ML20207A657

Recommends That Region IV Consider Reopening Allegation 4 of Insp Rept 79-15 to Asertain If QC Inspectors Intimidated or Repressed,In Light of Testimony Surrounding Alleged Inadequacy of QC Insps.Supporting Documentation Encl

ML20207A657
Person / Time
Site:	05000000, Comanche Peak
Issue date:	10/05/1984
From:	Treby S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Bangart R NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
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References
FOIA-85-59 NUDOCS 8607160044
Download: ML20207A657 (35)

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{{#Wiki_filter:t + Cctcber 5, 19E4 l t t'OTE TO:. - n Richard Bangart, Director - 5 ., / d x /l, 6'.~ z. Pegion IV Ccmanche Peak Task Force + ~ - / i 7 ;.l

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g :'C:, FRCM-(tuart A. Treby ,Y ' Assistant Chief Hearing Counsel

SUBJECT:

RECPENING OF INSPECTION REPORT 79-15 (JULY 2, 1984) o During the September 18, 1984 hearing session, CASE sought to use Inspec-tion Report 79-15 as part of their case on intimidation. See Tr. 16,730-32. This Inspection Report has been identified as Staff Exhibit 120 and admitted into evidence in the main licensing proceeding for CPSES. After argument by the parties (Tr.. 16,734-747), the Board ruled that it would be received into evidence in the intimidation portion of the CPSES hearing licensing proceeding. Tr. 16,746-747. - 'The Board also stated that the Staff "oucht to recpen that investigation [ Allegation 4 of Inspectian Report 79-15] and try to speak with this individual again and to other individuals that were working at the time at the pool, to find out what was going'on with the inspection effort." Tr. 16,744 In light of the substantial testiceny surrcunding the alleged \\- .? inadequacy of the QC inspections of the fuel pcci stainless steel liner welds, we recommend that the Regicn give serious consideration to the s. Board suggestion that this investigation be reccened. to ascertain, whether, 3 s s even though the lines are considered non-safety related, this represents /- ~ an instance in which QC inspectors were intimidated or otherwise repressed jr discouraged frca prcperly folicwing applicable QC inspection procedures. + 5 t Stuart A. Treby Assistant Chief Hearing Counsel, cc: T. Ippolito f f J=W((y)Q'K Q}r' p 9p 3 J w s 3 w 11 5 DISTRIBUTION: ,GSMizuno MKarman WBrcwn, Reg. IV 3 LEBachmann ESchristenbury O/C file GAEarry JPMurray Chren file SAireby JLieberman CPS ?OR/LPCR &.M.:,,-.,,~':aL' 4 7; d'% E- . l_ c a. w y_3._ 8607160044 860627 PDR FOIA GARDE 85-59 PDR t e

I ' back througn that listing. .i. 4 JUDCZ B LOCII : Okaj. I Just want to clarify,; 3 ;j are all of the welds that were mentioned by CASE now t i 4 accounted for in one way'or another? i 54 MR. ROISMAN: No, there,were, I think, at i.!. 6 !! least'three in Mr. Downey's recounting last week that he e l' 7 was not able to -- he thought they existed but they l.i. 8(1 didn't have them and no one has made a proffer to us of 1._.. 9 '; those. 10 } MR. DCWNEY: And we have judt not had an i: I 11 I. occortunity to work on those three weld numbers. We don't i'. l 12 I have an answer for those yet. l 13 JUDGE BLOCH: Okay. Mr. Roisman, I think L 4 14 perhaps the best way to proceed with this witness would be i L Ic by v.our conductinc an examination. p 16 ! MR. ROISMAN: Yes, sir. I i Mr. Chairman, actually, before we even 17g i: 18 do that, we want to make an e f fer of proof with regard to i i i 19 q-this issue and submit into evidence certain trafeiers and p i 20 it documents. (1 First of all, on July the 27th, 1982, the 21. I 22 ! Staff Exhibit 120 was received into evidence in this I l proceeding. 23 i t 24 We simply want at this pcint in the record 25 to note that we consider that document to be relerant tc 1 1

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~== enis -cart or the proceeding, and we intend to reference it ~ 3 i-2 l in our final findings. s i e 3 l We have orovided the -carties and the Board .i 3 -J -l l this morning with a copy o f that Staff Exhibit 120, which 1 5! is a July 2nd, 1979, letter from the Nuclear Rec.ulatory 1 6 I Commission to Texas Utilities Generatine. Comoany relating 3 7 i' to an investic.ation by the NRC of allegations regardine. i;i i l'l various improprieties with respect to stainless steel e -.9.J 7c liner welc,ing and inspsetion. 11 10 l They relate both to reactor building Unit 1 1 11 l and 2, and also to the fuel pool building, but it all 12 l relates to liners. e I 13 Secondly -- a_ l 14 Il JUDGE BLOCH: Is there anv objection on 1 15 th a t, or do the parties want to reserve that for their I 16 I later filings? i i 17 MR. DOWNEY: We would like to reserve anv I i 18 ob4Jection until we've had an opportunity tc review the i l l i 19 i document. i i si l 20 j MR. ROISMAN: Mr. Chairman -- l + i 21 l MR. MI:UNO: The Staff -- I'.

sorry, 1

i 22 Mr. Roisman. Please continue. 23 MR. ROISMAN: I'm merely noting it's 24 already in evidence, so that I ascume the f c rm o f an I l i 25 l' obiection would be to strike or somethinc like that, l t 1 i i i l 1 i

1, I mean it went in three vears acc, two years ac.c, excuse .e., 9 : i 1 I Just wanted to let the parties know, and as a courtesy .) 3 :1 we gave them copies o: it-last night. s 4 JUDGE BLOCH: Sure. I I 5! MR. ROISMAN: All right.

Secondly, Miss "Gart e will at 6

l this point read off, and I will tell t 7 l you what we have done, we've gone through in -- I think I i 8 l the word is random, we have done a random review of the 9 documents that were brought into the,rcom in the boxes, 10 some over the course of the weekend, some la'st night. I 11 I will state for the record that access 12 l was less than satisfactory. We were not provided with a ~13 ! private room where Taa could look at them. There were 14 Applicant's pecple present and our people were told that 15 there would have to be an Applicant person present when l 16 l they looked at the documents, so they didn't feel free to li i 17 discuss them. 18 l Nonetheless, we've gone through, and what I t 19 ) Mist Garde is going to do is to identify particular a 20 l travelers which we wish to have put in evidence in a non-4 21 evidentiary way but just for the Board's elucidaticn 22 indicate what that traveler shows. 23 Now, we don't think we need anybody's-3 24 l testimony about it, it will be apparent en its face. We're j 25 : Just going to tell you that you'll find in that document i l 3 a i i i I 6

.c - s "I i 1 JCCGE 3LOCIi: Mr. Mizuno. i i MR. MIZUNO: Yes. I would like-to now I j 3 I make a statement regarding the use of Staf f Exhibit 120, which appears to be Inspection 7915, dated July 2nd, 1979. l c At this time the Staff would like to 6 . indicate that it woulc object to the Intervenors' use of 7 this document in this portion of the proceeding for .I l}e .e !! several reasons. 4.__. N 9 First of all, and this may be just a llJ 0 10 problem of clari.fication in" terms of what evidence mav be i ll 11 lj cited in which c. art of the proceedinc., but it was my 12 understanding that all -- the reco rd for the intimidation 13 ; portion of the licensing proceeding was to be developed 14 ! during the July evidentiary depositions and subsecuent i I 15 l hearings, and so it's unclear to me whether this exhibit t 1 16 s is within tne reco.rc or intimication. I t 17 Assuming -- that's a minor thing, but -i ii la assuming that it is, the Staf f still has a problem for two 19 reasons. 1. 20 l First of all, my preliminary review of 21 this document shows that the allegations, and I believe i there were seven or eight o f them, have nothing to do 22 ' 23 with intimidation or threating or harassment o f CC inspectors. i 24 Rather, t h e v. relate to technical er:blems 25 involving the welding o f the Liner pcol, and I believe l l l it l 4 b

-13 ~~ " j that enose :inds of questions would be better addressed the proceeding relating to the technical issues as 2 in 3 - opposed to inttmidation. { .i h d JUDGE BLOCH: Well, m.v e.ve rests on 5 ;! I Allegation No. 4. L I 6 l MR. MIZUNO: I believe that if you go 1 7 through the discussion of Allegation No. 4 you will find 6 n 8 that there is no -- t'he person who made the allegation _. 7. t did'not say that, you know, QC inspectors had been 10 threatened or forced to approve these inspections over c 1i 11 l' the phone, I think it was. 12 ll As a matter of fact, I think the intent l 13 j. of the allecation is that the QC inspector went ahead en h li 14 4 his cwn volition to try and violate the procedure. I l. I 15 think there's no indication, at least as far as I can tell 4 16 4t in the allegation itself, that the CC inspector did '. : i 17 because he had been forced to do so. 18 In any case, apart from the fact that this 19, inspection report does not appear to involve allegations 20 l of intimidation of QC inspectors, the Staff believes that t, 21 f it would be tardy for the Intervenors to now attempt :: 22 introduce this document into evidence at this time and to 22 cite it in their response of findings. f i 24 If they knew that this inspection report i 25 l contained in fo rma tion that was relevann to their side cf i I t 1 I t i I i i I, t

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essentially determined that although the factual matters -17 i of the allegations may in :act be true, that there was .o t J l concern : rom an ultimate safety standpoint, and you will it I l find that the reason given by the NRC inspector is 1 3 precisely the same reason which Mr. Brandt testified ahtut, I 6 i to-wit, one,,the FSCR does not specify the refueling pcti 7 as a safety related construction, and'second of all, that 8 the ultimate -- the only reason that these welds were being ~ Y' u' sed and the ultimate standard for acceptance was this 10 question of leaking through and that the' inspector 11 recognizes in the inspection report that there vould be a 12 final test, I think it's a PT test, a dye penetrant tes, 13 l as well as a vacuum box test, and I don't have the 1 14 inspection report in front o f me but if I -- I i 15 JUDGE 3LCCH: We recall the test. It's t 16 ckay. You m.ay proceed. i l 17 i MR. MIZUNO: There's a reference in the l! inspection report referring to that fact. 18 39 20 i l 21 l 4. 23 24 i 25 I ? l i i i .I l s t

