ML20135A869

Investigation Case 5-82-019 Re Alleged Piping Sys Const Deficiencies.Violations Noted:Allegation 10 Re Foreman Ordering Cold Springing Confirmed.Case Closed

ML20135A869
Person / Time
Site:	Palo Verde
Issue date:	06/19/1985
From:	Hayes B, Joukoff P, Shackleton O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), NRC OFFICE OF INVESTIGATIONS (OI)
To:
Shared Package
ML20135A816	List: ML20135A813 ML20135A822 ML20135A834 ML20135A845 ML20135A856 ML20135A869
References
5-82-019, 5-82-19, NUDOCS 8509100298
Download: ML20135A869 (25)

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Title:

PALO VERDE NUCLEAR GENERATING STATION ALLEGED CONSTRUCTION DEFICIENCIES REGARDING PIPING

-_- SYSTEMS e

d. Licensce: Case Number: 5-82-019

1. Arizona Public Service Ccmpany Report Date: June 19, 1985 P. O. Box 52034 Phoenix, Arizona 85072 Control Office: 01:RY Status: CLOSED Reported by: Reviewed by:

[ f/ TW l ? _

Philip V. g' ukoff, Inves i N - Cwen C. Sfiackleton Jr., Dir9ctor Office of Investigati . Office of Investigations Ft' eld Office, Region V Region V Participating Personnel: Approved by:

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.' Eugene J. Power, Investigator 3 . .- i [.l( L 4 Office of Investigations Field Beh B4 fayes,

• Director Office, Region _V Officejof Investigations e

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____m

SUMMARY

This investigation was initiated to determine the validity and the cir-cumstances involving concerns expressed by a former pipefitter (hereinafter termed the alleger) employed by the Bechtel Power Corporation (BPC) at the Palo Verde Nuclear Generating Station (PVNGS), Maricopa County, Arizona. The alleger had worked for BPC for 2 years and 2 months from approximately March 1980 until May 1982.

. After terminating his employment at PVNGS, the alleger, in June 1982, wrote letters to Steven BECHTEL, Chairman of the Board, BPC; the

' Pipefitters International Union; and the Pipefitters Union Local in d Phoenix, Arizona; demanding a total of S20,000,000 as_ compensation for on-the-job injuries the alleger stated that the alleger had received

/ while employed at PVNGS. The alleger subsequently withdrew the demands made of the Pipefitters Union Local in Phoenix, Arizona and issued a public apology in the form of a classified newspaper advertisement, which appeared in the Arizona Republic Newspaper.

By letter dated August 1,1982, the alleger forwarded to the U.S. NRC in

, Washington, D.C. the alleger's concerns regarding PVNGS. As a result', '

the alleger was located and interviewed by two U.S. NRC investigators on

. December 20, 1982 in Corpus Christi, Texas.

During the course of the interview, the alleger expressed con: erns regarding the activities of Arizona Public Service (APS), the licensee; BPC, and the U.S. NRC at PVNGS. The alleger's concerns, which are hereinafter referred to as allegations, were as follows:

i Allegation No. 1. Inside the containment Building of Unit 1, a 14-inch stainless steel pipe that connects to a Safety Injection Tank 2A is made of unacceptable metal.

Allegation No. 2. At the 40'-0" elevation of the Auxiiiary Building of Unit 1, there is a four-inch drain line in which there exists an undocumented or " hidden" weld.

Allegation No. 3. At the 100' elevation of the Radwaste Building of Unit 1, there is a pump that the alleger thought would be used to pump " rad waste" material. The

. d .~', alleger overheard a conversation in which the installation of a catch basin was being discussed for 4

the packing gland of this pump that would catch leakage and drain it to a floor drain. The alleger stated that this catch basin and a leaking packing ,

gland did not seem proper for a pump moving " rad waste."

Allegation No. 4. The pipe supports for large piping in the Main Steam Support Structure (MSSS) appeared, to the alleger, to '

be welded to inadequate (only one-inch thick) steel imbed plates.

2

. Case No. 5-82-015 1

Allegation No. 5. At the 156' elevation (roof top) of the Turbine Building and the Control Building of Unit 1, the alleger stated that there are " cold laminations" in some of the ten-inch pipes that connect to " chillers" located on this roof.

Allegation No. 6. In the Radwaste Building of Unit 1, the alleger stated that there is a pipe support that is welded across the width of a large I beam. The alleger r e advised that he had been taught not to weld across a

beam as this weakens the beam.

'. Allegation No. 7. The alleger stated that he was critical of inspections performed by the NRC at PVNGS since the NRC inspectors rely on documentation provided by BPC and do not talk with individual workers.

Allegation No. 8. The alleger advised that while employed at PVNGS, both drugs and alcohol were openly sold and used on the site. . -

Allegation No. 9. The alleger expressed concerns regarding the location

-i of PVNGS as there are two old volcanoes located near j the site.

Allegation No. 10. The alleger stated that while working on a large pipe at PVNGS (approximately 30 inches in diameter),

the alleger was directed by a foreman to " cold spring" the piping system to achieve the correct

" fit-up." The alleger advised that it was necessary to " cold spring" the pipe as a 90 elbow that was previously installed on the pipe was not straight.

According to the alleger, the foreman did not want the elbow removed and reworked so that it would be straight. The alleger added that it was while working on this pipe that the alleger was seriously injured.

i' Allegation numbers 1 through 9 are contained in-a signed sworn statement

,[ executed by the alleger. Allegation number 10 was provided verbally to

, ., U.S. NRC investigators by the alleger after the alleger had signed the statement.

Allegation numbers 1 through 6, 9, and 10 were determined to be issues of a technical nature, and were referred to the Regional Administrator, ,

Region V (RV), U. S.- NRC, for_ their evaluation and possible inspection and_ enforcement action. The results of these inspections are documented in U.S. NRC Inspection Report Nos. 50-528/83-02, 50-528/83-11, 50-528/83-17, 50-528/84-36, and 50-528/84-65.  !

In January 1983, after initial. inspection by RV inspectors, RV requested that the Office of Investigations Field Office, Region V (01:RV) provide assistance to the'RV inspectors in determining the circumstances surrounding- -

1 Case No. 5-82-019

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the completion of an undocumented Quality Class 1 weld, that the RV inspectors had located, which was completed in violation of NRC rules /

regu?ations (Allegation No. 2). RV further requested the assistance of OI:RV to ascertain whether or not welder /pipefitter supervision directed the improper installation of Quality Class 1 piping by directing that piping be elastically deformed or " cold sprung" during installation (Allegation No. 10). RV inspectors had confirmed, from their inspection, that the alleged " cold springing" had occurred.

