ML20138L612

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Requests Call During Normal Hours to Discuss Const Practices at Facility.Recipient Name Deleted.Related Info Encl
ML20138L612
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/15/1983
From: Madsen G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
AFFILIATION NOT ASSIGNED
Shared Package
ML20138L611 List:
References
FOIA-85-59 NUDOCS 8512200002
Download: ML20138L612 (29)


Text

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                                -                        s As a result of a recent article in the Fort Worth Star-Telegram been attampting to contaot. you.

during our We would request that you call this office collect (817) 860-8100 normal work day hours of Monday-Friday, 7:15 a.m. to 4:00 p.m. and ask for ~ T. F. Westerman or me. Your cooperation in contacting us would be greatly appreciated. Sincerely, , r odstnet sise*d W G G 4..M M 8!e,n, Chief Reactor Project Branch 1 l I \ I l \ h C

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I MR. GRIFFIt;: I oay have to call you or 'te may - 2 nave to get one of tne inspectors to call you, wnoever . 3 adcresses some of tnese things that you have raised today. 4 he may have to asx you some more cuestions. 5 okay. on this statement we 6 sent in there about tne tort;uiny;omha.ee--rnn

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Enu.yer ttrar.- destyned%hemianger=:rnr.etn2Etrnativ::rwr.ong so ne , 8 could see where they had 'oeen checking while he designed 9 the nangers,'is there any way we can get him to show you 10 all these areas do you think? . II MR. GRIFFIri: What.is his name? 12 Well, I don't want to bring no 13 names up. He said he didn't want to go to no hearing, but

    -                           I4      he would lixe to taxe you all down and show you. He would I5      like to have a showing.                    He says he knows about them                                    -

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17 p_ g , , . .g .,,, t 18 and stuff like that. 19 MS. ELLIS: You can tell nim off the record. i "O

                                 '                        (hhereupon, a short recess was taken.)

al MR. HE.RR: Back on the record. 22 All right, do you want to talx l I ,think' yot1' adren %Qdat Mr. i 23 about the concrete? 24 mnn-- accumbuweNr15E""titL?mwetseeiecq= 25 ma t GE 7Gi(Ab.. _ ~ .mutsnitisz:;5tilfr s . TAYLOE ASSOCIATES

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         ;                                   JUDGE BLOCH:         Excuse me.           -
                    ,       5 M:                  Eirst of all, for me, the reasor.

6 that I've been interested in this for about the last six 7 years is because -- 8 JUDGE BLOCH: You ac ually may be more 9 comfortable sitting. 10 h I'm really nervous. 13 JUDGE BLOCH: You may relax if you sit a little 12 bit. 83 M Okay. Id . I have 6 children and being a 6

               -           35 l                always prompts me to do things for their future, and that i           16 is why after the last five years I've been involved, and 1

37 I've read and I've studied but Im not an expert. But I 18 l believe that I counterbalance a lot of the experts, and l' I believe that my cause is a fust cause, and I may no l 20 use professional terms. So pardon that. f 2' It's like a lot of things I have to say have i . 22 been said and will probably be said again, and that is 23 t why it amazes me, because it always is very repetitious, 2d e b'cause it is the same thing. People that care and 25 people that learn are going to say the same thing over

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l 1 and over again, and I've said it before, and I've sat here I 2 in f ront, of all these people before and I've said it, and

                                                                                                            ~

3 I've heard other people saying it. 4 I think we have to keep saying it- It is 5 really the only hope we have, and I'll say it some = ore. 6 All the same things, the construction faults. 7 I remember when the concrete pads were poured a and the papers were full of that. They were poured during . 9 freezing weather and they were never done right. All to the way frem fthat to the welds, to the crac4ed turbine, il everything, on and on and on. It does tend to make one 12 nervnus. { 9

                   ./       13            And I know a lot of them wil'. be fixed, or won't 4
           \                Id be fixed, but it is sich a compounding problem thatit.

15 is hard to believe that every little detail that we have h . 16 read about for years and years and years and years could 87 be fixed fine. I hope so. You know, I really do hope la so if it goes on line. 89 But it is such an amazingly dangerous thing to 70 try and contain anyway, radioactivity. 21 One of the byproducts of fission is plutonium, 22 and it's half life is 25,000 years. You know, that 23 is pretty astounding, to try, we as humans, to 2d contain something like that. 25 And the deadly waste -- I guess at this point, J 3

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                                 .,.-                                                                                                                                                     q 6107 the last I know of, is to be stored on-site, because there 2

is no other place to. store it. That means anywhere from

                                                  '3 20 to 40 to 60 to 80 miles from our homes, this will just build up and build up and build up on-site, and there is 3

no safe means of disposal, none. And I don't think 6

  • there ever will be.
                                                  '7 Go, we are going to have it in Texas now.                                                         At a

this point we are a nuclear-free state. Texas really is a growing state. Here we are. We are in the middle of 10 ' it. He - are the next New York City, or the next Olivetti,

                                             ,               and we are on the brink rightnow.                                               He are not nuclear.

j. 12

                                      $)                    We don't have to go nuclear.                                               I knoti that we've got 13
                              /-                            millions and millions of dollars in it, but right now j

b' Tie could stop. It is possible. Ne are not totally

                                                   '3
                         ,                                  made of money. .That is not everything, is money.                                                            We could stop right now.

You know, we could do like New England is d.cina j , is and try small hydro plants. We could do anything. We have the engineering, we have the brains. Do we want to j 2o go ahead with this?

                         --                        2t
                                                                            - All and all, I really feel like Comanche Peak
                         ';.                       22 is an environmental and financial white elephant.                                                           The
s. .

23 electrical usage is down now. It is not like it was 24 when we started building years ago. And we are either f going to have to operate it under peak capacity or we are s

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going to have excess generating capacity, both of which 2 is a waste. The cost of maintaining of such a mammoth, n 3 dangerous plant, let alone insurance costs, which is 4 questionable, decommissioning, which is a huge cost, and 5 storage of waste is so uneconomical in these days and 6 ~ times that I and many others, a lot more than are here, 7 really feel that this plant should not go on line. 8 And another thing that I think we have failed o to look at is in the long run, and that is what we have 10 to think of, is in the long run. It is not just for right is now. Maybe it will work for right now. But in the f 3' long run, that is our future. We' can ' t just. do the l g' k, 14 short run. And in the long run, it would be safer if 1 , Comanche Peak was not turned on. 15 I think if I was a shareholder, I wculd be 16 kind of nervous. But I'm not a chareholder. I'm just 17 a citizen. Maybe I don' t have the same interest as a 1 18 shareholder or as an official in Texas Utilities. But 19 I have a big interest. . And that is a 20

     -                           big interest.        I want to protect that, and I want to have 1                       21 a say in that.         And by not sitting up here and saying what
      ,                           I need to say, then I'm condoning that.

I 23 That's about all I have to say. 24 JUDGE BLOCII: Thank you, .

         .                                       I would just like to make a brief inquiry.

l M 4

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6109 I l I .) I hadn't heard about any concrete pours in frozen 2 weather. Is that something that happened? Is it something 3 to be concerned about? Does the Staff happen to know anything about that? - 3 A VOICE: Yes, it happened. . O JUDGE BLCCH: I'm sorry. We have no evidence 7 on it. I don't believe we have evidence on it. 8 A VOICE: It was in the newspapers when it 9 happened. 10 A VOICE: There are IE reports on that. The s .' NRC wrote up d violation report.

                        'I
              /                                JUDGE BLOCH:                    Is it in our records?

13 Thank you very much. W: Thank you.

         '              15 7

JUDGE BLOCH: W to 1 Is that M.r. or Mrs.? 17 - 1a

        ?

a I want to first of all express my appreciatic.- f to you for scheduling this meeting. I know that it is a very busy week for you with the licensing hearings 2 i going on, and what we are saying here tonight has 22

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                       ,3 relatively little weight in wheqher or not that Comanche
        ,1                    Peak Nuclear Power Plant is licensed.                             But I also want to 24 express my frustration at the limited nature of licensing hearings for nuclear power plants as a whole.
            .k 6133
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having.

  • Then think of our children and their children and their children's children. It is they who must live with the consequences of our destructive short-sightedness ,

we g must stop licensing of the nuclear power plant, ~ Comanche Peak. 6 (Applause.) 1 JUDGE BLOCH: Thank you. a

                           '#                                                              My name is M tU             ,,          W and I live in southeast Forth Worth.                                          We are K                           about 30 miles from the plant.                               And I, too, have two 12
                                     children, and I came here tonight with a little something prepared, but it has all been said before me, veryeloquently.(

b ' All of my concerns, everything that I feel as p I j - 16 a mother and as a member of the human race has been - 17 said, and I urge the Board to ,please deny the license

         ,a to operate Comanche Peak.
18 ,

S (Appfause.) W' j to JUDGE BLOCH: Thank you. 20 1 21 2 g , before you speak, I would like to list l 23 the following speakers so they can be available . I hope you don't mind. 2s 25 *

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                                 '                                   in that order.

I Please begin. I'f you do come up, please do it interrupt the speaker. 3 unostentatiously so that we don't

                                   '                                               Thank you.       My name l's 5        I am a resident of' this community,
                                            @ I'm a' Iso a member of Citizens for Fair Utility 0

I Regulation. 8 We were one of the criginal intervenors in

                                     '         chis proceeding. We had to drop out because of a lack 10                                          it is interesting to me that tonight of funds. However, this Board was 11 jdst for one brief, shining moment,                                                                l the concrete            l 12         able to see the NRC at work. When you ask about                                        '
                                     '3         that:had been poured during f reezing temperature',, and
   .y (

la I believe that was in 1974 -- I could be wrong about

                                     'S          the year -- however, when you requested an answer f rom
                                               the audience as to whether that had actually occurred, you The NRC did got an answer from a member of the public.

there was an la not respond. They did not when you asked if I&E report. But I think to me, having been in this process 20 as long as I have, since 1978 or '79 -- I can't even 21 remember gow -- this has been our biggest problem, 22 and this,is why, the citizens of this community are ,so not done its job. 23 frustrated, because the NRC has 24 I don' t f ault Texas Utilities nearly as much as I 25 fault the>NRC. But the evidence that will deny this 4 ) l l i 2 1

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                                    '    plant a license is in the NRC records.            It is there, 2    by their own hands,.by their own inspectors.,            It is 3    in the I&E reports.        And gentlemen, if you will       ,

study, and I don't envy you that job -- it is a massive D mound of paper, and the records must be enormous. I l 6 wouldn't even begin to guess how much paper work has been 7 generated by these hearings. - e But if you will study the records, you cannot

                                    '     issue this plant a license, not in good cosncious and
                                  'O     .not by the law       If you are going to follow the law - ..then
                             -    'I      the law has best. violated so many times, and the t!RC has b     12      allowed those violations to go by so many times, that 13      any member of good conscious will deny this plant a license.

i is You want specifics. I urge you to go back I6 to the original records of our group, along with Case and

                                                                       ~

2

                                   'I     Acorn, which was another group that had to drop out. Look f               18     at CEFER's first document, where we listed our
                                        contentions, and I ask you to read the contentions 70       that we wrote in our own hand before they were rewritten 21 i                       by Mr. Reynolds and the NRC.

22 The issue of the concrete is there; the date r i . 23 and the number, the I&E report number is in that document. 24 There are other specifics that I can give you,and I would 25 like to be able to -- by the way , I heard about this M y

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h Okay, here is one here. This 2 is kind of funny. My foreman, , when ne was 3 working on his tools like three or four years ago, he - 4 loaned a pipe fitter a crowbar and tne pi e7 fitter dropped 5 it down in a pipe in the reactor core. Nell, I tried for

                 /     6 two y' ears to get it out, and they always said well, we I

will have a pipe journeyman down there and you sho.< him 8 wnere it is at. I woulc get down tnere and well, we I -. are really busy today, and this went on for a couple of 10 years. II So I finally told them, and they sent me to 12 Westinghouse and Westingnouse said well, in ene end we are 13 going to send a little TV camera down in there and we are

      ~

34 going to look all around. So that solved that proolem. 15 i Okay, the stainless steel liner hollow places. l 16 We was making a pour -and I was down there maning sure I7 nobody stepped on the e= bed, and this is around the 18 reactor core and une floor and everything and tne 19 stainless steel liner. I had a na=mer in my belt and ! 20 just pulled it off and laid it up on tne bracing, the al stiffeners in there anc wnen it hit the wall it is real

                     .,o nellow in enere. So I tapped and they nad already poured 23 ene concrete above this area.

24 So I calledgand told him we have got a 25 problem, that we nave got a hollow place in the concrete TAYl.OE ASSOCIATES 1625 i sum. w.W. - sum too4

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                   .                                                                             G6 I    wall. Well, he crought I think N own tnere.

2 . hell, they send this colored ghy, down there, tne ia-3 general foreman over concrete and he sends the foreman down enere. Well, they tell me you stay with them until 5 you get the problem solved, or if I can help them in any 6 way to do it. I So tells this foreman, he says, now I 8 am going to go up Onere and we are going to vibrate this area for 45 minutes and tihey are still pouring and it is 10 still wet and you don't say what it is.'Just say either it 11 is there or it is not tnere. I2 So ne goes and boy they vibrate and chey I3 vibrate and they viorate. So he says how is it, and he . 14 says no, still there. So he says we are going to do it 45 I3 more minutes. So this goes on again, and of course your 16 ~ concrete, tney are getting higher up and it is getting l'* narder. 18 So he hollers down there again how is it, and 19 ne says no, it is still there. hell, he says we are going to do it for an nour. So Iney did it for an nour. He

                       *1 no11ered down and said how is it?              He said it is still U      cnere. So ne says well, it is enat olc Japanese metal, U

tnat is wnat it is, you know. So that solved that problem. 24 MR. EERR: 4

                                                        ~ hat year is this?

25 You can look at the concrete TAYl.OE ASSOCIATES 1625 i sTaur. s.w. - sum ico4 WASHINGTON. D.C. 20006 (2021 293 3950

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pour. This is in Unit 1 I think, tne liner, tne year wnen o they mace ene next pour from the floor up I think it was.  ! 3 tou know, you made it up to a floor and you would let it  ! cure and then you made your next pour and then a next. U MS. ELLIS: This was Uni't 1 'a round the reactor? 6 . I think it was Unit 1. I have 7 got une area here marxed out where it was at. I 8 (Pa:I s .it.il s looks througn his 9 papers.)

               /

Ab 10 6 hell, it was right over here 11 on the wall any ay. I guess it is proba:ly six foot off l 1 12 tne floor. You can mark it right in this area nere. Put ' 13 Unit 1. I am pretty sure it was Unit 1. You have got the I4

    /* 3                  elevation.            Well, I have got it marked.right here.

