ML20106G634
| ML20106G634 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/02/1983 |
| From: | Tolson R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20106G461 | List: |
| References | |
| NUDOCS 8410310274 | |
| Download: ML20106G634 (38) | |
Text
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9 Cont er6 fact Poem Nc. ~c 10 visitcrs Inicrmation Center ~
Te::a s Utility Generating Cc::pany
.o . O . - c, ..<. 43.s,.w g3 .
Glen Rose, Texas 76043 s,
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Fricay, Decemoer 4, 13
'in e i n t e r vi e., cv..:..;e n c ec , ;u r s aa r.
to notice,-
14 6 15 at 1: 05 p.m.
. PM TIES P R E S I:.i T :
Cn echalf of the NRC Offace ci investi:ations:
18 h, bRCOKS GRIFFIS, Investigater i;O:< ALD D. F R I S *'. I L L , Investigator 19 C. S. suel+a: 3egulatcry Commission
- 010" l '#
"O
- l cil Ryan Pla::a Drive 5.:i . s 19 u i, l
krlington, Texas 76001 n,
On ce.alf of 'I e x t s Utility Generctin: Cc: .:.a n y :
3 iich'E.I L L nATKINS, II, ESC.
f.sebevoice & Lie t:e r:r.a n .
e4 120u Seventeenth Street, is . n,
,. Washington, D. C. 20036 a - - -
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'l P R' C C E E D I N G S MA. DRISKILL: Ecr tne record, tnis is an 3
interview of Ronald Tolson, spelled I-o-1-s-o-n, wno.is "I
employed oy Texas Utility Generating Company at Comanene 5
Pear: Stean Electric Station. -
6 The location of tais interview is the Nuclear Operhtions Support Facility at Comanene Peal: Steam ;
8 Electric Station located near Glen Rose, Texas.
9 Present at this interview are Mr. Brooks 10 Griffin, Investigator, NRC, and Mr. McNeill Watkins, II, t
II' I
.of Debevoise and Liberman, hashington, D. C.
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Enereupon, ,
I3 RONALD G. TOLSON I4 naving been first duly sworn cy Investigator Driskill, was i I5 examined and testified as follows:
! 16 1
EXAMINATION I
BY MR. DRISKILL:
18 O Just for the record, is Mr. Watkins acting as i
l9 your personal attorney?
O 4 A That is correct. .
ng e
Q Did you choose Mr. natkins as your personal i i
nn 8 attarney?
13
{ A I chose the firm. Mr. Wa-kins was seiectec and
28 I nave no proolem witn tne selection.
23 Q I believe tnat we have already infornally TAYLOE ASSOCIATES 1625 i STRf fT, N.W. - Sulff 1004 ,
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ciscussed the matter of wnether it is TOGCo's policy to riave counst:1 present and you stated that it was not a requirement that you nave counsel present, but censidering 4
tne circumstances here, vnicn are insomuch as we nave a court reporter present, you preferred to nave an attorney; 6
is that correct?
A Tnat is correct.
8 0 non, basically one of the areas I wantea to 9-discuss with you was the August 26tn, 1963 termination cf 0
william Dunnam as a protective coatinos quality control II lead inspector. I understand,~ based on conversations I I2 have hac with'others that your involyement in this matter I3 was somewhat limited, but I would like to discuss that 14 with you.
First of all, I would like to find cut wnen or f
16 on wnat occasion did you first learn or hear abcut II Dunha;a's conduct in a meeting which I believe was nelu 18 with coatings inspectors on about August the 24th, 19837 19 A I ciscussec this with Mr. Rice and told him it 20 was ettoer hednesday afternoon er Thursday morning. I 21 nave since checxed the gate logs and it r.ad to be Thurscay 1
22 morning because I wasn't nere on hednesday.
43
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Q And would you describe how thi s informaticn og
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carae to you? '
23 A 11r . Erandt apprised me of some input he.had t
?
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received'from people in the meeting, that Mr. Dunham was 2
cisruptive and that is basically how I found out about 3
what transpired in the meeting.
4 Q This sas on about tne morning o5 Augus,t 2Stn?
A That is correct.
6
.Q hat was tne setting in wh'icn he told this to you? here you having a meeting with several people?
8
-A I was in my office.
9 0 Did ne call you on the phone or dic he come to 10 see you?
11 >
- A He catae to my of fice.
[
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- Q Ano did Mr. Brandt tell you that he had a 4
4 I3 concern with regard to Dunham's conduct at the meeting?
34 I A I don't recall exactly what we discussed. I as 15 l'
le t with the impression that Mr. Brandt was seeking my j 16 opinion or advice on what, if anything, he should do II i relative to Mr. Dunham's conduct in the meeting.
]
18 Q cid at that time Mr. Erandt propose any sort ;
19
),
cf cisciplinary action to you? l 20 l A I do not recall. The only tning I recall of I
tnat session is how we jointly ended up ceciding on a
.,n i
. course of action that morning. I can't remember wnether it 13 was something ne recommended or sometning that I thought I -
28 l was appropriate. That is the reason I am pnrasing it the '
23 l way I am.
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Q Do you recall discussing this topic.at all in tne presence of Tor.'Brandt and some of tne etner people
- 3 wno attencec tne meeting?
4 A No. I think it was strictly between me and Mr.
5 Brandt. .
6 0 would you mind telline me what then you ana Mr. Branat ceciced you would recommend?
8 A Basically a formal counseling session ana tnree days off without pay. '
10 0 That was a recommendation you decided on on II the morning of Thursday?
12 A Yes, sir.
I3 Q Did you have any more discussions with Mr.
~l4
,Branct or with anyone else relating to this decision?
15 A Mr. Branct was cif site Fricay attending to 16 personal 'ousiness and I contacted with Mr. Krisher Friday II morning and asked him what the status was. I was told tnat 18 norning had transpired at snien time I changed the 19 reccanmendatico.
20
[ Q Sow prior to this discussion or talx witn Mr.
21 drisner, have you previously talxed with Mr. Purdy?
22 A I may have. I don't rememoer.
23 '
0 You nad not related to him ---
4 24 A I may have, or Mr. Purdy may have come and 5
l!
asked me did I Know what was going on. I just don't i
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O And would ycu explain te me again the reason?
3 a If you need to ta<e action, such as three days oft witnout pay, then you need to do tnat -- that should 4
have happened Tnursday. It didn't nappen Thursday, anc I
- nus enanged,it to just telling him that we dion't 6 .
appreciate nis attitude.
- old Mr. Purday later tnat day explain wnat 8
happenec after the counseling session with Dunham i: ycu?
9 A he came to my office alter the couns'eling 10 session, yes.
II 0' And snat did ne tell you?
3, .
A In essence he reiterated that .Mr. Dunham, and I3 I won't use vulgar terms, but had told nim to do something I4 with his counseling report and a few other things, anc 15 Goruon nad attempted to calm hin. down, did achieve that 16 goal anc escorted Mr. Dunham out tne gate, which I took as I
a resicaation on t'he part of Mr. Dunham.
18 2 Dia Mr. Purdy cccmunicate witn you curing tne 19 ceeting regarcing the termination of Dunnan.or his
'O cecision to tert..inate Dunham?
"1 A No.
<,n MR. hnTXIh5: you mean curing the counseling 23
,ses3 ion?
24
.MR . DRISKILL: Yes, I am sorry, I meant during 3
tne counseling session.
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- BY MR. DRISKILL:
E , !
Q Going back.to the previous day, curing your 3
discussion wita .w.r. Tolson or with anyone else recarding 4-the proposea cisciplinary a'e tion, .hien wat both tne counseling session and tne proposed three days off witncut 6
,c a y , did.you discuss what Mr. Dunham's reaction might.be to that?
A fo, sir.
9 -
Q Tnere was no discussicn then that ne might not 10 accept that or what his attitude might be with respect to i
11 enree days off or the counseling session and any other I2 disciplinary action that might be taken if nis anti uce 13 were wnat it was? '
I4 A Let me try to answer tne question this **ay, }
15 ano tne record needs to be corrected wnen you referred to 16 Mr. Tolson, because I don't ta l.t to myself.
II Q I am sorry. I thins I was referring to Mr.
38 3randt.
I9 A An action ci three cays off without pay or a0
, with pay, regardless of which, is designed to give the {
2I indivicual an cpportunity to tnir.k acout anat was said at toe counseling session and come cack in with a fresh mind 3 after the enree-day period so we can sit and talk a~ uout .
s tnings calmly anc rationally. That is really the best 3
ans.or I can give to what I perceive your question to be.
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Q Okay. Witn respect to Mr. Dunham, were you previously acquainted with him?
A Tnat is correct.
4 0 in wnat way?
a sometime, and the dates escape *me, I am 6
tninking June or July- something in that time frame, Mr.
I Purdy auvised me tnat one of tne paint inspectors, anc it 8
was apecifically Mr. Dunham, had some concerns, anc 9
concerns in tie area as I perceived it from hr. Purdy of 10 things that I needed to hear personally, at which time I II requested a meeting between Mr. Purdy, Mr. Dunham, Mr.
j, -
Erandt anu myself, Mr. Purdy, since he is the senic I3 representative for Brow. and Root and Mr. Brandt because 14 he is technically responsible for the particular area and Ib myself so 1 could hear firsthand wnat Mr. Dunnam's 16 concerns were.
1:
Q .And what were these concerus?
18 A Tne bottom line appeared to be that ne didn't 19 li<e Harry williams, and I nave read his lacor com.claint.
60 I frankly don't recall nim stating all tne tnings that he al claims to nave states in that particular session, and 22 specifically intimidation and narassment, et cetera. He 23 was emotionally di;turbed, or at least appearec to be, 23 upset, anc I assed, you know, specifically on a num'oer of 25 occasions, just, you anow, trying to come to grips witn TAYLOE ASSOCIATES 1625 1 STREET. N.W. - SUITI 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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I just what ne was trying to say. But the only thing I caine out.cf enat session with was, and I" recall asking him 3
point blans., cnat the bottom line appeared to be that he 4
cid not like Harry hilliams, at which time n,e, as I 5
recall, said, yes, that 'is part of my' problem. i 6
I dic not record this' session nor did I taae notes on wnat ne saic. I did promise him, as I sculd any 8
inspector, to conduct a follow-up preferably wnen the 9
emotions had settled uown so tnat communication could ce 10 cetter, and that follow up with him was conducted by-11 anotner individual on my staff. The_i.ndividual's report to s l'-
me verbally, wnich has subsequently been formalized, was 13 essentially tne same conclusion I came of the initial -
I#
session with, which was ne didn't nave a wnole lot of ;
I respect for Mr. Williams.
