ML20106G153

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Transcript of 831202 Interview of RG Tolson in Glen Rose,Tx Re Discrepant Coating Repts,Qc Personnel & Falsification of Records.Confidential Info Deleted.Pp 1-53
ML20106G153
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/02/1983
From: Tolson R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
NUDOCS 8410310067
Download: ML20106G153 (55)


Text

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UNITED STATES OF AME.RICA n

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NUCLEAR REGULATORY COMMISSION 3

INTERVIE.s 5

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0 RONALD G. TOLSON 7

',' @t:d^ - Conference Room No. 2 l 10  ! ' * #* " ** " *" *#

Texas Utility Generating Company II P. O. Box 2300 .l' Glen Rose, Texas 76043 j

12  :

Friday, December 2, 1983 13

[

The interview commenced, pursuant to notice, la.

at 10:20 a.m.

16 PARTIES PRESENT:

I On Behalf of tne NRC Office of Investigations:

18 H. BROOKS GRIFFIN, Investigator DONALD D. DRISKILL, Investigator 19 U. S. Nuclear Regulatory Commission 60

  • 9 "

611 Ryan Plaza Drive 21 Suite 1000 Arlington, Texas 76001 22 On Behalf of Texas Utility Generatina Comcany:

23 McNEILL %ATKINS, II, ESQ.

Debevoise & Lieberman 24 l 1200 Seventeenth Street, N. W.

  • 25 Washington, D. C. 20036 TAYLOE ASSOCIATES 1625 i STREET, N.W. - SUITE 1004 WASHINGTON, D.C. 20006 8410310067 831202 (202) 293 3950 i

PDR ADOCK 05000445 T

pyp EXHIBIT (12)

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' 1. ' TABLE OF CO:;TE:; E . ,

2 WITNES'S: EXAMINATION BY MR. GRIFFI5 : MR. DRISXILL -g

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2 MR. GRIFFIN: We are on the record.

3 This is an interview of Ronald'Tolson. He is

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4 employed by Texas Utilities Generatir.g Corporation -- is that 5 right, Ron?

t 6 MR. TOLSON: Yes.

7 MR. GRIFFIN: .- Company. -

8 The location of this interview is the Comanche 9

Peak Steam Electric. Station near Glen Rose, Texas. Present.

10

,at this interview are for TUGCO Ron Tolson, his personal 11 representative, McNeill Watkins, an attorney with the Law 12 Firm of Debevoise & Lieberman.

13 This interview is Deing transcribed by a court 14 reporter.

15 Ron,.if you would rise. I need to swear you for 16 the contents of your statement.

17 Whereupon, 4

18 RONALD G. TOLSON 19 having first been duly sworn by Investigator Griffin, was 20 examined and testified as follows:

21 EXAMINATION ON BEHALF OF NRC 22 BY MR. GRIFFIN:

23 Q Uhat is your present title?

24 A Construction OA Supervisor.

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25 Q And jou are a TUGCO employee.

4 I

i i

g A That's correct.

2 0 Who is your immediate supervisor?

i 3 A David Chapman.

4  ; O I have a number of areas that I want to ask you i

5 about. We will just be jumping from one subject to another.

6 The'first one is, were you aware of an NRC that 7 was written in March of 1982 by Charles Atchison regarding 8 bender welds on the pressurizer tank in Unit l?

9 A You used the phrase "was." What I think you are 10 asking is, the 822 incident that we discussed in licensing 11 hearings.

12 Q I believe that's right.

13 A I would have to say the correct answer is , no.

14 Q Okay, you didn ' t have anything to do with that 15 situation?

16 A Not in the context of, was I aware of it in March 17 of '82, no.

18 Q Okay. Were you involved in anything that had to 19 do with that situation prior to tSe hearings?

m A No. Well, I became aware of the existence of a 21 numbered 822 NRC form in prefiled testimony.

Q So that the sequence of events that occurred that 23 related to the finding of the NRC by one of the employees 24 out here, you had nothing to do with any of those events ,

25 no knowledge of it as the events occurred?

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2 Q Were you involved in the decision to issue the NCR  ;

3 after Atchison's termination?

I think this was in August 4 of '82.

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5 A Let me answer the question this way: ,

When the 6

blank NRC came to my attention, which was either through 7

prefiled or a limited appearance statement, as I recall, by l

8 Henry or Darlene Steiner -- I can't recall which -- I 9

directed that the NRC be put in the system at that point in 10 time.

. 11 Q And was it issued?

12 A Yes, it was.

13 0 Are you aware of any threats, pressure, attempted 14 intimidation, intimidation that was perpetrated against 15 Mr. Atchison as related to this affair during the time _you 16 were still employed on site?

17 A No, sir.

18 Q Okay, I want to switch subjects now.

19 Did you ever review an NCR that related to bolt N failure which occurred during hydrotorquing in Unit 1, that 21 r,esulted in an NCR written by Charles Atchison?

22 A I am familiar with the NCR. I don't recall having M reviewed it, again, until it became a hearing topic.

24 0 Were you involved in anything regarding this M- incident as it developed?

I I

1 6 l

l A

\ I don't recall. I 2

Q l Was your first 3

hearings? knowledge of this incident in the 4 .

A As I recall, yes.

5 Q

6 So, the people involved like To consult you about m Brand didn 't 7  !

this affair.

A I don't 5 k issue. remember any consultation on that parti t cular '

9 Q

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Did you ever, 10

( at any point in time, have occasion 11 to counsel or discuss this issu

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an employee on the site? e with Atchison while he was 12 e

! A No, sir. . I 13 Q

i Are you aware of ani 14 following the issuance of the NRCtesting on these same bolt ,

j 15 the test being conducted by Chicago Bridge & Irons?

6 A

7 I don't recall CB&I doing any te sting.

I know t there were some tests performed .

1.

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Did these bolts fail during thi l s test? l No, they passed. I O Has this issue been completely resol  ;

time? ved at this .

A 5 To the best of my understanding, yes. l . it i ..--.

Q 1 E5 Are you aware of any threats l Syh intimidation, '

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levelled at Mr.

S of this NCR - Atchison as a result ~~

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1 A No, sir.

2 0 -- through third parties?

3 l A No, sir.

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j Q I am going to switch subjects again.

5 Do you recall an. incident in February, 1982, 6

when Atchison refused to sign off on design changes on a 7

Westinghouse whip restraint, or whip restraints, without 8

blueprints containing Westinghouse headquarters approval?

9 A At the time,'no. '

l 10 l Q Did you become involved, or were you aware of 11 this as the situation developed? j 12 A He testified in a hearing something along that 13 line.

14 Q Did you have any centact with this issue prior to 15 the hearings?

16 A No, sir.

17 Q Are you aware of any threats against Atchison's 18 person made by Millwright Lead over this incident?

19 A No, sir.

20 Q Did you ever have ,a personal counseling session ,,

21 with Atchison during his employment in which you told 22 Atchison to back off, or I'll fire you?

- M A No.

24 f

Q Okay, I am going to switch subjects again, M

25 What was your involvement in the termination of 0

^ E 3 ' Robe'rt H ir.; .' t e n , Joe Krolak, ar.d Sherman Shel: n?