1*~ See, you nave got the little round end down i 6 e n e r e ,. That is at a certain elevatio'n. Then this is your core area where your reactor sits down mere. Then your 8 next drop down wnere lixe your lower internals go in here. 19 It is in that area, rignt up there on tne wall. But you

0 can take a baraer and tap on the wall until you find a ,

1 al nellow place. I ar. pretty sure that is the one it es . I MR. HERA: The elevation? ' 3 It is 634 and add 6 to that,  ! 24 642. Let's just go with 642 for the necx of it. 25 1 uns standing.up on the bracing and I coulo 1

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  • 1 reaon it. So wnen you are standing on une floor it should a

2 oe from the snoulder up, somewheres along that area. Bu 3 it is real nollow and you can find it. 6 Exhibit @ ollows:) 5

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                                                                                                                            /.r.-il 10. J C7'y 0545 hrs

Subject:

Interview With 6 0 ;, 4 Stig* 4 Place & Time:

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jose's Restuarant-Cranbury. Texas Mi ' i 3 835 hrs to 2000 hrs. ' '-- 1- ..r April 9.1979

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W.A.Crossman R .C. Stewart R.C. Taylor f i Cb} Preliminary statement By Interviewee. , L_ _ 3

1. The reporter from the Star-Telegram had visited him In Nashville, Term. and has called several times since on specific points,. The reporter prwnised not to use his name in print in any article growing out of the interviews. The interviewee stated that he has been -- ---' with 11 rm by unidentified ,

fArenfert persons. 2.The interviewee stated that he had r the R.W. Hunt I.ab. at CPSES

Summary of Allegations; l 1. The interviewee stated that equipment used to perform s. odium sulfate test I

i of aggregate was unused for several months but stated he had seen_ equip, ment f used. He remembered the bad oder made by the test. He stated the he asked i the ** chemist" about not running the test and was told that he , the chemist, ! didn't often run the test because the results always came out the same. The l Interviewee stated that the records would make it appear that the test had been performed when it had not. Chemist was identified as P. 7"as are ree.a resa sii un z.sce o ruc Ccu rw ew 1' :o nar t : c.tu a Ogygrw NC e C- TM C ' C" O d * /

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2.In regard to a placement of concrete in the' Circulating Water Imake Structure. the intervieweee stated that he and others had rejected concrete trucks for ~' being over specification limit on time to discharge. m C the then and present B & R concrete superintendent) ordered his people to dump (he concrete on the ground and shovel it into the formwork.. which was done. Interviewee was aware the structure was not safety reisted. t Tant -

3. The !!unt 1.ab cylinder curirg evn was poorly run in late 1976 through early'1977, primarily duelo poor mainfenance. The cy,linders were allowed to dry out.
                              /.. A building area near the unit two containment structure was initiauy installed upside down due to the inability of the craft personnel to read the blueprints.

lie stated that il$cre was a " master carpenter" hired h_ did not know which

                                                                                                           ~

end of a hammer to use.

5. The unit one basemat was placed so fast that all of the required concrete f

test were not performed. . (5% ee d f.) ) i Additional Information Not Obtained From the Interviewee:

1. The on file records Indicated the No cause for termination is stated in records examined. . )
2. The unit I containment basement was placed on Feb. 21.1976 and did consist of aprroximately 6,600 yrd 3 of concrete.

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35 i . I wor < on site. Sow that is what we are interested in 2 finding out. 3 Obviously after you went to Houston you nad a 4 lot _cf difficulty with these people out there and they 5 gave you a hard time as you have already discussed. 6 I just went into confinement. 7 It eren't a hard time. As a matter of fact, I enjoyed it. 8 I was drawing tne same money.', 9 MR. GRIFFIN: But wnat we are trying to find i 10 out is who intimidated you orLochers out there that caused 11 them to perform improperly. 12 he was pushed to a point where 13 we was not doing it correctly. They always wanted to do a

      .-         14   certain amount that is impossible to do, and they don't 15   care how you do it, but they want it done.

16 MR. HERR: Who is they? 17 and I adt sure 18 is the one th~at pushes k Just like QC, and I 19 can give you a real good example. 20 When I was first hired in there in 1974 or 21 .19 75 lie 7, . ara- nugnome-Q vork or. so.se-~snear ^ollP iha' 9 oes# We was using rebar 22 ar44ud-rs~~ vat +I4:2*n). It was '75. 23 and we was welding flat bar to,, it. Well, when the rebar 24 come in, and it is Q or.QC, and tney yomwr-N and they 25 c.SiE6k=it%nowney-werTt97TCt.Wnuabet=esoh sid-s

                                                                                                  ~

TAYLOE ASSOCIATES 1625 t STREET. H.W. - SulTI 1004 l l WASHINGTON, D.C. 20006

               .                                             (202) 293 3950 e

( ( I stuff. Well, when they' get all tne proper paperwork in and 2 get it documented, unen they release it to us. How do we 3 know it is released? They.go out and they paid a blue end 4 on it. 5 Well, we run out of recar and here come a 6 true; load of rebar. It cameewe=stertedmutrang Ap 7 and we s tar.: iaw e i a it. So nere come QC. OC and M 8 continuously had fights because didn't want to go 9 by their book and they was always bumping heads on it. 10 Here come the QC. He just walks in there and 11 he puts red tags on all the stuff tnat is not right. Tjell, 12 jumps in there and he just got on butt. So 13 he called . So here come 14 down there, which is a little guy and this QC kid is real

      ~

13 big. So-they started naving it out, and ne told this QC 16 man, he said you ain't nothing' out a goddamn evergrown 17 punk witn too muen responsibility, and ne said I ought to 18 just knock your godda'n m brains out and he draws back on 19 nim and he pushed nim arounli for 30 minutes cussing him 20 because the guy was just doing his work and he was the 21 superintendent. Now that is typical. 22 MR. GRIFFIN: Did the QC inspector pull those

               )   23           tags?            .

24

                .f                                                                                   He had his people hurry up 23           wighm may :nac~moano--tm&1esL,.t_ .e t a es of f .
  -                                                                                    TAYLOE ASSOCIATES 1625 i STREET. H.W. - $UITI 1004 WASHINGTCH, D.C.              20006-(202) 293 3950                                             ,

l

        -                       -       .,         , , - , . , , . ~ , _ , . . , , _                  ~ . _ . . . _ _ , , . , _ _ . . . . _ . . .          _ . - , , . . ..

b i ( - - 27 s.

           . '         I   howey.ermau.uiu-not- sttipNorting%ncahwt-i-nueho wor n                                                l J
                         '     _?

2 on 10. 3 MR. GRIFFIN: So tne QC inspector signed off on

- 5 tnose, on tne work? j 5 Yes, eventually he signed it 1

6 off. l

             \         7                 MR. HERR:        That is after he finished nis                                          !

i

              !        8   inspection?       He hurried up his inspection.

j 9  : Well, he was getting his ass 1 f10 eat out. He had a whole bunch of people there painting the 11 ends of it. I don.t know where he got them. We didn't even f l 12 stop. We just xept on working. He wWiir ,=yy - --- - - - - - -- = l 1 13 set %FDPd-Ur'l'_*5*" E fS<-P'r^ ;>c em - ' - ; m e-- - -;Qa t 5 14 $hmoetai je:- d" . 15 MR. GRIFFIN: What about this work you were 16 talking about like the condenser box a while ago? Weren't 17 there QC people around to inspect your work on that? I l 18  : That is non-Q on this job, but l f19 on other jobs it is Q like South Texas. 20 MR. GRIFFIN: Who was the QC inspector back in

                     ~21   '75?

23 MR. GRIFFIN: Is he still out there? 24  : No. J 25 MS. ELLIS: You don't have any idea where he is TAYLOE ASSOCIATES 1625 I STREET. N.W. - $UITI 1004 WASHINGTON D.C. 20006 (202) 293 2950

                    ;e
   , ~. . .o .                               .

a l '. ,  %

  • 1 now? ,

2 No. Another good, example was 3 setting.tne condensers. The BOP inspector come dcwn and 4 caecxed the welds on it. he rejected all the welcs. We had 5 a rig hooked up. He even rejected the factor welds. M , 6 h ae said have you got a condenser in that hole 7 yet? I go no, I.saic it don't look like we are going to do 8 it eitner because a BOP inspector just turned down all the 9 welds. Eoy he started cussing. He said I want that son of

 -                             10       a biten's name and badge num'oer.

11 So he started making calls. So I dropped back 12 to the guy and he just bought it off sitting in his 13 office. Well, as a matter of fact, it got to a point where

        -                      14       they wouldn't even come and look at none of the welds.

15 They would just buy them off. 16 MR. GRIFFIN: Who is this guy again that bought 17 it off? 18 I don't know his name. He is 19 still out there. M I tnink it the last name. 20 MR. GRIFFIN: M 21 6 Yes. He got run off of BOP and 22 I think he ended up in OC. I think he name was @ 23 MR. liERR: What year was that? 24 T is was probably ' 79 or 'oO 25 wnen we was setting Unit 2 condensers. Condenser Fi was TAYLOE ASSOCIATES 1625 I STREET, N.W. - SUITE 1004 WASHINGTON, D.C. 20006-

                                                                               - (20,2).293 3950        _  _
     *- t f                                                 35
  • I work on sito.
  • Now that is what ,,,

2

                                          .                                             wa are interested'in                    -

finding.out., , 3 Q C. fm 4

                                                   'Obviously
                                                         .-.          after you went to Houston you had a lot of diffi culty with these people out                              -
                                                                                                                      . 4, 5                                                                       tnere and they 6

gave you a hard time as you have already discussed .

                                                  *4m ^-              wn* :

7 It weren't I just went into confinement. a hard time. As a matter of fact, I enjoyed it.

                         '8 I was drawing the same money.

9 MR. GRIFFIN: But wnat we are trying to find ' 10 out

                                                                                                                                               ~

is who inticidated you or others out th 11 ere that caused

                      . ,,   -n   them to perform improperly.

12 * ~ ..m. was pushec. . i 13 to a point where g we -was not doing it correctly. 14 They always wanted to'do a , certain amount that

                               -                                                              ::m.                        I is impossible            to do, and they don't 15                                                  nw care how you do it, but they want it done..*

16 MR. HERP.: Who is they? 5 17 I 18 e =- -Xs the one and I am sure- %l2llllEil IGD

m. tnat pushe 19 Just lire OC,'an'c I d can give you a real good example.

2V ( 21 When I was first hired in there in 1974or 22 1375 de was coing some Q work on some shear bar s that goes around your containment. It was '75 We was using recar

          . 23 and we was welding f v    t bar to it.

24 Well, when the rebar i come in, and it is Q or QC, 25 and they go out there and they cneck it,and they verify ene heat number and all tnis l~ TAYLOE ASSOCIATES 1623 I $Ta117. H.W. - sutTE 1004 q l

                                                     '          WA$hfNGTO**. 0.C. 20006                           }                  .

(2c2 293-3950 j

                                                                             ^

s II' I -

                                                                       -                         --      -~.

J4 J { $hdo h 8 36 1 stuff. Kell, when they get all the proper paperwork in and 2 get it cocumented, tnen they release it to us. how do we 3 xnow it is released? They go out and they paid a blue end 4 on it. 4 5 Well, we run out of recar and here come a  ! 6 truckload of rebar. It came in. He started cutting it up 7 _and we starting using it. So nere come QC. QC an a continuously had fights because idn't want to go 9 by the:.r ocor, ano they was always cusping heads en it. , 10 liere come the QC. He just walks in there and 11 ne puts red tags on all the stuff tnat is not rignt. Kell, 12 jumps in enere and he just got on butt. So 13 he cal' led so here come 14 down there, which is a little guy and this QC kid is real 15 big. So they started naving it out, and ne told this QC 16 man, he said you ain't nothing out a goddamn overgrown 17 puna witn too mucn responsibility, and ne said I ought to 18 Just knock your goddamn brains out and he draws back on 19 nim and he pushe6 nim around for 30 minutes cussing him 20 because the guy was just doing his work and he was the 21 superintendent. t.ow tnat is typical.

        "2
         .                          MR. GRIFFIN:            Did the QC inspector pull those 23        tags?

l 24 n w e d iie had his people hurry up 25 witn what they nad to do and tney pelled tne tags off. i 3 TAYLOE ASSOCIATES 1

 /                            ,                   1625 i STREET. N.W. - SulTE 1004 WASHINGTON, D.C. 20006                                  g (202: 293 3950             ,                         j
                                                               'b                      0
         -I',          howaver, wa did/npt.stop working and we continued to work 2      on it'.
  • f 3 MR. GRIFFIS: So tne QC inspector signed off on 4 tnose, on tne work?

5 6: Yes, eventually he signed it

              -6       off.
  • 7 MR. HERR: That is after he finished his 8 ins.oection? He hurried u.o his ins.oectio n .

9 Well, ne was getting his ass  ; i 10 eat out. He had a whole bunch of people there painting the . 1 11 ends of it. I don't know where he got them. We didn't even 12 stop. We just Kept on working. We was supposed to have 13 stopped until they made sure we was using tne right heat 14 number and all that stuff. h 15 MR. GRIFFIN: What about this w'ork you were

          ;    16      talxing about like the condenser box a while ago?                 Weren't 17      there QC pecple around to inspect your work og that?

18 7at is ncn-Q on this jco, but  ! 19 on otner jams it is Q like South Texas. 20 MR. GRIFFIN: Who was the QC inspector back in 21 '75? 1 23 MR. GRIFFIN: Is he still out there? 24 . . 25 ci3 . ELLIS;.You con't have any icea wnere he is TAYLCE ASSOCIATES  ! 1623 i ST2!!T. M.W. == SUITE 1004

  • WASHtHGTCM 04. 20006 e t

202. 153 3950 l  ! i I

     ,        ./r      s                    ..

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       ..]3 took place, unis btittering?                                                  h                                          f Tnat is on one of the elbows I 3

chink. MR. HERR: The eloows of reactor one? 4 , Reactor one. Reactor two was still 5 i bits and pieces when I was there. j 6 MR. HERR: On how many elbows? We have a lot of f

                                                                                                                                                     \

t elbows.  ! 8  : I realize that. You are going to 9 l 10 nave to talk to the welder on that. MR. GRIFFIN: Do you know who the welder was? g \ I don't know his name, no. You need to start.with Juanita Ellis. -

                                                                            *:    lf' we could identify which elbow 4                              or which welder and he cocid identify which elbow then we Q-                 la.                   .

could go look at tnis, not.us, but somebody else could. g

                                      .          MR. HERR:                   Do you think Juanita Ellis would
                           ' nave his name?

18 She could get ahold of an they could eventually come up witn it. 20 Tnere was anonner guy that toic me that ne witnessed when Brown and Root overexcavated underneath the g No. 1 containment. Did you hear about that? They dug the hole too deep. It was supposed to go down to a certain elevation before they poured the first concrete mat. They

                     ,o_
                                                                                                                               ~

TAYLOE ASSOCIAT55 1625 i STREIT, N.W. - SUITI 1004 f WASHINGTON, D.C. 20004 (202; 293 3950 l i

                                   -                    . . _ _ . _   .m_                                s .           s 9 't *9 2*f $h_ "t_9
                  , ,f 4~
      .         -'-                    mada it too deep.                               'Oh, my gosh, it is too de'ep, you know.

3 xm

                              ,        So they Just tnrew the rocks cacx in tne hele and poured e nerete over it.                                  So there is no telling what is under                          ,

3 4 tnat. You know, there coulo be a Carlsbad Cavern under 5 that thing. 6 MR. GRIFFIN: Don't they do seismic studies

                              -        before they pour concrete?

I e re you say? 8 9 8 MR. GAIFFIX: Yes. ell, not if Eney know they are g3 going to flunx unem they are not going to do any seismic

                                                                                     . ..s o gg studies.