. As a result of the above, the Director, 01:RV, directed that an investi-gation be conducted into Allegation Numbers 2, 7, 8, and 10.

In respect to Allegation Number 2, investigation determined that two BPC craft workers, a welder and a pipefitter, completed the weld in question.

/ The two workers completed signed sworn statements attesting that they completed the weld of their cwn volition to correct a mistake they had made, and were not directed to do so by any APS/BPC supervisors or APS/BPC management representatives. Investigation further revealed this incident to be an isolated case; however, the investigation also uncov-ered that a BPC foreman may have had knowledge, after the fact, that the weld in question had been completed and did not take any corrective '

action. The foreman in question was interviewed twice by 0I:RV investi-gators, but did not admit to any knowledge of the weld in question. The foreman'in question subsequently retained an attorney who would not allow further 0I:RV contact with the foreman without the foreman first being granted immunity from prosecution by the U.S. Department of Justice (00J). During the investigation of this allegation, a total of 15 craft workers and craft worker supervisors were interviewed, and no evidence of the existence of any other similar welds was developed.

In respect to Allegation Number 7, the alleger stated that he was critical of the methods used by NRC inspectors at PVNGS (i.e., reviewing documentation provided by APS/BPC and not talking with craft workers).

The alleger added that craft workers at PVNGS are directed by their supervisors not to talk with NRC inspectors. The alleger did not, however, make any allegations of wrongdoing on the part of any NRC

inspectors. Investigation into this concern revealed that both-the NRC regionally based and NRC resident inspector (s) routinely talk with craft workers during their inspections. The NRC inspectors that inspect at PVNGS further advised that they conduct their inspections at times alone

, ano sometimes accompanied by APS/BPC representatives, and that the high majority of their inspections are conducted without prior notification -to APS or BPC. During the course of this investigation,15 craft workers and craft worker supervisors were interviewed and it could not-be sub-stantiated that craft workers were directed not to talk with NRC .

inspe: tors.

In respect to Allegation Number 8, the alleger stated that hoth ccntrolled drugs and alcohol were openly sold and used at PVNGS. The alleger was advised that the NRC was concerned with the practice of such illici activities on a nuclear construction site; however, the NRC had Case No. 5-82-019 3-

no jurisdiction in such matters since they are the responsibility of the local law enforcement agency in the area in which a plant is located.

Therefore, in accordance with current NRC practices, all available information regarding drugs was provided to the licensee, APS, for appropriate action. No further action was taken by the Office of Investigations concerning Allegation Number 8.

In respect to Allegation Number 10, the alleger stated that while employed at PVNGS, he/she was directed by a supervisor to " cold spring" e or plastically deform a large 30-inch pipe in violation of normal installation procedures. Initial inspection by Region V inspectors 4 determined that the alleged " cold springing" had occurred. Initial

-~ investigation by OI investigators determined that the alleger's foreman had ordered the " cold springing" as was alleged. The foreman could not

/ recall whether or not he had the " cold springing" approved by BPC engineering prior to directing that it be completed. The foreman further stated that none of his superiors directed him to order the " cold springing." On January 25, 1985, RV issued their final inspection report on this allegation concluding that although some " cold springing" did occur, the "as-found" conditions of those piping systems analyzed were technically acceptable. -

l -

O Case No. 5-82-019 4

l

i ACCOUNTABILITY i

The following portions-of this ROI (Case No. 5-82-019)-.will not be included fin.the material placed in the PDR. .They consist of pages 5 through 23.

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TABLE OF CONTENTS Pace No.

SYN 0PSIS ....................................................... 1 DETAILS OF INVESTIGATION........................................ 7 Purpose of Investigation................................... 7

. Background................................................. 7 Allegation No. 2 - Existence of an Unauthorized and Undocumented Quality Class 1 Weld......................... 8 d Interview of Alleger........................................ 8 Information Obtained from Paul P. NARBUT, Reactor

/ Inspector, U.S. NRC....................................... 9 Interview of Kenneth Wayne NARREN........................... 9 Interview of Robert D. JANTH0............................... 9 Intervi ew of James R. PAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Contact of Ross ANDERSON, Attorney for James R. PAGE........ 11 Review of Revised Statement of James R. PAGE................ 12 Interview of Other Involved Individual s. . . . . . . . . . . . . . . . . . . . . '12 "

Allegation No. 7 - NRC Inspectors Rely on Documentation Provided by BPC and do not Talk with Workers; Workers Told not to Talk to NRC Inspectors........................ 13 Interview of Alleger........................................ 14 Interviews of PVNGS " Mechanics"-(i.e. Non-Supervisory Craft Workers................................................... 15 Interviews of PVNGS Supervisory Craft Personnel............. 15 Interview of Lucian E. VORDERBRUEGGEN, Senior U.S. NRC Resident Inspector, PVNGS................................. 15 Interview of James H. ECKHARDT, Former Principle U.S. NRC Project Construction Inspector, PVNGS..................... 16 Interview of Paul P. NARBUT, Principle U.S. NRC Project Construction Inspector, PVNGS............................. 16 Re-Contact of Lucian E. V0RDERBRUEGGEN. . . . . . . . . . . . . . . . . . . . . . 16 Allegation No. 9 - Drug / Alcohol Usage at the PVNGS Site..... 17

. Interview of Alleger........................................ 17

• -Allegation No. 10 - Alleged Plastic Deformation or

" Cold Springing" of Quality Class 1 Piping During Installation.............................................. 18 .

Interview of Alleger........................................ 18 Interview of Nicholas.MAVR0LAS.............................. 19 Interview of Lloyd HESTAND.................................. 19 Interview of Robert L0NG.................................... 19 Interview of Nelsen N0FSINGER............................... 20 Review of RV Inspection Reports............................. 20 LIST 0F. EXHIBITS................................................ 23 Case No. 5-82-019 5

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Case No. 5-82-019 6

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DETAILS OF INVESTIGATION Purpose of Investigation The purpose of this investigation was to determine the circumstances sur-rounding the completion of an undocumented Quality Class 1 weld at the Palo Verde Nuclear Generating Station (PVNGS), Arizona, by welders /-

pipefitters employed by the Bechtel Power Corporation (BPC). This investigation was further conducted to ascertain whether or not welder /-

. pipefitter supervision (i.e., foreman, general foreman, and superintendents) directed the improper installation of. Quality Class 1 piping by directing that piping be elastically deformed or " cold sprung" during installation.

