ML20082P648
| ML20082P648 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/30/1991 |
| From: | Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Selin I, Taylor J NRC COMMISSION (OCM), NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20082P633 | List: |
| References | |
| 2.206, CPA, OL, NUDOCS 9109100432 | |
| Download: ML20082P648 (20) | |
Text
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- . .. .o.. ".. . ., =. .o c July 30, 1991 c
Non. Ivan Selin, Chairman l Mr. James M. Taylor, Executive Director for Operations i United States Nuclear Regulatory Commission [
Washington, D.C. 20555 ,
Ret 10 C.F.R. 52.206 Request to Evaluate Material False Statements Made on Behalf of Texas Utilities :
Electric Company During Licensing and Construction [
Permit Amendment Proceedings held Beforts an Atomic !
Safety and Licensing Board, Docket Nos. 50-445 OL; !
50-446 OLi '50-445 CPA i I
t I. A11eaations- f The National Whistleblower Center ("Petith'nor") hereby f requests on behalf of itself and certain confidential allegers !
i working with the National Whistleblower Center that'the Nuclear i
Regulatory Commission ("NRC") determine whether Texas Utilities i Electric Company ("TUEC") repeatedly submitted material falso statements-to the NRC. The intentional making of material false -!
statements to the NRC and intentionally hiding relevant i i
information from a NRC-Atomic Safety and Licensing Board ("ASLB") j demonstrates that TUEC did not, and does not, have the requisite !
I character and competence to operate and construct a nNicar power j plant. Specifically, the continued safe operation of t r.e CPSES
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. cannot be guaranteed inasmuch as high-level managers currently 1
- employed at the CPSES do not have the integrity needed to operate 4
and construct a nuclear power plant. In this regard, Petitioner !
J asserts that because CPSES managers weret 1) willing to submit i
material falso statements to the NRC in order to obtails a license to operate Unit 1 of the CPSES, and 2) in, fact, did submit material false statements in order to conceal significant safety flaws in the design of the CPSES pipe support system, then it stands to reason that these same managers t--se a current safety threat inasmuch as they are capabic of submitting material false statements in order to conceal significant safety problems at the CPSES.
Specifically, Petitioner makes the follows allegations:
- 1. During the construction of Units 1 and 2, TUEC engaged in overt fraud and deceived the NRC about the method used to certify pipe supportst
- 2. During the construction of Units 1 and 2, TUEC submitted material falso statements to the NRC in order to cover-up and further an illegal practice used to certify CPSES pipe supports in violation of 10 C.F.R. Appendix B requirements;
- 3. The individuals responsible for and who assisted in covering-up the illegal certification process continue to be employed by TUEC and have played and continue to play critical engineering and quality assurance roles at the CPSES.
- 4. Essential evidence in the CPSES Construction Permit Amendment proceedings concerning intentional conduct resulting in a delay in constructing Unit 1 of the CPSES was intentionally kept from the ASLB by TUEC, CASE and NRC Staff in violation of a pending request by the ASLB to be kept informed of 2
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II. Facts :
In the late 1970's the NRC convened an Atomic Safety and Licensing Board (ASLB") to adjudicate licensing issues related to ] >
TUEC's request to construct and operate the CPSES. Parties to i i
the ASLB licensing proceedings included NRC Staff, TUEC, and, j t
eventually, a single citizen intervenor group by e.he name of Citizens Associated for Sound Energy (" CASE").
I In 1982, CASE began to present the ASLB with testimony by t i
two former CPSES cngineers, Mark Walsh and Jack Doyle. Messrs. j Walsh and Doyle advised the ASLD that TUEC had designed CPSES pipe support system in violation of HRC requirements.1/
A major area of concern raised by Walsh/Doyle related to the r organization and design interfaces of the-CPSES pipe support design groups.I/ One of the concerns rhised by Messrs. Walsh !
l and Doyle cent 9 red around the organizational and design {
interfaces between the various pipe support design groups.
Specifically, they were concerned that a lack of coordination
{ between the three pipe support design organizations jeopardized i ,
the safety of the CPSES pipe support design because the three i pipe support design groups were using a different set of design criteria when designing the pipe support system.
