ML20078B851
| 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: |
| 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
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n the P.stter of
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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-ooyects to the Board's September 14. 1963 Prohear2 7 n . r o b'.'
Order in a number of particulars. mov.c for
.<.nference and revision of that order an he:cafter
- 'concidarstion seeks other rellof by way of " s i m p l i f 1 ? s t l e r. ,
c;.cified, 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
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Appeal Board. Painetto or the ' Atomic Safoty and Licensing 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 \
l As Palmotto A111anco reads this Board's September 14, 1.
- 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 T
-rovisions or 10 C.F.R. 2.752 (a)(1); or, in the alternative, 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
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thir spec 2fication of cading of this Order is indeed correct, improperly targots the " trees" while missing tho
.the issues by limiting proof to " specific construction
" forest" deficiencies" which are meroly the symptoms of the more pervasive malady: the systematic Quality Assurance breakdown at datawba. By the Board appears to accept tho same fallacious no doing, approach to this issue as is reflected by Duke Power Company's response to the serious, generic and programmatic complaints by Duke's response there was, the Catawbs welding inspectors.
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 ;
t will provide some guidance in litigation of Contention 6." Indeed l
l it does:
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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 thus, cefects tied to Quality Assurance lapsou . . . .
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 d9ubt_ge_tg_tbe_ersE911_intestity_ef_the__fecility__ sed Ate ___Fafety-relsted__etructurgg__ged__cgepggentg3 A 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 oxcludod from tho hnaring upon a Limoly disclonnd may bo 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 offected by Catawbs's operation, as a direct the public consequence of this approach to Ps1metto Alliance Contention 6.
Power's Task Forces, its outside consultant the There, Duke II Staff, Managemont Analysis Company (MAC), and the NRC Region
" 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 programmatic failures in the Quality exprosuod its concern for 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 which go to the heart of adequate Quality
.msterial issues Acsurance Progrsm: instructions not to write Non-Conforming Items
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(NCI's), harannment and" company proesuro" not to report faulty wit h the Nuclear I<equ1 nt cir y we,rkmannhip or t c. ecm un2cate 26, 1983.) 5uch programmatic, coro Commission. (Order of August breakdown has been identified by evidence of Quality Assurance Palmetto Alliance since the beginning of this proceeding.
explicit in oxpressing its concorn.
Palnetto Allianco was to Intervene, at p.5, Palmetto In its July 22, 1981 Petition advanced this contention:
Control Substandard worknanship and poor Quality is strongly suggests that actual plant construction below NRC standards in many substantially safety-related areas. A number of former Duke Power construction workers, including a certified Conpany of Quality Control Inspector, have complained plant construction and systeratic deficiencies in 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 below NRC standardn in many sofoty subctantially Applicants have failed to provide a related steos.
Quality Assurance program which meets the requirements App. B, and no reasonable-of 10 C.F.R. Part So, that the plant can operate without assurance exists The endangering the health and safety of the public.
has noted that 'the regulated Commission 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, of 775-776 (1981). The NRC's Systematic Assessment Group found the Catawba Licensee Performance Review facility 'Below Average' among power rwactor facilities of under construction particularly 'in the areas assurance including management and training.'
quality 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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Inspector, heve complained of systematic deficiencies to approve in plant construction and company pressure faulty workmanship.)
December 1, 1982 Memorandum and Order, the In its and accepted it for Contention 6 Board recast 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 supplyrecant a cufficient the a contention. We basis for necopt t o" read a r, contention that we now follows:
deficiencies- in plant Because of systematic approvo f ault y to conntruction and company prenr,uro that the workmanship, no reasonable accurance exints the healt h and c ri<la rigor i n ct pinut con op roto without safety of the public.
The thrust of this contention is attitudes primarily toward alleged company contention, and practices: proof of this presumably involving specific instances of the nisfeasance, need not be adduced at _
stage.
