ML20107K498

Forwards 841028 Request for Investigation Into Util Actions Suppressing & Substantially Modifying J Lipinsky Opinions Re Painting Coatings Qa/Qc Program

ML20107K498
Person / Time
Site:	Comanche Peak
Issue date:	10/28/1984
From:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
To:	Noonan V NRC
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ML20107K479	List: ML20107K498
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NUDOCS 8411130160
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{{#Wiki_filter:c. GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, N.W., Suite 202 Washington. D.C. 20036 (202)2324550 October 28, 1984 Vincent Noonan Director . Technical Review Team U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: CASE's Brief in Opposition to TUGCO's Request for Non-Disclosure of Relevant Lipinsky Documents and Request for OI Investigation

Dear Mr. Noonan:

Enclosed is a copy of the Government Accountability letter dated today to Mr. Ben Hayes, Director of the Office of In-vestigations (OI) requesting an investigation into the actions of TUGCo in suppressing and substantially modifying the opinions of Mr. J. Lipinsky about the paint coatings quality assurance / quality control program at Comanche Peak. I have also enclosed a copy of the brief and attachments for your information. (I have sent the letter to Mr. Hayes to the service list, but-I have not docketed this memorandum.) Sincerely, 4 Billie Pirner Garde Citizens Clinic Director . Enclosures I ( i f i [ it ( h- (* i g J e'x guggoat1*13,J ~ r ,DR s A n Q 4., e 'g t n \\ s s o, 2 k $ .C

~ l 1 GOVERNMENT ACCOUNTABlUTY PROJECT F g 1555 Connecticut Avenue, N.W., Suite 202 l! Wastegun, D.C. 20036 (202)232 8550 October 29, 1984 l BAND DELIVERED Mr. Ben Hayes Director Office of Investigations U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Comanche Peak

Dear Mr. Hayes:

Within the past week, remarkable evidence has been disclosed in { the Comanche Peak licensing proceedings from the O. B. Cannon Company. investigation.This evidence necessitates our request for an OI I As you know, O. B. Texas Utilities Generating Company (TUGCo) Cannon Company was the s l get its paint coatings program on course. in 1983 to help TUGCo Stemming from that contract came a memorandum by one of its employees, Mr. J. J. Lipinsky, whose sharp criticisms of the program has prompted-l several NRC, IE, OI and NRR inspections and investigations. As you are also aware, in the context of those investigations, Mr. ) Lipinsky entirely recants hi protective coatings program. s previous criticisms of the plant's Lipinsky's 1800 turn has been un-( . explained. until now. .TUGCo officials to influence Mr. Lipinsky through coerci ~ Peak to the NRC investigators / inspectors.sure or some other measur -( It is still unclear visors as target or sources.whether that investigation should include Mr. L t iAttached,.to this letter is a brief filed by the int'ervenor Citi-i l sens Assiociation for Sound Energy (CASE J which some of the evidence of coverup an)d coercion are summar,ized. through its counsel in i The brief itself is not intended to det 5 disclosed through the hearing process. ail the evidence recently A review of that material will itself provide the best demonstration of the actions and the efforts by TUGCo to prevent the various officials from the O. B. -Cannon Company to testify honestly to the Nuclear Regulatory Com-mission,about the nature of the problems discovered in the paint coatings department, t i t h-y pog e ~ w I% 0 .. ~. u 3y--. 2~~~~ ^

il Mr. Ben HOyOc 4 Octobar 29, 1984 5 g Page Two 1 A Government Accountability representative will be glad to meet with any of your Washington agents to inform them of the specific ^ . - ;7 nature of the evidence developed to date in the licensing pro-ceedings on this issue, and to also provide them with the names of other personnel who we believe have further evidence regarding this matter. Sincerely, \\ ouis Clark

• Director LCamk Attachments to Serv /o attachments copy w ice List

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8 GOVERNMENT ACCOUNTABlUTY PROJECT 1555 Connecticur Awmue, N.W., Suite 202 g Washington, D.C. 20036 (202)232-8550 October 26, 1984 3 I l Mr. Harold R. Denton l Director l Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission t Washington, D.C. 20555 ) l Mr. Darrell Eisenhut Director l Division of Licensing l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Comanche Peak Steam Electric Station, Units 1 and 2 (Nos. 50-445 and 50-446) i Texas Utilities Generating Company Program Plan, October 8, 1984 L

Dear Mr. Denton and Mr. Eisenhut:

This letter serves as preliminary comments, analysis and recommen-dations of the Government Accountability Project (GAP) and the Citizens Association for Sound Energy (CASE) regarding the adequacy i l of design, construction and operation of the Comanche Peak Steam Electric Station (CPSES) and the compliance of CPSES with federal regulations and industry standards, t f It is clear to us, and we believe should be to the NRC and the public, that the Comanche Peak plant is the victim of a comprehen-sive quality assurance / quality control (QA/QC) breakdown. l Since the scope of the Technical Review Team (TRT) is limited, it is understandable why Texas Utilities Generating Company's (TUGCo) response is f.qually narrow. Such an approach is extremely imprudant by both the agency and applicant, at this juncture. Based on our review of the October 8, 1984, proposal by TUGCo or applicant, we make the following recommendations: 1. Reject the October 8, 1984, proposal (Revision O) as submitted. 2. Require TUGCo to hire'an independent contractor to develop and implement any subsequently approved re-inspection or corrective action proposal. W~ l.

a.

Mr. H2rold R. Denton Mr. Darrell Eisenhut October 26, 1984 Page Two Require TUGCo's response to include a " vertical slice" 17 3.

re-inspection program of at least three safety systems.- 4. Expan'd the NRC's TRT's efforts to include those expanded items in Section II of this letter, including a total in-spection and ~ documentation review of either one major safety system or one separate area of the plant (similar to the major Diesel Generator Building inspection at the Midland nuclear power plant in October, 1982). 5. Expand,tJun official agency review of the adequacy of TUGCo's response effort to include a review by a panel of.former employees. At this time, we remain skeptical of the plan being provided by TUGCo 'to allay legitimate NRC and public concerns about the safety of the CPSES project. I. BACKGROUND Comanche Peak Steam Electric Station is a two-unit power reactor under construction near Glen Rose, Texas. It is owned by a consor-tium of six utility companies. Texas Utilities Electric Company (TUEC), through its subsidiary TUGCo, retains responsibility for design, construction and operation. The plant has been plagued by.a lengthy history of allegations of inadequate design, improper construction, and a flawed QC program. These allegations have come to the attention of the NRC primarily through the citizens intervenor organization, however, throughout the seven to eight years of construction, employees have independently contacted the NRC to report' design and construction deficiencies. The project has undergone a number of special NRC inspection efforts, as well as the regulatory program. The plant has not yet received an operating license. There are currently two ongoing licensing dockets, both actively involved in hearings. In March, 1984, GAP announced an independent investigation of CPSES. GAP filed an emergency request pursuant to 10 C.F.R. 2.206 requesting an immediate stop work order, an independent audit of the project, and a major investigation by the Office of Investigations (OI). That request was subsequently granted in part and denied in part. E!A similar request is pending in front of the Licensing Board (ASLB or Board) both in the technical contentions docket (Docket 1) and the harassment and intimidation docket (Docket 2). --e -ee== e*e-i a

Mr. HOrold B. Denton Mr. Darroll Eiccnhut October 26,-1984 Page Three On March 12, 1984, William J. Dircks, Executive Director for Operations (EDO) announced the reorganization of NRC resources for the-Waterford III and CPSES projects. This reorganization was to coordinate all agency actions on these projects under one office-- the Office of the Director of the Division of Licensing. The stated purpose of this unusual organization was to resolve the remaining issues before the staff could make the licensing decision. The initial focus of this coordinated " task force" approach, l used previously at Diablo Canyon, was to " expeditiously" resolve all existing and new issues "so as not to delay the licensing decisions." (March 12, 1984, Memorandum to John T. Collins, et al., from William J. Dircks, EDO, re: Completion of Outstanding Regulatory Actions on Comanche Peak and Waterford.) l In early April, a coordinated team of NRC management officials, inspectors and investigators arrived on the CPSES site to conduct a l preliminary review of the adequacy of construction at the project. The report of this effort was issued July 13, 1984. On September 18, 1984, a second report was issued which high-lighted some of the issues which had been' identified by the TRT in its inspection and review effort conducted during July and August, l 1984. On October 8, 1984, TUGCo responded to the findings of the TRT by announcing the establishment of a Comanche Peak Response Team t (CPRT) and a complimentary response effort to the NRC's findings. On October 19, 1984, a meeting was held in Bethesda to discuss the TUGCo response to the TRT findings. (That meeting was completed at a second meeting on October 23.) l Additionally, on October 19, 1984, the NRC staff submitted to the ASLB its projected schedule for completion of outstanding ASLB issues. Although the ASLB schedule outlines the schedule for the items necessary for resolution before the ASLB, it does not incor-porate all items requiring NRC review, inspection and resolution prior to licensing. (Those additional items, or a timetable for resolution, are not addressed in the staff submittal.) l Following the release of the latest schedule, the original in-structions from Mr. Dircks, EDO, to his staff, that is, the expedi-tious resolution of open issues to meet the utilities' timetable, seems inappropriate. Outlined below are what GAP and intervenor CASE believe to be a more prudent and regulatory-efficient approach.

Mr. Hnrold B. Denton Mr. Darroll Eietnhut October 26, 1984-Page Four II. PROPOSED NRC ACTIONS The following outline is submitted as a proposed modification to the ongoing TRT efforts: (see Attachment A) 1. Expanded field inspection effort "Whole system" or " vertical slice" approach; a. b. As-built inspection with final design paper; Audit of documentation to field to vault for c. in-process construction. 2. Incorporation of source review Appointment of allegations source response a. coordinator; b. Field visits by allegation sources; Review panel for former employees. c. 3. Allegations recruiting program i a. Establishment and promotion of information " hot line;" l t {- b. Publication of a summary of unanswered questions to the workforce; l Establishment of an NRC interview program; c. i d. Structured " debriefing" program. i 1 III. MODIFICATION IN THE CPSES RESPONSE TO THE TRT The current proposed Revision O of the Program Plan and Issue-Specific Action Plan (" Program Plan") has several fundamental flaws in its structure, scope and methodology. Essentially, we believe that TUGCo needs to completely revamp the programmatic basis and philosophical approach upon which the Program Plan is based. These flaws are summarized below: No organization-independence. Inherent conflict of interest of personnel involved in the Senior Review Team, review team members, issue leaders, etc. rr

~. Mr.-Harold B. Denton Mr. D2rrell Eisenhut October.26, 1984 Page Five Fundamentally inadequate program objectives and principles.