16 Q I see. To regress just a moment, what did Mr.
Purdy tell you Dunham's concerns were based on nis, that 18 is Mr. Purdy's converaation witn Dunnam?
I9 A I don't rememoar, except it was tne type cf "O
tning that I typically don't want to hear about. It very I
't likely includen a phrase sometning to the extent of that
^'
it we can't oc something he woulc go to the NRC and all a1 this kind of stuff, whien it is my job to take care of .
, 1 that type of thing.
U Q Mr. Purdy then didn't .nention to you tnat ,
t 4
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Dunnam nac said tney were being harassed or intinidated?
2
. ;t I will be frant, with you. I am not sure I Anow 3
wnat narssan.ent and intimidation means.
I really don't.
4 rnose are words wnien it is naro icr me to distinguisn or 3
associate witn any conversation because it*nas oeen a
, 6 gapic og lliscussion over tne last year coming cet of tne
~
entire group. I con't recall at this time whether those 8
woras were used. They could have been.
9
. Q hhen Mr. D'unham came to your. office did you 10
.maxe toe statement which is qu'oted here, " Boy, what is II tais bull shit about harassment and intimidation?"
I2 A Aosolutely not. The word " boy" is not in my
'I3 vocabulary. I was raised in Soutn Texas and we were taught I4 not to use tnat. I probably opened the conversation with 15 tne word "Eill," but I definitely never used the term 16
" boy."
I Q During the course of this meeting did Mr. !
18 3randt and yourself use an interrogation lixe manner in 19 questioning P.r. Dunham regarding hi.s concerns?
20 A I 6on't think we did, but again P.r. Dunnam aas 23 I guess in our pnrase bouncing off tne wall, very 22 emotional. Most of tne tal'<ing was done by him. he asked a U
.few; questions, anu I will asx questions any time anyucuy 24 gives me a generic statement. I am going to have to get it 25 oown to sometning specitic tnat I can come to grips wi-h.
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but as I recall, tne session was as calm as you can be un=er tne circumstances.
3 I tains he during the course of the 4
conversation nade a statement wnich I personally 3
consicered to ce out of line to so,ne extent of running to 6
the NRC or sometning 11<e that, nis quote in enere about
'I i me saying tnat now you are intimidating me is correct l l
8 because tnat is the way I toos his remar.<.
9 Keep in mind that all I am doing is sitting 10 tnere and gi'ing v tne gentleman an opportunity to tell me II firsthand Just wnat it is his problem was, because unless 12 ne tells me I can't come to grips with it.
d 13 Q he says that he told you and Mr. Brandt and I4 presuma bly Mr. Purdy tnat you didn't have to take his word 15 for it with respect to'what he was trying to tell you, but 16 other inspectors woulc basically corroborate what he was j saying. Did he mage that statement?
18 I A de probably did. j I9 0 and I uncerstand from tal'<ing to Mr. Brandt
- nn
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tnat .N r . Brandt did conuoct interviews of all of the !
,i personnel worcing in th'e coatings CC group subsequent to n,
that meeting to determine whetner in fact there were any 23 problems in that area.
24 A Tnat is correct.
25 Q Dia Mr. Brandt relay to you any inlormation or TAYLOE ASSOCIATES 1625 i STRitT H.W. - 1Ulf t 1004 WASHINGTON, D.C. 20036 (202) 293 3950
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part'of tne year. Part of my dilemma is tnat same scenario 2
was played in the hearings, it seems lite they was last 3
year, last sommer.
Q Did that have to do with the protective coctings?
6 -
A Yes, the nit-picxing phraseology. I am riot personally fai..iliar with a meeting of any kind in January 8
whera I came back and relate to tne nit-picsing.
9 Q .May. I ask whose testimony tnat was in the 10 hearings?
11 A Procably Hamilton.
l' Q And to whom did he attribute tness type ,
statements?
I4 A Mr. nilliams.
I Q Did Mr. Brandt relate to you so - quent to his 16 interviewing tne protective coating QC 1 is that I
Harry Williams or another supervisor subort. .e to Harry I8 Williams nao instructed coatings QC inspectors not to go 19 to Mr. Bran.lt's office or t3Ae advantage of Mr. Brandt's
'O open-coor policy?
- 1 A I don't remember taat discussion.
22 Q You don't recall nim telling you that he nad U cotained any such information? ,,
A flo .
U Q You said previously tnat you had another TAYLOE ASSOCIATES 162$ 1 ST8tti, N.W, $Ulf t 1004 WASHINGTON. D.C. 20004 ,
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suecrainate supervisor reinterview Dunham at a later date 2
. to cetermine exactly what his concerns were when he 1 3 previously came to your ofrice and I suppcse fins out wnat 4
the status of those' concerns might ce at that t i nie ?
1 5
- A ,
nell, to put it in my worus, Mr. Dunham -
6 I
appeared to oe en:otionally upset and we appeared to nave i
reached tne end of me being acle to get specitic input p a from him at wnien time I terminateo tne aession ana told i .
him th1t we would follow up and dic so but in a calmer IJ 4
way, i
l II Q May I ask who the supervisor was who I
1 reinterviewed him at a later date?
13 A That was Mr. Boo Scott.
14 l o And.would you again tell me what Mr. Scott's .
15 report back to you cons!sted of?
16
! A Essentially Mr. Dunaam didn't li'<e Mr.
II williams, as I recall.
j 18 Q To your knowledge, had Mr. Curiham explained 19 wny he didn't lite Mr. Williams to Bob Scott?
) 20 A 1 don't remember Mr. Scott and I discogning 23 that, but he may well nave.
Q Dia Mr. Scott give you any sort of written 23 l report? I 4
~
25 A !;ot at tne time. '
I had since asked nim a 25 j ,
couple of months later to sit down and provide me a r.emo
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on his recollection of discussion with Dunham.
Q Did Mr. Dunham or Mr. Scott as a resul of his 3
Later interview of Mr. Dunham relay to you that he feit 4
harry W1111ar.is was not allowing tae inspectors to properly 5
te' port deficient or non-conforming conditions?
6
. A ahat is proper?
I Q wnat he thougnt was the proper way. If you 8
will allow me to repnrase it, what Dunham tnought was a proper way. I don't want to miacharacterize what is right to ana what i= wrong.
i 11 '
A Tne intent of tne protective coating QC 32 progra.n has been and , remains that items which can be 13 hanaled enrough 4tandard repairs are to be encordeu on an I'
inapection report. Now my definition of proper is I
following the procedure. That is what the proccuure 16 requires.
I Q We had a discusaion earlier during Mr.
18 Grittin's in:erview where we talked anout tne use of l'
i inspection reports and tne use of non-coriformance reports.
"O I don ' t want to get into that in a lot cf detail, out ,
4 I i based on a lit,tted review of protective coatings 22 inspection proccuuros uuring the last several years, I 21 celieve that Mr. GriJfin identified a date somewhors in ..
2
- ao late fall or early winter of 1981 as a tin,e in wnich 23 ene pratective coatings uopartment began using an
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- I inspection report rather than tne previously used check 2
lists as a means of documenting their inspections; is that
- 3 correct?
4 I' A That is what I recall f rom our eai-lier discussion, yes, sir. -
{
6 Q Did the use of toe inspection report intend to i deny tne inspectors the right to use the non-conformance
~
8 f report?
9 A No.
10 0 If you could briefly, would you explaia or r
II #
differentiate between the purpose of tne two documents 1a subsequent to'the late fall or early winter of 1961 for i I3 toe protective coatings QC people?
I4 A 1 would prefer to reparase it without time t
15 restraiata of any time, because witn tne exception of *nat -
16 I call toe paper, it all accomplishes tne same thing. To II illustrate, the pre '51 check list, as we have used that ,
18 term, contained essentially all of the information that is t
^
19 currently reported on an inspection report, dry film
- O l thickness measurements, surface preparation, temperature j 21 and humidity readings and things that are importan , QC 22 characteristics to check during tne inspection process. I 23 I need his question back because I just lost l 24 my train of thought. .
,3 MR. GRIFFIN: He asked you the difference I
i TAYLOE ASSOCIATES 16251 STREET. N.W. - SUITE 1004 l WASHINGTON. D.C. 20006 (202) 293 3950 .
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d betseen tne NRC program and ocr program.
MR. DRISKILL: Not tne program, c'ut the 3
purposes of those documents. Just give a brief explanatior.
4 of what the purpose of tnose documents were in the 5
6 TnE v:ITNESS: They are both tailored to fit Criterion 16 or 17 of Appendix B whien requires tne 8
identification and documentation of discrepant items. The 9
inspection report is.used for those things that can be 10 re olved routinely tnrough the'QC cepartment and tne 11 -
crart.
I MR. DRISKILL: Between?
I3 THE WITNESS: It only requires those two levels I4 to coiamunicate and resolve discrepant conditions. In tne I
area of protective coatings I personally cannot conceive 16 of the situation that can't be handled on an inspection
" report. We have a situation where you are doing an 18 inspection to a prepared set of requirements and it is a I9 go/no-go situation. It either meets tne requirements or it i i
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doesn't. If it doesn't meet the requirements, most of tne !
1 7
time the re . olution is to repair it, if not all of the en
~~
time.
U The only time that it won't get into a repair ..
' 23 cycle is if for one reason or another the discrepant 25 condition is now in accessible, at which ti.ne the only TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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vehicle for resolving the discrepant conditien is a ncn-conformance repcrt. .
- 3 So, as we discussed with Mr. Griffin earlier 4
tais me*ning, one of the two or tnree ways of closing an 5
inspection report is to convert it to an ntn-conformance 6
report.
EY MM. DRISKILL:
8 Q And witn respect to the inaccessiale areas, o
tnat requires an engineering evaluation ana disposition:
10 is that correct?
II A 7 hat is correct, and we prefer to use a I2 non-coniormance report to accomplish that.
I3 Q Well, Ron, I don't thin.< it is any surprise to I4 me and probably not yourself that some of the inspectors believe tnat other areas require an engineering 16 disposition for evaluation and disposition.