3 MR. GRIFFIN: I mean before they select the y site for a nui:: lear plant don't they do seismic studies? 15 But this.was a Carlscad Cavern of 16 tneir own canufacture. You don't understand. You are , g supposed to pour this on top of bedrocx, but they dug down t deep in the bed ock. 18 b - MR. GRIFFIN: Do you xnow how f ar too deep? g Six or eight feet I think. They g just threw ne crap back in the hole and crougnt it up to ene rignt elevation and then they poured the concrete on 3 top of it. That is no guarantee that the concrete is going 3 g to go all tne way to tne bottom. _a MR. GRIFFIN: I see. TAYLOE ASSOCATES

 .                                                                                              1625 i STREET, N.W. - SUITE 1004 WA$H!NGTON D.C.      20306 (2021 273-3950 i

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SU3 JECT: CONTACT WITH ALLEGE;. - C:'5ES * ( ,lg, . y g 9

                                 -On April S.1979. R. C. Stewart and R.- E. Hall met wi:                                               . W m in a restaurant in Arlington,                                       was a qu:.:c f :urce in the rtic:5                igarding concrete                                                -

testing inadequacies at .the CPSES construction site. 6 was an employee of R. W. Hunt, the concrete > He was disris#ed ty R. W. Hunt for alleged falsification of records; however, he conter.ds - at his dismissal was due tc his attempt to pressure R. W. Hunt inte a pt increase. -

     .                           Allegations:                                                                        .,.
1. He substantiated the FWS-T artig allegati n at fc'r the first 3-4 weeks of his employment, while he was we'rking the second shift under M M' supervision, he was encouraged to " dry lab" the gradation

( tests to eliminate the time consuming oven drying process. He indicated et that this had also been the practice of M M, his predghsor on this testing. After 3-4 weeks, h h was replaced as foreman by mm who insisted that the test be performed properly. This change occurred in about mid-February 1976 according to M t W indicated that it would not be apparent frc= records review which tests Were perfor nd which were* dry labbed." These tests were aggregate tests of gradation performed on sample accumulated

during the day shift and tested on the second shift. The# samples included supplier source, production run and stockpile source and aggrega te.

Q _K, p C /YV > 1 e .

       ., o       .

V l

    .-                                                                                         .                                                        1
2. Fr: Mi :1 t.d 'ror v.( !. :. :t/'s personal observation (date ur.kr.o r,, m indicatec : et cylinders were'being broken with the test ma: hine brake (1ca: rate limiter) bypassed. If break '

l stengths were observed, the were recorded, if not, in tolerance l entries were made. If brc;.c cylinders yielded low strength , I results, rather than atter- to locate spare cylinders, the technician l

  • 1 would enter an in-tolerance value. This practice reportedly was j l l

common from about April 197c, until early 1977 at which time M '

                                                                                                                                                        )

g and M 6 were assigned to break cy.linders. M felt they did a con'scientious jo: . h Overall morale of the R. W. Eunt QC technicians was reported to be very poor due to pay inhuities. 6 felt at this resulted .

          --                      in lack of interest and slovenly work by. the co-workers.
4. When he first reported to work he did not possess the education and experience for his job' as defined by R. W. Hunt procedures. This L has already been an NRC citation and has been resolved (per Stewart). '
5. From hearsay the reported acceptance of 4-1/4" slump concrete (vs. a 4" allowable) was done 4

l at the insistence of a foreman 6 to M. m was

  • not directly invol,ved.

A In.the summer of 1976, during an all night placement of a slab in the north part of the Auxiliary Building (estimated 3400 cu. yd. pour), R. W. Hunt technicians (M was included) stopped the placement due to out of tolerance slump and air. Tr.e concrete was referred to by 6 as " soup." m indicated that someone named W { presumably G&H engineer, 6' cc.:;r.tersigned the Hunt

     .       - .           . .        - . . .        . -      - _ .    . _ . - _ . - - .         . _ _ - _ . -               -                   ~-
  ;     J,         ,.                                                                                            .~-
                                                  - - - + -   - - -          -   ~ ~ -                     -
                                                                       ~                        -

rejections and authorized completion of the placement. He indicated that 6 was another Hunt QC inspector on the placement.

7. He had hearsay of a void in the first lift of the containment.

Stewart was aware of the event .ind its proper disposition.

8. . 6 was very critical of his supervisor.W. He classed him as a poor supervisor and was obviously upset because W had fired him.
- 9. ,q@ was referred to by W as a good, conscientious inspector who "got fed up" with Hunt practices and quit.
    '.            10.
                            @ also reported, but without details..                           W was not ,

r g perfonning' Cadweld production test samples as required; but was i. gTY s' imply reporting data. He thought this involved a timeframe from L'- early spring 1976 till .mid-sumer 1976. After that time, others were trained for this testing $nd he wasn't aware of further problems. 'b - o l' l l l l , l i i I (

                                                                                                             . - _ -      u

A ' .e. 4

     .+

APPENDIX U. S. NUCLEAR REGULATORY C0FWISSION REGION IV NRC Inspection Report: 50-445/83-27 Docket: 50-445 Construction Permit: CPPR-126 Licensee: Texas Utilities Generating Company (TUGCO) 2001 Bryan Tower Dallas, Texas 75201 Facility Name: Comanche Peak, Unit 1

          ' Inspection At:         Comanche Peak, Unit 1, Glen Rose, Texas
          -Inspection Conducted:            y 10-Jul    1, and September 9-22, 1983 Inspector:

l (A. n

                                                 ~
w. )

I E~E8*85 R'. C . Stewa N or'Insp h or Date Reactor Project Section A f l / Approved: /// M Ib ' O. M. Hunnicutt, Chief Date Reactor Project Section A DN " W S] CSD N '7@-

               -- 7-- T ,/ (A ra iv9gi. /A 7 /',7

2 Insoection Summary } Inspection Conducted'May 10-July 1, and September 9-22, 1983

                                          ~

(Peport 50-445/83-27) AreasiInspected: Special, unannounced inspection of alleged improper construc-tion 'oractices expressed by Robert L. Messerly'in an affidavit dated. February 3, 1%1836 prepared for Citizens' Association for Sound Energy (CASE) and in an  :

             . interview conducted on April 14, 1983, by members of the NRC Office of
              ' investigations Field Office, Region IV. The inspection involved 120 inspector-hours onsite by one NRC inspector.-

Additional information was received from an individual, who requested confidentiality, that a former B&R millwright had drilled holes through rebar without the required engineering approvals. This supplemental inspection

               . involved 10 inspector-hours onsite by one NRC inspector.

Results: Of-the seven allegations regarding improper construction practices expressed by Mr. Messerly, five were found to be unsubstantiated. One

             ' allegation regarding improper documentation was found to be substantiated, however, the error was properly corrected by the licensee and appears to lack technical merit; and one- allegation regarding the posting of NRC Form 3, could neither be refuted nor substantiated, however, it too appears to lack technical merit. No violations or deviations were identified.

Results of Supolemental Inspection The allegation that unauthorized cutting of rebar during installation of

                " trolley tracks" in the fuel handling building is considered to be unsubstantiated. No violations or deviations were identified.

.c s 3

                                                         .0etails                                           ,

l '. A. Persons Contacted Texas Utilities Services Incorporated (TUSI) Employees

                 'B. G. Scott, Quality Engineering Supervisor G. Tanley,_ General Superintendent C. R. Hooton, Lead Civil Engineer R. M.'Kissinger, Project Civil Engineer C. Fleming, Field Engineer Brown & Root (B&R) Employees _

W. Wright, Project Welding Engineer B. Hauser, Field Engineering Superintendent C. Osborn, Tool Crib Foreman The NRC inspector also contacted other licensee and contractor employees duri,ny the course of the inspection.. Note: ' Prior to this inspection, separate _and independent investigative interviews were conducted by members of the Office of Investigation dated Field May 20, 1983). Office, Region IV-(see attached Report A4-83-005, B. Alleoed Imoroper Construction Practices R. L. Messerly's The NRC inspector, through an interpretative review of Mr. affidavit, dated February 3,1983, and his statements during his interview, April 14, 1983, determined that.there were seven specifically alleged matters that required a detailed inspection effort to assess their technical merit and/or their potential impact on safety-related systems, component, and structures.

                      .The seven areas of NRC concern which Mr. Messerly' alleged to have occurred are summarized as follows:
1. That'B&R employees drilled undocumented and unauthorized holes that cut through reinforcing steel and that such drilling and Mr. Messerly cutting provided was a copy done at'the direction of supervisors.
A (. ,3() of a personal diary which, he alleged,' reflected undocumented and hw" I unauthorized drilling.

2. That one of the main steam lines in Unit 1 was moved using the polar crane, thereby placing the section of pipe line in an unsafe stressed condition.

3. That he had cut through concrete reinforcing steel as directed by work inst' ructions that were rpt in accordance with the approved method of documentation, i,

[ - 9 e

               <~

l

                                                                                                              .-r,' D 4

4; That. tubular hanger / support steel anchor bolt holes were enlarged * '

                                    ~with a burning torch which he said was unauthorized.
                  ,~-)5.            ;Thatl(Richmond) anchor bolts were not perpendicular to concrete surface and, therefore, unacceptable.

2 f- '

                           . 6.      .That. stainless steel pipe attachments were welded on piping with'out an inerting purge.
                            '7.        That NRC Form 3, " Notice to Em,ployees" was not posted on three main bulletin boards, Inspection Findings-hL .               cC.

Allegation l'

                             '1.        Discussion iMr..Messerly stated that during his assignment as foreman over the
                                      ' first _ crewr responsible for drilling through concrete and reinforcing d                steel-(rebar) during installation of cable tray and pipe hanger supports, he was ordered by his supervisorr to loan out drill bits
             )\b-E(L ((I ~ and/or drill undocumented and unauthorized holes through rebar.

To further support his allegation, Mr. Messerlyj named B&R employees ' responsible for the alleged improprieties and those who could

  • substantiate his allegations.1/-

In addition, lir. Messer],f provided .the NRC staff a ' copy of his personal daily diary 'in which he logged drilling of holes for electric cable trays / hanger supports and rebar cutting details. He stated that this diary also identified he'.es he drilled, in or through, rebar and concrete without hav<,g documentation and author- ' ization.

2. Chronological' Findings 1978-1982 In order'to determine the magnitude of implication and the resulting findings of,'Mr. Messerly's; allegations.

1/ -See attached " Assistance to Inspection Report," Report A4-83-005, dated

                               ' May 20, 1983 e                  %-"#+--        e.  +,.e--4 e. g , . -,g- ,'y, e  e y   <,e-,,, ,e

I 6 inspector during his review of randomly selected " Core Drilling Request Forms" (1978 through 1982). Construction records indicate that electrical cable tray, conduit hangers, and pipe hanger support installations were initially started in late 1978. This coincides with the formation of the steel fabrica-tion department pipe hanger crew (s), special drilling crew (headed up by Mr. Messerly), and the requisition of the water cooled diamond core drills and motors by the steel fabrication department (of which LMr. Messerly.was a member) on September 6,1978. A record search i~ndicated a Design Change / Design Deviation Authorization 2470, dated September 5,1978, authorizing rebar cutting for Cable Tray Support No. 597. This was an initial rebar cut made on September 9, 1978, and identified by Mr. Messerly in his personal handwritten diary (see paragraph 6). The primary anchor and fasteners utilized at CPSES for the attachment of cable tray supports, conduit supports, pipe hanger supports, etc., to concrete surf aces are the "Hilti" drilled-in concrete expansion anchor and " Richmond" screw anchor. The Richmond screw anchor is positioned prior to concrete placement, whereas the Hilti requires concrete drilling and placerent at the time of component installation (a licensee representative stated, that based on purchase orders, over. one million Hilti bolts 1/2" to 1-1/4" in diameter, have been ()- installed to date).- Drilled-in expansion bolts are bolts having g(L7 . expansion wedges so arranged that, when placed in a drilled hole and the nut tightened, the wedges are expanded and the bolt is securely anchored. The most predominant means of drilling holes into concrete for expansion bolts is the use of Hilti power drills, using Hilti carbide masonry bits of the' same nominal size as the bolt. This form of drilling does not have the capability to drill through rebar. In limited access areas where the Hilti power drills cannot be used, a flexible Drillco drive drill with drill press / vacuum base and Drillco water cooled carbide / diamond bits are used. This form of drilling has the capability of drilling through rebar and was restricted to the steel, fabrication department special drilling crew (headed by

Mr. Messerly;from September 1978 through October 1979).

For these two methods of drilling, no authorization is required for Hilti bolt installations (other than an approved hanger support installation " traveler" with its accompanying location drawings). A

                              ' design change authorization is only required if relocation is beyond the drawing tolerance limits, or'if rebar is encountered and requires cutting. Construction quality programs of this nature rely heavily on each individuals personnal integrity to adhere to prescribed procedure requirements.
                         ~                                    se

n n

      *:e~.
         ~

15 an installed tubular hanger hole having been enlarged by a cutting {; torch. Based on the' lack of specificity by'Mr. Messerly', the lack of-corroborative testimony by ,Messerlys! witnesses, interviews by the NRC inspector with. cognizant. site personnel, and the (limited)

                                 . examinations of' installed hangers, this allegation could not be substantiated.
                           'There were-no violations or deviations identified in this area of the
                            -inspection.
                           ; Allegation 5
                           ~ 1. Discussion During the interview on-April 14, 1983,~Mr. MesserlyJstated that Richmond Insert anchor bolts installed between elevations 905' and 860' in the reactor containment building have.not been installed perpendicular to the concrete-surfaces and, therefore, are unaccept-
             -           1          able. In addition, Mr. Messerlyl stated, ".    . . whatever angle it is.
                                  -we would drill it at that angle so_that it would come through.the
                                   . tube (i.e. , tubular steel) and when it comes out the .other side of the tube, it comes out as close to center as we could get it."

Mr.'Messerly also stated, "Just go out there and pull any . . .

                                  ' studded rod out of .there, pull three of them and two of them is'[ sic]

crooked." ,

2. -Conclusion - Allegation 5
                                   . During the NRC inspector's onsite follow up of this matter, tne inspector found that the B&R Procedure CP-CPM 9.10. " Fabrication of ASME-Related Component Supports," (original-issue 12/28/78) is the primary construction installation precedure to be implemented and followed by the hanger installation crews. The " General Fabrication
                                                       ~

and Installation Requirements," Section 3.3.1.2 " Installation Tolerances," states in part,

                                           " Field Fit Tolerances                                   .
                                           "The tolerances discussed above shall be maintained for support fabrication activities. However, if during the installation, the support won't fit, the members may be " field fit" provided               I
                                          .the piping and elevation tolerances shown below have been-maintained. ~All-other tolerances regarding axial location,                   I alignment, and base plate attachments must be adhered to unless otherwise noted on the drawing."                                             l l

1 1 l

v- . 16 L In' addition, Section 3.3.2, states in part, i r

                                 ". . . Surfaces of bolted parts in contact with the bolt or not             !
                                .shall .have' a slope of no more than 1:20 with respect to a plane Where'the surface of a high strength normal to the bolt axis.

bolted part has a slope or. more than 1:20, a beveled washer shall be used to compensate' for the lack of parallelism." During discussions with the cognizant design engineers concerning the specific installation requirements relative to .the limiting perpen-

dicular Langle of the anchor bo'lts' (Richmond Inserts), the NRC inspector was informed that the limiting perpendicular angle of fanchof bolts-(Richmond-Inserts) to the concrete surface is, aside from the requirements of Section 3.3.2, is handled on a case-by-case basis. No enlargement of the existing predrilled holes in the TU tubular steel is permitted without prior approval; however, numerous CMC's have been issued wherein offset holes have been authorized.

1 The' approval is generally _ accompanied by the requirement that the large square bolt washer.be welded in place using a 1/4" fillet on 2 sides. The cognizant engineer further stated that the requirement above only applies to safety-related supports (ASME III, subsection Enlargement of'the

  • NF, Classes 1, 2,=and 3 component supports).

predrilled holes -in the tubular steel for nonsafety' supports is

                      . permitted without prior engineering approval.

