Text

M Gregory Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc Encl
	ML20215K295
Person / Time
Site:	Comanche Peak
Issue date:	06/15/1987
From:	Roisman A; GREGORY, M., ROISMAN, A.Z.
To:	; TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20215K256	List: ML20215K251; ML20215K295;
References
	CPA, NUDOCS 8706250286
	Download: ML20215K295 (22)
	v • d • e

_

As

q. .

[h

s UNITED STATES NUCLEAR REGULATORY COMMISSION l Before the Atomic Safety and Licensina Board l i l

In the Matter of )

)

TEXAS UTILITIES ELECTRIC COMPANY, ) Dkt. No. 50-445-CPA et al., )

) l (Comanche Peak Steam Electric Station ) l Unit 1) )

HEDDIE GREGORY'S RESPONSE TO APPLICANTS' INTERROGATORIES TO " CONSOLIDATED INTERVENORS" (SET NO. 1987-1)

AND MOTION FOR A PROTECTIVE ORDER General Objection This response incorporates by reference the following materials:

1. CASE's Response to Applicants' Interrogatories to

" Consolidated Intervenors" (Set No. 1987-1) and Motion for a Protective Order, 6/6/87.

2. Petition to Intervene of Meddie Gregory, 4/7/86; Petition to Intervene of C.A.S.E., 4/7/86; consolidated Intervenors' Motion to Admit Contentions or, in the Alternative, For-Reconsideration of Certain Previously Denied Contentions, 9/30/86; consolidated Intervenors' Reply to Permittees' and Staff's Responses to Motion to Amend Contentions, 10/22/86; consolidated Intervenors' Motion for Reconsideration, 11/4/86; and any other filings or oral arguments by Meddie Gregory or Consolidated Intervenors that deal with the bases for contentions, including all documents referenced.

3. Safety Evaluation Reports, Supplements 7 - 11, and the three TRT letters to Applicants.

4. All CPRT Results Reports, including yet to be released reports, and all discrepancies, deficiencies, deviations, or other differences from the original standards, checklists, procedures, and requirements identified by the CPRT, other consultants, and TUEC consultants, contractors, and subcontractors since

"~

8706250286 870615 PDR ADOCK 05000445 Q PDR

1 s

August 1984 with respect to all previously completed and inspected work, including design work, construction work, and QA/QC work on Unit 1 of Comanche Peak Steam Electric Station.

5. All NRC trend analyses (by whatever name), draft trend analyses, inspection reports. caft inspection reports, and other documents that ide ;fy discrepancies, deviations, deficiencies, or other differences from the original standards, checklists, procedures, and !

requirements applicable to Unit 1 of CPSES.

6. All reports, draft reports, briefings, or substantive !

informational communications (including minutes or I notes of meetings or phone calls) of consultants, !

auditors, or independent contractors relevant to the compliance of TUEC with NRC and/or plant procedures, standards, requirements, or checklists, including the Cresap audit (s).

7. The discovery materials and evidence to be presented at trial by the minority owners against TUEC in the state )

court litigation.

Applicants' discovery request seeks to know what they should already know. They know, or should know, far better than Meddie Gregory, what past mistakes they have committed that caused them to fail to complete Unit 1 on time. If after more than two years l i

of work they do not yet know why Unit 1 was not properly built in i 1

the first place, then the problem is far more serious than even we have imagined. It is significant, however, that after all I this time the lead Applicant has not once attempted to present any comprehensive explanation of how it happened that Unit I was built with such a major neglect of safety requirements that it l has had to be subjected to the massive reinspection, redesign, and reconstruction program that is now going on. Even in this proceeding where the Commissioners have ordered the parties to focus their attention on why Unit 1 was not properly constructed i

within the time available, Applicants have offered no explanation j l

for their dereliction. The most powerful evidence that Meddie Gregory's contentions are correct is that the party with the burden of proof in this proceeding has offered nothing in the way of evidence or explanation to support its position. See, e.g.,

Applicants' Request for Extension of the Construction Permit I l

Completion Date for Unit 2, 4/29/87. !

