ML20093F058
| ML20093F058 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/10/1984 |
| From: | Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| CON-#484-438 OL-2, NUDOCS 8410120365 | |
| Download: ML20093F058 (37) | |
Text
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RELAJED CORRESPONDENCE . 00hc
- October 10,~1984 84 00112 A10:29 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFF:CE Or SPd@ '
cc0 E itt4G A #
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Md In the Matter of )
)
TEXAS UTILITIES GENERATING ) Docket Nos. 50-4e5-2 COMPANY,-ET AL.
) and 50-446-2
)
(Comanche Peak Steam Electric )
S ta tio n , Units 1 and 2) )
CASE'S MOTION FOR PRODUCTION OF DOCUMENTS FROM APPLICANT Pursuant to the Board's ruling on October 2 that CASE flie a written motion for production of documents, CASE moves for production of the following documents:
All documents (including notes, memoranda, tape recordings, word processing diskettes, photos, charts) related to the termination of James Cole.
Mr. Cole's role in the liner plate incident was not known to CASE until after Septemoer 1, 1984 when for the first time Applicant produced the liner plate travellers for Unit 2.
Suosequent to that production, when CASE's document experts were I 1
reviewing the travellers, it was noted that the name of James CoJ a appeared on a suostantial numoer of the travellers. One of the CASE document reviewers, a former CPSES employee, remembered that Mr. Cole had Deen terminated from the plant and Delieved that the-reason for the termination was falsification of documents.
Several other former employees have expressed similar De11efs.
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In addition, within the last two weeks CASE ootained a copy of an August 13, 1982 CPSES internal memorandum (attached to this Motion) related to allegations of harassment and intimidation oy Avril D1111ngham, J r. , a former general foreman. One focus of the allegations was welding work and documentation regarding stainless steel liner plates for tne fuel pool for Units 1 in 2.
On pages 19-25 of that document there is extensive discussion of Mr. D1111ngham's allegation involving missing hold points on fuel pool liner travellers and Mr. Cole's alleged involvement in the issue ' including an initial (later withdrawn Oy Dillingham) allegation of document f alsification oy Cole.1/ Given that Cole's name appears f requently on line 1 of the traveller forms (the same line Ms. Neumeyer was asked to sign for missing hold points in 1983 and which she was reluctant to do) and that Mr.
Cole had not referenced any NDE Chit when he signed the hold point (an apparent violation of the proper procedure) we De11 eve it is extremely relevant to know whether in fact Cole was discharged for document falsification.
Based on this information CASE carefully stated in its Septemoer 27, 1984 filing that:
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Finally, we understand that Mr. Cole was terminated for i
' falsification of documentation. If that is correct, and we have a good faith Delief that it is, all of Mr. Cole's work on these travelers is invalidated.
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- Note on page 21 of the CPSES Memorandum that apparently the i
proper action in the event of missing hold points is to write an NCR, not have them signed of f some years later as Ms. Neumeyer was pressured to do.
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l Applicant now purports to controvert the allegation involving Mr. Cole. Only oy production of the pertinent documentation can we conclusively determine wno is correct. We see nu sense in our producing second-nand nearsay evidence to show Mr. Cole was terminated for falsification of documents any more enan we saw sense in Applicant producing second-nand nearsay to prove tne opposite. We Delieve there is sufficient new evidence wnich cane to CASE's attention only during Septemoer -
1984 to allow production of the requested documents.
Tne Cole information is potentially very important. CASE nas alleged, oased on Ms. Neumeyer's testimony which was confirmed in part oy Ms. Gregory, that Ms. Neumeyer was pressured into signing of f missing nold points on stainless steel liner travellers. Applicant claims there was no pressure and that the sign-off, as done oy Ms. Neumeyer with notations to the NDE Ct._ts, was proper. Yet Mr. Cole, apparently f aced with the same proolem of missing nold points on similar travellers, appears to nave signed them witnout reference to any NDS Cnits. Was Mr.
Cole falsifying tne documents? Did 'he get fired for f alsifying documents thus calling into que3 tion all documents signed oy him?
These issues remain in controversy netween Applicant and CASE.
Tne Cole termination papers will shed important light on that controversy.
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For the reasons stated aoove we Delieve the Board should allow production of the requested documents. Inasmuch as the next hearing will not Degin until Octooer 22nd, production of the documents will not cause any impact on the nearing scheduled.
Respectfully suomitted, s
$12 x rs 9utTHONY Z.
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map Trial Lawy - for Public Justice 2000 P Street, N.W, Suite 611 Wasning ton, D.C. 20036 (202) 463-8600 Counsel for CASE Octooer 10, 1984 4
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EU Es@c
( MEMORANDUM W OCT 12 #0:29-i TO: William M. Rice C FFg E nr 003EG d < n~y~ .
Group Vice President # '"'M Brown & Root Power Division FROM: H. C. Dodd, Jr.
Vice President Brown & Root Power Division
SUBJECT:
Brown & Root Management Investigation in Response to August 6,1982 g
Complaint of Arvil Dillingham, Jr. (Comanche Peak Nuclear Power Plant) r I. DILLINGHAM COMPLAINT In an undated letter (Attachment "A") from Arvil Dillingham, Jr., a &R 1/1L-general foreman at the Comanche Peak Nuclear Power Plant (" , personally
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delivered and discussed on August 6, 1982 with Thomas J. Feehan, President, Brown & Root, Inc., Mr. Dillingham listed eight areas in which he believed violations of CP safety procedures have occurred.
g The letter states that Mr. Dillingham either has observed or has personal knowledge of the eight alleged violations.- The letter does not indicate when any of the alleged violations occurred. The letter states that there
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was one instance (Item 5, inyolving steam generators) in which Mr. Dillingham reported a concern to B&R Management; however, the letter does not indicate that Mr. Dillingham previously reported any of the other concerns listed in the letter. it$ *For item 8, involving rebar cutting, Mr. Dillingham states yQt e tha e nnamed individual reported the alleged problem to a supervisor.