A 2 I was consulted on the issue before the fact, 3 c ntrary to what Mr. Hamilton testified te. Ir his testimony said something to the extent that he thought I was off-site, 5 and that's incorrect.

6 I was conceptually aware of the refusal to perform 7 the inspections and probably indicated to Mr. Brandt that 8 he and Mr. Purdy maybe get together and make a decision.

9 Q What is your understanding of the reason that these 10 tb.reemenwereunwillingtoperformthisinspection?

A 11 I'm not sure I understand why they didn't do it, factually.

12 They just, in my judgment, decided one day that 13- they were not going to do the job. That is the only thing I can tell you.

14 I have never talked to any of them individually 15 about it, relative to their motivation or what.

16 But it seemed a little odd to me that they had i

17 been essentially requiring this work for some period of time, 18 and all of a sudden on one day they decided they were not 19 going td do it.

20 0 Are you aware of any incidents, events , other 31 considerations, that might shed light on their' refusal to j 22 conduct this particular inspection, that may have been on going 23 at that time?

l l 24 A Nothing that I'm aware of. '

r 25 0 Are you aware of an incident that occurred about I

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1 approximately a ' year earlier on a similar ype safety C

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inspection on which a former supervisor by the name of )

3 1, Hawkins indicated that the inspecticns in the same area were 4 unsat? I 5 A The only thing I am aware of is, again, is what 6

Hamilton appeared to have said in his testimony, and it was 7

not the same incident, it was Unit 1 as opposed to Unit 2.

8 So, that is as close as I can come to it because I was not 9

personally involved in either situation.

10 Q

Had these three men performed adequately in their 11 jobs, performed their jobs adequately, prior .to their 12 termination?

13 A I have no direct knowledge of that. Shelton had 14 been here a year or so previously in an inspection, rebar 15 and concrete. I do not recall any negative performance 16 apect on him at that time.

17 In the case of Hamilton, I need to catch this in 18 the proper way, I was not pleased with the decision that 19 was made back in '79 to discentinue following the documentation 20 requirements of the QA program.

21 Q

We will be getting to that in a little while.

22 Do you know of anything in these three gentlemen's

. 23 personnel evaluations that was inadequate or had listed them 24 as unsatisfactory employees?

25 A

I was unaware of anything that was following that at

1:

, 1 the time it occurred and I : ce never since retiewed their 2 files.

3 Q Who made the final decision to terminate these  ?

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4 three men?

i 5 A All three were Brown & Root employees, so it would 6 have to be Mr. Purdy. -

7 Q Do you know, or are you personally aware of any 8

other considerations for their termination, other than they 9

were unwilling to perform the inspection?

10 A That is the only thing that I am aware of.

11 0- Do you know if part of the reason of their

?

12 termination was based on the fact that they were inspecting

.13 too well, or generating'too many N'CRs?

14 A No, sir.

15 0 Was the decision or the discussions prior to the 16 decision made to terminate these men discussed with any 17 corporate officials of TUGCO like Mr. Chapman or Mr. Clements?

18 A. That's too far back. I typically informed Mr.

19 Chapman of any significant personnel actions. As to whether 20 or not it occurred in this case, I can't recall.

21 Q Do you recall whether Chapmen, or Clements, or any 22 of their associates had any input prior to the termination?

23 A No, sir.

24 Q Okay, I am going to switch subjects again.

25 Do you recall, or are you aware of an incident

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1 involving Darlene Ste : :: and a QC. trainee who was applying s 9

2 copious amounts of liquid penetrant on a wall during'a.

3 training exercise in which Ms. Steiner was overseeing her 4~

activities, or in the area where her activities were taking I 5 place?

6 A I can ' t make ' the tie to Mrs . Steiner. . It has 7 been brought to my attention,on occasion, what I will refer 8 to as' willful destruction of walls. As to whether it was QC-9 training, I' don't know. It has occurred. As to whether 10 not it is tied with her, I don't know.

11 Q Do yo,u recall a specific instance? Did you ever 12 counsel or have discussions with Ms. Steiner on a similar-13 incident?

14 A No.

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, 15 Q Did you ever personally instruct Darlene Steiner 16 to perform plug welds?

  • 17 A No.

i 18 0 Are you aware of any other supervisors on site 19 that had given instructions to Ms. Steiner to use or accept

Al plug welds?

21 . A Again, the o.nly knowledge I have of that subject -is 22 wha ~t Ms. Steiner has said in the licensing hearings.

23 0 Do you recall an incident regarding vendor' welds 24 on large doors which Ms. Steiner wrote an NCR on?

25 A I'm not aware of anything associated with large

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doors'and Mrs. Steiner.

I 2 O' So, you don't recall any such incident?

3 Ar No.

4 Q You don't recall counseling or discussing an issue 5 with Ms. Steiner. '

6 Do you recall any incident'related to a probl'em 7 with vendor welds on large doors?

8 A Yes.

9 Q Do you recall who was involved?

~ 10 A My QC group.

11 Q But not any individual name?

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12 A I can't associate it with names.

13 Q Do you know if these vendor welds with NCRs were 14 written on the vendor's doors , vendor welds on these doors?

15 A There have probably been some NCRs written on 16 doors, yes, sir, relative to welding.

17 Q But do you remember a specific incident?

18 A No, sir.

19 Q Have you ever had occasion to instruct Ms. Steiner 20 to confine herself to reporting deficiencies, or conducting 21 inspections to only those inspections to which she was .

assigned?

22 '

23 A I don't recall discussing that subject with her.

24 Q Are you aware for yourself, or any of. the other 25 supervisors, ever having occasion to counsel Ms. Steiner to

1 s.: .-t r from making whs:*. I will ten random inspect:,ons?

2 A No, sir.

3 0 Do you recall meetings between you and Ms. Steiner 4

5 A. Yes.

6 Q How many of these meetings were there, do you f 7 recall? I 8 A There were probably two.

9 Q What was the purpose of,these meetings?

10 A The first one was, it was reported to me that she 11 I sensed a need to -- because.

12 she was in a position in the field of climbing, et cetera --

13 I wanted to be sure she understood that if she continued in 14 that activity, I was uncomfortable with the idea 15 working in the field. I 16 guess that is the best way to state it. So, I wanted to be 17 'sure that she understood what she was doing.

18 Q Did you encourage or suggest to Ms. Steiner that 19 she leave her employment?

20 A No, I didn't couch it in that way. I suspect 21 you are talking now about the second time, not the first

i 22 time. The first time it was'just -

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1 -l The second time was suosequent to her testimony l The purpose of the meeting was to -- and 3 at the hearings.

3 4 ' M NN hdlAk0$ QM M 7Q:N,1-lwit.jg ;'NN ;lAr8fC . " l 5 j and _ wanted to be sure she understood the .

6 ramifications of ' he insurance coverage that she carries at l 7 Brown & Root, to be sure that we communicate with her her 8 options that were available to her to maintain insurance 9 coverage.