1 In these circumstances, Meddie Gregory objects to answering any questions beyond the information incorporated herein by reference, items 2-7. To answer more is to function as an unpaid auditor for Applicants. It is their duty to first set forth, as they would if this were a license application and they had filed an FSAR, the basis for their case. Until they do that -- in effect, file a statement of particulars in support of their application by detailing why Unit 1 was not built properly in the first place and what is now being done to avoid repeating those mistakes -- Meddie Gregory cannot and should not be expected to provide the information sought. Such detail, beyond what has already been pled, will be provided well in advance of hearings after Applicants have presented their basic position. To do so before that time is premature, particularly since detail beyond that originally pled by Consolidated Intervenors has not yet been assembled by Meddie Gregory. See Memorandum and Order (Discovery Sets 1987 6,7), 6/2/87, in Dkt. No. 50-445,446-OL. Meddie Gregory seeks a protective order.

=

1 l

Without waiving this general objection, and in the spirit of 4

cooperation, Meddie Gregory has decided to answer the questions J l

to the extent she is able and to the extent information requested j has been assembled by her. Her answers in each instance are i

supplemented by answers given and/or to be given by CASE. Thus, 1

for a number of questions, no answer is provided with this l

response. Also as part of her answer Meddie Gregory includes a l l

statement attached to this pleading and offers an appropriate l 1

representative of Applicants the opportunity to visit her at her home in Glen Rose to inspect and copy any documents in her 1

possession relevant to this discovery and to take her deposition.

Additional Answers 1 Pursuant to 10 C FR 9 2. 7 4 0 ff, the Applicants propound the following interrogatories to Consolidated Intervenors.

As used in these Interrogatories, the following terms have the i following meanings:

" Identify" with respect to a person means to state the name, business / corporate title and business / corporate address.

" Cite" with respect to documents means to state its date, its author, the type of document, the document's title (if any) and its present location (if known). l l

" Person" means natural persons as well as business entities.

" Document" means any printed, typewritten, handwritten or otherwise recorded material of every nature.

" Consolidated Intervenors", "you" and "your" refers to Meddie Gregory and Citizens Association for Sound Energy or either or l both. ;

1 I

1 These answers are based on present knowledge without the benefit of full discovery from Applicants. They do not represent the final positions that Meddie Gregory will pursue during the i hearings nor the evidence on which she will rely.

4 l

. d*

l You have alleged (Amended Contention 2) that:

"The delat in cons truction of Uni t I was caused Applican ts ' in ten tional conduc t, which had no valid purpose'and was the result of corporate policies which have not- been discarded or repudiated by Applican ts. "

1. With regard to your allegation, please specify all instances of the Applicants' " intentional conduct" upon which you base your allegation. In your response, please:

a) Identify all person (s). who engaged in this intentional conduct.

b) Specify the date(s) upon which the conduct was <

undertaken.

c) Explain precisely how the alleged intentional conduct caused a delay in construction of Unit 1; and, i d) Cite all documents which support your conclusions.

2. What do you claim was the purpose of the Applicants'

" intentional conduct?"

a) State all-facts upon which you base your claim that the alleged purpose is " invalid "

b) Please identify all persons having knowledge of the facts described in your answer to Interrogatory 2a.

3. List all the " corporate policies" which the Consolidated i Intervenors refer to in Amended Contention 2; and with respect to each:

a) Identify the person (s) who formulated or promulgated the " corporate policies".

b) Specify, with as much precision as possible, the date(s) upon which these " corporate policies" were formulated or promulgated.

c) Specify when each corporate policy was first implemented?

d) How was each " corporate policy" implemented?