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-II. FEEHAN MEETING AND MANAGEMENT RESPONSE Mr. Feehan and Richard P. Negri, B&R Power Division QA Department, discussed with Mr. Dillingham the concerns listed in his letter, in a
. meeting held on Friday, August 6,1982, in Mr. Feehan's Houston office.
At the request of Mr. Feehan, on Monday, August 9,1982,' a group of senior B&R Power Division management representatives under your direction went to the C.P. site to begin an investigation of the concerns raised by Mr.
Dillingham. In addition to Messrs. Rice, Dodd, and Negri, this group included Dr. Knox M. Broom, Jr., B&R Senior Vice President; Lawrence A.
Ashley, Jr., B&R Senior Vice President; Raymend J. Vurpillat, Jr. , head of the B&R Power Division QA Department; and Michael L.'Herzik, an attorney in the B&R law department.
III. C.P. SITE INVESTIGATION A. Initial Conference with Dillingham Before any interviews were conducted of B&R employees having knowledge of b
the areas addressed in Mr. Dillingham's letter, Messrs. Dodd, Negri, and Herzik conducted an initial interview with Mr. Dillingham to review the f concerns listed in his letter. I reassured Mr. Dillingham that B&R management wanted to know of any potential safety problens at the plant, and that management appreciated the fact that Dillingham had made known I . his concerns to management in his letter to Mr. Feehan.
I Mr. Dillingham has been with B&R approximately nine years, including two b approximately '
years on the Brunswick nuclear power plant, n;. followed 9 h5hys~ rA. . m b .se seven years at C.P. Dillingham began as a M leight, and progressed [i ve / k **
to his current position as Boile1naker general foreman. Most of his ,
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, . , 3 work at C.P. has been in the power block area of the plant, where he has l supervised Millwrights, welders, and others in a variety of functions.
I Mr. Dillingham told us that he is satisfied that the plant as constructed, will be safe to operate. In fact, he pointed out that he owns property near the plant, and intends to live there during plant operation. Nonethel ess, Mr. Dillingham said he did have concerns about past procedure violations as set out in his letter. He stated that he didn't believe any B&R employee involved in the areas of his concern needed to. be fired, but just needed "to work per procedure and do quality work." -
Mr. Dillingham was asked why he failed to report his concerns sooner. He responded that he was waiting for people (not named) to " work per procedures" and that when they didn't he reported his concerns to Mr.
Feehan.
The only explanation Mr. Dillingham gave for going to Mr. Feehan rather than to the responsible site management personnel, was that he " wanted to go to the top". In this context, Mr. Dillingham gave no indication to us that he was ever discouraged from reporting concerns to site management.
Still, when I encouraged Dillingham to report any future concerns to his superintendent, George Tanley; or to Doug Frankum, B&R Project Manager;
- or to Charlie Scruggs, Assistant to Mr. Frankum; Mr. Dillingham told me I
he was not comfortable doing so, without giving any other explanation. I again urged him to report problems to site management, but also gave him my personal and business phone numbers in Houston to call if he had con-f cerns. After out interviews, in an August 13, 1982 project general foreman meeting held by Doug Frankum, Mr. Frankum stressed again the importanci of s
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encouraging any employee to bring any concern about the job to the attention of site supervision, without fear of retribution. Mr. 1 1
Dillingham's specific comments to us on each of the eight items listed in his letter to Mr. Feehan are discussed below. -
- 8. Investigation of Dillingham's Eight Letter Items
- 1. Item 1 - Swipe Tests
- a. Letter States "I have been instructed to clean the three .
areas known to be tested, and told to not worry about the other areas. It is my understanding that TUGC0 wants a thorough job of cleaning in all areas, yet the time is not taken to do this."
- b. Dillingham Interview Mr. Dillingham told us he had only one incident in mind under Item 1. He said the incident occurred on a Saturday, about b
five week: :go. He said he thought the incident occurred in the Steam Generator Compartment 3, but he wasn't sure. Dill .
i ingham said he and others were working under George Tanley's.
supervision cleaning the compartment in question, prior to swipe testing. (Swipetestinginvolvesrunninganabsorbent f material along random samples of a surface and then testing a
the material in a lab to determine whettier there is debris remaining on the surface after cleaning. If excessive residue is fcund, the surfaces are cleaned and tested again.) Mr.
Dillingham told us that TUGC0 performs swipe tests for the steam generator.
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According to our intervicw with Mr.' Dillingham, he recalled I that George Tanley directed him to concentrate cleaning on three particular areas of the compartment in question, and J that Tanley indicated ^.o Dillingham that TUGC0 planned to perform swipe tests in those areas. (The procedures call for i TUGC0 to perform random sampling, and not to indicate test areas in advance.)
I Contrary to the suggestion in Mr. Dillingham's letter that areas were not thoroughly cleaned, he told us in the interview that B&R cleaned the entire steam generator compcrtment in question.
I His complaint in the interview was that he believed Tanley had
( some improper advance knowledge of swipe test areas.
f Mr. Dillingham suggested we discuss this issue with Bob Walton and Ken Lane.
- c. Investigation Results The steps and procedures governing cleaning and cleanliness testing of the steam generator are listed on construction oper- 1
, ation travelers, which are required to be completed by responsible l
craft and QC personnel at designated hold points listed on the traveler. There are four travelers governing the final cleaning and swipe testing of,the u four u
Qsteam el1f Vglenerators, L all of which are included in Attachment .. Because these travelers cover all cleaning and testing'of steam generators, they would necessarily cover any instances such as those which Mr. Dillingham is concerned t about. The travelers indicate that numerous hold points for clean- i ing and swipe testing were confirmed by various B&R and TUGC0 .
personnel, and do not show any evidence of the kinds of irregularities about which Mr. Dillingham is concerned.