1/ NRC Staff responded to the Walsh/Doyle concerns by l filing a Special-Inspection Team (" SIT") Report 82-26/82-14-on ,
February 15, 1983. The SIT Report was subsequently submitted I into the record of the ASLB proceedings as Staff Exhibit 207. l Z/ Up until 1985, three design organizations were, for the jl most part,-responsible for designing and certifying CPSES pipe supports; they were Nuclear Power Services, Inc. ("NPSI"), ITT- ;
Grinnell ("ITT-G") and Pipe Support Engineering ("PSE"). l 3 i f
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curing the ASLB proceedings witnesses appearing on behalf of TUEC and NRC Staff testified before the ASLB to defend the use of multiple sets of design criteria by the three pipe support design organizatisns. One of the critical witness testifying on behalf of TUEC was Mr. John C. Finneran, Jr.3' During the ASLB proceedings, Mr. Finneran testified as follows:
...The changes made [to the pipe support designs) will go to the oricinal depian oraanization and they will review it and nake all their own calculations for that change...I might point out that after tl.e final review of these drawings, they are stamped and signed by an engineer with the mttginal decian oraanization...After all the field changes are incorporated in the drawing and the drawing goes through final review from the as-built loading, the drawing will be stanped and signed certified by the p.riginal desian orcanization...[E]ach organization that designs supports will be responsible for certifying that the support is good for tha as-built loads...[These organizations) would be ITT Grinnell, NPSI...and my organization, Pipe Support Engineering.
ASLB Tr. pp 4 t , 4985'4986, 5013 (emphasis added).
The Chairman of the NRC ASLB panel, Hon. Perer B. Bloch, summarized his understanding of Mr. Finneran's testimony and the i
l other evidence submitted to the ASLB as follows:
... Staff was relying primarily on the notion that the rajor groups had to be properly coordinated...
[C]oordination is necessary so that each major design organization knows what it is doing, and what it is responsible for...We are talking about design i interfaces, as I understand the interpretation of the L Staff. That is, places where the groups might be l working on areas of the plant 9here they have to know l
how the work of one affects the work of another, but i
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1/ Mr. Finneran is currently employed at the CPSES as
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l TUFC's Manager of Civil Engineering.
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where the resoonsibility is clearly defined. there is f no necessity to talk about everv- interf ace that occurs t within the aroues...The resoonsibility under_the testimony was clearly assioned to each of the three I succort Dice aroups...They don't lose any -l responsibility for the accuracy of desian. I ASLB Tr. pp. 6985-6989 ('mphasis added).
On December 28, 3 43. ;he ASLB. relying upon the evidence-presented by ?UEC and NRC Staff, issued a Memorandum and order 1
("M&o"). This M&O specifically addressed the Walsh/Doyle concern ~
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regarding the impropriety of the organizational and design-interfaces between the different CPSES pipe support design f i
groups. Egg M&O Section IV(I). The M&O explained its reason for j dismissing the Walsh/Doyle concerns regarding the interface !
between the threelp'ipe support groups as follows: f An early decision was made by1the applicants that pipe i support design would.be. contracted-out to companies who are in.the.businessfof designing and fabricating pipe i support components. In order to satisfy ASME Code ;
requirements...it s necessary to provide them with !
thefoverall-design criteria to be met. The... document !
.which! accomplishes this objective was Specification MS-46A.. Contracts for=the design of pipe supports at l CPSES'(Comanche: Peak] were awarded to,ITT-Grinnell and j NPSI. In addition,-Applicants created what became the PSE [ Pipe Support Engineering Group], which also i utilized-Specification MS-46A. :Since neither ;
Specification MS-46A nor the ASME Code dictato in i detail the means by which an engineer is to satisfy'the design criteria, differences in engineering approaches l occurred-between the three parallel. pipe support f groups.-(Staff exhibit 207 (SIT Report] at p. 12; *
-Applicants Exhibit 142,.p. 9). -
The fundamental-issue for this-.[ASLB] Board to i' resolve is whether these differences in design approaches represent a-safety or engineering concern, 3*
or it they violate any NRC regulations, Staff guidance or other NRC-endorsed standard... l
)
5
/
The evidence establishes that each of these three eine sunoort desian orcanizations has its own specific agone of responsibility since each has been assioned the responsibility for a specific aroup of supports.