4. Identify any action by the Applicants' upon which the Consolidated Intervenors rely to support the contention that the Applicants have not discarded or repudiated the alleged

l

" corporate policies," and include a description of: l l

a) Who undertook the action? !

b) When the action occurred?

c) Cite all documents-which make reference to the alleged action by the Applicants.

With regard to the alleged bases for Amended Contention 2:

5. Identity the document which the Consolidated Intervenors refer to in Footnote 2 zus supporting the alleged ba,ses.

With regard to statement of Basis A.1, viz.:

" Applicants deliberately refused to take posi tive action to reform their QA/QC program in the face of consistent cri ti cism, . . ."

6. Please specify each and every instance in which the Applicants have refused to take positive action to reform their QA/QC Program; including in your answer:

a) A precise definition of the " positive action" which i was refused.

b) The identities of the person (s) who deliberately refused to take " positive action."

c) The dates on which the alleged " deliberate refusal" took place.

d) The exact manner in which each deliberate refusal was made manifest, and e) A citation to all documents which refer or relate to the " deliberate refusal."

7. Describe all criticism (s) to which the Consolidated Intervenors refer to in its statement of basis A.1.

8. With regard to each alleged criticism identified in response to Interrogatory 8, please answer the following:

a) State the source of the alleged criticism.

b) Indicate the date(s) the alleged criticism was made.

c) Was the alleged criticism communicated to the Applicants?

d) If the alleged criticism was communicated to the Applicants, identify the person (s) to whom it was communicated.

e) If the alleged criticism was communicated to the Applicants, indicate the manner in which the Applicants were informed, f) State the dates on which the alleged criticism was communicated to the Applicants.

g) Cite all documents which indicate the existence of the alleged criticism and all documents which indicate that the alleged criticism was communicated to the Applicants.

With regard to statement of basis A.2, viz.:

" Applicants have failed to properly design their plant, specifically:

a) Applicants failed to correctly apply fundamental engineering principles, b) Applicants failed to properly iden ti fy unique designs in their PSAR, c) Applican ts constructed much of their plan t prior to i ts design having been completed, d) Applicants have failed to comply with 10 CFR Part 50, Appendices A and B, including their failure to promptly identify and correct design deficiencias, and delibera tely refused to take posi tive action to correct such a'eficienci es. "

9. List every instance where the Applicants have " failed to correctly apply fundamental engineering principles.

10. For any instance listed in response to Interrogatory 9, please answer the following:

a) Specify which fundamental engineering principle was allegedly violated.

b) State the sources from which you derive the engineering principle.

c) Identify the person (s) who allegedly failed to apply the engineering principle.

d) State the date(s) on which the alleged misapplication occurred.

e) Cite all documents which reference or support your conclusion that such a failure occurred.

1

11. List each " unique design" that the Applicants failed to

" properly identify" in their PSAR.

s 12. For each design listed in response to Interrogatory 11, please explain the basis for your conclusion that it was/is

" unique." _

13. List every aspect of the plant which was constructed before its design was completed, and include an explanation of any/ principle or requirement which dictated any different sequence of design and construction from that employed by the' Applicants.

14. List every section of 10 CFR Part 50, Appendices A and 8 that the Applicants have not complied with.

15. For every section of 10 CFR part 50, Appendices A and B identified in response to Interrogatory 14, please answer the following:

a) Explain the precise manner in which the Applicant failed to comply with the specified section.

b) Indicate the date(s) the alleged failure to comply took place.

c) Identify all person (s) who were involved in this alleged failure to comply.

di Cite all documents which indicate that the Applicants allegedly failed to comply.

16. List every instance where, in the Consolidated Intervenors' opinion, the Applicants failed to promptly identify design deficiencies.

17. List every instance where, in the Consolidated Intervenors' opinion, the Applicants failed to correct design deficiencies.

18. List every instance where, in the Consolidated Intervenors' opinion, the Applicants " deliberately refused" to take positive action to correct deficiencies.

