ML20040D360
| ML20040D360 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/30/1981 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Crane P PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML17083A976 | List:
|
| References | |
| NUDOCS 8202010217 | |
| Download: ML20040D360 (40) | |
Text
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APPENC!X C 8
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wAtwur cattn. cAusonmA s4sse Docket Nos. 50-275 50-323 DEC 3 01981 Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94106 Attention: Mr. Philip A. Crane, Jr.
Assistant General Counsel dentlemen:
With respect to the NRC's continuing investigation of the Dr. R. L. Cloud matter:
1.
Please direct Dr. Cloud to provide under oath or affinnation the following infonnation, directly to this office, with a copy to the Pacific Gas and Electric Company:
a.
A compilation of all written and known oral comments related to the four draf t reports from R. L. Cloud Associates that were submitted to PG&E on October 21, October 26, November 6, and November 12, 1981.
b.
For each comment, identify the draft report, the page number, the section number and whatLr the comment was made by a PG&E employee or an employee of Dr. Cloud.
If the comment was made by an employee of Dr. Clo5d, identify the employee by name.
For purposes of these responses, please identify the draft dated October 21, 1981 as draf t 1, the draft dated October 26, 1981 as draf t 2, the draf t dated November 6,1981 as draft 3, and the draft dated November 12, 1981 as dra f t 4.
c.
For each comment, indicate whether or not the comment resulted in a revision of the material being commented on.
d.
For each comment for which a change was made, provide an explanation as to why the change was made, e.
For each comment that resulted in a change, identify the log or other document which substantiates the explanation.
Dr. Cloud should be instructed that neither Dr. Cloud nor any of his employees should discuss any of the responses or any draf ts thereof with PG&E employees, or seek any other information from PG&E employees in preparing the above information.
8202010217 820127 DR ADOCK 05000275 PDR
APPENDIX C (Cont.)
Pacific Gas and Electric Company
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DEL 30 Nijl 2.
Please provide under oath or affirmation the following information to this office:
Identify all persons (PG&E, Westinghouse, etc., with specific names) a.
who were provided copies of the four draft reports from R. L. Cloud Associates, and identify the draf t number of each such document.
For purposes of these responses, please identify the draft dated October 21, 1981 as draf t 1, the draf t dited October 26, 1981 as draf t 2, the draft dated November 6,1981 as draf t 3, and the draf t dated November 12,1981 as draf t 4.
b.
Identify all persons and parties, other than employees of Dr. Cloud who made either oral or written comments on such documents, and list each comment, the commentor, the draft number, the page number, and the section of each document.
Identify which of these comments were forwarded to Dr. Cloud.
c.
d.
For each comment transmitted to Dr. Cloud, identify how and through whom (Mr. Rocca or otherwise) the comment was submitted to Dr. Cloud.
The responses to these requests should be submitted by January.15,1981.
If you or Dr. Cloud have any questions concerning this request, please contact my office directly.
Please be advised that the information requested above is in addition to that requested of you in my letter to PG&E dated December 23, 1981.
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R. H. Engelken Regional Administrator cc:
G. A. Maneati s bcc:
E. Case, NRR F. Miraglia, NRR K. Cornell, ED0 J. Lieberman, ELD R. Fortuna, OIA J. Sniezek, RRRI J. Crews, RV B. Faulkenberry, RV
- 0. Shackleton, RV C-ii vd b
APPENDIX D SUMMARIES OF SWORN TESTIMONY AS RELATED TO ISSUES OF CONCERN Appendix D D-i Pages D-i through 30
APPENDIX D SUMMARIES OF SWORN TESTIMONY AS RELATED TO ISSUES OF CONCERN During the conduct of this special investigation sixteen issues of concern were identified. These issues are listed in the Table of Contents, beginning on the following page.
Fourteen of these issues were examined during this phase of the investigation (issues number 1 through 14).
s This appendix ~ summarizes the sworn testimony of each individual as it relates to each of the fourteen issues.
Further details may be obtail;ed from Appendix E of this report, which contains a verbatim transcript of all the sworn statements'taken during this investigation.
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APPENDIX D TABLE OF CONTENTS Issue Page Number 1-2 1.
What was the knowledge or understanding as to how the R. L. Cloud findings should be handled prior to submittal to the NRC?
2.
What has been the practice / custom at PG&E regarding 3-5 the review of the results of a consultant's findings prior to these findings being placed in a final draft or final report form?
3.
What were the instructions that had been provided to 6
PG&E personnel on how to review and comment on the R. L. Cloud findings as' contained within the draft reports?
4.
What were PG&E's purpose and intent of providing 7
comments on the R. L. Cloud findings as contained within the draft reports?
5.
What were the instructions provided to the R. L. Cloud 8-9 staff regarding the draf ting of reports and the handling of comments received from PG&E?
6.
Were employee's of R. L. Cloud 'under any pressure to 10 - 11 accept PG&E's comments that were provided as a result of PG&E's review of the draft reports?
7.
Did Dr. Cloud mislead the NRC in statements he made at 12 - 13 the meeting with NRC on November 3,1981? If he did, was this done knowingly?
8.
Did PG&E representatives mislead NRC in statements they 14 - 16 made at the meeting with the NRC on November 3,1981?
If they did, was this done knowingly?
9.
What explanation was given by Mr. Norton, Mr. Maneatis, 17 and Dr. Cloud (speakers at the November 3,1981 meeting) for the statements they made that the R. L. Cloud report had not been received by PG&E?
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Table of Contents (cont.)
Issue Page Number
- 10. What are the explanations given by people attending the 18 - 20 November 3,1981 meeting, who knew of the existence of draft reports, for not bringing the existence of the draft reports to the NRC's attention after statements made by Mr. Norton, Mr. Maneatis, and Dr. Cloud?
- 11. Was the existence of the R. L. Cloud draft reports 21 - 23 discussed by PG&E representatives at the November 3, 1981 PG&E pre-meetings, at the lunch break en November 3, or after the meeting?
12.
What is the basis for the NRC expectation that the 24 R. L. Cloud work and findings should be independent?
- 13. Are there any policies or procedures within PG&E, 25 - 27 written or otherwise, of not providing information to the NRC unless it is specifically asked for by persons from the NRC?
- 14. What is the relationship of mrtain contract terms, as 28 - 30
' contained in the December 1,1981 contract with R. L. Cloud Asscciates, Inc., on the performance of R. L. Cloud as an independent contractor?