Background

The Palo Verde Nuclear Generating Station (PVNGS) consists of three nuclear power units under construction. PVNGS is located in the desert region 36 miles west of the western boundary of Phoenix, Arizona. The construction permits were issued to the Arizona Public Service Company (APS) by the U.S. Nuclear Regulatory Commission (NRC) for PVNGS 1, 2, and 3 on May 25, 1976. The Bechtel Power Corporation (BPC) is the -

architect-engineer and constructor for these three pressure water reactor plants.

By letter dated August 1, 1982, the Reverend Dewey E. WILLIAMS, a former pipefitter employed by BPC, forwarded to the NRC in Washington, D.C., his concerns regarding improper construction practices at PVNGS. A copy of this letter was forwarded to U.S. NRC Region V (RV) and also the U.S. NRC Office of Investigations Field Office, Region V (OI:RV), for inspection /-

investigation (see Exhibit 1).

Prior to receipt of this letter, 01:RV had been verbally advised, during

, July 1982, by Arizona Public Service (APS) personnel, that a Reverend 1 Dewey E. WILLIAMS had sent letters to Mr. Steven D. BECHTEL, Chairman of the Board, Bechtel Power Corporation; Mr. M. WARD, President, Pipefitters International Union; and Mr. Ray BROOKS, Business Manager, Pipefitters Union Local 469 (Phoenix, Arizona); in which WILLIAMS made allegations

. concerning PVNGS and a workman's compensation claim. APS personnel at that time advised that they were investigating these allegations.

y.

. , Copies of these letters were provided to OI:RV by Mr. William.IDE, Site QA Supervisor, APS (see Exhibit:2).

s On December 20, 1982, WILLIAMS was interviewed by OI:RV Investigators

0. C. SHACKLETON and P. V. JOUK0FF in Corpus Christi, Texas, and a signed ,

sworn statement was obtained, which outlined WILLIAMS' concerns (see Exhibit 3). In addition to the statement, WILLIAMS made one verbal allegation to the Investigatars. A review of all the allegations made by WILLIAMS determined that of a total of ten allegations, eight were of a technical nature. These eight allegations were forwarded to RV for inspection. The remaining two allegations, one pertaining to the

, methodology of inspections by NRC (Allegation No. 7), and the other regarding alcohol / narcotics usage at PVNGS (Allegation No. 8), were Case No. 5-82-019 7

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retained by OI:RV for investigation and/or referral to the appropriate office.

In January 1983, _after initial inspection by RV inspectors, RV requested that 0I:RV provide assistance to the RV-inspectors in determining the circumstances surrounding the completion of an undocumented Quality Class 1 weld, that the RV inspectors had located, which was completed in violation of NRC rules / regulations (Allegation No. 2). RV further requested the assistance of OI:RV to ascertain whether or not welder /-

pipefitter supervision directed the improper installation of _ Quality

• Class 1 piping by _ directing that piping be elastically deformed or " cold l sprung". during installation (Allegation No.10). RV. inspectors had l

• - confirmed, from their. inspection, that the alleged " cold springing" had

, occurred.

As a. result of the above, the Director, 01:RV, directed that an investi-gation be conducted into Allegation Numbers 2, 7, 8, and 10.

Allegation No. 2 - Existence of an Unauthorized and Undocumented-Quality Class 1 Weld Interview of Allecer On December 20, 1982, between 1900 and 2110 hours0.0244 days <br />0.586 hours <br />0.00349 weeks <br />8.02855e-4 months <br />, Dewey E. WILLIAMS, a former pipefitter employed by the Bechtel Power Corporation (BPC) at the Palo Verde Nuclear Generating Station (PVNGS), was interviewed at the Sandy ' Shores Motel, 3200 Surfside Blvd., Corpus Christi, Texas, by Investigators 0. .C. SHACKLETON and P. V. J0VK0FF. During the interview, WILLIAMS furnished the following information regarding this allegation:

WILLIAMS stated that in approximately May 1982, a welder employed at PVNGS by BPC by the name of Ken WARREN completed welding on a four-inch drain line located at the 40' elevation of the Auxiliary Building of Unit 1. WILLIAMS advised that_during the process of ccmpleting this welding, WARREN fabricated a short. piece of pipe, commonly called a " pup" piece, which WARREN welded into the line. WILLIAMS stated.that WARREN further buffed and ground the pipe to hide the weld. _ WILLIAMS added that WARREN did the above act without authorization and that x-ray _ analysis of the weld was nct done. WILLIAMS averred that the insertion of such a

." " pup" piece and the-grinding'and buffing of the weld to make it not

, identifiable was contrary to construction practices he had learned for nuclear power plants.

( Investigator's Note: Welding of an unauthorized and undocumented Quality Class 1 weld in a-nuclear power plant is contrary to regulatory-

. requirements--specifically 10 CFR 50, Appendix B, Criterion V, which states, in part: " Activities affecting _cuality shall tut prescribed by idocumented instructions, procedures, or drawings of a. type appropriate to the circumstances and shall be accomplished-in accordance with their instructions, procedures, or drawings...."

Cas: No. 5-82-019 8

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Information Obtained from Paul P. NARBUT, Reactor Inspector, U.S. NRC On January 24, 1983, Paul P. NARBUT, Reactor Inspector, U.S. NRC, RV, contacted Investigator P. V. J0VK0FF and advised that during the week of January 17-21, 1983, he physically inspected the drain line involved in this allegation while at PVNGS. NARBUT stated that his inspection revealed that an unauthorized and undocumented Quality Class 1 weld had been completed as WILLIAMS alleged. l

. NARBUT advised that from his review of BPC welder and welding records, he determined the names of 12 engineers, welders, and quality control (QC) inspectors that were involved with the drain line. NARBUT stated that

• . his interviews of all of these individuals failed to determine what person (s) willfully directed and/or completed the unauthorized and

/ undocumented weld in question. After review of the violation by the Director, OI:RV, an investigation was initiated.