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- :. 6 The travelers indicate that "all" residue and impurities were I l
cleaned and inspected for the interior of the primary chambers t of the steam generators. The travelers indicate that the primary side interiors were cleaned to a stated cleanliness standard,. and that interior side swipe tests were performed confirming cleanliness.
Additional procedures for closing' the steam generator, and for swipe testing adjacent areas and p'aps, were performed and verified ca the traveler. -
Final steam generator cleaning, as covered by the attached travelers, takes approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The B&R employees performing the cleaning are suited out with gloves, hats, coveralls, booties, etc.
The steam generator is rinsed or flushed with Grade A test water.
All areas are wiped with alcohol, rinsed again, and then wiped again.
Swipe tests are then taken by TUGCO. B&R QC witnesses all of these
( steps. When these steps are completed, the vessel is filled with Grade A water, and a water sample is taken by TUGC0 to test for impurities.
We discussed Dillingham's complaint with George Tanley, who denied that he ever had advance knowledge from TUGC0 of swipe test areas.
? Tanley told us the men were always instructed to clean the entire vessel. This is consi$ tent with what is reflected on the travelers.
, James Calicutt, B&R General Mechanical Superintendent, interviewed b'
Bob Walton, as suggested by Mr. Dillingham. Mr. Walton is a Boiler-s' maker journeyman. Walten told Calicutt that procedures specified on the travelers were always followed on the work Walton did on the* steam p generator, and that cleaning and swipe tests were properly performed g .
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, v and witnessed by QC. Richard Negri interviewed Mike Ivey, one of h the inspectors wnose signature appears on the attached steam generator l
travel ers. Ivey stated that the generator was thoroughly cleaned and that swipe test areas were not known in advance. Al Moore, Millwright General Foreman, also confirmed that swipe test areas are not k'nown in advance.
After we reviewed the travelers, we concluded that the " Lane" named by Mr. Dillingham was not " Ken" but Timothy Lane, B&R Millwright, whose signature appears on the travelers in question. I spoke with Mr. Lane who indicated to me categorically that B&R had no advance knowledge of particular areas to be swipe tested by TUGCO. Lane further stated B&R cleaned the entire interior areas of the vessels, as indicated on the attached travelers. Moreover Lane stated that if a particular area was ever questioned by either B&R or TUGCO, B&R craft recleaned not only that area, but the entire vessel.
In light of our investigation, we can find no support for Mr. Dillingham's concern that the steam g:.nerator was not properly and thoroughly cleaned and tested in accordance with all requirements. We understand that Mr. Dillingham was only assigned to clean the steam generator on a 1 temporary basis, and only worked on cleaning ur. der Mr. Tanley for a short time. This may account for what appears to be a misunderstanding a
on Mr. Dillingham's part concerning steam generator cleaning and testing practices. We found nothing to support Mr. Dillingham's concern that George Tanley had improper advance knowledge of swipe testing areas.
I have reviewed with Mr. Dodd the B&R management response to letter item ,
e #1, as contained in this memorandum. I no longer have a concern about j this item, based on my review.
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- 2. Item 2 - Shims
- a. The letter states: "In some instances I have observed after y
chipping concrete that equipment shims had grey tape wrapped
. around them in order to achieve proper thickness. This was -
l needless, as I feel sure that the proper thickness of shims could have been used without the tape."
- b. Dillingham Interview Although the letter refers to " instances", in our interview I with Mr. Dillingham he could only recall one instance. His recollection in the interview was that the situation occurred in the turbine generator building, no. I building, at elevation 2 778. He was not certain, but thought the incident occurred on the feed pump for the auxiliary boiler.
...Y With respect to this one incident, Mr. Dillingham basically a * , . .-
t repeated what he had asserted in his letter, namely that,he had seen shims covered with grey tape, which suggested to him that the tape had been improperly used to thicken the shims in order to achieve proper leveling of the equipment resting on the shims. Mr. Dillingham did not document his concern at the time.
7 Dillingham told us that in the one incident in question, it had been necessary to remove a agrout the pump because the pump b was grouted in abouth out of line. The removal and re-grouting was not related to the use of tape, according to P
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.- . g Dillingham. He told us that the pump was then re-shimmed correctly and re-grouted. Again, Mr. Dillingham told us this was the only instance of which he was aware in which tape was used on shims.-
- c. Investigation Results We discussed Mr. Dillingham's concern with Bob Turner, a B&R Mi11 wright working at the location described by Mr. Dillingham.
E We also spoke with James Cockfield and W.S. Fry, B&R Millwrights who worked in the general area of concern. In addition, we interviewed George Tanley, Mr. Dillingham's supervisor.
None of the individuals we interviewed knew of any instance in which tape was used for the purpose of thickening shims to achieve proper leveling of pumps or other equipment.
Turner recalled the removal, re-shimming, and re-grouting of I the pump at the general location described by Mr. Dillingham.
The removal and resetting of the pump had been requested by ,
TUGCO, who complainep that the base plates under the pump were warped. The plates were removed and straightened, and the pump was replaced and leveled to TUGCO's satisfaction.
It is important tb emphasize that the pump to which Mr.
Dillingham is referring is a non-safety-related pump. Moreover, l the individuals with whom we spoke emphasized th.at even if someone wanted to circumvent shimming requirements as asserted by Mr.
Dillingham (of which we have found no evidence), there would be e
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n) rcason to usa tape on a shim fcr purposes of levoling. l since any tape used would flatten upon tightening of the plate over the shims.
We located the grout placement card for the original. setting of the pump in question, and the traveler used to verify the re-setting of the pump (Attachment r Mt t/n/t*
). The original grout placement card for the June 28, 1978 placement indicates that the placement was properly witnessed and signed off by B&R, craft and engineering personnel. The grout placement card indicates 4
that the placement was reviewed for both " setting, position, level & alignment", as well as for " cleanliness." Had tape 7
been improperly wrapped on the shims, it is likely that this
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would have been identified and corrected prior to signoff.