10 The only reason for this was because obviously that would have been covered. But I wanted 11 to be sure that she got the appropriate counsel on 12 13 complications 5 :ly::71' i N h.- 'n the event 14 that she had to go beyond that because if she wasn't careful 15 on how she handled that she might have -- she had mentioned 16 , to me M k ;M4 Y Y d-D M 79'D 1 W N The way I understood the insurance coverage, the 17 18 19 jf} % h ? W , N yn;yg,$ g 4964$4-,}6r a '3 / what is a

0 very expensive I wanted to be sure that she had 21 the benefit of making the proper, decision _3o protec_t herself ne insurnace standpoint.

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23 O Since you have been on site, you have been 24 employed at this site, have there been other people under your .

25 supervision. g I

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A I am sure there have been some.

2 0 That you personally knew about.

3 A No. Well, other than what you see walking up and i

4 down tne hall. Sut none that were working in what I 5

consider to be a somewhat hazardous situation for their 6 perscnal health.

7 O In your second meeting, did you encourage or 8

suggest to Ms. Steiner-that she leave her employment?

9 A What I think we recommended for her consideration 10 was that if she wanted to take a leave of absence, it could 11 be arranged, with the insurance coverage to be extended.

12 That was the purpose of this session.

13 0 Did Ms. .Steiner's appearance before the SLB 14 prior to this second meeting have any influence, was it 15 the result of this special attention given to Ms. Steiner?

16 A Yes, it had some influence because obviously at 17 that pcint in time she was a protected employee. It did not 18 take any genius to figure that out. And to a certain extent 19 I felt like I was sitting on a keg of dynamite ready to go 20 off. We have all had the press coverage and various and 21 q, sundry accusations and "untrues" that have been told. You j 22 know, I am sitting there just waiting for the next one, 23 magymygg4Weggsm"mW for 24 example, and we did not take appropriate protection because 25 she was one of them that was testifying against us.

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i l I j S, es, that influenced me in talking to her 2 personally.

3 Q Did Ms. Steiner's duties change 4

1$@.53 5 A Yes, they did. .

6 Q Could you tell me briefly what those changes were?

7 A Basically, we moved her to the l'ab Shop location 8 i where she would not have to climb, she could conduct l l

9 inspections, still paid and work in the QC group, with j i

10 much lighter duties that what she would have had if she had 11 remained in the field force. You do away with the climbing 12 and this sort of thing. ,

13 The other thing is, we did arrange to provide l l

14 transportation for her from the gate to the Tab Shop, i 15

} or anything like that.  ;

16 0 Have you ever made similar arrangements for any i

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18 A Again, I have not had much experience with QC 19 people in the field M M T@ $ d> # - ut it is common policy 20 on people that.;f6p j fg M M M$' a: eto provide certain ,

23  !

privileges. '

l 22 Q Was Ms. Steiner's work considered adequate?

23 A At the time, yes.

84 0 And you recall that there were two such sessions 25 where you counselled her @ W @ M % CAV@ET&1laddB l

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1. A That 's right .

2 MR. WATKINS: By " counseling" 3 .

MR. GRIFFIN: I did not mean that in the formal 4 sense, just discussing the situation.

5 MR. WATKINS: Meetings to discuss the subject.

6 BY-MR. GRIFFIN:

7 Q Ron, do you consider Ms. Steiner's testimony before .

1 8 the Board having raised any legitimate concerns? 1 9 A Without going back and. reading every detail, the 10 answer to the question is, no, I don't.

There has been a lot a

11 of testimony and a lot of talk. So, just from my personal

?

u participation in reading the transcript, 'I would have to 13 say, no.

14 0 And a different subject, were you involved in the 15 decision to terminate Henry Steiner?

16 A No.

17 Q Were you involved in the incident in any way?

18 A No.

19 Q Were you aware as it was developing?

m A No.

21 Q Are you aware of why Henry Steiner was terminated?

n A Not anything other than what he said in the 23 hearings and wh'at cross-examination b'rought out. I did not 24 even know who he was until he showed up in the hearings.

2- Q Have you ever heard discussion indicating Mr. Steiner

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- y have been fired fcr report:n; a deficiency 2

r defect to 2

f QC?

3- A Nothing other than what he said in hearings.

4 Q Are you f amiliar with the relationship between the 5

timing of the reporting of this defect and his termination? -

6 -No, sir.

.A 7 Q Okay, I'll go on to another subject.

8 I have had an opportunity to look at the historical 9

file and the quality instructions that relate to coatings.

10 i

If I am reading the file correctly, prior to Revision 4 of 11 the quality instructions, I believe I was looking at one 12 relating to steel. Prior to Revision 4 which was October, 13 1981, NRC 16.0 was included in the quality instructions.

14 Do you know why in Revision 4 NCRs were removed?

i 15 A Do you have a date sequence because I don't 16 l associate Rev numbers with sequence.

17 0 If my recall, my review of the file, is correct, 18 October of 1981 the IR Program was implemented and NCRs were 19 removed from the procedure.

20 A It doesn't ring a bell to me because I have had the 21 inspection re, port concept built in on the QA program.since 22 1978. But what you are saying from your review does not 23 make sense to me. i 24 Q Are you aware that 16.0 was dropped from QIs 25 relating to accatings inspections for a period of time, from c -

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1 k'81to I

'83? , '

1 2 A That time frame doesn't make sense to me. I guess 3 I would have to disagree with the term " dropped."

4 Q Well, it did not appear in Revisions 4 thrcugh 15.

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5- A I would have to go check the file. We can have the 6 file brought up, whatever you choose.

7 Q Okay. Well, I am asking you as to what you are 8 aware of right now, rather than asking you to review.

9 A What you are saying doesn't ring a bell with me.

10 0 Okay. Were you aware of an approximate 14-month 11 gap between 1980 and '81 in which no NCRs were generated in 12 the coatings arena by the inspectors?

13 A I am aware of the accusation that Mr. Hamilton 14 made, and I have been made aware of an apparent gap in the 15 record.

16 Q Do you have an explanation? If this is true, if 17 there were no NCRs written in coatings for a 14-month period, 18 are you aware of the reasoning or why this occurred?

19 A The only thing that makes sense to me is from 20 sometime in '79 -- and I am thinking in late fall, early 21 winter -- until approximately the same time frame in '81, 22 nothing that was prescribed in the program really got carried 23 out the way it was intended to be.

! 24 That goes back to the detailed documentation 25 requirements that we mentioned earlier, as I recall from i

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~ Claude Johnso..'5 . - estigation and scms other results 1 that i 2

kept informal sets of logs documenting the inspections that 3 they accomplished. They had opened but not closed a number-4 of " final inspections" on the liner specificall- under the 5

pretense that we do that later because all the mechanical 6

damage was bothering them, and.this type of thing.

7 The only other thing. that seems to add up to me, 8

that the liner at that point in time was probably well on 9 the way to being: primed. It had a thin seal coat on it, as 10 I recall, a top coat, just to protect the prime. And we 11 probably -- and I have not, studied the-production records --

12 may not have been pushing at the finished coat on the liner 13 at that point in time.

14 If that is true, then the majority of the paint 15 l work that was being accomplished would have been hangers 16 or bulk-steel, and in the Paint Fab Shop which is a go-no go i

17 itype situation, it either meets the requirements or it does 18 not.

19 With the philosophy that they appeared to develop --

20 to my-chagrin -- logs, et cetera, it is not too hard or too 21 difficult for me to perceive a gap in an "NCR log" for some

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22 period of time.