• ~ i Inadequate and unacceptable program processes and QA (methodology).

Insufficient program record plans and tracking systems. Overly-narrow and restricted scope. Because of the overall inadequacy and fundamental flaws of the TUGCo proposal, we do not think it is a prudent expansion of our efforts to provide a line-by-line analysis of this revision. We will, how-ever, delineate our principle objections and recommendations below. 1. Any analysis or re-inspections which are responsive to the TRT's findings should be done by an independent contractor. This contractor should be chosen according to all of the criteria for independence..Those criteria are outlined in a February 1, 1982, letter from Chairman Palladino to Congressmen Dingell and Ottinger. The three elements necessary are: a. Competence: " Competence must be based on knowledge-l of and experience with the matters under review." i l b. Independence: " Independence means that the individ-uals.or companies selected must be able to provide an objective, dispassionate technical judgment pro-vided rolely on the basis of technical merit. In-dependence also means that the design verification program must be conducted by companies or individ-uals not previously involved with the activities they will now be reviewing." c. Integrity: "Their integrity must be such that they are regarded as respectable companies or individuals." We have reviewed the independence criteria as it has been applied by the NRC to the independent contractors at the Diablo Canyon, Midland and Zimmer nuclear power plants in preparation for this res-ponse. There is no question, given that criteria, that Ebasco, Inc.-- evidently selected by TUGCo to perform the independent review--does not qualify to perform an independent audit or analysis of Comanche L Peak problems under any of the three criteria. l First, we do not find that Ebasco is competent. We draw the I attention of the NRC to its own recent findings about the significant ! W~ ~^ ~

Mr. Harold B. Drnton Mr. Darrell Eisenhut October 26, 1984-Page'Six QA breakdown at the Waterford nuclear power plant.. In the September, 1984, Supplement to the Safety Evaluation Report (SSER No. 7),:on page 15, the'NRC made the following conclusion in the summary of-a review of 350 allegations: 2. Quality Assurance activities during most of . construction were principally delegated to the major contractor, EBASCO, by the utility. The lack of a fully staffed and effective utility QA program, along with EBASCO's. 3 failure to fully carry out the QA responsi-bilities delegated to them, led to quality p problems during construction. Documentation available to both GAP investigators and the NRC clearly indicates that Ebasco was willing--and in fact did--shortcut compliance of its work to federal regulations. We also understand that Ebasco is currently under investigation by OI for its activities at Waterford nuclear power plant. However, it is not necessary to' leave Comanche Peak to make - general assessments about Ebasco's lack of competence. Both TUGCo and the NRC are well aware -of the lengthy trail of misjudgments made by Ebasco's lead employee on the Comanche Peak site. Perhaps the l most notable incident currently in front of all parties is the liner i i plate mishap. (This incident is described in detail in a CASE pleading, September 27, 1984, CASE's Evidence of a Ouality Assurance - Breakdown.) Mr. Thomas Brandt, senior Ebasco employee, has attempted l~ since.the issue came to the attention of the ASLB, to explain the l basis for his personal conclusion that the stainless steel liner l plates are installed in an indeterminate condition. This position i by the senior Ebasco employee is evidence under both the integrity and competence section. It is indicative of the same type of sloppy attitude that has led the Waterford NRC team to reach its conclusions about Ebasco. Second, Ebasco simply does not meet the independence standard. Ebasco personnel have been involved in every aspect of the construc-tion,-inspection, litigation and re-evaluation of the Comanche Peak project. Even if Ebasco brought in personnel who have had no previous involvement with the project, the company would not have any cor-porate independence. lo We hope that TUGCo has recognized that organizational inde- [ pendence is impossible for Ebasco to achieve. c i l l _._.___.m,- ~~~~ ~~ '~

Mr. H2rold B. Denton Mr. Darrell Eisenhut October'26, 1984 Page Seven Finally, the history of Comanche Peak's Department of Labor record and its Waterford evaluation are full of Ebasco's demon-strated lack of integrity. We draw the attention of the NRC once again to the Secretary of Labor's finding that Thomas Brandt was not credible in his testimony about the termination of Charles Atchison. (See the Secretary of Labor's Decision, Atchison v. Brown & Root, June 10 1983, pg. .) We hope that TUGCo has the foresight to voluntarily withdraw i Ebasco as its nominee and rgsubmit a set of three nominees to the agency for their selection.6/ In' choosing the companies to nominate for this independent re- . view, we request that the utility be required to adhere to both the independence criteria (discussed above) and the following process recommendations: 1. Do not " hire" any contractor until the NRC has the opportunity to review the nomination for compe-tence, integrity and independence. 2. Arrange for the public-(intervenors, former employees, lay persons) to comment on the selection prior to entering into any contract. l 3. Be prepcred to have the contract for the indepen-dent contractor publicly available. I Our specific recommendations regarding the contract of the independent auditor are noted below: 1. The independent contractor should be responsible l directly to the NRC, submitting all interim and L final product simultaneously with TUGCo and the NRC. 2. The independent contractor should do a histori-cal assessment of TUGCo's prior work. 3. The contract should ensure that, once hired, TUGCo cannot dismiss the independent contractor from the project without prior notice to the NRC l 2/This process of nomination, selection and a public meeting on the selection was used at Midland, Zimmer, Diablo Canyon and LaSalle (partial HVAC audit). ....... ~ ~~

Mr. Herold B. D;nton Mr. Darroll Sicenhut October 26., 1984 Page Eight and an NRC-sponsored public meeting to jus-tify the decision. S 4. The contract should require that each auditor subcontract any services for which its direct personnel are not qualified. 5. The contract should require that the proposed methodology be disclosed: specifically selec-tion criteria and size of the samples for. inspections and testing. 6. The contract should require the auditors to provide calculations demonstrating that it is possible to adequately complete its work during the proposed timeframe. 7. The contract should require the auditor to support its proposed methodology through references to established professional codes (i.e., ASIM, ASME, ANSI, AWS, etc.). 8. The contract should require all auditors to report all safety-related information directly to the NRC. i l l 9. The employees and auditors should demonstrate that the personnel assigned to the project are free from conflicts of interest. 1' 10. The auditors must recommend corrective action, and then control its implementation. We are extremely alarmed that TUGCo has provided such sketchy details about the persons or organizations that will be performing the detailed review of the Comanche Peak deficiencies. We request that first the NRC delineate in writing to TUGCo what it expects in a nomination of a third-party / independent re-review to respond to the findings of the TRT.(including instructions to TUGCo to not hire a contractor without NRC approval). 2. Inherent conflict of interest of personnel involved in the Senior Review Team, review team members, issue leaders, etc. This item is, in actuality, dealt with through the independence section above. However, any analysis of the TUGCo Program Plan would be incomplete without pointing out that the Plan, as submitted,

~ Mr. Harold B. Denton Mr. Darroll Eicenhut October 26, 1984 Page Nine contains as the Senior Review Team, issue leaders, and team members, the very-people charged by the allegers with causing the problems in the first, place. This flaw is incredulous. In reality, the situation without modification, results in the following typical scenario: Inspector "A" identifies problems on the Comanche Peak site with System X to Supervisor "B." Supervisor "B" and Manager "C" prevent Inspector "A" from pursuing l his concerns. Inspector "A," believing he has been harassed and intimidated, either quits or is fired and reports his concerns to the NRC TRT. The TRT substantiates Inspector "A's" concerns and requires TUGCo to respond to those concerns. TUGCo assigns-Supervisor "B" and Manager "C" to resolve the l concerns initially raised to them by the alleger. i Obviously, the supervisor and management were neither capable nor willing to solve the problems in the first place. They are certainly even more incapable of now indicting their own previous decisions and lack of action. {- Any credible response must be done by an independent team. [- (See Item 1 above.) 3. Fundamentally inadequate program objectives and principles. The three sections of the Program Plan describe TUGCo's ob-jectives (SII) and principles (SIII). In SII, Program Plan Objectives, TUGCo states that it is "commited to the safe, reliable, and efficient design, construction and operation of CPSES...." We think this initial statement is illustrative. TUGCo is commited under the law to a code of federal regulations and industry standards. In the past, TUGCo has ignored the former commitment and embarked on an uncharted journey while Paying lip service to the latter commitment. l No one questions the intent of TUGCo to ultimately safely { operate the Comanche Peak project. That commitment, however, must be to the unique programs and. processes which it agreed to through its FSAR commitments. The five objectives outlined in %II are the correct broad goals. Unfortunately, the Program Plan Project is not capable of. fulfilling.those objectives. .:... : = ~ -- -,=

• _3; _

Mr. Harold B. Denton Mr. D2rroll EicGnhut October 26, 1984 Page Ten l Section III, Program Plan Principles, uses ten basic elements for each question raised by the NRC. These are listed below, with j the primary flaw of each category beside it. 1. Specifiu Questions - Is limited to only those identified by the NRC TRT. 2. Expanded Reviews - Provides for expanded sample size which can l erase the problem. 3. Generic Imp'.ications - Only a " forward look"/ horizontal approach as opposed to assessment of systematic implications 4. Thorough Reviews - Potentially a " Rube Gold-berg" search for an acceptable, instead of legitimate answer. 5. Root Cause - Does not concede that breakdowns in the implemen-tation of the system inher-ently indicate a defective system. 6. Corrective Action - Lack of comprehensiveness. First, TUGCo should receive centralized and controlled NRC approval for corrective action. l 7 Collective Significance-A totally useless category in its present form; only i potential use is internal management tool 8. Future Occurrences - Must be controlled by inde-pendent auditing firm. 9. Personnel Training / - All personnel doing any work Qualifications on this project must be in-dependently qualified for tasks, since the qualifica-tions of personnel involved, or the procedures they were qualified to originally may. have been totally inadequate. l

