ML20078B851

Objection to ASLB 830914 Prehearing Conference Order, Motion for Reconsideration & Other Relief & Request for Certification or Referral.W/List of Witnesses to Be Subpoenaed Re Palmetto Contention 6 & Certificate of Svc

ML20078B851
Person / Time
Site:	Catawba
Issue date:	09/23/1983
From:	Guild R GUILD, R., PALMETTO ALLIANCE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20078B853	List: ML20078B851 ML20078B910 ML20078B931
References
NUDOCS 8309270278
Download: ML20078B851 (39)

Text

• u o

903ETES USNRC

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IIN ITED STA TES OI-A Miih iC A N U Cl.!. AIi I?EGil.. ATORY NMt'. I SS I ON 13 SEP 26 #1:43 esE9dE_IBE_oIOUIG_06EEIY_oMD_LIggNQ1HQ_B96FD n the P.stter of

)

)

DUKE POWER COMPANY, et si.

)

Docket Nos. 50-413 S0-414

)

(Catowns Nuclear Statien,

)

Unit-1 and 2)

September 23: 1983 PALMETTO ALLIANCE OBJECTIONS TO PREHEARING CONFERINCE ORDER MOTION FOR RECONSIDERATION AND OTiiER RELIEF OH-ICQUEST FOR CERTIFICATIuN O I.

ndFh:<RAL Pursuant to 10 C.F.R. Sections 2.716 and 2.762 Palmotto A11 t an c-n. r o b'.'

ooyects to the Board's September 14.

1963 Prohear2 7

.<.nference Order in a

number of particulars.

mov.c for

'concidarstion and revision of that order an he:cafter c;.cified, seeks other rellof by way of

" s i m p l i f 1 ? s t l e r.,

c.crifiestion and specificatior. of the issues" for hearing in

~

+his proceeding, and, in the alternative, requests certification' or reicrral of those patters for deternanction to.the Comnissian or the ' Atomic Safoty and Licensing Appeal Board.

Painetto

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Alliance's request for extension of 21ve days additional time for the filing of ob]ections to this order has been denied by Order cf September 20,.1983.

8309270278 830923 gDRADOCK 05000413

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1.

As Palmotto A111anco reads this Board's September 14,

• 1983 Prehearing Conference Order it appears that th2s Board oither misroads or micunderstands Palmotto Allianco's Quality Assurance Contention Number 6 in serious ways that cloud and obscure the nature of Palmotto Allianco's concerns expressed since the outset of this proceeding, the allocation of the burden cf proof with respect to the adequacy of applicant's Quality Assurance Progran and the assuranco that the Catawbs Nuclear Station is safely built, seriously hinders and limits palmotto Alliance's ability to offer evidence on this subject in upcoming heerinoc.

Ps1 motto ob3 ecto to thic Board's Prchooring Conferenco Order and i r. tnis reqard, respectfully roquentc clarification of

4. h a n....!..:

11 :En a und a ssis au :vt oi1octivu of Llan t Urdut*a torms astd oficet; requesto

• • bi m pl a i l ca t iota,

clar111 cation and spect: 2 cation of the incuon" with respect to this subject, under

-rovisions or 10 C.F.R. 2.752 (a)(1);

or, in the alternative, T

requestc certification or refer si of these matters to the Commiscion or the Atomic Safety and Licensing Appeal

Board, as apprcpriate,under provisions of 10 C.F.R.

sections 2.718(i)- and 2.752(c).

The thrust of the Board's-September 14, 1963 Prehosring Conferenco Ordor with respect to its characteri=stion of Ps1 motto

• Contention 6 is to mistakenly limit Psimetto's proof on its Quality Assur-ince Contention to- "Information about specific construction deficiencies."

(Ordor at pp.

6-8.)

If Psimetto's

_ 3 _

cading of this Order is indeed correct, thir spec 2fication of

.the issues improperly targots the " trees" while missing tho

" forest" by limiting proof to

" specific construction deficiencies" which are meroly the symptoms of the more pervasive malady: the systematic Quality Assurance breakdown at datawba. By no doing, the Board appears to accept tho same fallacious approach to this issue as is reflected by Duke Power Company's generic and programmatic complaints by response to the

serious, the Catawbs welding inspectors.

Duke's response there

was, likewise, to target only the

" specific construction deficiencies",

i.e.,

the bad welds, while ignoring the procedural cnd programmetic Quality Assurance breakdown.

Quality Assurance pronicco at Cstswbs have not and will not be solved by simply reworking or exple_.ing away the known construction deficiencies.

It is the indeterminate character of the as built condition of the plant - the unknown construction deficiencies that should be the proper target of palmetto's Quality Assurance Contention 6.

By memo to the parties of September 16,

1983, the Board Chairman transmitted the Appesi Board's most recent pronouncement on the subject of Quslity Assurance:

Unigg__Elegtric__Cg, (Callsway Plant. Unit 1),

ALAB-740,_____

NRC_______

(September 14, 1963),

with the appropriate admonition that, "[T]he decision litigation of Contention 6."

Indeed t

will provide some guidance in it does:

4 -

I

A recurring issue in reactor oporating license proceedings is whether the incility hoe been properly constructed.

In most instaneos, the focus is upon the execution of the Quality Assurarre Program designed to eliminate the possibility that construction deficiencias of potential safety significance will go undetecteo and therefore unrectified.

In any project even remotely approaching in magnitudo and complexity the erection of a nuclear power plant, there inevitably will be some construction cefects tied to Quality Assurance lapsou

thus, in examining claims of Quality Assurance deficiencies, one must look to the implication of those deficiencies in terms of safe plant operation.

Obviously, this inquiry necessitates careful censideration of whether all ascertained construction errors heye been cured.

Eygn_ii_thig_1g_gstgbiighgd_tg be__the__ css 91__bewex9Et__theE9_esr Eeealn__9__9999tien whether_theE9_bss_been_9_bteeBdewn_in_Quglity_Aggurageg ereceguren_gi_syiiicignt_dingagigag_tg_rgigg_iggitingte d ubt_ge_tg_tbe_ersE911_intestity_ef_the__fecility__ sed 9

A Ate ___Fafety-relsted__etructurgg__ged__cgepggentg3 demonstration of a pervosive failure to carry out the Coality Acsuranco Proqran miqht well atand in the wny of tho reslutolto uninty 1 A ntli n s.

(lien pla n n i n nupplietd.)

bj., n11p vpanion at [.g,.

1 3.

At tho Apponi Itoo nt aptly o t,o e r v e rs,

ident121 cation anu dcmonstration that "all encortained construction orrors have boon curod" is only,the beginning <-i the Quality Assurance inquiry and not the end.