23

, Q Do you know or do you recall, did you or any of 24 your subordinates issue orders or instructed anybody in the 25 coatings department to suspend NCRs for any period during

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} this time?

i 2 A According to Hamilton's testimony, to the best of 3

my recollection that is the first time I became aware of any 4

I.

such order that he was in fact told not to use NCRs. -!

5

, Q Do you have any recollection of making any such 6

-s'tatement or instruction, giving him such. instructions?

7 A It is totally inconsistent with my obligation under-8 Appendix B.

9 Q But even if it is inconsistent, do you recall?

10 A No.

11 Q Okay.y 12 A I need to clarify that, though, and re-emphasize 13 the fact that the non-ASME OA program was designed to 14 utilize to the maximum extent possible an inspection report 15 which accomplishes the same thing as an NCR.

16 Q Okay. As relates to the Inspection Report Program, 17 how were inspection reports used to report the deficiencies 18 that were identified that were not part of assigned 19 inspections?

M A I am not with you.

21 Q If a deficiency was identified that was not a part 22 of an assigned inspection, how were inspection reports used 23 to report the deficiencies?

24 A I am not sure they were. But you are losing me.

J Q It is my understanding that inspectors who were i

i l

I assigned specific inspections, d w, identified a 2

deficiency that was not part of their assigned inspection, 3

what method did they use, or how did they go about trans-4 mitting this?

5' A We have used different forms at different times, 6

but the NCR certainly has always been available. At one 7

point in time we used what we called FDR, which is a field 8

deficiency report , and that vehicle was available to them 9

and they used that in a large number of cases. It was 10 primarily for things like inadvertent damage to equipment 11 or something like that. ,

12 O Was this field deficiency report removed from the 13 procedures when the IR Program was brought in?

14 A No. It was removed from -- again, to go back, 15 the IR program concept has been in place since the advent 16 of the "non-ASME QA Program." i 17 Q Well, wasn 't it '81 when it was incorporated in 18 coatings, in the procedures for coatings, the quality 19 instructions for coatings?

20 A I need to be careful with semantics here. The 21 inspection report form that I have been using since '78 was 22 in fact incorporated in the coatings program in, as I recall, 23

.early winter of '81.

24 However, the coatings program always had a 25 documentation format that didn't carry the title " Inspection

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1 . 1 Report" but E g t c. , accomplished the scme thinc. 1 2 l Q Issee the distinction'you are making.

l 3 A Okay.

4 Q When I refer to the Inspection Report cr IR program,~. I 5

I am speaking of the use of this new reporting form which 6 was, again, in fall of '81.

7 Sc, ac'I refer to it during the rest of this 8

interview, that is what I am referring to.

9 A I keep hammering -- excuse me -- on one point, 10 that it was not a new form.

11 Q Okay.,

12 A It was just, the old forms on the coatings --

13 Q Were check lists --

14 A No, it ras the same thing, still an inspection 15 report, still a check list.

It very likely had a di fferent 16 I

title on top of it, but it still accomplished the same thing.

17 It is "the" things that an inspector has to do to satisfy 1

18 the QA Program from an inspection standpoint.

19 Q Okay.

20 A Obviously, the people had trouble with the old 21 forms, otherwise, I would presume, they would have filled them 22 i

out proper 1y.

So, we thought we had had great luck with the 23 i

" Inspection'. Report Form" and simply revised the attributes 24 that were in the old forms under the. Inspection Report Form

-t 25 and made that a viable part of the coating program, t

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1 I; Q- In my review of the' historical file c.. cue._.;

2 instructions, prior.to the implementation and use of this 3

new form, the Inspection Report Form, I notice that the-i 4

' QIs referenced final acceptance as related to theJ-- I think 5

you mentioned a while,ago -- the FDRs; is that it? ,

6 A You are losing me again.

7 O Okay. I wish I had a copy of that here.

8 In my review when the inspection report, the new 9

Inspection Report Form was implemented, which I believe 10 is Revision 4, 'i'n October '81, this final acceptance criteria 11 is referenced in the Inspection Report or the Check List .

12 Report, was dropped.

13 I didn't know whether this indicated a change in 14 the program or not --

15 A

You are leaving me with the impression that you have 16 not reviewed the entire program.

17 0 That may be true.

18 A

You are leaving ne with the impree ' ',, that you 19 reviewed only a very small portion of i .

20 0 I just looked at the historical file, 4.1.

21 A That's the impression you are leaving. I think your 22 question answers itself if you look at the birth-and-death 23 type concept that is involved -- there is more than one 24 3

instruction in the protection coatings program.

25 Q I think this was steel.

.r l

25 :

I l

~A Again, there is more than-cne just for steel. '

2]  !

Q Is there?

3 :: A Yes.

11  :

I 4- ,

Q Okay. Well, let's move on, then.

5 A I think.

6 Q How are "unsats" on irs dispositioned?

7 A There are at least two, and possibly three ways, 8 that that is accomplished. That is either fixed, which is 9

the preferred method, or it can be converted for a non-10 conformance report or, I believe, as Mr. Brandt testified 11 in the hearings,last year, in selected areas that engineering 12 can get involved with the discrepancy on an inspection 13 report and issue a change or deviation to the spec or 14 drawing, and it can be closed on that basis.

15 0 You indicated the preferred method was to have it 16 fixed. How does the "unsat" on the IR, how is that 17 transmitted to Craft? -

18 A A copy.

19 Q It is just given to Craft?

20 A Yes.

21 Q How are "unsats" on irs tracked?

22 A I am not with you.

23 0 How do you keep up with all these "unsats" that 24 are going to require rework or dispositioning?

25 A Okay, prior to some time this year -- and I don't 3

J

I s ..

.=

i i

i remc mber . exactly when -- we didn ' t have tne wor:c's best l 2 tracking system for "unsat" irs. We have always had a good 3 l handle on total accountability for irs but not specific I

4 6 "unsats."

5 It'became very obvious in the first part of the 6 year when we worked up a plan and are currently tracking 7 all of the "unsat" -irs through a computer program.

'- 8 Q Could you describe the system prior to use of the 9 computer?

10 A We relied on the Craft, the transmittal of the 11 copy to Craft and construction management to see that the C problems got resolved.

13 Q So, it was not formally tracked?

14 A It's always been formally tracked through a log 15 system as far as I am concerned, but from a completion 16 standpoint it was a little bit informal as far as Craft was 17 concerned.

18 0 Who was responsible, who did attempt to keep up 19 with these "unsats" on the irs?

20 A Well, we had copies in our files and we, of course, 21 s till had an .open log entry. What the Craft did, I do not 22 know.

D , Q Now, if I have this right, all irs were given 24 . numbefs and they were tracked as a group. Are you telling me 25 that there was no ceparate tracking for those irs that

3 _ - ..

l

't il 27 t'.

1 ' ccntainec "cisats"?

2 A Not'until this computer-program.

I a Q okay.

4 . J. Other than the log. Keep-in mind, the log 5 serves the same purpose as the - computer, it is just .not as 6 easy.to communicate.

7 0 Who maintained this-log?

8 A QC.

9 Q Is there any individual within QC that had that.

10 responsibility?