17 A such as?
18 0 well, I believe that you have procably seen l9 examples of inspectors who believe that. At least they
'O have written hCR's waicn would indicate that where some of
'l tnem believe that tney are qualifiec to determine what perhaps is a generic type problem that needs to be 23 evaluated witn respect to the various technical aspects of
'4 coatings.
25 A I am sure that there are some of enem tnat TAYLOE ASSOCIATES 1625 i STREET. N.W. - SUITE 1004 W A SHINGTON. D.C. 20G06 (2021 293 3950
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rancy themselves as protective coating engineers based on
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the amount.of tne input that I have received over the past 3
few montns, but that is not what they-are employed to co.
4 They are employeo to inspect to a prescriced program and tnat is what I expect them to do.,
. The NCR's tnat I see are generally t, hose.that either my supervisors or craft cannot comprehend why hey 8
are escalated to that level because I do not routinely go 9
back and just look at every NCR by people. Obviously, 1 10 don't have tne time for that.
My evaluation of those tnat are brought to my 12 attention is the same as the people's that brought them to 13 me. I cannot ccmprehend why the people feel compelled to
" put them on NCR'3. A classic example. During concrete 15 preparation we used what is referred to as a recar chair 16 which is a plastic device, a small plactic device, w'e knew going in that the protective coating, particularly if an 18 abrasive substance such as overalls or shat-have-ycu comes I9 into contact si~.n tnat plastic that there sas a goed
'O possioility that the coating would flaxe or peal off, a et
~
i little small cnair.
Recognizing that, built into the construction
'3 procedure is a standard repair procedure for these ..
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'1
. situations. As I said earlier this morning, as we come 25 f down-trom tne top of tne reactor building to elevation TAYLOE ASSOCIATES 1625 I STREET, N.W. - SUITE 1004 l WASHINGTON, C4. 20006 (202) 293 3950 4
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I 831, any ana all of those situations ,will be identitiea i
. i a i ana resolved tnrougn stancard repair procedures. Why
- 3 certain individuals reel compelled to wander to 810 4
looking for flakes paint on rebar ciiairs is beyonc ne, out l 5
tney nave done it. .
i 6
After a few examples like tnis, i felt the I
need to bring a selective group of people in and tal.< to 8
tnem aoout it, wnich I did very calmly, very openly and in O'
essence pleaded witn them to let me nelp them uncerstand
.10 the prcgra:a because it seemed to me that pernaps they 11 didn't understand tne program.
o l'
Th'ere were a few examoles tnrown out along the I3 same lines of wnat we have talked about here today because I4 1 really find it hard to conceive of a situation out there I3 out31ue of the inaccessible condition that I cannot ,
16 '
properly document and resolve on an inspection report.
II After our exchange I asked tnem as a group dio I8 ** * "'S anyoody now have any problems and I got ne+449 but smiles 19 ana what I perceiveu tc be understanding at whica time .
"O they left and the following day I got anonner rebar chair 21 NCR. I con't Know what they are doing. It is not a 22 complicated thing for me. You map an area out on a wall U that you need to inspect and repair to make the coatings 24 on the wall meet the recuiretaents, you do that tasx and n3 you go away and you get on to something else.
s TAYLOE ASSOCIATES 16251 STREET, N.W. - SUITI 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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occurred I think it was the 7tn of October 1983 2
reincorporated 16.0 anc the NCR references loss of acnesion as being an NCR condition. Otherwise, the 4
i n s.t ec t ion report is the venicle.
5 THE WITNESS: Let me digress jbst a little oit 6
.and it' mignt help the conversation. You are correct on wnat you are saying here and I know what napper ed tnere.
8 Again, it comes bac.<, even in tne case of losc 9
of acnesion, I personally could nandle it on an inspection 10 report, but I could see where some of the inspectors coulo U not, so we decided to reinsert that condition.
In -
, Keep in mind what I am trying to do, anu tna:
13 is by I have got 15 revisions, is as we communicate with I4 the people anc cegin to understand what is ougging tnem or I
bothering them from a technical standpoint, then tnat 16 gives us a clue as to how to phrase tne inspection I
instructions so that they don't nave any concerns 18 wnatsoever about what their job responsioilities are. We 19 need to do that for tnem.
"O Between the one you referred to and the 21 previous revision, there must have been some questions 22 raised well, how do I nandle this condition. It nad not 23 been procedurally describea. So we went back and added 24 that specific condition. But again I could hancle that n8 with an inspection report also.
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MR. GKIFFI.N : -Well, the gist of out. questioning relates'to, and if you will accept for the moment tnat
-3 16.0 was excluced from Rev. 4 through Rev. 15, which is a period of two. years,-in the particular one I loo;ted at 5
wnica wasL4.1, if you will accept.that as being accurate,-
. 6 ene gist'of our questioning is during that period between
, -4 and 15-were CC inspectors discouraged or prevented from f, 8
.; usi g the NCR in that it didn't exist at least in so:ne of 9
the procecures or in some of tne quality ins'tructions? ,
1 10
~i Thti; WITNE.S$ : I have a harc time conceiving on !-
1.
33 how nat could possioiy occur because~there is. somethinc t ,
U g.
else I co as a matter.,of routine. Even thouga it may not' '
} 13 have been in that instruction, I will accept tnat for the time being, but I.will' reserve final decision until I-15
, actually look myself. Every one of the inspectors as part-t 16
-of tneir initial indoctriniation-gets exposec to GP 16.U.
1' j
1 There is a note that I wrote personally on 16.0, which 18 appears rignt on the front page, that in essence says that :
19 :
in the event of lack of guicance witnin inaividual '
l en t- inspection iactructions the provision of this procedure j
$ "1 snall go.
Now there has-been a few external critics that l
, ,3 C C r.s c s'e .
triea to get me to reinote tnat note which I refusec to ao -
n.
because I put it in there for an awfully goou reason. I ara ,
4
,3 act trying to discourage the icentification of i
4 t
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25 I
ciscrepancies. _I am trying to 6irect the effort to the most efficient methou for documenting those ciscrepancies 3
unich is certainly consistent with the requirements in 4
Appendix b and that is all we are trying to co.
MR. GRIFFIN: -Well, if.somepody makes a 6
statement to time parties involved say in tne hearings, and
~
nat statement is we are not allcwed to arite NCR's, and 8
then you start exploring that fact and in exploring it one 9
of the tnings.you go into is the quality inspections. Then 10 you find that for a period of time 16.0 has been deleted II from some ci toe instructions and you combine tnat sith 12 the testimony'of discouragement of writing NCR's er I3 instructions not to writ'e NCH's, it raises this-question I4 and tnat is the. reason we are asking these questions to 15 you.
16 ThE WITNESS: I am beginning to understand your U
dilemma, but again I think it deserves repeating. You got -
I8 I back an6 pull snat individual's traininc file that made I l
19 that statement to you and review the otner documents that a0 he has oeen exposed to as part of his indoctrination frcm
'l the QA viewpoint, anc then I want you to go bacx to guy
{
-- 1 that made tne thing and asi: him what his real motivation i f
U is. That is the thing I am having trouble coming to grips 24 witn, what is he motivated by. f
{
MR. GRIFFIN: The NRC's concern of course from '
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start to fini.sh is are they allowed to report the deficienc'ies.
ThE WITNESS: Certainly.
4
'MR. GRIFFIN: Regardless of tne forinat or the form tnat you choose, if the allegation is that their 6
reporting of deilciencies is :li.5couraged, it'is our concern and we explore the issues to the satisfaction of 8
the Commission.
~
THE WITNESS: I understand that, but there has 10 ceen no ciscouragement in their reporting of 11 discrepancies. I will.reacily aamit enat the instruction I2 procedures, or instructions is a better phrase, do lean 13 toaa$ds the use of an inspection report for accomplishing N tnat, but it an in:iivicual feels strongly about whatever it is, ne nas been given the procedural autonomy to use 16 a non-contor. nance report .'ts
. ." he so encoses.
All ne nas to I
do is pick up a phone and get a number. lio one can stop 18 him from doing that.
19
.Now if ne continues to identify tnings, like no the rebar chairs that you have got a standard fix for, I ni am going to call nim in ano ask him to use the inspection N report and I am going to do tnat every time.
"3 MR. GRIFFIN: I understand. .
24 TtiE WITNESS: All I am doing is managing tne n3 people.
[
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27 1
BY MR. DRISKILL:
Q Let me nsa you one question. We.ciscussed a
- 3 few minutes ago an indeterminate condition'. I believe we 4
used tnat pnrase; is that correct?
A That is correct. .
6 ~
0 would you ueJine what in your mino that is?
A Micsing records is a good examplo. Susoected 8
internal damage that you can't see is indeterminate.
9 Virtually any Part 21 that I receive is. indeterminate
,- 10 because I never know wnat they are talking about for two II or three montns until they get arouno to writing all the la-reports. A lot of 50.55(e's) are indeterminate, 13 particularly since we use the term potential which'really I4 isn't in tne law, out we have learned to use it because it 15 '
mates the conununication between us anc the Cemn.ission 16 better. There are probably some more, out I can't think of II them off tnc top of my head.
18 Q for the average inspector, anc we will use tne 19 protective coatines inspector since that is tne area that 20 we are talking about, if ne comes across a condition whicn al for some reason or another he feels unable to evalaate 22 basec on wnat he has before him or something of that
- 3
nature, could he identify that area as an indeterminate 24 condition?
25 A He can and I think that they have.
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Q Have you ever instructed personnel to use the inspection report to report indeterminate conditions?
3 A- no, sir.
Q You have instructed them to use NCR's to report indeterminate conditions? ,
6 A I honestly can't recall ever discussin'g one, .
wa s or the other witn any of.the inspection force ahich i 8
piece of paper you use, except for that group that I 9 . . '
mentioneo earlier.
10 0 Well, for instance, in tne context of that i
11 particular meeting witn that group, did you discu.ss that?
10-A Yes, we discussed the _rebar chair issue, and I3 tne way I left tnat with them, you know, tnat rebar chair N
is not going anywhere and when we get to that level we I
will pick it up on an inspection report.
16 Q Did you discuss the issue of indeterminate I
concitions?