Mr. Harold D. Denton Mr..DIrrell Eiccnhut

' October 126, 1984 '~ 'Page Eleven 10. Records - Narrative format too com- . plicated. Any data sub-mitted to the.NRC must also be publicly available, not only "NRC auditable." 4. Inadequate and Unacceptable Program Processes and Quality-Assurance (Methodology). Section IV, Program Process (pages 11 through 15) and Attach-ments 1-4 of SV, are the extent of the detailed implementing pro-cedures offered by_TUGCo. .The abbreviated " bullets" of TUGCo's plan do not provide the level of detail necessary for the public (or the NRC)_to have any confidence in the TUGCo Program Plan. We'suggest that Section V be. completely rewritten, utilizing a subcontractor with experience in development and implementation of program processes. If TUGCo does bring.in a consultant to re-develop this section, we would request permission to provide them i comments on the reorganization prior.to submission to the NRC. As a guideline, we include the following list of inadequacies: 1. Program has no organizational independence. (See pages 4 through 9). 2. Program does not include any assumption or accep-tance of error as a serious possibility; in other words, the approach is backwards. For example,'a concern substantiated by the TRT and submitted to TUGCo for evaluation and resolution, should be approached from the " ground up." The response team (or independent reviewer) must first gather the~ appropriate standards and procedures used, review and audit the processes followed by design and construction, iden-tify deficiencies in the craft and QA accomplishment of their . tasks from a historical documentation perspective and, finnaly, audit the as-built condition of the system or component against a final design document. Then, once the cause of the as-built deficiency has been L identified, evaluated and tracked for similar discrepancies, the i safety significance of the item can be separately evaluated. The reverse process--identification of the safety significance, has the very real potential of failing to diagnosa a multitude of l' 7--~..- L --m

Mr. Harold D. Denttn Mr. Darroll EicCnhut October 26, 1984 Page Twelve c generic causes necessary to understanding the QA/QC breakdown, 5: Quality Assurance / Quality Control Program The QA/QC program for this effort should be a completely -seperate function. Their program and to the-NRC prior to the start of any p, procedures should be submitted. rogram. Currently the QA ef-fort for'their Wesponse is to come from the existing QA program. _J.1 If that were actually implamented Mr. Antonio Vega would not only wear the hat.of.the Senior Review Team in which he is going to audit and review his own work as both a team leader and an issue leader, he will also head up the QA effort to audit his own work while wearing the other three hats. 5. Insufficient Program Record Plans and Tracking Systems All audit records'should be disclosed simultaneously to the public, the ASLB and the utility company. These records should include any and all basis--including calculations and judgments which the TRT was given by TUGCo, as well.as all data described in the " Project Working Files Section." isee pg. 13) More specifically, the record format described in Attach-ment 2 and 3 should be revised from a narrative form to a one page (with continuations,1f necessary) form. (We have found that the format used by the TERA Corporation for the Midland IDVCP project i was particularly useful and flexible.) l The narrative approach is simply too subjective, very dif-ficult to work with, and unreliable. As currently proposed,'almost each line item of the Action Plan Format includes an interjection of opinion, conjecture and, ultimately, inaccuracies. Program Process Steps to the implementing steps is in chronological order. Our own analysis of the Comanche Peak problems lead us to believe that change in the order of tasks is more sensible. We propose that Step Eight, Identification of Root Cause and PotentialGeneric Implications, follow Step Four. Further, we propose that additional steps to review as-built verses final de-sign be included after Step Eight. We resist the Motion that any rework or corrective action can be taken by TUGCO or any of its contractors prior to any resoC lution of,the concerns itself being approved by the NRC. A' p g q q,.... ....., an.. n,..n,- w, -.m m

Mr. Enrold D. Denten Mr. Darroll EicCnhut October 26, 1984 Page Thirteen i Finally,"we.strongly object to the TUGC0 plans to not.. _~ forward.the new information to the NRC until after it is a.com- [ plated work project. ~ N 6. Overly Narrow and Restricted Scope Due to schedule constraints on intervonors who were required to submit several motions last week, as well as attend NRC meetings ~ with the new:TRT management and the. late receipt Jf the TUGC6 Program Plan, ion. We anticipate submitting this item within ththis letter will h to this sect e next l two days under separate cover. VII. Conclusion The evidence of noncompliances, knpropriaties, QA breakdowns' imprudence and massive construction failures repeatedly misrepresentations, false statements, waste, corporate meets the general NRC and Region IV criteria for suspension of a construction permit or the denial of an operating license. In recent months Comanche Peak has been the subject of re-peated revelations and ac,cusations of construction flaws, coverups, and negligence. The evidence already on the record is indicative of a significant failure on the part of TUGCo to demonstrate respect for the nuclear power it hopes to generate, or the agency which reg-l ulates its activities. TUGCo has taken repeated risks with its stockholders' in-vestments, its corporate credibility and its regulatory image. In i aach of these risks it has lost. It is too much to expect citizens to accept TUGCo's arrogant disregard for the publics health and safety. GAP recognizes the steps forward by the NRC--establishing a special team to review Comanche Peak's problems and the request for an independent audit, however, this must only be the beginning. TUGOD has numerous problems to worry about, and it is clearly not in its own best interest to put the strictest pos-sible construction on the regulations under which they have agreed to build this nuclear facility. It is for just this reason that the nuclear industry is regulated, but even regulation, fines, extensive public mistrust, and corporate embarrasment have not humbled Texas Utilities. If Comanche Peak is ever going to be a safe nuclear fa-cility, someone else is going to have to put their professional cred-ibility on the line. This independent auditor, paid by TUGCo, must be given strict guidelines for accountability and responsibility in order to justify its hard line recommendations. 4

Mr. H2rold R. Denton Mr. D2rroll Ei:stnhut October 26, 1934 Page Fourteen GAP hopes that both the Office of Nuclear Reactor Regula-tion and the Region IV office of the NRC will give serious consid-eration to GAP's concerns and recommendations set forth above and r implement a system whereby there is a truly independent system of -auditing the extensive problems with the Comanche Peak plant. i ? Sincerely copy to service list \\ Eillie Pirner Garde = Director, citisens Clinic for Accountable Government I {. I 4 d a

? M Attachm7nt A l \\j RECOMMENDATIONS FOR TRT REORGANIZATION b our recommendations incorporate the best of the various Nuclear Regulatory Commission (NRC) inspection and review programs which the l Government Accountability Project (GAP) has worked with since 1980. We believe that with successful implementation of the current Techni-cal Review Ta'am (TRT) plans along with the modifications described below,the NRC should be able to ascertain the actual condition of i Comanche Peak, resolve all pending allegations require the appro-priate utility zeview or reinspection program,,and provide assurance that all concerns of the workforce have been found by the NRC now instead of on the eve of licensing. 1,/ 1. Expanded Field Inspection Effort We have previously explained this item in our September 26 letter to Darrell Eisenhut regarding the ina acies of the i TRT effort to date. In short, our concern is that TRT effort will f only pursue allegations. We know that the NRC's concept for these special inspection efforts is to follow an allegation until it is confirmed or substantiated and then turn it over to the utility for such things as " root cause evaluation," etc. Such an effort is incomplete when the objective of the special inspection effort is to determine" root cause." Admittedly there is a large number of allegations and allegers at Comanche Peak. However, it is not acceptable for the agency to depend upon the willingness of plant workers to indepen-dently report all significant violations. Such an attitude would be i dangerously optimistic. We also recognize that the NRC does not have unlimited resources. Therefore we suggest that the agency conduct either a "whole building" or " vertical slice" inspection as a means of deter-mining the validity of the projects design and construction status. We suggest that such an inspection be conducted of an area or system that is completed. This will enable the NRC to check the accuracy of the final design documents. Such an inspection must, of course, be unannounced if it is going to have any legitimacy. l lAs the NRC well knows it is an unfortunate, uat predictable phenomena that members of a nuclear plant workforce wait until the last possible minute before making their concerns about plant safety known. This is a result of a combination of factors-including the belief that the problem will be resolved before start-up and fear,of losing their job. l l I ~._

i 1 ^ ~ .y Further we. propose that the QA TRT personnel conduct a documentation audit of a sample of construction work in progress. To assess the extent that documentation problems invalidate ongoing con-struction and. inspection work. 2. Incorporation of Source Review our recommendations in this area stens.from our dis-appointment about how the TRT effort has failed to utilize the know-ledgeable members of the workforce who brought the problems to the a*.tention of the NRC. (See also September 26,-1984 letter to Darrell Eisenhut from Billie Garde). We suggest that the TRT appoint a coordinato'r to deal specifically with the allegers in order to both utilize their ex-1 perience and expertise to the fullest extent. Further, the coor-i dinator would insure that the NRC inspection is of the same defi-l ciencies the alleger identified. We have found in the past that taking the allegers on the site one of the best ways to take advantage of the level of detail and assistance which they can provide. That approach would be parti-cularly helpful at Comanche Peak, especially among those personnel with experience in documentation. Finally, we propose that the NRC establish a methodology i which provides equal time (including preparation time) to the allegers i to review the responses proposed by TUGCO to the TRT findings. This could best be accomplished through the establish-l ment of a review panel composed of members of the public, former CPSES employees, intervenors and any experts which were retained by the intervenors to review the adequacy of the resolutions proposed by TUGCO. This process would institutionalize much of the time consuming effort of recontacting the various members of the public or allegers for their comments on a particular response. Further, it would provide a process in which the NRC staff - rather than a single l representative - could direct questions at the intervenors or allegers who raised the concerns. These types of meetings have been going on, informally at plants where there are allegations and disputes over i resolutions, however these types of meetings have rarely been institu-tionalized. If such a procedure is considered GAP will provide the mechanism for setting up the meetings, contacting the appropri- . ate group of allegers, and insuring that the personnel have the ques-i tions and materials necessary to adequately prepare for the meeting. V '* -.- -.. L - 2 2 : ~l.~: - : X--T T

l, l a, ! \\j Obviously such meetings would, by financial necessity, have to be held in Texas. By efficiency we expect that the meeting, would be broken down by either discipline or by particular systems (i.e. problems in start-up, documentation deficiencies ) - t