11 A At'that time, it was done by each discipline.

12 O Was each inspector required'to make entries in the 13 log?

14 A No, it was done by clerks, as I recall, working 15 for the discipline's supervisor.

16 Q What instructions do coatings QC inspectors have 17 if they. should identify a deficiency that is not.part of the 18 assigned inspection attributes?

i 19 A I'm not aware of any that they have, that are not

, 20 part of the program.

21 0 So, the inspection, hypothetically, if the 22 Inspection Report hhd 17 attributes, they are required to 23 address all 17, or are there instances where they are asked 24 to address, say, just a portion thereof?

t 1 25 A Well, it depends on the circumstances the-Inspection-

t 28 1 Report-Term covers. ' et 's - j ust take the. primary'applicarion 2 :on steel, as an example.

, It would cover all of the 3

attributes that were required to complete _the primer and 4

could conceivably include things like the primer repair. .

5 Now,_if.for a given' inspection requirement or .

6 function the only thing that had to be accomplished was

'7 primer repair, then all the other steps would be marked B-N/A because they are obviously.nct applicable.

9 0 If there were a. deficiency that was covered under i

10 one of those other attributes, are the inspectors liable 11 to make entries even if it is not part of the assigned, f or --

l 1 12 A Certainly- as far as I know they do.

13 i-Q Are inspectors allowed to make random or routine 14 inspections that they are not assigned?

i 15 A It-is not preferred.

16 Q Do inspectors get into trouble with QC supervision 17 if they conduct these routine or random inspections?

18 MR. WATKINS: Excuse me, routine or random? They i

18 are two different things.

i 20 BY MR. GRIFFIN:

t 21

-Q I h-ave a point here I want to communicate to you, M

and it relates to unassigned inspections. Do you understand 23 i uhat I am talking about when I say " unassigned" inspections? '

24 j A Let me paint a scenario and let's see if we under-M stand, l

1 i-

~

,- Il - i t

y . l

. 1  ; O Okay.

i 2 A If what you 'are alluding to is' Atchison's testimony,[.

3 then I can relate to that.

4 O I have not read his testimony. But what I am trying-5 to refer to is-, if an inspector were walking around and 6 looked at something that was not part of'an assigned 7 inspection he had been asked to perform,'are inspectors

~

8 allowed to do that?

9 A As far as I know, yes.

10 Now, let's be careful.

11 Q In what sense?

12 A. I do not want 300 people just arbitrarily walking.

13 around the plant site, that presents'me with a management 14 problem.

15 0 Well, my follow-up question was, if they do that, 16 they do get in trouble? Or are they discouraged from doing 17 that?

18 A It depends on the circumstances. We are beating 19 around the bush here, I think, to a certain extent and 20 perhaps I will volunteer some stuff and maybe we will come 21 to the point.

Z2 0 Okay.

23 A If I am working Elevation 905 linerplate and what 24 we are' tryina to do from the project standpoint is come out 25 of the reactor building, working from the top down to

_ , y.y- wi-r - -

W

30 i

1 i appr:x:: 2:ely Elevation 830 and frcm the botto.: ;p to 2 approximately 830, and then go out the hatch, if I sent an -

3 l individual to work for paint inspection at Elevation 905, 4

that is where I expect him to be and to stay.

5 0 Okay.

6 A Now, if all of a sudden he starts wandering around 7

in 810, identifying things -- and I don't like your term 8

" trouble," he is not in any trouble, but he will be called 9 in and told to get back to 905.

~

19 Q Okay, let's take another hypothetical. If an 11 inspector is assigned to perform an inspection and it 's 12 right in front of him, but three feet to his-right there is 13 something else -- and we are talking about the arena of 14 coatings here -- and he sees something that is not part of I

15 his inspection and he identifies a deficiency on this, is 16 he allowed to report that? l 17 A Certainly.

18 Q Is he discouraged from doing that?

19 A I am not aware of any discouragement along that 20 line.

21 Q Okay, that's the point I am trying to make. That 22 is my question.

23

, In identifying deficiencies under the use of this 24 new inspection report format that was implemented in the fall 25 of '81 and is in current use --

YI Y 31 '!

I ll A

, 3 l l

I am going to have resist every :::. jeu say "new  !

f 2 report."

3 Q Okay, new format.

A No, wait a minute.

4 The word "new" is what.I am 5 having trouble with. The inspection report has been in the 6 program since 1978, okay. It was incorporated into the 7 Protective Coating Program in '81. But it is not a new 8 form.

9 Q I'll tell you what, Ron, rather than repeat this 10 25 times every time I say " inspection report," what term 11 can I use to differentiate the inspection report from the 12 old check list?

13 If I cannot say inspection report, if that is not 14 satisfactory --

15 A Just drop the word "new" and then I won't have to 16 bring it up every time because it is not a new form, 17 semantically, to me.

18 Q Well, I spent a lot of time in your vault there 19 looking at those old check lists, and when I look at that 20 inspection report it looks new to me because it is different 21 than those old check lists.

22 A It's new -- maybe we just ought to drop it and M I'll just ignore "new."

24 0 Okay. I am not trying to inflame you or anything, t

25 I am just trying to move this thing on. When I say "inspectiert

m _

l-  !-

l-1 report" '

2 A 'Why don't we just agree, check list for the 3 coating program is in exisrence prior to '81, a..d inspection 4 . report subsequent to '81, and I won 't have te repeat this.

5 'O All right.

6_ When deficiencies were identified under this system 7 used'after October '81, were reject tags used to --

8 A They are used now. I don't recall when they felt 9 the need to start using a status indicator like th a t . I 10 would have to go back to the instructions myself to get that 11 time frame. *

?

12 O was the purpose just to quick 1_j identify exactly -

! 13 what area of the-inspection r quired examination, or rework 14 or repair?

i 15 A It is simply a physical indicator to the Craft 16 that there is something that is holding up completion in 17 this area.

-18 O So, the reject tag does not communicate the same 19 intent like a hold tag which accompanies an NCR?

20 A That's correct.

21 O Okay. I believe earlier that NCRs have been part 22 of coatings procedures, since '81; is that correct? Or M .to your knowledge, your personal knowledge?

24 A To our knowledge, they have been part of the i

25 program since its inception.

_ . - _ . _ _ _ . _ . _ _ . . . ~ _ . . ..

I _

-' Lh O i

, 1 Q Okay. - Say, . be r " e .19 81 and 198 3,' were coatings 2

inspectors allowed to write NCRs and attach hold' tags if 3 they.didn't find-a deficiency? F 4 A They have always been perndtted, if in their 5

judgment they needed to issue an NCR and to apply a hold tag, 6 then and now.

7 -Q Okay. Who does the final review for NCRs generated 8 in coatings ,

by coatings inspectors , ~ which supervisor?

9 A Well, it would be under Brandt.

10 -Q So, he would be the final reviewer?

11 A I don't know.

12 Q Well, where I am goi' n g with this is, the inspector 13 writes it.

His first-line supervisor reviews it. Does his.

14 first-line supervisor have the authority to void NCRs?

15 A He doesn't have authority to void it. He has the 16 authority to recommend voiding it.

17 Q Does that then put it on Brandt to make the final 18 decision?

19 A Yes.

20 0 Are hold tags applied before Brandt's decision?