The following two issues were also identified during the course of the investigation, but were not fully addressed during the initial phase. Testimony summaries are not provided for these issues in this Appendix.
15.
Did any PG&E comments, oral or written, on the R. L. Cloud draft reports result in any unjustified changes in findings as contained in the November 12, 1981 draft report submitted to the NRC?
- 16. What were the bases for the substantive changes made in the R. L. Cloud draft reports?
D-iv j
4 ISSUE NUMBER 1 - WHAT WAS THE KNOWLEDGE OR UNDERSTANDING AS TO HOW THE R. L. CLOUD FINDINGS SHOULD BE HANDLED PRIOR TO SUBMITTAL TO THE NRC?
Person Interviewed Location in Transcript Summary of Sworn Testimony B. Norton Page 276, line 4 through Mr. Norton considered the criteria for Page 278, line 7.
- Also, independence to mean that the person Page 280, line 3 through doing the review must not have done Page 283, line 7.
the original work. Mr. Norton stated that PG&E never received any direction from the NRC to handle things differently than they did. Mr. Norton stated that an offer was made at the November 3 meeting to submit the Cloud reports simultaneously to the NRC and PG&E but the NRC never responded.
G. Maneatis Page 391, line 2 through Mr. Maneatis stated that at the 12, and line 17 through November 3 meeting Mr. Norton Page 395, line 10.
- Also, volunteered to follow any method the Page 398, line 16 through NRC wished in submitting Dr. Cloud's Page 399, line 6.
reports.
He said the NRC did not give PG&E any specific directions on how to handle Dr. Cloud's reports.
Mr. Maneatis stated he would welcome clear instruction from the NRC as to how they want PG&E to proceed.
For future reports, Mr. Maneatis stated that the Cloud findings, as of a particular cut-off date would be sent, unadulterated, to the NRC along with separate and distinct PG&E comments.
Mr. Maneatis said, "We will not, in effect, receive his (Cloud's) report comment on his report, send it back to Cloud and then receive his official report."..-
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ISSUE NUMBER 1 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony J. McCracken Page 86, line 15 through Mr. McCracken was not aware of any page 87, line 9.
directions being issued regarding Page 88, line 1 through 5.
how Dr. Cloud's work should be handled as regarding the independ-ency issue other than Dr. Cloud should complete the report in a method he sees fit and to report the facts as he sees them.
E. Kahler Page 38, lines 12 to 20.
Mr. Kahler doesn't believe there Page 378, lines 1 to 19.
was anything formal, from the NRC or internally, on how Dr. Cloud's findings should be handled. Mr.
Kahler stated he is not aware of any effort to revise Dr. Cloud's findings, as their (PG&E) efforts are directed to providing a true and accurate picture of their work to the NRC.
R. Cloud Page 18, line 12 to 18.
Dr. Cloud stated he had not been Also, page 23, line 14 advised by PG&E nor the NRC as to through page 24, how to handle his reports. He line 9.
does not believe the issue of Page 30, line.19 to 25.
independence reached a degree of Page 40, line 18 to 23.
importance until the November 3 meeting. Dr. Cloud stated that any adverse findings, that were reported to and commented on by_
PG&E in draft reports, were not removed without documented justi-fication. He also stated, "We would never change any negative findings arbitrarily at the request of the client."
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ISSUE NUMBER 2 - WHAT HAS BEEN THE PRACTICE / CUSTOM AT PG&E REGARDING THE REVIEW 0F THE RESULTS OF CONSULTANT'S FINDINGS PRIOR TO THESE FINDINGS BEING PLACED IN A FINAL DRAFT OR FINAL REPORT FORM?
t Person Interviewed Location in Transcript Summary of Sworn Testimony V. Ghio Page 192, line 19 through Mr. Ghio considers it the general page 194, line 20 approach within PG&E to review drafts of reports from various consultants who are performing work on Diablo Canyon, or for that matter, any of the design work or engineering work that PG&E is involved in.
Ghio stated he saw nothing unusual in reviewing consultant reports, including Cloud's drafts, since the review was to determine factual content, identify errors, ensure completeness and offer legitimate assis-tanc'e on where to get factual information<
E. Kahler Page 376, line 8 through Mr. Kahler believes normally that when Page 377, line 16.
PG&E lets out a contract they review Page 379, lines 10-20 preliminary reports before they are published as final and it was not out of the ordinary for him to review and comment on Dr. Cloud's work.
The purpose of reviewing Cloud's report was "to get a more conc'.se, better written report that aimed at best at neutrality... the type of thing that could be taken out of ccatext and appears to be a complete statement itself when in fact it isn't."
b D. Brand Page 300, line 11 through Mr. Brand stated it is standard Page 302, line 21.
practice within PG&E, and the industry, Page 323, line 11 through to review a consultant's preliminary Page 325, line 22 draf t report or findings for Page 327, lines 9-17 technical adequacy and to see if there are errors or omissions and to comment on the format.
He said a consultant retained by the California Public Utilities Commission followed this same practice.
He said the Comptroller General of the United States has issued a document, " Standards,-
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ISSUE NUMBER 2 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony for Audit of Governmental Organization, Programs, Activities and Functions",
which states:
"One of the most effective ways to ensure that a report is fair, complete and objective is to obtain advance review and comment by officials of the audited entity."
He said the OIA office of the NRC also follows the practice of issuing draft reports of audits for review and comment.
O. Steinhardt Page 240, line 22 through Mr. Steinhardt affirmed that it is Page 241, line 2 standard practice within PG&E to review and comment on the results of a contractor's work prior to the results being placed in final report fo rm.
E. Wollak Page 224, lines 12-17.
Mr. Wollak affirmed that PG&EJalways Page 231, lines 8-18 reviews or comments on the results of a contractor's work prior to it being placed in a final. report form.
A draft report is received for review and comment and to make corrections if there are inaccuracies.
B. Norton Page 275, line 17 through From observation, Mr. Norton said Page 276, line 3 he knows it is standard practice at PG&E for members of PG&E to review a consultant's reports and rough draf ts prior to the issuance of completed reports.
J. Hoch Page 470, line 18 through Mr. Hoch thinks it is the rule rather Page 471, line 11 than the exception at PG&E to ask for draft reports or preliminary reports with the express intent to make comments and indicate corrections that should be made prior to a report being made final.