Late in Discovery Duke Power Company and the.NRC the Catawba Welding Staff disclosed the existence of the underlying Inspector Task Force Investigation and inspectors serious and pervasive complaints by welding QC documents and of harassment, falsification- of to implement on managonent failure longstanding Program. On the basis of offect2ve Quality Assurance recognizr.d the sorious this information the Board .
safety implications of the Quality Control and Quality I
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Annura Me allegationb in tha weldinq nrea and granted paimetto Allinnee's MacAAB tA hPABen f:9 Bien 13AB $
to focus on the welding inspector Discovery With loss than a month of reopened complaints.
the matter almost fulltime, discovery, pursuing Pslmetto conducted extensive oral depositions of Duke in this area. This discovery and NRC personnel confirmed Palnotto's eerliest fears, revealed extensive QA breakdowns at Cstswbs, evidence of widespread 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 Station." Ovor Pro 3cct Eve.iuation for Catawba Nucle 3nr 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,
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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.
further sought the conduct of an Office of GAP 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 Catawba; or , in the alternative, to certify or refer this matter for determination to the Connission or the Safety and Licensing Appeci Board, ac Atomic 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 with respoct to Palmotto Contention 6.
of ovidenco 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.
appropriately provides for the Staff and The Board Contention 44/18 Applicants to precede Intervenors on this contention "is based on its observation that 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 of the wolding inspoctor complaints resolution of its Quolity Acnurance Justifios Palmetto's focus 6 primarily towards Applicants, and Contention 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 further objects to the Board granting Applicant's and 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 testimony it is Applicants and the of such witnesses' should be offered the NRC Staff. Intervenors 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 with respect to the " designation of Board's Order witnesses" as specified at page 3. The identities of Palmetto'c proposod voluntoor witnesses on Contentions long lie t o n known t.o t. r.o Doord and G and 10 havo parties. From tho outuot of this proceeding Palmetto identified Messra. lioopingarner and McAice as its has witnesses on its Quality Assurance Contention. Since the summary disposition stage Palmetto has identified Resnikoff and Mr. Lindsay Audin as its Dr. Marvin 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 is not corroet in its by palmotto in discovery, it that the disclosuro of the identitles of belief 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) testify." (Order at p.3.) As stated at the to Prehearing Conference Applicants assert only that they "may" call unspecified welding inspectors and welding supervisors to testify on Contention 6.
inspector 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 class of welding inspectors and welding snnpector the supervisors -
such disclosure 'would, Ps1metto is informed and believes, indeed, cause " harm to these persons or affect their willingnoss (or unwillingness) to. testify." In documents available to all parties.anc Weld 2n9 Inq ectorc Board many of the Cataw1.a tulo for documented instances of haroaament and retallation safety and Quality Assurance their expression of On the basis of confidential Program concorns.
information made available to Palmetto by investigators Government Accountability Project Palmetto from the such states its belief that further identification of harm and affect their persons would sub]ect them to Palmotto ability to offer evidence in this proceeding.
prgfiled testimony and is herewith serving adontific~: tion of subpoor. sed witnescos, consistent with the limitations of this obyection.
Palmetto A111snee objects to the provisions of 4.
14, 1983. Order with rocpoct to the Board's September to the extent
" profiled testimony" appocring at p.4, "1. a general that it requires for cubpoonsed witnesses matters on which each witness outlino o'f tho sub 3cet Contention 6, and 2. as to the will be er.anined, particular instanco of cpocific referenco to any the alleged substandard construction concerning which witness will be questicnod. Filing of this information witnesses will be a precondition to for subpoenaed Such a requirement is issuance. of a subpoena."
burden,' on ob3ected to on the grounds of hardship and the basis-that it improperly shifts the burden of proof y
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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 inconsistent w2th the Contentiost 'G, and that it is section 2.720 with regard to provisions of 10 C.F.R.
requiring attendance and the iss'Jance of subpoenoes Commission's Rule of testimony of witnesses. The that a party is sbovo cited, make closr Practice of en* : led to compsi the attendance and production evidence by witness, through the mandatory issuance of then s subpoons by the presiding officer, upon no more of the testimony or a " showing of genersi rolovence "shall evidence sought," however the presiding Officer, the adminnibility of n.it attompt to dototmino 1or subpoons. Tno evidonce," In nuch applicot'lon Septenber 14, required by the Bosrd in its showing t.he showing 1993, Ordor burdonu Palmotto for beyond Further, as the Board has required by section 2.720.
about the " hostile" recogniEnd in its obcorvationn on Contention 6 in tho employ of charactor of witnosses Applicants, and perhaps the NRC Staff, provision of the will simply serve to permit information specified
" coaching" of such witness by the ' party who' controls task of her' or him and will make more difficult the likely Palmetto Alliance to " fully anticipate" their testimony.' With respect to item 2 required to be filed i l
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e for subpoenaed witnesses the " specific reference to any particular instance of alleged substandard conctruction concerning which the witness will be questioned," the Board's Order. if understood properly by Palmetto fails 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 of its intention to file ob Jections. - attempts to 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.