3. iAllegation Recruitment Program I

i t GAP has been inundated with requests for help by alle-gers and intervenors at nuclear power plants accross the country. The primary reason cited for contacting us for help in investigating prob-l 1 ems is a deep distrust in the Nuclear Regulatory Commission. i. We have determined that this distrust among intervenors stems from a history of broken promises by the agency ' officials, un-professional and often rude treatment,by the agency., lawyers, and blatant agency-industry 'hobmobbi,ng" on techniggl tasues and legal arguments. Intervenors soon learn' that the agen'cy is rarely on the side of the public, t l Workers who contact us, however, usually have either' l little or no prior experience with the NRC or have only ' heard" that the agency can not be trusted. l Most workers (except those in Region IV) have no pre-determined attitude against the NRC. They think that the agency wants to make sure a plant is safe and the rules are followed, they turn to GAP as a way to get their concerns to the agency. Our program for flushing out allegations has been tre-j mandously successful at almost every. plant. We believe a similar pro-gram should be adopted by the agency as part of final agency re-view at each plant to preclude last minute allegation crises. We sug-gest that Comanche Peak be,the place'to start. Outlined below are the steps we think should be taken at this time at Comanche Peak plant to preclude a deluge of allegations throughout the remainder of the plant construction. I 1. Establishment of an NRC " hotline" for Comanche Peak workers to report their concerns. 2. An on-site NRC information program in which the TRT, its purposes, and the conditions of confidentiality l are explained 3. Publication and availability of the TRT's unanswered questions to those members of the workforce who can supply the answers. i n,. -.. 7- _,,_..7,,,,,,_.., p:

_4_ ( \\ 4. Establishment of a separate NRC exit interview and in-formation sheet for all departing employees, explain-ing their Department of Labor rights and their rights

and obligations under the law to report problems.

(GAP will be glad to provide a copy of the form we use during our major investigations) 5. A structural " debriefing" program which is conducted by skilled interviewers as opposed to technical in-spectors. GAP representatives will be glad to meet with any or all members of the TRT to discuss in more detail any of our proposals des-cribed in this attachment. i i ' l. t i e 5.

i in Octooer 26, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In tne Matter of' ) ) TEXAS UTILITIES GENERATING ) Docket Nos. 50-445-2 COMPANY,.et al. ) and 50-446-2 ) (Comanche Peak Steam Electric ) Station, Units 1 and 2) ) CASE'BRIEF IN OPPOSITION TO APPLICANT REQUEST 4 FOR NON-DISCLOSURE OF RELEVANT LIPINSKY DOCUMENTS In a letter to tne Licensing Board dated Octooer 18, 1984,. 4 Applicant refused to provide the parties with relevant documents regarding O.B. Cannon and J.J. L1pinsky, asserting that those documents were privileged oecause prepared in anticipation of litigation. (See letter to the Board, Octooer 18, 1984) CASE L i opposes the assertion of privilege and requests that the Board . order production of all of - the withheld documents. CASE and Applicant agree that if the materials sought i' represent attorney-work product then the standard to-apply in deciding whether to produce them is: A party may ootain discovery of documents and tangiole things otherwise discoveraole under paragraph (o)(1) of this section and prepared in anticipation of or for the hearing oy or for anotner party's representative (including his attorney,. consultant, surety, indemnitor, insurer, or agent) only upon a showing that the party seeking discovery has l suostantial need of the materials in the preparation of this h 1 6

case and that he is unaole without undue hardship to obtain 4 the. suostantial equivalent of the materials oy other means. In ordering discovery of sucn materials when the required snowing has Deen made, the presiding officer shall protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of an attorney or other representative of a party concerning the proceeding. - 10 C.F.R, 52.740(o)(2). At the outset it is crucial to' place the information Deing withheld into the context of the issue involved. The issue is whether, as the result of pressure Drought to oear oy Applicant its counsel on Mr. L1pinsky and/or O.B. Cannon,.Mr. Lipinsky or modified his previously held opinion 3 regarding the adequacy of the paint coatings, and QA/QC related to it, at CPSES. A part of that issue is whether Mr. L1pinsky had what he had indicated and celleved was a reliaole casts for changing his opinion. What is no t at issue at this point is the adequacy of the paint coatings program as sucri, an issue to De fully explored in the other phase of-the hearings. (It was apparently in preparation for the former issue that Mr. L1pinsky was preparing testimony.) In summary, CASE Delieves that Mr. Lipinsky was pressured, coerced, or influenced into recanting and changing the conclusions that he originally reached aoout coatings and related l quality control at Comanche Peak. In his original report of l August 8, 1983 aoout his trip to Comanche Peak on July 26-28, 1983, Mr. Lipinsky expressed a nusoer of serious concerns aoout the adequacy of the coatings quality control program at Comanche Peak. Nonetheless, over time Mr. L1pinsky recanted those concerns, ultimately culminating in an af fidavit filed with the Board on Septemoer 28, 1984. CASE DelleVes that numerous factors .e. _v-~%.e.,.- e,_y--,.,f -,,,y ---.,,w,....,--,._m,.co.,, v.-.- - ,---..,.-,-.--_----.w.--,._m.,__.

- point to' the very_ real possio111ty that Mr. L1pinsky was Improperly pressured or influenced into changing his conclusions aoout quality control at Comanche Peak, and indeed may have Deen coerced into participating in a " cover-up" of serious quality ~ concerns. d Because CASE has a substantial need of any evidence of pressure on Mr. L1pinsky to recant the concerns that he expressed in nis August 8, 1983 trip report and oecause any evidence of such pressure is clearly relevant to these harassment and intimidation proceedings, Applicant should be compelled to produce all of the relevant documents which it has until now w itnheld. The withheld information apparently contains draf t testimony proposed by Applicant's counsel representing what they wanted Mr. L1pinsky to testify to regarding the adequacy of the paint natings at CPSES; the information also apparently contains Mr. L1pinsky's reaction to that proposed testimony. Meeting f notes and letters apparently further memorialize the exchanges Detween Mr. L1pinsky and the Applicant'.s counsel on exactly what Mr. L1pinsky would and would not say. Thus the withheld t l Information will likely provide important evidence of any actual attempt to pressure Mr. L1pinsky and of any evolution of his testimony or views thereoy potentially proving that such pressure had oeen orought to near. A nunner of f actors point very strongly to the likelihood that Mr. Lipinsky was pressured, coerced or influenced into changing his appraisal of the coatings rpogram at Comanche Peak. 4 First, Mr. L1pinsky never undertook any audit of Comanche Peak l

- suosequent to tne July,1983 trip on which he cased his initial trip report. At least as late as four months af ter that initial trip, Mr. L1pinsky noted in his " diary" (produced in discovery Dy O.B. Cannon) on Novemoer 17, 1983, that any full audit of coatings at Comanche Peak "would or might confira JJL's concerns". The only " data" that Mr. Lipinsky received on the quality control program at Comanche Peak subsequent to his initial visit was the information he received during.the November .10-11 meetings with Ron Tolson, John Merritt and others (meetings whicn took place prior to the Novemoer 17 diary entry cited aoove, and in which L1pinsky Indicated that his concerns might De confirmed oy a full audit). Nonetheless, oy the time he met with NRC inspector Hawkins in January,1984, and certainly oy the time of his Septemoer,1984 affidavit, Mr. Lipinsky, without the Denefit of any new information, had reached radically different conclusions aoout the quality of the coatings program at Comanche Peak. Further evidence that Mr. Lipinsky was improperly pressured Into changing the conclusions that he had reached in his August 8 l l trip report can ce found in numerous other entries in Mr. Lipinsky's diary. On a nunner of occasions af ter the November 10-11 meetings (in which his initial report was " discussed" Dy Tolson, Merritt and others), Lipinsky made entries in his diary which indicate that an attempt was Deing made to cover-up the concerns voiced in the August 8 trip report. For example, Mr. l L1pinsky was clearly concerned that he might De pressured into l l perjuring himself: on NovemDer 14-15 he wrote at least three l l l l

times that he would not commit perjury, and felt the need to express that feeling to Norris, Roth, and Trallo. On November 17, Mr. L1pinsky wrote that O.B. Cannon President Roth was demanding that he sign a changed version of his original trip repo r t; L1pinsky did not. In refusing to sign the modified report, L1pinsky expressed a conce'rn that "the more JJN/RBR [No r ris/Ro th) talk to the utility or try to cover-up, the deeper OBC _gets -- OBC could have serious proolens if federal agencies perceive OBC committing f raud." (See Lipinsky 11/17 diary entry; received from Applicant in discovery) (Emphasis added) 2 L1pinsky further wrote on Novemoer 17 that: JJL pointed out [to Roth] that JJL has proDlem in signing a changed trip report (may De thought of as fraud). RBR (Roth) became flush and said that was not fraud, Dut final copy of memo / trip report, and JJL was to sign the changed trip report and place a copy in the Dlue three ring Dinder today. JJL said "yes sir" Dut did not sign the changed trip report. JJL draf ted a meno from RBR for RBR signature (telling JJL to sign the changed trip report), if RBR forces JJL to sign the changed trip report. L1pinsky was clearly feeling pressure to cover up and ignore his concerns. The pressure he felt was so intense that he felt the 4 need to protect himself Dy draf ting a letter in Roth's name l~ detailing that he had oeen forced to alter the report and to sign the changed copy against his will. CASE has no way of knowing to a certainty why Roth was pressuring L1pinsky -- i.e., CASE cannot L De certain that Roth was himself Deing pressured Dy the Appl.1 Cant or their counsel. Clearly, other correspondence Detween - L1pinsky, O.B. Cannon, the Applicant and their counsel, and any draf t testimony prepared during this period for L1pinsky will shed light on the degree to which L1pinsky was pressured and