Interview of Kenneth Wayne WARREN On January 19, 1983, between 0800 and 0945 hours0.0109 days <br />0.263 hours <br />0.00156 weeks <br />3.595725e-4 months <br />, Kenneth Wayne WARREN, a welder employed by BPC at PVNGS, was interviewed at the NRC Resident ~

Inspector's office at the Palo Verde site by Investigator P. V. J0VK0FF.

During this interview, WARREN furnished substantially the following {

information regarding this allegation: j WARREN admitted that he and the pipefitter that was working with him during February 1982, Robert JANTH0, completed the undocumented Quality Class I weld that is involved in this case. WARREN stated that he and JANTH0 did the weld to "fix" a mistake that they had made. WARREN further stated that he and JANTH0 did the weld of their own volition and were not directed to complete the weld by anyone. WARREN completed a signed sworn statement regarding his involvement in this weld (see Exhibit 4).

Investigator's Note: During WARREN's interview on January 19, 1983,

} WARREN requested that his name be kept confidential and a confidentiality

} agreement was executed (see Exhibit 5). On January 20, 1982, while

, executing his signed sworn statement, WARREN stated to Investigators E. J. POWER and P. V. JOUK0FF that he had told his superintendent at

." PVNGS, Robert LONG, that he had admitted to the NRC that he had made the

., undocumented weld in question. WARREN was advised by J0VK0FF that due tc this act on his part, the MC will consider him to have waived his

,' right to confidentiality.

Interview of Robert E. JANTH0 .

On February 3,1983, between 1830 and 1915 hours0.0222 days <br />0.532 hours <br />0.00317 weeks <br />7.286575e-4 months <br />, Robert E. JANTHO, a pipefitter employed by the BPC at PVNGS, was interviewed at his residence, 5425 E. Terry Drive, Phoenix, Arizona, by Investigators-

0. C. SHACKLETON and P. V. J0VK0FF. During this interview, JANTH0 furnished substantially the following information regarding this allegation:

Case No. 5-82-019 9

t

e - t L

JANTH0 admitted that he and Kenneth WARREN, the welder with whom he was working in February 1982, completed the undocumented Quality Class 1 weld that is involved in this case. JANTH0 stated the he and WARREN did the weld to "fix" a mistake that JANTH0 had made while cutting the pipe that they were working on. JANTH0 further stated that he and WARREN did the weld of their own volition and that no supervisors or anyone else told them to do it. JANTH0 added that his crew foreman, James PAGE, was aware that he and WARREN had completed the weld in question.

JANTH0 completed a signed sworn statement regarding his involvement in

, this weld (see Exhibit 6).

Interview of James R. PAGE On January 19, 1983, between 1040 and 1120 hours0.013 days <br />0.311 hours <br />0.00185 weeks <br />4.2616e-4 months <br />, and on April 4, 1983, between 1410 and 1515 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.764575e-4 months <br />, James R. PAGE, a welder and former foreman employed by SPC at the PVNGS, was interviewed at the NRC Resident Inspector's office at the Palo Verde site. The first interview was conducted by Investigator P. V. J0VK0FF while the second interview was conducted by Investigators E. J. POWER and P. V. J0VK0FF. During the course of these two interviews, PAGE furnished substantially the ~

following information regarding this allegation:

PAGE was questioned regarding the four-inch drain line located at the j 40'-0" elevation of the Auxiliary Building, east side, of Unit 1 at e PVNGS. PAGE stated that he was contacted by NRC inspectors in the early part of 1983 regarding this drain line. PAGE added that he could recall the " tees" that were used on this job as they originally would not fit in the line and had to be modified by the APS machine shop at the site in order to be used. Other than remembering the " tees," PAGE advised that he could recall little else about this job. PAGE did recall that at the time this job was done, he was a foreman and did have werkers on his crew "in and out" of the area, but PAGE could recall little else about the job. l' After being shown BPC time cards regarding this job, PAGE recalled that two workers on his crew, Kenneth WARREN and Robert JANTHO, worked on the job. PAGE added that he thought that his general foreman, Paris ROGERS, took him down to the area and shcwed him the job originally; hcwever, the J' only four-inch " tees" that were available on the site were schedule 40, and the piping system involved required scheduled 10 " tees," according to PAGE. Consequently, PAGE recalled, the " tees" were sent over to the APS f machine shop located on the site where they were counter-bored to fit.

PAGE added that he recalled there being a " rush" to get the job done; however, it took quite a while for the machine shop to complete the counter-boring and return the " tees" for installation.

PAGE was questioned regarding the fact that BPC time sheets indicate that WARREN and JANTH0 spent a total of 44 man hours working on this job without apparently completing a great deal of work. PAGE agreed that it was a long time to spend on such a job and stated that when the job was in progress, he was not cognizant of the large n'.a er of man hours being expended. ,

I

PAGE stated that during the time period that this ' job was in progress, he was a foreman and, as a usual rule, would check on each of his crews once in the morning and once in the afternoon. PAGE recalled that he checked on WARREN and JANTH0 while they were doing this job, but did not recall observing any peculiar work being completed such as WARREN and JANTH0 inserting a " pup" piece or working on an undocumented weld. PAGE, in response to questioning, stated that he did not shake his head in a negative manner while looking at the work that WARREN and JANTH0 were doing as JANTH0 had stated in his signed sworn statement.

PAGE was questioned regarding the number of hours on the BPC time sheets that he charged to the job in question. PAGE advised that it was and is customary practice to charge a foreman's time basically in an evenly

' distributed manner among the jobs that workers en his crew were doing on any particular day. PAGE added that a foreman's time is not charged to the specific job on an actual basis, so he may not have spent numerous

, hours on this job as the time sheets reflect.

PAGE stated that the first time that he became aware of the undocumented weld in question was in early 1983. According to PAGE, a member of his work car pool told PAGE that WARREN had been called in to see a U.S. NRC~

representative regarding an undocumented Quality Class 1 weld. PAGE l reiterated that prior to this instance, he had no knowledge of the weld j in question.

I

! PAGE was cuestioned regarding his knowledge of any other uniocumented Quality Class 1 welds at PVNGS and he stated that he had never done such welds, had never seen anyone else do such welds, had never directed anyone to do such welds, nor did he have any knowledge of such welds in l any of the uaits at PVNGS. PAGE added that, to the best of his know- I ledge, ncne of his supervisors had any knowledge of this undocumented l Quality Class 1 weld.