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9/23 Work on pru111od tr stimony, work on objections and other required nubminnionn.
rollof from requirements of the Palmotto requonto 4
respect but, nonotholons, Board's Order in this its bout offorts at complianco herewith 2iles consistent with this ob]oction.
objects to the adoption of the S. Palmetto for close of Discovery with Februcry 1, 1984 date respect to Emergency planning Contentions on the grour.d stated of_ the Prehearin9 Cearerence. We enphasize -the an adoquate opportunity to gather importance of evidence end review the results of the Cotswbs Station Exorcico. The Discovery deadlino provided Energency 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 of its September 14, 1983 Prehearing at page 5 Conferenc'o Order with r.,spect to accoso to Applicant'c stands by its position that it documents. Palmetto acted in gustifiable and good faith reliance on the have continued access to Applicant's-ability to voluminous documents, the reproduction of which would be unduly burdensomo and expansive to Palmetto. It is and expense" that Palmetto Just such " inconvenience oli sought to avoid by not making wholesale copies oof
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 sought," but makes no mention of the the...ev3dence 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
an impossibility of prosents Psimetto Alliance with did not even have tho complianco. Palmotto Alliance afternoon of Ordor an it'n hand until the
. Board'n 1983. An stated above, counsol Fridsy, Sootomber 16, had a l ong- st ar. ding businesc ict Palnetto A11aar.ce available comnitment in New York City and was not even the afternoon of the attempt compliance until to the argument deadlino date. Ps1metto A111snee renews objections in Psregraph I advanced in support of its above. It is the language end treatment of the matters "New Evidence of Construction under the heading Deficiencies" which causes Palmetto A11isnce such grave Board's approach to the Quality coacern about the Aanuronen insuo in than procer d ing .
irankly puzzlod by t. n o Palmetto Allianco is Board's language and direction on this matter.
"now information about Intorproting the terms most narrowly to specific construction deficiencies" wolds, cracked pipes, or valves mean specific. bad need add nothing to its installed backwards Palmetto August 15, 1983, to Applicant's previous responcos responded to Mr.
motion. Wo mean what we said when wo on this subject, "I don't McGarry's first complaints If he has have anything further to say to Mr. McGarry.
I stand by our a problem, he should put it in writing.
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August Ib, or statomonts." (Sop, Applicant's motion statements by Applicants mischaractorized 1983. )
in this motion as making l councol for Palmotto Alliance l to the contrary. Counsel for Palmotto any such claim Laceneing board's proposed faceo with the Alliance, schedule, appointment of an bifur-ation of the hearing noparato board and propocod hoaring additions 1 loading proceedingo to meet Applicant's May 1984 iuel to it by information passed on date, communicated Proyect investigators, Accountability Governe.ent confidence from Catawba workers, received by them in that that construction schedules had been speeded up, pressure to meet scheduling workern were under intenne dandlina , and t hat workmanship wnn 1ikoly to suffor as had nothing and has a consequonce. Palmotto Allianco of response to to add by way nothing further or by way of 1963 Applicant's motion of August 15, that motion as of rnsponno to thin Board'n 4 ranting 14, 1983, Prohearing in its September reflectod Conferenco Ordor.
term "new information If, however, the Doord's is understood about spocific construction deficiencies" task at hand is indeed sense the in its broadest specified by the Board impossiblo of accomplishment as time provided, i.e., betweer. the afternoon of with the
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ft14Ay, SOptembet A C. , ivuit and Muanl4y . Septemter 19, 1983 when such information was to be in the hands of and StaII. Palmotto Alliance obyocto.