It would be unusual if there weren't factual inaccuracies in the first version of a report..-
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ISSUE NUMBER 2 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony
'M. Furbush Page 436, lines 5-12 Mr. Furbush stated it was a standard practice for consultants to provide PG&E with a draft prior to the final report to verify the " factual predicates" upon which conclusions were based.
R. Cloud Page 18, line 19 through Dr. Cloud stated it is routine practice Page 19, line 11 for his company, and he believes for other engineering consulting companies, to provide draft. reports for review and comment to their clients prior to formulating a final draft or final report.
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ISSUE NUMBER 3 - WHAT WERE THE INSTRUCTIONS THAT HAD BEEN PROVIDED TO PG&E PERSONNEL ON HOW TO REVIEW AND COMMENT ON THE R. L. CLOUD FINDINGS AS CONTAINED WITHIN THE DRAFT REPORTS?
Person Interviewed Location in Transcript Summary of Sworn Testimony V. Ghio Page 193, line 22 through Mr. Ghio said he does not recall Page 194, line 20 being provided any.
He thinks they were trying to offer legitimate assistance and provide information that would be helpful in getting factual information accurately and as completely as possible portrayed.
R. Bettinger Page 181, line 24 through Mr. Bettinger said they were told Page 184, line 4 to assure the findings are accurate, but not edit them. These instructions possibly came from Mr. Brand.
D. Brand Page 303, line 18 through Mr. Brand said he issued verbal Page 304, line 19 instructions not to edit or do wordsmithing but to call Dr. Cloud's attention to any additional information he should see.
B. Shackelford Page 358, line 25 through Mr. Shackelford saic he issued no Page 359, line 13 explicit directi ves.
He talked to Mr. Maneatis about how the program should proceed to preserve Dr. Cloud's professional integrity and independence, but as to how information was to be passed, they did not discuss it.
J. Rocca Page 130, line 10 through Mr. Rocca stated that, when given the line 19 draft reports they were asked to simply review the reports and that
...we (PG&E) just were commenting on-them as to what we thought the content of the report was, how accurate it was... "
ISSUE NUMBER 4 - WHAT WERE PG&E'S PURPOSE AND INTENT OF PROVIDING COMMENTS ON THE R. L. CLOUD FINDINGS AS CONTAINED WITHIN THE DRAFT REPORTS l
Person Interviewed Location in Transcript Summary of Sworn Testimony R. Bettinger Page 175, line 17 through To assure accuracy and correctness Page 176, line 23 but not to play down the truth.
V. Ghio Page 200, line 22 through To get accurate information into Page 201, line 21 the reports.
J. Rocca Page 143, line 17 through For accuracy and completeness.
Page 143, line !8 D. Brand Page 303, line 18 through Not for editing or wordsmithing but Page 304, line 19 for accuracy and completeness.
E. Kahler Page 378, line 10 through To get a more concise, better written Page 379, line 20. Also report that aimed at best at neutrality.
Page 380, lines 12-20 Mr. Kahler believes his department has been trying to do their best to get a true and accurate picture of PG&E's work.
O. Steinhardt Page 244, line 25 through To improve the accuracy of the Page 246, line 10 interpretation that Dr. Cloud and his associates gave to the work of ours which they were reviewing.
E. Wollak Page 226, line 16 through To reflect accuracy.
Page 227, line 13 J. McCracken Page 88, lines 13-25 To make the report as complete and as accurate as possible.
S. Motiwalla Page 608 through 610.
Mr. Motiwalla, an employee of Also Page 612 Dr. Cloud, reviewed PG&E's comments through 615 (lines are and concluded that the comments were not numbered in this intended to identify supplemental transcript).
information, which may not have been provided to Dr. Cloud's office previously and to reduce the negative connotations of certain words and phrases used in the Cloud reports (editorializing).. ~ > -.... _ _
i ISSUE NUMBER 5 - WHAT WERE THE INSTRUCTIONS PROVIDED TO THE R. L. CLOUD STAFF REGARDING THE DRAFTING OF REPORTS AND THE HANDLING OF COMMENTS RECEIVED FROM PG&E?
Person Interviewed Location in Transcript Summary of Sworn Testimony E. Denison Page 523, line 4 through Regarding drafting of reports:
line 19. Also Page 526 line 12 through 22.
Mr. Denison did not specifically state what instructions were provided regarding the drafting of reports, other than to say that they followed the-same procedures throughout the October 21 to November 12 time frame.
Regarding handling of comments:
Mr. Denison stated that instructions were to address the comments.
" Address the comments" entailed several things.
If the comment was unreasonable then it was left as is.
If it was reasonable and it was correct, the changes were made in the report.
If the comment alluded to additional information, they sought to get that additional information.
P. Anderson Page 107, line 20 through Regarding drafting of reports:
Page 111, line 14 Mr. Anderson stated "we~ received our instructions from Dr. Cloud. Our basic instructions broke down various responsibilities to examine the chain of design for various aspects of the plant, breaking it down into different types of buildings and et cetera.' We formed a little internal task team where engineer or groups of engineers were assigned the responsibility of developing the flow of information and examining the existing qualification for a number of these areas." ~
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ISSUE NUMBER 5 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony Regarding handling of comments:
In the development of the October 21 draft,"we tried to stay away from any personal conclusions or conclusions as told to us by PG&E engineers."
H. Loey Page 584, line 24 through Mr. Loey stated he received no
- 25. Also Page 5, line 1 specific instructions for developing through line 8, and the report and handling of comments.
Page 586, line 11 However, Mr. Loey stated, in regard through 22.
to preparation of the report that since the first day of the project they proceeded on a day to day basis, revising the procedures and actual objectives.
P. Chen Page 596, line 8 through Mr. Chen recalls no rigid guidelines line 16, being provided regarding the drafting of reports or handling of comments received from PG&E.
S. Motiwalla Page 607, 611, and 614-Regarding draf ting of reports:
(lines are not numbered in this transcript)
Mr. Motiwalla did not provide any specific statements regarding instructions in this area, except to say they were under the pressare of a time constraint to issue the report.
Regarding handling of comments:
Mr. Motiwalla said Dr. Cloud did not give any specific instructions regarding the handling of comments.
He said they were to address PG&E's comments in the best possible manner.
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ISSUE NUMBER 6 - WERE EMPLOYEES OF R..L.
