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7c 1d3 OFC 03 ISM ,
Ms. Billie P. Garde Government Accountability Project 1555 Connecticut Avenue, NW NETUTWE Suite 202 Washington, D.C. 20036 Cear Ms. Garde:
On Tuesday November 27,1984. Mr. R. sma members of e Comanche Peak lechnical Review Tea _m (TRT) met wit ,
f
' ' [and yourself to iscuss certain aspects o '
investigation into a legations raised regarding the Comanche Peak facility.
In accordance with your request, we are enclosing a copy of the transcript of the interview. We will provide you with a Safety Evaluation Report when it has been completed.
If you have any questions, please call me or Mr. R. Wessman at the following ,
numbers (301) 492-7903 and/or 492-8432.
Sincerely, Vincent S. Noonan, Project Director Comanche Peak Technical Review Team
Enclosure:
As stated DIST:
w/o encl.
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t; :TRT
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___:_______ _ g ____________:____________:____________: M- L O<_ ]_h:_ ]_y_l____
AME :RWessman:pf~:VNoonan : : : : :
ATE :12/3 /84 :12/X/84 : : : : :
OFFICIAL RECORD COPY 860710o476 PDR FOIA 860624 GARDE 85-59 PDR h 3 _ _... J I
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' # UNITED STATES
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NUCLEAR REGULATORY COMMISSION .
,j WASHINGTON, D. C. 20555 O
.....f DO N OT DISCLOSE Ms. Billie P. Garde Government Accountability Project 1555 Connecticut Avenue, NW Suite 202 Washington, D.C. 20036
Dear Ms. Garde:
On Tuesday November 27, 1984. Mr. R. Wessman members of the Comanche Peak Technical Review Team (TRT) met with
~and yourself to discuss certain aspec s o -
investigation into allegations raised regarding the Comanche Peak facility.
In accordance with your request, we are enclosing a copy of the transcript of the interview. We will provide you with a Safety Evaluation Report when it has been completed.
If you have any questions, please call me or Mr. R. Wessman at the following numbers (301) 492-7903 and/or 492-8432.
I Sincerely,
'e
. nar , Project Director 6 anche P k Technical Revieu Team
Enclosure:
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AFFIDAVIT DO NOT DISCLOSE
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C My name is I am submitting this affidavit freely and voluntarily without any threats, inducements or cotercion to Mr. Ernest Hadley, who has f
! identified himself as an investigator with the Government ;
- l Accountability Project (GAP).
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l This statement covers my concerns over the breakdown A
of the Quality Assurance (QA)/ Quality Control (QC) program l l
' l 1 at the Comanche Peak (CP) nuclear power plant under l construction in Glen Rose, Texas. I Fro assigned to the Comanche Peak power plant. Prior 1
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. . . . ,, 'k' l- -' , , - ^ 6 Based On my previous
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experience, I have developed several concerns about the CP plant. .
My concerns over the breakdown of the QA/QC Program at Comanche Peak fall into two main' categories: 1) flawed -
procedures which do not violate any particular regulation of which I am aware, but are not consistent with industry practices and pose p o't e n t i a l safety hazards; and 2) =
procedures which represent regulatory violations and pose substantial safety hazards. The examples used in this affidavit do not represent an exhaustive list of my concerns and should not be used to limit my allegations.
1 It is my belief that the flawed QA/QC inspection
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procedures at Comanche Peak reflect a major problem with upper-level management at t h ;2 plant. The tendency of upper-level management is to relax standards whenever 2- 4 s
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AFFIDAVIT OF DO NOT DISCLOSE management feels interpretation will permit, rather than erring on the side of caution. Final Safety Analysis Report (FSAR) committments are construed liberally instead of conservatively. This is not consistent with my experience in the nuclear industry. If the Nucleaar Regulatory Commission (NRC) Regulatory Guide states that a certain item "should be" or "should not be" done a certain way, TUSE will usually interpret this committment as discretionary and not follow the NRC Regulatory Guide '
unless it suits the company's purpese. My own experience in the field indicates that the trend within the industry is to interpret such language narrowly and treat such provisions as mandatory.