Investicator's Note: As a result of the two interviews of PAGE, a draft signec sworn statement was prepared for review, possible modification, and signature of PAGE (see Exhibit 7). On April 6, 1983, in the presence of Investigator P. V. JOUKOFF, PAGE reviewed the draft statement and stated he would not sign the same without it first being reviewed by an attorney that he had retained. PAGE was asked by JOUK0FF if the state-

. ment was essentially correct as written and PAGE refused to answer stating, " Call my attorney." PAGE then supplied the name and telephone number of his attorney, a Ross ANDERSON of Phoenix, Arizona.

9 i Contact of Ross ANDERSON. Attorney for James R. PAGE On April 6, 1983, Investigator P. V. J0VK0FF telephonically contacted Ross ANDERSON. ANDERSON stated that he had been re ained by PAGE to act as his legal counsel. ANDERSON further stated that he did not want PAGE to execute a signed sworn statement or talk further with NRC investi-gators without ANDERS0fi reviewing the statement and/or being present.

ANDERSON added that he wanted immunity from prosecution for PAGE by the Department of Justice prior to any further interviews.

Case No. 5-82-019 11

Investigator's Note: On April 8,1983, a copy of the draft statement of James R. PAG G as hand delivered to ANDERSON's office in Phoenix, Arizona by Investigator P. V. J0VK0FF for ANDERSON's review. After numerous telephone contacts, ANDERSON finally supplied, on August 1, 1983, a revised signed statement for PAGE (see Exhibit 8).

Review of Revised Statement of James R. PAGE A review of the revised signed statement of PAGE submitted by ANDERSON shows that certain information provided by PAGE during his interviews (see Exhibit 9) with OI:RV investigators and incorporated in his draft statement had been eliminated. Specifically, the following two

'. references to PAGE having knowledge of the unauthorized and undocumented

' . Quality Class 1 weld at the time it was completed were eliminated from the revised signed statement:

1. "I recall that I did check on WARREN and JANTH0 while they were working on this job, but I know I didn't see anything peculiar being done. I know that I didn't see either WARREN or JANTH0 inserting or welding a " pup" piece or working on an undocumented Quality Class 1 weld. I further know that I did'not go into the area where WARREN ~

and JANTH0 were working and look at their work and then shake my head in a negative manner."

2. "...nor did I have any knowledge that it had been done until I heard on the way to work in the early part of 1983 from a member of my car pool that WARREN had been called in to see a U.S. NRC representative about an undocumented Quality Class 1 weld."

Investigator's Notes: i

1. The elimination-of these relevant passages from the signed statement of PAGE raises the question that PAGE may have supplied false /-

nisleading information to U.S. NRC Investigators E. J. POWER and P. V. JOUK0FF during his two interviews. During both of the j interviews, PAGE stated that he had no knowledge of the weld in question until the U.S. NRC started inquiries into the matter although JANTH0, in his sworn statement, stated that PAGE was aware of what transpired when the weld was being done.

l

- , 2. When PAGE's attorney, ANDERSON, was contacted by Investigator P. V. J0VK0FF on April 6, 1983, ANDERSON stated that he would not i

allow further interview of PAGE without immunity from prosecution i being granted by the U.S. Department of Justice. Consequently, the issue of PAGE's knowledge / involvement in the completion of the weld could not be pursued further during this investigation.

l Interviews of Other Involved Individuals During the course of the investigation of this allegation, the following additional individuals were also interviewed:

Case No. 5-82-019 12.

Results of Interview Name Title Employer Location Frederick Bernard HERMAN Welder BPC Exhibit 10 Abraham (NMN) ROSIN Pipefitter BPC Exhibit 11 Gregory Finis MILLS Welder BPC Exhibit 12 Charles Allen NELSON QC Inspector BPC Exhibit 13 Samuel John GRIGGS QC Engineer BPC Exhibit 14 Nicholas Jack MAVROLAS Welder BPC Exhibit 15 David Matthew BENNETT Welder BPC Exhibit 16 Louis Gran FREEMAN Pipefitter BPC Exhibit 17 Paris (NMN) R0GERS General B.'C Exhibit 18 Foreman Lloyd Wayne HESTAND Pipefitter BPC Exhibit 19 (former . ,

foreman)

Robert Heinz LONG Superinten- BPC Exhibit 20 dent (piping)

Nelson R. NOFSINGER Pipefitter BPC Exhibit 21 (former General Foreman)

The overall results of these interviews and the signed sworn statements executed revealed no evidence that APS or BPC management or supervision directed.that the unauthorized and undocumented weld in question be completed. Also, the interviews developed no evidence that other similar welds exist at PVNGS.

Furthermore, no evidence was revealed that APS or BPC management or

. supervision had knowledge that the weld in question was completed with the possible exception of PAGE, whose testimor.y could not be pursued

.' further without immunity from prosecution being granted by the U.S.

. ,- Department of Justice. '

~

Based upon the above facts, further investigation into the' issue of

.PAGE's knowledge of the weld prior to the U.S. NRC inquiry could not pursued at the time of this investigation.

4 Case No. 5-82-019 13

~

Allegation No. 7 - NRC Inspectors Rely on Documentation Provided by BPC and do not Talk with Workers; Workers Told not-to Talk to NRC Inspectors

-Interview of Alleger On December 20,,19C2, between 1900 and 2110 hours0.0244 days <br />0.586 hours <br />0.00349 weeks <br />8.02855e-4 months <br />, Dewey E. WILLIAMS, a former pipefitter employed by BPC at PVNGS, was interviewed at the Sandy Shores Motel, 3200 Surfside Blvd., Corpus Christi, Texas, by Investigators

0. C. SHACKLETON and P. V. J0VK0FF. During this interview, WILLIAMS

- furnished the following information regarding this allegation:

WILLIAMS stated that he was critical of HRC inspections made at PVNGS as

.,, the NRC inspectors rely on documentation presented by BPC and do not talk with individual workers. WILLIAMS further averred that workers at PVNGS are told by their supervisors not to talk-with NRC inspectors. WILLIAMS added, however, that he was not aware of any falsified documents.at PVNGS, nor did WILLIAMS allege that any . specific NPC inspector was derelict in his duties.