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.1. 1 states, cuote: "No items of noncompliance or 4 + 2-deviations were identified." 3 3 MR. ROISMAN: I might also point out that I believe the NRC inspector's-discussion of that 4 1 5 particular allegation disclosed that the_ alleger was 6 unable to provide any specific examples of where this 7 allegation might have occurred, so there was no 8-independent corroboration of the allegation and he _._.i, couldn't go any further. l 9 I 10 l So on that basis he ended up saying that 11 I it could not be corrobor'ated. 12 JUDGE GROSSMAN: Mr._ Roisman, are you I l 13 l offering this document to show the truth of what is i i 14 ! stated in the' report, or only that these allegations I i 15 were.actually raised at that time? i 16 i MR. ROISMAN: To begin with, I believe t .17 the Staff offered it for the truth of'what was in I I 18 in 1982, and the Applicant did not object at that f 19 j point to 10. 20 Sc all I am doing is identifying tc the i l 21 Soard that it is in evidence in this record already. 22 I think if the parties have an objection i j 23 to those aspects of it, that they have waived it. l 2J But secondly, I think that it at leas j t i 25 l demonstrates the existence of thic kind of problem, i i I { i I j i t a r a c.r e ,-w- ,----,,www,-,we

although_. I believe that it is a document prepared in 1 i 2 the normal course of the business of the Nuclear l I i 7- ts the ofticial records, l 3 i Regulatory Commission. i

i 4 1 as well as the business records, exception to the 5 !

hearsav rule.

i 6 ll So the conclusions reached there by the 1

7 inspector, who by the way, Mr. Taylor who was a 8 ! witness in this proceeding is one.cf the two l 9 inspectors who prepared this report, is able to be ll 10 l offered for the truth of the matter. il Il i I think for our purposes we would l lll believe that it should be in for both, both to show 12 1 13 the allegations as n de, to show that the NRC reached i l that concluaion. I4 P.i 15 E MR. DOWNEY: The conclusion being that F il 16 il there was no problem? l-I7 ll MR. ROISMAN: The conclusion beinc I8 that all of the concerns expressed about the 19 inadecuacy of the welding were correct and that, yes, I 't 20 ) we have no problem with acknowledging that the Staff 21 also decided for the same reas.ons the Applicant did 4, 22 five years later that although there may have been 1 23 i a problem with the welds it didn't matter to them. 74 MR. DCWNEY: We would continue :c o b j e c t-to the d o c u m e n t-being r e c e 1.v e d in evidence to { it H I d. I, i 1 l L

m. mm. m. s, 't I 2 1 specifically found te be without merit in the 1 31 inspection report. l, e 1 4 MR. ROTSMAN: That is simply not an i 5! accurate reading of the document. i 6 i (Sench conference.) 4 7 [ MR. DOWNEY: Your Honors, I would like i a l-to make one additional point, and that is we have l 1 - ~9'[ Ell, I think, been proceeding with the assumption i, f 10 ~ that we make our own record in this proceeding; and 11 that.those matters received in evidence in the ~ ,I technical part of this case are not in evidence fcr 12 i I 13 ~ ; purposes of the hari.sment and intimidation issues. 14 J.UDGE BLCCH: With this exception, that I l the Board stated that there are aspects of the reccrds 15 i 16 that are inextricably intertwined and'those aspects, 17 I think, can be part of the findings in this case. Here, however, I think our majcr pr blem ! 18 I 19 is that we are having our attention called to an 20 allegation. l i l It appears from the surface of the reper l 21 1 22 that because the NRC was looking at the time at 23 technical matters, that it did not adecuately 24 investigate the allegation of the inspec:cr, this i i, 25 whole business of the way in which the pec; was be ng l i l f i j 4

1 i inspected was not being taken seriously. i 2 There are ways of investicating-that 'l 'l 3 j without having-specific information on which joints 4 i were affected, and it seems to me that given the 5 Il su'bsequent information in this hearing that the NRC i 6 l ought to reopen that investigation and to try to 7, speak to this individual again and to other l' i! individuals that were working at that time at the 8 il 3 9 i pool to find out what was going on with'the I 10 inspection effort. 11 It just has not been investigated at 12 all from the face of this document. 13 MR. DOWNEY: Your Honor, I don't think 14 that that's a fair conclusion based on the document. 15 JUDGE BLOCH: It says, "The RRI did 16 i not investigate the alleged lots of QC ccverup because i 1 17 of the lack of s.oe ci fic s. " Yet I see the allec.ation i 18 as being a rather serious one, that the man on i i] 19 d e.c e n'd i n c. on i n s t. e c t i c n s.nerfcrmed b.v occasion was 4 20 ll f e l l.c w inscectors, that.... i 21 Well, I don't -knew whether it was 1 22 serious, because it looks to me like they were l 23 ; looking at it at the time as if it were a technical i 24 allegatica and they had :: have specific jcints :: 25 look at in order. to know.whether: there was.a.:e:hn cal

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O But in the course o f your ]cb you didn't E.8 E 2 get a lot of time to see how thoroughly other people were 3' doing thetr work, dtd you? I i i ' 11! A That's -- it's true to a certain extent. i 5), You do follow up on other inspections. For instance -- 6 l, well, you "do ~ follow up on other inspections and you might b 7 I' have some interface with other inspectors, but that is 8 II basically true. ,l _.a. 9 l G If you were following up on another i 10 l inspection, that is, someone else did one of the earlier I I 11 attributes on the IR and you were doing a later one -- 12 A Yes, sir. I 12 l G -- and you saw a deficiency on the earlier I I 14 attribute, what would you do? l A I would identify it, if I would pass on it 15 9 1 16 for that inspection I would identify it and whateve.r I I 17 action was required, UNSAT it out. 13 G Okay. It's not clear to me what you're I i ] saying. The example I gave you was, let's say someone had 19 'l 20 i previously done surface preparation and they checked it t 21 I as SAT, and you saw something that made you think that the 22 surface preparation had been inadequate, could that happen? 23 A Yes, sir. 24 G And then what would you do? It was already I i 25 l marked SAT. What would you do now? l t'

1 MR. MIZUNO: I think the inspect :n 2 report indicates that he talked to several peop'e. I 3,;, JUDGE BLOCH: Where does it indicate 4 ; that in terms of Allegation No. 47 i I 5s MR. MIZUNO: I believe that on the !I kl detail section it indicates who he talked t o., He 6 Ii 7 talked to Individuals B and C who are welders, and ,e 8/ also Individual D, a QC inspector., assigned to 9 inspection of pool liners. I! 10 l JUDGE GROSSMAN: Mr. Mituno, do we know 11 that this matter is not the subject of one of the j ongoing OI investigations at this point? 12 13 i MR. MIZUNO: I cannot tell you tnat y l 14 g because I have not seen what or OI has not informed 15 l me. i 16 My inclination is that it probably i 17 j isn't scmething that OI is looking at, if I had to i 18 guess, because this special report was done in 1979. 19 JUDGE ? LOCH: Thank you. At any rate, t 20 ] it says that there was no investigation of the i 21 alleged " lots of OC coverup,". 22 It's going to be hard to do an 23 investigation now of something that happened in '79, 24 l but given that it coincides w.th documentatien il i 25 l' problems on these same liners, I think that the l i I 1 l l I

i 1h/****"*" ', ' '., + ,. _. s :: te 3 also be hanpy :: '. ave the S: 2.. . g,.,; --

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fj e .,. g L. g whose allegattens which were not able tc he put in:c >_. m 5' this record because o f ly.ps.o illness happen :: relate ~ l to two welders c:her than the ones invcived in this 1 ] 6 I l 7 inspection, whose complaints were also ahcut the 8 stainless steel liner, so that we can help. FidyY,;d,, -. e,i.4 o t s i v g a, v o ~.u. u, w 4 n c.,. n ..e. i. e r 10 the NRC. We can help them find o th e,r welders who may 1 l 11 be a b l'e to help them pin it down, se thev can co bevond 12 the bare bones c' this J u l.v '79 inve s tic. a tio n, and we it i w .1 1 do t ". =.. 1, i i I j,, 6--- .=. L O C "...- 7 ~ 5. 4..>. "e .- a. e a... s.'. "- e - -n--- I -.,..". e 4 1.5 c.'. v r u.- o #.# a -.i e . *. a *- s i.. c a 4-4s -.a. e ". 4 d a.. u-a_ ,s 16 other case and it's relevant, it cught to be here. 17 I can't see how the Board can rely in is any important way on this because it's nct an 19 4.". v a.". 4 c. ' ~ a " a l _' a_ .' *- 4 c.n. .a 1 .._.2 vu -a

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1. In R ply Refer 70:

P.IV 7 Docket No. SG '.45/Rpt. 79-15 50 :.ih! Rot. 79-15 -i S e. Tex:.s Cti'ities Cenerating Co:pany ATTN: lir. R. J. Cary, Executive Vice President and Ceneral 1;ana3er 2001. '; rya: To. er Dallas, Tc::2s 75201 Centleman: This ref ers to the investigation conducted by liessrs. R. C'. Taylor r.nd U. A. Crosse:.n of our staf f on 1:ay 29 through June 4, '1979, of activities authorized by URC Construction Perriits No. CPPR-126 and 127 for th: Co:.nnch: Peak f acility, Units No. 1 and 2, concecning allegations by a forrer Comancha Peak c:ployca., The it.vestigation and our. findings arc discussed in the caelosed investica:;cn report. No items of nonec pliance or deviations verc identified. Even though no itc s of nonecapliance uith Nnc requirements ucre ident.i led durin; thir. investi;ation, uc did find that the a13 ccatic. s ucru es:.cutially We nico noted during this investigation that a thread of cec.tinui:y true. existed batucen this investigation and others recently conducted relative to alleged problems with cite 1:.anagement and quality con:;rol in cert in c.rcas of construction. Although we feel that the rnjor organizational chan ;c: you r ade 'n January 1978 have stren;thened the QA/QC pro;; ram st Comeccha Pct.k, uc cannot ignora the f act that we are continuing to receive aliccations eenecrnin; construction practices. Taken individually these allegations, some of which have been substantistcd, do not appear to have any significent adverse impe:t on the conformance of your pinnt to N3C cc nitments. 11eucvar, ns u: di:,cua:.:d in cut n:cting with you cud Mr. Fihar, in our of fict on Ju:w 22,1979, uhen these allegations are taken collectively, there appears to be a norale prcklen uhich is evidenced by savar:1 of th2 clicuers and racy be attribu:abic, in part, to cc==unication problems bctueen th: ucrhers and supervi: Ion. To cur June 22 nenting, you indicated that you uculd look into t.her.c app..rcut i co:nunication proble.s along with the adequacy of Q.\\/QC inds:trina:. ion of plant supervicion and workcrs and take ppropriate actica to corrent nay ueaknesses that you dete:t in th2se areas. We intend to fo11cu this r.:tter clocaly during subsequent inspections. ee. ~ 140s DLLg Av