Ilowever, hero, if Palmetto Alliance's understanding of the Board's Prehearing Conference Order is correct the existence of " specific construction deficiencies" is the be all and end all of this Board's inquiry.

By its express terms the Ecord's Prehooring Conference Order observes that the offecs of its terns is to requiro Palmotto's dicciosure of all information about specific construction deficiencios for the record by Septenber 19, 1983 - the Monday following the Friday receipt of.

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tho Ordor i t.se l f

- on pa2n that, "(Alny nuch inf ormat. i on not no disclonnd may bo oxcludod from tho hnaring upon a

Limoly ob3nction."

Order at p.8.

Palmetto Allianco fooro that the como sort of "squeo=o play" worked upon the Catawbs wolding inopoctors by Duke Power Company in responding to their Quality Assurance complaints, will be worked upon Palmetto Alliance, and ultimstely the public offected by Catawbs's operation, as a

direct consequence of this approach to Ps1metto Alliance Contention 6.

There, Duke Power's Task Forces, its outside consultant the Managemont Analysis Company (MAC), and the NRC Region II

Staff,

" solved" the welding inspector problem by addressing only the nuncrous specific construction deficienciec (tho technical

.:..nco r rm )

whilo ionorinq tho programmatic Quality Annuranco Program br oole down - the haracsmont, falsification, and lack of management support (the nontechnical concerns).

We urge this Bosrd not to repost that mistake.

Fron thu outnet of this proceeding Psimetto Allisnco has exprosuod its concern for programmatic failures in the Quality Assurance Program at Cotswba on the basis of the first hand experience of its members Nolan R.

Hoopingarner and William R.

McAfeo. In ruling on Applicant's and the NRC Staff's Motion for Fartial Summsry Disposition of Contention 6 this Board explicitly acknowledged that Hoopingarner's and McAfee's experienco raised

.msterial issues which go to the heart of adequate Quality Acsurance Progrsm: instructions not to write Non-Conforming Items

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(NCI's), harannment and" company proesuro" not to report faulty we,rkmannhip or t c.

ecm un2cate wit h the Nuclear I<equ1 nt cir y Commission. (Order of August 26, 1983.) 5uch programmatic, coro evidence of Quality Assurance breakdown has been identified by Palmetto Alliance since the beginning of this proceeding.

Palnetto Allianco was explicit in oxpressing its concorn.

In its July 22, 1981 Petition to Intervene, at p.5, Palmetto advanced this contention:

Substandard worknanship and poor Quality Control strongly suggests that actual plant construction is substantially below NRC standards in many safety-related areas.

A number of former Duke Power Conpany construction workers, including a

certified Quality Control Inspector, have complained of systeratic deficiencies in plant construction and cornany pronnuro to approve faulty workmannhlp.

In its D..combor 1961 nupplomont containing Contont. ion G Palmetto Alliance asserted as follows:

Substandard workmanship and poor quality control strongly suggest that actual plant construction is subctantially below NRC standardn in many sofoty related steos.

Applicants have failed to provide a

Quality Assurance program which meets the requirements of 10 C.F.R.

Part So, App.

B, and no reasonable-assurance exists that the plant can operate without endangering the health and safety of the public.

The Commission has noted that

'the regulated industry... bears the primary responsibility for the proper construction and safe operation of licensed nuclear facilities' Egdgrg1__Igrt__C1gie__gf__Gegergi Pghlic_Utilitigs_C_orp3,,gt_g12,. CLI Al-lo, 13 NRC 773, 775-776 (1981).

The NRC's Systematic Assessment of Licensee Performance Review Group found the Catawba facility 'Below Average' among power rwactor facilities under construction particularly

'in the areas of quality assurance including management and training.'

NUREG 0834, NRC Licenoco Assessments, August 1981, p-B-1. A nuncer of former Duke Power Company construction

workers, including a

certified Quality Control

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deficiencies heve complained of systematic Inspector, to approve plant construction and company pressure in faulty workmanship.)

In its December 1, 1982 Memorandum and Order, the Board recast Contention 6

and accepted it for litigation, stating:

Much of Palmetto 6, which is concerned with substandard workmanship and poor quality The control, lacks sufficient specificity.

last

sentence, however, concerns alleged

' corner cuttino' and does supply a cufficient basis for a

contention.

We recant the contention that we now necopt t o" read a r, follows:

Because of systematic deficiencies-in plant conntruction and company prenr,uro to approvo f ault y exints that the workmanship, no reasonable accurance without c ri<la rigor i n ct the healt h and pinut con op roto safety of the public.

The thrust of this contention is attitudes primarily toward alleged company and practices:

proof of this contention, of presumably involving specific instances nisfeasance, need not be adduced at the stage.

Late in Discovery Duke Power Company and the.NRC Staff disclosed the existence of the Catawba Welding Inspector Task Force Investigation and the underlying serious and pervasive complaints by welding inspectors of harassment, falsification-of QC documents and longstanding managonent failure to implement on offect2ve Quality Assurance Program.

On the basis of this information the Board recognizr.d the sorious safety implications of the Quality Control and Quality

_ a.

Annura Me allegationb in tha weldinq nrea and granted paimetto Allinnee's MacAAB tA hPABen f:9 Bien 13AB Discovery to focus on the welding inspector complaints.

With loss than a

month of reopened discovery, pursuing the matter almost

fulltime, of Duke Pslmetto conducted extensive oral depositions and NRC personnel in this area.

This discovery confirmed Palnotto's eerliest fears, revealed extensive evidence of widespread QA breakdowns at

Cstswbs, extending far beyond the welding craft ares.

Through this discovery Palmetto learned for the first time of the critical October 1982 sudit of construction p'octicen at Catawba the INPO study - " Cone.truction Pro 3cct Eve.iuation for Catawba Nucle 3nr Station."

Ovor Duke Power Company's oblectione, this Board directed production of the INFO study together with past revisions of cor.struc tion and Quality Assuranco procedures in use over time at the Catawba Station.

On the basis of this information learned.since May 1983 Palmetto Alliance sought by Motion of September 9, 1983, reopened discovery of Quality Assurance matters beyond the welding aros permitted earlier and additiensi relief to permit the comprehensive treatment of systematic Quality Assuranco concerns at Catawbs.

Finslly, on September 14,

1983, the Government.

Accountability Pro 3ect, on behalf of Palmetto Alliance, -

requested the NRC Comnissioners' inmediate action pursuant to 10 C.F.R.

section 2 206 to require independent audits of the as-built condition of the facility and the Quality Assurance program at Catawba.

