ML20040D374

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Transcript of Rl Cloud Associates Testimony by Ph Anderson on 811231 in San Francisco,Ca.Pp 104-114
ML20040D374
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 12/31/1981
From: Patricia Anderson
ROBERT L. CLOUD ASSOCIATES, INC.
To:
Shared Package
ML17083A976 List:
References
NUDOCS 8202010232
Download: ML20040D374 (10)


Text

1 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY CO?dISSION 3

4 INVESTIGATION OF 5

DIABLO CANYON UNITS 1 5 2 6

7 INTERVIEW OF 8

PAUL H. ANDE RSO'I 9

10 Robert L.

Cloud Associates 125 University Avenue 11 Berkeley, California 12 Thursday December 31,1981 13 C'

14 The above-entitled matter came on for hearing, 15 Pursuant-to notice, at 3:0 8 p.m.

16 17 APPEARANCES:

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18 On behalf of the NRC Staff:

i OWEN C. SHACKLETON, JR., Moderator g

19 j

20 PHILIP J.

MO RRILL a

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22 23 s

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8202010232 820127 j

hDRADOCK 05000275

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r ERRATA SHEET Interview of Paul H. Anderson, December 31, 1981 The following correction should be made:

Page 5, Line 21 - Change til to until.

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The above correction was identified by Paul H. Anderson and Owen C. Shackleton, Jr.

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3:08 p.m.

3 MR. SHACKLETON:

The date is December 31, 1981.

4 The time is 3:08 p.m.

This is an interview of Mr. Paul H.

Anderson.

Mr. Anderson is an engineer employed by Robert 5

6 L.

Cloud & Associates, Inc.

This interview is taking place 7

in the offices of Robert L. Cloud & Associates, Inc., at 8

125 University Avenue, Berkeley, California.

9 This is the second interview of Mr. Anderson and 10 he has already been sworn in.

33 Whe reupon,

12 PAUL H. ANDERSON 13 was recalled as a witness and, after being reminded he was 14 still under oath, was examined and testified further as follows :

15 16 MR. SHACKLETON:

Do you also understand, Mr.

17 Anderson, that you have the right to have personal legal l

18 counsel necessary?

g 19 MR. ANDERSON :

Yes, I do.

That won't be j

20 necessary.

f MR. SHACKLETON:

Thank you.

And again, I request 21 i

f 22 and ask that you understand that we are asking that you keep t

23 your testimony confidential.

j 24 MR. ANDERSON:

I understand.

25 MR. SHACKLETON:

Very fine.

Mr. Anderson, how

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1 long have you been employed with Robert L. Cloud & Asso-2 ciates, Inc.?

3 MR. ANDERSON:

I joined Dr. Cloud's company 4

around November, 1980.

5 MR. SHACKLETON:

And are you presently working 6

on the contract on the reverification program for the 7

Pacific Gas & Electric Company concerning their Diablo a

Canyon nuclear power plant?

9 MR. NIDERSON:

Yes.

I've been involved with this contract since it first came about, around October 11.

10 11 MR. SII ACKLETON :

Were you involved in the prepar-ation of the October ~21, October 26, November 6 and November 12 13 12, 1981 draft reports which you people refer to as the 14 preliminary report?

MR. ANDERSON :

Yes, I was.

15 16 MR. SHACKLETON:

Were you involved in the revi-17 sion of the October 21, October -26, November 6 draf t aj 18 reports?

g 19 MR. ANDERSON:

Yes, I was.

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20 MR. SHACKLETON:

What were the original instruc-f 21 tions provided to Cloud employees by Dr. Cloud or by PG&E a

f 22 to perform the development of the report and the handling 3

g 23 of its commnts?

24 MR. ANDERSON:

We received our instructions from 25 Dr. Cloud.

Our basic instructions broke down various

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responsibilities to examine the chain of design for various 2

aspects of the plant, breaking it dawn into different types 3

of buildings and et cetera.