CAS M um r b. --6 % ?g::ai, titilities Centrating Company. July 2, 1979 In accordance utth S.:ction 2.790 of the I:nC's " Rules of Practice," Part 2, Title 10, Code of Tede: al Regulations, a copy of r.his letter and the enclosed ihvesti;. tion report vill be placed in the SRC's Public Docur. ant Rocm. If tha report c:r.tains cny inf o=ation that you believe to be proprietary, it is necess. y that you submit a scritten application to this office, within 20 days of the d:.ta,of this lettur, requesting that such inf orma tion be uithhald f rc.; public dicalosure. The application must include a full statement of the reasons s:hy it is claimed that the info =ation is proprietary. The cpplication should be prepared so that any proprietary infor=ation identified is con:ained in nn enclosura to the application, since tha application uithant the enclosura trill also ba placed in the Public Docu:ent Room. If va do na; hear frc.,you in this regard uithin the specified period, tha report will be placed in the Public DoEufaht Rcha.' Should you have any questions conecrning this, investigation, ve vill by pleased to discuss them uith you. Sinc.rcly, ~ /' / f ./,,,- ' s h ~,Q _ -r-g +r ' !!. C. Seidlb, Chief Reactor Construction and Engineering Support t ran c.h En:lssurc: II Investigation neport 1:o. 50-445/79-15 50-445/79-15 ec: v/caclosurc 'Ie::as Utilities Cencrating Company /, tty : Ir. 11. C. Schmidt, Proj cet llanagcr 2031 Eryan To.iar Dallna, Texas 75201 9

CMWOMN C. S. t:11Cl.LN.; I;r.UU!_MO: Y CC:::llS S I ON OFL'1CE Ol' I!;Svi:C'i[0.'; AND D;rC;;CE.."E;T 4E PIC10N IV Report 2:c. 50-445/79-15; 50-446/79-15 Docket :;o. 50-445; 50-445 Category A2 Licens2s: Icxas Utilities Ceneratin; Co.mpany 2001 Eryan Tower Lallas, Tczas 75201 Tacility Na:e:.Co anche Peak, Units 1 & 2 1 Inves.igation -a t: Comanche l'eak Steam Electric Station, Glen Rose, Tc:: s Investigation conducted: !!ay 29 through June 4,1979 Ir,b/ 79 M ^' Inspectors: _ G. Taylor, Reactor Resident Inspector, P r oj ec t Sections Date R. ..., a :: / b'YA--ww'" " (>l.2/ f/; L'. A. Crossman, Chic f, l'rojects Sec tion Date /Z/[7 [W (> Approved: "~ U. A. Cro s:;na n, Chief, Projects Section nate Investi<:ation Summary: Investination on !:ay 29 thronnh June 4, 1979 O'. cn n r t No. 5 0-44 5 / 7 9-l 'i ; "0-465/79-15) Arcas Investicated: Special investign: ion of allegation received regarding inproper and po:carially very poor valding of inter-plate secas in the Unit 1 Refueling Pool, spent fuel pools, and transfer canal of the ec :en facility Fuel Handling Duilding. The investigation involved twenty-ci:;ht inspe :: -h:urs by the I;e ctor P.esiden: Inspector (::P.I) and the Chief, Proj ec ts Se icn. Results: The alle:;ations ucre neither specifically confirred nor refu:cd. The allegations, if confirned, uould hava no safety significance. !;o itens of nonco-pliance or deviations were identified. 749fD $17 3 Tf?

GA W i v.... ! Fc g '- It.~th0Dt!CT)ON Ceanche Peak Steara Electric Station (CPSES), Units 1 and 2 are under constri.rt. ion in Sacervell County, Te.s:as, near the tcun of Glen Rose, Texas. To:as Utilities Generating Company is the Const.ruction Permit hold::r uith braun and Re:t, Inc. as the con:tructor and Gibbs and Hill, Inc. as the .A rchite r t/Eng inee r. PIASON FOR THE ItTF.STIGATION The Region IV Reactor Construction and Engineerins Support Branch received a -telephs..e call from a forrner CPSES coployee who reported several allegations indicating a potential breakdown in the CPSES Quality Assurance program and a possible threat to the health and safety of the public., The substance of the alleg:ttiens also appeared in an edition of the Fort Uorth Star-Telegram published en ilay 30, 1979. Sl:IPIA"hOFFACTS Ths IM ;ien I'l R:nctor Construction and Engineerius Support Branch r:-ceived i a telephone call on ::ay 25, 1979, f rom a party t;ho identified hin:: elf as a f:rmer CPSIS erplcydF ulia had worked a: a Boilerraaher velder. The call va:, tehn jointly by the Branch Chief azul the Section Chiefs of the Projects S::ction an'd :.he Engineering Support Section who in turn provided the infor-ration to the assign::d Resident Reactor Inspector at CPSES on !!ay 29, 1979. The allegations were revieued uith the alleger in an interview uhich took place on isy 30, 1979, at his hen;e. Each of the follc> wing allegation: relate to celding of stainles steel liners in the Unit 1 Reactor Containa.ent tuilding or in the c:renon Fuel Handling Intilding: 1. illc ation No. 11/ ~ Celding and veld repairs on the liners were dif ficnit becan.se water f rc:a concreting activit.ies had run doun the leah chase channels aad out pa:.t the baching :, trip into the ucld area. Ueld: finally conpleted vere very some teelds had been slug < ed with weld rod and others ucre so thin p:wr; th:st if buffed a second tinie with 120 grit, they would not have pa:ned PT (Penetrant Test). 2. Alleration ?:o. 2 l There are ' roblu..a with the gate y,uide (refers to a gate in the Peactor p Containment separating the refueling pool f rem a s. mall storage pool and the transfer canal). 1/The r.t nerents i.bove a re t he allerations a received. Clarific: tic >ns obtained irca the alleger during the intarvic'. of !!ay 30, 1979, ate indicateJ by lured:.e;;t. 2

C.:= ~r n % =% y.? a. In: gate guide betueen the large and sn.all pool was ucided in the Shop. When tha gate guide u.is inst.lled in the pit, the end bevel was cut off so it could be fit-up. Uhen the guide uns instelled, it uas not reheveled and where a fillet veld of 3/C" uns required, only 3/16" fillet veld was made, b. The gate guide had to be welded to both sides of the liner. traen velding the back side, the velder had to crawl down between 'the rebar to get to the weld. The position was so cro.eded that the uelder could not cake a good weld. Also, the velder couldn't see what he eas uelding very well. Six inches of the chase 'hanneks were lef t off the gate guide and c. c added af ter the gate guide was installed. The rebar vas so thick in th'e areas where velding was perforced that "you could hardly ge.,your finger through, ensch less the velding torch." Consequently, the velds were not rnade properly. 3. Allegation No. 3 ~ Welders have no experience. They spend as cuch as SO hours trying to make a test veld. They finally learn how to nahe a weld that vill pass the gaalifying test and then when they get into the field they don't know what th:y're doin;.

4.. Allegation No. 4 e

There is " lots" of QC coverup. QC is " buying-ofi" on velds over the phone. One QC inspector bought of f a scam before he ever saw the scam and it uns not z. good veld because water uns co.aing through chile the weld was being r'a d e. (The huy-nf f involved was joint preparation and cleanlinens pr: par-atory to velding). 5. Allegation No. 5 Erown and P. cot is not following procedures in velding the liner plate. (The procedures referred to are velding procedures and specifically refer to use of a do.en-hand velding technique being used versus the procedurally required up-hand technique). 6. Allega tion No. & So::e of tha top scams IS" above water level on the fuel pool had baching strips tach velded to the liner plate. There are places where the plate did not cover the baching strip. He would not guarantee the weld. The veld was probably 60*; rust, air, concrete, etc. .C, ~_. -..w.. CC:.J LUS IOS..} g.f Revicu of t h:: CPSES Final Safety Analyais Report, Project Specifications and Engineering Drawings, as they pertain to the liner f abricat. ion and installation, have led to the following conclusions relative to cach allegation s.ated in the Se_.ma ry of Fact.s above. To better understand these conclusions, the follouing considerations are necessary: The liner systems are not installed to prevent or r.iiti;; ate the conse-qu=nces of any of the pastulated desi;n basis accid :nts, but rather a:= installed t.o prevent an excessive burden on the liquid waste col'setion and disposal system and to allow the unll and floor area to be core easily decontaminated after pool usage. The liners as a functioning clement are, therefore, not considered safety relar.ed r and are not norraally included in the !!RC inspection program. L The liners, as passive elements and parts of the building structura, are usually classified into seismic Category I since if one or r 3re of the liner plat.es vere to become detached from the Onll, serious danage could be done to stored fuel assemblics. The plates are, therefore, secured to the concretc supporting structure with a systera of weld studs attached to the back of the plate and embedded into the concrete. The veld stud system is not a factor in these nllegations. 1. Allec tion !!o. 1 .= The IU:I, bas'ed on the intervicu with the alle;cr and wi th other uelders, has b: coce reason:bly sure that there cere di f ficultics encountered by tbc uniders uith water, moisture and in some instance.s vi th concretc on the uc1d surfaces and that in some instances, the velds may not be cou-I pletely sound internally. These velds, however, serve no strength purpost.- and need only to be sacoth and leak f ree, factors which a re est_blished by vinual ir.spection, dye penetrant examinationn, and by vacuum box tentu of the joint after it is cor.qilete. The allegation, chile probably true, has no safety con:,equence. 2. Allentions No. 2.a, b, & c Th:5.c collecti.e allegat. ions, chile probably true in a substantial r.ce::e, also have no sa fety consequence. The veld joints in que:. tion caly need to be :..coth and leak free in the case of a. and b. and Icah f ree in the case of c. The welds do nnt serve to lend strength t.o the stre:.ure. 3. Alleration No. 3 i The project specifications for all velding, including'the pool liners, require that uclders be qualified under the requirements of the American Society of ?!cchancial Engineers, Doiler and Pressure Vessel Code, Section IX or a ccmpa rabic requirement such as thoue of.the American t'ciding ' "6

Of.Z I.G+1+-tr, t.. 7"-- Sarie:,.. Section IX of the AS!': requires that a urider ruist perforia d j a ucld prdtess involved arc! the as-welded coupon r.:nst pass specified ' tests t.he:1 complete. No tirae limits are specified or _ implied as a requirecent in Section IX for making the qualification test coupon weld. The RRI has verified previously that the site uclder qualification pro-gram is in full compliance with Section IX. 4. Alleration No. 4

• fhe ff.I examined the circumstances surrounding the specific portion of the ell'egation and' discussed the. matter with the QC inspector directly involved.