18 A 1 don't recall tnat. If you confine and think j t
19 in terms et tne inspection function, they don't run onto
'*0 many indeterminate coi.aitions. It is when they decide to i
ng 1
go cutside the scope of the inspection function that in- '
nn tneir mino it mignt be indeterminate. To give you an "1
exataple , dea testing on the coatings themselves. Fro,n 24 their viewpoint that is indeterminate. Frota my viewpoint n
3 that is outside the scope of tneir joo and don't worry TAYLOE ASSOCIATES 1625 i STREET, N.W. - SulTE 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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about it. That has come up.
Q So in most situations you would censicer an
- 3 inacterminate condition something that eitner you or your
' 4 subordinate supervisors would encounter with respect to 5
testing or the adequacy of documentation and tnings of 6 '
tnat nature, rather than an actual inspection finding?
I A In the area of coatings that is definitely 8
true.
9 MR. DRISKILL: Let's take a brean for a f e *-
10 minutes, 11 (Brief recess.)
I2 HS. DRISKILL: We can go back on the record.
13 Ron, I have got one otner area tnat I would I4 li<e to discuss.and that has to do with tne memo generated 15 by J. 3. Lipinsi:y of O. B. Cannon and Sons, Philadelpnia, 16 Pennsyivania.
II The first thing I would like to ao is I would 18 lixe to ask you to ---
19 an. h4TKIns: Can we identify tne memo? Do you 60 have a copy with you?
al MR. DRISKILL: No, unfortunately, I don't.
22 MR. GRIFFIN: Maybe we could identify it as an 23 internal O. B. Cannon meme allegedly generated ' cy Mr.
23 Lipinsxy followiag a two or.three-day site visit here 25 related to coatings. Is that descriptive enougn?
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MR. DRISKILL: It was ' a memo written to R. B.-
Roth ' whof was- the Pre:iident of O. B. Cannon, and Mr.
'3 Lipinsky characterized that document to me as a. trip i
- report to his boss'and a document shi.ch was intended for 5 .
Internal O. d. Cannon use. Somehow the document got into 6
tne' public 6cmain.and I received a copy of it.
I understand.tnat you, Mr. Tolson,. nave had 8
the opportunity to review it and tal.k witn Mr. Lipinsky about some of the statements ne made in.that internal I
memo.
11 ThE WITNESSi That is correct.
l'
. BY MR. DalSKILL:
13 Q First of all, I would li<e'you, i f you woulo,-
- I4 to characterize that memo with respect to its accuracy and
- I impact that it may have had on your coatings program.
16 A Okay. Relative to accuracy, it is my 1'
considered opinion based on some nine years of experience 18 on Comanene Peak that it is totally inaccurate. I'think it ,
M f
i.s not too mucn unlike what we have recently experienced J
'O witn the NRC CAT inspection where a snapshot of preceived og
~
conditions gets committed in writing without benefit of a f
i 22 full discussion and evaluation. In my judgment, that is 23 l
what has essentially nappened with the "Lipinsky meno."
2I l
We did ciscuss-it and we went over and corrected many of Cne errors that were in there regarding TAYLOE ASSOCIATES 1625 i STREET, N.W. - $UITE 1004 WASHINGTON, D.C. 20006 (202) 293 3950 1 -
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I who workeu.for who. We discussed possicle reasons at least l 1
i
-3 at my level for why Mr. LipinskyLeoncluded what he did
- 3 relative to me personally in tne protective coating
'4 orogram.
5 I met with nim the second day ne was here for, 6
as.I rec'all,' no more than five minutes. I remember little, if anytning, of toe aiscussion. I perceived tne purpoee of 8
him coming to my office was to introduce him:, elf. My o'
purpose was to get him lashe'd up witn Tom Brandt because I 10 thing at tne time I was' late for a meeting. So I was a 11 little bit short witn him.
i I2 Ou.r next exposure was at a discussion the 13 following day wnere the statement was made of something to M
the efiect tnat ne didn't think we met all of the AFSI 15 requirements. I asked for a specific example or examples 16 of hat he waii talking about at which time I think ne saic U something to tne effect of well, I can't answer that 18 without a detailed audit, and I probably said something to i
- 19 the extent that I am not interested in an audit, that 60 wasn't the purpose of O. B. Cannen ecming in, wnich he al took, as nest as 1 can perceice, as a negative. attitude on
- .n the part of QA laanagement.
23
What I did not discuss with him at tnat 24 session, but have since, is there is an awfully good 25 reason for me not encouraging an audit. I have had botn TAYLOE ASSOCIATES 16251 STREET N.W. - SulTE 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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32 I
cachnical and O&I investigations on protective coatings 2
since the 1st of January virtually continuous. I am at 3
this time unaware of any technical problems. I have had at leasr six cocporate QA audits of protective coatings in tne last year anu I am unaware of any technical problems 6
ana I ;ust con't need another audit.
Q To regress Just a moment, wnat was the purpose 8
of Ar. Lipinsky's visit?
9 A I don't <now, because he was not retainec by 10 the GA' side of the' house. Cannon was brought in by Mr.
11 Merritt who is the Assistant General Project General 12 Manager to provide an overview of tne protective coating 13 production work, and now Mr. Lipinsky came down here, I I4 haven't got the foggiest idea because ne was not retained '
to provide QA services.
16 Q dow long was Mr. Lipinsky here?
I' >
A His trip 'eport r indicates three days and I 18 can only accouat for one of tne three days, or two of the 19 taree days. I don ' t know wnat he was doing the first day.
"O I met oriefly with nim on tne second day and again
-' l sligntly longer on toe third day when we got togetner in a >
n, conference discussion.
U Q There were a couple of things in that memo 24 that I wanted to ask you about, one of whien was Mr.
5 i gipinggy.s statement that he had learnea from interviews TAYLOE ASSOCIATES 1625 1 STRf!T. N.W. - SUITE 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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with Erown anc Root, TUGCO or someone else that approximately 30 of li.ke 450 personnel doing coatings scrk
- 3 were actually qualified to At;5I standards.
4 A speaking in an order of magnitude type of A
discussion, tnat is not too far froir. the truth, but'you 6
have got to be careful with, and'I think'he used the term
" painters," and that is an unf air or an _ untruth. There is 8
a lot of work force involveu in masking _anc sancing and 9
things of that nature wnich do not require painters. It is 10 a labor force, if you will.
II There is a heavy number of laborers as oppotec I2 to the number of " qualified applicators" that ,it cases to 13 perform the painting anu they are ascisned to the paint 14 department, but they are laborers.
15 Q Are enere painters who are not qualified to 16 Ar!SI standards?
17 A No. That is not what he is trying to sa" .
18 t tnere. The way he phrased it, you are left with the .j i
19 impression that out of the 454 painters we have only got k
l t
20 34 that have teen qualified and that is totally incorrect. '
21 e That is not what ne intended to say.
f' Q Another statement that he mace in the memo
,3 related to the A.s1SI requirements and how a posalble
- .. c
{
28
- - failure to meet those requirements at Comanche Peak might )
impact on the licensing proceeding.
- 1
)
i i
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e.
34 I
liith respect-to that statement,' he indicatec I n 1 cnat you in response to him made a statement to the effect 3
that you had no interest in the licensing proceeding or--
4 sometning to tnat effect.
5 A Let me digress just a minute. The only~
6 opportunity se had! for tnat type of a discussion Eas the
=craing of t.se second day that he--claims to have oeen l 8
- here. If you will simply look at his trip report and what 9
he accomplishea the first day, which basically boils down 10 ~
to getting badged in and talking to a.few folks, he ha=
I 11 hardly had time at that point in time to either come to j 6
1"
, preliminary conclusionc or final-conclusions ci any kind.
13 Now it is very li'<ely in our brief ciscussion I4 that seconc morning that he got around, and he thinks ne ,
is I talked about the stuft he put in his report, I don't j 16 rememoer it. We probably used tne phrase " licensing." Ihe intent of my ouote that got in tne memo is that I am not 18 I responsible for licensing the plant, which is true. I am {
M responsiole for quality contrcl of the plant," but there is i "O
I l
4 anotner manager that is responsible for licensing. That is
'l not me. I wanted him to understand that so that we cidn't 22 get into a lengthy discussien of licensing proceedings. I U
did'c even knaw why he was there and I~certainly didn't 23 want to spend the entire day discussing now to license a 23 nuclear power plant and that was wnat I was a f raid we TAYLOE ASSOC!ATES 1625 i STRitT N.W. - SUITE 1004 1
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mignt get into.
n C As I celive we have alreacy establisned, you I had the opportunity to sit down with Joe Lipinsky at a later date and discuss tne contents of ni-s i.nternal memo.
A That.is correct. .
6 0 I would li<'e to asx you were the two of you able to resolve so.ne of his apoarent concerns witn respect 8
to tne protective coatings program?
o A In my Judgment,*yes. I think if you were to 10 asx the same question of Mr. LipinsNy, nis statement would II
, be something to the effect that if we are in fact doing l'
wnat I tolo him we were doing, then he has no problems. He 13 is a f airly conservative indiviaual and conservative 34 people'will seldom make positive statements unless they 15 are afforded the opportunity to perform, in nis words, a 16 detailed audit, wnicn again I think I have already U explained. I cannot justify another one at this point in 18 t i .ne .
19 Q Sc you telt that as a result of your meeting 20 with him that he was sa tis fied that some of tne areas in 21 which he hac concerns were procably less a concern than ne t2 han originally oelieved if in fact your explanations i 23
regarding those specific things were true?
23 A I would li<e to be a little more positive than 25 that I would think that all of his concerns had been TAYLOE ASSOCIATES 1625 i STREET, N.W. - Sulff 1004 WASHINGTON, D.C. 20006 (202) 293 3950
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~
~
36.
resolved and not.just some of them.
x_
MR. CRISKILL: I don't nave'any other 3 .-
qcestions.
, (
4 .
MR. WATKINS: Can we take just a short recess? ,
5 (Brief recess while Counsel Natkins and Mr.
6 ~
_Iolson confer outside tne conference room.)
MR. CRISKILL: Mr. Tolson or Mr. 6atkins, co l either of you have anything to ado before we close?
9 TtiE WITNESS: No, sir.
10 MR. WATKINS: I don'to t
I 11j MR. DRISKILL: Mr. . Tolson, nave I or any otner 8 l'
NRC representative here threatened you in any manner or
~
13 offered you any rewarcs in return for tnis statement?