We formed a little internal 4

task team where each engineer or groups of engineers were 5

assigned the responsibility of developing the flow of 6

information and examining the existing qualification for 7

a number of these areas.

We first started out with the intent of searching 8

i 9

thercorrespondence between PG&E and URS/Blume to determine i

what controls and what documentation existed.

This would p) directly relate to the engineering correctness of the y

analyses that took place.

Our interface with PG&E was they 12 were to provids us with documentation as we required it.

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14 Now in the preliminary stages, from October 11 to October 21, we essentially set up office inside PG&E 15 in one of their conference roons and went through volunes 16 17 of file information, trying to document the things we were l

18 setting out to examine, to document exactly what had g

19 transpired in the design flow.

One of the problens we had j

20 as far as information available is that this project is of l

a magnitude that there is obviously too much material to 21 i

f 22 completely. assimilate in a short time.

We utilized PG&E's 23 cognizant engineers to help us locate the specific documents 24 we were looking for at times.

25 Maybe I am saying too much.

I don't want to sit 108-4 x.

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I here and ramble on.

2 MR. SHACKLETON:

No.

This is very helpful for 3

the Commission to understand exactly what the responsibil-4 ities were for your company and the procedures that you had 5

to follow and the interface that was required in order to 6

obtain the necessary information for your study.

So please 7

continue.

8 MR. ANDERSON:

Okay.

Basically I am talking g

about the research done in preparation for the first draft, which is the draf t prepared on October 21.

The 10 results of that draft showed there were several areas n

which we had either found conflicting information docu-12 mentation or had not found sufficient information docu-13 C-mentation.

In our first preliminary draft of the 21st 34 15 we tried to stay away fron any personal conclusions or 16 conclusions as told to us by PG&E engineers.

17 What we did try to do is state the information

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j 18 we had received thus far, which sonetimes was incomplete.

g 19 From my own personal standpoint, the effect that seemed j

20 to have was to create a priority withi PG&E to supply us with the information we needed.

Up til then I could say 21 i

f 22 that perhaps we hadn' t been given a real priority treatment 2

in all of the information we needed.

When the October 21 l

23 24 draf t was given to PG&E a lot of these areas which we had 25 just been unable to find sufficient information, these (J

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1 areas were commented on by the cognizant PGLE engineers.

2 Now the engineers made several types of comments.

3 They either made comments to the effect of "there:is ~more 4

information and I will help you find this information" or 5

perhaps that is not my understanding of it".

Now when 6

they made the comment that there is additional information, 7

we searched the information and, if we found it,,we utilized 8

it and documented it.

9 On the other hand, if someone were to say this to particular area :is just not true, our response was fine, 11 show me the documentation, such that the report of the 12 26th in affect reflected our gathering of a little more 13 info rmation.

That is basically the only difference, to my k.

14 recollection.

15 MR. SHACKLETON:

Were all the verbal comments 16 that you received, were they documented?

When I say verbal 17 Oomments I am referring to directions or requests or comments l'

l 18 that related to requests for revisions.

g 19 MR. ANDERSON :

Basically we had a surprisingly i

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20 little amount of verbal interface with PG&E.

In the

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21 initial stage, from the October 11 to October 11, we were a

f 22 functioning as our own little self-contained task group Ii 23 and no one seemed to pay much attention to us.

Indeed, that

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24 was part of the problem.

From the October 21 and subsequent-l 25 work, we performed all of that work in our own office and i

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primarily formally interfaced through PG&E or interfaced 2

through Dr. Cloud.

We had some level of informal communica-3 tion merely following up researching some of the areas"that 4

we had already identified in the first draft.

5 In the first dreft and I believe the subsequent 6

drafts we fairly across the board address all of the holes, 7

all of the areas of concern, either by providing substan-8 tiating documentation, which we should have on file, or 9

in the cases that we don't have enough information we have to stated either that this will have to be addressed in a more 11 detailed scope, such as the ser ;nd phase of the reverifica-12 tion program.

13 MR. SHACKLETON:

What you are stating then, if I 14 understand you correctly, Mr. Anderson, these were made 15 open items.