Therefore, after carefully investigating Mr. Dillingham's concern under Item 2, we conclude that the cencern is without basis, and that the one shimming he identified was conducted in accor-dance with all requirements.
I have reviewed with Mr. Dodd B&R management response to letter item #2,
. as contained in this memorandum. I no longer have a concern about this
- item, based on my reviey.
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. 3. Item #3 - Paint
- a. Letter Stated: " Paint was not allowed time to properly cure prior k to installation of the floor plates on the Stainless Steel Liners, and under equipment in several instances. I have removed some of the floor plates for repair and discovered that the paint had not bonded to the concrete underneath."
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- b. Dillingham Interview We could not tell from Mr. Dillingham's letter whether the incident in question occurred in the containment building or the fuel pool building, and we asked for clarification in the interview. Mr. Dillingham told us that his concern related only to a single incident involving containment liner floor plates. He could not give us any approximate date for the 1,cident in question. With respect to the statement in the latter that paint failed to cure "under equipment in several -
instances," Mr. Dillingham told us in the interview that he actually did not recall any such instances involving paint under equipment.
L Mr. Dillingham told us that we could verify his concern regarding the containment stainless steel liners by checking concrete pour cards, paint dates and weld data cards, but he could give us no 1
I specifics as to which of these containment records to check. Mr.
Dillingham suggested that we discuss this item with Craig Fowles, B&R Boilermaker foreman, and with Larry Witt, a former B&R M111 wright documentation clerk.
- c. Investigation Results We interviewed both Fowles and Witt, and neither was aware of a I
p paint curing problem such as Mr. Dillingham had described, t .
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m We reviewed the applicable drawing (DWG Al-538) which shows those areas of the plant having safety-related protective coatings. The drawing shows that neither the containment nor
) fuel pool building liners have safety-related coatings. Our ,
investigation showed that the only coating applied under floor plates of stainless steel liners in either the containment or fuel pool buildings was a non-safety-related material with the trade name NUTEC 115, which is a thick greyish substance applied to smooth concrete finish under the liner flonr plates.
We reviewed all applicable containment records, and found no documentation reflecting the removal of floor plates as de-I scribed by Mr. Dillingham in our interview. Although Mr.
Dillingham clearly stated in our interview that his concern related only to the containment building, we decided to check the records for the stainless steel liners in the fuel pool D ,e M
building. We did find an NCR (M 1819. Rev. 2). Attachment dl?/
includes the NCR and the inspection reports and travelers documenting four instances in which liner floor plates were removed in Mr. Dillingham's area of responsibility. Dillingham's signatures are not on the NCR and were not required. We talked 7
with James Cole, the principal B&R QC inspector signing the a
travelers. Mr. Cole's recollection is that there was NUTEC 115 under the plates but no paint. He said that he could understand h '
how someone could mistake the NUTEC 115 for paint. However, Cole l
s recalls no curing problem with N'JTEC 115. Cole's signatures on the travelcrs, and those of oth;r inspectors on the travelers and
{ NCR, indicate that the floor plate removal process was thoroughly
/ inspected and that no curing or other problems were identified.
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In light of our investigation, we conclude that there is no, basis for Mr. Dillingham's concern about improperly cured paint.
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, I have reviewed with Mr. Dodd B&R management response to letter iten #3, as contained in this memorandum. I no longer have a concern about this item, I based on my review.
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P RTtnessed 7 (date) 5
- 4. Item 4 - Welding e a. The letter states: "The welding in some instances on the permanent t'
equipment was performed by non-qualified employees without any form I!
of certification as welders. This project has plenty of qualified
( and certified welders, but in several instances the uncertified people were used to " speed up" the jobs."
- b. Dillingham Interview In our interview with Mr. Dillingham he stated that the second sentence of letter Item 4. quoted above, was written by Larry Witt, E'
and that Dillingham had no personal knowledge of the use of unqual-F s ified welders to speed up the job. At this point in our interview, Mr. Dillingham told os that his letter to Mr. Feehan had been typed for him by Larry Witt.
O With respect to the first sentence, Mr. Dillingham told us that at I the time he wrote the letter, he was actually thinking of only one h instance, and not " instances," as the letter states. After we dis-h q
cussed the one instance of concern, described below, Mr. Dillingham
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stated that even in that one instance he did not actually witness ;
welding by an unqualified employee.
The incident occurred approximately 1 years ago. Dillingham was supervising welders at the time. (Although Mr. Dillingham' is not a welder, as a Millwright general foreman, he~ has been responsible for directing welding work and assuring that welding is performed in accordance with procedures.)
Mr. Dillingham stated that Lee Carnes, B&R General Foreman, asked Dillingham to provide a welder on the day in question.
Mr. Dillingham. informed Mr. Carnes that none were available at that time. Mr. Dillingham told us that later in the day, he saw a M111 wright (no name was given), who was not a certified welder, near a hot weld. (M111 wrights who are not also certified as welders are not permitted to perform welding on the plant.)
- Although Mr. Dillingham did not see the M111 wright welding, he had seen the same M111 wright on site with a welding hood (it was not clear from our interview whether Dillingham actually saw the hood r
at the same time he saw the Mi11 wright standing next to the weld inquestion.)
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Dillingham became concerned that the M111 wright might be im-a properly welding, and told George Tanley, his supervisor.
Dillingham told us that around this time, he asked Hank Hankins.
B&R Millwright, and Mike Phillips, B&R M111 wright foreman, about the weld in question, and was told that the weld had been welded by a certified Ironworker welder.
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R After Mr. Dillingham reported his concern to George Tanley, he and Tanley and James Calicutt, B&R General Mechanical Superintendent, discussed Dillingham's concern. According to our interview with Mr. Dillingham, Tanley told Dillingham E . that if a non-certified Millwright was improperly welding, -
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( T ey would fire him. After Tanley made this statement, Dillingham clarified that he had not witnessed the Millwright w
( in question performing any welding. In the circumstances, according to Mr. Dillingham, he and Mr. Tanley agreed not to f take any action.