GAP further sought the conduct of an Office of Investigation inquiry into "the deliberate mishandling by Duke Power Company management of certain serious complaints by Catawba welding inspectors ** and an Office of Inspector and Auditor (OIA) internal investigation i

of the Region II Staff response to the welding inspector complaints.

In Jight of the foregoing ralnotto Alliance respectfully objecte to the Board's Pretnaring Conference Order, seeks clarification and revision of that Order to clarify ano specify the Quality Assurance issue for hearing in this proceeding consistent with Palmetto Alliance's originci Contention 6

and the guidance contained in ALAB-740 to permit litigation of the programmatic Quality Assurance breakdown at in the alternative, to certify or refer Catawba; or,

this matter for determination to the Connission or the Atomic Safety and Licensing Appeci

Board, ac appropriate.

2.

Palmotto A111anco obyoctn to the Board's Prohoarino Conferenco Ordnr of Sept ember 11, 1983, with

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rcepoct to its decision as to the order of presentation of ovidenco with respoct to Palmotto Contention 6.

While the Board properly providos that Applicants, who have the burden of proof, should proceed

first, the Board failed to provide that the NRC Staff proceed next with Intervenors fo11owine.1 third on thiu Contention.

The Board appropriately provides for the Staff and Applicants to precede Intervenors on Contention 44/18 based on its observation that this contention "is directed primarily towards the Staff." With respect to Contention 6 the NRC Staff's approval of Applicant's Gaality Assurance Program and of Duke Power Company's resolution of the wolding inspoctor complaints Justifios Palmetto's focus of its Quolity Acnurance Contention 6

primarily towards Applicants, and secondarily towards the NRC Staff. Since the Staff has undertaken to endorso and support Applicant's GA track record Intervonors shoulc be permitted to respond by following third in order of presentation.

Palmetto and further objects to the Board granting Applicant's NRC Staff unsought and un]ustified advanco opportunity for rebuttal not provided Intervenors. While the Board properly observes that testimony of witnesses subpoenaed by Intervenors "cannot be fully anticipated,"

the " unanticipated matters" which would crise upon the examination of such witnesses burden.

Intervenors and not Applicant and Stoff who employ and control the nubpoonced witnesses.

If any party is in a botter position to more fully anticipate the substance of such witnesses' testimony it is Applicants and the NRC Staff.

Intervenors should be offered the opportunity for rebuttal on this ground, or, at least, all parties should be provided the opportunity for rebuttal on equal footing.

3. Pc1metto Alliance objects to provisions of the Board's Order with respect to the

" designation of witnesses" as specified at page 3.

The identities of Palmetto'c proposod voluntoor witnesses on Contentions G

and 10 havo long lie t o n known t.o

t. r.o Doord and parties.

From tho outuot of this proceeding Palmetto has identified Messra. lioopingarner and McAice as its witnesses on its Quality Assurance Contention.

Since the summary disposition stage Palmetto has identified Dr.

Marvin Resnikoff and Mr. Lindsay Audin as its proposed witnesses on Contention 16.

The sub3ects of the witnesses' proposed testimony has likewise been long known to the parties.

The only witnesses whose identities have yet to be disclosed by Palmetto are the witnesses in the employ of Applicants and NRC Staff with regard to Contention 6.

While the Board is correct in observing that-many of the potential subpoenaed.

w

witnooseu are houtilo and also many havo been doposed by palmotto in discovery, it is not corroet in its belief that the disclosuro of the identitles of witnescos who have not boon deposed but romain in the enploy of Applicants will not "cause any harm to those persons or affect their willingness (or unwillingness) to testify."

(Order at p.3.)

As stated at the Prehearing Conference Applicants assert only that they "may" call unspecified welding inspectors and welding inspector supervisors to testify on Contention 6.

Palmetto. notes that in Applicant's filing of September 19, 1983 it lists some thirty-four welding inspectors and supervisors who "may be collod" to address

" mpressions of technical and nontechnical concerns

+

reqordinq OA/UC in wolding at Catawba." boyond statinq that it wishes to examino each and every witness idonti21cd by Applicants with respect to Contontion 6, and that it intends to seek, by subpoons, to compol the testimony of each of those persons not voluntarily appearing, as well as additional noned persons who either have already been deposed or who are members of the class of welding inspectors and welding snnpector such disclosure 'would, Ps1metto is supervisors informed and believes, indeed, cause " harm to these persons or affect their willingnoss (or unwillingness) to. testify."

In documents available to all parties.anc tulo Board many of the Cataw1.a Weld 2n9 Inq ectorc documented instances of haroaament and retallation for their expression of safety and Quality Assurance Program concorns.

On the basis of confidential information made available to Palmetto by investigators from the Government Accountability Project Palmetto states its belief that further identification of such harm and affect their persons would sub]ect them to ability to offer evidence in this proceeding.

Palmotto is herewith serving prgfiled testimony and consistent with adontific~: tion of subpoor. sed witnescos, the limitations of this obyection.

4.

Palmetto A111snee objects to the provisions of the Board's September 14, 1983. Order with rocpoct to

" profiled testimony" appocring at p.4, to the extent general that it requires for cubpoonsed witnesses "1.

a which each witness outlino o'f tho sub cet matters on 3

will be er.anined, and 2.

as to the Contention 6,

cpocific referenco to any particular instanco of the substandard construction concerning which alleged witness will be questicnod.

Filing of this information precondition to for subpoenaed witnesses will be a

requirement is subpoena."

Such a

issuance. of a

burden,' on ob3ected to on the grounds of hardship and improperly shifts the burden of proof the basis-that it,

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on $t$14 'tr$ttor to Iriturvonors irom the Applicant.o. but i

iI is' Utconsistent with the guidance or ALAB 740 with roepect to guidanco for litigation of Gus11ty Assurance Contentiost

'G, and that it is inconsistent w2th the provisions of 10 C.F.R.

section 2.720 with regard to the iss'Jance of subpoenoes requiring attendance and testimony of witnesses.

The Commission's Rule of Practice sbovo

cited, make closr that a party is en*

led to compsi the attendance and production of the mandatory issuance of evidence by witness, through s subpoons by the presiding officer, upon no more then

" showing of genersi rolovence of the testimony or a

"shall evidence sought," however the presiding Officer, n.it attompt to dototmino the adminnibility of evidonce,"

In nuch applicot'lon 1or subpoons.

Tno showing required by the Bosrd in its Septenber 14,

1993, Ordor burdonu Palmotto for beyond t.he showing required by section 2.720.