Interviews of PVNGS " Mechanics" (i.e., Non-Supervisory Craft Workers)

. During the course of the investigation of this allegation, the following non-supervisory craft-workers and Quality Control (QC) inspectors were *

+

intarviewed:

i Results of Interview or Signed Swcen flame Title Employer Statement Location Frederick Sernard HERMAN Welder BPC Exhibit 10 Abrahan (NFN) ROSIN Pipefitter BPC Exhibit 11 Gregory Finis MILLS Welder BPC Exhibit 12

, Charles Allen NELSON QC Inspector BPC Exhibit 13 Samuel John GRIGGS QC Engineer SPC Exhibit 14 Nicholas Jack MA"ROLAS Welder SPC Exhibit 15 J' David Matthew BENNETT Weider BPC Exnibit 16 Louis Oran FREEMAN Pipefitter BPC _ Exhibit 17  ;

,' Kenneth Wayne WARREN Welder BPC Exhibit 4 l Rcbert E. JANTH0 Pipefitter BPC Exhibit 6 All of these individuals, during the ccurse of their interviews, were asked a standard question commonly utilized by 01:RY during interviews.

This' question, in essence, was "has anyone ever directed cr coached you cn how to respond to questions posed by.MRC inspectors or investigators."

All the above individuals replied that they had not been so. directed or i coached, l Case No. 5-82-019 L14

'l

. l l

. 1 Interviews of PVNGS Supervisory Craft Personnel During the course'of investigation of this allegation, the following supervisory workers were also interviewed:

Results of Interview Name Title Employer Location Paris (NMN) R0GERS General BPC Exhibit 18 Foreman Lloyd Wayne HESTAND Former BPC Exhibit 19

• Foreman

.' ~

Robert Heinz LONG Superinten- BPC Exhibit 20 dent Nelsen R. NOFSINGER Former BPC Exhibit 21 General Foreman James R. PAGE Former BPC Exhibit 9" Foreman All of these individuals were asked, during their interviews, if they had ever directed their subordinates not to talk with NRC inspectors or investigators, and all of the individuals stated that they had never done so.

, Interview of Lucian E. VORDERBRUEGGEN, Senior U.S. NRC Resident l Insoector, PVNGS On July 13, 1983, between 0730 and 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />, Lucian E. VORDERBRUEGGEN,

' Senior U.S. NRC Resident Inspector (Construction) at PVNGS, was inter-viewed at the U.S. NRC Region V office by Investigator P. V. J0VK0FF.

During this interview, VORDERBRUEGGEN furnished the following information regarding this allegation:

He stated; that during the approximately three and one half years that he j' had inspe'cted at P7NGS, he has not relied on documentation provided by

., APS, BPC, or any site contractor. VORDERBRUEGGEN advised'that he-4 routinely conducts unannounced field inspections of construction activities during which he physically inspects plant hardware during and after installation in addition to reviewing construction documentation.

~

VORDERBRUEGGEN stated .that during his field inspection, he talks with construction workers, QC inspectors, and construction supervision to obtain their views lof the construction process. VORDERBRUEGGEN advised that during the time he has inspected .PVNGS, he has never heard of any i

field supervision directing their subordinates not to talk with him or other NRC representatives.

i

~

Case No. 5-82-019 15

Interview of James H. ECKHARDT, Former Princioal U.S. NRC Project Construction Inspector, PVNGS On June 23, 1983, from 1510 to 1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br />, James H. ECKHARDT, a principal project construction inspector employed by the U.S. NRC, was interviewed by Investigator P. V. J0VK0FF. The interview was conducted at the U.S. NRC Region V office. During this interview, ECKHARDT furnished the following information regarding this allegation.

- ECKHARDT stated that he was the principal regionally based U.S. NRC inspector for PVNGS for approximately three years. ECKHARDT advised that during this time, he conducted routine unannounced construction 4 inspections at PVNGS.

ECKHARDT stated that while conducting his inspection, he would only on rare occasions give any advance notice to APS or BPC of what items he was going to inspect. ECKHARDT added that normally, an APS or BPC engineer would accompany him on inspections to verify first hand when a problem was discovered.

ECKHARDT averred that during his inspections, he has routinely held i discussions with craft workers, craft supervisors, and engineers regarding their work activities.

Interview of Paul P. NARBUT, Principal U.S. NRC Project Construction Inscector, PVNGS On June 24, 1983, between 1415 and 1505 hours0.0174 days <br />0.418 hours <br />0.00249 weeks <br />5.726525e-4 months <br />, Paul P. NARBUT, principal regionally based U.S. NRC project construction inspector for PVNGS, was interviewed by Investigator P. V. J0VK0FF. The interview was conducted at the U.S. NRC Region V office. During this interview, NARRUT furnished substantially the following informatior :

NARBUT stated that he is currently the principal regionally based U.S.

NRC inspector for PVNGS. NARBUT advised that he had held this position since November 1982 and that during this time, he conducted routine unannounced construction inspections at PVNGS.

.NARBUT stated that while conducting his inspections, he would not give

." APS or BPC advance notice of the areas that he would be inspecting.

., NARBUT advised that normally, an APS or BPC representative would accompany him during inspections to assist in arranging physical work that was required to be done for the' inspection. 'NARBUT added that the APS/BPC representative could also observe first-hand U.S. NRC inspection findings.

NARBUT stated that during his inspections, he had routinely held discussions with craft workers, QC inspectors, field engineers, foremen, and superintendents regarding their work activities. NARBUT advised that he felt it was not possible for him to inspect only those areas that APS/BPC wanted him to.

MARBUT recalled during his interview that during 1980, a trial U.S. NRC program was tested by Lucian VORDERBRUEGGEN that involved interviewing Case No. 5-82-019 16

- . -. - -- . - .. . - ~ .

craft workers at PVNGS. NARBUT stated that VORDERBRUEGGEN might be able l to supply further information regarding this program.

Re-Contact of Lucian E. VORDERBRUEGGEN On November 17, 1983, VORDERBRUEGGEN telephonically contacted Investigator P. V. JOUK0FF. VORDERBRUEGGEN advised that he had researched his files regarding the 1nterviews of craft workers, which he conducted during 1980.