9 We asked Mr. Dillingham whether he had knowledge of any bad welding practices or bad welds on the C.P. site. He told us that to his knowledge, all welds and welding practices on the
[ site are " good".
E d c. Investigation Results a
b As far as the one incident discussed during the interview, it appears that Mr. Dillingham is now satisfied, and was satisfied a
M at the time of the incident, that there was no basis to take"
]( action, since he never actually witnessed the Millwright in question performing welding. (Millwrights are not permitted to E perform welding on the plant.) It is not unusual or improper for y
a Millwright to ha/e a welding hood on the site. There are a
$ variety of possible explanations. The most common situation fhi would be a Millwright who welded on a job prior to C.P. and who kept his hood in his tool box brought to the . site. Since Mr.
M Dillingham told us he has no knowledge of welding by non-qualified employees, there is no basis for further investigation of the E[ first sentence in letter Item 4.
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In our intervicw with Larry Witt, he acknowledged that he typed l the letter to Mr. Feehan, but he told us that he had not written the second sentence of letter Item 4, but had typed it from a handwritten letter prepared by Mr. Dillingham. Mr. Witt told us he had no knowledge of C.P. welding being performed'by uncertified
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people to " speed up" the job or for any other reason.
Both Mr. Dillingham and Mr. Witt disclaim responsibility for sente[ ice 2 of letter Item 4. Mr. Dillingham has no knowledge of welding by uncertified employees, as noted herin. ~ Therefore, based on our interviews with Messrs. Witt and Dillingham, we find no basis for thi concerns expressed in letter Item 4.
2 I have reviewed with Mr. Dodd the B&R management response to letter Item #4,
, as contained in this memorandum. I no longer have a concern about this item, based on my review.
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Ritnessed 6 /(date)
- 5. Item 5 - Steam Generators
- a. The letter states: "The main support steel on installation of lagging on the steam generators'was received on the jobsite with 7
improper welding. I reported this to George Tanley, my supervisor, and to Greg Brown, a mechanical engineer. I was told that the problem had been solved by writing a letter to Westinghouse telling
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them to strive for better craftsmanship among their subcontractors.
( The bad welds are still in existance and have not been repaired.
We could have repaired tham ourselves, as a backcharge to Westing-
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house, but Mr. Tanley an0 Ar. Brown accepted the faulty supports, thereby making Brown and Root responsible." -
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e -
In cur interview with Larry Witt, he acknowledged that he~. typed the letter to Mr. Feehan, but he told us that he had not written the second sentence of letter Item 4, but had typed it from a f handwritten letter prepared by Mr. Dillingham. Mr. Witt told us he had no knowledge of C.P. welding being performed'by uncertified people to " speed up" the job or fcr any other reason.
i Both Mr. Dillingham and Mr. Witt disclaim responsibility for i
sentence 2 of letter Item 4. Mr. Dillingham has no knowledge of welding by uncertified employees, as noted herin. Therefore, based on our interviews with Messrs. Witt and Dillingham, we find 'no 4
basis for the concerns expressed in letter Item 4.
y h I have reviewed with Mr. Dodd the B&R management response to letter Item #4, as contained in this memorandum. I no longer have a concern about this item, based on my review.
0 .0 % Azr1 h0-$L 3
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Ritnessed~ * /(date)
- 5. Item 5 - Steam Generators
- a. a. The letter states: "The main support steel on installation of lagging on the steam generators'was received on the jobsite with 7 improper welding. I reported this to George Tanley, my supervisor, and to Greg Browns a mechanical engineer. I was told that the problem had been solved by writing a letter to Westinghouse telling b ,
them to strive for better craftsmanship among their subcontractors.
, The bad welds are still in existance and have not been repaired.
We could have repaired them ourselves, as a backcharge to Westing-house, but Mr. Tanley and Mr. Brown accepted the faulty supports, j 4
thereby making Brown and Root responsible."
- 5 !
l 1
)
i
b b. Dillingham Interview F Mr. Dillingham told us he identified a problem with welds on
.( {
r Westinghouse main support steel used for the installation of i insulation lagging. He said he uncovered the problem "in the sandblast yard during blasting." Dillingham said he was looking at Westinghouse vendor material in the yard (prior to plant' install-I ation), and that welds on the material in question had pinholes and no penetration. Mr. Dillinsham told us this was contrary to the F requirements of "the print" (drawing) for the vendor material, which ,
I he said called for full penetration welds. !
l l Mr. Dillingham told us that he brought his concern to George Tanley's attention, and that rir. Tanley told him that the problem hac been " solved." Mr. Dillingham stated that he is still con-i cerned because he has seen no rework performed on the welds.
- c. Investigation Results We asked Mr. Tanley and Greg Brown, B&R equipment engineer super-f visor, whether they were familiar with Mr. Dillingham's concern.
( Even though it was not Mr. Dillingham's responsibility to install or inspect the welds in question, he did notice a potential problem I and reported this to Mr. Tanley. Tanley told us that when he was informed of Dillingham's concern, Tanley went to the laydown yard with Mr. Dillingham to look at the welds. Mr. Tanley agreed that '
i engineering should review the welds. Within a day..Mr. Tanley took
, Mr. Brown to the yard'so that Mr. Brown could perform an engineering review.
o We talked to Brown, who told us that he inspected the welds being questioned by Dillingham. Brown said the welds were furnished not by Westinghouse, but by Mirror Insulation Co. Brown said the welds
)
Were not safety-related and that therefore, QC inspcctions had not been required. Although Brown agreed that the welds were not l l
of " top quality", his engineering judgment was that the welds would !
perform their intended function and could be dsed as is. This ;
explains why no rework has Deen performed on the welds. .