Further, as the Board has recogniEnd in its obcorvationn about the

" hostile" on Contention 6 in tho employ of charactor of witnosses and perhaps the NRC Staff, provision of the Applicants, information specified will simply serve to permit

" coaching" of such witness by the ' party who' controls her' or him and will make more difficult the task of Palmetto Alliance to " fully anticipate" their likely testimony.' With respect to item 2 required to be filed i

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r e

for subpoenaed witnesses the " specific reference to any particular instance of alleged substandard conctruction concerning which the witness will be questioned,"

the if understood properly by Palmetto fails Board's Order.

to appropriately treat the Quality Assurance issue as argued under paragraph 1 above.

F 1.7 a l l y,

compliance I

with the Board's direction with respect to subpoenced witnesses is burdensome in the extreme, bordering on the impossible if provided in the detail understood by Palmetto to be required and within the time permitted.

Palnetto Alliance faced the following time. burden with respect to compliance with this Board's Prehearing Coniotonce eitdet:

9/14 Order issued 4 p.m.

Order read to Palnetto office staff on 15 minutes notice.

Palmetto.Counse' not present.

9/16 Order received by Counsel in the afternoon in.Chcrlesten.

5.C.

9/17 Saturday Pc1metto receives GAP's 2.206 Petition:

Counsel departs for prior business commitment in !;ew 7 rh City.

9/19.

Monday s.n.

Counsel has prior. business commitnent in New York City.

P.M.

Counsel works on analysis of Order and 9/19 deadline; inforns Applicant and Staff ob ections. - attempts to of its intention to file J

reach Board Chairman, conveys request for extension on the basis of workload and burden to Board's Law Clerk.

9/20 Counsel attends cito visit, Catawba Station, with Commissioner Gilinsky.

9/21[

Councel for Palmetto informed of denial of extontior l ' of. time in which to file ob3cet2ons: work on profiled j

testimony.

9/25 Work on profiled tuctinony.

i.

i s.

4 u; a,.

9/23 Work on pru111od tr stimony, work on objections and other required nubminnionn.

Palmotto requonto rollof from requirements of the Board's Order in this respect

but, nonotholons, 4

herewith 2iles its bout offorts at complianco consistent with this ob]oction.

S.

Palmetto objects to the adoption of the Februcry 1,

1984 date for close of Discovery with planning Contentions on the grour.d respect to Emergency stated of_ the Prehearin9 Cearerence. We enphasize -the importance of an adoquate opportunity to gather evidence end review the results of the Cotswbs Station Energency Exorcico.

The Discovery deadlino provided wt11 n. i t.

pnrmiL u s.n sof it s n. ovn: y t.< sci 1 a t i,

.irst h..:

t hai ovidence f or hoor a n<s.

6. P,almotto Alliance ob3ects to the Board's rulir.g at page 5

of its September 14, 1983 Prehearing Conferenc'o Order with r.,spect to accoso to Applicant'c documents.

Palmetto stands by its position that it acted in gustifiable and good faith reliance on the ability to have continued access to Applicant's-voluminous documents, the reproduction of which would be unduly burdensomo and expansive to Palmetto. It is Just such " inconvenience and expense" that Palmetto sought to avoid by not making wholesale copies oof oli,.

voluminous con c.t.ruction audits for example.

The Board'n ruling can only place an artificial roadblock, based solely on ability to pay, on access to concedodly relevant evidence to be considerod in this proceeding.

The Board's ruling with respect to the requirement on Palmetto to pay costs of reproduction in advance of the subpoona of records from Applicants is simply wrong.

10 C.F.R. section 2.720 makes mandatory the issuance of a subpcene by the presiding officer for "the production of evidence" upon "a showing, of genersi relevance of the...ev3dence sought,"

but makes no mention of the payment of costs of reproduction.

Ps1metto does not seek the reproduction of evidence but only the fair opportunity to have.

access to and inspect such evidonCo.

production of evidence by subpoons may not properly be conditioned upon payment of its costs of reproduction.

7.

Esimetto Alliance strenuously ob3cets to the provisions of the Board's Order with respect to "new evidence of construction deficiencies" appearing at pages 6 through 8 of the Board's Prehearing Conference Order of September 14, 1983. As understood by Ps1metto, such directives to provido the detailed specification "in the hando" of Applicant and Stsff by Monday,.

September 19, 1983 is punitive, burdensome, and simply _-

with an impossibility of prosents Psimetto Alliance complianco.

Palmotto Alliance did not even have tho Board'n Ordor an it'n hand until the afternoon of Fridsy, Sootomber 16, 1983.

An stated above, counsol ict Palnetto A11aar.ce had a

l ong-st ar. ding businesc comnitment in New York City and was not even available to attempt compliance until the afternoon of the deadlino date.

Ps1metto A111snee renews the argument advanced in support of its objections in Psregraph I above.

It is the language end treatment of the matters under the heading "New Evidence of Construction which causes Palmetto A11isnce such grave Deficiencies" coacern about the Board's approach to the Quality Aanuronen insuo in than procer d ing.

Palmetto Allianco is irankly puzzlod by

t. n o Board's language and direction on this matter.

Intorproting the terms "now information about deficiencies" most narrowly to specific construction mean specific. bad wolds, cracked

pipes, or valves need add nothing to its installed backwards Palmetto previous responcos to Applicant's August 15,

1983, motion.

Wo mean what we said when wo responded to Mr.

McGarry's first complaints on this

subject, "I don't have anything further to say to Mr. McGarry.

If he has problem, he should put it in writing.

I stand by our a

j-l T

or August Ib, statomonts."

(Sop, Applicant's motion statements by mischaractorized 1983.

)

Applicants in this motion as making Palmotto Alliance councol for Counsel for Palmotto to the contrary.

any such claim faceo with the Laceneing board's proposed

Alliance, schedule, appointment of an bifur-ation of the hearing board and propocod noparato additions 1 hoaring 1984 iuel loading to meet Applicant's May proceedingo to it by communicated information passed on

date, Accountability Proyect investigators, Governe.ent from Catawba workers, received by them in confidence that construction schedules had been speeded up, that workern were under intenne pressure to meet scheduling dandlina, and t hat workmanship wnn 1ikoly to suffor as had nothing and has Palmotto Allianco consequonce.

a nothing further to add by way of response to Applicant's motion of August 15, 1963 or by way of rnsponno to thin Board'n 4 ranting of that motion as reflectod in its September 14,

1983, Prohearing Conferenco Ordor.

If, however, the Doord's term "new information is understood about spocific construction deficiencies" in its broadest sense the task at hand is indeed specified by the Board impossiblo of accomplishment as betweer. the afternoon of with the time provided, i.e.,

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ft14Ay, SOptembet A C.,

ivuit and Muanl4y. Septemter 19, 1983 when such information was to be in the hands of applicant and StaII.