21 A yes.

M Q Can individual inspectors call and receive NCR 23 numbers prior to Brandt's approval?

24 A Most definitely.

! 25 Q I want to touch on an area that was not incorporated.

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.34 i

1 I'already know that it was not incorpora r- t u: I want to ,

2 touch on it briefly.

3 I recently became aware of the fact that for a 4 time consideration was given to having Craft supervision 5 conduct in-process inspections of codes.

6 A That's correct.

7 0 Was this possible program addressed to the NRC 8 for consideration or approval?

9 A It's a chicken-and-egg type of situation. There 10 was no discussion with the resident until prior tc making 11 the decision to draft the procedure, to see if it could be 12 done.

13 Upon receipt of the procedure and some external 14 activities, I changed my mind.

15 0 so, you were the one that created the possible 16 idea, and you were clso the one that decided not to go 17 with this?

18 A Yes. Now, as I often do over the years and have 19 done, I tend to use the resident as a sounding vehicle 20 relative to the wisdom of my independent thought process.

21 I ,have never approached him for approval, nor

'23 would he endorse anything I do other than to advise me on 23 the brilliance or ignorance associated with a particular 84 move.

25 0 Okay. It's my understanding that recent procedure I

l 25 1 ch ar. u _. :r the coatings area dropped dry spray, cverspray, 2

imbedded particles from the inspection criteria. Are you 3

familiar with this? \

4 A No, I am not.

I 5

Q Also, another change that I believe has been 6

either pending or it's already been incorporated is 7

instructions that inspections are to be conducted at arm's B

length, using a flashlight at a 90-degree angle; are you 9

familiar with this?

10 A Yes, I am familiar with that.

11 Q Could you tell me what the background thought is?

12 A It's my understanding from some people I have 13 reason to believe know what they are talking about, that 14 th at is a common inspection technique in the area of 15 protective coatings industry wide, not just Comanche Peak.

16 Q Tell me this, based on your knowledge of coatings 17 and coatings inspections, does using this method, a.m's length, 18 flashlight, is an inspector -- average inspector -- likely 19 to be able to accomplish and evaluate all the attributes 20 that he should consider in a coatings inspection?

21 A Yes.

22 O Do you know exactly why those changes were 23 incorporated?

24 A Again, it's my understanding that th at is a cormon 25 technique. There was, I think, lack of specific direction

n t

p 1 relative to technique in.particular construction and I would

2 ~

assume'therefore that was the reason for incorporating the  !

3 l technique.  !-

i

'4 I O . I ' understand that recently a number _.of painters have r

T 5

been brought over to be incorporated in the QC inspection 6 program.

They are being trained and certified; is that 7 true?

s 8 A Yes. I am not sure the term " painter" is all 4

9 inclusive,.but there are people that -- ,

10 0 That have been already employed here.

11 A Have been employed in the Craft site that we have 1

12 -

selected for QC people.

4

13 0 Has there been some. recent change or something --

14 has there been an increase in the amount of paint applied,

.i j 15 or something, that has caused - from which you have 4

16 anticipated the need for large numbers of new OC inspectors?

17

! A Yes. We expect to be up to around 35 paint crews,

.I 18

?

which will include r ,ps people and applicators. Our plan

)' 19 is to have a qualified inspector for each group.

I.

i 20 0 Are these crews going to be working in Unit 1 or 21 both? -

Et A I

In Unio 1 primarily.

23 .

O Is this an indefinite program, or is the need going j 24 to be for a limited period of time?

25 A Hopefully, it is going to be limited. The word 1 -

^

4

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y m.-. - . _ _ . . _ _ . . - , , , , . . . _ . - , . , _ _ , . . _ _ , . _ , . . . . , _ _ _ . , . . , . . , , . _ _ - , . , , ~ . _ _ _ , _ , , , - . _ - _ , _ . . . . . _ , . , . . . , - - . , - _ ,

1 27

. I )

" indefinite" has'a conr. station assceiated with fuel load 2

that I do not think I like. So, in that context I~would 3

hope that it would be a short period.

4 Q I am trying to find out if you are gearing up for 5

a particular short period of time to, you know, accomplish i

6 a gre.at deal of painting, or in subsequent. inspections --

7 A We plan to paint the Unit 1 reactor building, 8

finish painting. Most of it is repair or finish-coat h

8 application. I mentioned eatlier those thin seal coats on 10

, the liner. So, as we come down again from the top to 832 y 11 and from above,,our plan is to' paint the reactor building.

12 Q Does this include rework or repair of damage?

13 A Yes.

14 0 once you have completed the repainting or th 15 paint that you anticipate applying, that will be applied to 16 Unit 1, what normally takes place and what do you anticipate 17 taking place as related to all these QC inspectors?

i 18 A The question is a little premature because we 18 have not, at least at my level, developed a detailed schedule 20 for Unit 2. One thing that could happen is that they would 21 simply flop the Unit 1 group to Unit 2 and proceed with the 22 samd concept.

23 But again, it is premature. Until we decide for 24 sure what we are going to do with Unit 1, my personal plan M

is to keep the necessary number of inspection people to 1

6 1

38 I  !

I i c uppo r- t r <. Unit 2 schedule, whatever that may be. .

2

! O Prior to the completion of Unit 1, this painting l

3 p and inspections, do ycu anticipate the termination of any of f

4

' the coatings QC inspectors currently employed?

I 5 A I'm not going to terminate them. .

6 Q Ron, as the normal practice, are employees on site 7

i normally debriefed by supervisors following their interviews i

B

' with NRC?

9 A It's not a policy. I am sure it has occurred on 10 occasion but it is not a policy.

11 Q Have you ever di,,rected anybody to have an emp. myee 12 debriefed or interviewed concerning his testimony to the 13 NRC?

14 A I don't recall having done that. I 'm inquisitive ,

15 so it's possible that I may have asked a question. But I 16 don't normally dictate to people what they do. We all like 17 to know what's going on.

18 Q Is it a policy of your department to conduct a 19 concurrent investigation of your own when you become aware of 20 on going NRC investigations?

21 A I will object to the term " concurrent." If I hear 22 of something, I am going to launch into an evaluation, or 23

.Mr. Chapman will.

24 I have no way of knowing what you guys are doing.

25 so, if it's concurrent it is purely coincidental.

q l

,5 .

1.'

. p.

, i ,

O Well, if we come on site and we start bringing

, -i _

2 people in and question them in some area, does'that trigger 3 you to begin an' investigation on similar --

i 4 A , No, only those' things which the people feel strong i 5 enough about to bring to my attention. ~

6 0 You mean Chapman or Clements?'

7 A I can't speak for them. I am just talking about j 8 myself.

i 9 Q Okay. I want to go back.to, in October, 1981 Paul 10 Johnson, an NRC inspector, wrote a Notice of Violation 11 regarding coatings which resulted in NCRs being written'.in 12 various divisions on things that had paint applied to them 13 like liner plate, concrete.

14 What was the original intention for the disposition 15 of these NCRs?

16 A The intention of any NCR of that magnitude is to 17 evaluate possible paths for corrective action. I don't know 18 that there was any single path even considered prior to the 19 issuance of the NCRs, just a routine procedure.