An example of this liberal interpretation of committments is apparent in the practice at CP of using Craft personnel to perform functional testing. In particular, I am personally aware of several instances of Electrical Testing Group (ETG) Craft personnel performing functional tests without a Systems Test Engineer (STE) being present during actual testing. In one test performed by ETG Craft it was necessary for workers to rotate two i
l wires on an alarm system in order to make the alarm work.
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AFFIDAVIT OF DO NOT DISCLOSE The test was performed without an STE being present in the field to observe and supervise the testing. I also know that approximately 100 percent of the breaker testing at the plant was performed by ETG personnel without an STE being present during testing.
Another example of this practice exists in the Emergency Evacuation Lighting System.
he STE esponsible for the system had signed off on approximately 300 tests records where Craft had performed the prereouisite testing and the STE was not present during the majority of th6 testing.
wrote a Test Deficiency Report (TDR) against these tests, but I am uncertain of the number of the TDR or its disposition.
I feel this practice of allowing Craft personnel to perform functional testing without an STE being present is not consistent with ANSI 45.2.6., which requires that personnel have a certain level of qualifications in order to perform testing. It is also not consistent with my experience of the way functional testing is performed at
- 4 -
AFFIDAVIT OF DO NOT DlSCLOSE other nuclear plants.
1 An additional problem presented by this practice is that it is not apparent from looking at the documentation on the tests that they have been performed by Craft personnel without an STE being present. In fact, a review of the documentation would suggest the opposite. In order to fully understand this problem, it is necessary tor me to describe my experience of the manner in which testing is peformed at other sites. In the normal scheme of testing, Craft personnel will carry out the physical testing under -
the direct supervision of an STE who is present in the field at the time of the testing. In this scheme, the
" performed by" block would be signed by the STE. However, at CP the FSAR standard is interpreted to require only that an STE review the paperwork of the testing, and not that he or she be actually present during the testing. The signature by the STE only indicates that he or she has reviewed the testing documentation and that it appears to be in order.,
The result is that documentation at CP I
appears to comply with industry practice when, in fact, it does not.
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AFFIDAVIT OF DO NOTDISCLOSE I am concerned that these tests performed by Craft personnel without an STE are invalid since the personnel performing the testing do not have adequate qualifications, or at least do not have supporting documentation for their qualifications. I am further concerned that, because of the manner in which these tests are documented, it is not possible to identify which tests have been performed under the direct supervision of an STE. In fact, it may be necessary to reconduct all tests in order to ensure that they have been peformed properly by qualified personnel.
I also believe the testing procedures are flawed in other ways. For example, it is a common practice at CP to work on more than one system with one Start-up Work Authorization (SVA) and use only one system number. I am personally aware of instances where many systems.were worked on in the Auxiliary Relay Rack, but only one system number was used on the SWA. The result is that different portions of the same system are tested by different STE's and, by the same token, one STE is responsible for testing portions of several systems instead of testing one entire system. The overlap is confusing and may lead to portions of a system being overlooked during inspection. This I
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AFFIDAVIT OF 00 No f' DISCLOSE practice is also not consistent with my experience in the industry where it is preferred to'have one STE responsible for an entire system.
Another flaw in the testing process at Comanche Peak is that STE's are not provided with a computer printout-which informs them of all tests that are required to be performed on a system. It is my experience that the Bechtel Corp. provides such a printout to its STE's a t' -
nuclear sites. Essentia11'y, the printout provides the STE with a checklist and insures the STE performs all the relevant and necessary tests. The failure to provide such a printout at CP, means STE's are left to determine on 4
their own which tests are required, and when they are finished testing a system. The likely result is that each i
STE devises his or her own scheme for testing a system.
This means there is no consistency in testing at the plant and some tests may be overlooked or omitted.