Palmotto Alliance obyocto.

Psimetto Alliance is indeed concerned about

" specific construction deficiencies" both those occuring prior to May 27, 1983 stretching back to tho bogtuning of construction of Cotswbs, ss well as those which have occured and will likely continue to occur after that date.

However, Palmetto's concern and conviction that such significant deficiencies exist as to

" raise legitins,te doubt as to the overall integrity of the facility and its safety-related structures and ccaponents,"

Caloway, slip opinion at p.2, is founded upon "a breakdown in Gunlity Assurance procedures of cui12ciant dimensions to raiso legitimate doubts as to thu overall integrity of the facility."

Id. Such "new information" has indeed been gleaned through the dcoositions and document discovery flowing from the is indeed contained in welding inspector complaints, the newly-discovered INPO study of construction at

Catawbs, is reflected in the transcript of Palmetto's crsi notion of September 9,

1983, and,

finally, is analy=ed and detailed compellingly in the GAP section 2.206 petition to the Commissioners. These matters are j

)

all as available to this Bosrd and the other parties as they.sre to ' Palmetto Alliance.

To require Palmetto f

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.n i: ann-to spec liy "any sucri information" in the tcrm and within the time apucified by the Board on pain of its exclusion from the hearing 1stor, improporly shiftn the burden of proof of the Gafoty of the facility from the Applicant Duke Power

Company, et al.

onto Intervonors and the public.

Palmotto Alliance respectfully obycets to these directives of the Board, seeks clarification of the Board'c moaning its those provisions, asks the Board to reconsider and revise its Order accordingly:

or, alternatively, requests certification or referral of these matters to the Conmission or Appeal Board for determination.

6.

In the altornativo, Palmotto Allianco requesta ihn ILon d erntt Iy or anina I his mni t us :.

sibinitnd t..

horoin for thit.o m i nn t.1 on to iho Commannion at tbo Atomic Safety and L1 conning Apponi

Board, an appropria'to.

Such certification in exprescly authori=od with respect to objections to Prohoaring Conference Orders such as the Board's Orcer here under provisions of 10 C.F.R.

section 2.752(c)., as surther authori=ed pursuant to section 2.718(i). 1 Palmetto-Alliance urges that such a referral is especially appropriate here within the guidance of the decision in 919velsad__ElecLric__111ueinstins__992t__et__si (Perry Nuclear Power Plant, Units 1 and 2), ALAB-675(May 17, 1962), whero significant legal and policy questions are involved in the appropriate constdoration of the Quality Assurance tenuen presented in this proceeding, upon which guidanco is newly availablo and needed,p_alaway, supra, and whore the Board's decision as reflected in this Order objected to

" fundamentally alters the very shape of the ongoing adjudication."

Perry, slip opinion, at p.15.

This Board itself has noted the preeminence of the Quality Assurance issue faced for hearing in this proceeding.

The appropriate standard,'for consideration of this matter as well as allocation of burden of proof and Intervenor's proper ability to offer evidence on this subject all are fundamentally affected by thic Board's September 14, l'Ju s Ordos. 1*n i mot t o Alliance

• is o t. o ?

t hat t h i c. Ib ia rd han referred rulings to the Appeal Board earlier in this proceeding, at the request of Applicants and tho NRC Staff.

Ccnoiderations of foirness further support referrol* of this me. ter-et the request of this Intervenor.

For the foregoing reasons Palmetto Alliance respectfully requests that the Board consider the obyectionc herein, that it reconsider and revise its September 14, 1983 Prehearing Conference Order in ordor to address Palmetto's objections; or, in the alternativo, that it refer or cert 1Iy the quontions raisod here for determination by the Commiasion or the j

i

- Appn41 Board, an appropriate.

N

/

/

j/

'_t___ _____Q_____

Ro =rt Guild P.O. Box 12097 Charleston, S.C.

29412 Counsol for Palmotto A111anco t

Y

?

Oopts.mber 23, 1983 1

I I

I o

k 3

f

- 24 c,.-.-.

~.. -..

c. i.. r.

111:l'010. Till' ATi)M i t ' * : Al'l:T Y A!JD

1. I t 'Ef! ; ! !!G liOAHD In the natter of

)

Docket Noc. 50-413

)

50-414 DUKE POWER COM1'IsNY, et al.

)

)

(Cat.awba Nuclea r Sta tion,

)

September 23, 1983 Units 1 and 2)

)

CERTIFICATE OF SP.RVICP.

I hereby certify that copics of PAI.MMTTO AI.LIANCE Obiecticar

,etc; Direct Testimony, and Witnesses To Be Subpoened, etc.

in the above captioned matters, have been served upon the follow-ing by depositing same in the United States mail, postage prepaid, b

en this N. lay of 198J.

g Ja~cs L. Kelley, Chair.r.

"Chaiman Atric Sa#ety and. Licensing Board Panel Atcnic Safety and Licensing Appeal ha U.S. Nuclear Regulatory Carlssion U.S. Nuclear Reculatory Carlssion Washington, D.C.

20555 Washincton, D.C.

20555 Dr. A. DixOn Calli".an Don R.

Willard Union Carbide Co:7 oration Mecklenburg County P.O.IW: Y 1200 Blythe Blvd.

n.k uitt:., n nn. :.. v r/H to Charlofte, NC 28203 Dr. Richard h. Fxter

[.J. P.icluel n t'.irry, III, Euo.

P.O. Box 4263 IMcvoice & Liben:an Sunriver, Orecon 97701 1200 ::eventwnth St., N.W.

Washi:19 ton, D.C.

20036 Chaiman Attnic Safety a:vi Licenning ihml Panel Jesse T., Eiley U.S. Nuclcar Rcy latory Car.insion 854 llenley Place Washington, D.C.

20555 Charlotte, N.C.

28207 g Gocrge E. Johnson, Esc.

Scott Stucky Office of the Executive Local Director Docketing and Service Station U.S. Nuclear Regulatory Carlssion U.S. Nuclear Regulatory Carission Washington, D.C.

20555 Washington, D.C.

20555 William L. Porter, Esc.

Ccrol F. Fagan, Attorney Albert V. Carr, Jr., Esq.

'Atcmic Safety and Licensing Pmrd P6nel Ellen T. Rd f, Esq.

U. S. Nuclear Roqulatory Comission Duke Power Coqcny Washington, D. C. 20555 P.O. Ecx 33189 Charlotte, N.C.

25242 Richard P. Uilson, Esq.

Assistant Attorney Cencral State of South Caroli.m v'

P.O. Sox 11549 Robkrt Guild Coltrhia, S.C.