CLOUD UNDER ANY PRESSURE TO ACCEPT PG&E COMMENTS, THAT WERE PROVIDED AS A RESULT OF PG&E'S REVIEWS OF THE DRAFT REPORTS?
Person Interviewed Location in Transcript Summary of Sworn Testimony E. Denison Page 523, line 13 through Mr. Denison said that instructions line 19, also Page 528, were to address the comments.
line 11 through 15;
" Address the comments" entailed Page 539, lines 2 through several things.
If the comment was 4; Page 541, lines 16 unreasonable, then it was left as is.
through 25; Page 542 If it was reasonable and it was lines 1 through 3; and correct, the changes were made in Page 543, lines 1 the report.
If the comment. alluded through 4.
to additional information, we sought-to get that additional infonnation.
Each of the comments from PG&E was an encouragement of a sort. When someone crosses out 3/4 of a page and wrote " incorrect" that was an encouragement.
PG&E and Denison discussed each of the findings in detail and there was no disagreement about the nine findings in the report.
Denison states that in instances where they could not obtain information or where people were not as cooperative as they might be, the item would be left open, then PG&E reacted quickly by providing additional information.
Civud employees were not required to make any changes without substantiating documentation.
P. Anderson Page 111, line 19 through Mr. Anderson stated he was not line 23, also Page 112, encouraged at any time or directed by line 1-5.
anyone to change any of his findings that showed something wrong.
If there were holes in the information, PG&E engineers made comments and did request that Cloud find additional information and examine it.
ISSUE NUMBER 6 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony P. Chen Page 597, line 17 through No.
Some of the comments he took, line 22.
Also Page 599, but some of their comments he simply line 4 through line 19, neglected or ignored because he and Page 603, line 3-4.
did not feel those comments were good in the sense they had enough factual information to substantiate the statements in those paragraphs he wrote.
He was never told or hinted to do something which would be in favor of PG&E.
H. Loey Page 588, line 18 through Not to change the findings, no.
line 25. Also Page 599, He felt he had the appropriate line 1 and 2; Page 590, freedom and was able to express his line 12 through line 25; findings honestly.
Page 591, line 1 through line 12.
S. Motiwalla Page 607, line 16-20.
Mr. Motiwalla stated there was no Also, Page 608, line outside pressure or undue influence 15-19, and Page 613, on the findings other than a time line 31-35 and Page 614; constraint.
He further stated they line 35-39.
used the draft report and the PG&E comments as a basis to make another more correct and more relevent report.
Mr. Motiwalla stated Cloud employees had the impression that PG&E wanted Cloud employees to make PG&E sound a little better, but felt that they were " cosmetic changes" on words, not of substance in the reports.
ISSUE NUMBER 7 - DID DR. CLOUD MISLEAD THE NRC IN STATEMENTS HE MADE AT THE MEETING WITH THE NRC ON NOVEMBER 3, 1981? IF HE DID, WAS THIS DONE KNOWINGLY?
Persons Interviewed Location in Transcript Summary of Sworn Testimony, R. Cloud Page 32, line 16 through Dr. Cloud stated he considered the line 25.
draft reports as working papers he Page 33, line 1 through had sent to PG&E's engineering page 34, line 25.
staff to make sure whether or not Page 36, line 1 through he had any of his facts wrong. He page 38, line 24.
said that he did not even consider these documents in the nature of a draft.
Dr. Cloud said he did not recall Mr. Norton saying at the November 8, 1981 meeting that no results had been submitted to PG&E.
He said he did not remember it in those terms.
D. Brand Page 135, line 22 through Mr. Brand viewed Dr. Cloud's earlier page 317, line 22.
work as a very preliminary effort to "get the ball rolling," and the discussion on an interim report-referred to something to be developed subsequent to the November 3, 1981 meeting.
l M. Furbush Page 429, line 23 through Mr. Furbush stated that Dr. Cloud l
page 434, line 7.
didn't provide erroneous informa-l Page 435, line 20 through tion to the NRC since he asked page 438, line 3.
Dr. Cloud what he was thinking about on November 3 and Dr. Cloud l
said that was not "my" report - his report was not completed, he still had people in the field.
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ISSUE NUMBER 7 (Cont.)
Person' Interviewed Location in Transcript Summary of Sworn Testimony J. Rocca Page 150, line 2 through In reference to Dr. Cloud's statement line 23.
Mr. Rocca stated, "... I didn' t see any inaccuracy, really...Dr. Cloud, in my mind, was ' talking about the final draft that we were going to submit
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and we did not have that in house."
M. Tresler Page 489, line 23 through In reference to whether Dr. Cloud's Page 494, line 6.
(and Messrs. Norton's and Maneatis')
statements were erruneous or misleading Mr. Tresler stated, "No.
I did not (think they were erroneous or misleading).
...I considered the work that Dr. Cloud was doing at that point in time to be preliminary..."
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ISSUE NUMBER 8 - DID PG&E REPRESENTATIVES MISLEAD THE NRC IN STATEMENTS THEY MADE AT THE MEETING WITH THE NRC ON NOVEMBER 3, 1981?
IF THEY DID, WAS THIS DON KNOWINGLY?
Person Interviewed Location in Transcript Summary of Sworn Testimony B. Norton Page 267, lines 23 through Mr. Norton stated:
"Well, obviously 25, Page 270, lines 8 when you take the statement I made on through 11.
Page 280, pages 216 and 217, it's factually line 3 through Page 287, incorrect.
Indeed, PG&E had received line 1.
a report, so, yes." Mr. Norton also stated:
"I honestly did not have any meaning to that.
If I had known the report of October 21st had been received by PG&E, I would not have said what I said because when I used the term report, I was encompassing any report whether it be preliminary, interim, final, whatever and it was --
because I'd asked the questions where is the report on the previous day or two and was told it would be prepared in a week or two, I guess I assumed whoever was answering my questions was using the same definition of report I was.
In all probability, they _weren't."
Throughout his sworn testimony, Mr. Norton stated there was no attempt on his or anyone elses part to mislead the NRC. Also, Mr. Norton did not become aware of the draft reports until December 14, 1981.
M. Furbush Page 429, line 23 through Mr. Furbush does not believe Page 434, line 7.
Dr. Cloud, Mr. Norton, or Mr. Maneatis intentionally furnished the NRC erroneous or misleading information at the November 3 meeting.