It appears that this enn, on occasion, was depending on the icspections performed by a fellou inspector and so recorded on the appropriate weld data card. The joint was covered over with tspe af*.cr it had been inspected for cleanliness and fit-up and the inspector re-leased it over the phone based on the record card entries. L'ater in the --leak chase channels appears to have been a constant problem. The QC inspector may have raade a jud:;ement error in not re-examining the joint, ~ but not uithstanding, the joint had been inspected ang found satisfact'ory at that tic:e. The Pd:I did not investigate the alleged " lots" of QC coverup because of the lack of specifics. 5. Allevation No. 5 1 i As noted in the Su. nary of Facts, the general allegation of failin:: to i follow procedures was subsequently refined in the intervieu uith the alleger to rela.te specifically to an occasion where the alleger was directed by his supervision to veld doun-hand rather than up-hand as required by the velding procedures. AS:E Section IX indicates that such a chan;e is in the category of a non-essential variable and, therefore, is not a prohibited change in the procedure, if recorded. It appears that the change uns not recorded. Intervicus with other ucide'rs en the same activity failed to reveal any similar experiences a::d supervir. ion has denied directing the alleger to perform out-of procedure. The k!!1, t here-fore, has no racchanism by which to confirra the allegation. Again, ascu.,ing that the alleger did wcld doun-hand instead of up-hand for whatever reason,. the consequences of such an action are essentially ucaningless as related to a ucid, since such a change has no effect on the finished veld of the type involved. 6. Alle:;ation."o. 6 The particular velds in question are even less consequential than the c.ther scam celds in a functional sense. These ucids, which at e abc.ve the vater line in the pools, do not need to be leak f ree, just smooth for the purposes of cany decontamination. The allegation, while perhaps true, has no conse-quence. 5-L l

Dl;iAII.S GAE5-1.M D 1. Pe r-ens Conr::c red All ar The alleger, hereaf ter ' identified as Individual "A " is a f ormer cnployee of I'roun and Root, lac. (the site general contractor). The person iden-tified himself as a for=er uelder ascinnac* to the nilluright/boilercaker unit c2.the construction force. Prin:in21 Licensee F:nlovee Site Quality Assurance Supervisor _.1;roun end Roo t, Inc. 1 Project Construction II: nager P.illuright/Scilermaker Superintendent Individual "E," a velder currently vorhing as a pipefitter but who uss c Ecilersaker / Iridividual "C," a velder currently uorking as a pipefitter but who was a Boileranker Individual "D," a quality control inspactor who uns assia ned to inspecti n a of pool liners 2. Back round of Allerations Individual "A" contacted the Ragion IV of fice at appro::imately 9:25 a.ra, on Friday, F:y 25, 1979, to express concerns cbout the uciding activitics which had taken place on the spent fuel pools, cask loading poo1 and the transf ar canal in the co=an Fuel Handling T,uilding for both Units as uell that uork accomplished in the Unit 1 ref ueling pool and temporary storage as potel installed in.the Reactor Containnant Luilding. The RR1 uns notified of these allegations on Tucs' day, Itay 29,1M9, 0:ay 20 a holiday) and initiated an icnediate investigation. The first peint of centact uns the licensee's site Quality Acsurance supervisor who inforned tha ERI that he uns cuarc of the allenctions, since his company had been apprised of then by a neuspa,aer rcporter c= ployed by the' Tor 1.'o r th Star-Telegram. The site curarvisor also informed the RRL that another velder, Individual "B," had exprenced similar ccaccrns to the Troject Conctruction :anager on :::y 23,1979, and that concerns had been f orwarded to c ite Quality Assurcate for investigation. The RRI uns provided an inf ormal r.:enarandum giving the resultu of the investigation dated :tay 23, 1979. -- _ _ _

eAss=w--$ - f, la.li v idua l "A" a l:an umtact ed t he l'roject Ccant t uction fl.ui:q a on 197-), :md expr essed essen:.ially the same concer ns as those express Individual "l;" and which in turn he expressed to the Region IV off tia y 2.5, 19 7 9. It appears that Individual "A" and his supervision, through the Project Const ruction i; onager, had reached a substantia of disagreement and Individual "A" voluntarily terminated his cr.plo r en.. at the site as of they 24, 1979. The voluntary tecmination'is a catter of record in Individual "A's" cmployment file. ~ p ~ 3. Investiestion The .I.I initiated the site phase of the investigation by extensively reviewing the CPSES Final Safety Analysis Report in order to ascertain the safety classification of the various pools and pool liners icvolved in the allegation and to review the fucctional descriptions. heference to. Section 3.2, " Classification of Structures, Components and Systems," - 4n the--FSAR does not indicate the liners as being ::.fety related althon;;h the buildings in which they exist are shown to be in seismic Category I. Paragraph 3.8.3.7.1 provided a ecmmitr.:ent to test the liner seams via a vacuura box for leak tightness and briefly described a' leak chase system behind the liner scarts. Paragraph 3.8.4.1.3 provided a brief additional desreiption of the function of the liners. Figurcs 9.3-9 and 11.2-4 revealed that the extensive Icak chase system has lead-out piping which Jeads to a building sump and hence into the liquid radioactive uaste collection and disposal system. The RRI then. obtained Project Speci fication 2323-SS-18, Revision 3, " Stainless Steel Liners," to ascert.ain what requirements the design engineer had established for the liners. The KR1 noted the following si;;nificant ite.... Icon the specification: The design engineer invcked the genecal qualILy assuranCO requ i rer.:ent.s a. of 10 CFR 50, Appendix B on the f abrication and installa:.ica worh. b. The design engineer provided three full pag;es of detail requircaent e, relat.ive to the system of studs to be velded t.o the reverse or concre'e backed side of the liners. t The design engineer made reference to tha inter plate scam ucids caly c. by requiring that the velding procedures and welders be quali.fied t o ASE, Section IX. C ri t.e r ia f or finir.,hed welds r equire that, "Su rf aces of all velds shall be smooth and free of any irregularities such as secrations, ridges, crevices, or pinholes which may oake it subsequently difficult to achieve an ef fective vashdown of the liner surface." Under ter.t.ing the desi;;n engineer provided the following, "All scan vel dr. shall also be tested by vacuu.n box for Icah Lightuess for their entire letth." No other quality requirements ucre iupased on the scam uelds.

p L. -,:w LV d. The HRI t hen obtained t he de.eign engineer'. drauir:n. S-0831 thron;,:: S-CO34, SI-0560,111-05S1, all of uhich provide details of liner fabrication and inst.allation In addition,1 be 1:!:I obtained vendw design detail drawings for the gat.e guide ins.talled in the Contain.ent building batueen the refue-ling pool and the ternporary st.orage pool. These drawings, taken collectively, showed that the d2 sign engineer had designed a syr. tem wherein the liner plates and the gate guide would be supported by and anchored to t!:e surrounding concrete utils by a very extensive system of "T" headed studs velded to the concrete s, ides of the plates and gate guide f rerne. The sea:n velds are entirely f ra a plate'-to plat.e and provide no atta ch:::ent. into r.he basic building structure. Tne PJ:1 courluded on the basis of the abcVe inforraa tion thr.t the liner system had been designed such that. resistance to seismic ef f ect was vested in the "T" headed stud installation and that.. t.he seam velds were necessary - ~6nly to' provide a' very low leahage path for the pool cater and that what lenhage taight occur would be drained to an appropriately designed method of disposal. The RRI iaterviewed Individual "A" on May 30 1979, in conjunction uitb the Region It teactor Ccastruction and En;ineering lirauch, Projects Section Chief, in order to gain additional information relative to each of the allegar. ions received over the telephone on itay 25, 1979. The additional 'infor;:a. ion and clarifications were a:: noted in the Sun:na ry of Fat t:: included in this report. In addition, Individual "A" achnuuledged that he ha.d only very rc.cently be.:ome awa re that the st.ud synt.e:., existed for holding the plates in place and vas, in fact, unauare ti:a t the leak chase chanrels ucre piped to a co]lection point for controlled collection and di::pc:.21 of any leahage which nicht occur. The MT!I interviewed Individual "E" in the presence of the liceb.sce's site ' QA supervisor, also on May 30, 1979. (This arrany. ment cas allowed sincu Individual "b" only came to the attention of t.he 1:l:1 through the a::r. is tance of ti.e licennee's repreannt:tive.) The allegations of Individual "A" were revleu=d in detail with Individual "U" who esscatially ccafirmed Allegations 1, 3 an:! 6, but indicated he had not uorked in the Allegation 2 arca and further indicated that he had no cc:aplaints about lach of effective QC nor had he been instructed not. to follow welding procedurer.. i The Rhi intervicued Individual "C" on llay 31, 1979, with r.he same resnits as those obtained in the intervice uith Individual "B." Individual "C" ira!1cated that. he perhaps cas one of the pernons re Entred to by In.livi.dua) "A" in Allegation 3. He also indicated that he had very limited velding experience before coming to work at CPSES and none in "l!cliarc" ucid prc:er.:.. lie was given some forty hours of very informal training and then used fif ty-t.uu hcurs to r:ake his weld test coupon, a durat. ion tha t he n:.,u considers t.o be excessive. He now thinks that he is a good uelder. _g_