I#
THE WITNESS: No, sir.
MR. DRISKILL: Have you given this statement 16 freely anc voluntarily?
THE WITNESS: I was requested to be here and I E
am here.
19 MR. DRISKILL: Thank you.
O Is there anything further you care to add for !
e !
i tne record? s on THE WITAESS: No, sir.
,3 (Whereupon, at 2:25 p.m., tne INTERVIEW OF 43 RONALu G. TOLSON concluded.)
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C2.nTIFICATE OF PROCE h.01 HGS 2
- 3 ih i .3 la to certliy tnat tile cttacnec proceeair:gs cf toe 4
Interview of RC:;.sLC G. TCLSON oetore the of .ce cf 5
Investigations at Texas Utility Generatird Company, 6
Co:nanche Peaa steaa Electric Staticn, Glen Rose, Texas 766-;3, on Ericay, D e c e..s o e r 2, 1983, commencing at 1: 05 8
p . a. . , was held as nerein appears, ano that tnis is tne 9 . .
criginal . transcri,ct for tne 111es of the Or... rice er.
10 Investigations, Region IV.
11 10 -
13 Mary C. Simons 14 15 Official Reporter - Typed 16 -
1:
___ __ % _____ M C % __________
18 Ofricia1 Repcrter - Signature 19 20 21 20 23 .
24 25 TA LOE ASSOCIATES 1625 1 STRitT. N.W. - SUITE 1004 WASHINGTON. D.C. 20006 (202) 293 3950
TEXAS t TILITIES GENERATING CU.\ll'ANY m: . us n. c r. .__o :t w -u. .
.. c...
Decemoer 13. 1953 Txx 4057 John Collins Recier.ai Administrator -
U.5. hu lear Regulatory Commission 611 Ryan Plaza Dr. Suite 1000 Docket hos.: 50 'z:5 Arlington, TX 76012 -50 446 COMANCHE PEAK STEAM ELECTRIC STATION INVESTIGAT10 tis IriTO ALLEGATI0fiS FILE NO.: 10066
Dear Mr. Cellins:
. In accordance with our agreement, enclosed please find a copy of the report of our investigation into allegations made by W. A. ,
Dunham and concerns expressed related to protective coatings. -
Very truly yours, RJG:In
.y -
EnCiosure cc: lGC Region IV (0 + 1 copy)
Director, lnspection f. Enforcement (15 copies)
U.S. Nuclear Regulatory Comission Washington, DC 20555 l
L l
x y I ,,5 i r: m
- 7 c< E~.ilb1T (23 v- a v sv 0V L w J
~d 6*3 M L2 [.N M.51;Ti k h7 [ E'NUTM b 'I ~
~ " ^" ' U A' ' 's ~ '" ' - - ~ ~
r .
. CC-cEl TEXA5 UTILITIES GENERATING COMPANY OFFICE MEMOF. ANDL*M To D.N. Chao.ar' DaUns.Texa, Octobe- ?5. 1983 Subject INVESTIGATION INTO ALLEGAT!ONS MADE BY W. A. DUNHA" AND CON.iRh5 EXPRESSED REuTED TO PROTECiiVE COAllN55 In accordance with B'.R. Cle ents' memo dated September 19, 1983, to D.N.
Chapman, an investigation was conducted into allegations made by William (Bill)
A ndy Dunham. Bill Dunham, in filing Form B-3 (1282), Initial Claim for Benefits, with the Texas Employment Commission, indicated in part, *! was fired for identifyi ng quality problems .. ."
The investigation was basically a two part investigation. The first part included discussions with Bill Dunham, with other inspectors he suggested I talk to, with persons attending a meeting between the Corrosion Engineers and QC Coatings Inspectors on August 24, 1983; and persons present at the counseling session on Augu'st 26, 1983. The purpose of these discussions was to detennine if Bill Dunham had been dismissed for iden'ifying quality problems.
The details of the first par.t of the investigation are included in Attachment A. The allegation that Bill Dunham was terminated for identifying quality problems wa s refuted.
The second part of the investigation followed up on matters initially brought up during the first part of the investigation. .
The rest of the coatings QC inspectors, both day and night shifts, were also i nterviewed. In addition, Mr. Harry Williams, the forer Coatings QC Supervisor, was also contacted at his present job. In addition, TUSI Engine'ering personnel were interviewed and engineering documentation which supports engineering decisions was examined.
Basically, six technical concerns were voiced during the investigation. These
~
itms are detailed in Attachment B, Part 1. The technical concerns were discussed with TUSI Engineering and with the Principal Corrosion Engineer for Ebasco. The Gibbs & Hill Specification AS-31, " Protective Coatings," was reviewed. Industry standards referenced in the G&H specification, and site procedures for coatings application and inspections wire also reviewed.
The validity of each of the technical concerns was evaluated in light of specification requirements and requirements in referenced standards, Engineering positions were evaluated in light of r.anuf acturer's recuamndations and where deemed necessary, Design Basis Accident (DBA) testing reports were examined to further assess the validity of engineering conclusions.
On the basis of the above, the technical concerns expressed by the inspectors i were found to be u%arranted.
(
1 l
l
QTQ 481 10/25/53 fage 2 The allegations of harassment, intimidation, and threats were investigated.
The results of thi,s inve.stigation are detailed in Att achment.B, Dart 2. These' phrases had varied meaning to different inspectors. Also, the related actions were been differently among the inspectors, and perceptions varied from normal occurrences to improper actions. These discussions were highly subjective.
In sumT.ary, ins pectors worki ng under the previous coating QC Supervisor, Mr.
Harry Williams, perceived less than total support from him. Mr. Williams, contacted at his present assignment, stated that he would provide support when inspectors were right but could not support an inspector when wrong. He stated that these disagreements came about primarily because of inspector beliefs that procedures reflect unacceptable technical practices. However, better supervisory practices at times of disagreements would have helped to minimize the adverse morale effect. Morale problems are worsened by a small, but very vocal and articulate, group of inspectors who appear technically knowledgeable, ard who have a disproportionate enount of influence within the Protective Coati ngs QC force. The incidents related were relatively few and none of these incidents resulted in inspection anissions which constitute a safety concern.
It is recommended that a procedure be established on site, by which craft can appeal an inspector's decision, that prevents the atmosphere of confrontation that arises when craft and QC supervisors become involved. This procedure should be consistent with good supervisory practices when there is disagreement between the inspectors and their supervision.
Kanagement actions relevant to previous allegations were reviewed. These are detail ed in Attachment B, Part 3. I have concluded that these investigations properly covered the scope of the allegations made at that time and that management actions taken as a result of those investigations were appropriate in addressing the problems identified at that time.
Inspectors' concerns related to the Protective Coatings Program at CPSES were evaluated and detailed in Attachment B Part 4. The investigation concluded that the use of the IR UNSAT instead of the NCR for &ctivities that can be reworked to meet engineering requirenents is consistent with 100FR50 Appendix B. However, there appears to be a need for additional traini ng on the use of the IR to address missed hold points.
In addition, inspectors expressed a programmatic concern that there are no provisions by which inspectors can express technical concerns and obtain f eedback. The TUGCo " hotline" could be used to address this concern, although a policy decision must be made to define the extent to which inspector technical qsestions are to be ar.swered, especially if other disciplines are i r.vol v ed .
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10/25/53 page 3 Another concern related to the program is that there are no provisions for recertification of coatings applicatio' n personnel. The engineering s>acification aM referenced industry standards do not specifically require rec erti. fica tion. Hosever, this area will be audited during the week of October 31, 1983. Any areas found- deficient will be handled in accordance with approved procedures.
During the investigation, two manage'nent items that are significantly affecting inspectors were noted. These are. detailed in Attachment B Part 5. The inspectors state that they have been working six 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> days per week. They state they -have been on this schedule since May of 1983. Inspectors state their proficiency, objectivity, alertness, and tempers are suffering. There appears to be an urgent need for additional Protective Coatings QC Inspectors.
.This item was brought to the immediate attention of site and Dallas QA ma nagement.
The second item is one of a perceived campensation disparity between Ebasco and '
B&R inspection personnel. B&R inspectors note that all Coating QC Supervisors are Ebasco personnci. They state the client does not want B&R Coatings QC Supe rvi sors.
In addition, they state that Ebasco personnel get sick leave, paid holidays, per diem, and regular salary, while they do not. They state that this is the most significant item affecting morale. They state it has surfaced in Coatings but is festering in other areas, including Electrical and Mechanical disciplines. This item was brought to the immediate attention of TUSCo site aM Dallas QA management.
I have two additional observations which are of concern. Fi rs t , some inspectors interviewed appear so hostile that I believe they are adversely affecting the Protective Coatings QC Group in parforming its assign ent.
Secondly, the refusal on the part of some inspectors to recognize Engineering decisions on technical matters, aM their refusal to accept QA Management decisions such as the use of the IR in lieu of the NCR, constitutes insubordination and creates an un .anageable situation..
i W Antonio Vega AV/brd A t t achme nt l
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. ATTACFMENT A e
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. t DETa!LS:
In accordance with management directives, an investigati.on was ir.f +iated on Sept emaer 19, 1953 to investigate William A. Dunham's allegation that he had been " fired for identifying quality problems."
Prior to any discussions, Bill Dunham's personnel file was reviewed to obtain a basis for further investigation. ,
DISCUSSION n'ITH W. A. DUNHAM- -
On Septe.ber 20,193'. Mr. Dunham was contacted and ady' sed of the purpose of the investigation. Mr. Dunham's initial statement was that he want ed me to know that he had previously reported his supervisor, Harry Williams, to the NRC; and to Tom Brandt, Gordon Purdy, and Ron Tolson, for intimidating, harassing and threatening his inspectors. He suggested that I interview certain inspectors to obtain details.
He stated that when he initially reported his concerns to Mr. Purdy, he was promised confidentiality. Mr. Dunham stated that his objective in going to Mr.
~
Purdy was to request a transfer out of Protective Coatings QC. He stated he was called to Mr. Tolscn's office the same afternoon he talked to Mr. Purdy and therefore feels Mr. Purdv did not keep his promise of confidentiality.