He believes Dr. Cloud was thinking of the final draft report and that neither Mr. Norton or Mr. Maneatis had any knowledge of the existence of draft reports. ;
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ISSUE NUMBER 8 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony Page 435, line 17 through He stated, regarding Mr. Norton, Page 439, line 7.
"I would assume had Norton known about it (the draft reports) he would have said it immediately.
So would Mr. Maneatis -- would have said immediately that we had seen some because there's nothing, no reason not-to say it. There is absolutely in the scheme of things no justification for not making a statement had you known it to be the case."
B. Shackelford Page 361, lines 4 to 15.
Mr. Maneatis, Mr. Norton, and Also, Page 358, lines Mr. Shackelford were unaware at the 7 to 24.
November 3 meeting that Dr. Cloud had submitted draft reports of his findings to PG&E. Mr. Shackelford was not made aware of the draft reports until Mr. Crews of the NRC called on about December 11, 1981.
Mr. Shackelford does not believe Mr. Norton or Mr. Maneatis made misleadins statements in light of the knowledge they had at the time.
Page 363, lines 5 to 13.
Specifically, Mr. Shackelford stated, "From what I know, M.. Maneatis and Mr. Norton did not know of the draft reports and therefore they were talking in terms that there had beer no final report submitted."
Page 366, line 16 through He also stated, "I would suggest also Page 367, line 1.
that even had I been aware that that material had been here, I'm not sure in the context of that meeting, I would have construed the answers as being incorrect. What we had was not a repurt. What we had was work papers of the engineer we were checking for factual accuracy." -
ISSUE NUMBER 8 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony G. Maneatis Page 397, line 17 through Mr. Maneatis stated that no one, Page 398, line 8.
until Jess Crews called on December 10, 1981, had ever indicated to him that he, Mr. Norton, or Dr. Cloud had made any misleading statements at the November 3 meeting.
Page 386, line 12 through Mr. Maneatis stated, "... I believe Page 389, line 6, and the first time I was aware that these drafts were in existence was the errata sheet, Page 383.
when Jess Crews from the NRC called-me...."
He further stated that his statements at the November 3, 1981 meeting were in reference to Dr. Cloud's oral reports, "... I was thinking that they were talking about his oral report. When I said that they got it just almost the same time that I had, I was implying that I had gotten it within the past few days."
J. Rocca Page 146, line 11 through In reference tu Mr. Norton's statement Page 147, line 23.
Mr. Rocca stated "I guess I realized that there was an inaccuracy in his statement...I realized there was an inaccuracy in his statement and I made the assumption in my mind that he was talking about the final document..."
M. Tresler Page 489, line 23 through In reference to whether Messrs.
Page 494, line 6.
Norton's and Maneatis' (and Dr. Cloud's) statements were erroneous or misleading, Mr. Tresler stated, "No.
I did not (think they were erroneous or misleading)....I considered the work that Dr. Cloud was doing at that point in time to be preliminary..." -
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ISSUE NUMBER 9 - WHAT EXPLANATION WAS GIVEN BY MR. NORTON, MR. MANEATIS, AND DR. CLOUD (SPEAKERS AT THE NOVEMBER 3, 1981 MEETING)
FOR THE STATEMENTS THEY MADE THAT THE R. L. CLOUD REPORT HAD NOT BEEN RECEIVED BY PG&E?
Person Interviewed Location in Transcript Summary of Sworn Statement G. Maneatis Page 387, line 10 through Mr. Maneatis considered his stateinent, Page 389, line 25. Also, as recorded on page 215, lines 20-22, Page 386, line 2 through of the transcript of the November 3 Page 387, line 9 meeting, to apply to the oral report Dr. Cloud gave to the NRC on November 3.
Mr. Maneatis was not aware until about December 10, 1981 that draft reports of Dr. Cloud's work, other than the November 12, 1981 draft, existed.
B. Norton Page 256, line 4 through Mr. Norton did not know of the Page 258, line 19. Also, existence of any draft reports by Page 266, line 14 through Dr. Cloud prior to November 3.
He Page 287, line 1.
did not learn of the existence of these draft reports until December 14, 1981. Mr. Norton considered the statement he made, as recorded on page 216, line 5-7, of the transcript of the November 3 meeting, to be the case at the time.
R. Cloud Page 37, line 7 through Dr. Cloud considered his statement, Page 38, line 24 as recorded on page 216, lines 2-4, of the transcript of the November 3 meeting, to be directed toward the final draft report and not toward the previous draf ts which he considered to be working papers..
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ISSUE NUMBER 10 (Cont.)
Person Intery!ewed Location in Transcript Summary of Sworn Testimony this subject to Mr. Brand at the meeting lunch break and may have discussed the subject with Mr.
Tresler while on the airplane, returning from the meeting. Mr.
Rocca stated that, if the subject had come up, it was addressed only briefly.
D. Brand Page 304, line 20,through Mr. Brand did not think the draft page 308, line 3.
report of October 21,1981, was Page 337, line 23 through significant with regard to the page 343, line 12.
statements made by Mr. Norton, Mr. Maneatis, and Dr. Cloud. Since Mr. Brand had not read the October 21 draft report, he assumed they were talking about a totally different report. Mr. Brand did not recall discussing this issue with Mr. Rocca or anyone else on November 3, 1981, or thereafter.
J. Hoch.
Page 459, line 18 through Mr. Hoch had not read the draft page 466, line 21.
reports.
While Mr. Hoch considereci the statements by Mr. Norton, Mr. Maneatis, and Dr. Cloud concern-ing draft reports to be possibly misleading or erroneous, he did not bring this concern to their attention.
Mr. Hoch stated he either was unsure about the context in which the term
" report" was used, or considered himself a peripheral participant at the meeting and expected someone else to correct the statements. After the meeting broke up, he forgot about the statements they made.
M. Tresler Page 489, Line 23 through Mr. Tresler did not consider the page 494, line 10.
statements made by Mr. Norton, Mr. Maneatis, or Dr. Cloud to be erroneous or misleading, because the work at that point was considered preliminary. Mr. Tresler stated he discussed this issue with Mr.
Rocca following the meeting, but still; did not consider the statements to be misleading.