SincelMr. Messerly!specifically referred to the 860' and 905' elevations in the reactor containment building in his testimony, it was assumed by- the NRC inspector that his specific concern was in - reference to the permitted angularity of the safety-related Richmond Mr. Messerly*was apparently of the opinion that

                        -Insert anchor bolts.        ~

the anchor bolt should be precisely perpendicular to the concrete surface, which appears to be a misunderstanding on his part-of the-installation specif.ication. Furthermore,'Mr. Messerly's' testimony reflected his awareness and knowledge of the procedural. requirements,

                                                                                ~

therefore, it must be assumed thatfMr. Messerly did not ignore procedural requirements and did not~ indiscriminately enlarge pre-Further,. drilled tubular' steel holes in safety-related supports. that any offset or enlargement done by Mr. Messerly -had prior engineer-ing approval as required. As noted in-Allegation 4, paragraph 2, the NRC inspector conducted a limited visual examination of approximately 60 hanger supports at the 905' and.860' elevations in the containment building. During the examination, the NRC inspector found no hole o enlargements or anchor bolt angles (parallelism of bolt nut surface to washer surface) that appeared to violate the above installation speci.fications. It is concluded by the NRC inspector that this ,

                          ; specific allegation appears to be more of a design concern by

[Mr. Messerly; than an improper installation construction practice having been impl,emented by him.

. . - f. . APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV Report: 50-445/83-03 50-446/83-01

           ~' Dockets: 50-445; 50-446                                         Category: A2 Licensee: ' Texas Utilities Generating Company (TUGCO) 2001 Bryan Tower Dallas', Texas 75201 Facility Name: Comanche Peak, Units 1 an'd 2 Inspection At: Comanche Peak Steam Electric Station (CPSES), Glen Rose, Texas Inspection Conducted: October 1982 through February'1983                                    ,

Inspectar: / /6 3

                         'R. G. Taylor, Senior Resident Inspector-                          Date Construction Approven                                  -
                                                                                                /6 ! M
                          'T. FY W(sterman, Chief '                                        Date Reactor Project Section A Inspection Summary.

Insoection Conducted October 1982 Through February 1983 (Recort 50-445/83-03: 50-446/83-01) Areas Insoected: Routine and special inspection, announced by the Senior Resident Inspector-Construction (SRIC) including facility tours, investigation of allegations, participation and assistance to the Construction- Assessment Team Inspection, and other inspection related activities. The inspection involved 263 inspector-hours by one NRC inspector. Results: Within the areas inspected, one violation was identified (failure to implement a QA program for fabrication and installation of underwater lighting

           -poles.)

C57 D cqut_13 PP- ,' 43@f/d@y(5-

2 Details

1. Persons Contacted Principal Licensee Personnel
                   -R. G.LTolson, Site Quality Assurance Supervisor D. N. Chapman, Quality Assurance Manager B. R. Clements, Vice-President, Nuclear J. T. Merritt, Manager of Startup J. B. George, Vice President and Project General Manager Other Personnei G. R. Purdy, Project Quality Assurance Manager, Brown &~ Root (B&R)

D. Frankum Construction Project Manager, B&R The SRIC also interviewed other licensee and contractor personnel during the inspection period.

2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-445/79-24) Quality of Unit 1 Reactor Building Dome Concrete. This item related to the need for additional assurance that a small amount of concrete placed on the Unit 1 reactor building dome during a . rain storm without appropriate controls by quality control was adequate. An earlier evaluation of the in situ concrete'by a proprietary testing program had indicated that the material was acceptable. The testing program was found'to be unauditable and therefore, some additional
                  . assurance was judged to be required. The licensee has now completed the structural acceptance test of the Unit 1 reactor building with special attention directed to the repair area. The test was successful and no anomolies were identified in the repair area and therefore, it is judged that the concrete is of adequate quality.

(Closed) Unresolved Item (50-445/80-20; 50-446/80-20) Design of the AC

                  ' Instrument Distribution Panels. This item involved a finding that the segregation of safety and nonsafety wiring in the panels was not in accordance with Regulatory Guide 1.75 but was in essential compliance with the panel design displayed by FSAR Figure 8.3-15. After discus-sions between the SRIC, NRR personnel and the licensee's electrical engineering group, a method of correcting the matter was developed.                j FSAR Figure 8.3-15 was revised by Amendment 27 to reflect the metnod of correction. The SRIC has examined the-implementation of the change in two        ,

of the four panels involved and had no further questions. j (Closed) Unresolved Item (50-445/81-14; 50-446/81-14) Control of Stainless Weld Reoairs. This item involved an observation that a previously well l controlled program for the control of the number and extent of repairs l me -

                                                                                                 + - r
                         ~

3 J made to weld joints in stainless steel pipe had become less well con-trolled due to personnel changes. The licensee revised Construction Procedure CP-CPM-6.90 to reflect proper -identification controls for craft and QC actions = effective in January 1982. The engineering controls were promulgated ef fective with the issuance of Procedure CP-EP-10.0 in March

                                    '1982. The SRIC has not observed any instance where the procedures are not being complied with and therefore, has no further questions.
                         '3.         Action on - Licensee Identified Design / Construction Deficiencies
                                    -(Closed) Over-Torqueing of Safety Rel.ief Valves. On September 10, 1982,
                                    -the licensee informed the SRIC that a potentially reportable condition under the purview of 10 CFR 50.55(e) had been identified. It was reported that the main -steam safety relief valves had been over seated by excessive torquaing to stop leaks during the main steam hydrostatic test.      It was found that the excessive tightening had damaged the valve seats in some
                                    ' instances and that some of the valves appeared to have the valve stems r                                     bent out of tolerance. By letter dated November 10, 1982, the licensee informed the NRC that after review, the matter was not considered formally reportable under the regulation. The SRIC has reviewed the documentation uof the examination of the valves by the licensee. The examination did not reveal any significant damage had occurred to 'any of the valves that would have prevented the valves from lifting under pressure which would satisfy the-safety function. Some of the valves may have leaked under operating conditions which would be undesireable but not a safety hazard.       The SRIC had no further questions on this matter.
                        ' 4.         Allegations By Dennis K. Culton, On September 16, 1982, ~Mr. Dennis X. Culton made a limited public appearance before the Atomic Safety and Lic'ensing Board hearing in the matter of TUGCO's application for an operating license for the CPSES. His statement during the appearance appears in the hearing transcript at 5551 through 5555. In addition, Mr. Culton. furnished the Board with a written statement which appears in the record at 5556 through 5559.      Based upon a review of the record, NRC Region IV determined that there were two areas of interest that should be evaluated for their validity and effect of
                                   ' safety of construction. The first area dealt with the potential misuse of a group of drawings referred to as BRHL while the second dealt with the alleged splicing of safety-related or "Q" electrical cables. The SRIC was assigned to make the evaluation.
5. Allegation Relative to BRHL's
                                    .Mr. Culton's concern in this area appears at Tr. 5552 through 5554 and 5557 through 5558. His concerns can be summarized as follows:

(a) Bcsed upon limited information, he was directed to generate isometric drawings giving support locations. He states at 5557 that he did not feel qualified to do this work in the manner directed.

 . .t.t             .

s5 . 4 , (b) The' drawings that he and others in this group generated were released to the field unapproved and were used by the craft labor personnel to locate and install supports. A BRHL .is an isometric drawing made from a modified piping installation isometric. drawing to identify the supports on the pipe and to provide locational information at an appropriate point in time. The drawing series has 'rm unique title with the BRHL appearing only before the drawing number to distinguish.it from the parent pipe isometric which carries the same number except for its unique prefix, BRP. , Discussions with various licensee personnel who are familiar with the history of the development of the BRHL's indicate that the need to gen-erate the drawings became apparent when planning was initiated for the as-build verification program as required by NRC IE Bulletin 79-14. ' The . " I very early phase of'the work appears to have started at about the same time that.Mr. Culton was assigned to the drafting department and it is understood that he and others were hired and/or recruited from the field labor forces specifically for the effort. As an aid to further understanding this matter, it is also necessary to understand the type of information that appears on individual support drawings.- These drawings, which carry a prefix BRH and an entirely , different number scheme, provide, in addition to the design details of the l support, information as to where the support was to have been installed. The plan type information is provided by a snail square generally with j four notations indicating building column lines. Within the square, there  ; is usually a dimensional figure in feet and inches from one or more of I the column lines. The s.pport elevation information is furnished on the main face of the drawing where the elevation of the pipe and the building j

                                                                                                                                                                                 ~;

structure, as appropriate, are shown. The use of this system requires either a substantial degree of familiarity with the various buildings and l their column line grids, or ready reference to a set of the architectural layout drawings which clearly show the column line grids. It can no longer be established just exactly what information was given to g 'Mr. Culton:for his use in generating the drawings. An interview with the ..

                              "one remaining person still in the original group when Mr. Culton ' worked

~ there, indicated'that the package contained a piping is'ometric and the individual support drawings along with any of their outstanding change docurentation (CMC) that changed the . locational information. The pipe isometric was reproduced such that information relative to pipe instal-lation was deleted. This would include deletion of weld joint data and the bill of materials. The remaining information was the isometric line detail, location data (again in the form of column lines and elevation) and. reference to connecting isometrics. The modified isometrics were then annotated 'with a symbol that was to depict the approximate location of supports and a support number was assigned to each symbol. The location of a given support appears to have been estimated from the support drawing using the building column lines, elevations, and the piping isometric dimensions that still remained on the drawing after modification. The

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5 early BRHL drawings did not give any dimensional information on the , supports and the first issues were stamped " issued for hanger identifica-

                                . tion and accountability only" in the drawing approval block.                                                     Subsequent revisions, apparently beginning in early 1981, were updated and began to show dimensions for support locations. The final versions of the drawings

. . provide verified support locations, at which time the individual support - drawings' are revised to delete the location information. According to the present supervisor of the central document control center, the BRHL drawings have > never been routinely distributed to any of the possible user organizations such as the support installations crews. The drawings

                               , were only 'available on an individual . requisition basis which would be stamped "For Information Only" when given to the requisitioner.                                                            The BRHL drawings were originally developed and updated periodically to facilitate the final as-built stress analysis. The only use of the BRHL by other than the stress analysis groups presently occurs when a support has to be modified after the initial as-built verification effort.                                                  This arises by reason of the deletion of the support location information on the individual support drawing which then makes the use of the BRHL vital in order to find the support in the facility. This situation only arises on a limited basis and is treated on a case basis by the support instal-lation group and the document control center.                                                 .

4 In regard to.Mr. CuTton's-two major concerns in this area, the SRIC was

                                           ~

able to locate a few of the early BRHL drawings which carry the initials "DKC" in either the draftsman identification block or in the checker block. A comparison of these drawings to those generated by other drafts-men indicate no significant differences. The SRIC can only conclude that Mr. Culton was as competent as the other people in the group. Given the

non-use of the drawings at the time they were originally developed, this level of competency appears to have been adequate. Mr. Culton's_ statement that the drawings were released unapproved for use by the construction forces has been shown to be incorrect in two different ways. First, the original issues were provided to the document control center for filing with the note " issued for hanger identification and accountability only" on face of each drawing and were approved in the appropriate block on the drawing face. Secondly, the drawings, while on file in the document control center, were never subject to a routine distribution and were not readily available to the construction force who in fact had no need

. -for them. In addition, numerous observations by the SRIC of the suppor . installation process has indicated that the support location informati6.1 on the support drawing was used to install and to inspect the supports - and that any use of the BRHL for this purpose was so limited in frequency of occurrence that it was never detected. Mr. Culton's allegations regard-ing BRHL drawings is thus considered to be refuted.

6. Allegation Relative to the Solicinq of Electrical Cables At Tr. 5551 through 5552 and 5556 through 5557, Mr. Culton. stated that he had observed that "Q" electrical cables had bee 6 spliced and that these splices were in the Unit 1 spread room. Following Mr. Culton's apoearance
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r- a a 6 before the Atomic Safety and Licensing Board, Mr. Culton .was interviewed - in the NRC Region IV offices on November 8, 1982, in an attempt to obtain more information on the matter. The interview was tape recorded by a  ; representative of the intervenor CASE in the proceedings. At Tr. 5552, Mr. Culton stated that he observed the splicing to have occurred two times.

                     ;and further that there were other instances for which he had some papers.

During the. interview, Mr. Culton also indicated that he had other drawings available to him that would pin point the matter and promise to make them available to the NRC, or alternatively he would provide a sketch that would provide more detail. For the record,;Mr. Culton has not yet made available to the NRC-any of the documents to which he has alluded.

                                    ~

Based on the'information in the hearing record and in a transcript of the

       ,               interview referred to above, the SRIC initiated an investigation that
                     . attempted to determine what cables may have been involved when Mr. Culton                                                                   '

made his observation. The following key statements were utilized in attempting to isolate the involved cables from the other estimated 6,000 "Q" cables in the Unit 1 spread room:

a. At Tr. 5552 and 5556: The cables in question are 800 or more feet long.
                                                   ~
b. At Tr. 5556: Two cables were observed to have been spliced.
c. At Tr.-5557: The cables were going to a relay panel.
d. Interview Record, Page 3: The relay panel was the third one in from the aisle.

Using the above statements, the SRIC was able to narrow the number of possibilities down to two cables, presumably the same two as observed by Mr. Culton. The basis of the analysis was as follows:

a. The applicant has a computerized listing of all cables for the entire facility. By arrangement with tne computer operators, the SRIC was able to obtain a selected sort of the cables based on the "Q" identification and those in excess of 800 feet.
b. The list was reviewed by the SRIC to eliminate those cables that were not routed to equipment in either the cable spread room or the control room. A total of 42 cables were then involved.
c. Of the 42 cables, only 5 were shown by the routing records to be terminated in a relay panel, more correctly called relay racks.
d. Of the seven relay racks, only one is the third one from an aisle and
also has "Q" cables terminated in it, this being a cabinet identified as the "80P Auxilary Relay Rack 1" with Tag Number CP1-ECPRCR-03. Of the five cables. terminated in relay panels, only two are terminated i in this panel.
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7

e. The cable pulling records indicate that the two cables were orginally identified as E0009231 and E0009240 which were pulled on January 14 and 15, 1980, respectively. Based on his employment records, these
                                    - dates coincide with Mr. Culton's employment in the construction labor force as an electricia,n.

f .- Engineering changes subsequent to the pulls changed the designation of cable E0009231 to A0009231 and E0009240 to SP009240. The change from "E" to "A" signifies that a previously identified safety function-had been downgraded to nonsafety with the cable still routed with safety grade cables. The change from "E" to "SP" indicates that - the electrical circuit involved has been deemed to be no longer

                                      . required and the cable has become a spare.

Specific findings relative to cables A0009231 and SP009240 are as follows:

a. The SRIC, with the assistance of two other NRC inspectors, traced cable A0009231 through the spread room cable tray system from the
                                      . point at which the cable entered the room until it left the tray to pass through a conduit into the relay rack. The only portion of the cable not examined was the approximately 17' of cable in the conduit.

Of the estimated 50-60' of cable in the tray, there were no anomalies identified.

b. The SRIC found that cable SP009240 had been removed from the tray system on or about November 23, 1982, in-response to NCR E-82-01210 which stated that certain tray sections were overfilled. The enginet.ing solution was to remove saveral cables that been spared by other design changes. The removal was through the tray system but left the cable in the conduit entrance to the relay rack, again approximately 17' . The SRIC located the removed portion of the cable in a storage yard and visually examined the entire 400' with no anomalies identified.