applicant about " specific Psimetto Alliance is indeed concerned construction deficiencies" both those occuring prior to stretching back to tho bogtuning of May 27, 1983 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 deficiencies exist as to " raise such significant overall integrity of the legitins,te doubt as to 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 has indeed been gleaned through the information" dcoositions and document discovery flowing from the welding inspector complaints, is indeed contained in INPO study of construction at the newly-discovered Catawbs, is reflected in the transcript of Palmetto's of September 9, 1983, and, finally, is crsi notion and detailed compellingly in the GAP section analy=ed 1 1
j 2.206 petition to the Commissioners. These matters are )
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 Duke Power Company, et al. onto the Applicant and the public. Palmotto Alliance Intervonors respectfully obycets to these directives of the Board, clarification of the Board'c moaning its those seeks 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 Safety and L1 conning Apponi Board, an Atomic 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 (Perry 919velsad__ElecLric__111ueinstins__992t__et__si Nuclear Power Plant, Units 1 and 2), ALAB-675(May 17, 1
1 1962), whero significant legal and policy questions are in the appropriate constdoration of the involved Quality Assurance tenuen presented in this proceeding, which guidanco is newly availablo and upon needed,p_alaway, supra, and whore the Board's decision as Order objected to " fundamentally reflected in this the very shape of the ongoing adjudication."
alters 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 proper allocation of burden of proof and Intervenor's offer evidence on this subject all are ability to Board's September 14, fundamentally affected by thic 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 this me . ter- et the request of this referrol* of Intervenor.
For the foregoing reasons Palmetto Alliance requests that the Board consider the respectfully obyectionc herein, that it reconsider and revise its September 14, 1983 Prehearing Conference Order in ordor Palmetto's objections; or, in the to address l
l l
alternativo, that it refer or cert 1Iy the quontions I
j raisod here for determination by the Commiasion or the 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
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. . . . . c. i . . r . .. .
- 1. I t 'Ef! ; ! !!G liOAHD 111:l'010. Till' ATi)M i t ' * : Al'l:T Y A!JD 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, en this N . lay of b 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 PALMETTO ALLIANCE CONTENTION #6 {~Q~f_0,,{,7;p(f
. . . . ., 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
~
turn. IlowcVer , since the'desionation of witnesses on contention 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
a.-Approval and review a. Knowledge regarding
- 1. James P. O'Reilly " technical concerns Region II Admin'. of Duke Power Co.'s of Catawba welding 4
Quality Assurance 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
- c. Response'and inves- technical concerns of Catawba welding tigation of Catawba welding inspector inspectors, Duke concerns, Duke inter- Power Co.
nal investiaation b. Knowledge of specifi and remedial measures 4
INSTANCE OF SUB.1ECT FATTERS SU11 STANDARD WITNESS CONSTRUCTION Innpection and enforce- technical findings d.
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
- a. Knowicdoc of concerns a. Knowledge regardinc
- 2. Peter K. VanDoorn of Catawba welding " technical concerns Senior Resident of Catawha welding-Inspector inspectors.
inspectors" reflect Catawba Nuclear in specific file Station b. Review of Duke Task Force recommendations. numbers listed at i I
of vol. 2 Final rei.
- 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 inspectorn of catawba welding Inspector, 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-
- a. Technical concerns of
. G.F. Maxwell a. Complaints by welding inspectors during his welding inspectors Former Resident brought to his atten-
. Inspector tenure.
Catawba Nuclear tion and communicated
- b. Allegations brought to to Duke's Lary Davison Station-4 his attention by Nolan as reflected in Davison R. Hoopingarner II. deposition.
- b. Concerns brought to his attention by Hoopin-garner as reflected in !!oopingarner prefiled testimony.
DUKE. POWER COMPANY EMPLOYEES AND AGENTS I
W.S. Lee n. Quality Annurance Proqram a. " t ""h:u r.i l . cnn e' ' n n organization and history. of Ca tawba we 10 t att
- Chairman .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.
- e. Organizatic".. of welding D- nP"C 3 "
inspector Task Force. technical findire.w .
con t a inct' in "rrnntrue-
- f. Pay reclassification of tien Proj ect - Ev<. l r a-weldina inspectors. tion for Catawba
" Nuclear Station", Oct.