O 7 -
AFFIOAU$T GF DO NOT DlSCLOSE As an example, I am aware that on or about March 15, 1984 it was discovered that the instantaneous trip setting calculations on approximately 100 breakers had not been performed corra cly. This omission was only discovered because iployee went beyond what he was qualified and required to do and attempted to
~
check the calculations. s checking the paperwork related to t. h e s e breakers to verify ,the size and attempted to heck the calculations at the same time. I am !
not certain how it was determined that only 100 brea'kers' were involved. I believe that there could be more,'but -
I without a computer system it is impossible to tell except l l
by checking all the present test records. A TDR shoul d have been written against these faulty test records.
l Another flaw in the testing procedures occurs in the breakdown of interaction between Prerequisite Testing j
(Prereq.) and Preoperational Testing (Preop.). It is my experience that at other nuclear power plants certain steps of testing performed during Prereq. are again performed during Preop. to insure they were, in fact performed, and performe_d properly. This is not the case at CP where it is assumed that Prereq. Testing has been completed and performed properly. This means that, in some cases, at Comanche Peak portions of Prereq. Tests are being used to prove FSAR committments.
3-
AFFIDAUIT ,CF
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. .- ;;CLQ$[
CPSES Prerequisite Test Instruction XCP-EE-3, " Circuit Control Testing", Rev. 6, further complicates the flaw in the interaction between Prereq. and Preop. testing. Note (1) to Section 7.8 provides that "(einergized functional testing of control circuits is desireablei however, if the STE deems this impractical, de-energized functional testing will suffice." Since steps performed during Prereq. are not necessarily Vepeated during Preop., this means that it is possible that a system can pass through both stages of testing without ever undergoing an energized functional test. It is highly possible that this has happened with many light indicators. I am further concerned because the test instruction provides no guidelines that assist an STE in det, mining when energi:ed functional testing is
" impractical", and there is no notation on test I
documentation that indicates the functionah testing was de-energized.
r I
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{ The_above paragraphs represent my concerns over what I consider to be flawed testing procedures that can lead to errors and omissions in the testing process. As I stated i
! above the examples cited in this affidavit should not be used to limit my concerns. Rather the examples are used i
i 3_
l I - - - - - - _ - - - - - _ . . . _ _ _ - _ _ - -
[
AFF1 DAVIT OF a,SCLOSE for illustrative purposes and I believe indicate an overall ,
failure of the QA/QC program at Comanche Peal:.
My second categ'ory of concerns regards procedures that I believe represent actual violations of specific regulations and, in some instance's, represent substantial safety hazards. I also believe the following examples further indicate the breakdown of the QA/QC program at Comanche Peak. -
L As an example, I believe that Cable Separation -
Specification 2323-ES-100, Rev. 2, is in violation of Regulatory Guide 1.75. A portion of ES-100. Section 4.11.3.2, provides, "(m)inimum separation between a conduit (safety related or non safety related) and a bottom or side of a tray (solid bottom or ladder) shall be one inch."
This is not consistent with the minimum separations l required by Regulatory Guide 1.75, which provides that conduit separation should be at least five feet from the bottom of a tray and thr ee- f eet from the side, except in the cable spreading room where it can be two feet from the I
side and three feet from the bottom.
I I am particularly concerned about the above situation
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l AFFIDAVIT OF DO NOT bixLUSE j i
since, if I am correct in my interpretation of the regulations, then the entire plant has been built using errant specifications. In order to correct this situation, it would be necessary to reinspect all cables and conduits at the plant to ensure proper separation. I am not the only one who believes that.ES-100 is in violation of Regulatory Guide 1.75. I am aware of one instance where a i Design Change Authorization (DCA) was written against ES-100 to change a portion of the procedure unrelated to cabia separation. The Gibson Hi'.1 employee who was asked to authorize the change refused to sign off on the OCA because of the violation existing in ES-100.
Another example of the violation of regulations at CP is in the practice of regularly using " butt splices" on both quality and non-quality cables. Butt splicing is used on a routine basis at Comanche Peak where cables are not long enough to reach their intended destinations. (Butt splicing is a means of physically attaching a new length of cable to an existing length of cable using a crimp to secure the attachment.) The problem with butt splicing is that, if it is not properly done, the cables can separate posing a potential fire hazard. This potential hazard is heightened by the fact that the majority of the butt
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AFFIDAVIT OF
' dJT.DISCLost splices are in bundles cf cables and the hazard extends beyond the cable that has been spliced to the cables that i
surround it.