CAZ L...!M Mr-h, II i 3 Th: 101 in:.ervit g.ed individu.il "D" un M;iy 30, 1979, and a::ain J::ne 1,1979, tc dwelop ary iactr r elat ive to the r.peci f ic allegation o f "iniyin;.-of f" joints over t.he phone. Individual "D" cat.cnoric.dly densed that be, or to hi:. huowledge any other QC inspector assigned to thir. vock area, had ever '"hou;;ht of f"'a designated inspection point vithout caking the required ,inspec. ion. On June 1,1979, Individual "D" indicated that there had been very.few occasions uhen he had given consent to the uciders to veld up :n sea a that, by the-inspection reports, had been previously inspected for fit-up and cleanliness. Ile also indicated that he and others had repeatedly .stop,:ed work on velding of seams where it ca:ne to their attention that unter or coisture was interfering uith good velding. The F2I interviewed the Boilermaker. Superintendent on June 4,1979, relative to his knowledge and/or' pari.icipation in any of the allegaticas. He cate-gorica11y denied ever directing velders to make yelds where uster or r:sisture -.vas present, but acknowledged that it vas.a constant proble. :. He indicated that he fin:lly received engineering permission to drill holes through the liner at the ends of the leak chase channels so that niecould be bloun through to dry out the channels-and that this action helped a ;&:st deal. He indicated that he had continuely attempted to impress the velders uith the inaportance of rusking good seam ueld. 4. F21's Assessment of the Liners f The Im1 observed some of the velding vorh on the refueling pool in the Un'.t l J!c. I containment during the lattSc part of 1978 and the early part of 1979 incidental to ci.hing inspectinn of other activities in the sa: c work arcai I The velding appeared to be norm 1 and the dye penetrant c::a:ainations appeared to be prcperly accomplished. The finished surf aces c::n.M ned have been uni-for:a*1y smooth and appear sound. Th: 131 also examined sc=e unfinnhed aw.,: in the linit 2. spent fuel pool and can appreciate. the dif ficulties that nay he ' encountered in removing some of the concrete laitance from the' vertical ueld 1 joint arcas. t'g NO% T 'i ~ c.

i ' l l o Draft 7/CF5A AQ-55 and AQ-78 11/16/84 SSE C

f. s /

i ~ O. , -', g r,- -. - - 1. Allegation Grcup: QA/QCa Category 8 JS ~.'g "I ^ 2. Allegation Number: AQ-55 ard AQ-78 3. Characterization: It is alleged that fuel transfer canal liner documentation was falsified, that required weld radiography was not completed, and that hold points on inspection travelers for the fuel building were signed off improperly. 4 Assessment of Safety Sienificance: The implied significance of this '$ &\\ i allegation is that Ac:c fuel transfer canal liner (liner) fabrication A % \\tnte and installation were inconplete and incorrect,ar-4 may net comply with design requirements, therefore, rendering the quality cf the liner indeterminate. r0lA-8s%5ec h i h mu

%s The We Technical Review Team (TRT) learned that the liner ccnsists' of a series of 3/16-inch-thick stainless steel plates welded together and attached to the inside of a concrete structure within the fuel building. Transfer tubes at either end of the canal-connect to similar fuel storage pools inside containment Units 1 and 2. The method of &v 'all vertical liner pla )e f, t W, construction tws4. required th-preassembpi *in f 1 -& vteQ+)ch concrete was poured around the outside of the plates. The plates also had studs welded to the back and embedded in the concrete to hold the plates in position. .. sf f ,4.

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,v ~,. - h.y<w..i . o I The plates wer $ joined w44.h a backup bar on the bac e', f M,7% ~ a n u-x ~ U V/. ( g, :-j ) ) !!..o.rb y n n + c + 4 r-

Sd +h3t fcrmed--the ser ::dd htweere-the. liner pkt+s. A channel was then welded over the bac &up bar to form the leak chase k

& s-v.c<G wa .: "<- ed g the number of ccrrections required for pre-entered dates y - t d. '- s l The TRT concludes that there are record anomalies which are not t l adequately explained, which violate procedures, and which wploy l inadequate procedurcs. .pk 'M 4;'- t c.- i ' ..c i.

.tr-w+4ee-4s wt-che -sebs tant 4thn ferthc --k tr.,J f af N.4 l P_pi n t Nn 1 - 4 n e. the yn-cdur-e--r.+4erenced--had beefr4eleted ' years 4 yo magts-pre =4e,:!y, e it;.3; p ;-y,;;; w 1 g e.,sc -w.y a.f ter-ttre--ir:pectior+ -wa+-peMormad r-et-on th; dW Mpcciin 2;- (tg O. r49eived bypocedure.CP.-QCl--2,144 Pea.- c,_Therefort, these allega-Gs tionsdohavesafetysignificanceandgenericimplicationsof[QA/QC breakdown. j 6. Actions Required: Before loading fuel in Unit 1, TUEC shall complete the i following: a. Determine the effect on continued seam integrity resulting from I lack of documentation of the second inspection for cleanliness of j plate-to-plate searr welds. i b. Determine the validity by ultrasonic testing of a sample of all pool i and canal field (water side) welds. This sample should be biased toward floor welds. 3 4. 's. Measure the plate thickness in these large areas ef, surface grinding c. i . ore-t h - liceq t'y ultrasonic testing to det2rmine if the remaining c material meets the minitrum thickness requirement specified in 1 specificaticn 23:3-5S-18 "Stainlets Steel Liners." i i i d l 1 v--emm------,v. ...,.,,,m.= -,mm-.,.-y-.e c ..,r. ..,em--- r w.%--py-,7--,-- mv.-y ---,,y-y,.,-, - _,., -,- - - -,. -, - - -

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2- ~~ ~~~ ' ! Y C. Cl? %^ lu.1 G f-5(-lh,0, s If the,'io'nconformina condi tion ) When changes are required to or disposition, the NCR shall be revised. ThH rivisi67T shall be denoted on the NCR ntnber and the reason (s) for revision included in the comrnents section. The necessary approvals shall be obtained in accordance wi th this procedure for the portion affected by revision. C~r/ fl,? 'c .;,,. I <lJ'a'.$.',m ) r ia ', l' The inspector signs and presents the NCR to the QC Supervisor for review. The QC Supe rvi sor indicates his review by initialing after the inspectors signature 4 v' :pers.u /'* i *i- / /.c Lci.f,r;.v ,.C , xs. : ,,.m +. ./ c a / j f'? .J t-b.s [ (j //6 6 /f D to. r..' r4' h c.~W L h -G n-A 0 5 5r ) ~ YA s'A 4 ;$ f.'d-Le!

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. 7. B&R Procedure CP-QCI-2.11-1, Welding Inspecticn and Fit-up of Stainless Steel Liners, with IM-16606, dated " January 10, 1979." 8. Office Memorandum TU0-2340, " Stainless Steel Lirer Travelers Unit II," dated September 11, 1984. l 9. A-3 Interview, pages 60 through 89. .4n - ctu ep -d"= t'- ??:"-::-1C fu,- Si.aintustmt-Linen r Sav.is4u LS-1D. Bostrom - Bergen Dwg. 2401. 4 I 11 A-4 Testimony, March 7, 1984, pgs. IS, 19, 20. lj_. A-3 Testirony, August 1,1984, pgs. 59,516 thrcugh 59,536. 15. G&H Specificatien 2323-55-18. " Stainless Steel Liners," Rev. 3, s April 6, 1979.

10. This statement prepared by:

T. Curry, TRT Date Technical Reviewer

O

s. Reviewed by:

H. Livermore, Date Group Leader Approved by: V. Noonan, Date Project Director

'k M / ,ys JAN 1 8 1985 /. -; \\ ?!cte to: TRT Group Leaders .i s

Subject:

Useful Depositions Attached is a list of useful depositions compiled by 0 ELD. For certain allegation reviews we should have read (and referenced in our SSERs) these depositions. Most of these depositions were made available to the TRT when we were ensite, look over the list (arranged by(xy)), iho will obtain a copy from OELD topic if you think we have missed g something, contact C. Haughney _f, _ ( N. Lw R. H. Wessnan cc: w/o encl. C. Haughney 4 _ [ n.. y m v ,4am.. m. w / t c u c k L,cu,c s&&!l u KLLc-du - NP2ced c' u v ' s_.v - n PJc-85-59 73 7w ' qsou e 30 2 sore

Document Name:

SUMMARY

OF RECORD - CPSES Requestor's ID: PATILDAL Author's Name: GSM/RGB/ GAB /Lucas Document Comments: Intimidation Alleg., and A11eg. Derived fm Intimidation Pro. 6 1 e

NRC Intimidation in an Interview of an Allecer ^ . { %.:dre,?WfA'Oil' a fonner electrical helper and draftperson at CPSES, e r'iegec tYi~rMegion IV inspectors intimidated him in an interview. ~ The evidence consists of: Dep o s i ti on o fj kQ,Kg$ff.T[,'j%$fdh, (July 25, 1984),4 [-0l$N a tape recording of the alleged intimidating interview a written transcript of that interview. 4 l i 1

Intimidation of OC ' Inspector in Auxiliary Buildina f f[allegedth,atheobserved!hn'< [Toreman for{k!f[i[:gregypsgyelling and shouting obscenities 2;/Md'Ni ns , a general at a QC inspector Tor "rE@ cagaing" too many cable tray supports. The evidence on this incident consists of: r_ 7 Dep.osition ofp;$ %uj.S'pWhQ}(July 12,1984),P;%;jp+p:lpgglsbj A e

-3 Intimidation of Weldina OC InsDector in North Valve Room ' tin,s 7,U<StsMttkla former iron worker at CPSES, alleged that he saw a NC inspector iden,tify improper welding in the North Valve Room. Accord-ing tofm 9 ce._Jthe QC inspector left, saying he was going to stop it, but later retur6Fd 'and did not'stop the improper welding. The evidence on this issue consists of: 'f 4 Deposition of !W__n_e,:v:'@tif)](July. 12, 1984),{ @ s 0:M._: W'-fl 4m u ~ 01 Report 4-84-012 (14 August 1984) 01 Report 04-84-011 (13 March 1984) ~01 Report 4-84-006 at 23 (7 March 1984) 9

~ l ? ^ ', - , a, ; ' < l Incident p: ' Alleged intimidation regarding voided NCR written byk * ??N6ig /J J. A1 wrote NCR on QC inspectorE3 indicating he had falsified dates,~fhus enabling craf t to bypaff QC hMt points. NCR was voided. ~ Applicants assert that dates were changed only to correct error. The witnesses and their testimony which deal with the alleged incident are as follows: s ?

d. '

gj'ugust 1,1984l9f.S@99p(3f] and Depositionofbi g August 2,1984'Ts,g,yg;e,gg.gg j