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ISSUE NUMBER 10 - WHAT ARE THE EXPLANATIONS GIVEN BE PEOPLE ATTENDING THE NOVEMBER 3,1981 MEETING, WHO KNEW 0F THE EXISTENCE OF DRAFT REPORTS, FOR NOT BRINGING THE EXISTENCE OF DRAFT REPORTS TO THE NRC'S ATTENTION AFTER STATEMENTS MADE BY MR. NORTON, MR. MANEATIS, AND DR. CLOUD?
Person Interviewed Location in Transcript Sunmary of Sworn Testimony R. Bettinger Page 177, line 14 through Mr. Bettinger did not recognize the page 178, line 1.
statements made by Mr. Norton and Page 180, lines 1 to 18.
Dr. Cloud to be incorrect or misleading.
Mr. Bettinger stated that he was not well enough informed to know exactly which reports they might be talking about.
V. Ghio Page 206, line 14 through Mr. Ghio did not hear the statements page 208, line 24.
made by Mr. Norton, and did not recognize Dr. Cloud's statements to be incorrect or misleading.
J. Rocca Page 146, line 11 through Mr. Rocca recognized Mr. Norton's page 150, line 23.
statement, that PG&E had not received Also, page 160, line 9 a report of Dr. Cloud's work, to be through page 165, erroneous.
However, a second statement line 16.
made by Mr. Norton, that the NRC could have Dr. Cloud's reports prior to receipt by PG&E, upset him and this caused him to assign a much lower priority to Mr. Norton's first state-ment. As a result, he stated he never brought his initial concern of Mr. Norton's first statement to higher management's attention.
Mr. Rocca did not consider Dr. Cloud's statement to be inaccurate.
He stated that he believed Dr. Cloud was talking about the final report.
During his second interview, Mr. Rocca stated that he may.have mantioned this 1
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ISSUE NUMBER 10 (Cont.)
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j Person Interviewed Location in Transcript Summary of Sworn Testimony i
R. Cloud Page 32, line 16 through Dr. Cloud considered the statements page 36, line 9.
made by Mr. Norton, Mr. Maneatis, Also, page 37, line 7 and himself to be directed-toward through page 38, the final draft report and thus line 24.
did not believe them to be i
erroneous or misleading.
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ISSUE NUMBER 11 - WAS THE EXISTENCE OF THE R. L. CLOUD DRAFT REPORTS DISCUSSED BY PG&E REPRESENTAflVES AT THE NOVEMBER 3, 1981 PG&E PRE-MEETINGS, AT THE LUNCH BREAK ON NOVEMBER 3, OR AFTER THE MEETING?
Person Interviewed Location in Transcript Summary of Sworn Testimony J. Hoch Page 465, line 2 through Mr. Hoch stated that Dr. Cloud went page 468, line 21.
through his presentation at pre-meetings.
However, Mr. Hoch didn't recall if the subject of drafts of interim reports was mentioned.
M. Tresler Page 492, line 3 through Mr. Rocca had a conversation with page 494, line 20.
Mr. Tresler while on the airplane Also, page 503, line 2 returning home from the November 3 through page 505, meeting regarding the draft reports
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and the statements made by Mr. Norton.
During this conversation, Mr. Rocca told Mr. Tresler that Mr. Rocca had knowledge of a draft or preliminary report from R. L. Cloud and Associates that was received by PG&E prior to the November 3,1981 meeting. Mr. Rocca stated to Mr. Tresler that this fact was contrary to statements made by Mr. Norton at the meeting. Mr. Tresler indicated to Mr. Rocca that he did not feel Mr. Norton's statement was misleading to the NRC. Mr. Tresler was not aware of any discussions of the draft reports during lunch or at the PG&E pre-meetings although Dr. Cloud's presentation at the meeting was discussed in pre-meetings.
B. Norton Page 270, line 12 through Mr. Norton, at one of the page 273, line 4.
pre-meetings, asked where the Page 275, line 17 through interim report was.
He-page 276, line 3.
specifically asked "is the report Page 280, line 1 through done or do we have the report page 287, line 1.
yet meaning the report that was going to the NRC." Someone answered that it would be ready within the next week or two. Mr. Norton.
ISSUE NUMBER 11 (Cont.)
Person Interviewed Location in Transcript Summary of Sworn Testimony also stated that he was aware of the general practice of PG&E reviewing consultant reports and rough drafts prior to the issuance of completed reports, although in this case no one specifically told him of any draft or interim reports.
Mr. Furbush Page 434, line 22 through No,not to his knowledge, page 435, line 12.
Mr. Locke Page 453, line 12 through No, not to his knowledge.
page 454, line 18.
B. Lew Page 480, line 11 through No, none other than a question that page 482, line 3.
was asked by someone as to when would Dr. Cloud's results be finalized and when would the results be available in a formal report.
J. Herrera Page 515, line 2 to 25.
No not to his knowledge.
J. Rocca Page 147, line 1 through Mr. Rocca discussed with Mr. Tresler, page 150, line 1.
on the airplane flight home from the Page 153, line 17 through November 3 meeting, Mr. Norton's page 154, line 14.
statement offering to provide NRC Page 159, line 8 through copies of Dr. Cloud's reports before page 166, line 9.
receipt by PG&E.
He may have discussed Mr. Norton's statement about PG&E not having Dr. Cloud's report, but he can't recall it explicity.
During his second interview (January 4, 1982),
Mr. Rocca stated that he believed he mentioned his concern about Mr. Norton's statement regarding draft reports to Mr. Brand.
D. Brand Page 338, line 5 through Mr. Brand recalls discussing with page 343, line 12.
Mr. Rocca, at the lunch break, Mr. Rocca's concern about Dr. Cloud's statement that the verification program plan had been Dr. Cloud's idea and his idea alone. Also, he -..
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ISSUENUMBER11(Cont.)
Person Interviewed Location -in Transcript.
Summary of Sworn Testimony was discussing with Mr. Rocca, Mr. Rocca's concern about Mr. Norton's statement that the NRC can have 4
Dr. Cloud's report prior. to receipt by PG&E. However, he does not recall having any discussions with Mr. Rocca regarding Mr. Norton's statement that 1
j PG&E did not have Dr. Cloud's report as of November 3, 1981.
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ISSUE NUMBER 13 - ARE THERE ANY POLICIES OR PROCEDURES WITHIN PG&E, WRITTEN OR OTHERWISE, OF NOT PROVIDING INFORMATION TO THE NRC UNLESS IT IS SPECIFICALLY ASKED FOR BY PERSONS FROM THE NRC?