16 MR. ANDERSON:

Yes.

17 MR. SHACKLETON:

Within your draft report.

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18 MR. ANDERSON:

And well defined as open items.

3 19 MR. SHACKLETON:

Mr. Anderson, were you encour-j 20 aged at any tine or directed by anyone to change any of your a

l 21 original findings?

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22 MR. ANDERSON: If you define a finding as somethina aj 23 that is wrong, certainly not.

24 MR. SHACKLETON:

That's the main point that we 25 are looking towards, b

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h) 1 MR. AMDERSON:

The only thing I micht add is 2

there were holes where we did not have information and, 3

in this case, PG&E encineers did make comments and did 4

request that we find the additional information and examine 5

it.

6 MR. SHACKLETON:

In the course of writing your 7

sections of the drafts that we are discussing here, did c

you ever make any changes without substantiating documenta-9 tion?

I'm talking about substantive changes, not just in 10 grammar or punctuation.

11 MR. ANDERSON :

I either had substantiative 12 documentation or I explicitly qualified the change, such 13 as pending all subsequent investigation.

The qualification

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14 would be in the report.

15 MR. SHACKLETON:

I understand from testimony we 16 have received that this has been a very intensive effort 17 on the part of yourself and the other engineers here at

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l 18 Robert L. Cloud & Associates, Inc.

Do you feel, Mr. Anderson, g

19 that your staff that you are associated with on this reverif--

j 20 ication study for the Diablo Canyon nuclear power plant, f

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21 that you have been able to work with a free hand and to f

22 freely express your true findings without any interference?

23 MR. ANDERSON:

Within my own company certainly.

24 As a professional, I feel I would have to insist on freedom.

25 I wouldn' t be here if I didn't have the freedom.

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MR. SHACKLETON:

Are you satisfied.then, Mr.

2 Anderson, with the contents of the preliminary report dated 3

November 12, 1981?

4 MR. ANDERSON:

I am satisfied as to the validity of the facts stated in the report.

There are certain open 5

6 items which are qualified in the report as requiring to be addressed later.

There are itens which we did not get 7

enough information on that a subsequent program has been 8

g developed to address.

With that exception -- that has some bearing on my overall impression of the first program, if to you can understand my point.

33 MR. SHACKLETON:

Yes.

12 Mr. Morrill, do you have any questions?

33 MR. MORRILL:

Yes.

Mr. Anderson, did you receive g

any verbal comments fron people other than PG&E, such as 15 from Blume or Westinghouse or any of the other contractors'.

16 17 that you might have interfaced with?

l 18 MR. ANDERSON:

We certainly had some level of interface with both Westinghouse and URS/Blume.

As far as g

39 a

j 20 the type of interface where they cormented on the contents l

of our report or the things that we had found, I wouldn't 21 say I had any of that type of interface.

f 22 MR. MORRILL:

Thank you.

23 MR. SHACKLETON:

Mr. Anderson, going back in 24 25 review of the questions that wa have asked and the resnonses k.

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i that you have made, are there any comments that you would 2

like to add to your testimony?

3 MR. ANDERSON:

Merely I would like to emphasize 4

or restate that I feel both personally and as a company 5

to have performed a conscientious job in ' preparing all the 6

reports, all the drafts of the preliminary report, and that 7

I feel upon scrutiny of the various drafts it should be 8

an obvious conclusion that the type of development occurring g

through the drafts was an actual accumulation of information, accumulationsof knowledge, and that is all.

10 MR. SHACKLETON:

Mr. Anderson, is there any ij additional information relating to this seismic reverifica-12 tion study that you would like to make a matter of record 13 at this time?

14 MR. ANDERSON :

I don't believe so.

15 MR. SHACKLETON:

Mr. Anderson, on behalf of the 16 37 Commission, we thank you very much for your testimony here.

18 and the time that you have given to us.

The time is now l

g 19 3:27 p.m.,

going off record.

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20 (End of interview) ij 21 i

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