Mr. Dunham stated that on Tuesday ( August 23,1983) he was advised that he could not have Friday ( August 26,1983) as his day off. He came to work on
! Friday, and at 4:00 p.m. went to Gordon Purdy's office. Dunham stated Evert Mauser, "Curley" (Krisher) and Purdy were there. He stated none of these ~
persons were in his supervisory chain of command. He stated the meeting lasted two minutes and that it was a " set up."
He stated that Harry Williams, his supervisor, was not present; that Williams had missed that day because Williams knew that he (Dunham) was being fired. He further stated that he did not consider Purdy his supervisor.
1 I asked him about the meeting with the Corrosion Engineers. He stated that he had raised his hand before speaking and that he had spoken the truth. I asked him what he had said in this meeting that was considered disruptive. He i
replied, "I'll tell you in court." He stated that he considered me an i a dve rsa ry. He suggested I contact several inspectors.for details of " safety l problems."
I i
DISCUSSIONS WITH CPSES SITE PERSONNEL:
In regard to this phase of the investigation, Messrs. Evert Mauser, M.G.
"Curley" Krisher, C.T. Brandt, R.G. Tolson and the suggested OC Inspectors sere i nte rvie wed. In addition, Thos. Kelly, Principal Corrosion Engineer for EEASCO, was interviewed.
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Fage A3 Tne substate of several key events was establishec llows:
- 1. On Wednesday, August 24, 1983', a oteting was arrange tween the corrosion Engineers and the QC Inspectors for the pur, of discussing changes mace to the procedures, their technical basis, . , to answer any technical ouestions that the QC Inspectors might have. During this meeti ng, Mr. Dunham persisted in bringing up for discussion, non-technic 1 supervisory protlems. In addition, Mr. Dunham was reoorted to have. made gestyres o.f hopelessness with' his hands and verbal comments, following statenents from the engineers, that were considered rude and ouestioned the competence and integrity of the engineers.
- 2. Following this meeting, Curley Krisher, representing Tom Brandt at the meeting, discussed with Mr. Dunham his behavior at the meeting. In addition, Mr. Kelly visited Mr. Brandt at his office to express his adverse feelings about Mr. Dunham's conduct at the meeting. Mr. Brandt met wi* h Mr. Tolson and Mr. Purdy. Mr. Tolson decided that Mr. Dunham should be fomally counseled and given a three-day furlough without pay.
Mr. Tolson directed that this be done'as soon as possible. Mr. Krisher was . assigned the responsibility to prepare the counseling report.
On Friday, August 26, 1983, Mr. Tolson inquired as to the results of the counseling session. Mr. Tolson was advised that the counseling session was scheduled for 4:00 p.m. that day. Mr. Tolson advised Mr. Brandt and Mr. Purdy that their failure to conduct the counseling session sooner would render the three-day furlough ineffective. Mr. Tolson directed that the three-day furlough be. eliminated and that Mr. Purdy limit his action to a counseling session. Mr. Purdy acknowledged Mr. Tolson's directive ard concurred. The counseling form was prepared on Friday, August 26, 1983. During the day on Friday, Mr. Brandt's secretary called Mr. Dunham g to obtain his badge number, since it is required to be shown on the form. ,
- 3. The counseling session took place in Mr. Purdy's of fice. Because Mr.
Purdy is the top BE QA/QC representative on site, Mr. Purdy personally conducts disciplinary meetings involving BH employees. Mr. Mauser was representing Mr. Williams who had telephoned in sick with back p oblems.
Mr. Krisher was representing Mr. Brandt. Mr. Purdy started the session by handing to Mr. Dunham, a copy of the counseling report. Mr. Dunham reviewed it briefly, apparently not reading it all, and threw it back to Mr. Purdy, saying either: .
"(Expletive deleted) it -- you might as well walk me to the gate because I'm not going to change," or,
"(Expletive deleted) you guys -- you might as well walk me to the gate. I'm not going to change the way I am -- just walk ne to the gate." or, "No, damn way. I've had it. You might as well get my time and walk me to the gate." (Saying later, "ho (erpletive deleted) wsy -- this ain't gonna (expletive deleted) work -- I don't have to take this shit.")
Fage A4 Mr. Durdy made two more efforts at asking Mr. Dunham to settle doc and to discuss what was perceived as an attitude problem. These ef forts were
. answered with similar comments by Mr. Dunham. Mr. Purdy asked Mr. Dunham if he was sure 'that "this is what you want." After Mr. Dunham's response, Mr. Durdy said, " Fine, let's go." Mr. Purdy then entered a handritten sum.ary of what transpired in the counseling session on the counseling report, a copy of which is attached as Attachment 1.
Mr. Mauser accompanied Mr. Dunham to the QC trailer to collect his personal belongings. Mr. Krisher later joined Mr. Mauser and Mr. Dunhn at the QC trailer. Mr. Krisher accompanied Mr. Dunham to the time of fice.
where M . Dunham's brass and badge wa: picked up. Mr. Dunham ;;igned the teminatio , fom, "(expletive deleted) Lie." This temination fann is atta:hed as Attachment 2.
On the basis of the above, I have concluded that Mr. Dunha.7 was not tenninated for identifying quality problems. Mr. Dunham's conduct and statements at the counseling session, in substance, constitute a request for voluntary temi nation. Mr. Purdy prepared and signed a temination fom which was .
rejected by Mr. Dunham. -
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ATTACHMENT B e
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-DETAlts:
- 1. Technical Concerns -
During the course of the investigation, inspectors collectively brought up the follond ng technical concerns:
- a. Zinc primer is being applied. The primer is then water cured for two
! (2) hours, and a top coat is applied immediately thereafter.
According to some inspectors, this is too soon. .
- b. The " nickel" test (where a coin is used to test the curing status of the primer) should be'used in conjunction with curing tables, taking account for humidity and temperatures. At CPSES the " nickel" test is used exclusively to test primer curing.
- c. The substrate profile on hangers is too slick for proper adherence between it and the crimer. L
- d. Instances have been identified where zine primer is being applied over Phenoline 305 topcoat and questions whether this has been DBA (Design Basis Accident) tested.
- e. Successive coats of zinc primer are being. applied. Inspectors state that primer will adhere to substrate and to topcbat, but not to i t s el f. They cite this as a reason for delamination within the primer thickness between successive applications.
- f. Storage provisions, including compatibility among primer and topcoat batches manufactured during different time frames; and pot life-restrictions on zine primer.
Interviews with engineering personnel were conducted to assess the validity of these concerns. The results are as follows:
- a. In regard to water curing time of Carboline CZ-11 zinc primer, prior to topcoating, the following documents were reviewed:
- 1. Gibbs & Hill Specification 2323-AS-31, Rev.1, v. arch 15,1978,
" Protective Coati ngs" ,
, 2. ANSI N101.2, " Protective Coatings (Paints) for Light Water Nuclear Reactor Contai nment Facilities"
- 3. ANSI N5.12. " Protective Coatings (?aints) for the Nuclear I rdustry"
- 4. ANSI NIO1.4-1972, " Quality Assurance for Protective Coatings Applied to Nuclear Facilities"
! 5. TUGCo Procedure Ql-QP-11.4-5, " Inspection of Steel Substrate Primer Repair and Seal and Finish Coat Application and Repair" I 6. B&R Procedure CCP-30. " Coating Steel Substrates Inside Reactor l Building and Radiation Areas."
__ . _ , . _ ~ _ _ _ _ _ _ _ _ . .. _ _ . _ . - _ _ _ - - -
Page B3 Tne first four documents do not impose any QA requirements on testing for price coat curing. The document that addresses curing is B&R Procedure CCP-30, which is referenced by TUGCo Inspection Procedure QI-OP-11.4-5.
This procedure bears the approval signature of a TUSI Engineering reo esentative. This document, on page 8 para 4.4.1.1 permits the use of either curing tire tables cLr, the following:
" Carbo Zinc 11 is sufficiently cured for top coat when the coating's may be burnished rather than removed when rubbed with the flat portion of a smooth edged coin such as a nickel." This same paragraph further states, in pa.rt, " Application of water spray for curing purposes may be as of ten as necessary to obtain proper cure."
This acceptance criteria is endorsed by the manufacturer, Carboline Company, in a Telex dated 1/23/80 which -states, in part, " Carbo Zinc 11 is sufficiently cured to topcoat when the film is able to burnish when scraped with a coin, rather than removed." In regard to force curing with water spray, a Telex from Carboline states, in part, " Force durirg of Carbo Zinc 11 by fine water spray or low pressure steam is acceptable prior to topcoating Carbo Zinc 11."
The documentation supports the following conclusion:
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- 1. Forc'ed water curing is an acce'ptable process that may be used as often as necessary to obtain proper cure.
- 2. Topcoat may be applied after proper primer coat cure has been obt ained . The detennination of cure can be based on curing tables which require time, temperature and humidity measurements, j!( physical testing of the coat for a burnish,
- b. In regard to the use of the " nickel" test exclusively without concurrent use of the curing tables, iten a. above adequately addresses this concern. There is adequate justification for exclusive use of the " nickel" test as a physical confinnation that proper curing has been obtained.
- c. In regard to the concern that the profile on hangers is too slick for proper adherence between it and the primer, the following documents were reviewed: .
- 1. G&H Specification 2323-AS-31, Rev.1, March 15,'1978. In paragraph 4.2.a. it requires that the surface preparation of ,
substrates conform to the applicable requirements of ANSI 101.2 a nd lists sona exceptions.
- 2. ANSI N101.2 under Section 6.3.1, Carbon Steel, states, in part, "The surface shall be cleaned in accordance with SSPC-PS-10,
, 'Near White Blast Cleaning' ..."
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- 3. S&R Procedure CCP-30, Rev.11, dated 8/16/83 in para 4.1, Preparation of Substrate's and Coating Materials, states, in
. part, "The surface shall then be cleaned by blast, hand, or -
power tool operation to achieve a surface cleanliness equal to SSPC-SP-10 ' near white' bla st clea ning." It further describes what constitutes compliance with this requirement. It states,
" Typically, power. tooling utilizing, but not limited to, 3-M
. Clean-N-Strip, 80 grit or coaster Flapper Wheels or sanding discs, roto-peans, etc. , may be used to achieve surface cleanliness equal to SSPC-SP-10." .