Although Mr. Browr.'s disposition was not required to be docu-mented, we asked him to prepare a memo confimin the engineering
- i. ,, yd/f4-review that was performed. Attachment & is a memo to Mr. Tanley and Mr. Frankum, dated August 10, 1982, on this subject. The' memo 1s signed by Mr. Brown, and by Mark Smith for C.K. Meehlman, l
Mechanical Engineering Supervisor. The memo states that "although the welds are not ' pretty' they are acceptable for this non-Q I service." The memo also reflects that "the vendor has been cautioned regarding workmanship in the future "
Based on our investigation of letter Item 5, we are satisfied that
(
Mr. Dillingham's original concern over the referenced welds was properly investigated and dispositioned by B&R site manageme'it and engineering personnel. We find no evidence that any safety procedures were violated, or that there is any basis for the concern expressed in letter Item 5. As with all the other items addressed in this letter, management will carefully explain its findir.g to Mr. Dillingham. ,
I have reviewed with Mr. Dodd the B&R management response to letter Item #5,-
as contained in this memorandum. I no longer have a concera about this item, based on my review.
c O.12Y2b 4. T-/1 82L date) l Q
( Witnessec (ff'2-(date) J l
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19
- 6. Item 6 - False Documentation
- a. Letter states: "In many instances, false documentation has been filed by the Millwright and Boilermaker departments. I was in ,
fonned that approximately 350 ' Travelers' had hold points missed.
Later, they were filed as being complete without any re-work.
These were all safety related 'Q' Travelers."
- b. Dillingham Interview g giz. Ng/
% th Dillingham told us that approximately i=6 months ago George Tanley instructed Mr. Dillingham and others to assemble all outstanding weld documentation, such as weld filler material logs, t
weld " chits" (showing the welder, weld number, and weld filler material number), NDE logs, and other documentation held by various disciplines, pertaining to completed welding performed on the stainless steel fuel pool liners. Tanley asked that all outstanding documentation be assembled, and that the information be transferred to the appropriate traveler, in order to update the wns ruo a QR,.
j
' travelers and move them to the QA Vault. Dillingham sa44 that . Aa
- Ord #
some 350 travelers were involved. An example of a stainless steel l 6df (In/n-t liner inspection traveler is attached (Attachmenty) w rk .
in the field on the stainless steel liners hd br. completed at I
the time of Tanley's request.
L Mr. Dillingham was surprised that information in the various weld
- documents was sufficient to demonstrate that all weld hold points (as listed on the travelers) had in fact been completed. Howevdr, e
contrary to the reference to "many instances" in letter Item 6, 1
] ,
20 in the interview Mr. Dillingham told us he knew of only one l specific instance, described below, where documentation could not be pioduced to . verify a hold point. He was careful to state in the interview that even this one incident did r.ct involve " false documentation," as alleged in the letter. Mr. Dillingham cited no instance of false documentation during the interview.
The only specific incident cited by Mr. Dillingham in the
- - interview involved an NCR writteri by James Cole, B&R QC inspector.
Mr. Dillingham ~said that in the incident in question, a stainless hanger had been hung over the weld, covering it up.,When Mr. Cole went to the weld location for final inspection, he could not find
- the traveler verifying that a previous weld inspection had been perfomed. At the time, the traveler had been temporarily -
k misplaced by the Boilermaker department. Since Mr. Cole did not have the traveler to verify that a previous inspection had been -
e performed, he properly wrote an NCR, requiring removal of the hanger and reinspection of the weld. Thus, although Mr. Dillingham was apparently concerned about the misplaced traveler, he believed
- that B&R QC (Mr. Cole) responded in accordance with procedure, and Mr. Dillingham stated to us that no problem exists today with the wel d. Mr. Dillingham suggested we discuss Item 6 with Craig Fowles,
) - B&R Boilemaker Foreman.
K h
. c. Investigation Results -
We talked with Mr. Cole about the incident described in our 4
interview with Mr. Dillingham. He confirmed the incident in
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.. 21 o
question, but agreed with Dillingham that proper QC procedure
- had been followed; the NCR in question is attached (Attachment ) YFM f I which verified that proper responsive action was taken. Mr.-Cole )
- told us that he had actually performed the original inspection - l 1
on the weld, prior to placing the hanger. He indicated that
- the' traveler in question was located subsequent to removal and reinspection of the hanger per the NCR. Cole said the
}
original traveler is included with the current documentation i
for the weld in question.
l .
f,.. Mr. Cole has had responsibility for fuel pool travelers since ,
i late 1981, and has worked with fuel pool travelers since January,
~
1980. He told us flatly that he never sa'w any evidence of falsification of the travelers. Cole could recall only "a few" instances where hold points had been missed on the fuel pool travelers. In each case, Cole wrote an NCR and properly i
dispositioned the nonconformance. These nonconformances did
(
not involve any falsification.
i Cole emphasized that the inspectors would have identified falsification of QC signatures on any fuel pool travelers, had it ever occurred! He said that missed hold points likewise
. would have easily been detected at final inspection points. In response to letter Item 6, we asked Mr. Cole and Sam Wilkerson, another QC inspector familiar with the fuel pool travelers, to select a random sample of fuel pool travelers from the QA vault;
. and to look for any signs of either missed hold points or i '{
- (
l j
i l
YM u $22[ 5lHlW signature falsification. Attachment N ,sumarizes the results of ,
1 their reviews. Mr. Cole and Mr. Wilkerson state in the attachment that there were no indications of unsigned holdpoints or falsified signatures on the sample of fuel pool travelers examined. .
l We also discussed letter item 6 with Craig Fowles, as suggested '
by Mr. Dillingham. Fowles knew of no instances of missed hold points, traveler falsification, or other procedural violations involving the fuel pool travelers.
We discussed this item with Janet Yourbrough during two interviews conducted this week. Ms. Yourbrough is a documentation clerk working under Mr. Tanley with the fuel pool traveler documentation. She has worked with the fuel pool travelers for approximately the past three years.
i During the first interview Ms. Yourbrough cited an instance which appeared to her at the time to involve the improper traveler entry by Mickey Garrett, B&R millwright documentation clerk, of what she described in the first interview was a i " weld number". She gave no other specifics.
t We spoke with Garrett 4 who in addition to working at the plant serves as the Mayor of Glen Rose, Texas.