. coerced into ultimately completely recanting the very real concerns that ne strongly felt Ef ter the November 10-11 seetings at Comanche Peak. M r. L1pinsky's diary contains numerous other indications that the recantation of his concerns was not completely voluntary, indications that will almost certainly De further evidenced if the documents that Applicant has refused to produce are in-f act produced. For instance, in notes on his Novemoer 22 meeting with TUGCO attorney Nicholas Reynolds, Lip,insky wrote: "JJL [L1pinsky] asked attorney (NSR) whose side they represented. Indications are that OBC [ Cannon] is not getting all info." The next day, L1pinsky wrote tnat ne pointed out to Trallo "that 2 out of 2 acetings were not what JJL had Deen led to Delieve -- what is going on, someone is not aoove ooard." These diary i entries oy L1pinsky are compelling evidence that the concerns that he voiced in his August 8 trip report were recanted oecause he felt coerced or was in some other way influenced to change his po s itio n. (See Exnibit 1) Additional evidence that uipinsky was pressured into changing his story aoout the adequacy of coatings and related f ' quality control at Comanche Peak lies in the f act that at the ~\\ NovemDer 10-11 meetings at Comanche Peak, officiated by John , Merritt and attended oy Tolson, Lipinsky, Trallo, Norris and four others-(see CHI Exh1Dit 4 of CASE's Preliminary Proposed Findings b.g. of Fact), Lipinsky said almost nothing. At that meeting, Tolson, Merrit and sometimes others characterized Lipinsky's concerns and purported to " address" them, Dut L1pinsky himself apparently did A i j, ~s u

. not fedl comfortaole enough himself to say. auch of anything. By eitner his own admission or the recognition of someone else at the meeting (contained in notes appended to the diary produce'd by 0.B. Cannon in discovery), there was a " lack of JJL talking on tape" (of the Novemoer 10-11 seating). Those meetings could l hardly have convinced L1pinsky that his concerns aoout coatings l and quality control at Comanche Peak were unfounded. The like21 hood that L1pinsky was coerced into participating in a " cover-up" of his concerns is lent additional, support oy the f act that O.B. Caunon President Roth was extremely sympathetic to the concerns of TUGCO and even hostile to the concerns voiced oy L L1pinsky. This " motive" for Roth to cover-up is. evidenced not only oy the diary entries cited aoove, out also oy Roth's own I categorization of Cannon's concerns. In a Novemoer 3, 1983 meeting with Joe George, Dave Chapman, John Merritt, Billy 4 Clements, Tony Vega, J.J. Norris and himself, Roth " apologized again for the lack of security at OBC, in that an in house meno ' leaked out' and had caused our client such consternation and new additional exposure to intervenors" (from Roth meno to file, dated 11/4/83, Exhioit 2). In a Novemoer 28, 1983 letter to Nicholas Reynolds, Roth wrote that " Cannon's posture is to support TUGCO/TUSI with whatever oojective and honest ef fort we can render". When these -professions of support for and apology 0 1 r to "their client" are viewed in the light of the intense pressure i aptlied oy Roth to L1pinsky to sign an altered version of his trip report, ~ the clear inference arises that the O.B. Cannon president, the Applicant, and/or their attorneys may have oeen seeking to paper over and cover up Lapinsky's concerns.

~ 3,, \\ v s g' r ~ / ' a '4 6 + Finally, support for the argument that 2,1pinsky was pressured into retracting his initial concerNi ls found in the L D repeated insistence by Doth L1pinsky and Trallo; that the concerns o s raised in the August 8 trip report would only De either allayed O }( g -t or conformed -if.a full audit of the plants were undertaken.,, For! l - 1 s3 example, L:e llo wrote in his November 28',' 1904 trip report that .[' >l' g ', lp,* ,N

• /

" Comanche Peak Site Management adequately' detailed the*, program and controls in place, which would relieve or allay the concerns A 71 A. ( i raised in.the "Lipinsky Memo". (See Exhibit 4) Cannon has nc' \\ Y* Dasis to confirm that these programs and.c'ontrols aN, in place.. N. n (> N and are Deing ef fectively implemented. Conf, ir matio,n.could only q De provided Dy a detailed audit." Sim'ilarlyc,,Lipinsky wrote in 1 ,/ his diary on Novemoer 17 that only an audit,,'which would require four to five weeks could confirm or alkay his initial concernss, .(See also the October 28, 1983 Lipinsky letthr, ExhiDit 3) ) Nonetheless, Dy the time he met with NRC inspector Hawkins in i January, 1984, Lipinsky was much less concerned with the adequacy - l: of coatings at Comanche Peak than he had Deen only a month s t earlier. (CASE is also concerned aDout toe'posgiDie inferences arising from the awarding to Lipinsky of raise only one and one-half weeks Defore his crucial meeting with Hawkins (see Lipinsky's December 23, 1983 diary entry), atipecially when viewed N ,4 .in the light of Lipinsky's fear for his joD' only six weeks ]l: earlier. (See L1pinsky's November 14 diary' } entry) J a s. Baseo on the documents that CASE has seceived thus far through discovery in these proceedings, there is simply no adequate explanation for Lipinsky's 180 degree aDout-f ace with M f + t. l N .e i f e ~.. -....,... _.. -,.. - - -,.. - -.. - -,. -. ~.... - - -. - - - - -.-. -,.... -.

c ...y _g_ .y 'w "Iregard to his feelings aoout tne adequacy of coatings and.related x " quality control at Comanche Peak. It seems incrediole that ( t- .Lipfbsky simply accepted.the explanations given oy Tolson at the Novemoert 10-11 meetings and oy Brandt in his testimony. On the contrary, suostantial evidence exists which gives rise to the j inference that L1pinsky recanted his August 8, 1983 conclusions either Decause of pressure applied to nia to cover up or some other reason unexplained and unimaginaole. As detailed Delow, a

g. 3 g. suosdantiated Delief in the likelihood of a cover-up provides a dsufficieni snowing of necessity to require production of t

s documents that might otherwise De undiscoveraole under 10 C.F.R. 3 \\ 52.740(o)(2) or Federal Rule of Civil Procedure 26(o)(3). .g -' 10 C.F.R. 52.740(o)(2), adapted f rom Rule 26(o)(3) of the c, a, Y Federal Rules of Civil Procedure, allows discovery of trial preparation materials upon a showing oy the party seeking . discovery of "suostantial need of the materials in the ' preparation of nis case and that he is unaole without undue .nardship to oDtain the suostantial equivalent of the material oy (g cener means." The allegations detailed and suostantiated aoove l' N J, [19 ,and in Exhioits 1-5 satisfy the requirements of this. standard: k ) Applicant should tt erefore De compelled to produce all of the by relevant L1pinsky documents. l h As a preliminary matter, CASE notes that no time need De spent on the " undue nardship" prong of this standard: CASE

,,L ooviously cannot hope to ootain the suostantial equivalent of the materials witaneld here oy other means.

The contempor'.neous i. -notes and written draf ts of positions taken oy or proposed to Mr. V E ks \\. s . m 11pinsky are the uniquely superior evidence of what transpired -- possiole pressure, coercion, cover-up -- and no similarly rellaole evidence exists anywhere else. - CASE's need for. the withheld L1pinsky documents is apparent. If Mr. Lipinsky recanted his initial concerns aoout quality at Comanene Peak only Decause he was pressured into doing so, and only as part of a larger attempt to cover up the quality control 4 L proolens at Comanche Peak, then his initial concerns.still stand. Indeed, those concerns cast serious doubt over the. adequacy of Comanche Peak's coatings program.1/ Claims of necessity very similar to CASE's claim in this motion have Deen recognized by the Federal courts as a sufficient showing of necessity to justify production of otherwise t-undiscoveraole work-product documents. In In Re Grand Jury Suopoena Dated Novemoer 9,1979, 484 F.Supp. 1099 (S.D.N.Y. 1980), the district court ordered defendant's lawyers to prcduce withheld documents which the Government (the party seeking discovery) alleged would provide evidence of a cover-up. The court characterized the Government';s claim of necessity as l l compelling, stating that an assertion that documents sought will 1 provide evidence of a cover-up is an even stronger claim of 1/ This issue is not moot if, in reality, the sought after documents contain evidence of attempts (regardless of their success) Dy TUCGO QA management to cover up the seriousness of Lipinsky':s initial concerns. On October 19, 1984 Applicant suositted to the NRC its Program Plan responding to the findings of the NRC's Technical Review Team (TRT). Mr. Ron Tolson, the very individual descrioed by several witnesses in this proceeding as the cause of the QA deficiencies in coatings, was named as Project Leader for the resolution of all coatings problems. (See Exh1Dit 5)

_ 11 - - necessity than other claims routinely accepted oy courts. 484 F.Supp. at 1103. (Tne court in In Re Grand Jury applied the standard of Rule 26(o)(3) even though the case oefore it involved a grand jury case, not a civil suit. 484 F.Supp. at 1102) The courts in Doth In Re Grand Jury Suppoena Dated Novemoer 9, 1979, 484 P.Supp. 1099, 1105 ( S *. D. N. Y. 1980) and In Re Grand Jury Inves tiga tio n, 599 F.2d 1224, 1232 (3d Cir. 1979) recognized that a mere naked assertion of a cover-up does not co,nstitute a sufficient showing of necessity to warrant ordering discovery of work product. However, in this proceeding, as in In Re Grand Jury Suppoena, 484 F.Supp. at 1105, a suostantiated claim of a suspected cover-up has oeen alleged. The requireuent of suostantiation means only that the party making the assertion of cover-up suostantiate its Delief - the party needn't prove its allegations in order to compel discovery. 484 F.Supp. at 1105. CASE has offered a quantum of evidence suostantiating allegations j l. Attached to this orief are the Octooer 31, 1983 of a cover-up. meno in which Mr. L1pinsky reconfirmed his initial concerns; a Novemoer 28 memo in which Mr. Trallo emphasized that none of the concerns raised in the August 8, 1983 trip report could De completely put to rest unless a full audit was done (and none ever -was done); and numerous excerpts f rom Lipinsky's diary which l; indicate that he was pressured into recanting his testimony and l l may have oeen forced to participate in a cover-up of the concerns raised in the initial report. Further, the record in these proceedings contains the August 8 trip report, a transcript of the Novemoer 10-11 meetings, the January interview of L1pinsky oy Hawkins, and the Septemoer 28, 1984 affidavit of Lipinsky. l

