problems 4 experienced by1the. craft.^ The craft'was experiencing 1 problems'on site with the air supply forgspray painting or;

- sand blasting. The air apparently. contained water,or oil,.

and'the.craftiwas soending.a great deal of time correcting .

the problem,Lwithout-being ble to' sandblast orIapply. .

'e i coatings.- Mr.-Norris later provided. site' management with a "s -

description of equipment.that would solve the problem, and 4

. . my understanding is that the equipment was purchased. I

.n

have.'no-reason to believe that the air supply. problem adversely affected the. quaIity of applied ' coatings . because ~

management was aware of it and took appropriate steps to rectify it.

The summary of my Trip Report includes the' statement

/ that-Brown and Root-wanted to " buy the 'right' answer."

. That statement relates back to my initial impression that'~

Mr. Tolson was-disinterested'in quality matters. Again, my

' ~

reference to'"B&R" in the Trip Report was erroneous.

4 Further,'I am now convinced that my original impression of Mr.-Tolson'.s attitude.was also erroneous.

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-CONCLUSION.

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a:

MyLAugust'8,'19831 Trip Report reflected-myfinitial

.5

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" impressions conveyed".during aEvery short' visit!to-the site duringLwhich I had' little opportunity to diiscuss;my conc' erns - 4

~ ^ '

withisite management?. 1Myf subsequent in-depth discussions:-

~

with' sit's. management have' demonstrated'to'me that'my initial impressions wiere l i correct. LI-have.not-been induced-in any way tol retract my TripLReport, and I'have notlb'een sub'jected.

to any harassment, -intimidation' or threats by; rq employer,

the Applicantis"or anyone associated with: this proceeding.

. Indeed,'I was. asked-by the intervenor, Mrs. Ellis, to .

testify on-her. behalf in this proceeding,candLI~ tentatively r

agreed. My. testimony'would have been the-same had-I testified"for.Mrs. Ellis. It is' unfortunate that a Trip Report innocently prepared by me to advise my superior of my

~

'ob'servations andLconcerns in early August has apparentlyf F '

. ,. become the basis for a challenge to the adequacy of the-

- Comanche Peak coatings. program. As I have stated earlier, a

[

L the Trip Report,was based on incomplete information.

! Further, it-was not, nor was it intended to be, a final view i,

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of me or my company. It was merely input to the broader.

-diliberations that my company needed to undertake'in' order to fully evaluate the. adequacy of the ' Comanche Peak coatings

. program.

j l W J pg. pingy Subscribed and. sworn to before me this Jf d ay of September, 1984.

/

h '

Notary 'Pbt11'ic 8 l 4

'L_ - - _ ' _ ._ _ _ _ . _ - - - - _ - _ _ _ _ _ _ - - - - - - .__ - -

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