With regard to statement of basis A.3, viz.:

l

.r 1

" Applicants ignored consisten t criticism of their QA/QC i program over a period of at least ten years and of their design over a period of a t least four years, in the facs of warnings by independen t auditors, the NRC, and ev3n the Atomic Safety and Licensing Board. As a result of these deliberate actions, Applicants built an unlicensable plant which must now be reinspected, redesigned, and reconstructed in the hope that i t can be made licensable. There is no valid purpose given by ;

Applic sn ts for why, in the face of these cri ticisms, they-refused to change their QA/QC implementation or address and correct design deficiencies. " ,

l

19. Identify all criticism of the Applicants' QA/QC program I which the Consolidated Intervenors allege the Applicants have ignored.

20. For each criticism identified in response to l Interrogatory 19, please answer the following:

l a) State the source of the criticism.

b) State the date each alleged criticism was made. I l

c) Detail the date and manner in which the criticism j communicated to the Applicants. !

d) Cite all documents which indicate the existence.of the alleged criticism and all documents which indicate that the alleged criticism was communicated to the Applicants.

21. Identify all criticism of the Applicants' design which the Consolidated Intervenors allege the Applicants have ignored.

22. For each criticism identified in response to Interrogatory 21, please provide the following:

a) State the source of the criticism.

b) State the date each alleged criticism was made.

c) Detail the date and manner in which the criticism communicated to the Applicants? ]

I d) Cite all documents which indicate the existence of the alleged criticism and all documents which indicate that the alleged criticism was communicated to the Applicants.

23. State the Consolidated Intervenors' understanding of how the Applicants " ignored" the alleged criticism; and

i a) Identify the person (s) who the Consolidated Intervenors allege " ignored" the criticism.

b) State why the Consolidated Intervenors assert the alleged action was " deliberate".

c) Cite all documents which indicate that the alleged criticism was ignored.

24. List every warning by independent auditors to which the Consolidated Intervenors refer in statement of basis A.3.

25. List every warning by the NRC to which the Consolidated Intervenors refer.in statement of basis A.3.

26. List every warning by the Atomic Safety and' Licensing l Board to which the' Consolidated Intervenors refer in statement of basis A.3. ,

27. List every instance where the Applicants refused to change their QA/QC implementation.

28. For every instance listed in response to Interrogatory 27, please answer the following: ,

a) Identify the person (s) who so refused.

b) Indicate on what date(s) each such refusal was I manifest.

1 c) Cite all documents which support or relate to each refusal.

29. List every instance where the Applicants have refused to address and correct design deficiencies.

a) Identify the person (s) who so refused.

b). Indicate on what date(s) each such refusal was manifest.

c) Cite all documents which support or relate to each refusal.

I With regard to statement of basis B, viz.:

" Applicants have never acknowledged tha t this or any l o ther corpora te policy was the cause of the delay or l tha t anything in the con trol of corpora te managemen t caused the delay, and thus Applican ts have never discarded or repudia ted the policies tha t caused the l

delay. .This basis is supported by the absence of any statemen ts of repudiation and of any stated in tent to discard any corporate policy."

30. Do the Consolidated Intervenors agree with the following statement:

"The Applican ts canno t discard a corpora te policy which the Applican ts have never adopted. "

Answer to Int. 30: I Depending on the definition of the words used, yes.

31. If the Consolidated Intervenors does not agree with the statement in Interrogatory 30, explain why.

With regard to statement of basis C, viz.:

"Applican ts have actually con tinued in place the corporate policies and personnel primarily responsible for the original delay."