However, in view of the f act that Lipinsky ultimately recanted nis initial concerns without ever performing a suosequent audit at Comancne Peak, the record completely lacks any legitimate reason for L1pinsky's shif t. Indeed, the gaping lack of a leg itimate explanation for Lipinsky';s shif t lends further support for the argument enat Lipinsky was pressured or coerced into recanting and covering up. Finally, CASE does not concede that the documents withheld oy Applicant are eitner privileged or contain attorney work t product prepared in anticipation of litigation. Indeed, without I seeing those documents, CASE cannot De sure what they contain. There is suostantial evidence that tne drafts of testimony and otner documents likely contain proof of improper pressure on Mr. L1pinsky to recant nis story; evidence of this improper pressure [ is not " privileged attorney work product.*jb/ Even if the Board does find that the documents do contain privileged work product, CASE has demonstrated its substantial .need for those documents. Lastly, if the Board is reluctant to ( 2/ Consumers Power Co. (Midland Plant, Units 1 and 2), ALAB-691, 16 N.R.C. 897, 917 (1982), cited Dy Applicant as justification for witnnolding the relevant L1pinsky documents does not control this case. First, Consumers dealt with the possiDie discover-ability of ordinary drafts of testimony. However, the Lipinsky drafts were very unlike the typical draft testimony case. Here the focus is on the possioility that those draf ts will point to pressure and coercion of Mr. Lapinsky to change his original story. The documents sought are sought precisely to show that the ultimate testimony was coerced and thus unreliable, no t to prone attorney thought processes. Second, though Consumers addressed tne possibility that draf ts of testimony signt De privileged f rom discovery, it did noc reach he merits of that h ques tio n. The Board in Consumers decided or ' that counsel who asserted the privilege could not De censurt ar making that asser tion, it did not decide whether the drcits were in fact privileged. l l _ - _ _ _. _ - - - - _ _ _ _ _ _._=, _ _ _. _ _ _ _._ _.__ ___ _. -. _ _ _.- _ _ _ __ _.__ _ _.-_ _ _

4 ' allow CASE to view the documents in their entirety without first ascertaining their contents, CASE urges the Board to view those ' documents y camera to determine whether tney contain evidence of pressure and cover-up. If they do, then Applicant snould De denied. its assertion of privilege. For all of tne aoove reasons, CASE requests that the Board order production of all of the witnheid documents. Respectfully submitted;- b \\ b/ u ANTHONY Zd ROISWAN WO - Trial Lawyers for Public Justice 2000 P Street, N.W., Suite 611 Washington, D.C. 20036 (202) 463-8600 Counsel for CASE p t-a l l ~..

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OLIVER 13. CANNON Q SON INC. sxnist n s ( 'd DEPARTMENTAL CORHESPONDENCE O DATE Ffecting TUSI - Dallas licadqu. art ers - Wednesday 11/3/83 - RE: CO.'!ANCllE PEAR COATINGS SUDJECT-File cc: JJNorris, RATrallo T3 FRONI - DE0th Joe George, Vice President - TUSI Dave Chapran, Corporate QA Manager - TUGO John Merritt, Jr., Assistant Project General Manager - TUSI Billy R. C1.ments, Vice President-Operations - TUGO Tcny Vega, QA Manager to Chapman - TUGS R. B. Roth & J. J. Norris - O. B. Cannon & Son, Inc. 1. Session siarted at 3:00 p.n. and was principally on clients reaction to August 8, l'.*83 Joe I.ipinsky trip report. In general, with only a three ( day site visit in July, 1053, certain"of the positions taken by Joe, and \\ stated as ' factual', would have taken weeks of close examination and evainations according to the clients people. 2. RiiR cpologized annin for the lack of security at OBC, in that an in houst. inmno ' leaked ont' and h.id caused our client such consternation and new additioaal emposure to inteivenors.

3.,In answer to RER specific qu.*stions, Billy Cismonts said that site Q. C.

i r(ports directly to him, also, contrary' to Lipinsky inemo, site QA Manager, Tolson, report s t o him.-ad not to Production. Dave Chapnan readily con-s i fitued this. Further, Teulron is a TUC0 man and not Brown & Root. 4. Joe Ccorge is Vice President and has complete charge of C. Peak, lie g emphasized that Erown & Roor, currently are essentially Labor Brokers and s suggcuted by Li iinsky wmo, whether he is calling the shots. 11cace, a' l Brown & Root tvould be receptive to, or responsive to a Cannon audit and/or I the findings thereof is a m'.ite point with TUSI.

5. ' JJNorris raised po*nt of writing NCR's, or the lack thereof, and C1cuants and Dave Chapnan respon& d t hat nothing in 10CFR50 requires "NCR".

TUGO clected to have 'u.c:at infactory reports' as their rnechanisin for identifying corstruction or celui[m.nt deficiencies. \\ 1 e...._

<- 01.1\\1:R H. C.\\NNON ri SON, INC. s t. Hecting TUSI - Dallas !!cadquarters Page 2-6. HilRoth asked further who has responsibilitics for generating QCP's, QAP's 4 nd QIP's and Ch.ip. nan answered, TUGO, throu;;h Teinison's gr oup. Jack added th.it he was present, when JJr.ipinsky ra t with Toulcon and Toulson's rimark about 'not his concern' related lo',the Plant bicansing Procedure and not to JJLiplakys's voicing his view.of the quality of work and inspection at the site. 7. EURoth suggest ed that to further addrecs C. muon and TUST concerns on the Class I coatings, and recognizing its been three mnths or bett er since C.mnon i<tado any actual site inspections, that C innon set up a Taskforce Group, to visit the site ASAP and. take shatever time is required to cosac up with a realistic overview of the coatings effort,

e. specially since the retro. fit program was effected around the first of Septinber.

8. All..grei d - we were t. hanked for coming to Dallas on short notice and the in. eting adjourned. {'- 9, 1983.

9. ' R11 Rot h to set up the Taskforce Group, to cum.cnce site visit Novetabor f

4 g,h-R. B. Hoth /s W ( D -wein **

DEPARTMENTAL CORRESPONDENCE DATE October 28. 1993 a SJECT _. Texas Utilit ics Services - Letter _ dated October 27, 1953 R. B. Roth OM-J. Lininnkv i 1. In addition to the individuals identified in the subject trip report, the writer act with a number of the coating quality l control inspectors. l These individuals were: 1.anet t e Adams i Dave Ambrose l Cary Corrigan Joe Deshanbo (sp?) Margaret Lucke Evert Houser Casandra Owen 1 Note: The writer net other inspectors but cannot recall the individual names. The writer discussed job status, project conditions, work activitics and other miscellaneous itens with the above individuals. The writer has either employed or worked with the above listed individuals on one or more nuclear projects. 2. As stated repcstedly by the writer, a thorough review / audit would be required to provide specifics on the ziz itens listed by 3. N. Chapman. However, the following explanation is provided for each item as listed by D. N. Chapman. A. Material Storage - the writer observed that the coating material is mixed, and ret on pick up pallets outside Containment. None of the material had tags attached (status or six information), and there is no apparent control on how long mixed material sits on the pallets. B. Workmanship - at the time of the writer's visit the applicator qualification program was being administered by production personnel with no inspection or monitoring of the* qualification proecss (befer during or after) by quality control. This information was provided to the writer by Mark Wells of site engineering and quality control. With regard to the quality of the work, the writer observed numerous areas of in place wo.rk which by appearance was less than the quality of work put in place by Cannon on nuclear and non-nuclear projects. one 315 - - ~ e-w-e n--- e-w- - " '

c. ~. J To: R. B. Roth Res Texas Utilitico Services Letter Dsted 10/27/83 October 28, 1983 Pste 2 a Additionally, the writer was i f , by engineering and/or production that a low individuals n ormed on more than one oc .any good as p(ainters.34 out of 452 individuals) emplperce n the report formet utilized oCompliance with AN oyedaspaintqrswereno C. nts - the writer only briefly exami Also, ANSI has requirements foall of the requi n site. included en,the inspectiohH ned. manuf acturers' instructions, to neuthere ar ra reports. e stcrial storage, tagging, andcatio D. e a few. "Possibly" coating integrity t E. Possible document deficiencies sce item E and F on page 4 T. Norale probicas - based on conve see Item C above personnel, including those individrsation with various i f the writer concluded thatthe ins'pection personnel on th vere not satisfied with their job s. H. WilliamsTo the writer's knowledge e project J are no longer,on. Deshanbo, E. Nouser, C. Owen and I the project .3. As indicated in the subject site as of Octob6: that 'prclininary assesscent btrip report, when the writer 31, 1983. problems t painter qualification and indo t iin areas of material sto y J. J. Lipinsky, that Comanche PadvikedR c r nation), not satisf..wcrke.enship (quality o ments and possibic co eak has not my job or concern"ating integrity', he (M. Tolso )ying ANSt require of coating integrity (and that The itees indicated, with the preplied *"That 's n opinior., with quality related e t is debatabic) deal, at ossib e, Thet is not exception to believe that R. Tolsonhis job or com rn".s ters and R. Tolsor., least id the writer was indicating that he (R. Tolson)Th cerned with quality. . e inclined 4. C. Brandt was not con-advised them (C. P.randtand R. Tolson mentioned T. Mille ' Cannon employees (inspectors)and R. Tolson) that approximatr sp The. writer was referring to i were or are employed on the projeely 5 ct. See item 2B abr.ve. ssues raised in Item 2 above 6 7 In the writer's opinion and at the meeting of July 28 apparently in the opinion of th result , 1983 (see page 2) this was the situati of this a get Inspectors and foremen togeth ose individual together was planned to bring the Quality based on follow-up conversatio on. As er. ontrol ns with the site personnel e, _ _ _ _ _ _, _ _. _ _., _. ~ _. _ _.. _. _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _

^ To: R.'B. Roth l' ka: Texas Utilitico Servicca October 28, 1983 . Letter dated 10/27/83 Page.3 8. Apparently, the air compressors or air supply' lines were not providing cican (water and oil free) air, and up to half the shift, approximatc1d five hours, was utilized to make the air quality acceptabic. l-

9.. Zimmer has probicas related to coatings as a result of placing more emphasis on production than they (Zitweer) did on quality.