~

3 Deposition off,;g'g-.q Q M @ uly 28, 1984 W ME B M M E M F M W g ~~ Deposition of Dwight M. Woodyard; July 24, 1984 (Tr. 56,505-572) Deposition 'of( m@QhJuly 25, 1984 (Tr. 57,500-587) Deposition of John T. Blixt, Jr.; July 25, 1984 (Tr. 57,045-076) Deposition of Robert Siever; July 25, 1984 (Tr. 58,057-105; 58,129-130) Deposition of Gordon Raymond Purdy; July 10, 1984 (Tr. 41,156-188) Testimony of Robert Marshall Duncan; Tr. 17,420-523(9/19/84); Tr. 18,091-152 (9/20/84) Testimony of Terry Matheny, Tr. 18,904-19,025 (10/1/84) Testimony of George W. Chaney, Tr. 20,455-526 (11/26/84) Prefiled Testimony of Richard W. Simpson; August 15, 1954 (pp. 1-38) Prefiled Testimony of Danny Ray Wricht; Augusdt 16, 1984 (pp. 1-9) Prefiled Testimony of Ronald D. McBee; August 16, 1984 (pp. 1-24) Prefiled Testimony of Alan Dale Justice; August 15, 1984 (pp. 1-20) Edward :wahr and Daniel Thomas Prefiled Testimony of Jare e Wilterding; Augsut 15, 1984 (pr. 1-21) Prefiled Testimony of Jarer F. Brewn, Aucust 15, !cS4 (pp 1-21) See OI Pep e t 01-S4-037 (12 S e p t e+c r 1C94) t

• Intimidation of Protective Coating OC Inspectors

. __ _. ' W. " ids' a former protective coatings QC inspector. at CPSES,

-;4 {,5. T [~. _ N1eged that he wa'T aware of attempts by his supervisor,M T G W 2;Mra ~' to intimidate protective coatings QC inspectors. W Mr The evidence consists of the Dep_artment of Labor Transcript o6*; LN 'l Section 210 complaint Eggv. Brown & Root, Inc., 84-EPA-1 ~ (Februa7y 13-14,1984). See etreciarty: + y Testimony of{gsdiWOM51'DOLf'9E 'M C -1 Testimony of{(p@pg DOL [WN i MW Testimony of Raymond Yockey, D0L Tr. 309-319 Testimony ofjf M j$ $ DOLpkQg g ~ Testimony of Myron Krisher, DOL Tr. 371-415 Testimony of Gordon Purdy, 00L Tr. 420-465 Testimony of Thomas Brandt, 00L Tr. 472-512 01 Report 4-83-001 (24 August 1983) 01 Report 4-83-013 (3 November 1983) OI Report 4-83-016 (26 July 1983) OI Report 4-84-006 at 19, 21 (7 March 1984) OI Report G4-83-025 (10 February 1983) 01 Report 04-83-026(18 October 1983)

~6-A j 0 $ p(kl$ M M Termination Allegation that OC inspector was terminated because of his complaints concerning QC. ,ky.j$[fi' led a complaint with the Department of_ Labor claiming he wasdtermi Tid?- 'tirerfor criticizing the QC program, and oneLfppWUpgin particu-lar. r The parties have stipulated _thatfi)d W 91t'stimony is contained in the e record of the DOL hearing,iudks%. Brow'n & Root Inc., 84-EPA-1 (February 13 and 14, 1984)C N During the evidentiary dFpositions in this prosseding, ApM icants presented further testimony on circumstance surroundinggr unwggtermination: Deposition of Gordon Raymond Purdy; July 10, 1984 (Tr. 41,247-259) Deposition of C. Thomas Brandt; July 11, 1984 (Tr. 45,196-198) Deposition cf Myron G. " Curly" Krisher July 9,1984 (Tr. 37,011-064 Testimony was also given by Applicants during the hearing sessions of 5eptember 11 and 18, 1984: Testimony of B. R. Clements; Tr. 15,460-63 (9/11/84) Testimony of Thomas Brandt; Tr. 16,777-794 (9/18/84) By Order dated November 30,1984, the ALJ in the DOL proceeding dismissed y p w acomplaint ht,,_ 9.' Brown & Root, Inc., 84-EPA-1, " Recommended Decision and Order"). f-OI Report 4-83-016 (27 July 1983) 01 Report 04-83-025 (10 February 1983) OI Report 4-83-001 (24 August 1983)

l (~ ', T-Shirt Incident Intervenor alleged that electrical QC inspectors wearing T-Shirts were intimidated by management. Certain electrical OC inspectors were wearing T-shirts referring to " nitpickers." They were subsequently sequestered by manacement and their desks searched. (There is a question of their prior involvement with " destructive testing" prior to the incident.) Some of those involved were later transferred or terminated. Applicatns assert management might have overreacted, but the 6ctions taken were not intimidation. Evidentiary depositions: MfQMp'] July 16,1984; }l2$.l!RM f 4 r- . Deposition ofg&h&gj@Q:aiW[ July 17 M ?.w y y Deposition of Vu;3%7; j}g , 1984; L _ _ W Q q %_ _ Deposition of Jack Pitts; July 31, 1984; (Tr. 73,500-553) Deposition of Ronald Tolson; July 10, 1984 (Tr. 40,546-562) Deposition of B. R. Cler.ents; July 10, 1984; (Tr. 40,096-105) Deposition of Thcmas Brandt; July 11,1984;(Tr.45,128-149) Deposition of Boyce Grior; July 11, 1984; (Tr. 45,591-599) Deposition of Gordon Furdy; July 10, 1984 (Tr. 41,198-199) Deposition of James Cummins; July 17, 1984 (Tr. 54,008-055) Hearing Testimony: Testimony of Michael Spence, Tr. 14,924-930(9/10/84) Testimony of Antonio Vega, Tr. 15,055-060; 15,191-193; 15,197-251; 15,278-416 (9/10/84) Testimony of B. R. Clements, Tr. 15,418-428; 15,470-503; 15,514-521 (9/11/84) Testimony of Thomas Brandt, Tr. 16,107-133; 16,175-201 (9/13/E4) Testimony of Gordon Purdy; Tr. 16,358-373 (9/13/8a) Testimony of Ronald Tolsen, Tr. 16,399-575 (9/14/S4); Tr. 16,652-658 (9/18/84) i I . -. - - ~,

~B-Testimony of Gregory Bennetzen, Tr. 17,745-934; 17,954-968 (9/20/84) Testimony of David Chapman, Tr. 17,969-18,031 (9/20/84) Testimony of Doyle Hunnicutt, Tr. 18,515-669 (10/1/84) 01 Report 4-83-001 (24 August 1983) t l l

.= F 9- - // 1 Liner Plate Traveler Incident U) g hjfdTdN alleged that { was intimidated into signing off on OC weia hold points.on liner plate travelers. n .gYetemallegedly was ordered to sign off QC weld hold points for fitup ~and cleanliness on travelerj for the stainless steel liner plates of the Unit 2 reactor cavity. Osignature was to be verified by inspection chits purportedly [o,ne'By gher inspectors for these hold points a few o years prevjously, ryewhqdid not aJrej that the chits matched the hold was to sign, alleges [ was compelled to sign under flosing4heupcominaweekend@off. points Applicants assert,that the. threat procedurepcwwa wa_s to follow was proper and thereforegwas not i r,timidate'in ~ [ Note: Thih. allegation has resulted in another separate issue at the hearings following the evidentiary depositions, the adequacy of the OC weld documentation for the liner plates. See Deposition of C. Thomas Brandt; August 16, 1984 (Tr. 45,239-355).J Evidentiary depositions: Deposition Affs:/ 9MGUV *l sucust 1,'198a,j}AY N E D Y N ] t

%!ila'no August 2,1984 DA c% ' mef=

~ / r Deposition ofppss;g"; ply;; ff4l{ July 31,1984[$QQ@fip#$$] Deposition of Dwight Woodyard; July 24,1984 (Tr. 56,561-566) Deposition of John Blixt; July 25, 1984 (Tr. 57,015-036) Deposition of Robert Siever; July 25, 1984.(Tr. 58,024-056) 01 Report 04-84-037 (12 September 1984) \\ + -r. Liner Plate Traveler fncident (B) Intervenors alleged that there was a QC breakdown in the documentation of the liner plate welds. As a result of documentation which was supplied by Applicants in the course of testimony on " Liner plate traveler incident (A)," Intervenors raised the issue of an overall GC breakdown in the QC process as applied to the liner plate welds. Applicants responded with testimony ostensibly refuting each of the alleged deficiencies. [ Note: The subiect of the adequacy of OC inspections and their documentation of the liner plate welds has been looked into by the TRT. The TRT's conclusien is not yet known.] Evidentiary record: The background and context for this issue is in the material listed in " Liner plate incident (A)." Deposition of C. Thomas Brandt; August 16, 1984 (Tr. 45,239-355) " CASE's Evidence of a-Quality Control Breakdown" dated September 27, 1984 Prefiled Testimony of C. Thomas Brandt; October 3, 1984 (Tr. 45,356-480) " CASE's-Further Evidence of a Quality control Breakdown in the Construction, Installation and Inspection of the Stainless Steel Liner Plate" dated November 15, 1984 Testimony of C. Thomas Brandt, Tr. 15,629-697 (9/12/84); 15,978-16,214 (9/13/84); 16,728-777 (9/18/84); 17,264-363 (9/19/84); 20,569-774 (11/26/84); 20,778-21,091 (11/27/84) i i o Voidiac of flCR on Polar Crane 'd];fyyye/ib'9@ # a former welder and QC inspector at CPSES, alleged ' tnat an tiCR which$ wrote regarding a hole in the polar crane rail was improperly voided and the hold tag improperly removed. The evidence on this allegation consists of: s r D e o o s i t i o n o f 6is.ggl:(22$Yp].(p ;y 13, 1984 ),f 4 % h,.jpl+ @ g Jul 1 gy;w y;a clB;%% ,., ;. g

'gg Deposition of C. Thomas Brandt, Tr. 45,273-76 (submitted as prefiled written testimony)

.01 Report 4-84-008 (9 July 1984) OI Report 4-84-006 at 26 (7 march 1984) l l l I l l l