VORDERBRUEGGEN advised that from December 1979 through March 1980, he d

interviewed 35 craft workers and QC inspectors selected at random that m, were employed at PVNGS at that time. V0RDERBRUEGGEN stated that the interviews were conducted as the result of. a Temporary Instruction (TI)

. that was issued by .the U.S. NRC Office of Inspection and Enforcement.

During his. interviews, he asked the interviewees if they had any corcerns-regarding the quality of construction at PVNGS or knew of any instances where construction was not being completed in accordance with specified requirements. YORDERBRUEGGEN advised that as a result of these interviews, he was unable to identify any alleged violations or deficiencies. * ~

' Investigator's Note: VORDERBRUEGGEN supplied Investigator JOUK0FF with a

copy of the document he generated as< a result of the interviews he ,

conducted (see Exhibit 23).

Allegation No. 9 -' Drug / Alcohol Usage at the PVNGS Site Interview of Alleger On December 20, 1982, between 1900 and 2110 hours0.0244 days <br />0.586 hours <br />0.00349 weeks <br />8.02855e-4 months <br />, Dewey E. WILLIAMS, a former pipefitter. emp' iyed by tha Bechtel Power Corporation (BPC) at the Palo Verde. Nuclear Generating Station (PVNGS), was interviewed at the Sandy Shores Motel, 3200 Surfside, Blvd., Corpus Christi, Texas, by Investigators.0. C. SHACXLETON and P. V. JOUKOFF. During the ~ interview, WILLIAMS furnished the following.information regarding this allegation:

, WILLIAMS-statec that when he worked at PVNGS, there were drug and beer sales openly being conducted in the parking lots .at the beginning of the f' day shift. WILLIAMS averred that he'could smell the odor of marijuana in

.. the staircases of the plant and saw beer cans in and around the plant.

WILLIAMS could not identify any "pusners," dealers, or: suppliers of -

^

controlled drugs (i.e. marijuana, cocaine, etc.) or alcoholic beverages at the site. WILLIAMS stated that'this activity should have been obvious to BPC. .

Investigator's Note: The. investigation of centrolled substances on PVNGS-

'is not.witnin -tne jurisdiction of the U.S. NRC. -WILLIAMS was advised during this. interview that.the U.S. NRC was concerned with the practice

.of. such illicit activities on PVNGS.and woeld provide to local law enforcement officials the identities of any alleged drug sources.

WILLIAMS could not-provide any such information. The alleged sales /use of controlled substances at PVNGS was previously reported to 01:RV Case No. 5-82-019 17 o . .

investigators in case 5-82-009, and this information was furnished to Donald B. FASHACHT, Nuclear Ccnstruction Manager for APS, in accordance with current NRC practice. As a result of WILLIAMS' allegation, FASHACHT was again advised of the alleged activities by Investigator P. V. JOUKOFF.

On both occasions, FASHACHT advised that APS' Security Department was working with local law enforcement personnel regarding the alleged drug traffic on the site.

Allegation No.10 - Alleged Plastic Deformation or " Cold Springing" of

- Quality Class 1 Piping During Installation

" Interview of Alleger

,. On December 20, 1982, between 1900 and 2110 hours0.0244 days <br />0.586 hours <br />0.00349 weeks <br />8.02855e-4 months <br />, Dewey E. WILLIAMS, a former pipefitter employed by.the Bechtel Power Corporation (BPC)'at the Palo Verde Nuclear Generating Station (PVNGS), was interviewed at the Sandy Shores Motel, 3200 Surfside Blvd., Corpus Christi, Texas, by Investigators 0. C. SHACKLETON and P. V. JOUKOFF. During the interview, WILLIAMS furnished the following information regarding this allegation:

WILLIAMS stated that while he was employed at PVNGS, he was directed'by "

his foreman, Lloyd HESTAND, to " cold spring" or plastically deform a

! large 30-inch pipe in order to achieve the correct " fit-up" for welding.

WILLIAMS advised that he and his working partner, during the involved period of time, Nicholas MAVROLAS, " cold sprung" the pipe as directed.

WILLIAMS stated that he and MAVROLAS had to " cold spring" the pipe in question because a 90 elbow that had been previously welded onto the pipe was installed such that it did not align with the remainder of the piping system that was to be welded to the elbow. WILLIAMS advised that he and MAVROLAS utilized " porta-powers" and "come-a-lcqgs" to rotate the elbow approximately 3/4" to achieve fit-up of the joint. WILLIAMS stated that during this " cold springing" process, a nylon strap that was attached to the pipe broke, indicating that a considerable amount of force was being applied to the existing pipe and 90' elbow.

WILLIAMS advised that after " cold springing," tack welds were completed,.

. but the next welder assigned to this job refused to complete the weld.

WILLIAMS stated he did no more work on this job and was not aware of the final outcome of this weld.

3 I Investigator's Notes:

, 1. WILLIAMS was shown a plant layout of PVNGS Unit 1, and he pointec out that the heat exchanger involved in this case was the "A" or

" north" essential cooling water heat exchanger.

1

2. The " cold springing" of Quality Class 1 piping in a nuclear power plant is a violation of 10 CFR 50,- Appendix B, Criterion V, whict states, in part:

" Activities affecting quality shall be prescribed by documented i instructions, procedures, or drawings of a type appropriate to the 1

Case No. 5-82-019 l 18

circumstances and shall be accomplished in accordance with their instructions, procedures, or drawings...."

Interview of Nicholas MAVROLAS On May 25, 1983, from 0845 hours0.00978 days <br />0.235 hours <br />0.0014 weeks <br />3.215225e-4 months <br /> to 0940 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.5767e-4 months <br />, Nicholas Jack MAVROLAS, a welder employed by the Bechtel Power Corporation (BPC) at the Palo Verde Nuclear Generating Station (PVNGS), was interviewed by Investigator P. V. J0VK0FF. The interview was conducted at the NRC Resident

. Inspector's office located at PVNGS. During this interview, MAVROLAS furnished the follcwing information regarding this allegation.

.s g MAVROLAS stated that he and WILLIAMS " cold sprung" the piping system in question as WILLIAMS alleged. MAVROLAS advised that this " cold springing" was done at the direction of his foreman, Lloyd HESTAND.

MAVROLAS ad.ded that a nylon strap attached to the piping and being utilized during the " cold springing" did break as WILLIAMS had alleged.