20 0 Well, were you all considering total backfit at 21 that time?

%! A No. I would say, nd. Like I said, I didn't have 23 any. single thing in mind except, you know, it was a type of 24 a situation where we had what you would call an indeterminate 25 condition which technically gets an NCR issued. Then you go l

t 40 ,

l through the ecaluation process between engineering and my 3

people and come out with a course of action that we are 3 i

! comfortable with.

4 l Q Was a decision made to completely backfit concrete 5 and liner plate?

6 A Subsequently, yes.

7 O Was that your decision?

8 A Yes, I have to endorse it.

9 0 What did you decide is related tc miscellanecus 10 steel which included conduit, support and cable tray support?

11 A I think we adopted a consistent. pattern across 2 the board. We just looked at everything.

13 Q All right. It's my understanding representative 14 sampling was used in the miscellaneous steel to --

15 A Not initially.

16 Q okay. But as backfit continued, a decisien was 17 made?

18 A Recently.

19 0 Okay. And was the sampling conducted?

20 A Yes.

21 0 1: hat was the outcome?

22 A Let me put it in my words. Approximately -- and I 23

.get weekly reports on the status of the backfit since its 24 inception, relative to percent complete, and we needed some 25 idea where we stood from a scheduling standpoint. Approximately

.e l

y .

b ~

. 1 j 99 percent of the liner had been co:pleted: 80, 2 5 p-; r -

. 2. of the concrete backfit had been completed, and approximately 3 80 percent of miscellaneous steel had been completed, at 4- which time I asked our corporate OE group to review the 5 records and advise me on one or two possible' future. courses 6 of action -- one of which is to continue as is. The other 7 is to delete things which statistically are not increasing 8 the quality of the work effort.

9 It was their recommendat' ion, as'I recal1, to 10 delete on this miscellaneous steel.the destructive aspects 11 or destructive, testing aspects of backfit, which is essentialli 12 the scratch test and adhesion test.

13 Upon receipt of their report to me I caused the 14 program to be revised accordingly.

15 O So, is this backfit complete in miscellaneous 16 steel?

17 A As far as I am concerned, yes.

18 Q Have the NCRs that relate to miscellaneous steel 19 been closed?

20 A I doubt that they have at this point, but they will 21 be in the near future.

22 As related to the old coatings inspection rec'ords O

23 that were generated back in '77 through '79 or 1980, that 24 are in your vault, it is my understanding that the basis for 25 the Notice of Viol = tion that Johnson wrote,'are those records, i

L ,

42 1

h(thoseold:n_..:on records, being used -- current 13 bcine 2

used -- for any purpose to attest to these old inspections?

3 A There is a possibility some of them may be.  : am 4

not that close to the intricate details. The concept we 5

went into on the backfit was to backfit those things which 6 we could not comfortably determine from the records that 7 had been properly inspected.

8 If I am faced with a totally complete and 9 believable record, then I very likely might not backfit that 10 particular area.

11 What I really think has happened is that for 13 various and sundry reasons the people under Brandt decided 13 it was easier to backfit than try to review the records. I 14 suspect I got redundant records.

15 0 I see. Well, it is my understanding in my 16 inquiries prior to our' meeting today that initially, following 17 that Notice of Violation, Mike Foote and R'ichard Cummings 18 performed a review of those old records and did some mapping 19 that related to " sat" versus "unsat" records.

20 A That's correct.

21 And that later on, I think, Brandt was also Q

22 involved in that. Then, later on, Neil Britton took over

%3

.a similar review in which he made a log and mapped also as 24 to whether areas were " sat" or "unsat" according to the 25 records that existed.

I

. 1< My question to you is, die . se areas that were 2

mapped as having satisfactory documentation, were they 3 indluded in the backfit?

'4 A They may or may not have been. That's why I said 5 what I did earliei.

I think there is a possibility of 6

redundant records.<

7 Q But as far as you know, they were not systematically 8

removed from the backfit in that a determination had been

~

9 made by somebody -- Britton or whoever -- that adequate 10 documentation existed.

11 A The p,rogram, the way it was. set up,'certainly 12 permitted that. There is.nothing wrong with that. Whether 13 or not they ac'tually did that, I am getting conflicting 14

~

input from a lot of different directions that leads me back-15 to where I have said a minute ago, I,think I have both 16 efforts going on simultaneously. I have the mapping effort 17 going on at the same time I have a field force out there 18 slapping dollies on the wall and running scratch tests.

19 0 Well, the reason I asked the question is because 20 in that I have been looking at those old records. One of 21 the questions I need, that I am looking for the answer to, 22 is as to whether those records are going to be used for any 23 purpose other than historical purposes. Whether they are 24 going to be used to represent inspections that have occurred 25 and attach to the conditions and sufficiency -- or whatever

1 4'

1 i i

i the proper terninology would _ -- as to the pain: O.at was 2 applied.

3 A I don't know myself right now which way they are 4 going. I don't plan to throw anything away.

5 If the records can ae comfortably tied to a civen 6

area and we have confidence that there has been no other 7

work activity that causes those records to be invalid, then 8

I would have no reservations to consider them a part of the 9

protective coating formal records that eventually get 10 , transferred to operations.

11 At tlis point in- time , I have not been asked to 12 make the decision nor have I had the time to pursue it to 13 that degree of detail.

14 0 Well, are any of your subordinates involved in a 15 review, current review, of these records to see if any of them 16 meet --

17 A Britton is doing some sorting work back there for 18 me right now which is largely the result of a question that 19 the resident asked. We have a pretty heavy effort to satisfy N ourselves that we have identified anything that was "unsat." ,

21 It'may well be that some of those older records may 23 be picked up in that review.

23 Q Again, it is my understanding that Britton has 24 already done a comprehensive review.

I am looking at a log 4 that he has done. Some inquiries I was making indicate that

45

'l -he has -- I fcrgi.* .e-number, but 3 , ? C' c r s eme .e. o r e . ar c=.d .

2 He mapped these areas and also mapped them in his log as 3 " sat" or "unsat. " ,

i 4

Are you saying that you are having'to go back over 5

this same material again-to give it a more ' critical -- 1 6 A About.two r three weeks ago, as a result of some 7

overall restriction in the paper management with him, I

}

8 found a cardboard box full of coating records, okay, and 8

calmly but positively caused somebody to get with it and tell 10 me what in the world is going on.

11 I no believe that I have captured all of the 12 official, unofficial, incomplete or otherwise existing

.' 13 documentation on coatings and we are. sorting through that 14 right now, again to satisfy myself that any "unsat" conditions 15 that need to be resolved have been identified.

16 0 And in consideration of Britton's efforts 17 previously, in his log that identified various documents as 18

" sat" or "unsat," are those that he identified as " sat" 19 going to be used or do you anticipate their use as quality 20 documents?

21 A They may be. Again, you are asking me a detailed' 22 question that I don't have first-hand knowledge on. .But I 23 l

do know that they put unique identifying numbers on a number 24

7. .

of those records. I would assume that the only reason for i s 25 i

them doing that is that in their judgment they felt the I

i

g ..

,I 46 i

11 documentation .was adequate and therefore shou d: .:

2 incorporated into a record system.