General findings and considerations:

a. Project Specification ES-100 " Electrical Erection" does not totally prohibit the splicing of safety-related cables as indicated by lMr. Culton. The specification allows splicing to be done based upon the engineer's direction and this has been done by the use of engineered junction boxes. It should be noted the industry standards (IEEE) do-not prohibit field run splices provided they are properly qualified,
b. There have been a number of instances where the cable jackets have been repaired when the jackets were damaged either in the process of manufacture or during installation. These repairs have been accom-plished under a standard repair procedure, EEI-13, when directed by the site engineers. One of two repair measures are applicable within the procedure. One of the methods utilizes heat shrinkable plastic tubing when the damaged area is not prohibitively far from the end of
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8 the cable and thus allows the tubing to slip down the cable. The other procedure which was much more generally used early in 1980 involved the use of a fire resistant tape wrapped in half-laps over the damaged area. The former procedure produces a very neat slim appearance while the latter. procedure is relatively bulkly'and might well appear to be' a splice. .A number of both types of these repairs were identified during the examination of the specific cables discussed above and during an earlier more extensive examination of several-tray runs in the spread room. All of these anomalies were judged by the NRC inspector to be jacket repairs.

c. The SRIC believes that yet another consideration may well be relevant to this matter. The consideration involves a much earlier allegation that cables had been repaired in an unauthorized manner. The allega-tion was received by the-SRIC sometime during February 1980 from an electrician assigned to the electrical cable pulling crew that had pulled the cable then in questior. and the two cables identified with Mr. Culton's allegation. All three cables were pulled during early to mid-January 1980. The SRIC's recollection of the person was that he was a journeyman electrician and assisted the foreman in the detail supervision of the crew of about 16 men, all of whom were classified as helpers except for the foreman and the journeyman. Since the electrician was sufficiently concerned to report a cable jacket repair involving the use of Scotch 33 tape rather than the approved tape, it seems to follow that he would have also reported an actual cable splice for which there is no approved repair. Given the electrician's position with the pulling crew, it also seems unlikely that he would not have been aware of an error of a magnitude that would have caused such splices to be made. (For more information about the 1980~ allegation and the results of the subsequent investigation, see NRC Inspection Report 50-445/80-08; 50-446/80-08.)
d. Since 17 feet of each of the identified cables were not inspected by the NRC during the course of this special inspection, it was not possible to conclude positively that the allegation is either confirmed or refuted. Notwithstanding, the inability to positively state that the allegation made by Mr. Culton is substantiated or refuted, the SRIC believes that no further action is warranted based j on the following cumulative information as follows:

(1) Cable jacket repairs utilizing wrapping with a rubber tape were not and are not unusual. (2) There has been no identified reason why the splices should have been necessary. The rubber-like jackets on the cable are relatively easy to cut with even a dull edge but the wire insulation material and the wire itself are relatively hard to cut. 1 1 s

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Y 3 73-03 , 3as83 (3) A jacket repair made with tape would be very difficult for the inexperienced person to distinguish from an actual splice. The splice generally would have a somewhat bulkier shape and would prcbably be somewhat lumpy rather than smooth. (4) The probability that the SRIC would have learned of such an

                         - nusual event as a splice being made to safety-related cable through contacts that had been established in the electrical crew involved.                                                            i (5)   Removal of the cable would probably cause damage to the nearly 30 cables in each of the conduits.

(6) Neither of the two cables now have a safety-related function and there are no requirements that prohibit the splicing of nonsafety cables. 7. An article appearing on page 13A of the Fort Worth Star-Telegram dated 983, stated that had made allegations

          @hichweresubsequentlyinvestigate w

rirs by personnel of B&R and later by. personnel of TUGCO. The article stated that was then charging that these investigations were a " cover-@up" to hide safety hazards at the Comanche Peak nuclear power plant. The article stated that ad been employed at the construction site as a foreman and was laid off weeks after he made the allegations. The article =1 attributes three technical type allegations directly to In summary, the technical allegations appearing in the article were: (a) pparently stated when interviewed by the writer of the article that rejected aggregate was mixed with concrete that was subsequently poured to form the base for the nuclear reactor. The article stated that a 6 was the B&R equipment operator who had apparent first d knowledge of the matter. The article also stated that could not be reached for comment. (b) A second allegation, that the article stated was never previously investigated, involved the construction of underwater lamps for the g } pools surrounding the reactor. M am charged that he was n(- prevented from cleaning out drill shavings from the lampposts and that these shaving could be washed into the reactor during refueling and could jam the fuel cells and could even fuse to the control rods. (c) The third allegation dealt with a contention that holes had been improperly drill through concrete walls and the interior reinforcing steel. The article attributes the information to another party {'f identified as

                          . -                                 .      -                 ~.~. .                  -               .      .            ..                  .                      - _

4 r 10 The SRIC-assigned to the Comanche Peak station obtained both the E&R and TUGCD files pertaining to the investigations that were stated by the newpape'r article to have occurred. The B&R file was found to contain an undated and unsigned letter addressed to Mr. Thomas Feehan, President of

B&R. The letter is indicated in two different places to have been prepared by Arvil .Dillingham, Jr.' The letter is stated in a memorandum addressed to a group vice president of B&R from a vice president of the
                                    -B&R division to have been hand delivered to Mr. Feehan by Mr. Dillingham on August 6, 1982. . The memorandum was dated August 13, 1982.                                                               The undated letter to Mr. Feehan contained eight violations that the writer stated he had observed.or had knowledge of that had occurred during his

+ period of employment at the Comanche Peak station. Review of the letter addressed to Mr. Feehan indicated that only one of the eight violations correlated with the allegations appearing in the newspaper article, this being .the item outlined in (c) above pertaining to the drilling of holes - in the cor. crete walls. .The B&R memorandum of August 13, 1982, which is a report of the internal B&R investigation of the eight violations, indicates that seven of the allegations were found to be either without a basis or were not substantiated. The remaining item was considered in effect to hav.e been substantiated but the corrective measures were already taken. In each case, by what is assumed to be Mr. Dillingham's signature, , _ [Mr. Dillingham; acknowledged his satisfaction with the B&R findings. The

                                   . above memorandum indicates that a number of other people were interviewed by the B&R . investigative group, one of whom was Mr. Witt. Mr. Wittl                                                      .

apparently did not confirm Mr. Dillingham's, allegations but made I additional allegations related to his experiences during his past employment at CPSES. .One of these allegations appears to be substantially th'e same as that appearing in the summarization of the news article as (a). Mr. Wittl also charged that some personnel biased the operation of the concrete batch plant scales by leaning on the wires connecting the scales to the sensors. Additionally,,Mr. Witt' stated concerns about a possibly missed hold point'during the welding of the fuel pool liner and that some welding had been done by an uncertified welder. In an internal B&R memorandum dated August 17, 1982, the B&R investigators summarized

                                    .Mr. Witt'sf concerns and their findings relative to the concerns. The B&R memorandum indicates that the investigation relative to use of rejected aggregate was apparently partially substantiated but of no concern in that the aggregated pile, rather than actually being unacceptable, simply had not been tested prior to use as required.                                            The matter was documented on Deficiency and Disposition Report C-446 dated December 9,1976, which appears as attachment A to the memorandum.                                              In the matter of the missed
,                                      hold point for the' fuel pool liner weld, attachment B to the memorandum documents that no hold point was missed. Regarding the two remaining Witt allegations, the memorandum states that the allegations were investigated and found to be without basis but provides no other information.
                                     ' Personnel of TUGC0 performed a separate investigation of Mr. Dillingham's '

allegations (the Feehan letter) during August of 1982. The results of that investigation were furnished to TUGC0 management by memorandum dated September 2, 1982. This investigation found that two of eight items were substantiated with one of these being the same item that was substantiated T t

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   /.-                                               11 by the B&R investigation. Both of the substantiated allegations were found by the investigators to have been adequately documented and that corrective measures had been taken or were in progress.

In a separate memorandum dated December 10, 1982 one of the TUGC0 nves

  • s- ocumented a phone call from 'n which pparently made yet additional allegations. One of these allegations. regarded welding done by an unc e m welder on the turbine-generator pedestal (by implication). 1so apparently further mentioned ho was supposed to know about a sensor that had broken off and was buried in the main dam. Also, % was alleged to have personally driven a front loader that returned dry and lumpy cement that had been rejected to the bin, that this cement had been subsequently used in the reactor core, and that this was why the cracks happened. The writer of the memorandum stated t a e had encourge to take his ccncerns to the NRC. in turn was reported as saying that he had intended on going to the newspapers and Congress instead.

It appears that carried out his above stated intention in' that the above referenced newspaper article has appeared and to the best of SRIC's knowledge, as made no contact with any component of the NRC. NRC Region IV determined that the allegations in the news article should be investigated but that those made in the Feehan letter and in the telephone conversation with TUGC0 should not. This decision was based on the premise that as had his earlier concerns satisfied except for those appearing in the article. Regarding the above summarized allegation (a), the SRIC established that 6was no longer an employee at CPSES and further established that he had relocated from the Glen Rose, Texas, area to another state. NRC Region IV personnel made several attempts to contact M by telephone at his new address, to no avail. A registered letter, receipt requested, was then sent to M equesting that he contact Region IV as soon as Receipt of the letter was acknowledged but as of this date,

                  @possible. as not contacted the region. It appears that Mr. Witt does not intend to assist the NRC in investigating allegations attributed to him.

It should be noted that only the B&R investigative group has been able to establish contact with M all others have apparently failed. __Regatding summarized _ allegation 4.c), the SRIC, with assistance of another c' Region IV inspector, was abTii to' establish that the underwater lighting standards were fabricated in such a manner as to leave drilling chips inside and had not been removed. It was also established that the lign ing standards were ' fabricated completely outside the licensee's QA program which included various welding operations. There are ro records of inspection or of the welders involved or of the weld procedures utilized. Review of the design drawings do not. reflect tnat the A/E considered the lighting standards to be within the QA scope, yet should the standards physically fail during the seismic event, fuel could be damaged. Given the possibility of failure, the stardards should have been classified as Seismic Category II (licensee's FSAR afinition for

  • I
. _ ./

12 components which have no safety function but must not fail in a seismic event since such failure could jeopardize the functioning of a safety-related component) and should have been included in the QA program. This is considered to be a violation of Appendix B to 10 CFR 50. Regarding the premise that the drilling chips inside the standards could be swept into the reactor during refueling and cause an accident, the SRIC found six of the standards are normally located with their bottoms just about the floor level of the refueling pool and that the chips that might have worked their way out of the botConr of the standard could have carried into the reactor at the conclusion.of the refueling process. The size of the chips that could work their way out through the 1/2" holes are not of a size that could be expected to plug a water channel through the reactor core and create a hot spot. Further, the idea that the chip could fuse to the control rods is equally remote in that far higher temperature would be required in the core to achieve such fusion than actually will exist there, the differential being 600 to 800 F. Thus, the safety significance of the chips is very small. The uncontrolled (no QA) problem with the standards is relatively more important since workmanship on the devices has not been established. Regarding sumamrized allegation (c), the allegation has been the subject of another allegation by a person who appears to have substantially more direct knowledge of the matter than indicated by Under these circumstances, the NRC has determined that i can acoress the issue in a more satisfactory manner by investioating and evaluating the second party's allegation rather than N

8. tgstino of NRC Form 3 .

10 CFR 50 was revised by 47 FR 30452 to add 10 CFR 50.7 " Employee Protec-tion." The change was published July 14, 1982, and had an effective date of October 12, 1982. An important element of the change was that of a requirement to post NRC Form 3 at locations where the form can be readily viewed by employees on their way to or from their place of work. It has. been alleged that 'the licensee did not post the form. The SRIC learned of the allegation during early January 1983 and found that the form was posted throughout the main construction administration building and on a bulletin board where most of craft labor force can readily see it, particularily when departing from the construction area. The SRIC has been informed by licensee employed personnel that they received and posted the forms in the administration building about the first of 1983. A senior B&R manager indicated that the forms were received, he believed from B&R's Houston office, sometime between Thanksgiving and Christmas and were posted on the craft labor, bulletin board near the " brass alley" well before the first of the year. It is thus clear that the forms were not posted on the specified effective date of the change to 10 CFR 50 as alleged. It is much less clear as to when the forms were actually posted nor is it clear that most people would even have been aware of the posting. The " brass alley" bulletin board is a large board, pernaps 4' by 6' in size with many postings. The majority of the postings are required under various federal statutes or regulations. The posting of an additional form probably would not draw much attention from the average worker. As of the time of 1 l

n . . 13 inspection by the SRIC, the licensee and his principal site contractor were found to have the form posted and to be in compliance with the regulation.

9. Manacement Interviews T'he SRIC held management interviews with one or more of the persons identified in paragraph 1 on a nearly daily basis throughout the inspec-tion period to discuss NRC findings developed during various special inspections and investigations. The discussions also included the licensee's positions on the NRC findings.
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                                              '~ ;,6 2IJ OiliS                                                          .

59 l C0le.Ala.lir' FEA!. STEAI. ELECTT. C STATIOU: 5::EJEC1:

                      .                              ALLEGED !!*.WCFEl. CC?.5TPI'CT!0" PRACTICES                                       { }$]}

F.EPORT !@P6ER: Q4-8'4-036 1.- On February 28. 1084'. the Region, IV 01 Field Office received a telephone call from ummsagitamusgg a former Brown & Root, Inc., at " Comanche Peak Steam Electric Station (CPSES). Mwlaimed he was in 4 possession of documents, photographs and tape recorTings containing enoug'h - infomation to diose down CPSES with regard to improper construction practices. M agreed to provide specific information durir.g personal interviev. and agreed to meet with Regicn IV 01 Field Office on Februar 29, 1 84. related that he worked for Brown & Root for abou s r. s.

                                                                                                                                                            .c
2. ,

4i On Februar 29 19 was 'in4 rviewed by i;EC Ir.vesti tors

3. '

A Results cf Interview wittu ~ is ~ included witle this kcport of Inouiry is Exhibit (2). 4 hy rovided the fcilcs:ing infor:. .ticn during his interviest: ( first major concern related to the possible damage of l (' w~ - stainWss steel reds, approximately 15 feet in length and 2i inches in diameter, that are located in the upper internals behind a missel

shield in the core of the nuclear reactor ir. the Eeactor Building.
                                                 ^ claimed that tuc ci the itainless steel bars had beer. bcrt
                                       ~

l i ywci cu6 shhpe approximately 1 toc.. ircr_the_ e,nds during an accident

  • with either a fork lift or a cr<;c. Emmalleged that the bars nac beer. pullec Lati, ir.te t hart. ly. r. lacing a rope frer ti c crra c, a d l

tlin t1.e dar.:.5r hrc rever beer. r op--ly repnra 6 er dtct.r.ented. l < Ms-i eccri :- cerr: ir.velved c .ut s ir U r n :>.i t b pid c. t

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               'r) ghirc cer.ccr:4 dcc h i.                                 'l.    '.ii -          ?!r cier.r lccz.ted on te; rf the re&ctor vessel.                           u.s . c:.c. r. _c that when tiet pci6r crri.e e 'c.c.;*rr ir that area.
                         'u rif     (. s:, t '. c i i t i nto ha r.gcr s, i h r. -

M.l c r: rciated that festuna cabics iccated or the polar crane were defective beci.ct.e it.t> ccntainec t roken ir. terr.a' uf rir.r.

     @was uncble to furnish detailed inf ormatior, involving names, dates or places. W information was only of a general nature. 6had previously indicated he had obtained documents, photographs and tape recordings that could close CPSES down. g however, refused release any documents, photographs or tape recordings to investigators. M contended that he was in possession of such evidence; however, he refused to turn any evidence over to the Office ci Invcstigetions or reveal the hidder lecctier of the evidence.