- 4. TUGCo Inspection Instruction QI-QP-11.4-1, Rev.14, dated 9/23/53, page 4, Section 3.2.2.c requires the inspection of anchor pattern depth at randan locations using a Keane-Tator Surface Profile Comparator, Model 373 or equivalent. It requries a minimum of 1.0 mils anchor pattern depth. It further states, " Surfaces that have been power tooled with 3M Clear-N-Strip, 80 grit ard coaster " flapper wheels," sanding discs, " roto peans" or equivalent, provide acceptable surface profile."
The above documents demonstrate that substrate profile requirenents, as specified by G&H, Specification 2323-AS-31 and the referenced ANSI
. N101.2 document, are accurately refl'ected in site application procedures and inspection procedures. In addition, DBA testing documents indicate that panels tested and primed with Carbo Zinc 11 have a surface preparation in accordance with SSPC-SP-10 with a 1 mil . (minimun) blast profile. Accordingly, this concern is deemed to be without merit.
- d. Instances have been identified (NCRs which have been dispositioned) where zinc prirer is being applied over Phenoline 305 top: oat. Has this system been DBA tested? In discussing this concern, Engineering indicates that this procedure was used on " spot" touchups only.
" Spot" or minor defects are defined as an area, either circular or linear, in which a 1/2" diameter circle could not be completely inscribed at any point along the entire length.
A "Special Engineering Instruction" 35-1195-CEl-9, dated Novenber 11, 1976, states, in part, " Area will be repaired with appropriate coati ngs, i .e. , Phenoline 305 if damage does not extend to the
( primer; Carbo Zinc 11 and Phenoline 305 if primer is damaged."
l Subsequent Carboline docuwentation as recent as 9/30/83, reconfims the acceptability of using Carbo Zinc 11 as a touchup of Phenoline 305. The latest Telex ;tates, "Should an excessive osarlap exist, i: -
can be rc:.ed by hand sanding. Though we have no hard, f ast rules for overlap .:reas, a one to tro inch overlap is not unrealistic."
l Ba sed on the coating r.anuf acturer's expressed approvals of the repair process used and its application to minor repairs, the coo:ern and stated naed for DE A testing is dee .ed to be without erit.
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- e. In regard to successive coats of zine primer being applied, the follo A ng documents were. reviewed: - .
- 1. Carboline Telex, dated 11/15/78, states, " Theoretically, Carbo Zine 11 may be recoat ed with itself an unlimited number of times. ... We prefer that the original Carbo Zine 11 prime coat not be recoated.with itself more than twice, and only if absolutely necessary ...."
- 2. " Report on Irradiation, Decontamination and DBA T~ e sting," dated 8/16/78; prepared by the Analytical Chenistry Division of Oak Ridge National Laboratory, tests acceptability per both ANS]
N101.2 and N5.12. The test documentation reflects that two successive coats of Carbo Zinc 11 were tested under DBA conditions. Two separate samples were used. Tne coatings remained intact without defect. s.
Accordingly, this concern was found to be without merit. ~
- f. In regard to the storage concern related to compatibility of paint system component (primer and topcoat) batches manufactured during different time periods, the engineer was interviewed. He most 2
vigorously rejected the -statement t. bat there was any restriction on use of component batches manufactured duri7g different tikW periods.
He stated that in his experience, with three different nuclear plants i
and over seventeen (17) years of additional experience.with these ,
particular materials, the vendor has gone to great efforts to assure i'
that both their customers and their inventory provides consistency among stock interchange.
In addition, ANSI N101.2, " Protective Coatings (Paints) for Light Water Nuclear Reactor Contai nment Facilities," supports the i Engineer's position. It states, "The coatings manufacturer shall maintain a quality assurance program ard provide adequate documentation to show that the quality of a given coating system is reasonably identical to that of the coating system qualified -under this system. The coating system shall be requalified if there are changes in formulation or manufacturi ng procedure which will alter the performance obtained from a previous test." Accordingly this I
concern is deemed to be without merit. -
In regard to the storage concern related to P't life, the Engineer states pot life expiration is defined by the . nufacturer as when the -
! material can no longer be applied successfully by normal methods.
'The Engineer states the actual pot life is a function of temperature, pressure, agitation, and thinning. The same applies to shelf life.
The Engineer states the charts are provided as guides only, i
The manufacturer concurs with this. In a letter dated 0:tober 27,
, 1981, Carboline states: "The true pot life ends when the product is no longer sprayable.
In conclusion, the inspectors' concerns relevant to storage are without serit.
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1 Fage B5 In conclusion, technical concerns expressed by the inspectors were discussed with engineering, investigated, and were found to be unwarranted in light of the design specification, referenced standards, manufacturer's'
, recommendations and DBA test documentation.
- 2. Harassment. Intimidation and Threats The entire subject of " harassment, intimidation and threats" as stated by s
Mr. Dunham, was dicussed with site QA/QC personnel including the protective coatings inspectors.
The discussions were particularly difficult because what pecole perceive as being harass ent, intimidation or threats varied very sienificantly among inspectors. In addition, the three phrases were at times usec ir.terchangeably to varying degrees.
In conducting the investigation, questions were formulated so a' s to attach the broadest interpretation.to " harassment, intimidation and threats." In addition, the phrases " undue pressure", and " coercion" were introduced into the investigation questions to solicit even a broader range of input from the inspectors.
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The results are summarized as follows: -~
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- a. / One recurring 4eneral complaint was voiced involving the previous M~QC Supervisor (Mr. Harry Williams) and one " Lead" Coatings Inspector, Mr. Bob Wallace. Neither person is employed at CPSES at the present. Several specific instances of this general complaint were provided.
- b. giv0 Tifef ?/r D was- mentioned by several . inspectors where they were
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admonished on the subject of " nitpicking" during a meeting called by Mr. Willins.
- c. One inspector stated he had been directed to accept primer cure on the basis of a " nickel test" performed on material still wet from water curing. He stated this had occurred 10 to 12 times during the last 18 months that he worked for Mr. Williams.
The details of the above itms are discussed below.
- a. The m3st prevalent complaint was that in several instances, ,6en an insoector rejected an item, the craft foreman would go to the craft general forec.an, ..50 at times would al so invlove the craft s epe rinte n'e nt. They would collectively get Mr. Willirs, the Coatings 00' Supervisor, aM converge at the point of i pection with the inspector. Different inspectors viewed this diffa. -ntly. Some inspectors stated they saw this as part of their job at somthing-that is enected aM experienced on any construction job. Others saw this cither as harassment, intimidation, undue pressure or coercion to va ryi ng degrees. Only one inspector was adversely influenced on i
Fage B7 one occasion. In this instance, the inspector was inspecting the tcpcoat on the polar crane. _ The inspector noted two areas,of weld spatter over the topcoat that the inspector felt needed to be knocker off prior to final acceptance. The craft called for Mr. Williams wno was off site. Mr. Williams agreed that one area needed to be cleaned off and retouched and this was done. However, he disagreed that the second area was weld spatter. This area was not cleaned off and the inspector signed off the inspection. The area where weld remained was described by the inspector as "the size of a quarter." From a safety standpoint, the remaining spatter bears no significance.
Mr. Harry O. Williams was contacted at his current place of empl oyment. Mr. Williams stated that some inspectors felt that Q:
was being overrun by the craft because engineering was approving cha nges. He stated that some inspectors insisted on evaluating procedures and changes, which is not their job. Accordingly, some inspectors did not consistently adhere to acceptance criteria in their procedures. Mr. Williams stated that if the inspector was correct, he would support the inspector. However, if he was not correct he would not support him.
- b. The " nitpicking"-meeting resulted from an inspection of the skimTer pump room floor and the -adjacent heat exchanger room floor (Elevation 808' R.B. #1). The inspectors identified 'overspray,' embedded particles and pinholes. The craft forenan and the general foreman contacted Bob Wallace, Coating QC Lead at that time, who called Harry Wil li ams. Mr. Wallace, who was also a certified inspector, Mr.
Williams, and later Mr. Brandt, the Coating Level III, disagreed with the validity of the overspray, and embedded particles deficiency.
Messrs. Wallace, Williams and Brandt attributed the appearance of overspray and enbedded particles to the 115 surfacer used below the coati ng. However, they noted some pinholes that constituted an unacceptable condition which had not been identified by the inspectors even though they had spent approximately 12 manhours (2 persons working 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) to inspect a 10 ft. x 12 f t. room. Mr.
Williams stated that on the following day he assembled the inspectors and that the roans in question were examined physically. Mr.
Williams stated that he and Mr. Wallace used the examples of apparent overspray and particle enbed.7,ent as exaiaples of " nitpicking," and -
pointed out that while doing do, some rejectable pinholes had been a ccepted . He stated that if the " nitpicking" recurred, that he would examine these same areas for valid rejectable conditions, such as pinholes, and if he found any, he would pull their certifications.
This is the only incident that could be construed to be a threat.
' Although there appears to be some justification for the supervisory action, it would have been appropriate to have discussed these matters with only the inspectors involved in the inspection. The ranner in which this ratter was handled is indicative of poor
. s upervisory practice.
Ot5ereise, the incident is a moot point, in that since then the floors ere sanded, recoated and reinspected.
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- c. One insoector stated he had been directed to conduct " nickel tests" on material that was still wet from water curi ng. He stated that this occurred 10 to 12 times during the last 16 to 15 m:nths that Mr.,
_ Harry Williams was his supervisor. The inspecto'r stated that he initially tried to document this on the IR and by attaching a 3-cart memo that stated that an item was acceptable "per KW." He stat ec Mr.
Williams would destroy the 3-part memo and bring the IR and ask that it be redone. The inspector emphasized this was prirer work'done in the shop and that he could provide no specifics on the irs involved.
Mr. Williams was questioned on this matter.
- Mr. Williams stated that on one occasion only, the craft had been drying off panels used for painter cartifications. Sone areas were wet, but nickeT tests were not run on these. He asked the inspector to run a nickel test on dried areas. Mr. Williams stated that he asked the inspector to enter his (Harry Williams') initials on the inspection certifications because they were only for painter certs,
'not anything that would be used at the site. Mr. Williams strongly denies he ever ordered the inspector to run a " nickel . test" on wet material . He stated that this would be a direct violation of procedure and the test would fail. The inspector indicated there was no third party involvement, and so it is difficult to resolve conclusively such contradictirg staterents. _.