(Staff Exhibit 207, p. 13; Applicants' Exhibit 142, p.
9). There is no need for cross communication between the three aroups INPSI. ITT-Grinnell, and PSE1 since they share no common, in-line desian responsibility...
The Board concludes that the Applicants have adequately defined and documented the responsibilities and paths of communications between...the pipe support design groups. No NRC regulation has been violated, and the programmatic objectives ...have been satisfied.
(Staff Exhibit 207, p.13)
M&O at pp. 67-68 (emphasis added).
Although Section IV(I) of the M&O dismissed the Walsh/Doyle allegations regarding the design interfacts of the pipe support groups, the M&O generally observed that serious " doubt on the design quality" of the CPSES existed, Egg M&O at p. 1. In an attempt to resolve the doubts raised by the ASLB, TUEC began to submit a series of motions for summary disposition with the ASLB.
TUEC often repeated in the affidavits and text of these motions for summary disposition the same type of factual assertions which led the ASLB to conclude that the certification process being employed by the three pipe support groups was acceptable. For example, Mr. Finneran states in one such affidavit that:
Ap I creviousiv testified...desian chances ar6 subiect to review by the resognsible desian orcanizati2DE. (Tr. 4970-71).
See Affidavit of John C. Finneran, Jr. regarding Stability of Pipe Supports and Piping Systems, dated June 17, 198__ at p. 14 (emphasis added).
In another affidavit submitted in July of 1984, Mr. Finneran 6
(and other affiants) reiterated that he three design organizations (NPSI, ITT-Grinnell, and PSE) had "sperate and distinct responsibilities for the design of pipe supports" and all design changes are dreturned to the original designer for correction and rechecking..." Egg Affidavit of D.N. Chapman, J.C. Finneran, Jr. , D.E. Powers, R.P. Deubler, R.E. Ballt.nd, Jr.,
and A.T. Parker regarding Quality Assurance Program foc G9 sign of Piping and Pipe Supports for Comanche Peak Steam Electric Station, stated July 3, 1984, at pp. 13, 36.
By 1985 TUEC's effort to design the CPSES pipe support system remained plagued with design deficiencies. At this point in time, the construction permit issued to TUEC by the NRC to construct the CPSES expired. When TUEC sought to renew its permit, the NRC decided to institute Construction Permit Amendment ("CPA") proceedings. The contention admitted ir :he CPA proceedings was as follows:
The delay of construction of Unit 1 was caused by Applicants' intentional conduct, which had no valid purpose and was the result of corporate policies which have not bee discarded or repudiated by Applicants.
See 25 NRC 912, 919 (1987).
In 1985, a former senior pipe support design engineer stationed in the NPSI pipe support group, Mr. S.M.A. Hasan, met with CASE President Juanita Ellis and CASE attorney Billie P.
Garde and explained, inter aliq, how pipe supports were being transferred between the various pipe support groups and were certified using multiple sets of design criteria. CASE then agreed to represent Mr. Hasan before NRC Staff and arranged for a 7
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'. i grant of confidentiality. On January 10, 1986, Mr. Hasan, NRC Region IV Staff, and Ms. Ellis met. During this meeting, Mr. ,
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Hasan raised a series of allegations, which were transcribed. At i
this time Mr. Hasan stressed to NRC Staff and CASE President Juanita Ellis, that (contrary to what was stated to the ASLB !
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regarding the process used to certify pip ( supports in the j various pipe support groups) pipe support design packages were !
routinely transferred between the three pipe support groups and certified using multiple sets of design criteria.6/ Mr. Hasan ,
specifically alleged to the NRC at that time Mr. Hasan advised NRC Staff: f
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... Dave Rencherl/ took the package from us and got it '
passed in another group. I just ask NRC, is this engineering? Just because we could not qualify a !
particular pipe support package based on the criteria given us...(Dave Rencher) said, ' Don't worry. Give me ;
the package back. I will get it passed in another group ' Because they were using another criteria. And ;
they got it passed, certified, and gone....Quite a +
number of times I got a package,/ we could not qualify it, and we used to write a mem@ to Jay Ryan, chief I
engineer (within the PSE group), telling him that this support is failing under NPS criteria...(a)nd they used !'
to pass it.