It is my understanding that butt splicing is specifically prohibited by the NRC. I have confirmed this belief by contacting the NRC Region V Office. In particular, it is my understanding that Regulatory Guide. .
1.75 specifies that cable splices in raceways should be prohibited and further, that if such splices do exist, the resulting design should be justified by analysis and submitted as part of the FSAR. However, at Comanche Peak, DCA 19264 and several other DCA's allow butt splicing of quality cables. At Comanche Peak not only do the butt splices exist, but in some cases no notation is made on desigr. drawings that the splices exist. As a result, there may be no record of where butt splices have been made. It l
l is my belief that it will be necessary to reinspect all cables and conduits for butt splices since'no records tre l kept of ,their existence or location.
I am particularly concerned about the practice of butt splicing because of its potential for starting fires, and because it is my experience that there are many fossil fuel AFFIDAVIT OF Ji DISCLOSE i
plants where butt splicing is not allowed.
AnothEr incident which I believe shows a failure on the part of upper-level management to follow nuclear regulatory guidelines and a lack of'committment on the part of management to an adequate QA/QC program -involves the j .:
breakdown of ferroresonant transformers provided by Westinghouse. In February of 1983, two of the transformers
- failed on same weekend and a third transformer' failed within one month of that time. There are four inverters and each' inverter has its own transformer. If any two of the transformers fail there is an automatic scram and the plant shuts down. Although these problems occurred in February of 1983, it was not until February of 1984 that TUSE filed a report pursuant to 10 C.F.R. 50.55(e) with the NRC. This delay is particularly dis' concerting since shortly after the failure hese transformer failures were similar enough ,
to cause me concern particularly since Westinghous
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AFFIDAVIT OF D0 hurolSCLOSE maintained that no other nuclear plants had reported having problems with the transformers. It is also my belief that after the transformers at Comanche Peak failed, Vestinghouse discovered some defective transformers in its factory.
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I also feel the NRC should r e v'i e w the results of ~ test PT 55-11. This is a thermal expansion test. on piping where ..
I understand that 60 percent of the test points failed the .
acceptance criteria. These f'ailures were due to the fact
~
that the pipe either moved too far or moved in the wrong' direction. The reason for this movement could be that s on.e 260 pipe supports were not installed prior t o' t h e test run.
The test was further flawed by the fact that temperature
. readings of the pipe were not properly taken. Although temperatures were taken and logged during the test, the calibration of the test devices was not logged. The result is that traceability of the testing devices has been lost.
At least two TDR's (853 and 355) have been written against these t e s,t s . However, I am uncertain as to their resolution. I am further concerned about this test because Engineering has provided no justification for the "use as is" determination on this piping.
. - 14 -
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.", 7 AFF10AVIT OF DO NOT Dldu_va Another area of concern e ists in the practice of QC
- personnel keeping log sheets of problems spotted during inspections instead of writing Non-Conformance Reports (NCR). The QC procedur es provide that before ccmponents are turned over to TUGCO, QC inspectors do not have to write NCR's on problems they discover. Instead of writing i
NCR's, the inspectors are instructed to keep a log of.the ,
problems they discover and their disposition. I believe, but am not sure, that this procedure is covered by the Construction Procedures in the section on Procedures for Non-Conformance Reports. This informal practice of keeping logs means that no formal records are kept of many of the problems discovered by QC inspectors.
1 I
I .
I am cor.municating these concerns to Mr. Hadley so that the information contained in this affidavit can be transmitted to the NRC for investigation. I have asked Mr.