29211 Attorney for Palmetto Alliance, Inc.

e-

00CNETED USNRC PALMETTO ALLIANCE, INC.

S h3 WITNEGGES TO HU SUHPOMNAED W1Til liMGAltD TO

{~Q~f_0,,{,7;p(f PALMETTO ALLIANCE CONTENTION #6

....., t y v

Subject to the objections contained in the accompanying filina by Palmetto Alliance with respect to the provisions of the Board's Prehearing Conference Order of September 14, 1983 with respect to "prefiled testimony" at p. 4, Palmetto Alliance hereafter endeavors to provide as fo.llows:

.(1) A general outline of the subject matters on which each witness will be examined, and (2) as to contention 6, specific reference to any par-ticular instance of alleged substandard construc-tion.concerning which the witness will be ques-tioned.

uider at p.4.

Pursuant to 10CFR 82.720, Palmetto Alliance hereby applies te the Chairman for issuance of subpoenas requiring the attend-ante and testimony of the following witnesses and the production of evidence from them with respect to contention 6.

Palnetto

~

seeks t:.e production of any and all documents in the possession of the witness or subject to the witness s control which reflect their knowledge of quality assurance and workmanship at Catawba within the scope of Palmetto contention 6.

If the witness is voluntarily tendered for examination by another party Palmetto seeks only the production of evidence fica that witness and an opportunity to examine that witness in i

~

since the'desionation of witnesses on contention turn.

IlowcVer,

6 by both Applicantu aru! the NRC Staf f appears by its termu to

'be conditional, Palmetto Alliance asks that subpoenas issuc to compel their attendance, testimony and production of evidence unless such attendance, testimony and production is otherwise agreed to.

Pursuant to 10CPR 92.720 (h) (2) (1), Palmetto Alliance socks an Order of the presiding officer recuiring the attendance, test-imony and production of evidence from the below named NRC person-7 nel who are bdlieved to have direct personal knowledge of material facts with respect to Palmetto contention 6 unicuely known to them reflecting such exceptional circumstances as reauires their testimony on this matter.

NRC STAPP EMPLOYEES INSTANCE OF

]

h'ITNESS SUBJECT MATTERS SUBSTANDARD CONSTRUCTION i

1. James P. O'Reilly a.-Approval and review

a. Knowledge regarding Region II Admin'.

of Duke Power Co.'s

" technical concerns of Catawba welding Quality Assurance 4

Proaram at. Catawba inspectors" reflect-ed in specific file

b. Policy regarding re-numbers listed at sponse to safety n.

4 of vol. 2 Final complaints by whistle-report of Task Force blowers effort to evaluate technical concerns

c. Response'and inves-of Catawba welding tigation of Catawba welding inspector inspectors, Duke Power Co.

concerns, Duke inter-nal investiaation

b. Knowledge of specifi and remedial measures 4

INSTANCE OF WITNESS SUB.1ECT FATTERS SU11 STANDARD CONSTRUCTION d.

Innpection and enforce-technical findings ment policy with regard contained in "Conut to construction at tion Project Evalue Catawba.

tion for Catawba Nuc1 car Station", 0 1982, the "INPO Stu 2.

Peter K. VanDoorn

a. Knowicdoc of concerns

a. Knowledge regardinc Senior Resident of Catawba welding

" technical concerns Inspector inspectors.

of Catawha welding-inspectors" reflect Catawba Nuclear Station

b. Review of Duke Task in specific file Force recommendations.

numbers listed at i of vol. 2 Final rei.

I

c. Review of implementation of Task Force effor of Task Force recommenda-to evaluate technic tions.

Concerns of Catawba welding inspectors,

d. Review of Catawba Quality Duke Power Co.

Assurance Program procedures and management.

b. Knowledge of specif technical findings contained in "Const tion l'roject "valu.,

t i r,i-for ca

,a Nuclear Stat.

n",.L 1982, the "INPO Ste 3.

Jack C. Bryant

a. Knowledge of concerns

a. Knowledge regardine Senior Resident of Catawba welding

" technical concerne l

Inspector, inspectorn of catawba welding Oconce Nuclear inspectors" reflect Station (formerly

b. Review of Duke Task in specific file supervisor of Force recommenda-numbers listed at }

Van Doorn) tions.

of vol. 2. Final rei of Task Force effor

c. Review of implementa-to evaluate technic-tion of Task Force concerns of'Catawbc

~

recommendations, welding inspectors, Duke Power Co.

d. Review of Catawba Quality Assurance Program pro-b..Hoopingarner and Mc ceduros and management.

allegations admitte-for hearing in the-

e. Allegations-of construc-

. Board's 8/26/83 Ord tion deficiencies made by Nolan Hoopingarner' and Ronald McAfee. - - _ - _ _ - _ _ - - - _ _

INSTANCE OF SUBSTANDARD WITNESS SUBJECT MATTERS CONSTRUCTION i-

. G.F. Maxwell

a. Complaints by welding

a. Technical concerns of Former Resident inspectors during his welding inspectors

. Inspector tenure.

brought to his atten-tion and communicated Catawba Nuclear Station-

b. Allegations brought to to Duke's Lary Davison his attention by Nolan as reflected in Davison 4

R.

Hoopingarner II.

deposition.

b. Concerns brought to his attention by Hoopin-garner as reflected in !!oopingarner prefiled testimony.

DUKE. POWER COMPANY I

EMPLOYEES AND AGENTS

" t ""h:u r.i l. cnn e' ' n n W.S.

Lee

n. Quality Annurance Proqram a. of Ca tawba we 10 t att Chairman organization and history.

.i n:n me; o r: " re f1. etr d

b. llis involvement as in upacifir !i1-nuni "rn li nted a t p.

• original QA manager.

of vol. 2 Final report

c. Lack of independence of Tcnk Force cffort of QA from construc-to evaluate techrice.

tion, concorns of Ca' iwha welding inspectors,

d. Response to welding Duke Power Co.

i inspector concerns.

D-nP"C 3 "

e. Organizatic".. of welding technical findire.w inspector Task Force.

con t a inct' in "rrnntrue-

f. Pay reclassification of tien Proj ect - Ev<. l r a-tion for Catawba weldina inspectors.

Nuclear Station", Oct.

1932, the " INFO Study" a.

Contract with Management i

Analysis Company.

h. Cause and remedial response Lo SAI.P I Iteport lielow Average rating.

i..INPO construction analynin.

q 3 !