EliD OF RESLLT'. OF II.'TERVIEl! WITh0N FEBRUARY 25,19E4 e I w ) ' S %:.AT'J..E  : : Om < l.<(- -

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                                    .ccetts ci: it.;. r ~ tl.c rcactor vessel,                                                     .

i t w( t.i t. 1.i ciit h;. : '. t ? *- *itt rrrr lcreted ir tb I. -. Cid idir.g. ' g,t. :. 1 ! c Et li tu: il:61 iestur,i cabicsrict r. f. W. s r rt i.< . i s s i c.t . t cl iu. , as ti.e . l.ac t rci t h i t.;<. rt.: ' ica' v'rirT. On lurch ],19Pt, t t r 4 rc t. tul.nict.1 issues stear, ins frc.: g-

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ir.tc evits. vti t tur i.ec c'eer it T.csio: ".'.' ita e ci it i 14 c: . kepici . t-inferracc' tt'r 01 f'c~.d C.'iice that problems with the prier crei+ and the problems witti cr. chis.g . the concr&te bElm, the rencicr vr.!!fl were old g issues that the ?!CC had addressed previousi r ir. ip.ing.c.t.ioAreports.

- Region IV however dic recuest an ir:n.ediate inspecticr. cf the persibility of having damaced staisiless steel bars located in the upper internals of the reactor vessel.. Subseque..t.ly, an inspection ucs performed by Region IV personnel to determine if any damage existed. A visual inspection resulted in no damage being observed, and information received from the resident site inspectors indicated that this also had been an old issue that the,tiRC had previously addressed. An incident involving damage to the upper internals had previously been reported by the utility and ..

properly repaired,and dispositioned. Findings of.the inspection conducted by Region IV perpsnnel are located in the Monthly Regional Inspector's mo Report technicalfor allethe% nth.nfJir,c{i:1936 Due to the fact that the threeiins steam - properly addressed by Ecgior. IV, this inqu-iry is CLOSED. 7 2-2g-84 Exhibit (1) Results of Intervicw wit 2-29-84

                                                                                                                                                                ~' .

Exhibit (2) Results of Interviu uith REP 0kiED BY: / Wcr. del E. Frost, investigatcr OI Field Offict

                                                                         .                   Region IV
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P.~ithard 7.. Herr, Director 01 Field Office Region IV - cc: E. C. Gilbert V w/exhibiti J. T. Collins w/ exhibits T. F. b*esterman w/o exhibits

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mair. techi.. .al cor.cerns involved the iciict:ir c three creas: (e) SLidm 'irst major concerr. related tc dir+ce to 15 foot lono, 23 irch steinless steel tirs locates ir. the upper interna'.s in the  ! reactor veuel locatcc ir. the P.eactor Building. 4kEl!EE t:as cor.ccrr.cd that. two of the stain 1.ess stee.1 bars leave been bant 1 foot i

                             -          fror the tcp with either a fork lif t or crane. % contended                                                                l i

f that a re . lead beer. pli.ce.d cr the stainless steel bari ard pulled by Il~.e trane ia order to straictic r it. rin:st:g related tha no , 1 (t tt

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i . . e 1 1 2 1 1 I i 1 i EliO 0F RESULTS OF INTERMO: lliTH g.4 0!; FEBRUARY 29, 1984. i i T p - l -

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SIGH'ATURE : _

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,,            .c p.:f g                          73-D3                        ,               3 A8 83 (3) A jacket repair made with tape would be very difficult for the
                 -            inexperienced person to distinguish from an actual splice.                 The splice gener* ally would have a somewhat bulkier shape and would probably be somewhat lumpy rather than smooth.

(4) The probability that the SRIC would have learned of such an unusual event as a splice being made to safety-related cable through contacts that had been established in the electrical crew involved. (5) Removal of the cable woukd probably cause damage to the nearly 30 cables in each of the conduits. (6) Neither of the two cables now have a safety-related function and there are no requirements that prohibit the splicing of nonsafety cables. 7. An article app' earing on page 13A of the Fort Worth Star-Telegram dated 983, stated that had made allegations

                 @hich w            were subsequently investigate      rirs by  pe-sonnel of B&R and later by_ personnel of TUGCO.          The article stated that                        was then charging that these investigations were a " cover-up to hide safety hazards at the Comanche Peak nuclear power plant. The article stated that ad been employed at the construction site as a foreman and was laid off weeks after he made the allegations. The article =1 m attributes three technical type allegations directly to In summary, the technical allegations appearing in the article were:                .

(a) 6%pparently stated when interviewed by the writer of the article that rejected aggregate was mixed with concrete that was subsequently. poured to form the base for the nuclear reactor. The article stated that a @ was the B&R equipment operator who had apparent first d knowledge of the matter. The article also stated that could not be reached for comment. (b) A second allegation, that the article stated was never previously investigated, involved the construction of underwater lamps for the

       -    }            pools surrounding the reactor. M am charged that he was prevented from cleaning out drill shavings from the lampposts and that these shaving could be washed into the reactor during refueling and could jam the fuel cells and could even fuse to the control rods.

(c) The third allegation dealt with a contention that holes had been improperly drill through concrete walls and the interior reinforcing steel. pj j The article attributes the information to another party identified as ' ~ g M gg

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v 10 The SRIC assigned to the Comanche Peak station obtained both th'e B&R and TUGC0 files pertaining to the investigations that were stated by the newpaper article to have occurred. The B&R file was found to contain an undated and unsigned letter addressed to Mr. Thomas Feehan, President of B&R. The. letter is indicated in_two different places to have been ,' prepared by The letter is stated f.1 a memorandum addressed to a group vice preside.nt of B&R froni a vice president of the B&R division to have been hand delivered to Mr. Feehan by on August 6, 1982. The memorandum was dated August 13, 1982. The

                                                                                                                                                                                                                                    ~

undated letter to Mr. Feehan contained eight violations that the writer stated he had observed or had knowledge of that had occurred during his period of employment at the Comanche Peak station. Review of the letter addressed to Mr. Feehan indicated that only one of the eight violations correlated with the allegations appearing in the newspaper article, this being the item outlined in (c) above pertaining to the drilling of holes in the concrete walls. The B&R memorandum of August 13, 1982, which is a l report of the internal B&R investigation of the eight violations, indicates that seven of the allegations were found to be either without a basis or were not substantiated. The remaining item was considered in effect to have been substantiated but the corrective measures were already  ! taken. In each case, by what is assumed to be signature, M acknowledged his satisfaction with the B&R findings. The

                             .above memorandum indicates that a number of other oeople were interviewed by the B&R investigative group. one of whom was                                                                                                                                                                             ,

i apparently did not confirm allegations but made - s additional allegations related to his experiences during his past l employment at CPSES. One of these allegations appears to be substantially I the same as that appearing in the summarization of the news article as j (a). Malso charged that some personnel biased tiie operation of ' the~ concrete batch plant scales by leanin on the wires connecting the scales to the sensors. Additionally, stated concerns about a l possibly missed, hold point during the welding uf the fuel pool liner and that some ewelding had been done by an uncertified welder. In an internal , B&R memorandum dated August 17, 1982, the B&R investigators summarized Mr. Witt's concerns and their findings relative to the concerns. The B&R l memorandum indicates that the investigation relative to use of rejected aggregate was apparently partially substantiated but of no concern in that l l the aggregated pile, rather than actually being unacceptable, simply had  ; 1 not been tested prior to use as required. The matter was documented on ' Deficiency and Disposition Report C-446 dated December 9,1976, which appears as attachment A to the memorandum. In the matter of the missed hold point for the fuel pool liner weld, attachment 8 to the memorandum documents that no hold point was missed. Regarding the two remaining M l allegations, the menorandur states that the allegations were investigated . l and found to be without baLis but provides no other information. ) Personnel of TUGC0 perfor.ned a separate investigation of allegations (the Feehan letter) during August of 1982. he resu ts of that investigation were furnished to TUGC0 management by memorandum dated September 2,1982. This investigation found that two of eight items were substantiated with one of these being the same item that was substantiated i I

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12 - components which have no safety function but must not fail in a seismic

                      -'   event since such failure could jeopardize the functioning of a safety-related component) and should have been included in the QA program.

This is considered to be a violation of Appendix B to 10 CFR 50. Regarding the premise that the drilling chips inside the standards could be swept into the reactor during refueling snd cause an accident, the SRIC found six of the standards are normally located with their bottoms just about the floor level of the refueling pool and that the chips that might have worked their way out of the botCorr of the standard could have carried into the reactor at the conclusion.of the refueling process. The size of the chips that could work their way out through the 1/2" holes are not of a size that could be expected to plug a water channel through the reactor core and create a hot spot. Further, the idea that the chip could fuse to the control rods is equally remote in that far higher temperature would be required in the core to achieve such fusion than actually will exist there, the differential being 600* to 800*F. Thus, the safety significance of the chips is very small. The uncontrolled (n,o QA) problem with the

   /

standards is relatively more important since workmanship on the devices has not been established. Regarding sumamrized allegation (c), the allegation has been 'the subject of another allegation by a person who appears indicatedtobyhave substantially more direct knowledge of the matter than Linder these circumstances, the NRC has determined that it can acoress the issue in a more satisfactory manner by

               ~

investicating and evaluating the second party's allegation rather than

8. Postino of HRC Form 3 .

P 10 CFR 50 was revised by 47 FR 30452 to add 10 CFR 50.7 " Employee Protec-tion." The change was published July 14, 1982, and had an effective date of October 12, 1982. An important element of the change was that of a requirement to post NRC Form 3 at locations where the form can be readily viewed by employ.ees on their way to or from their place of work. It has. been alleged that 'the licensee did not post the form. The SRIC learned of the allegation during early January 1983 and found that the form was posted throughout the main construction administration building and on a bulletin board where most of craft labor force can readily see it, particularily when departing from the construction area. The SRIC has been informed by licensee employed personnel that they received and posted the forms in the administration boilding about the first of 1983. A senior B&R mar.ager indicated that the forms were receiveo, he believed from B&R's Houston office, sometime between Thanksgiving and Christmas and were posted on the craft labor bulletin board near the " brass alley" well before the first of the year. It is thus clear that the forms were not posted on the specified effective date of the change to 10 CFR 50 as alleged. It is much less clear as to when the forms were actually posted nor is it clear that most people would even have been aware of the posting. The " brass alley" bulletin board is a large board, perhaps 4' by 6' in size with many postings. The majority of the postings are required under various federal statutes or regulations. The posting of an additional form probably would not draw much attention from the average worker. As of the time of

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1 s 1 IN THE MATTER OF: 2 SWORN STATEMENT OF

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  • 9 7 PRESENT AT THE TAKING OF STATEMENT:

Witness; ri f(1 . MR. E. SROOKS GSIFFIN; 9 MR. RICHARD K. HERR, Inte r r oga to r s ; 10 h MS. JU AN IT A ELLIS g e MR. DAVID COGBURN, Court Repcrter, c,,,3 . u . .. 14 SWORN ORAL STATEMENT IN Q U ES TIO N AND ANSWER 15 PORM of take befor David Cogburn, 16 a Court Reporter in and for the Sta te of Texas at 17 the United States Federal Courthouse in the City 18 of Fort Worth, County of Tarrant on the 14th day 1.9 of April, 1983 at 2:00 p.m., at which' time the 20 following proceedings were had: 43

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  • Stanley, Ea:ris, Rice 741-4567 --

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                                      ,1                  as such do what an a ttorney, I should say, 2                 would,do for CASE.                        And so to that extent I
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3 guess sort of a quasi-representative

  • status.

4 Q All right. Our purpose here today is to 5 ask questions concerning an earlier

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           -                   .        6     , statement that i b.eli' eve he m. ade' to you fn which he identified a nu'mber ,of' iss'u es that are of concern to 7

8 the NRC, and we would liKe to find out more specific 9 details about these issues.

                                                    ,                                                           So my questions will be 10       directed to you, 11                 A            Okay.

Cd *

 ,;)                                  12
                                                    . Q            'The first issue I would like to go into 13       is the use of a =ebar drill or a drill at Comanche 14      Peak that I believe you have indicated was used, 15       that you used in your job and war also used to drill 16       through cement and rebar; is that correct?

17 A That's correct. . 18 0 Would you mind telling me in more detail 19 what this drill ls? 20 A Well, it's like it says. They call it a 21 rebar eater, it's m'ade by."Drilco manufacturer who is-22 out of Miami, Florida and it's a -- well, they have

           .                          23      a diamond tip on them or they have a real hard steel 24      tip on them that cuts through other steel, concrete, lh                                                        '

1/ 25- any' thing else that gets in its way. And'they are l Chani moe De* eda Odm. 7J9 . der 9

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                            - 1      operated by anywhere from a half to a th'i e e-q u a r t e r 2      horse electric motor.                             .

3 0 Okay. And did you use this machine in 4 your capa city as an employee of Brown & Root? 5 A .Well, I was foreman over the crek that

                                 '                                                                '~

6 sed'this' dac' hine. '.'

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7 Q , All right. Didthe use of this machine 8 require documentation fro $ -- 9 A It did. 10 Q -

                                                                 .from engineers?

11 .'. ' It did. I 12 . Q And these were B r ow n -& Root engineers? 13 A Right. Not Brown & Root, they were Gibbs 14 anId' N'1117 They are the ones that first started it

                                                                                                           "      ~        '

. 15 whan they first come on the j ob" i; 16 Q All r i'g h t . 1 17 A' A guy named ..- is the one if 18 you want his name.

                 ,'          19                  Q       He was the one that issued --

20 A Be was the one that started o'ut with me l l 21 on the rebar drilling, and'later it changed into l 22 f o:u rteen dif f erent people if you want to know the 23 . tr.uth about it. . 24 0 What was his'last name?

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                                                                            .        He is still with Gibbs and Stanley, Harris, Rice 741-4567                                   ,

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6 l

                           ~1     Bill and he is out of the Dallas office how.

2 MS. E LL'IS : I believe that's 3 I have seen his"name. 4 THE WITNESS : Do you know who I'm 5 talking about?

           .I
                                                .' ' 'D'u ri n g ,[h e time that' members 6f your crew
                                                          ~

6' 'd . . 7 used rebar e a t e' r , did they make sure they had this 8 documentation? 9 A Most of the time yes, but there are times 10 that I was ordered by my superiors, a guynamedlllll 11 lllllllltoorderorgoout the gate, as I stated in 12 my affidavit before.

                  .         13           Q             Are you saying he asked you or told you 14    or ordered you td~ drill holes or use this drill in 15    the manner in.which it was' to be used without
            ,-              16    documentation as required by procedure?

17 A I am saping that. , i 18 Q Bow many instances. did this occur?  ! 19 A I wouldn ' t -- I mean, just to give you a 1 20 number, I couldn't do it. Many times. 21 0 Okay --  ! 22 A As far as number, you're going to say i 23 more than this or less than this,'I can't give you a 24 number. I won't give you a number because I don't 25 have that much -- well, how can I sap it, I'm Just Stanley, Harris, Rice 741-4567 -

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                                                                                                                                                                       )
                            - 1      not there.