B&R. Procedure CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," and TUGCo Inspection Procedure QI-QP-11.4-5, which address application, curing and inspection of primer, do not require the primer surface to be dried after water cure prior to testing for burnish. In addition, Engineering and the Coating Level III state that performing the nickel test on a surface wet from water cure does not detract from the test. The water does not prevent a horizontal force to be applied on the coating to test its adhesion to the substrate.
Although this item could not be proven conclusively either way, there is no technical basis for safety concern. No further action is deemed necessary.
In summary, the allegations of harassment, intimidation and threats were t horoughly i nvestigat ed. Several conclusions can be drawn.
- 1. Inspectors workirs under Mr. Williams perceived less than total support from him. So .e inspectors' stated belief that pro'cedures reflect unacceptable technical practices have brought about occasional confrontations where .at times QC supervision disagreed with the inspector. These situations had a greater marale effect because a small, but very vocal and articulate group of inspectors
.. who apptar knowiedgaable on the technical aspects of protecti've coatings, have had a dispropartionate amount of adverse influence within the Protective Coatings QC force.
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- 2. None of the incidents identified resulted in any inspection omission {
that Constitutes a safety Concern. ,
- 3. The insxctors spoke favorably of their present supervision.
However, there is a small number of inspectors that essentially refuses to recognize and support the f act that Engineering, not QC
- inspectors, is resoonsible for determining what application practices meet design requirements and what acceptance criteria are to be used by the inspectors. , . -
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- 3. Previous Manacement Investications As a result 'of Mr. Danham's previous discussion with QC supervision and management, twc previous investigations were conduc,ted.
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One of the investigations was conducted byJir B r.and t'. This investigation was conducted during the first week in.0uly, 983. Mr. Brandt interviewed eleven (11) coatings inspectors, inclu' ding two th.=t Mr. Dunham stated could substantiate his allegations. Mr. Dunham rr.ade two allegations. The first allegation, that Mr. Williams had publicly reprimanded Mr. Dunham, wa s not substantiated.
The second allegation, that Nr. Wil'liams',. who was not a certified inspector, had instructed Mr. Dunham on how to perfonn a " nickel" test, was substantiated. No direct changes were rr.ade as a result of the N investigation. Mr. Brandt conducted a general rneeting with Coatings Q~
personnel to discuss the NCR/IR program. The inspectors raised only one question ard that was answered. Mr. Brandt also invited inspectors to come in any time to discuss any directive' issued. by him or represen,ted, to have originated with him. ,e - g .4 p r,g.y4 a 4.;-
Mr. Brandt stated he and Mr. R.G. Tolson, TijGCo Site QA Supervisor, had previously tried to remove Mr. Williams frcra a supervisory role but were restrained by QA Management in Dallas. . . . . , . , . , ,
Mr. R.G. Tolson, as a result of his visit with Mr. Dunham, after Mr.
Dunham's visit with Mr. purdy, directed Mr. B.C. Scott, the Non- AS".E QA Supervisor, to conduct interviews to ascertain problems and arrive at corrective actions. Mr. Scott interviewed Mr. Wtiliams and Mr. Dunham.
Mr. Scott concluded there were two major issues. The first issue was that Mr. Williams sided with Construction and did not provide adequate feedback to his people. The secord issue was that inspectors wanted to issue NCRs ..
instead of "Unsat irs."
Mr. Scott stated that Mr. Dunham did not have any other prcblers. Mr.
Dunha.m stated the biggest problem was sith Harry and Harry's way of doing t h i ngs.
Fage B10 Mr. Scott was aware of the plans for a general meeting with inspectors to discuss the TR/IR program and curtailed the interviews and reported his conclusions to Mr. Tolson. Subsequently, Mr. Tolson visited infomally -
with Mr. Dunham at a barbeque held to bring the craft and inspectors closer together.- Mr Tolson stated that Mr. Dunham never mentioned "harassmant" or intimidation, but Mr. Dunham did mention that he didn't care for Mr. Willians.
Mr. Tolson stated that during the last 1-1/2 to 2 years he was under a in Dallas in regard to Mr. Wi-111ams. Mr.
restraintstated Tolson from that QA Managemegime at that . he wanted to reassign Mr. Williams out of a supervisory role but was restrained. v... -- f: .u r
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Mr. D.N. Chacun, TUG o Manager, QA was interviewed. Mr. Chapman stated that approximately a year ago, Mr. Tolson reported to him that Mr.
Williams had shortcomings as a supervisor. Mr. Chap.an stated Mr. Tolson d'escribed the weaknesses as communication difficulties and a general lack of supervisory strengths. Mr. Tolson reparted that he had looked into -
statements made at the licensing hearings regarding suppression of K.Rs j and that it was his conclusion that Mr. Williams was not harassing his people; that Mr. Williams was trying to do an earnest day's work as a s upe rvi sor. Mr. Chapman stated there-was a general agreement between him and Mr. Tolson, that since Mc. Will, tams primary strengths were in civil / structural areas which were winding down, Mr. Tolson~ shotrid contact .
Mr. Williams' employer, DUCI, and arrange for an orderly transition to another project. Mr. Chapman stated the plan was to phase out Mr.
Williams over a period of time. Mr. Chapman stated that Mr. Tol son subsequently advised him that he had contacted DUCI and advised them to start looking for a new assignment for Mr. Williams.
It is the conclusion of this investigation that Mr. Brandt and Mr. Tolson conducted their own investigation to address matters as they perceived then at that time. In addition, Mr. Chapman, similarily addressed the matter of Mr. Williams' reassignrent consistent with the facts presented t o him. The insistence for an orderly phasing out of a parson's service, in light of decreasing activities in his orimary area of expertise, is
' '(.. . . . consistent with good management practice. At the time this decision was made, the present situation had not materialized, since Mr. Tol son, Scott and Brandt's investigations had not yet occurred. ,
- 4. Procrarrr.atic Concerns Inspectors expressed the following p-ograsutic concerns in the area of protective coatings: '
- a. Some inspectors expressed concerns over the use of the IR UNSAT instead of an NCR. Inspectors state an IR UN5AT can be resolved without Engineering review and input. .
Page Bil This concern was investigated. It was detennined that an NCR is required when a deficiency is such that it cannot be reworted to .
bring it into compliance with Engineering requirements. In this
. case, Engineering resolution to either use-as-is or alter the requirement, is necessary. However, if the deficient condition can be brought up to Engineering requirement by rework, the use of the IR UNSAT is entirely consistent with 100FR50 Appendix B. This concern is deemed to be without merit. It should be noted that on September 29, 1983, QC management.on site had a general reeting with coatings inspectors to discuss this philosophy and answer questions. ~here is a resistance on the part of some inspectors to accept this perfectly acceptable practice.
- b. Some inspectors stated that the program does not define how to resolve instances ahere surface preparation hold points are not obse rv ed.
This concern was investigated. TUGCo Inspection Procedure Ql-QP-11.4-1, " Inspection of Steel Substrate Surface Preparation and Primer Application," Section 3.5 states that inspections required by Section 3.1 through 3.4 shall be documented on an IR. (Section 3.1 through 3.4 include surface preparation.) Section 3.5 further
, requires that a reject tag be applied to a_n UNSAT area together with the inspection report. Section 3.7, "Nonconformances," 'st'ates that
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non-conforming conditions shall be reported on an IR in accordance with CP-Qp-18.0. Accordingly, an inspector who is asked to perform an inspection subsequent to Item 7 (inspection of surface preparation) on the Inspection Report in Attachment 2 of the subject procedure, and notices a lack of QC signoff on the previous steps, should identify this on the IR itself. However, since there is confusion on this item, there appears to be a need for further indoctrination and training of inspectors on this subject.
- c. Inspectors state that there is no method by which inspectors can express technical concerns and have them reviewed by appropriate persons or organizations.
This item was discussed at the several levels of QC supervision. QC supervisors stated a willingness to accompany inspectors to visits with Engineering or higher levels of QA/QC r.anagement. Evidence of this was seen, in particular the meeting that was set up batween the Coatings QC Inspectors and the Corrosion Engineers. That meeting, he-ever, was apparently not productive in that non-technical subjects ,,
were persistently brought up by Mr. Dunham for discussion.
There appears to be a need for .anageaent involve.ent in deciding to what extent inspectors' ques'tions should be answered, especially if electrical, mechanical, and structural disciplines are to be hand'ed
, accordingly. The TUGCo " hotline" might be considered as a means by
, which inspectors can voice their questions.
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- d. Inspectors state that there are no provisions for recertification of I coatings application personnel. As a result of this concern, the -
Engineering specification and r'eferenced industry standards were
- revi ewed. These require that all application personnel be qualified in accordance with the coatirs applicators' qualification procedures.
Recertification, however, is not specifically recuired. It is Construction Management's pasi* ion that a recertification program is not requi. red. Construction Kanagement states that irs are reviewed-on an ongoing basis and trended by forenen. Trends are brought to the applicable foreman who then uses this 1.nfornation to assess the performance of his people.
This area will be audited by TU3Co 0A. Any deficiencies observed will be reported for resolution in accordance with established proc ed ures.
- 5. Management Items During the course of the investigation, several items of management significance were voiced.
- a. The Coatings QC Inspectors state they have been working 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a day, six days a week for months. While paint crews have been added inside containnents, the number of inspecIors has n6t increased accordi ngly. Inspectors state the work schedule is having an adverse effect on proficiency, alertness, and objectivity. Inspectors state that schedule pressures affect craft tempers. This creates a feeling of hostility that gives rise to a feeling of' harassment or intimidation.
- b. Some B&R inspectors complained of a compensation disparity. Several inspectors stated-that Ebasco personnel hold the QC supervisory jobs, get sick leave, get paid holidays, per diem, and a regular salary.
They state it is apparent that the client does not wish to have B&R s u pe rvisors. They state they do not get sick leave, paid holidays.
per diem, and are paid on an hourly basis. Some inspectors stated that the canpensation discrepancy is the mcst significant item af fe: ting norale among B&R QC inspectors. They state that the results are evident in coatings but that the same problem is
" festering" in other disciplines, including electrical a rd mechanical d i sc i pl i nes.
- c. 50me inspectors estplained that they did not have adequate facilities to do thair QC paparwork. They stated that it would be helpful if f acilities that are nell-lighted and . ay from unnecessary interruptions, are provided to perform their paperwork.
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