Person Interviewed Location in Transcript Summary of Sworn, Testimony G. Maneatis Page 390, lines 7 through No. He was not aware of any such 11.
policy and he did not issue any Also, page 397, lines 1 such instructions.
Mr. Maneatis through 16.
stated, "The only thing that we ever said in that regard was to be factual, to be accurate...not i
to be speculative, or inaccurate."
B. Shackelford Page 363, line 14 through No. Mr. Shackelford has not told page 364, line 1.
his employees to restrict any Also, page 365, information they pass onto the lines 20-25.
NRC. Mr. Shackelford stated, "We ask our people to be factual.
They ought to be sure of what they're talking about."
J. Rocca Page 150, line 24 through Mr. Rocca stated that there were page 153, line 12.
no policies or procedures on this issue to his knowledge.
"We are given the normal instructions that say answer the questions that you are asked and, if there is some-thing that goes beyond the question and you feel that it really adds to the answer, then that you can contribute also."
V. Ghio Page 208, line 25 through Mr. Ghio stated he was not aware page 209, line 17.
of a policy written down for that Also, page 214, line 14 or against that.
through page 215, line 6.
D. Brand Page 308, lines 4 to 22.
No. Mr. Brand stated, "I don't Also page 344, line 15 think we're withholding anything through page 345, line 10 or that there is any intent to and page 346, line 5 withhold anything." On January 4, through page 347, line 1.
1982, certain phases of the.
ISSUE NUMBER 13 (Cont.)
Persons Interviewed Location in Transcript Summary of Sworn Testimony PG&E contract with Dr. Cloud were discussed in regard to, " Consultant shall disclose no information to third parties...without written permission from PG&E." Mr. Brand stated this was a boiler plate used to protect the company from inadvertent disclosures and was not intended to limit the free flow of findings.
In regard to "Significant conditions requiring corrective action shall be reported to PG&E for concurrence," Mr. Brand stated the paragraph is intended to apply to (Dr. Cloud's) quality assurance procedures and does not deal with Dr. Cloud's findings.
J. McCracken Page 94, line 2 through On December 16, 1981, Mr. McCracken page 96, line 15.
stated he thought PG&E's policy is Also, page 102, line 21 that written material within PG&E through page 103, is considered internal material line 9.
and sould not be divulged to any outside source unless it is either requested or there is a question uf concealing that information as being an illegal matter. He stated he could not find a document that states this. When asked if he knew specifically of any conscious plan by management to limit or otherwise constrain their responses to NRC questions, Mr. McCracken stated: "No."
On December 17, 1981, Mr. McCracken pro-vided the company policy on this mattet which is taken from the employee's manual, Mr. McCracken quoted:
"It is the policy of this Company that employees shall at all times practice fundamental honesty.
It is expected that employees shall l
not deceive, defraud or mislead the Company, other employees, or l
those the Company has business or other relationships."
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ISSUE NUMBER 12 - WHAT IS THE BASIS FOR THE NRC EXPECTATION THAT THE.
R. L. CLOUD WORK AND FINDINGS SHOULD BE INDEPENDENT?
Documents Referenced Summary of Statements in Document Transcript of the meeting held PG&E representatives stated that between PG&E and NRC representatives Dr. Cloud had been retained by PG&E at Bethesda, Maryland, on November 3, to.do an independent and indepth 1981.
Pages 215, ~1ines 1-4 and reverification program, and that he was lines 6-10, and pages 216 through 218.
an independent consultant.
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ISSUE NUMBER 13 (Cont.)
Persons-Interviewed Location in Transcript Sunmary of Sworn Testimony E. Wollak Page 230, lines 16 to 21.
Mr. Wollak stated he never heard of Also, page 232, line 7 such a policy. His instructions through page 233, are always to tell the truth as to line 17.
what the _ actual situation is, however, he said they have been told by their Legal Department to answer the questions asked but not to elaborate unnecessarily on the answers.
O. Steinhardt Page 247, line 19 through No. Mr. Steinhardt did not page 248, line 4.
elaborate.
Also, page 249, lines 21 to 25.
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ISSUE NUMBER 14 - WHAT IS THE RELATIONSHIP 0F CERTAIN CONTRACT TERMS
- AS CONTAINED IN THE DECEMBER 1, 1981 CONTRACT WITH R. L. CLOUD ASSOCIATES, INC. ON THE PERFORMANCE OF R. L. CLOUD AS AN INDEPENDENT CONTRACTOR?
Person Interviewed Location in Transcript Summary of Sworn Testimony R. Cloud Page 6, line 6 through Dr. Cloud gave testimony stating that Page 7, line 21. Also, he is an independent contractor and Page 63, line 5 through not an employee of PG&E.
In reference Page 67, line 2.
to the specific contract terms l
Dr. Cloud stated:
1.1 related to reimbursement for services performed prior to issuance of.the contract (not related to independence);
Subsection 1.3, Dr. Cloud received verbal authorization from PG&E to essentially waive this clause to permit him to work with the NRC.
Dr. Cloud stated "these clauses are included to permit the sponsor...to approve any papers that subsequently result from the work." In this context Dr. Cloud was referring to professional papers not the specific report on his work to his client; Subsection 1.9 relates to independence, "It means to me,; hat it says, that I am an independent contractor and that I am not an employee of PG&E, which is a true statement."; Subsection 1.12 (Appendix Subsection 3.3) relates to a physical change to the plant, "...if_I believe that some physical change within the plant is required... "PG&E must concur with this recommendation... to a certain
- NOTES (1) S_ubsection 1.1 Services performed prior to execution of contract.
(2) Subsection 1.3 Consultant shall disclose no information to third parties...
without written permission from PG&E.
(3) Subsection 1.9 Consultant is an independent contractor and not an employee of PG&E...
(4) Subsection 1.12, Appendix Subsection 3.3 Significant conditions requiring corrective action --- reported to PG&E for concurrence...
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ISSUE NUMBER 14 Person Interviewed Location in Transcript; Summary of Sworn Testimony degree this statement is unnecessary...
because PG&E holds the licensee...and they would have to agree with and support any changes made at the plant in any event."
G. Maneatis Page 408, line 4 through Mr. Maneatis testified that the terms Page 412, line 17.
of PG&E's contract with Robert L. Cloud Associates, Inc., that he was questioned about by the NRC investigators, were standard conditions used. in contracts between PG&E and their consultants; that the terms in no way preclude the disclosure of information to the flRC.