Excerpts of the January 10, 1986 Hasan Interview are attached i
hereto as Exhibit 1. ;
i' This allegation was germane to the CPA proceedings inasmuch as, if true, it establishes that between 1982 and 1985, ,
TUEC had intentionally submitted material false statements before the ASLB which contributed to a d_.ay in the construction of the ;
CPSES. .
E' Mr. Rencher was the CPSES manager of the NPSI group.
s' Attached as exhibit 2 is a copy of one of the memos !
addressed to Mr. Ryan that were used to transfer pipe support l packages out of NPS and into PSE.
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Mr. Hasan went on to file a Section 210 proceeding against his former employer, NPSI, and TUEC and Stone & Webster
- Engineering Corporation ("SWEC"). See Hasan v. NPSI, et al., 86- ,
t ERA-24. During the course of the Hasan proceeding, evidence in the form of testimony by Mr. Rencher and another pipe support manager, Mr. George Chamberlain, demonstrate that TUEC was ;
involved in the intentional transfer of pipe supports between the t i
various pipe support groups and, as such, the testimony TUEC had i
repoatedly presented to the ASLB that pipe supports were not ,
being transferred between the various pipe support groups and l
were not being certified using multiple sets of design criteria constitute material falso statements. .
III. Evidence Establishing that TUEC Made Material False ,
Statements before the CPSES ASLB ;
On June 22-23, 1987, the Hasan Section 210 case went to hearing. Attending the hearing were counsel to TUEC and Ms.
Juanita Ellis, President of CASE. On July 8, 1987, Ms. Ellis ;
notified the ASLB that CASE considered "some of the testimony in .
[the Hasan) proceedings of such potential significance to...the construction permit proceedings that Applicants should voluntarily provide copies of all pleadings, documents, etc., in that case to the Licensing and CPA Boards." See July 8, 1987 l
Letter from Ellis to NRC ASLB, filed and on record in the ASLB 4 proceeding.
The most significant evidence to be aired during the Hasan ;
proceeding concerned the practice TUEC was employing on site to .
design the CPSES pipe support system. Specifically, the on-site t
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i manager of the NPSI group, Mr. David Rencher, testified both at p e
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his deposition and during the hearing that pipe supports were i
reatinely transferred between the various pipe support groups and l were routinely certified using more than one set of design l criteria. In this respect, Mr. Rencher testified under oath in a j deposition prior to the commencement of the Hasan hearing as ;
follows: l Q (Were you aware that) the NPS group was rejecting PSE supports during the certification process? t A Yes, I was aware of that, i
Q Were you aware of that in 1983?
t A <es, j
Q ...in 1984?
f v
A Yes, sir.
Q ...in 1985? l A Yes. 1 Q The NPS group was rejecting PSE packages during the !
certification process, right? !
A Yes.
Q of these that were being rejected, were they ever then ;
recalculated under different criteria?
A Yes.
Q And then they were certified after they were recalculated under different criteria?
A Yes.
ih Q Are you aware whether or not Mr. Hasan could not certify...some of the packages he was checking?
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A He could not certify some of the packages because of the NPS criteria on Richmond inserts, yes.
Q Did you take those pacP. ages to the PSE group for certification?
A Those supports were rejected to the PSE group. l Q By ' rejected to the PSE group,' what do you mean?
7 A Well, he attached a memoJ to it from my group to the PSE group saying the supports were rejected fer the following reasons...
Q And would the PSE group then certify the packages...
A ...yes.
Q And they could do that because PSE was using different criteria than NPS?
A Yes.
Rencher Deposition Testimony Tr. pp. 78-81, 96-97.
During the Hasan hearing itself, Mr. Rencher reiterated this testimony:
Q [W)ere you aware whether or not Mr. Hasan rejected Mr.
Ryan's pipe support engineering group [PSE) pipe supports while working in you group [NPSI]?
A There were pipe supports that were rejected out of my group, and I am certain Mr. Hasan had reviewed some of those.
Q And they were coming from Mr. Ryan's group?
A Yes, they were.
Q (W]ould Hasan attach a memoll to [the PSE packages he was rejecting while in Rencher's NPSI group)?
A Yes.