Weave Welding on a Pice-Succort in the Auxiliary Building -4 Cg,lrg;,,# 5 O a former welder and QC inspector at CPSES, alleges 'that!i?)Jwrote an NCR identifyinc unacceptable weave welds on a oipe suppYFt'~1n the Auxiliary Evilding., According tch dyJ!q;&M&,Nas intimidated by craf tworkers and byEj supervisor',ll.lGj%?,yfig4 into improperly accepting the welds on the~NCR. The evidence on this allegation consists of: / _. I(July 13,1984),[.,3fy m;<b'M"'@End-- R Depositionofja6b"5L N ~ r Deposition of C. Thomas Brandt, Tr. 45,287 (submitted as prefiled written testimony) In addition, substantial testimony on this allegation was received by all parties in the techr.ical portion of this proceeding. See generally: March 19-20, 1984 hearing session transcripts, Tr. 10,383-11,018 April 24, 1984 hearing session transcript, Tr. 12,138-285 OI Report 4-84-005 (9 July 1984) 01 Report 4-84-006 at 26 (7 March 19E4) Weldino of Diesel Generator Skids j'if:Gr"6 Or[] a former welder and QC inspector at CPSES, alleces __, ' thatt:3_.lwas harassed and intimidated byLEjsupervisor.f:-- - . J :. - lJ when"h'e'~~hssignecL%to conduct instscti'ons of wel.ds on.the diesel gene 7- ~ ator skids for CPSES, ~even afterQ~] protested that]was uncualified to conduct these inspections. The evidence on this issue consists of: _Depositionof.Ugyt,jy;7.yyyio,.s;:,.ws:uk ;;p (July 13,1984)[p$:ppffb3yg@y r ~1 ,,,n Deposition of C. Thomas Brandt, Tr. 45,276-80 (submitted as .prefiled written testimony) See OI Report 4-84-0086 (9 July 1984); 4-84-006 (7/19/84) W i I l l 1 l Weld Symbols on Doors

pwij z[] a fomer welder and QC inspector at CPSES, contends

( ' tnate M wa; #;'J s toic by Thomas Brand to improperly accept doors which had not been' properly welded in accordance with the design drawings for the doors. The evidence on this allegation consists of: h k <,' f ch' Deposition of Cl Thomas Brandt, Tr. 45,280-287 (submitted as prefiled written testimony)

. ~.. =. -. .f Harassment Due to Relocation of an Office - [~?9W. gym 1MNMb a former welder and QC inspector at CPSES, claim: that/2:fjwas harassed by Applicants after giving testimony in the July 1982 hejriag session in this proceeding. The harassment consisted cf moving!!Cidin a shack thatmlaimed way Jpsturdy, dirty, unaircor.- office four times,ovgr a two-day period, and of finally placing l ditioned for three. days, and smaller thargriginal office. The evid nce on this incident consists of: 1 j tammocus&#pb4%a(July 13,, 1984) emmm4rgygg '~ Deoosition ofR g p 4140 2 Q ~~- ^ ~ i . Deposition of Ronald Dempsey (July 20,1984) Deposition of Jimmie D. McClain (July 20,1954) ~ Deposition of C Thomas Brandt, Tr. 45,253-67 (submitted as prefiled written testimony) k See 01 Reports 4-84-006 (3/7/84); 4-84-008 (7/9/S4) i J e I 4 1 k l I I 4 { I .HarassingTelegramAccusing{chtspMf) of Imoracerly Copying Documents 6037Mtpp%fG a former. welder and OC inspector at CPSES, alleges {that a letter sently Applicants' counsel to Mrs. Juanita Ellis, President of CASE (as wel,1 y the other parties) accused {Qof stealing and lying, and threatened Q termination if caught. In actuality, a telegram, not a let.t.er, was 'sefit' to Mrs. Ellis, and the telegram did not accusfgd 3gjp))oflyingandstealing. Rafher the telegram suggests that/ -- 7_ _E47)was improperly encouraginggA@fMdWS to copy and remove documents f roriiln-site. The evidence and relevant material consists of: DepositionoffhME4&iM@J[ July 13,1984)h3MFliiQ() Telegram-(attached to CASE's Motion for Protective Order) (August 12,1982) Deposition of C. Thomas Brandt, Tr. 45,248-51, 45,252-54 (submitted as prefiled written testimony) ~ h 6

.. - = b .17 - Incidents Intended to Have %-{d;9.i/jleaveCPSES -r he? " WW - j a former, wglder and OC inspector at CPSES, related believes were intended to forcCDto a seri,es _of incidents which@CPSES site. i ~ leaveEC3 Employment at the These related incidents arei._, (1) nfeefi' hgs with Rona1A Tolsnn a d C. Thomas _Brandt wherefM 'h: claims they pressedQA+4 aboutE"::~J2 health andE2 ability tii continue",] 1 work due tojha:mEWmrdi(2)'W. BraJdL's reqTest thaty' bring (a j doctor's note in ez.ch week' to certifyc~=3 capability to wori, and 3) en CPSES,which[1@.bfblamesuponarticlesintheCircuitbreaker(acompany incident where was refused admittance to a bus carrying workers to ~ newsletter diftributed at the site). The evidence consists of: Deposition of h gf g f $ July 13,1984),h MMWG y;wyncp uMZk*pWlght$gb;g9gyf;;5gegp;#?$sd$$$$}%(([5+f Qf(( Q,Q i Affidavit of David K. Egbert (August 1,1984) 1 Deposition of C. Thomas Brandt, Tr. 45,241-52 (submitted as prefiled written testiciony) 4 Testimony of' Ronald Tolson, Tr. 51,0a4-45 Deposition of David Chapman (August 2, 1984), Tr. 76,522-527, and i Exhibit 7 See 01 Reports 7-84-005 (3/7/84); 4-84-008 (7/9/84) i d ~ i. 4 9 i

18 - f c E;w B il o P' i M ltestified as a Board witness on September 18-19, 1984 DE-US "was emploTed as a coatinc; intnec_t,or at CPSES from6x2M W ^ - -Hwa s employ _ed by[Fr" (RPRjM, $ Nhoweg r, 78~~7 r;g e:c;y d Because t % M a7Fa 1aterfd W%[MWRgWJJ bl#Wd his"administritive sumdvisor wasr.G. hig4d supervisor wasp ~ J ' rp7 3 Q ahp Considerino his b1ckaround ird udes Un WM iWM Mw

• JWW W,i cy w w 791 ano previous. engineering and inspection experience at several nuclear pT-ents,D CTNa~s one of the most qualified OC inspectors ever employed at CPSES.

gMn recounted several incidents relating _to harassment and intimidatiert. The finst incident invgived V WZE Njob meeting withg@pui;J/JC According tohwcc-74,hs a 'resu~ interview with W enoineeringjuaji?.ents. Tne second incident involved a concerr g' _ R lhad regarding ALARA review and reviews of. design change-authorintions (DCAs). According toRWmg he raised these questions to p # 9 4 R h g Training Ouality Engi~neer whowas]Hab,letoanswer, ~ u Althat meeting, according to["gigf m __ ' Cl _to[1W g instead too_kh ' hts questions. p -"<3ed JJfice to _, discuss the malter. E _ d indicated to w e 'I M that he was not to concern himself lith engineering matters but instea(wgs_to concentrate all of his efforts on perforging inspections. I: M ' Q was-later called,to discuss the _ same c;atter with[U; %g As a 'res ul t of th~ese encounters F'"~'1 - (E dtestified 'that he was~rsluctant to write an fiCR unless iTwas a "garcen-variety" type t;CR. The third instance of harassment. alleged b[ UUbolved, members gf-the painting crew. According tenwe M3 he was oFdered bjt@ a paint foreman, and other painters to perTorm inspections.C%g.ga mm stated that if he did not accede. readily to th,eir demands,~a complaint would ~ d who invariably sided with be lodged with his supervisor p - a s_m craft. -~~ The f~ourth incident involved an t CR written byf ~ hacjnspected. gj ' T} reporting an, indeterminate substance en a coated surface,whicn he t-Jitestified that after writing the tiCR&w

• m told him to~

not fo report for work the next day but in' stead report di7ect1v tcp r" !lon his next schpculed work day. During this meeting,g; cuesrToned'Q-g.iucgment and suggested that he was pafanoid. The final incident reccunted by[f _[linvolvedtheallegeduseby painter; of cigarette filters in the spray painting equipment. InC 1 view, painters ir.serted cigarette filters in the cheater v51Ves 0 1 of spr'a}v guns to pass the air acceptability inspection because t'he filters made the air supply appear cleaner than it was: the oainters then would remove the filters after the test. BeforC m_ ' Icculd report this ,tileaed non-conforming c:ndition, however, a complaint was lodaed with -1 {"' ~] supervisors. A meeting was held betweer 7 - y] J l ~ _ _.; -=- r= = .- n m __ N .g wf:v;jy h hm p the paint foremen, and C h 0 N M According tc 'e as gided with the painters becausef%:Trn 2. did not haVe personal ~ ~ knowledge ~that the filters were removed bf painters subsequent to the air acceptability test and because the use of cigarette filters was not a violation of any procedural requirement. Consequently,P ~.:;t.idid not write an NCR. It should be noted that the Technical Re9Tew Tea 5 fias confirmed l F n__.r dallegation. ~ Citations to the testimony byfhehlaTd Applicants on the matters described above are as followfi' H / A. h.,- ( W ifM!] initial meeting withb,ryM R % dit,i _ -L ,}3;Ms%@hW$@%pMQ

r. 21,445-47 (12/3/84 (Brandt)

Tr. 21,350-52 (11/28/84) (Brandt) Tr. 21,105-225 (11/28/84 (Brandt) Tr. 21,180-84 (11/28/84) (Brandt) m IE % ^ %',ikeeting withEfGN ' < idsfD Concerning ALARA B. G~eview anc Design Change'Kuthori;:ation ,-,r. %' _ g- % y.. Mr;f.s ' n;,w.W- + ' '., e.n v g;, n ~. i g q. N, _- Tr. 21,353-366 (11/28/E4) (Bra --ndt) i Tr. 21,125-35 (11/28/84) (Brandt) Tr. 21,187-237 (11/28/84) (Brandt) (NCR re rmetor core cavitvl a ?: W^^ - a oli N W &.dJ0iRC re reactor core activity)

r. 21,455-508 (11/28/64 (Brandt) (NCR re reactor core activity)

Tr. 22,453-526 (Manning) (12/18/84) C. Harassment by Painters 4N d42.%.x6:qeg::G.Mp{ee: eu.l y; Pf $ha :,d!Q b;ii .? s b D;- c ' :s G.~s un -c Tr. 21,,:T 74; 21,400-us (11/2S/64)_(Brandt) Tr. 21,243-63 (11/28/84) (Brandt) Tr. 21,434-41 (12/3/84) (Brandt) Tr. 21,490-96 (12/3/84) (Brandt) E. Detergent on Coated Surface NCR }3

jw :<.m p+. v n

ar. 21,374-377 (11/28/84) (Brandt) Tr. 21,263-272 (11/2E/84) (Brandt) Tr. 21,a41-445 (12/3/Sa) (Erandt) F. Cigarette Filer incident

y _g m.a;;;p;,;}

EG8hke r;..