1 INSTANCE OF UUDCTANDARD WITNESS SUBJECT MATTERS CONSTRUCTION

2. W.H. Owen

a. Construction design

a. Task Force Vol. 2 Executive Vice of Catawba Nuclear President for Station.-

b. INPO Study-Construction, Design Engineering,

b. Pay reclassification and QA Depts.

and recourses of welding inspectors

c. Task force investiga-1 tions of welding inspector concerns.

i

=

j

3. J.R. Wells Former QA manager

a. Establishment a,nd

a. Task Force Vol. 2 organization of QA dept.

b. INPO Study

b. Pay reclassification and recource of welding innpectorn.

4

c. Recommendations to resolve nontechnical l

concerns.

d. Circumstances of transfer to INPO - Atlanta

e. INPO construction evalua-tion as applied to Catawba in the Oct.

" Construction Evaluation"

. Task' Force.Vol. 2 4.-G.W.

Grier

a. QA-Program at~ Catawba Corporate QA

b. INPO Study Manager

b. Pay reclassification and recourse of welding inspectors.

c. Task Force investigations of welding.innpector Concerns.

d. Implementation of recom-mendationn in.ule by various Task Forces investigating welding inspector concerna (technical :& nontech-

. n i ca l l '

s s,..,,

-e~

e-n

.a r,

--e 4

4 INSTANCE OF CUBSTAMDAl(D l

SUBJECT MATTERS COMSTRUCTION WITNESS

c. QA management response to concerns.

f. Retaliation against welding inspectors and welding inspector supervisors for expression of. concerns.

2

a. A role in welding inspec

a. Task Force Vol.

5.

B. Gail Addis

Director, tor pay recourse.

b.

INPO Study _

Employee Relations

c. Instanccs of sub-r standard instruction reficcted in informa-tion from inspectors

'intervicwed as descri-bed in 12/3/81 memo to W.

11. Owen.

i.

T.P. McNechin

a. We I d i nej.i n::pec t o r

- a. Tach Force Vo]. 2 i

Member, Task Task Force 1 Fo rci-1 inve :t igat ion, b.

IN1'O Stualy findings and recom-mendations.

c. Instances of sub-standard instruction reflected in informa-

. tion from inspectors interviewed as descri-

-bed in 12/3/81 memo i

to W.H. Owen.

7. A. Parks Cobb

a. Work of the technical

-a.

Task Force Vol.-2

Chairman, task force, findings, Technical Task conclusions, and Force recommendations.

8.oC.N. Alexander

a. Review of welding a.-Task Force Vol. 2

Chairman, inspector nontechni-Nontechnical cal-concerns, findings,

b. Instances reflected Task Force

& recommendations of in-nontechnical task his. task force.

forco report and

~ correspondence.

b. Impicmentation of-recommendations.

I 1-i 4

_ (,.

4 s,

r-w

..E-

.m-,-

+

+

i INSTAMCE OP

Ult

:TA::1)Alti)

SUBJECT MATTERS CONSTRUCTION WITNESS 9.

L.R..Davison

a. QA Program at Catawba

a. Task Force Vol.2 QA Manager, Projects

b. Pay reclassification

b. INPO Study

& recourses of welding inspectors.

c.

Instances identified in walding inspector

c. Concerns expressed by nontechnical concerns welding inspectors.

report.

d. Task Force investiga-

d. Concerns expressed by tions.

Ron McAfee and Nolan Hoopingarner.

e. Implementation of recom-mcndations of Task Force.

f. Procedure provisions and changes in QAProgram.

g. Verbal voiding of NCI's,

h. Pressure to approve fm:1 I y workm.in::lii[.

J

i. Qualification of inspcctors.

j. Technical support in QA.

~

k. Resolution of construc-i tion. deficiencies.

1. Management support for-

~

'QC inspectors,

m. Responsibilities of QA-personnel.

n. Relationship with and direction of craft.

o. Compliance with OC procedures.

p. liarassment of' QC inspectors, q.

!<ctallation dc3ctinst inspectors for t'xlirt :::d tut ( s' net rn::.

7-

~

n yem+

r e

y-p

INSTANCE OF

.';U!:::TA!!!)Aki>

MITNESS SUl3 JECT MATTERS CONSTRUCTION 10.

R.A. Morgan

c. OA P r,q r ar.2 at Catawba

a. Tan:- Force Vol.2 Sr. QA Engineer b.

Pav recl.n :ification b.

INPO Study

!. :ecournen 01 welding i n :pec tc,r t.

c.

J nutru:cer, i F<:n ti fi<

in welding inspectc

c. Concernu exprenced by nontechnical concer welding inspectors.

report.

d. Task Force investiga-

d. Concerns expressed tions.

Ron McAfee and Nola.

Hoop i ne;arner.

c. lir.plementa tion of recom-mendationn of Tank Force,

f. Procedure provisions and changes in QAProgram.

c.

Verbal voidinc of NCI's.

h. Presnure to approve f.t u i t y w. ii 1. ::.n u.h i p.

.t.

Qualification of

.i nst' ecto r.

j. Technical utppo r t in QA.

k. Resolution of construc-tion deficiencies.

i. Manancment support for QC inspectors.

m. Responsibilitics of QA personnel.

n. Relationship with and direction of craft.

o. Compliance with GC prcceduren.

11.1 r.,.::nten t ol OC.i n:;tice L ur.

g. Rutallation ooginut 2napectors for e :pr e : i n.; con 1un..

.,\\' /

IN :TA! CM OF

Uls

:TA::DARD WIT::ESS StiBJECT MA';"PERS CO!ST'WCT7 0.

1. J.C. Shropshire

a. QA Program at Catawba.

a. Task Force Vol. 2 QA~ Engineer, Mechanical,

b. Welding inspector concernb. INPO Study.

Welding and NDE Implementation of welding c.

q inspector Task Force recommendations.

2. A.E. Allum

a. QA Program at Catawba

a. Task Force Vol. 2 Technical Supervisor Welding, NDE and

b. Welding inspector

b. INPO Study Mechanical concerns Inspection Implementation of welding -

c.

inspector Task Force recommendations'.

d. Reprisals against welding inspectors and supervisors for expressing concerns.

e. Evaluation of C.E.

Ronn and Ross recourse against 2

Allum.