32. List all the " corporate policies" to which the Consolidated Intervenors refer in statement of basis C.

33. Define the phrase "attually continued in place" as used in statement of basis C.

Answer to Int. 33:

i Applicants followed the same policy even after it was 1

obvious that Unit 1 had not been properly constructed. '

l

34. Define the phrase " original delay" as used in statement of basis C.

l Answer to Int. 34: j The delay caused by the failure to follow proper procedures and to comply with NRC requirements when first designing, inspecting, and/or constructing Unit 1. ,

i

_11 I

35. List the personnel who are "primarily' responsible for the original delay."

With regard to statement of basis C.1, viz.:

"The people running the plant now are most of the same persons who*made the original decision to ignore the legal requiremen ts for building the plant in order too build it fas t e r. Applicants' September 16, 1986, Supplemen ta ti on to Answers to the Consolidated In tervenors ' In terroga tori es to Applicants (August 27, 1985)."

36. Identify each of the person (s) to whom the Consolidated Intervenors refer as " running the plant now" in statement of basis C.1.

37. When was the " original decision" made which the Consolidated Intervenors refer to in statement of basis C.1.

Answer to Int. 37:

We do not know.

38. List all " legal requirements for building the plant" which you contend were ignored.

Answer to Int. 38:

10 CFR Part 50, Appendix B.

With regard to statement of basis C.2, viz.:

"Applican ts ' redesign, reinspection, and reconstruction program is in fact a continuation of the previous corporate policies which caused the delay."

39. Please describe precisely each and every one of the

" previous corporate policies which caused the delay."

I l

1 1

A Answer to Int. 39:

Applicants insisted on finding the shortcuts to building Unit 1 by creating new and hitherto unaccepted theories about the meaning of NRC licensing requirements, industry codes, and plant procedures. Employees who refused to go along with this approach were disciplined, harassed, intimidated and/or fired.

Inexperienced personnel were used extensively to avoid employees who had preexisting knowledge that would-conflict with the approach being taken by Applicants. Warnings from the NRC and independent auditors that Applicants had the wrong attitude and wee following incorrect procedures were ignored.

40. Please describe precisely the " delay" which you contend resulted from such corporate policies.

Answer'to Int. 40:

See Answer to Interrogatory 34.

With regard to statement of basis C.2.a. viz.:

"The CPRT is not sufficiently independent from TUEC since all Judgments on the safety significance of deficiencies and disposition of NCRs, design changes, and reconstruction are made by TUEC personnelt many of whom, like Messrs. Tolson, Brandt, Purdy, and Finneran (all now employed at CPSES), made'the original Judgments tha t allowed the deficien t condi tions to exi s t .' " :

41. Please list all " original judgments" referred to by the Consolidated Intervenors in statement of basis C.2.a, and >

identify the personnel who made each such " original judgment."

42. Please list all the " deficient conditions" referred to by the Consolidated Intervenors in statement of basis C.2.a.

e

43. Please identify each and every TUEC personnel referred to by the Consolidated Intervenors in statement of basis C.2.a.

44. Please identify each and every CPRT " judgment [] on the safety significance of" a deficiency (as defined in the CPRT Program Plan) which the Consolidated Intervenors contend was "made by TUEC. personnel."

45. Please identify each and every CPRT " judgment [] on the safety significance of" a deviation (as defined in the CPRT Program Plan) which the Consolidated Intervenors contend was "made by TUEC personnel."

46. Please define exactly how much " independence" would be

" sufficient" and include in your answer all references which you contend support the requirement for such independence.

With regard to statement of basis C.2.b., viz.:

"CPRT reinspections are being conducted without complying with Appendix B, thus making trending, documen ta tion , and any verification of the work performed impossible. "

47. Identify which CPRT reinspections you contend are being conducted without complying with Appendix B.

48. Do you contend that any of these CPRT reinspections are required to comply with' Appendix B?

49. Please explain, with adequate citation or references, thebasisofyoi{rcontention.

.I e

Answer to Int. 49:

Objection. Seeks a legal conclusion. Protective Order requested. !

I

^

l

50. Please state each and every reason why the Consolidated Int.ervenors contend that CPRT reinspections are impossible of trending.