Garrett was not aware
, of the incident to which Ms. Yourbrough was referring. Garrett ,
l denied ever making an improper entry into a traveler without supporting documentation to justify the entry. Mr. Garrett who has worked closely on traveler documentation with Ms. Yourbrough,
w--
. .. a y and-in fact helped train Ms. Yourbrough. Both have good employment records.
We interviewed Ms. Yourbrough again to try to get some specifics ,
I on the alleged incident. We emphasized to Ms. Yourbrough that we would be interested in any information she could give tending to support her recollection that Mr. Garrett improperly entered a weld number on a traveler. We emphasized that her statement
= appeared to suggest that Mr. Garrett falsified the traveler, and that if this could be verified Mr. Garrett would be subject to immediate termination, and conceivably could be subject to
{ criminal prosecution if it turned out that he actually falsified an official plant record. Ms. Yourbrough was repeatedly encouraged to furnish any information without fear of retribution.
Ms. Yourbrough could give few specifics. She did say in the j second interview that she believed the information entered by i
Mr. Garrett involved not a weld number, as she had previously
[. stated, but a weld filler material log number.. She said she E
- ,
- had never seen Mr. Garrett do anything else that appeared to her to violate procedures. Ms. Yourbrough said she had never seen other examples of popsible falsifications.
I l At the end of the second interview, Ms. Yourbrough stated that she was no longer sure about what she had seen Mr. Garrett l
do and that she wanted to leave the interview "to think it over." l We encouraged her again to bring to management's attention any information on this incident, or any other incident, involving possible procedural violations or safety problems at the plant.
t
.s ..
j Finally, Ms. Yourbrough stated in the second interview she had probably reviewed 50% of the C.P. fuel pool travelers, and that she had never received a traveler reflecting a
'Y ,
missed hold point, which she said would have been easy to ,
identify.
With respect to Mr. Dillingham's letter item 6, it appeared
)
from our interview with him that he is now only concerned about the one incident involving Mr. Cole's identification of a misplaced traveler. Mr. Dillingham's concern was not with falsification in that instance. We are satisfied from our p
investigation that the temporary misplacement of the traveler was properly handled by B&R QC, and that there is at present no indication that falsification or a missed hold point is involved. Our other interviews, as summarized herein, also k satisfy us that safety procedures were followed in connection with the completion of the fuel pool travelers. Thus, we conclude that there is no basis for letter item 6.
1 With respect to Ms. Yourbrough's statement in our first f interview that Mr. Garrett improperly filled in a weld number on a traveler, Mr. Garrett has denied any such occurrence.
Further, Ms. Yourbrough was not sure about her original assertion by the end of our second interview, and wanted to "think about it." Since Ms. Yourbrough has not told us which traveler or h plant area may have been involved, and has not directed us to.any P4 j other relevant evidence, there is nothing left to investigate.
s 7 ,,-. _.m ,. _ g..y- .p -
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8
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. ./
We conclude that there is no basis to find that safety procedures I
were violated by Mr. Garrett based on the information presented by Ms. Yourbrough, and on information received from other employees N I~ b with whom we spoke. g[
.,(M-
,-)
.sh'Ri I have reviewed with Mr. Dodd the B&R management response to letter Itemg
( as contained in this memorandum. I no longer have a concern about this item, based on my review.
N[M M hQ' i
r4-e l K uC th'd&
Witnessed '
(date) 6
- 7. Item 7 - Diesel Generators
'l
) a. Letter states: " Repairs have been made on the diesel generator main supports without proper documentation. The k
main support now has five foot cracks around the repair area.
(Proper paperwork would have taken about two hours to get)."
- b. Dillingham interview N '
Contrary to the reference in the letter to " repairs,"
Mr. Dillingham told us he was really talking about only one instance which he said occurred recently. This involved the y ,
repair of the Unit #2 diesel generator support structure to correct a weld discontinuity. Mr. Dillingham stated that in
} '
the course of the repair, the welder involved, Danny Flowers, had used weld filler material drawn for another temporary
~
- h attachment ticket, rather than receiving new weld filler r
~
. . 26
- ' . l l
~
material as required by procedure. Mr. Dillingham said that besides, Palmer and Dillingham, the procedural violation was known by either Mike Palmer B&R millwright, or Ira Bell,
, B&R millwright. -
Mr. Dillingham also stated in the interview that some time after the repair procedure, cracks were found in the same general base metal area on which the repair had been performed, i
However, contrary to the implication in letter item 7 that there was a relationship between the faulty repair procedure and subsequent base metal cracks, Mr. Dillingham made it clear in p the interview that the cracks to which he referred were not related in any way to 'the earlier repair.
- c. Investigation results b
9 We interviewed Craig Fowles, B&R Boilermaker Foreman for the diesel generator area in question. We determined that the i events to which Mr. Dillingham made reference in our interview
. with him had occurred in July and August of this year. After 2 talking with the velder involved in the initial repair, e
Mr. Flowers, and witih George Tanley, who also kinew of the repair, we verified ,that Mr. Flowers had violated procedure b -
by failing to draw new weld filler material, and that Mr. Flowersg AND Lc'E dneNe3 '~ f .,
and Messrs. Dillingham, Tanley, Fowles or Bell,all failed to p. * -
cause an NCR to be written as required.
44y S=~
.i~*
Mr. Frankum and I directed that an NCR be written to document the procedural violation in question. TheNCR(M-82-01207 dated August 12,1982) is attached (Attachment ). Because 1 . ta d Vi the base metal area containing the weld in question was subsequently removed due to an unrelated repair of linear indication in the same general base metal area (see Attachment ,
NCR M-82-00902, referenced in NCR M-82-01207.. which together verify that the base metal weld.in question was removed), there is no further concern that Mr. Flowers'. procedural violation presents any current problem with the diesel generator base metal area.