It is the writer's opinion that this appears to be a hang-up at Comanche Peak. ' IOJ The writer based this statement on conversations with inspection staff in what appeared to be poor instructions in the procedures (though tfie writer cannot recall specifics), coupled with the number of changes to the specifications (most of which catered toward relieving requirencntd l on areas or items where requirements could not.be satisfied. l The implications of the writer's statement is that somewhere down the road, another set of eyes may or may not concur with my assessment. l-(' 11. See It ens 2 above. l 12. As a result of the meetings attended by the writer, the site management! i pcopic (R. Tolson) declined the offer of Cannon to perform an in-depth l l sudit that would have either confirmed or satisfied the concerns I raised. 13. The writer based this on conversations with site inspection personnel and the apparently disinterested attitude of R. Tolson, when advised of potential coating quality problems. 14. Sec Item 2F above. j 15. The writer is unable to recall the names of inspection personnel encoun while-in the field. Ilowever, two of the topics frequently discussed we the quality of work and where employment possibilities may currently ex \\ l 16. There is an honest internal disagreement in the manner in which ANSI rcl quirenents impact the cost of a project and the quality of the, work. 17. Sec Item 12 above. 18. The writer based this observation on previous work experience, and suggests that the coating manufacturer be contacted to confirm same. Note: power grinding on isolated areas of one aquere foot or Icss should not be a probica. 19. Again, the writer based this observation on previous work experience and suggests that the coating manufacturer be contacted. However, old l'henolinc #305 (one year or more, wit,h weld fume accumulation) may not ..., m.. m.. ~..u.a. n L. u... -. .......,.....,....,................,,................ u.

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19. - continued be adequately cleaned and provide sufficient intercoat adhesion by solvent wiping.

20. The writer's'spceiality is Quality Assurance / Quality control, as,these terms deal with coatings and the writer's offer of an in-depth audit (in order to confirm or alley quality concerns) was repeatedly rejected Also see Items 3 and 12.

21. Based on the writer's observations on site.and my past Nuclear site experience, the work observed in place appears que'stionable with regard to quality. (Again, an in-depth audit /reviev snay resolve this issue.) Also, any attempt by Cannon or any qualified professional applicat or to gselvage "in place work", may not be practical or realistic, certainly, isolated areas may prove acceptable and perhaps complete rooms may be okay. However, realistically and from a cost /cffective viewpoint, l " rework" is more logical considering production effort and the attenden: documentation.

22. 'Sec Itcrn 21 above.

l r Additionally, the retrofit program insy well resolve the writer's concers but I have not reviewed the adequacy or results of the retrofit program Realir.ing that the writer is not. familiar with the results of the retro) program, I cannot comment one way or the other on the acceptability of J l retrofit program. 23. The writer distributed the trip report to n. B. koth and J. J. Norris, < or around Au, ast 8, 1983. 24. .The writer did discuss the subject mat ter in my trip report with p., Noui Field Coatince Quality Control Supervisor, on. subsequent trips to the project site. \\' ?i l ) i MQN M /L y Jokehhipibeby i Dated: I .) . r...,,.,.

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OLIVER 5. CANNON Q SON. INC. Exhibt 94 .i DEPARTMENTAL CORRESPONDENCE November 28, 1983 DATE ,4301 - Coatings Overview Task Group Reporl o, ort B.'Roth v.ph A. Trallo l

Background:

Cannon Personnel Concerned: Robert B. Hoth - President and Chief Executive Officer Ralph A. Trallo - Vice President Nuclear Services John J. Norris - Vice President and Project Account Manager John J. Lipinsky - Corporate Quality Assurance Directdr M. Keith Michels - Corporate Quality Assurance Lead Auditor On November 4,1983 a Cannon Task Group consisting of the writer, J. J. Norris, J. J. Lipinsky, and M. Keith Michels was established to perform i i follow-up'cvaluation of items previously addressed within the scopo protided under our Consulting Services Contract

• with this client.

This follow-up was to be in accordance with guidelines set forth in departmental correspondence from Robert B. Roth to the writer

• and the principle purpose detailed was to evaluate the nuclear coatings retrofit program at Comanche Peak. Key areas included:

t Material Storage and Control Painter mechanic qualification / documentation Working relationship between Production / Inspection Status and adequacy of documo'ntation/ traceability l l Implementation of coatings retrofit effort, see " Painting Minutes of Meeting", pagr>s 1 to 4, dated S/15/83, as prepared by R. M. Kissinger, Project Civil Engineer Compliance of Nuclear coatings to Project Specifications requirements Overview as to adequacy of current safety-related coatings in place, as per proper Industry practice, etc.

• 1000 Purchase Order No. CPF-15245
• Departmental correspondence R. B. Roth to R. A. Trallo, 11 81-83

[

.:. ~, ^ T.,_[ -.;_ __L. ' ~ ~ -d-- y.l,L, '\\ _z , cLWER fl. CANNON 0 SON. INC. 3 H-8301 - Coatingo Ovtrvitw Teck Grrup Riport - TO: Robert 8. Moth November 28, 1983 -Page Two-f II. Preliminary Preparation: The writer discussed the operation and purpose of the Cannon Task Group with the other participants. A point of departure schedule was established in aceprdance with Robert B. Roth's memo guidelines, and preliminary checklists were prepared to facilitate orderly progression and review.3* The intent war to have OBC QA Services (Lipinsky and i [ Michels) and J. J. Norris (Account Manager) onsite for wh'atever time was l ~ required to complete the necessary reviews. R. A. Trello was to visit the site to perform an overall evaluation as to the effectiveness of the 1 Cannon Task Group activities. Con.mencement dates for site activities were: November 9, 1983, J. J. Norris, J. J. Lipinsky and M. Keith Michels onsite to begin pieliminary reviews; November 10, 1983, the writer onsite to insure effective implementation of the Cannon Task i Group activities. i ( l III. Task Group Activities-l On November 8, 1983 I called John Merritt to advise him th'at Oliver B. Cannon personnel would be onsite November 9, 1983, and requested that he have available the folllowing information for review: ) Organizational chart with names and titles of individuals and positions filled I I Copy of current revision of the QA Program I Complete cooperation with various onsite departments, organir.ations and individuals List of namea of all inspection personnel and lovel of certification List of nancs and positions of production personnel (foremen and above) List of cortified painters and systems for which the painters are qualified -3 "JJL and Hot comanche Peak Trip Plan" (il Pages) ~..... -

OLIVER 11. CANNON r, SON, INC. H-8301 - Qoatingo Ovarvicw Tcck Gr:up R: port TO: Robert B. Roth November 28, 1983 h Pags Three-III. Task Group Activities: (continued) Liason or interfaco person for quality assurance, quality control, production, and other departments in order to expedite and aid in the performance of,this review l Mr. Merritt requested that any reviews conducted by OBC 9ere to be performed on a joint bas %s (ie. QA and Accout Management). Cannon personnel were onsito the morning of November 9, 1983 At that 3 time J. J. Lipinsky gave a copy of the preliminary review checklist. to John Merritt. J. J. Norris and John Merritt discussed the checklist and Mr. Merritt requested a " kick off" meeting prior to any formal reviews or implementation of Cannon Task Group activities. It became evident that the scope of the Cannon Task Group activities which had been previously outlined

• were not' coincident with that perceived by TUGO.

Mr. Merritt requested a review meeting to discuss the concerns of the "Lipinsky Memo"

• and based on the outcome of that meeting TUGO would re-define the scope of the Cannon Task Group activities. The review meeting was held commencing Thursday, AM, November 10, 1983, with John Herritt chairing.

Mr. Ron Tolson, Construction QA Supervisor, started the discussion. In essence the "Lipinsky Memo"

• was used as an agenda, and each memo paragraph, or statement, was discussed and clarified. The meeting was recorded and the transcript has been distributed for comment. It became evident that ocrtain statements in the trip memo
• were incorrectly stated or misinterpreted. This was principally due to the organizational structure at Comanche Peak.

(ie. A management team consisting of individual's employed by different organizations.) T

2. - Departmental correspondence it. B. Roth to R. A. Trallo, 11 11-83 3*

"JJL nnd MKM Comancho Peak Trip Plan" (il Pages) f> - Trip Iteport (JJL to it!3H) 8-8-83 "Lipinsky Memo Ho'eting on November 10 and November 11, 1983"

04.WhR ll. CANNON C[ SON, INC. ~ " - ~ ~ ' ~ ~" H-8301 - Coatings Ovsevicw Tcsk Group Rgport TO: Rabort B. Rsth .f November 28, 1983 Page Four p_ Mr. Tolson explained the operational ' coles of the individuals involved on the Comanche Peak Team, along with their proper titles, responsibilities, and lines of reporting. i Concerns raised in the "Lipinsky Memo"

• were for the most part, based on observations and discussions between Joe Lipinsky and site personnel. At face value this "information," would be the cause for raising concerns regarding the site coating activity. Throughout the course of the November 10 meeting, it was evident that Site QA l

Management at Comanche Peak was not interested in further audits, or E program reviews, since they have been subject to numerous outside and internal reviews and audits in.the past several years. These constant and sometimes redundant reviews, compounded by the apparent personnel matters,resulted in short or clipped responses, which could readily be misinteiproted. i. Recarding areas of coatings material handling, personnel qualifications, non-conformances, and quality responsibility, Mr. Tolson discussed the current procedures and controls in effect at Comanche Peak. This detailed information not readily. available to Joe Lipinsky during his site visit of July 26, 27, 28th, 1983, and on which visit he based his _ August 8, 1983 trip report to Robert B. Roth. Comanche Peak Management stated that they do not feel they have a problem in the areas of concern, as raised in the "Lipinsky Memo."