In reference to the specific terms Mr. Maneatis stated:
Subsection 1.1 is written "to cover any work done prior to the formal execution of the contract..."; Subsection 1.3 "merely precludes our contractor's...
from disclosing information...that might have commercial value, that they may want to use as testimonials without our consent, that they may want to write technical papers on without our consent.
It in no way would preclude the disclosure of information to the Nuclear Regulatory Commission...";
Subsection 1.9 relates to "... workman's compensation or things like that...so he (the contractor) is defined as an independent contractor in that very narrow legal sense.
It has no other significance."; Subsection 1.12 (Appendix Subsection 3.3) pertains to the consultant's quality assurance
' program, if "...there were any flaws...we would expect to have the option to tell them that this corrective action was either adequate or inadequate..." -
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ISSUE NUMBER 14 Person Interviewed Location in Transcript Summary of Sworn Testimony D. Brand Page 343, lines 14 Mr. Brand testified that the terms through 25.
Also of PG&E's contract with Robert L.
Page 343, line 1 through Cloud Associates, Inc., that he was Page 348, line 6.
questioned about by the NRC investi-gators, were standard conditions
("boilerplate") used in contracts between PG&E and their consultants; that the terms do not inhibit or restrict the free flow of Dr. Cloud's findings to the NRC.
In reference to the specific contract terms Mr. Brand stated: Subsection 1.1 means "...that work done before formal consummation of the contract...would be covered by the contract provisions."!
Subsection 1.3 is ". simply a boilerplate phrase that we use to pro-tect the company from inovert disclosures."; Subsection 1.9 is included to say Dr. Cloud has no employee relationship with PG&E regarding
...such things as workman's comp...";
Subsection 1.12 (Appendix Subsection 3.3) addresses "... quality assurance procedures and that, as such, it means that if there is any change in conditions whereby the procedures need to be modified that they are done so with PG&E's concurrence."
APPENDIX E TRANSCRIPTS 01 SWORN TESTIMONIES i
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i Appendix E E-i Pages E-i through 615
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j Sworn Testimonies I
This special investigation involved the obtaining of sworn testimony from the following identified persons. The complete transcript of each person's sworn testimony is contained in the following pages.
The transcripts are in chronological order for the period of December 16, 1981 through January 6,1982.
Interviewees Pacific Gas and Electric Company i
.Barton H. Shackelford, President and General Operating Officer
.Malcolm H. Furbush, Senior Vice President and General Counsel
. George A. Maneatis, Senior Vice President, Facilities Development f
. Robert Ohlbach, Vice President and General Attorney
. Donald A. Brand, Vice President, Engineering
. Philip A. Crane, Jr., Assistant General Counsel
. James V. Rocca, Chief Mechanical and Nuclear Engineer
. Richard V. Bettinger, Chief Civil Engineer j-Appendix E E-ii 4
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. Jess R. Herrera, Chief Electrical Engineer
. Warren A. Raymond, Manager of Quality Assurance
. John B. Hoch, Manager of Nuclear Projects
. Richard F. Locke, Senior Counsel
. Michael R. Tresler, Supervising Piping Coordinator for Diablo Canyon
.Erwin P. Hollak, Supervising Civil Engineer
.Barclay S. Lew, Supervising Licensing Engineer
.0tto W. Steinhardt, Senior Civil Engineer
. Vincent J. Ghio, Senior Civil Engineer
. James J. McCracken, Senior Mechanical Engineer
.Edwin R. Kahler, Senior Quality Engineer R. L. Cloud Associates, Inc.
. Robert L. Cloud, President
. Paul H. Anderson,. Engineer
. Edward T. Denison, Engineer t
.Hanson K. Loey, Engineer
. Pao-Chung Chen, Engineer
.Shafi Motiwalla, Engineer Appendix E E-iii
Law Fim of florton, Burke, Berry, and French
.A. Bruce florton, Attorney Outside Counsel in the Diablo Canyon Licensing Proceedings I
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Appendix E E-iv L
APPENDIX E Table of Contents Dates of Persons Interviewed Testimony Page Numbers ROBERT L. CLOUD 12/16/81 1-48 12/17/81 49 57 01/05/82 58 - 70 JAMES J. MCCRACKEN 12/16/81 71 - 98 12/17/81 99 - 103 PAUL H. ANDERSON 12/16/81 42 - 48*
12/31/81 104 - 114 JAMES V. ROCCA 12/16/81 115 - 155 01/04/82 156 - 166 RICHARD V. BETTINGER 12/17/81 167 - 186 VINCENT J. GHIO 12/17/81 187 - 216 ERWIN P. WOLLAX 12/17/81 217 - 234 OTTO W. STEINHARDT 12/17/81 235 - 250 R. 0HLBACH and 12/18/81 251 - 261 A. BRUCE NORTON 12/28/81 262 - 290 DONALD A. BRAND 12/18/81 291 - 318 12/21/81 319 - 334 01/04/82 335 - 351 BARTON W. SHACKELFORD 12/18/81 352 - 367 EDWIN R. KAHLER
'12/18/81 368 - 381 GEORGE A. MANEATIS 12/21/81 382 - 399 12/28/81 400 - 404 01/04/82 405 - 413
- Please refer to pages 42-48 of the testimony given hy Robert L. Cloud.
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Appendix E-(Cont.)
Table of Contents Dates of Persons Interviewed Testimony Page Numbers PHILIP A. CRANE JR.
12/21/81 414 - 419 12/28/81 420 - 423 MALCOLK H. FURBUSH 12/28/81 424 - 439 WARREN A. RAYM0ND 12/28/81 440 - 447 RICHARD F. LOCKE 12/28/81 448 - 455 JOHN B. H0CH 12/28/81 456 - 471 BARCLAY S. LEW
_12/28/81 472 - 483 MICHAEL R. TRESLER 12/30/81 (a.m.)
484 - 499 12/30/81 (p.m.)
500 - 506 JESS R. HERRERA 12/30/81 507 - 518 EDWARD T. DENISON 12/31/81 519 - 579 HANSON K. L0EY 12/31/81 580 - 591 RA'-C'lVNG CHEN 12/31/81 592 - 603 SHAFI MOTIWALLA 01/06/82 604 - 615 Appendix _E,
E-vi
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