Hasan v. NPSI. et al., Hearing Transcript at pp. 120-121. Also Il See Footnote 6, sopra.
E' See Footnote 6, Supra.
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- Egg Tr. pp. . 125,-130, 239, 275.F In essence,- the evidence elicited during the_Hasan Section 210 proceedings demonstrated that the interfaces between the various pipe support groups were not separate and distinct; rather,-the pipe support groups were routinely transmitting pipe support packages back and forth and certifying individual pipe ,
supports by groups using different criteria from the cr'iteria l_ used when the support was initially designed.(i.e. certifying i individual pipe supports using multiple sets design criteria).
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- IV. Evidence Establishing that TUEC Intentionally Withheld l Significant Evidence from the ASLB in Violation of ASLB j Instructions 1
During the' course of the Hasan Section 210 proceedings, testimony from the on-site manager of the NPSI design organization, Mr. Rencher, from another manager, Mr. George Chamberlain, and trom two pipe support engineers, Mr. Hasan and r
i F- Also see Rencher Depo. at p. 247 (wherein Mr. Rencher was-asked-to-comment whether it was true-that "...if supports did
- not meet the appropriate design criteria using the NPS design-I' specification, the supports were sent to another pipe support
, design ~ group, such as-PSE, and'would be considered acceptable
+ using'different design criteria..." tc which he answered with an l unqualified "yes"). Also see Deposition of george Chamberlain at
- p. 95, (wherein Mr. Chamberlain, a manager within the pipe j- support design area, was also asked-to. comment on whether E " supports were sent to-another pipe support design group, such as l PSE, and would be considered acceptable using different
- l. criteria..." to which he responded: "[S]ome companies did not have criteria addressing certain types of design. . For example,- -
ITT-Grinnell did not have criteria addressing the Richmond insert'
' tube steel design. If;[a pipe support] got redesigned-that way,
- then we would transfer responsibjlity for that hanger from Grinnell to the site engineering group [PSE)." Indeed, Mr.
1 Chamberlain went as far as to refer to the practice of
- - transferring responsibility of the various pipe supports as the "go.around". Chamberlain Deposition at p. 190).
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Mr. K. Rav a da transferr ed betw confirmed that pipe een the v supports between 1982 nd a 1985 arious pips were r support outinely being demonstrates fac t. th Moreov er, the design groups The at at no timew record befor although record befo 1
\ TUEC's re the ASLB as the ASLBerev e the ASLB apprise the Boardcounsel further advised of this
\ knew it it...," of e had an establishes that affirmativ Reynolds to ASLseg 1985 which January bear on 30,dev e duty "to lopments Pobert Wo o ldridge toB;March from TUEC att matters before algLagg with 21, orney Nicholas the Board's ASLB (noting a 1985 letter fo r eques t requir informed ofatters m that ement that rm TUEC Without TUEC " comply of the liapAD Secti question, theicensing" testrelating e kept of timely to the lBoa contention on 210 imony clicited the CPSES).8 constructionraised in the CPAproceedings during bar the of pro course conduct, Unit 1w ce dings ("Thees directly e
upon as the which had no caused by Appli delay of corporate policies valid purpose cants' Applicants") which hav
.- e and was the intentional to be Nothing could not been discardresult of able to prov
. hat pipe e this ed or show that all supports the repudiated by pport w ere groups, while TUEC wcontention er than bett the fact wnot routinely tr as telling the AS D as that LB t
the pipe ansferred betw een pipe TUEC wasIn not crespethisc t, supports its failure to omplying withCASE v were ating lproceeding notifywhich w the ASLB itsent as faras to eedings.icense proceedin about mattersresponsibilities tadvise the ASL
'ta Ellis toe thEen July gs 8,ere em"of extr e ASLB. 1987and constructione importancraised in theo the ASLB letter fro permite to boththe m CASE s
13 Pre ident
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Mr. K. .Ravada confirmed that pipe supports were routinely being transferred between the various pipe support design groups between 1982 and 1985. Moreover, the record before the ASLB demonstrates that at no time was the ASLB ever advised of this fact. The record before the ASLB further establishes that although TUEC's counsel knew it had an affirmative duty "to apprise the Board of developments which bear on matters before it...," Egg January 30, 1985 from TUEC attorney Nicholas Reynolds to ASLn; also see March 21, 1985 letter form TUEC Robert Wooldridge to ASLB (noting a requirement that TUEC " comply with the Board's request that Board members be kept timely informed of matters relating to the licensing" of the CPSES) .3' Without question, the testimony elicited during the course of the Hasan Section 210 proceedings bares directly upon the contention raised in tra CPA proceedings ("The delay of construction of Unit 1 was caused by Applicants' intentional conduct, which had no valid purpose and was the result of corporate policies which have not been discarded or repudiated by Applicants"). Nothing could prove this contention better than to be able to show that all the while TUEC was telling the ASLB that pipe supports were not routinely transferred between pipe support groups, the fact was that the pipe supports were 3' In this respect, CASE went as far as to advise the ASLB that TUEC was not complying with its responsibilities to the ASLB by its failure to notify the ASLB about matters raised in the Hasan proceeding which were "of extreme importance to both the operating license proceedings and construction permit proceedings." See July 8, 1987 letter from CASE President Juanita Ellis to the ASLB.