51. Please state each and every reason why the Consolidated Intervenors contend that CPRT reinspections are impossible of documentation.

)

I

52. Please state each and every reason why the Consolidated Intervenors contend that CPRT reinspections are impossible of verification.

With regard to statement of basis C.2.e, viz.:

"The work tha t Applican ts propose to conduct under the extended' cons truc tion permi t represen ts major changes in the original proposed construction and design and cannot be lawfully undertaken unless the construction 1

permit is amended. No such amendmen t has been sough t or received. This policy of ignoring the procedural j requirements of the NRC regulations has caused many l problems, including a construction work halt to awai t l

-staff approval of the proposed extension of the construction permit, which Applicants had allowed to expire wi thou t seeking a renewal . "

53. Please specify the precise manner each respect in which the Consolidated Intervenors contend in which "the work that the Applicants propose to conduct under the extended construction permit" is contended to " represent major changes in the original proposed construction and design," including in your answer the exact proposed work which is the basis of this contention and the source and content of the " original proposed construction and design" from which it is alleged to deviate.

54. Please specify the " law" which supports your contention that the proposed work "cannot be lawfully undertaken unless the construction permit is amended."

a) Identify the person (s) who formulated or promulgated this policy.

b) Specify, with as much precision as possible, the date(s) upon which this " policy" was formulated or promulgated.

c) Specify when this policy was first implemented or made manifest?

d) Describe how " policy" was implemented?

Answer to Int. 54:

Objection. Seeks a legal conclusion. Protective Order requested.

a a 55. please specify the precise " policy of ignoring the procedural requirements of the NRC regulations" to which you refer, and:

56. Please list each and every one of the "many problems" which you contend were caused by this policy.

)

With re2ard to statement of basis D:

57. please identify the precise basis for your contention that the Applicants must " adopt and implement a redesign, reinspection and reconstruction program that contains at least (the elements listed in D.1-7]", including in your answer the 1 legal source of the requirement for each such element.

l Answer to Int. 57:

Objection. Seeks a legal conclusion. Protective Order requested.

l with regard to expert testimony:

58. Do the Consolidated Intervenors intend to offer the {

testimony of an expert witness in support of their contentions? l If so, please state, for each such witness: l

a. The identity of the witness;

b. The subject matter on which the witness is expected to testify; I

c. The substance of each fact to which the witness is expected to testify;

d. The substance of each opinion to which the witness is expected to testify; and

e. A summary of the grounds for each such opinion.

1 j

l

o f

Answer to Int. 58:

Meddie Gregory does not know the answer to this question at this time.

All answers above are true and correct to the best of my knowledge and belief.

Respectfully submitted, i

MEDDIE GREGORY P.O. Box 152, 407 Ross Street Glen Rose, TX 76043 (817) 897-3345 60,U+ > Man ANTHONY Z. $0ISMAN /'

Suite 600 /

1401 New York Avenue, NW Washington, DC 20005 (202) 628-3500 (As to Interrog& tories objected to and argument.)

Counsel for Meddie Gregory Date: June 15, 1987 i- ,

(

\. a.

6 ,

e I

My name is Meddie E. Gregory. I was employed by Brown and Root in their QA/QC Department, ASME Section, at the Comanche Peak Steam

. Electric Station in Glen Rose, Texas from May 1962 until July 13, 1984. During the time I worked for Brown and Root I trended Certified Material Changes (CMC's), reviewed the final documentation, and trans-mitted the documentation to ANI and the Vault. I also worked with Dobbie Hatley in the Document Control Center when there was no other work for me to do. Prior to working for Brown and Root I had worked as an Engineering Draftsman and Technician for^ twenty four and a half years, which included Structural, Architectural and other related fields. - Therefore, my concern over the safety of CPSES is due to my experience in the field of Engineering and what occured during my employment at the plant.