The drill -- I was ordered to loan the . 2 drill out ,at times. I was ordered to loan a guy a 3 drill bit that he would go get a motor, a drill 4 motor out of the tool room and I'd never see these 5 three, four, f iv e , six bits again. Now, how many

            ..                6      holes were. drilled with it'there,'s no telling how 7      much rebar was cut.                                                                                        -

8 A man comes up and says, I want you to 9 give so and so six drills, he's got a pipe. hanger 10 that has to go down or a cable tray that has to go 11 down - a cable tray support - and we have got three hol es in it and we need the f ourth one bad. And I 12 13 went to my general foreman a,t that timewhowaslllll 14' and I told g 'I said keeps 15 giving me these orders to get this drill out, loan 16 it out to drill holes that are not a u th'o r i z e d . I 17 haven't got the paperwork from I 18 said, what can I do? He said, man, he'.s my boss, l , 19 what do you want me to do? 20 0 Do you know for sure that the' people that l 21 you loaned this drill to d'id not acquire the I 22 documentation that they needed to stay within i 23 procedure and use this drill? . I 24 A I'm positive they did not get the 25 procedure, because any time the procedure paperwork

                                                                                  ~

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s a 1 came through it came directly t' o oe from 2, and I handed it to my men and seen that 3 th'e job was done. Because there were are'as out  ; 4 there that there was -- strictly was illegal at all 5 to; drill any kind of rebar or cut any ki'nd of rebar,

           .I
                       '                               '                                          ~
                             '6'                                                               'Nc rebar od any kind it eb et'o r . 0'n'e, Was oneI , o[ iih en.
         .                                      !                                                                             )
                -               7      was allowed to be cut in that building anywhere.
                                                                                           ~

8 , Q Is this the containment building? 9 A Containment building, Reactor One. \ i 10 Q What the NRC would like to know in this 11 instance is the specific locatichs where holes were 12 d lied without proper documentat. ion. Is there any 3 13 wa'y that this information or these locations can be 14 . determined, rec.onstructed or anyplace we can go, t .. .. 15 anybody we can go talk to~to find out specific 1 16 locations? 17 A Let's see, borrowed it 18 several times to drill holes. Ed's still working 19 ut there. Other.than getting ahold of 20 is the only one I can think of. 21 And .as f ara:as sitting. here" and telling you 22 locations, evidently you haven't been out to that 23 plant. , 24 Q I have, yes.

       .4 cf                          25       -             A         Well, I had access to every btiildi ng on Stanley, Harris, Rice 741-4567 t

1.?.. . - e ~ w -~ ..~ . a ~. .- ----

     *d'.
                                                                                  )

s 0, . 9 1 that place. I have been in every building. I have  ;

                                                                                                                                                      \

2 cut rebar .in every building but containment one, 3 except the dam. Now, does that tell you anything? 4 Now, t'o'go tel1 you to go to a certain wall and see l 5 if the rebar is cut 'is impossible.

  • l
                 ..      .           6       ,

Q. .You understand what we're t,r yin g to do 7- with the inf ormation. He're trying to find out l 8 specific locations -- 9 A Right. 10 0 -- so that we can verify what you're 11 sa y i n g'. , Let: me ask you, in your statement that you 12 made to Ms. Ellis, you identified a -diary that you 13 have kept and im this diary -- dt's my understanding 14 in' this diary you logged in instances or timer when 15 this rebar eater was used to drill holes when you 16 did not have the proper documentation; is that I 17 correct? _. 18 , A No. This i s --

                     ,             19                     0              Was this just a work --

20 A This goes from 9-7-78 to 10 7 9. 21 l 22 And this documentation, there's.some of them - 23' . most of them have documentation. It also has the 24 CMt number, and like at the beginning it was a DCDDA

      ..                                           .i 25        or something.                       I got it wrote on there someplace.
                       ?._

Stanley, Barris, Rice 741-4567 i  :

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                       .              ~l             DCDDA is what they starte d dril. ling rebar with.                                                                      ,

2 Then they find out this was not the right  ! 3 documentation. Then they changed it to a' CMC, but 4 when they first got it they were doing it on S three-part memos. - I

                                                               'f, *. gug __                                   .- .
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  • 7 A And 'this 'is eve'ry hole that I drilled,
8. legal and illegal, and exc'ept f or the ones where my
                   .                   9            equipment -- I was ordered to loan my equipment out.-                                                       .

10 Q All right. . 11 MS. ELL IS : Just for the record, we 12 probably :should mention that is

                     ,                13     .

ref erring tu a looks like a " twenty-four page

                                    -14                        listing which he.had prepa.r.ed of these 15                      'dif f er'ent items and h'e will be giving that to 16                       you.

17 Q Is this a complete rendering of this 1,8 diary -- 19 A Uh-huh (affirmative). 20 Q S o -- 21 A It is in' comple'te form. 22 MR. HERR: Is it marked? You said 23 legal and illegal. Have you'got the illegal

                                                                            ~

24' stuff marked on it?

?

25 - THE WITNESS: No, I really haven't W- , _ . , *,..._.-n . -

m._..c.-,a.....~.,,,-. - - - . - ~ ~ - ~ ~ - - - -= 7 .. - ,,,

                        .'                                                                                                                                               l~

11 1 but if it doesn't -- it's going to have to be 2 interpreted by me, which ,'ll I try to explain to 3 you or I can tear off a page and y'_all can look 4 at'a page -- - - I 5 . MR. HERRt. Perhaps take a blue pen or l

                                                   .I
                    ..                   6       -
a. red jen and'we'll mark tlie illegal stuff.

7 THE WITNESS: No, I won't do that, I 8 can't do that because I didn't keep that much 9 of it. I mean, you can take a look and flip j i 10 . through it to see what it's talking about. I 11 didn't do that -- as far as that, if I had kept 12 that kind mf a record, it vould have been a _ 3 13 separate =wcord or something like that. 14 Q Would any of these entries in this 15 document lead us to the locations of where holes 16 were drilled without authorization?

     .                                 17                     A              It's very possible.                              It is very possible.
                         ,             1.8                                        MS. ELLIS:                    If I can call your l
                         /             19                     attention to this third column here, it says                                                              j l-                                                                                                                         -

l 20 "rebar cut" -- it's upside down. But in this

                                                                                             ~

21 - column, this is where" specific rebar was cut { l 22 apparently and -- 23 . THE WITNESS: Yeah, what I did va3, I, i 24 marked down -- this was my own deal and my own l 25 idea, because there were certain areas that you' Stanley, Harris, Rice 741-4567 hm ___ _ _ - _ ,_--- - ___._~_.............s..... ..

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                                                                                                                                         .             12
                                    ~
             .                          1                                       were supposed to take out a percentahe'of the
                                      ,2                                         rebar.             If vou cut a hole in the rebar it 3                                        should have been reported and thus ehd so 4                                        forth.

5 Q , In those instances, did you report it?

                                  .6 A,     . . .Yes , I' m , l e gal . - So i's this thing.

7 Q Okay. . 8 A 'But it gives th'e direction'of the.rebar, 9 which way it was running, north, south, east, w es t . 10 It gives the depth that I cut the rebar and it also

                                  'll                    giv es the percentage of rebar, just me looking at a 12                   piece of rebar end saying I cut :fif ty percent, ten 13                   percent or.if 1 just ni.cked it, -ins t whatever after 14                    the hole was drilled,                                                    r.
                             .-    15                                           Q             But on each of'those entries, does it 16                    tell the location os the site out there?

17 A It tells you the location,- what building, 18 what print. number it was taken off of or the hanger 19 number itself. So all you got to do is look up that

                                  - 2.0                  han ger number and it will give you the a r ea as2d 21                    e xa ct location of this particular hanger.

22 Q All right. So any -- which column shows 23 the authorization?

    . .                             24                                           A            This one here.

9

  ,)                                                                                          okay.      So if that column is 15ft blank,
                                  ~25                                            0
          .                                                                               Stanley, Earris, Rice 741-4567                             .

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I then that would be an example?

                                             -2                      A                Not necessarily blank.                              'I don't know how 3            in the hell to put that without sounding silly.

4 Q We are g o.'.n g t o ne e d to identify -- we're 5 not interested in the ones that were done p'roperly.

                                                                                                             '                  ~
                     .[ . ' -(~ 6" 9 e ' r e' on1'y' ,-- w e w a'ht t'                 to 2ook'$tti the ones that were
                        -                     7            done without documentation as required by procedure.

8 MS. ELLIS: We're referring to the 9 fifth column now on the far right. 10 A No, there's teally...not.no way of telling, 11 not withou't looking up the. hanger number and find i.j- .1 2 out what was done on the hanger, Jou will just have 13 to go over each individual hanger.and check the' CMC ~ 14 and see .what was ' legal ~ to cut and what was not legal-15 to cut 16 MS. ELLIS: You might mention, too, ' 17 in this column the ones on the front page all

                            ,             1.8                       seem to have items by them, but on several of 19                        them throughout the listing there were none.
f. . .

20 S o i t ' s no t -- each one of these ithms, in 21 other words, doesn't 'have rebar cut

                                          ~2 2                      necessarily.                            It's just as indicated on there.

23 . Q At this point I was just trying to limit I 24 it to holes drilled without proper authori=ation, , 25 r e ga r dl es s of whether rebar was cut or just

                                                                                  ' Stanley, Barris, Rice 741-4567
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             .                ;1          concrete.             'I f the drill was used improperly, we're 2     .trying to identify those instances.

3 . Can you think of any way with this 4 document or any other documents you may know' exist S that woul,d . lea d..N.RC_i.nspe ct. ors to - specific locations 6' she,r.e' h ol'e's'.[w'er e;d rille d ~with"o'EE~pr ope r - authorizationN Do you see'what we're trying to get?

                                                                                       ~

7 8 A I see exactly what you're trying to do. 9 You're trying to .make your j ob real easy and there's 10 no easy way way to do it. I'm. serious as hell 11 there's fust, ; no . easy way' to go to it ~ because you () 12 have so many th-ings ou' t .there that's been like this,

                              .13      and for me to pinpoint and giveryou an exact area by 14       this or any 4th.er.means -- I might be able to walk                                     1 15      out there and show y.ou things if I walk with'you and                                   j 16      say, this was done here and this was done here.                                 But      !
           ,                  17      you're asking me to remember back three, four years,
                                                                                   ~

18 too, and if you have ever teen in that area, if you 19 go in there a week later it's all different. 20' Q I understand what you' re saying. Can you 21 think of any way th'at I ca'n transmit this 22 'inf ormation to un inspector or to a group of 23 inspectors where we might be able~to identify these? 24 You're right, we are trying to make it easier in G. (j/ 25 that we can't reinspect all the holes drilled at I Stanley, Harris, Rice 741-4567 .

                                             ~

L_ . . l

    . . - . . . . . . .             . .         ~ . ~    - ~ ~ . , . - ~ ~ - ~ ~ - ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~ ~ ~ ~ ' ~ ~ ~ ~ ~ " ' " -     '   '
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y . 15 1 , Comanche Peak since its beginning, since' the 2 foundation was poured. 3 A This rebar didn' t come in until this date - 4 here. - 9 5 Q In other words, we want to address this

               ..       ,-         6. _ potential....p,r o bl em .,                     -

7 A I can't think o'f'the guy's name. There's 8 one area down in the tunne'l what they call the- i.I , -9 tunnel area, and he .was f oreman over it when he 10 borrowed that drill. He cut a bunch.of rebar down 11 in there and it would be a damn ssood place to start. (h 12 - Q If we talked to this man, do you think he 13 would be willing- to -tell us? r-14 A .I.can't think of his mame. Yeah, I do. 15 I really do. I'm trying to think of his name; I 16 can't think of it. 17 Q~ If you cannot remember'his name today

                                             ~

18 would you mind giving us that name when you do

                  ,            19         rehember it?                                              '
                             . 20            !.      A         He's still working out there,-                             He got 21         fi. red and he was -- he wen't into the pipe department 22         a tt Green Hat now.                 He's a welder.                        .

23 . O Do you think you will remember the name 24 eventually? g4/- 25 A If I don't I,' v e got it at home I would Stanley, Harris, Rice 741-4567

             .o    '.       -                                                                                 16
               .        o. . t And if you could I

call you, but he might testify. (phonetic) ,. he was a

                          .2        get ahold of a 3       man -

MS. ELL IS : Do you know how to spell 4 5 that? that. It's 6 A M something like 7 pronounced W but M in M now, I'll 8 tell' you that much. 2 9 Q Now? Well, g marrie.d in the A Yes. 10 11 service is the only r e a so n -- w ell ,g was a year ago. g might.be back over heret, now but M

                                                    ~

12 married to g in the s e rv i ce.. 13 14 Q Ok,ay. 15 A, Bu't W worked and dril. led a lot of holes 16 111ega11y. 17 Q_ Now, these illegal holes that you are 18 referring to that W drilled, this was when the 19 rebar was, or the rebar eater was on loan? also 20 A No, M worked f or % ButW was 21 around and could be a character witness to what $ ac And if 22 stliting as to when S was ordered to do this. d ow n , 23 you could pin that l And if you used to work for me, too. 24 put M on a stand and square @ in,@ will either 25

                 ^

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i tell you about holes g drilled , i perjure @ or I me and now g is in charge l

                                                                                                                                                                                                                  )

2 when g was working f or 3 of that operation. I.f you could pin W down, but that 4 i got 4 sewed down. tight. Ma 5 company has 9 6 puppet. . I'm not an

                                                                                      ;First of allt, 1(t me tell you, 7                         fQ                                                                                               technical engineer.                           I have an engineering or 8

9 background, i! but let me see if I can phrase this. In the holes that were.drille.d by your 10 documentation, can you 11 crew members without proper did you witness any

         #                          12                remembe'r' any isrstances or                                                                                                               or s

instances Nhere damage was done to containment l 13 ~ used 14 any of these o the r a r e a's w h'ir e ' Wed rill -w a s saf ety or health hazard or 15 that would constitute a 16 possible weakening of the structure?

                                                                      .A                   well 17 Q                    I know              that's detailed.

i 18 I have been-A I'm not an engineer either.

                         ,,'           19                                                                                                                                 I have been 20 in steel, I.have been in supervision,                                                                                     designs out there working.

And when an engineer 21 something, W designs it for that particular thing, 22 All cight. If strength. 23 for that particul.ar 24 somebody comes in there and cuts part of that out there's your answer. But I

  )'.                                     25                without documentation,                                                                                                                                  !

I t Stanley, Barris, Rice 741-4567 'l

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4 g 1 not an 'engi ne e r. - 2 Q so you're saying, if I understand you 3 correctly., you're saying that if it's done, then who I 4 knows what the effect will be? 5 A Well, the engineer knows, the engineer i 6' that designed it. If g puts in fourteen rebars 7 there and you cut out seven of them, then you have d g -8 , weakened _ half of them, what K designed it to hold.

             ~                               l
                                                  -And I have went down walls in thit h r*~ -~ ~ a h S       1
           .        1 IT '

o 10 that I was talking about and we ere putting up to 1 hold thirty-two inche lines down there. I saan' t, 1.2 - this g was if I could think of $ name. And we 13- had to rut a bzrnch'of rebar down in ther.e *

                                                                                                                                                                                                 ~

14 This was, I '.m - w el.1., .q u o tis m e if you

                                '1 5             ,w ant to, I think, I i m not.sure, but I think this was 16                an area that wasn't. supposed to have any rebar cut                                                                                               -

. 17 out of it. 18 Q All right. Let me ask you one more time 19 because you have accused me of looking for the easy 20 way. I would like to be able to walk out of this 21 room today and go find examples or i nstances of 22 holes drilled down there without proper 23 authorization. I hope there's some way'we can 24 figure out how that can be done because we would

      -h                                ;
      /                          25     .          like to follow up on this.

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O ~ I 1 A If I could just think of one exact hole l 2 that I could remember. I ke - e %amro Q ~ l

                                                                                                                                            ---= =- . -- w a :Er 3             turbi- - - ,                         -

m-1= s a  ; 4 wmIT. 16 i a . - There's another deal where I would have  ! 5 to go out and it's completely changed over now, and

6. it w o'u l d 'b e.,a spot check between' three or f our- .
                    - '                  7             hangers.