Hadley to hold my identity in confidence because I have been subjected to substantial harrassment anu intimidation for bring _ing my concerns to the attention of my supervisors
AFFIDAVIT OF DO IVOT DISCLOSE \
4 I have read the above 16 page affidavit and it is true 1
and accurate to the best of my knowledge. '
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Sworn and subscribed to before me this M day of nc
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,/41984
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My commission expires
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Ann'ex 3 Conversation Record Allegation Number N/A Time 4:30 P.M. Date 09/14/84 Type Visit _
Conference Telephone
- Incoming x Outgoing Name of Person (s) Contacted or in Contact With You Organization Telephone Number
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SUBJECT:
POTENTIAL ALLEGATIONS AS PREVIOUSLY INDICATED TO R. WESSMAN BY GAP.
SUMMARY
- Msaid that he had received two telephone calls from GA.P (names not known) but he did not have anything for them. He did not have any .
QA/QC concerns about CPSES, nor did he ever talk to anyone about anythina.
The only incident he could recall at all was the followino: 4 conths ago, h.is supervisor asked him to make copies of all CMTRs (Certified Ma erials e orts) for materials supplied by the vendor, Gulfalloy Co., fromthe vau and return the oriainal l CMTRs to the vault. This reques apparently from iho works for and involved 350 sets of CMTRs speculated that these copies of the CMTRs were'taken (cont.)
Name of Person Document % Conversation RC Tano Signature k/ Date 09//M8a Name(s) of Other Persons Whc Were Present During Conversation N/A I have reviewed the sunmary of the conversation with the individual (s) named below and agree that it accuratelv represents the conversation. '
Signature of Person Providing Information _ I/_[]r Y~l A '
File: Allegation Work Package cc: Project Director .
Group Leader Additional pages may be attached as needed. Additional pages should be identified, signed, and dated.
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SUMMARY
- to Dallas or some hearings, but claimed that he had no knowledge as !
(cont.) to whether they were falsified and that GAP had told him that he had '
information re falsified records. said that the originals of the CMTRs had been returned tot e vau after he made the copies.
He said that the copies had been left in the box at the vault for pickup and apparent were picked up since they were not ther the _,
day, said that he had informed his supervisor of the p one calls from GAP and NRC, and would call -
md~ r e information later.
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Gv-Telecon with B. Garde 1/24/85 (1342)
I contacted B. Garde in order to ascertain the names of various GAP witnesses so that the TRT may arrange for feedback interviews with these individuals.
Ms. Garde told me that she could not divulge these names since many are stJll employed by TUGC0 and they want to maintain. confidentiality. Specific GAP -
witnesses I requested included C, D, I, J, P. W, 0, #4, #37.
Additionally, Ms. Garde indicated that many of these witnesses have additional concerns which she would like to pass on to us if their confidentiality could be guaranteed. '
On another matter she mentioned that she.has available unnotarized affidavits which she would like to pass on to NRC if we can guarantee their confidentiality. The individuals involved are no longer at TUGCO.
.J. fh F0A-85-59
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CONFIDENTIALITY AGREEMENT -
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I have inforr.ation that 1 wish to provide in c'onfidence to the U.S. Nuclear Regulatory Cocaission (HRC.). I_ request an express pledgeI of confidentiality will act provide as a ccndition of providing this infonnation to the NRC.
-his information voluntarily to the NRC without such confidentiality being extended to me.
It is cy understanding, consistent witti its legal obligations, the NRC, by agreeing to this confidentiality. will adhere to the following ccnditions: i i
identify me by name or pers.onal identifier in any URC l (1) The NRC will notconversation, or connunication released ,tc the public which initiated dccument, I unc.arstand the- term "public i relates directly to the information provided by me.
reletse" to encompass any distribution outside of the NRC uith the exception of c-har public agencies which may rec.uire this. information in futherance of their responsibilities under law or public trust. ,
I (2)
The NRC will disclose my identity within the NRC only 'to the extent re-cuirec for the conduct of NRC related. activities. .
(3) During the course of the inquiry or investigation the NRC will also make
- every effort censistent with the investigative r.eeds of the Cc=nission to avoid actiens ;;hich wcuid clearly be expected' to resuit inAtthe discicsure a later stage Iofunderstand my ident-ity to persons subsecuently contacted by the NRC.
t .at even though the NRC will make every reasor.able effort to crc act my identity, ny identificatien could be compelled by orders or In subpoenas sucy cases, issued the basis by courts for of izw, hearing bearcs, or similar legal entitites.
crantir.; this promise of confidentiality and any other relevan- fac s will be cc. .unicated to the authority' ordering the disclosure in an effort to maintain.
tv ccr.fidentiality.