• A detailed indepth audit was not agreed to.

However, a review of specific items could be scheduled, or program " paper" be made available for review, at Cannon's request. After consideration the Cannon Tank Group decided that a limited review was unwarranted, since it would not provide sufficient support to a statistical extrapolation as to the entire coatings programs' ofrectiveness. ( Detailed discussion and information is provided in the notes of the November 10 and Novcxbor 11 meetings. (Reference footnote 5.)

• - Trip Report (JJL to RBR) 0-8-83

}. ~

Q1.1Wl(13. CANNON C, SON INC.

H-8301 - Coatin6s Overview Task Group Report g TO: Robert B. Roth November 28, 1983 Page Five

== IV. Conclusion:== The Cannon Task Group did not perform the total overview function as originally scoped by Robert B. Roth. This was due to the request of our client to explore and review the "Lipinsky Memo"

• in further detail, paragraph by paragraph.

The site meetings of November 10 and 11,1983 resulted in the following: The concerns raised in the "Lipinsky Memo"

• Were based on limited information and observations which were neither investigated nor discussed in sufficient. detail, during his site visit, to either allay or to confirm.

l-_ Comanche Peak Site Management adoquately detailed the programs and controls in place, which would relieve or allay the concerns raised in the "Lipin' sky Memo."

• Cannon has no basis to confirm that these programs and centrols are in place and are being effectively implemented. Confirmation could only be provided by a detailed audit. Such an audit could be redundant and certainly time consuming ~. Further, TUGO has neither requested same, nor is it required by the referenced Purchase of Services Agreement.

Based on the information provided by the Comanche Peak Site Organization we can assume that our concerns are unfounded, however, affirmation could only be finalized by further effort. ql Ralph A. Trallo HAT:jr I i 4 - Trip Report (JJL to HBR) 8-8-83

OLIVER B. CANNON Q SON. INC, DEPARTMENTAL CORRESPONDENCE DATE November 4. 198'l EUBJECT .14_118301-Coatines Overview Task Croup. Cannon to TUST'. Com,nche Penk TO R. A. Trallo. J. 3. Norris. J. J. Lininsky. M. Michele cer APMe. Acce Filn 5303g R. B. Meth 1. As a follow-up to car Consulting Services contract over the past summer, for this client, I am assigning this Cannon Task Force to l perform a Nucicar Coatings overview at the Comanche Peak Nucicar Plant, being constructed by Texas Utilitics Services, Inc. at Glen Rose, Texas i 2. Task Force to be: R. A. Trallo - Vice President - Nuclear Services J. J. Norris - Vice President llouston Operations J. J. Lipinsky - Corporate QA/QC K. Michcis - Lead Corporate Auditor 3. Site eff ort to commence, k'ednesday morning, November 9,1983.

Jack, Joe and Keith to report on Wednesday. Ralph may not be abic to schedule till later in the week. There is no established time limit.

I suspect from three to 'five days may be necessary, but the best judgment of our seniot managers involved will so ascertain. Ralph is designated as Task Force Leader.

4. Principal purpose is to evaluate the Nuclear Cuatings Retrofit Program that has been in effect over the last 3 to 4 months.

Key areas would include: Haterial Storage and Control Painter mechanic qualification / documentation Working relationship between P'roduction/ Inspection Status and adequacy of documentation / traceability Impicmentation of costings retrofit ef fort, see " Painting Hinutes of Meeting", pages 1 to 4, dated 8/15/83, as prepared by R. M. Kissinger, Project Civil Engineer Compliance of Nu'c1 car coatings to Project Specifications re-quiraments. ( Overview as to adequacy of current sa' ety-related coatings in f place, as per proper Industry practice, etc. - onc 315

.2.z:. -. OLIVER I). CANNON 4 SON, INC. To: R. A. Trallo, J. J. Norris, J. J. Lipinsky,.K. Michels November 4, 1983 Re: Job H8301 - Task Group Page 2 5. Separate individual and objective reports are due to Task Leader and his composite report shall be submitted to my office within five working days after site assignment. Ralph is further charged with the security of the reports / observations given to him and his composite report shall be directed to me..and no other copies issued or distributed. 6. I shall then communicate the results of our effort to TUSI. 7. All costs and expenses involved shall be submitted in separate expense envelopes, with appropriate receipts and c1carly marked with Job fH8301. 8. Any questions or clarifications to the above shall be addressed to my attention. .1 ,.) iIi' ? Jl'n -{ R. B. Roth /1 l t l l L l ,.,en w .-->-_-----.---,m,- wvve,n.--, - -, ,-rw,,r,meen.rm--... -, - -, - ,..,----www..--.----n,-.-----

r: memo ewrc 5 Page 1 cf 4 J.)L_&WMC0mrOEPEAKTRj NT.0: Organization.21 chart with n.vnes and titles of individuals and positions filled Copy of current revision of the QA Program Complete cooperation with various on site departments, organizations and individuals . List of nam:*s of all inspection personnel and level of certification List of names and positions of production persdnnel (foremen and above) List of certified painters and systems for which the painters are quallfled Require liason or interface person for quality assurance, p & 4 - y_- quality control, production, and oth1r departments in order ~ to expedite and aid in the performance of this review C PAY #1 Revic'w QA Program in general Review QC Procedures and how those procedurcs related to the s QA Program Go over QC Procedure num6ering sequence Review site organization and responsibilities (both individual and company', ~ Review Retrofit program (why implemented, still on-Oning-why? why nut?, what has been accomplished to date) Tour Site (containment, paint shop, warehouse, calibration lab, etc.) i NOTE: Dadge !!Kil as tim.! a]Ious e p p g 4...

~ P3y: 2 cr a DAY #2 Non-Confirming Conditions ~ Review existing NCR's ( Review procerfore for unsatisfactory reports to determine adequacy Review procedure for NCR to determino adequacy Review logs for NCR and unsatisfactory report Review status tag procedure and logs Review NCR and/or unsatisfactory coordinator status Procedure and Spccification Revision Control,* Review system and procedure for changes to specification and procedurcs Revicw controls - assure th'at only most current revisions of specification and procedurcs are utilized Examine on site situation to determine sequence of work activities g DAY d 3&4 Material Storage Review procurement documents Review receiving procedures and records Review personnel qualifications 'for receiving personnel Review product certification Examine reject and hold areas (review tagging procedures and logs) Examina facilities (take reprencntative batches and determine if procedure followed) Review warehoosing records Examinc facilitics and check calibration of recording therinographs (examinc certificates of compliance for instrun"nts, calibration recnrdr. for instruments, (] pursennal for individuals performing calibrations) V' Determlnn tr.reability of material frnm receiving to in place work ira. *"irehousing recards and clally reports (nico galoti I..ickw.irds f ra n in place work)

• Page 3 of 4 DAY #5 Personnal Qualifications Painter Qualifications Revicw indoctrination and training program Observe (if possibic) class room session and field quallrications
• Review documentation on personnel qualifications Inspector Qualifications Review indoctrination and, training program -

Review personnel qualif1* cation with regard to level of certification Review documentation on personnel qualifications Auditor Qualifications Review personnel qualifications for auditors ( Review documentation on personnel qualifications Audits N Review audits of the coating operation l l DAY #6 Calibration Review calibration Icos Review certificatas of compliance for test instrumenta Review traceability of instruments to NBS Review training and qualification of calibration personnel / Review documentation of personnel qualifications 4 n.

T Page 4 of 4 DAY #7 & S Daily Inspection Reports Review adequacy of daily inspection rcoorts (compared to information require J by A:ssI) Octermine traceability of records for representative arcas and/or items DAY #9 & 10 Wrap up and tic together items that were examined earlier. 140TE: The above schedule is tentative in nature and 1,s not meant to be all inclusive. Arcas or questions raised during the Icview will be pursued until a r'esponse is'provided. e o j e e O e \\ e e 0' 1 e e e 9 c.,_.[_.,, _f*,*,'*

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C i ~ October 26, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1 In the Matter of -) ) TEXAS UTILITIES GENERATING ) COMPANY, et al. ) Docket Nos. 50-445-2 ) and 50-446-2 (Comanche Peak Steam Electric. ) Station, Units 1 and 2) ) CERTIFICATE OF SERVICE By my signature Delow, I hereby certify that true and l correct copies of CASE's Brief in Opposition to Applicant - Request for Non-Disclosure of Relevant Lipinsky Documents, nave been sent to the names listed oelow this 26th day of Octooer, 1984, Dy: Express mail where indicated Dy *; Hand-i delivery where indicated Dy **; and First Class Mail unless [. otherwise indicated. i l -Administrative Judge Peter B. Bloch* U.S. Nuclear Regulatory Commission - 4350 East-West Highway, 4 th Floor Bethesda, Maryland 20814 HerDert Grossman* Alternate Cnairman ASLB Panel i U.S. Nuclear Regulatory Commission 4350 East-West Highway, 4th Floor Bethesda, Marylend 20814

1 d

t 2-l o Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074 Dr. Walter H. Jordan j 881 W. Outer Drive Oak Ridge, Tennessee 37830 Ms. Ellen Ginsberg, Law Clerk

• U.S. Nuclear Regulatory Commission 4350 East / West Highway, 4th floor Bethesda, Maryland 20814 Nicholas S. Reynolds, Esquite
• Bishop, Lioerman, Cook, Purcell & Reynolds 1200 17th Street, N.W.

Washing ton, D.C. 20036 l Stuart TreDy, Esquire

• I Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission l

7735 Old Georgetown Rd., 10th Floor Bethesda, Maryland 20814 l Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General l Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk Dallas, Texas 75224 A-ANTHONY S g OISMAN g ii t i i L}}