Applicants failed in their responsibility to establish and ex-ecute a quality assurance program as required by 10CFR50 Appendix B, Criteria I. General requirements set forth in 10CFR50, Appendix B, governing the establishment and execution of a Quality Assurance Program for a nuclear facility includes quality control. As used in this appendix, " quality assurance" comprises all those planed and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.

Quality control is the quality assurance action that comprises act-ivities related to the physical characteristics of material, structure, component, or system predetermined requirements. Meeting.the quality assurance -criteria outlined in 10CFR50, Appendix B is a legal require-ment governing nuclear facilities.

1. The evidence presented during the ASL3. hearings was sufficient to show a complete breakdown in the quality control program during the fabrication and installation of the Stainless Steel liner plates in both units one and two. I myself reviewed the liner plate documents obtained in discovery for unit two spent fuel pool and found what I beleive to be falsification of documentation. I know for a fact from overhearing Dwight Woodard order Sue Ann Neumeyer to sign off the liner plate documents that the falsification did occure.

2. Applicant down graded the Liner plate documents in the scent fuel and transfere canal from ASME (safety related) to NON-ASME (non safety related), but.in the latter part of 1983 I received a notice from another nuclear plant. It stated in short, that one of the liner plates in the transfere canal had come loose, the water had drained cut of the canal within minutes, and if there had been fuel rods in trans-it at the time, it would have resulted in a melt down when the rods were expeced to the air.

e 6

3 Evidence presented durin6 the ASLB hearings also proved that QC Inspectors were haressed and intimidate not only by Brown and Root, but by Applicants themselves. There would have been no reason for this harrasment and. intimidation if the plant had been built cafely to begin with and there had been nothing to hide, in any event, the harracment and intimidation of the QC Inspectors makes the entire quality Assurance program suspect as well as the conduct of Applicants.

4. While working in the document control center with Dobie Hatley I worked all night long helping her change the records in the DCC files.

I latter learned that I had helped her fC.sify the CYGNA audit.

5. Applicants failure to establich and execute a quality assurance program, and their refusal to heed the warnings over the years from independentauditorsandtheNRCshowsacompletedisregardforgeir responsibilty under 10CFR$0, Appendix B, and a total di ortile health, welfars and safety of public. The delay in the completion of the plant, the need for reinspection, and the additional cost due to their own failure and mismanagement has resulted frem their own dial-atory conduct. Applicants have proven by their conduct in the pact, and by their own irresposible actions, that they do not have the ability to construct a nuclear plant that complies sith NRC regulations, and if the unconditional extension is allowed, CPSES will not only fail to comply with NRC regulations, but will make the cost of the plant pro-hibative for the rate payers, and will put the burden of paying for the Applicants own mismanagement and irresponsible conduct on their shoulders.

I first became concerned over the safety of the Plant when I began trending Certified Material Changes (CMC's). There were too many "As Built" changes. This indicated to me that the Engineers were unable to design the plant, or that the Craftsman were working ahead of them by completing the work before receiving the construction plans. I know a Craftsman does not have the ability to design a nuclear plant, which it appears to me they have done, because it is impossible to construct a plant or system that is structuraly efficient without an overall study of the construction plans in order to determine the point of stress and the weight being supported at any particular point. 1 There ari also many other reasons I am concerned over the safety of CpSES, and Applicants abliity to build it safely. When the final l documentation was moved from the QA/QC building into the reactor in f order to speed up the final construction date, they were moved in an open pick-up and open containers. Many of them were lost due to the j haphazard manner they were being handled. What could not be found, they tried to rebuild. But when the permanent documentation had been ]

lost, all tracability was gone, and I do not beleive they cold rebuild j the package or regain tracibility without replacing the component or l part in question. My other concerns over the safety of Comanche Peak are listed in the affidavite given by me to the NRC in April 1984 and during the ASLB hearings in August of 1984.

l

_.____._J

e

'f My greatest concern at this point however, is the fact that those {

in uppermanagement who ordered the falsification of documentation, I and those responsible for the break down of the QA/QC program are still I employed at CPSES and will probably oversee the reinspection if the Applicants are allowed to complete the CPRT reinspection, redesign, and l reconstruction process, but those who reported the safety violations to the NRC have been fired.