3. C.R. Baldwin

a. QA Program at Catawba

a. Task Force Vol. 2

}

Technical Supervisor l

NDE and welding

b. Welding inspector

b. INPO Study inspection concerns.

c. Instances identified i

Implementation of welding in welding inspector i

c.

inspector ~ Task Force nontechnical concerns recommendations.

report.

t

d. Verbal voiding of NCI's, resolution of nontechnical concerns,-harassment, QC inspector / craft communi-cation.

i

-9_

a-i INSTANCE OF SUl:CTANDARD WITNESS SUBJECT MATTERS CONSTRUCTION

14. R.L. Dick

a. The welding inspector

a. Task Force vol. 2 l

Vice Pres, concerns.

b. INPO study Construction

b. Craft /QA relationship

c. Implementation of I

responses to welding inspector concerns by construction.

d. Harassment and intimi-dation of inspectors by craft.

e. Craft pressure on QA

f. Nonconcoformance eval-

~

untion team establishment 1

and opera tion.

g. changes in construction proceduren OA program.

h. current construction practices and schedules for plant completion speedup.

i. INPO evaluation of con-i struction at Catawba and implementation'of recom-mendations.

15. W.H. Bradley Catawba welding inspector A. Task Force vol. 2 a.

concerns b.

INPO-Study

b. Implementation of Task Force recommendations

c. Bradley files reflect-ing Task Force recom-

c. Nonconformance Evaluation mondation:implementa-Team tion

d. Nonconformance evalu-ation team log.

4 11

J -

INSTANCE OF SUBSTANDARD SUBJECT MATTERS CONSTRUCTION WITNESS W.O. Henry

a. Changes in QA procedure a.

Task Force Vol. 2 QA Manager, for handling NCI's Technical and other means for b.

INPO study Services documenting construc-tion deficiencies c.

Nonconformance evalu-(i.e., process control ation team log.

& R-2A's, etc.)

b. Resolution of welding inspector concerns

c. QA procedures and changes resulting from welding inspector task force.

d. Nonconformance evaluation Z

team and reevaluation of NCT'n 2

4 f.

Identification and descrip-Lion of records regarding connt ruc t-i on de f i c i enci en and QA problema.

a. liarassment of QC inspectors a. Task Force Vol.2-J.C. Rogers

- Catawba Project by craft b.

INPO Study Manager

b. Welding inspector task force report, recommendations

c. Incidents reflected l

& implementation.

in McAfee &

Hoopingarner testi-

c. McAfee.and Hoopingarner

mony, technical concerns,

d. Current construction schedule and speedup.

j D.G. Beam

a. Organization and history

-a. Task Force Vol. 2 l

Former Catawba of QA at Catawba

b. Incidents reflected ~in Project Manager,

b. Evolution of QC. inspection McAfee & Hoopingarner a

function profiled testimony.

c. Reorganization of QC under QALdopt.

d.

SALP.I Bolow Average evaluation of.CaLawba' construction.

c. McAfee & lloopingarner technical Concerns.

if r

_jj_

i

i INSTANCE OF GUl:STANDAltD -

CONSTRUCTION SUP.7ECT MATTP.RS WITNESS

a. Task Force Vol. 2

a. Harassment of QC i

Ed McKenzie

-Powerhouse Mcchanic inspectors Foreman

b. Craft pressure on QC

c. Use of NCI's

a. Welding inspector W.L. Sifford qualification

. Supervising Technician

b. Craft /QC relation-Welding Inspection

~

ship.

~

1

c. Harassment of QC

~

inspectors

d. Lack of support for OC inspectors from Ifid Tloig cific!!l lie

• lst I d.11 I Ull

.ltJ.t i 18:11

e. inspectors for expressing concerns.

a. Task Force Vol. 2

a. QC Program at Catawba

1. G.E. Ross

b. Nontechnical Task Supervising

b. Pay reclassification Force report j

3 Technician, and recourse by welding Welding Inspection

~

inspectors.

c. INPO Study

c. Technical and nontechnical concerns expressed by welding inspectors

d. Task Force investigations of those concerns.

Implementation & recom-e.

j.

mendations of Task-Forces

f. Procedure rvision and changes in OA program at Catawba.

~

g. Retaliation for expression of concerns.

l

h. Procenu control i.-NCI' resolution

j. Welding inspection t a

.. m m

=-

4 INSTAFCE OF SUj5GTANDisRD WITNESS.

.S U.B.J E.. C.T._ M A.TT.E..R.S

.C.O._NS_TRUCTION-i j '

(21:- G.E. Ross

k. Material control

. cont'd.)

1.' Design; drawings

m. Construction Procedure i

n. Weld procedures

o. VN. process

p. QA procedurc

g. Harassment

r. Management support i

22.

B.W.

Deaton

a. OA Program at~ Catawba

a. Task Force Vol. 2 Supervising.

b. Pay reclassification

b. Nontechnical' Task Technician, and recourses by Force report.

i Welding Inspection

' welding inspectors

c. Concerns (technical I

& nontechnical),

expressed by welding inspectors.

d. Task Force investigations.

<>f I ht)::e c<>ne e r ri:..

c.

Impicmentation of the reconma nil.i t i om. o f t.h e Task Force 1

f. Resolu tion of NC1.'s l

g. Technical support j

review of QA resolution i:

i i

1 i

1 T

- 13.

I

~-

1 ;1:.*.*l.l.. T. t O *

.:uti:.TA:::)AIt:>

. :U1 t.1 :.. 'T ::IsTT!.it::

'N*:::ITi" 3 "I' ! ' 3 -

t.; pt..;g.::;3,

23. Dean Benticy

a. GA Program at Catawba

a. Tank Force Vol. 2

b. Pay reclassification 6

b. Nontechnical Task

24. David H. Boney recourse of welding Force report l

inspectors c.

INPO Study j

25. John R.

Bryant

c. Concerns (technical &

26. James Bright nontechnical) expressed

27. William H. Burr by welding inspectors

28. Boyce Cauthen

d. Task Force investigations

29. Kenneth W. Karriker of those concerns.

30. Richard Childers e.

Implementation of the 31.

C.D. Crisp recommendations of the

32. Harold Eubanks Task Force at Catawba

33. T.A. Bumgardner

f. Procedure revisions and 3'. A.S. Gantt other changes at QA

35. V.C.

Godfrey program 1

36. Lindsay Harris, Jr.

g. Process control 37.

J.E.

Henson

h. NCI resolution

i. Welding inspection 38.

R.

Irby

35. Larry Jackson j

Material control

40. Richard Jones

k. Design drawings

41. Ronald Kirkland

1. Construction procedure

42. John McCoy

m. Weld procedure j,

43. Max Recp

n. VN process

44. Michael Rink

o. QA procedure

45. John M.

Rockholt

p. Qualifications

45. Mickey Standridge q.

Tech. Support

47. Ranuum Sinn,

r. Rosolutions l

s. Management nupport t.

Responsibilitics

u. Directing craft v.

Procedure w.

Harassment

x. Reprisal for expressing concernr..

t d

i k

l

-li-

.y

,,,y.,

m