r. 21.383-86 (11/28/84) (Br W t) 9-417 21,449-451; 21,496-508 (12/3/84) i (Bran t OI Report 4-83-016 at 13 (26 July 1983)

O 9 l i

/ . 77 [9 p fdDD % Witnesses: R E W M Trip Report h 5 m,. - hNgo MMNejhhmbh@In July 1983,b.fa qy, cg%g Director of Quality Assurance fo ~ visited CPSES to evaluate Applicants' "coatines progran in connection witr' a consulting agreement between TUGC0 andy NMVMMspent three days at CPSES observing the coatinr,s program alid speaking Mth site oersonnel. After he_ returned to[E M I-gorporate headouarters inF9 n rote a repo'rt tT6 PMW!bMQWNF@3np)$(dRW3NMR Wdetailing his observM lon.s and conc J 'regarding Appilcants coctings program. In his reportf5We"Ni _ expressed the view that the coatings program was plagu F by many p bblems 7 including lack 'of painter qualification, poor traceability and storage of materials, quality control reportino to craft._,and TUGCC management's lack of commitment to quality. I'&C h M. m n steport concluded with two explosive observations: (i) t Ef' CPSES and Zimmer plants; and (ii) parallels could be drawn between thethatD~ with TUGC0 because little, if any, ofiTe coatings work already in place was salvageable. ~- 4 TheI4NSMyrip report somehow found its way into the hands of the NRC, the'IntervE7ioFs, and the Dallas /Ft. Korth news media. The public discic-sure of the[Eu,:ggp report set off a chain of events culminating in o the recanting byb.-WMwManf the concerns and conclusions expressed in his trip report. The reas6fis behind p*- < - q dturnabout is the subject of this aspect of the intimiditT6n proceeding. The testimony relevant to this inquiry may be found at: - t-L. i ~.. . +y v.;e,;f:: ~~ W N M M,,.~, % m% w. v Xh,4 e.$ Ap ~ we um w a p w g y@r u n%s M MArdm{M@w%gu#rw$@n %m%w&.A an. 1% g~d6&m w gw yn r M me ug m w w< w. wp.m&n; e. e .e -yu. m ~. n v au m m ,n w n fYYYh rit[_ _ ,-y hNh 7 n Tr. 20,092-20',179 (11/20/84) (Roth) Tr. 20,180-20,450 (11/20/84) (Roth) Tr. 20,541-21,748 (12/3/84) (Roth) ~7 .s s

m Q%$,

p

~.:5 4:mx ', 7 4;, W.. ; hp~- ,,, yx g. 5 A w *g.; -t,- r, g q/ p % j {W. J g 3 k % L M t (w f Lgg-r%qw.. p%fpQQ,Jg w Tr. 22,309-22,452 (12/17/84) (Evid. Dep. of H. Brooks Griffin) &!;fQR.i%Qyy6$&&;f$.lh lh.$l& %%$;Q$fl%$?QQf,2,M,,5@Q }QQyMlI y :s,. w t- - cw ,r ue e, 2 v w. r n Q (- ~? . c d.f , N,,, 55 i; $_k; .( iff 14P pQ ( g)>[;' g/ QO ' f {.[? Ir >,,'M i? s .~j',,.fy. J p; _, i Y,$ yf'A'N. Y f h.w! _ 5l 7 _. l , if a.- - ae - - p. w c ,,+ i x -m ,,_ _ = -. __=

~ Termination of g g.w h 6M] - [5 wf.eMe.thi a welder, alleged that he was terminated for reporting a vgouge in vpip to a QC inspector. n- ~i:: wwwallegedly discovered a gouge in a pipe near where he was welding ron a' pipe._ hanger, His foreman supposedly wanted to. cover it up and-witnessedlpmmsjsh,owing_the gouge to QC inspectorji>:e ri%'g:v,,,[ a_s. Shortly thercarterrfisse:"m kas terminated. Applicants assert!!!; l terminated for absenteeism. ~ Evidentiary depositions: e 19ER$5MERESERR Deposition of Jimmie Green; July 9,.1984 (Tr. 35,000-078) Deposition of John Hallford; July 19, 1984 (Tr. 70,000-059) Deposition of Fred Coleman; July 9,1984 (Tr. 35,079-125 i i I I f i 4 e i i l l l } t I f' f. L/ g, s t. a- ' ~~ Valve disk incident s. hhX+WM %4 alleged that wheng brought a discrep_ancy in valve disk ' numbers to the attention of T dfiupervisor, he told $, ' it didn't matter, which madej;pjpg"' discouraged." ^ l _ n JUpt@@S@i}was shown a traveler byfRi9M!"UW%?lwith a valve disk number which did not match the disk #Dmber of the (Tata Reoort. When @ ~ brought.this to the attention of$ supervisor,tE?we.oW:rhyne ~ told Q it didn't matter and would cost too much money to check. Applica'nts assert that it really didn't matter and deny that cost would be a factor if the discrepancy were real. Evidentiary depositions: m ,hh;bkf hk)dk k 1 } Deposition of Gordon Purdy; July 10, 1984 (Tr. 41,139-166; 266-267) Testimony: Prefiled Testimony of Gordon Purdy; Tr. 41,331-336 (8/16/84) Prefiled Testimony of Gregory Bennetzen; pp. 16-17 (8/16/84 and 8/IE/E4)

' i Pressure on N-5 Viewers hdischt.Gh;j,allegedthatunduepressurewasappliedtoQA/QCdocument ' reviewers. ((.' 7 - J/'* Ialleged thatd supervisor,(fEW, -eMi' 5lp'ressured/ 'rintimidated ttr6 N-5 documenCreviewers by: "TI) demanding 40 iso's a week; (2) threatening the use of job shoppers; (3) comenting on company loyalty. Evidentiary depositions: Testimony: Prefiled testimony of Gregory Dennetzen; pp. 3-16 (8/16 & 8/18/84) Prefiled testimony of Gordon Purdy; Tr. 41,323-331 (8/16/84) Testimony of Gordon Purdy; Tr. 16,268-307 (9/13/84)

/j'l,,. - - CES Review Sheet incident ["[p - ~ -f r n !:lalleged that d supervisor ordered a reviewer to sign s oit a OES revTew sheet with5iit' doing the review. ((, - ijalleged that Bennetzen ordered a reviewer,[h'h to sion off on a QES ' cover sheet when the original was missing witnout having"E]do the review.' Applicants assert that this is an acceptable practicer Evidentiary depositions: r_ m I' $ f' ' f a Testimony: Prefiled testimony of William Darby; pp. 4-12 (8/18/84) Prefiled testimony of Gordon Purdy; Tr. 41,315-323 (8/16/84) Testimony of Gordon Purdy; Tr. 16,243-268 (9/13/84) 6

26 - s. Reduction of Force (ROF) Incident / jVfs:f'?Qjha~llegedthatthereissomethingwrongwiththeway ~ h ployees are. selected for a ROF. [f.yf@y-!;] alleged that the more qualified people were ROF'd. Applicants respViise-is that there is a comprehensive, mainly objective method of selection. Evidentiary depositions: m c. i 'a w. Testimony: Prefiled testimony of Gordon Purdy; Tr. 41,337-366 (8/16/84) Testimony of Gordon Purdy; Tr. 16,310-379; 16,384-387 (9/13/84) I l 1 Witness F Witness F was a system test engineer ("STE") employed by Impell Corporation at CPSES from September 1982 through April 1982. Witness F was assigned to the Electrical Startup Group, which is part of the Startup Organization. (Deposition of Witness F (July 18, 1984), Tr. 55,517-18; Deposition of Arthur Lodon (August 15, 1984), pp. 12-13). Witness F described five incidents which he believed were examples of intimidation or threats against him. In brief, these are: (1) an allegation that Fred Powers told Witness F, "You're treading on thin ice," in response to Witness F's refusal to sign a startup work authorization ("SWA") because of his belief that there was an inconsistency between ES-100 and Regualtory Guide 1.75 ("R.G. 1.75"); (2) that Dick Cano tried to discoura calling the NRC on the ES-100/Dr-1.75 conflict; (3)ge Witness F from an allegation that .Ivan Vogelsang threatened Witness F that he would get John Merritt to " pull his chain;" (4) that Xen Luken harassed Witness F in connection with a problem with ferro-resonant transfers; and (5) that Art London told Witness F that if he had enough time to find problems (such as the ferro-resonant transformer problem and the apparent conflict between ES-100 and RG 1.75) that he had time to do more work. The testimony relating to these incidents may be found at: A. Disagreement With Fred Powers and Dick Camo Tr. 55,620-44 (7/18/84) (Evid. Dep. of Witness F) Tr. 75,510-640 (7/18/84) (Evid. Dep. of Fred Powers) Tr. 77,009-17 (8/2/84) (Evid. Dep. of Ivan Volgelsang) (Vol.1) Tr. 76,011-099 (8/2/84) (Evid. Dep. of Dick Camp) (Vol. I) Tr. 76,215-250 (8/3/84) (Evid. Dep. of Dick Camp) (Vol. II) Tr. 53,390 443 (7/20/84) (Disc. Dep. of Witness F) Tr. 34-72 (8/15/84) (Prefiled testimony of D. Arthur London) Tr. 14,621-71 (9/9/84) (Witness F) B. Alleged Harassment Bv Ivan Vogelsang Tr. 55,650--679 (7/18/84 (Evid. Dep. of Witness F) Tr. 77,017-200 (8/2/84 (Evid. Dep. of I.W. Vogelsang) (Vol. I) Tr. 76,101-164 (8/2/84) -(Evid. Dep. of Dick Camp) (Vol. I) Tr. 74-84 (8/15/84) (Prefiled Tesimony of D. Arthur London) Tr. 14,671-89, 14,704-43 (9/9/84) (Witness F) C. Alleged Harassment by Ken Luken Tr. 55.680-86 (7/18/84) (Evid. Dep. of Witness F) Tr. 78,509-538 (8/3/84) (Evid. Dep. of Kenneth L. Luken) Tr. 76,164-181) (8/2/84) (Evid. Dep. of Dick Camp) (Vol. 1) Tr. 84-88 (8/15/84) (Prefiled Testimony of D. Arthur London) D. A11eoed Harassment By D. Arthur London .Tr. 55,686-89,706 (7/18/82) (Evid. Dep. of Witness F) Tr.94-153 (8/15/84) (Prefiled Testimony of D. Arthur London) Tr. 14,608-21.(9/9/84) (Witness F) Tr. 14,697-704 (9/9/84) (Witness F) r 4 -}}