When I went to the NRC in March 1934, I kne'v I would be fired when Brown and Root found out I had talked with them. I desperatly needed my job. My sister was dying with emphsema and required the use of an cxygen concentrator 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day. I was working thru the week in the QA Department, and on weekends as QC time keeper. I worked sick because I could not afford to take off work, but I also knew they inteneded to fire up Unit one in August. I talked it over with my sister. We both decided I had no other choice but to contact someone regarding my concerns. When Dobie Hatley was fired, I went with her to Fort Worth looking for Junita Ellis to find out how to get in contu t with Billie P. Garde. The entire QA/QC Department had been told by Gorden Purdey not to talk to her or anyone from the Govern-mental Project in Washington, D.C. Billie Garde contacted the NRC and the first 30 inspectors were sent into Comanche Peak to investgate our allegations. Although I had been absent less than 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months over the entire year for illness, and did not have a paycheck for less than 45 hours5.208333e-4 days 0.0125 hours 7.440476e-5 weeks 1.71225e-5 months in one week, I was terminatted on July 13, 1984 for excessive absentism, even though I had worked 835 hours0.00966 days 0.232 hours 0.00138 weeks 3.177175e-4 months over time that year. In discovery it was found that they had falsified my time sheet by charging me with Janet Gregory's time off and had charged me with absentism for the Mondays my department did not work because they were on four tens.

In the July 13th RCF, they laid off the seasoned Document Reviewers and moved others in from different Department with little or no ex-pierence in Document Review to take their place. Because of this it is apparent that they put more emphises on absentism than they did on the safety of the plant. Those they kept in the QA/QC Department were not qualified to review documentation, those who were terminated were.

I declare the above statements and allegations to be true to the best of my knowledge.

Yk$. A/M Meddie E. Gregory" "'

June 12, 1987

"s.

DOMEii!

UNITED STATES NUCLEAR REGULATORY. COMMISSION U ,t* C Before the Atomic Safety and Licensino Board

'87 JN 17 P4 :55 In the Matter of ) [dh i;;. . x en f

) ORMRh ;

TEXAS UTILITIES ELECTRIC COMPANY, ) Dkt. No. 50-445-CPA I et al., )

.)

(Comanche Peak Steam Electric Station )

Unit 1) ) {

l i

CERTIFICATE OF SERVICE I hereby certify that MEDDIE GREGORY'S RESPONSE TO APPLICANTS' INTERROGATORIES TO " CONSOLIDATED INTERVENORS" (SET l

NO. 1987-1) AND MOTION FOR A PROTECTIVE ORDER was served today, 1 June 15, 1987, upon the following by first class mail, postage j prepaid, or by hand where marked with an asterisk (*), or by Federal Express where marked by two asterisks (**).

1 Peter B. Bloch Administrative Judge -

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l l

Dr. Kanneth A. McCollom J 1107 West Knapp j Stillwater, OK 74075 1 Dr. Walter H. Jordan l 881 West Outer Drive Oak Ridge, TN 37830 Elizabeth B. Johnson Oak Ridge National Laboratory P.O. Box, Building 3500 Oak Ridge, TN 37830 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

l I - ___

F 1*

9 1 e i Geary S. Mizuno, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas G. Dignan, Jr.

Ropes &-Gray 225 Franklin Street Boston, MA 02110 Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk Dallas, TX 75224 i

Billie P. Garde Government' Accountability i Project - Midwest Office ;

3424 North Marcos Lane l Appleton, WI 54911 '

~

t.eG 0%$ '

Q Anthoni/ Z . Roisman l l

1

ML20215K295

Text

Navigation menu

Search