MAVROLAS advised that the general foreman of his crew, Nelson NOFSINGER, may or may not have been aware of the " cold springing." In addition, MAVROLAS was unable to recall whether or not the superintendent of his crew, Robert LONG, had any knowledge of the " cold springing." MAVROLAS-averred that when he was working on the pipe in question, he did not realize that he was completing work in an incorrect manner.

Interview of Lloyd HESTAND On May 25, 1983, between 1055 and 1135 hours0.0131 days <br />0.315 hours <br />0.00188 weeks <br />4.318675e-4 months <br />, Lloyd Wayne HESTAND, a pipefitter and former foreman employed by the Bechtel Power Corporation (BPC) at the Palo Verde Nuclear Generating Station (PVNG5), was interviewed at the Resident Inspector's office at the Palo Verde site by Investigator P. V. J0VK0FF. During the interview, HESTAND furnished the following information regarding this allegation:

HESTAND stated that he was the foreman supervising WILLIAMS and MAVROLAS while they were working on the piping in question. HESTAND recalled that there was a " fit-up" problem with the piping; however, he could not recall specifically how he resolved this problem. HESTAND averred that

. it was normal practice, when a " fit-up" problem existed, to contact a BPC field engineer to determine how to handle any " cold springing." HESTAND

' advised that in this instance, he could not recall if he did or did not

., contact BPC field engineering. HESTAND added that it is possible that he made the decision to " cold spring" the pipe and if this was incorrect, then it was his mistake. HESTAND stated that none of his superiors directed him to " cold spring" this or any other pipe that his crews worked at PVNGS. HESTAND further stated that at the time that this incident occurred, there was " pressure" being placed on him and his crew to complete as much work as possible, but this " pressure" was normal production pressure.

Interview of Robert LONG On May 26, 1983, from 1325 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.041625e-4 months <br /> to 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br />, Robert Heinz LONG, a Superintendent employed by the Bechtel Power Corporation (BPC) at the Case No. 5-82-019 19

A review of these reports was conducted to ascertain the technical

- findings of the inspections and to determine what violations of NRC rules / regulations had occurred.

In report 50-528/83-02, dated March 2, 1983, RV substantiated the allegation that "the amount of cold springing exceeded the allowable amount in the licensee's procedures" and further stated, "The inspector does not consider the substantiated allegation to be of immediate concern." However, RV retained this item as "open pending the results of the licensee's investigation." RV did not issue any Notice of Violation

',, regarding this allegation.

%. In report 50-528/83-17, dated May 24, 1983, RV addressed assessments mace

,. by the licensee (APS) regarding cold springing of piping both in this specific case and generically. This RV review determined that the NRC inspector " concurs that the piping and exchanger are satisfactory in the as-left (relaxed) condition." This RV inspection also identified seven examples in which cold springing may have occurred on safety-related piping systems. The RV review further requested that additional training of craft warkers be performed regarding cold springing. In closing, RV ~

retained this item as open "pending resolution of the analysis of ths NCRs and completion of craft training." RV did not issue any Notice of Violation regarding this allegation.

In Report 50-528/84-36, dated September 24, 1984, RV evaluated analysis completed by the licensee (AF'S) on four of the seven examples of cold springing and determined that the NRC inspector "did not consider that the analysis of four nonconformances provided a great deal of confidence that the condition of piping was satisfactory."

In this same report, RV noted that the licensee (APS) agreed to consider further analysis as other nonconformances had been identified which revealed cold sprung conditions. The cold springing item was retained as an "open" item pending further licensee action. The item pertaining to craft training was closed in this report as training was conducted in June 1983. RV did not issue a Notice of Violation regarding this allegation.

In report 50-528/84-65, dated January 25, 1985, RV closed the open item pertaining to cold springing. This report noted, "The licensee's review

.i identified ten nonconformances. Each was analyzed for the as-found condition and found to be technically acceptable." The report continues to state, "...although it is clear some cold springing of piping did occur during construction, the cases available for analysis show the as-found conditions were technically acceptable." RV did not issue a .

Notice of Viclation regarding this allegation.

Case No. 5-82-019 21

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, Case No. 5-82-019 22

LIST OF EXHIBITS Exhibit No. Description 1 Rev. Dewey E. WILLIAMS letter to NRC dated 8/1/82 2- Rev. Dewey E. WILLIAMS letters to: Ray BROOKS and Local 469 dated 6/28/82; Mr. WARD, undated; and the Legal Department of BPC dated 6/28/82 3 Signed Sworn Statement of Rev. Dewey E. WILLIAMS

. dated 12/20/82 4 Signed Sworn Statement of Kenneth W. WARREN dated 1/20/82

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5 Confidentiality Agreement of Kenneth W. WARREN g dated 1/19/83

,[.' 6 Signed Sworn Statement of Robert E. JANTH0 dated 4/7/83

- 7 Draft Sworn Statement of James R. PAGE, undated

. 8 ' Signed Sworn Statement of James R. FAGE dated 7/15/83 9 Results of Interview of James R. PAGE dated 1/19/83 10 Results of Interview of Frederick B. HERMAN dated 2/2/83 11 'Results of Interview of Abraham (NMI) ROSIN dated 2/2/83 12 -Results of Interview of Gregory F. MILLS dated 2/2/83

> 13 Results of Interview of Charles A. NELSON dated 5/24/83 14 Results of Interview of Samuel J. GRIGGS dated 5/24/83 15 Results of Interview of Nicholas J. MAVROLAS dated 5/25/83 15 Results of Interview of David M. BENNETT dated 5/27/83

17 Results of Intarview of Louis.0 FREEMAN dated 5/27/83 18 Results of Interview of Paris (NMI) R0GERS dated 4/8/83 19 Results of Interview of Lloyd W. HESTAND dated 5/25/83

! 20 Results of Interview of Robert H. LONG dated 5/26/83 21 Results of Interview of Nelson R. NOFSINGER dated 5/26/83 22 Results of Interview of Lucian E. VORDERBRUEGGEN

. dated 7/13/83 23 Results of Interview of James H. ECKHARDT dated 7/23/83 i 24 Results of Interview of Paul P.- NARBUT dated 6/24/83 25 SPENCER (RV) memo to THORNBURG (IE:HQ) dated 5/12/80 - Subj: Interviews with Craftsmen at Ccastruction Sites - TI 2512/4

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4 Case'fo. 5-82-019 23.