If this effort proves . unsuccessful, a reprcser.tztive of t'he
- [:.C dill attempt to inform me of any such action before disclosing cy identity.
the NRC will consider ma to have waived my right te con-I also ur.darstand that fidentiality if I take any action that may be reasonabiy expected to disclose my' i d e nti.ty . I further understand that the NRC will consider me to have waived my richts to confidentiality if I provide (or have previcusly crovided) ! ;rc.idic c information the NRC
-[try, cthar party that centradicts the infcrma-ion that
- - 4' circ; sta ces ir. dica e that I am inten-icr.aily provi ing # if it ir f orma tica
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2-hir CC'.citiCDs* (if,any)
~ ! zgree with I hive retc and fully ur.derstand the ccr. tents cf this agretmen .
Address: g p l
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Name: Chesive. lkt9
Title:
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-Q.- CONFlDENTIAllTY AGREEMENT o
I have information that I wish to provide in c' nfidence to the U.S. Nuclear Reculatory Cocaission (HRC-). I_ request an express pledgeI cf confidentiality will nct provide as a ccndition of providing tiiis information to the f4RC.
-his information voluntarily. to ~the NRC without such confidentiality being extended to me.
It is cy understanding, cons' stent with its legal obligations, the I RC, by agreeing to this confidentir.lity. will adhere to the following conditions:
(1) The NRC will not identify me by name or pers.cnal identifier in any NRC initiated dccument, conversation, or communication released I uncarstand,to thethe.
public term which "public relates directly to the information provided by me.
release" to encompass any distribution outside of the NRC uith the exception of
- har public agencies which may recuire this infornation in futherance of their responsibilities under law or public trust.
(2) The NRC will disclose my identity within the !!RC only 'to the extent re-cuired for the conduct of HRC related. activities. '
(3) During the course of the inquiry or investigation the NRC will also make
- every effort censistent with the investigative needs of the Cc=nission to avoid acticns : hich wcuid clearly be expected to result inAtthe disclcsure a later stage Iofunderstand my ident-j ity to ;srsons subsecuently contacted by the NRC.nat evsn though the NRC my identificaticn could be compelled by orders or subpcenas In sucy cases, issued by courts the basis for of i t, , hearing beards, or similar legal entitites.
gra ,tir.; this promise of confidentiality and any other relevant fac s will be ce=unicated to the authority' ordering the disclosure in an effort to maintain.
y ccr.ficantiality. If this effort proves unsuccessful,'a repraser.:ative of the
- i:.C will attempt to inform me of any such action before disclosing ny identity.
I also ur.darstand that the NRC will consider ca to have waived my right to con-fidentiality if I take any action that may be reasonabiy expected to disclose ay
- l identigy. I further understand that the NRC will consider me to have waived ay rights to confidentiality if I provide (or have previcusly crovided) I prc.idic :cinformation
-he URC I: Iny c:hsr .Erty that centradicts the infccma: ion that i-fo rma ticn
- 4# circu sti .:es ir. dica e that I am inten;icr.aily provi:ing 'tirt
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- -her Cc .citicas
- - (if. any)
I agree with I' have read and fully ur.derstand the contents cf this agresmen:.
Address:
Agraed to on behalf of the US !!ucle5r Requiatory Cch@r.np lj .
Q. .C.
... R0 (gg, ggy 1 -: ,
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Name: CAe w e. b M ar .
T.i tle: g% CooaMA Co e g o W E N .c.'. J G
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Q CONFIDENTI ALITY AGREEMEtiT
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I have infor:.ation that 1 wish to provi,de in confidence to the U.S. Nucle Regulatory Cor-aission (HRC.). I will nct provide as a condition of providing this information to the HRC.:his info extended to me.