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routinely being transferred between the various pipe support groups. This is the very allegation that had been explicitly raised in the briefs submitted on behalf of Mr. Hasan. Copies of these briefs were provided to TUEC's counsel, to CASE via Ms.
Billie Garde, and to NRC Staff.
The fact remains that the ASLB was intentionally misled about this allegation.
With respect to the allegation of the intentional withholding of evidence from the ASLB, Petitioner hereby incorporates the facts stated herein with the allegations set out in a confidential letter dated October 5, 1990, set to NRC Region IV Office of Investigations.lU Petitioner respectfully requests that the identity of the alleger and the contents of the October 5, 1990 letter and attachments thereto remain confidential. Nonetheless, Petitioner requests that this information be considered when rendering a decision with respect to this petitioner.
V. Re}ief Reauested WHEREFORE, Petitioners requests that licensing hearings be held to determine whether TUEC has the requisite character and competence to operate a nuclear power facility.
FURTHERMORE, Petitioners requests that TUEC be fined and i otherwise penalized for submitting false statements to the NRC i
IV A formal confidentiality agreement was entered into l covering the information provided in this October 5, 1990 letter.
l Petitioners are willing to work with the NRC to provide much of i
the information contained in.the October 5, 1990 letter on a non-l confidential basis.
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and ASLB.
FURTHERMORE, Petitioners requests that an investigation be conducted to determine whether NRC Staff learned of the existence of these material false statements, yet failed to act upon this knowledge.
FURTHERMORE, Petitioners requests that the NRC determine which high-level managers were responsible for submitting material false statements to the ASLB and NRC and ban these individuals from the CPSES and all other licensed nuclear facilities.
Respectfully submitted, Michael D. Kohn KOHN, KOHN & CCLAPINTO, P.C.
517 Florida Avenue, N.W.
Washington, D.C. 20001 (202) 234-4663 Counsel to the National Whistleblower Center Dated: July 30, 1991 15
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1 (CONFIDENTIAJi treatment recuested, agreement 2 !
signed.)
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- U.S. NUCLEAR REGULATORY COM?iISSION 7 \
and f 0 CITIZENS ASSOCIATION FOR SOUND ENERGY !
I 9
January 10, 1986 10 I
, 11 Marriott Hotel, Seville Room 12 2101 Stemmons Freeway 33 Dallas, Texas 14 e
is 16 DOW0t J$ CLOS 1 .
17 18 19 -
20 '
f .
2 MVe6A86Gr8h l'8 21 REPORTER: Sandra Harden 22 CENTRAL REPORTING AGENCY 2800 Buena Vista },
/l 23 Arlington, Texas 76010 f (817) 640-1553 25 PAGE DE 4
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MR. FIRRARINI: 1p the restrained directio*., i 1
2 okay.
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!1R. RASAN: 1xactl,. !
4 MR. TERRARIN2: Oka"...
t 5 MR. HASAN: Now, another ooint fror secumenat: I>
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6 view or from engine'erino uoint of view, we have cci poir! ,
i I 7 only on.. pro-ject, we should have only -one procedure of dealir -
B - with one particular item. Very siracle- comnon sense. !
t 9j I do the number at least one oloe sunnort tui.ng 10 badly under the so-called NPS criteria. Dave Rancher tec;. t.. h i
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{packanefronusandget-itnasset.2nenotheraroun.