- a. Contract with Management 1932, the " INFO Study" i Analysis Company.
- h. Cause and remedial response Lo SAI.P I Iteport lielow Average rating.
I
- i. .INPO construction analynin. q 3
1 INSTANCE OF UUDCTANDARD SUBJECT MATTERS CONSTRUCTION WITNESS
- 2. W.H. Owen a. Construction design a. Task Force Vol. 2 Executive Vice of Catawba Nuclear Station.- b. INPO Study-President for Construction, Design Engineering, b. Pay reclassification and QA Depts. and recourses of welding inspectors
- c. Task force investiga-1
" tions of welding i
inspector concerns.
=
j
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"
- a. QA-Program at~ Catawba . Task' Force.Vol. 2 4.-G.W. Grier 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.
Gail Addis a. A role in welding inspec a. Task Force Vol. 2
- 5. B.
Director, tor pay recourse.
- b. INPO Study _
Employee Relations r
- c. Instanccs of sub-standard instruction reficcted in informa-tion from inspectors
'intervicwed as descri-bed in 12/3/81 memo to W. 11 . Owen.
i.
i T.P. McNechin a. We I d i nej .i n::pec t o r - a. Tach Force Vo]. 2 Member, Task Task Force 1 inve :t igat ion, b. IN1'O Stualy Fo rci- 1 findings and recom-mendations. c. Instances of sub-standard instruction reflected in informa-
. tion from inspectors interviewed as descri-i '
-bed in 12/3/81 memo 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
& recommendations of in-nontechnical task Task Force his. task force. forco report and
~ correspondence.
- b. Impicmentation of-recommendations.
I 1-i 4
_ (, .
4
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r- w --
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+
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.
~
i
- k. Resolution of construc-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 StiBJECT MA';"PERS CO!ST'WCT7 0 .
WIT::ESS
- 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
- c. Implementation of welding q
inspector Task Force recommendations.
- 2. A.E. Allum a. QA Program at Catawba a. Task Force Vol. 2 Technical Supervisor b. INPO Study Welding, NDE and b. Welding inspector Mechanical concerns Inspection
- c. Implementation of welding -
inspector Task Force recommendations'.
- d. Reprisals against welding inspectors and supervisors for expressing concerns.
- e. Evaluation of C.E. Ronn 2 and Ross recourse against
. Allum.
- 3. C.R. Baldwin a. QA Program at Catawba a. Task Force Vol. 2 Technical Supervisor
} b. Welding inspector b. INPO Study l NDE and welding inspection concerns.
i
- c. Instances identified
- c. Implementation of welding in welding inspector i
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 SUBJECT MATTERS CONSTRUCTION WITNESS
!' 14. R.L. Dick a. The welding inspector a. Task Force vol. 2 l
Vice Pres, concerns.
Construction b. INPO study
- 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-1 untion team establishment 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
- a. Catawba welding inspector A. Task Force vol. 2 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 and other means for b. INPO study Technical 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 Manager b. INPO Study
- 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.
D.G. Beam a. Organization and history -a. Task Force Vol. 2 j .
l Former Catawba of QA at Catawba Project Manager, b. Incidents reflected ~in McAfee & Hoopingarner a
- b. Evolution of QC. inspection 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 l
i l
INSTANCE OF GUl:STANDAltD -
CONSTRUCTION SUP.7ECT MATTP.RS WITNESS i a. Task Force Vol. 2
- a. Harassment of QC
. Ed McKenzie inspectors
-Powerhouse Mcchanic 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
- e. lie
- lst I d .11 I Ull .ltJ.t i 18:11 inspectors for expressing concerns.
- a. QC Program at Catawba a. Task Force Vol. 2
- 1. G.E. Ross b. Nontechnical Task j 3 Supervising b. Pay reclassification Force report 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.
- e. Implementation & recom-
- 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 l
t a
. -- - - =- - . - . .
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 i Technician, and recourses by Force report.
Welding Inspection ' welding inspectors ,
I
- c. Concerns (technical
& 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 l
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
- 38. R. Irby - i. Welding inspection
- 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-
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