Mr. Frankum plans to ho geggi h extweekg Messrs. Tanley, fowles, and Dillingham (and possibly with either Mr. ' Palmer or Mr. Bell). Mr. Frankum will distribute copies I of NCR M-82-01207, and will reprimand those at the meeting for
)
failing to ensure that an NCR was drafted and dispositioned at /
the time the procedural violation in question was first f identified, as required by procedure.
g n
J L We conclude that the above responsive actions properly \ .' A address the concern raised by Mr. Dillingham pursuant to letter item 7.
~ ,
.. . q I have reviewed with Mr. Dodd the B&R management response to letter Item , ,
as contained in this memorandum. I no longer have a concern about this item, based on my review.
M.. I NM-7.2 fLudy '
Witnessed i (date) d E
- . - - - - , - - , - _ . . . . , . .--.~sm -- m.
.u..
- 8. Item 8 - Rebar Cutting
- a. The letter states: "Rebar has been cut on the Main Steam Support and other supports without approval. This could result in millions of dollars in cost of re-work. Jim ,
'Starkey has p'ersonally cut rebar in order to save energy ih moving the boring equipment to the correct location. I know that this was brought to the attention of Hal Goodson, and Mr. Goodson told this person to ' mind your own business if you know what's good for you'."
- b. Dillingham interview According to our interview with Mr. Dillingham, he has no first hand knowledge of the concerns recorded in letter item 8.
He told us the item was based on statements made to him by Danny Grisso, a leaderman who works in the B&R hanger department. According to Mr. Dillingham, Grisso told him that Grisso was the individual who allegedly complained to j
Hal Goodson, Grisso's Assistant Superintendent, that James Starkey, B&R foreman in the hanger department, was improperly cutting rebar. According to Dillingham, contrary p to statements in Mr. Dillingham's letter, Grisso knew of only one instance of, apparent improper cutting of rebar by Starkey, which Dillingham told us was in the H. P. Turbine support of elevation 830. Dillingham told us in the
' interview that when Crisso complained to Goodson, Goodson stated that Starkey had removed rust off the rebar in question but had not cut any unauthorized rebar.
, e d.
- c. Inv stigation results Doug Frankum and Larry Ashley interviewed Hal Goodson, Jim Starkey, and Danny Grisso. In addition, Doug Frankum and Jack Dodd accompanied Grisso, Starkey and Goodson to ,
visually examine TG #1 Pipe Support MS-1-071-001, the area of Grisso's apparent concern. Griso looked in the top west hole of the support, and saw cut rebar, and confirmed that this was the area about which he was concerned.
We returned to the office, and pulled documentation for that support. We reviewed the documentation separately and together, and identified one document in particular
_~ @Q} fp/8" (Attachment J ), dated September 3,1981, which provided engineering justification for cutting "second layer beam reinforcing or interior tie bars." Mr. Grisso and the rest of us concluded that the cutting Mr. Grisso has witnessed was I of an interior tie bar, as permitted by the September 3,1981 memeo. Mr. Grisso indicated that he was satisfied that there I t l 5 had not been any violation of procedure. Grisso further c( d l t
stated that he was not aware of any instances of rebar cutting without proper documentation. y, I
In light of the above, we conclude that letter item 8 is ,
without basis.
e I have reviewed with Mr. Dodd the B&R management response to letter Ite.m g as contained in this memorandum. I no longer have a concern about this item, based on my review.
d (2O Y A V- ^Y-7.2
] pidM&F f)'bTt 2 -
Witnessed I '(date)
/
.> August 13, 1982
],
l l
P ADDENDUM I '
In a meeting today with Jack Dodd, I told him I think the Comanche Peak plant is a totally safe plant, and that I have no safety concerns.
L I said chis of my own free will, and told Mr. Dodd I would be happy to say the same thing in writing.
0s
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-r k f~ /W~ VA y
MN Witnessed NtEYf'x 4(date) l.,.N y
I I
m l
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~-
gEug;D ;ui..r_Sica0ENCE 00cKETE0 USNRC October 10, 1984
'84 00112 A10:29 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFIE OF L'At %
00CKET*G & SEf6 ' '
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
TEXAS UTILITIES GENERATING )
COMPANY, et al. ) Docket Nos. 50-445-2
) and 50-446-2 (Comanche Peak Steam Electric )
S ta t io n , Units 1 and 2) )
CERTIFICATE OF SERVICE By my signature Delow, I hereoy certify that true and correct copies of CASE's Motion for Production of Documents from Applicant nave Deen sent to the names listed oelow this 10th day of Octooer, 1984, Dy: Express mail where indicated oy *; Hand-delivery where indicated oy **; and First Class Mail unless otnerwise Indicated.
Aaministrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission 4350 East-West Highway, 4 th Floor Betnesda, Maryland 20814
- Heroert Grossman
! Alternate Chairman ASLB Panel U.S. Nuclear Regulatory Commission l 4350 East-West Hignway, 4th Floor Bethesda, Maryland 20814 i
Dr. Kenneth A. McCollom, Dean Division of Engineering, Arcnitecture and Tecnnology
- Oklahoma State University
! Stillwater, Oklahoma 74074
I * * .,
l v
Cr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Ms. Ellen Ginsoerg, Law Clerk U.S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Bethesda, Maryland 20814 Nicholas S. Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, N.W.
Washington, D.C. 20036 Stuart Treby, Esquire Geary S. Mizuno, Esquire Office of Executive Legal Director U.S. Nuclear Pegulatory Commission Maryland National Bank Building Room 10105 4350 East / West Highway, 4th Floor Bethesda, Mary. land 20814 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis ~
President, CASE 1426 S. Polk
, Dallas, Texas 75224 l
l
/
.i >A /
$T80NY'Z*. $MfR Trial Law for Public Justice 2000 P S t, N.W., Suite 611 Washing n, D.C. 20036 (202) 463-8600 ,
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