'12 1 7ust ask NRC, is t.his encineerinc? Curt
{
13 because we could not nualify a narticular nipe support enekage !
14 based on the criteria =civen to us,-it only looks the suonort :s 1
15 in bad stano, dt.is fai2ina. Said, " Don 't -vorer.._c.inc_r!Lc .t.f e - !
15_ nackane back.
I will act_._it_._.n. a_ssed . in ~an. _other c rou.n . "
B c c iw .5 . l 17 they vero usina another criteria.
- nd they cet it rasscC-18 certified, and gone. t i
.19 MR. TERAO: Do you recall whct criteria-- o r , --
i- '20 what actually failed? What criteria failed? ?
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21 MR. RASAN: Right'now, no, because it was a ;
! 22 very old package. I cannot recall. I believe, if I recall l .t 23 correctl y , I think it was Ricrnand inserts. If : recall i
24 correct 1f, it was,Fichmond inserts. But I cannot tel vou a
'25 hundred nercent certainly that, but was one of the items that ev,w a r.r I
! RAGE'd *
( A
I pe, 3 vas failing badiv. Fe took it avcy, ar.d it un s pa s s ec bv 2 another aroup.
3l MR. TERAO: But do vou recall 1f it was a A ntress criteria, if.it was a deflection criteria, if it was--
5 Pa. ESAN- t; ell , I iust told you, if I recal:
0
< correctly, the main problem was. the analification of Richmem.
7 inserts. We could not cualify in our croup usiv, the UP5 0 criteria. So, that tackaac was taken away from us, an c'. I t uar 9
{ qualified at that time in another r roun by the nanc c: p pe 10 l supcort encineering grcup.
11 And t *. a t ouv came to me and said, "' oc): , ";.
12 could not salvage this package. We got it passed."
i 13 I said,
- I'i n e . " Because I could not de i'..
14 And I can cive instances after instances . :.t '
15 this. But NF.C is not aware of the fact that thert se en< are p 16 who used to do the desian review. 7nd when ve used to ec.t the 17 fint, as-built load from the stress nroco, we used to do *5<
IB certification of the entire succort.
19 Quite a number of times I got a naukaco, we 2D could not cualify it, and we used to write a memo to Jay Evar..
21 chief engineer, telling him that'this sunoort is failing under 22 NPS criteria.
23 And those neonle useC to complain to hicher 24 authorities: T. c o k , this cuv is writin ne neros t e ll ir ' tr,c 25 these sup': orts are f ailina. EXHIBIT)
P. AGE DE .
_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ .......h
f
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I >
I " M".. P.OU : Let ne ask some cuestion. .
2 '1R. ~rmSAN: Yes.
'3 MP. ROU: ' Yon sur that suwort .no assicrned to 4 one oroun -of engineexinct,- and they used .a set of criter . - . . .
5 And then e rs it to and then find -out it's Trot able to veet.-.
- ~ - - - . . _ _ . _ _
6 .another groue, .and they nne different kind.of criteria?
7 1m.ImSw: Exactisy. That's correct. And the-8 used to pass it.
9 MR. EnU: Ch-huh.
10 MR. 3ASAF: And they used to say, as fc: eur II criterin --
12 t?R. FOU: Okay. Now, can ' on be rere s*.-oc i f i::
13 l what criteria they used and what aroun?
Richnond inserts. ?.s I just saic' 14 MR. PASAN:
16 to hi: .
I 16 MR. uGU- Phieb ene une it?
17 v2 . TRMiMULL: Kell, I know that none c' t'cre c..,
IB have been given to us in enough detail to really flesh it i You're doing fine. I.et's qo on to the ne.':t .
19 but ':een going .
20 issue. I want to act then all. i.
21 MR. PASAM: All richt, I will trv.
I 22 Tie coefficient of friction, on this ca rticu ' - -
ad.-
23 ,
project, coef fi,cient of f riction is beine based en normal 24 This reans dead veight nlus trenor. :'ha t ' s it . EXHIBIT l i LL j
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