It is my understanding, consistent with its legal obligations, the NRC, by agreeing to this confidentiality. will adhere to the folicwing conditions:
The NRC will not identify me by name or personal identifier in any HRC (1) initiated decutent, conversation, or cocmunicatica released .to the public whichI unc relates directly to the information provided by me. f release" to encompass any distribution outside of the HRC uith the exception o
- .:har public agencies which may recuire this information in futherance of their responsibilities under law or public trust. _
The NRC will disclose my identity within the !!RC only 'to the extent, re-(2) cuired for the conduct of HRC related activities.
(3)
During the course of the inquiry or investigation the HRC will also make every effort consistent with the investigative r.eeds of th i:y to rsrsons subsecuently contacted by the NRC.even though the NR
- na:
my identificaticn could be compelled by orders In sucy or cases, subocenas the basis issued for by cou 13 -:, ' earing beards, or similar legal entitites.
grantir.; his promise of confidentiality and any c-her relevan. f ac .s will be cc.=enicated to the authorityDordering the disclosure in an effort y ccr.fidertiality.
- iRC will attemp- to inform me of any such action before disclosing cy identity.
I also ur.dcrstand that the HRC will consider ma tc have waived my right to con-fidentiality if I take any action that may be reasonabiy expected to disclose my ident i.ty. I further understand that the NRC will consider me to have waived my rights to . confidentiality if I provide (or have previcusly crovidad)
! :rc.ided tc the URC information
- - ir...c-hEr pirty that centradicts the infctma-ion that ~
i;st irformatien
- 4# ci cr5tt :Es ir.dicate that I am inter,-icnally provi:ing #
- ..c Gc.
- .ir Cc.ci:icas: (if.any)
' I agree stith I' hive read ar.d fully ur.derstand the ccr. tents cf this 2;resmen:. !
i.s previsicas.
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Agreed to on behalf of the US !!ucle5r Regulatory Cem.issicn.
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I have information that I wish to provide in confidence to the U.S. !(uclear Reculatory Cc,cmission (liRC-). I_ request an express pledge of confide'ntiality I will nct provide as a ccndition of providing tiiis information to the i4RC.
~
this .infor:ation voluntarily to the NRC without such confidentiality being extended to me.
It is my understanding, consistent with its legal obligations, the fiRC, by agreeing to this confidentiality. will adhere to the following conditions:
(1) The lihC will not identify me by name or personal identifier in any I!RC l initiated document, conversation, or communication released I unct r' to the oublic stand the. termwhich "public i relates directly to the information provided by me.
release" to encompass any distribution outside of the liRC with the exception of
- thar public agencies which may recuire this information in futherance of their responsibilities under law or public trust.
(2)
The liRC will disclose my identity within the !!RC only 'to the extent < re-
- cuired for the conduct of liRC related, activities.
(3) During the course of the inquiry or investigation the !!RC will also make
- every effort consistent with the investigative r.eeds of the Co=sission to avoid actions which wcuid clearly be expected' to resuit in Atthe discstage a later esureI of my ident-understand ity Int-to persons subsecuently contacted by the flRC.evan though the NR cy identification could be compelled by orders orInsubpoenas sucy cases,issued by forcourts of the basis izw, hearing beards, or similar legal entitites.
grantir.; -his promise of confidentiality and any other releva my ccr.ficer.tiality. If this effort proves ur. successful, a represer.tztive of the
.ti:.C will attempt to inform me of any such action before disclosing cy identity.
I I also ur.derstand that the liRC will consider me to have waived my right to con-fidentiality if I take any action that may be reasonably expected to disclose ay ~
ider.ti,ty. I further understand that the liRC will consider :.e to have waived my rights to confidentiality if I provide (or have previcusly crovided) information 3C trty that centradicts the inferta-ion that ! ; rc.ided to the !:
circ;tstisces indicate that I am inten-ic.. ally provi:ing # 1ist iricrnaticn
. Eny, c-her -
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- -he !!Ac. ,
Mher Cc .citions:- (ii; any)
= cf this agreemen . I agree with I'have read and fully ur.derstand the ccr.te i s prcvisions. .
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Agreed to on behalf of the US Huclear
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