8 C All right. 9 A In fact, out of the three or four;. I 10 think you will find a Hilti-bolt welded on the back 11 side because they couldn't get a hole in the ground. 12 0 What would it take to refresh your memory

                                                                                                                  ~

13 as to a possible location? 14 A I have no 3 dea, The -documents you could 15 get is -- now, this would be Turbine One area which 16 we'uld cut it down quite a bit, Jt's around them 17 tanks that they covered with the aluminum siding and 18 insulation. I don't know what tanks, wha't they are i

                     /                19               called, them big long tanks up on the turbine deck.

l . 20 An) it was right alongside one of then t'a nk s there 21 that three holes re'bar was' cut in without 22 documentation. - 23 . O Was there anybody else present that might 24 be able to further identify, help us identify this M 25 location?

                                                         .--+.
                                                                                                    ~

20 l 1 A There was I should. have r 2 brought my time books with me. I'm'not really sure 3 if- was there or not. 4 Q Ic it your pers6nal' belief that @ S could identify locations? l 6 A reah, I think 3 could, but I doubt if 7 you will get G to do it. 8 Q Is W atill employed by them? 9 A Yes, @ very much employed. 10 Q All right. Well, I'll tell you, let's i i 11 move on. W have got several oth e r

                                                           ,e                                                               X--

h 12 s y WS , ELL IS : Perhaps 1.f you had M

                           .13                                 appear under these. circumstances, you e

14 know, sw or.n with .a stenog.r.a pher and so f or th , 15 maybe it might enable M to say things that @ 16 mig'ht not feel comfortable saying not under 17 oa t~h . 18 A 2 seri.ously think M would. 1 have 1 19 known M f or quite a few years. I went through a

                                                                                                                                                          )

20 divorce with M and everything else when M was

                                                                                                                .                                         i
               .          21       working for me.                   But right now that company has got 22      % bought and paid for.

23 Q I can assure you the NRC is not bashful 24 about going and asking, so we will -- 25 l MR. HERR: I have one question I (~ ' Stanley, Harris, Rice 741-4567 . J . e

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                                 'I                             would like to ask.                       Did you see any of these 2                            people using the drill improperly?                                                      I know you 3
  • said you loaned them the drill out, buh did you 4 ever see them use it? .

5 THE W ITNESS : Oh, yeah. 6 MR. HERR: And that was during the 7 . time f rame -

                                ,8                    ,

THE WITNESS: That was during this t 9 [ time f rame that this covers. 10 , MR. HERR: Okay. That's the only , 11 . question I have. - 'N- . 12 Q Will t.ha t document that you are providing

     -) .

13 - -us., wil.1 examination of this document, say, by an 14 engineer, would .it 1:ead to any locations where such 15 holes were drilled? Seems- thi.s fif th columns seems 16 to.be f.111ed in. 47 A - What I would do if I was you, I would go 18 pull these CMC's and DCDDA.all through 1.t with an 19 engirteer, bump it against the number of the hanger 20 and see what was authorized to cut and what was not 21 authorized to cut, and then come back and bump it a n n *

  • i,4 ifm 22 against this, o

_ hnnr* * -Pr'+u- )

                             ' 23               ;. .' . - t           e---: :      '1~ 1 e rs = U u ?                 1      r- :          t-
                                                                                                                                                -"%'4 24 -           aunateu pecvent.

25 0 -Qoa-youtn-ink pWhc6da nd ofsam pl 2 rip

                                                                      ~

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                          ~1          done like that is going to reveal ins ta nc'e s of holes!

2 cut without author 1=ation? 3 A Uh-huh (affirmative). I really do,  ! 4 MS. ELLIS: It would seem to me on 5 that third column there where it shows the

      -                    6                     amount that was cut out, th'at it wodid be 7                     prudent at least to check all the ones where it 8                      says a hundred percent or maybe as much as S                      fifty percent.have been cut out.

10 A Because the way I understand that, on the

11 first part, all this -- these D'CDDA's and all.that 9j 12 and the three parts were all illegal. .-

13 , Q You : mea n whe re it .says _DCDD A7 14 A Yes. 15 Q Those are 11' legal cuts? 16 A At the beginning they were, and then they 17 changed it to a CMC. Now, if they went back and 18 covered their butts on that DCDDA I don't know. 19 Q If we checked all the ones that -- the 20 DCDDA and checked that number it might lead us to

                                                                                                         ~

21' locations? 22 A I would try that first and find out if 23 this was a legal document, because according t 24 th e engineer, that s all wrong until he s,/ 25 com'e up with the CMC -- talk - CMC i dea that Stanley, Earris, Rice 741-4567 -

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l had to be wrote by a specific engineer. 2' Q As I flip through here, I only see that 3l DCDDA recorded twice. Are some of these other items 4 also that type of number? _ 5 A All right. Here's-one that was wrote on an,RF'IC. ' 'T,h'a t w as illegal, t o o ."

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And a DCDDA -- 7 MS. ELLIS: 'Are all of these numbers 8 here, are those all -- 9 THE WITNESS: They could be CMC's and 10 they could be DCDDA's. I'm not real sure about 11 which they were. God, that's been, ' 787. {) 12 Q Right, f 13 A I really 'need to sitwdown -- I haven' t 14 looked at this other than a couple of days ago since 15 I have been out of it, and I could probably sit down 16 with somebody, and be glad to, to try to more or 17 less interpret exactly how it was wrote and what _ it 18- is. . 19 , Q Okay. We would greatly appreciate that. 20 A I would. I will; I'll be gla'd to do it. 21 . MR . 'G RI F F IN': Do you have any more 22 questions, Dick? 23 MR. HERR: No. , 24 Q Tell me now, you say, if I understand 25 correctly that this unauthorized use of this rebar Stanley, Harris, Rice 7 41-4 5 67~ . e .h 3' -w , g--m A _ <+ w ,T---- += .sc -c.s-

s4 U . 1 eater, is it truc you were th reatened with 2 termination if you f ailed to loan it out -- 3 A If I f ailed to do anything that this man 4 said as far as that rebar enter loan-out or drill 5 bits or the whole operation or failed to drill 6 something myself and'my crew, I'was told that I d'dn't do it.

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7 , would be te rmina te d if I i 8 0 Tell me what his name is again. 9 A You have to understand out 10 there exactly what the deal was. At that time 11 was the superintendent.. was, I 12 guess, and had 13 never done any *ind of work lika that in his life 15 had 16 one thing.out of his mouth, and that was producti 7. 17 He didn't come.out and say it, but he didn't give a 18 damn how you got it --

              ,             19                                 Q                         okay.

20 A -- as long as it showed up on paper. He 21 wanted production,.'he want'ed pipe hangers up,'he _ l 22 wanted cable tray supports up and he wanted them o'n l 23 the wall and completed and bought'off. He didn't 24 give a damn how they were put up, and this is what 25 did. And in doing soi if they ran into l Stanley, Harris, Rice 741-4567 -

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d 25 i D' 1 a problem, you've got to to' figure some holes were . 2 drilled, a. hundre,d and something holes f or one 3 hanger to try and find a decent spot to hang it 4 without hitting rebar. ,This brings on f rustration 5 on the men, they go'to their foreman, the f'oreman l 6 .goes to says go down and

                    ..            7        see                          an'd drill'the damn thing and put it up.

8 Q I understand. Let's move on. You stated 9 in your, af fidavit. to CASE that you observed or 10 witnessed the use'of the polar (.ph o ne tic ) crane to 11 pull up a piece of thirty-two inch pipe; is that

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                   ..          13                       A            That i.s abi~o'intely__ccrrect.

14 Q I'm mot an engineer; 2 don' t' understand 15 the significance of this. Could you explain it to 16 me, p1_ea s e ? 17 A All right. What.it amounts to is the 18 main steam pipe has a condensation joint like for -- 19 expansion j oint is what it's called. It's a huge ! 20 horsesh'oe type shape, and this thing is' coming out i . . 21 of the turbine building. All right. This 22 thirty-two inch main steam pipe, it's com'ing out -- 23 it's anchored in c.oncrete all. the way around it,. 24 it's a fixed object, you can't move it, right? It h,\ V' 25 comes into this expansion joint, makes huge Stanley, Harris, Rice 741-4567

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                                           \\                                          sit avan etara onivt. suiti sooo ARL NGloN.1( X As M011 ASSISTANCE TO INSPECTION REPORT May 20, 1983

SUBJECT:

  • COMANCHE PEAK ALLEGED IMPROPER CONSTRUCTION PRACTICES REPORT' NUMBER: A4-83-005 On February 3,1983, % provided an affidavit to the Citizens
1. CASE), an intervenor that included three alle-Association for Sound L Brown & Root personnel at gations regarding improper construction practices lieged the following:

the Comanche Peak Steam Electric Station.

a. That Brown & Root employees drilled ut. documented unauthorized holes' through rebar, and such cutting of rebar was done at the direction of supervisors.
b. That the main steam line pipe in Unit I was moved using the polar crane, tiiereby placing the pipe under unsafe tension.
c. That a Brown & Root employee used a cutting torch on hanger material in viplation of procedure.
2. On April 6, 1983, ontacted by the reporting investi " r, and a for the following day. ontacted meeting was arrang with reporting investigator on April 7,1983, and requested the meeting be changed to April 8,1983. .

On A ril 8,1983, NRC 01F0 Director R.K. HERR and the r 'ng investigator

3. as accompanied met at a restaurant in Fort Worth, Texas.

by s. Juanita ELLIS, a CASE representative, and Ms. LLIS' husband. Ms. ELLIS wished to record the meeting; however, 01FO:RIV was not previously informed of her intended presence nor of her desire to record the interview. 01F0 did not have a recorder, and in accordance with OI's policy, the meeting was rescheduled. On April 10, 1983, arrangements were made to use a room at the U. S. Attorney's office, Fort Worth, Texas, and for a court reporter to transcribe the interview of g

4. On April 14, 1983, as interviewed at the U.S. Attorney's office with Ms. ELLIS present. testimony was taken under oath, Attachment (1),

and Ms. EttIS rr2de her own personal recording of the interview In his testi-mony, p panded in detail on his original allegations. @. named Brown 6 Root employees responsible for the alleged improprieties ano tnose who could substantiate his allegations. % lso identified numerous employees by title, and agreed to la rovide the corresponding names when he was able to refr e his memory with his personal records located 4t3is_ residence. e kiso provided the NRC with a copy of a log. M N e m explained fiE ne maintained this log to document the cutting of recar at Comanche Peak. id not allege that all the entries in (Note: the log documented una s i . rizeo cuts through rebar, but rather that some of the entries in the log may have been for holes drilled through rebar that may not have had the appropriate accompanying authorizations.) During this interview, @ made a fourth allegation regarding instances of b&a W ~~ 44/03N%$ C/g -

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          , i-A4-03-005 Page Two Brown & Root welders failing to purge stainless steel pipes during welding.

l 5. On April 21, 1983, a copy of the recorded testimony was mailed to M at his residence. On April 27, 1983, 6 was contacted by HERR, and acknowledged receipt of the transcript, but postponed giving the names of the Brown & Root employeef he had identified by title in the transcript. g stated he had not as yet had an opportunity to read his entire testimony. un April 29,1983,6 was again contacted by HERR, but he again postponed providing the names, explaining he was very busy. On May 1,198 the i reporting investigator telephoned M at his residence, and provided twelve, additional names of Brown & Root craployees at Co e Peak he alleged had knowledge of unauthorized cuts through rebar.

6. On May 3,1983, interviews were initiated at the Comanche Peak site addressing the four allegations. identified 38 individuals allegedly responsible for, or having knowledge , the allegations. Review of employment records determined that eigliteen individuals were no longer employed at Comanche Peak.
 .        i.       Between      May 10, 1983, 19 Brown & Root employees and 1 Dravo Constructors         Inc,3,1983 employee  and May(formerly employed by Gibbs & Hill) named by Mwere interviewed, and signed, sworn statements dre taken from 19 of them. One Brown and Root employee interviewed left on vacation before a signed, sworn statement was obtained from him, and his testimony was recorded inythe form of a Results of Interview. One Piping Design Serivces Inc.

engineer was identified by the reporting investiga. tor as responsible for the movement of the main steam line. This engineer was interviewed, and executed a signed, sworn statement. _

8. Nine individuals alleged to have knowledge of improper, unauthorized cutting of rebar were interviewed and provided sworn statements. These individuals denied having kn:wledge of rebar that was cut withcut proper authorization. A 10th individual responsible for issuing the Com;a.nent Modification Cards (CP.C), j authorizing cuts through rebar, was interviewed and provided a signed, sworn  ;

statement denying.knowl, edge of any procedural violations. Testimony identified i instances where rebar was accidentally cut, but this testimony also established that in these instances, CMC's were obtained after the cuts were reported to the enigneers. There was no testimony received indicating that holes were drilled or rebar was cut without proper docun.entation, and no evidence was 1 found to contradict the testimony?.-of these individuals. _ i

9. Three Ero,en & Root employees alleged to have knowledge concerning the use of l the polar crane to move a portion of the~ main steam line in Unit I were inter- l viewed and provided signed, sworn statements. A Piping Design Services Inc. l engineer responsible for relocating the steam line, provided testimony of his evaluation and direction of the relocation of the line. The testimony taken from these four witnesses indicated that the relocation of the main steam line was done under s th.e direction of engineers, and was accomplished to remove ,

stress on the line and to return it to its designed location. No testimony was I recieved to indicate that the line was " cold sprung" or installed under stress. i I

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i.' ' .:.: A4-E3-005 Page Three

10. Eight Brown & Root employees alleged to have knowledge concerning the improper use of cutting torches on hanger material were interviewed. Two witnesses stated they remember.cd an instance during the redesign of a hanger in which a piece of tube steel was discovered to have had the bolt holes enlarged using a torch, which was a procedural violation. The testimony of the two witnesses indicated that this hanger was scrapped because of the procedural violation, and was replaced with new material. The other six had no knowledge of improper use of cutting tqrches or hangers.
11. Two Brown & Root employees were in,t,er; viewed concerning their alleged knowledge of lugs improperly welded onto stainless steel pipe without purging the pipe.

Both executed signed, sworn statements, and indicated that they did not know of any instances where welding was done on stainless steel pipe which required purging by procedure unicss a " purge deletion" was roccived from the engincers.

12. All of the employees mentEI) d by g in his affidavit who wera still employed or available for i,nterview cenied the allegations made b fio evidence was uncovered'$uring f these inquiries which indicated deception on Ithe part of'the witnesses. The witriesses ranged from pipe fitter helpers to Brown & Root superintendents. A Piping Design Services Inc. engineer and the Dravo Constructors Inc. project manager also provided testimony which contra-didifthe allegations.
13. The signed, sworn statements are maintained in 01F0:RIV. lio further inquiries are anticipated unless staff inspections identify additional pertinent information that would tend to substantiate the allegations or discredit the interviewees.
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Attachments: (1) Testiccr.y - dated 4-!4-83 (2) List of Interviewees , (3) List of termir.ated c .ployces ider.tified in Attachment (1) REPORTED BY: 7e fo H. Brooks Griffin, fr.vestigator 01 Field Office, Region IV APPROVED BY:  % . (( f-icnard K. He'rr, Director 01 Field Office, Region IV cc: W. Ward, 01:DF0 - w/ attachments J. Collins, RIV - w/ attachments E. Johnson, RIV - w/o attachments

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