3 So, those that you find with numbers, and I think 4

most of those I have seen, preceded by the letters "PC"

'6 would in fact .be incorporated as part of the permanent plant .

6 records.

7 Q Many of those records that are reviewed referenced 8 NCRs. Does the referencing of an NCR indicate that they are 9 unsatisfactory?

10 A In today's' usage, no. What was going on back in 11 those days, I would have to go look at specific records to be 12 able to answer that question. Normally, not. In other 13 words, normally the NCR stands on itself and the record '

14 that in essence led up to the NCR closes.

15 l Q Well, if you took a random sampling in the vault 16 of the OPC records and you pulled one out and it references-17 an NCR on the records, NCR and the number, does that referenci lg 18 of ,the NCR on that particular document render that document 19

" sat" or "unsat," or does it tell you one way or the other?

20 A Probably " sat," but you would have to pull the 31 NCR and answer that question because all you are doing is, 22 you make a cross-reference mainly with the check list and 23 i .the NCR.

24

{ O Okay, then what would you rely on to determine wheth er l

25 a document was satisf actory for the purposes of possibly i

l

_ _ ~ _ . - _ _ . . _ _ . , _ . _ . .. . _ . . . _ . , . _ _ . _ . . . ~ . ,_._ _ ,_. . _ _ , _ . _ _ . _ . . . _ _ . _ _ . .

~1 ]

47 i

.t

.1 (

..::ng it attest the paint in cens16efation of ycur on going .{

2 program? '

i 3 A The incorporation of a PC number written at all, 4

l cn: whoever was charged;with that, and the receipt of that 5

record in the vault and indexing it into the computer

.6 system is all it takes.

7 Okay.

Q Now, many of the records that I have reviewed 8

involved and did reference NCRs and did contain these PC 9

numbers,'were incomplete..

10 A Did you pull the NCR?

11 Q No. -

12 A You have to pul'1 the NCR to be able to understand 13 what they are trying to say. ,

Without looking, it is very 14

.. likely that the NCR numbers that are referenced on those 15 records are.the generic NCRs that we wrote against the 16 incomplete documents.

17 Q Well', now, I have reviewed it to that degree. Yes, 18 they are.

19 A Then those records are of no value to you.

20 Q And the ones that do not reference the NCRs may .

21 be something that can be used?

M A Possibly.

23 Q Okay. Do you anticipate that the records that you-f s'

24 will use will among other things meet ANSI standards?

I

! 15 A Yes.

t l

_ _ _ . _ . - . . . _ _ . , _ . ~ . _ _ _ . _ , _ . _ _ _ _ . . . . _ , _ _ . _ _ _ _ _ . _ , _ . _ . _ . . _ . . . . . _ , __ .. . . _ . , , _ . , , , . . - . . , _ , .

,(

li 48 r i 1- !; O Do you anticipate relying on Britton's already

, i 2-

-accomplished review and his- log to deternine which ' records 3 may be'ased?

4 A 1.will rely on Mr. Britton subject to overview 5

through the audit program. ,

6 0- Let me touch on another subject.

7 Does the phrase or term " corrective action program" 8

mean anything to you?

8 A Sure ,- it 's a requirement of Appendix B .

10 0 Do you have any other usage that you have made 11 or invented that relates to problems with employees?

12 A I have a humorous tale that I have limited to the 13 people that report directly .to me which is four or five senior- -

14 level people,that I have humorously captioned a " Built-In --

15 Correction Program."

16 They understand that, have no problem with it. It 17 is nothing more than what I consider to be good common 18 sense. I have worked very hard to select capable people to 19 report directly to me so that I have a competent individual 20 that I can delegate the various and sundry work activities 21 to which I obviously could not possibly handle by myself --

22 such as procedure, certification reviews, and responses to 23

-audit reports, responses to this, that, and the other.

24 The humorous tale I use with the senicr guys is, i

25 "Look at it this way, fellows, if this scheme doesn't work,

i

' l 49 I at least I've g:: buli: in one more corrective actic.- I can 2 take with the Commission."

3 If I did all this, then I don't have any other 4 built-in corrective action. Again, it's "HL, my gcod friend 5 Atchison has decided t'o make an issue out of it. He has 6 'never heard it direct from me, nor has any inspector at 7 Comanche Peak.

8 Q Along with the phrasing " Corrective Action Report" 9 used in this sense, are your instructions or is the under-10 standing that you hoped to communicate to the inspectors to 11 do what you say or you'll be fired?

12 A Never. .

13 Q Even jokingly?

14 A Not even jokingly.

15 0 And this is not what has been put to your 16 immediate subordinates in supervision?

17 A The thing that we try to do, I have tried to do my 18 entire career, is to create confidence amont my subordinates 19 in terms of confidence as well as dedication and diligence m to do their job properly, where they take the responsibility 21 for doing it that way.

22 That has never been intended for anything cther 23 than that. It is no different than what is expected of me.

24 All I am trying to do is develop that reason, logic, r

5'

%5 competence that people had to have to be senior, and do the

l 50 j i

1 ' job r ght the firs. time.

2

.MR. GRIFFIN: I think he only has a few questions.

3 I think we are finished with this phase.

4 BY MR. DRISKILL:

5 Q Mr. Griffin asked you a question a little bit. ,

6 earlier on regarding how "unsats" on irs are resolved, and 7

you answered "In three ways."

8 A I believe what I said was at .least two, and 9 possibly three.

10 0 Okay. Well, one of your answers was to transfer il the "unsat" characteristics on the report or information on IE there to an NCR.

13 A That's correct.

14 0 I would like to ask you, who is responisible for 15 doing this?

16 A Well, I am ultimately responsible for anything 17 that happens. But my senior people like Mr. Brandt certainly 18 have the authority -- I'm not sure it's a responsibility --

19 but the authority to close an inspection report in that way, N if in thair judgment that's appropriate and consistent with 21 our cha'rter under Appendix B.

22 O Another area that I would like to clarify. There

^

U -was some discussion going on a few minutes ago that had to 24 do with hiring new QC inspectors in quality coatings, and 25 you indigated that you have 35 crews, paint crews, and you I

L .. 1 t  :; l i l 1 j need additional. people because you are currentiv concentratinc 2 your efforts on Unit 1; is that correct?

3 A Yes.

4 Q I want to ask you, is .there any coatings work-5 going on in Unit 27

,, 6 A Yes, there is.' .

7- Q There is. And are there coatings inspections 8 going on?

9 A Yes, there are..

10 Q Okay. Another area. One of'the r,esponses you 11 gave to a quest, ion -- and I don't recall specifically what 12 the question was -- you made the statement that an  ;

a 13 indeterminate condition typically gets an NCR written.

14 A That's correct.  ;

15 Q That goes back to the firs t question. Whose 16 responsibility is it to see that an NCR gets written with 17 respect to these indeterminate conditions?

18 A The same answer, I think , applies , that I am 19 ultimately responsible, but my senior people typically take 20 the lead and see that it gets done.

21 Q And do the inspectors have the right to write an ,

22 ~ inspection report when they identify a condition which is e

2 considered indeterminate?

i 24 A Did you mean inspection report or NCR?

M Q I am talking about an NCR. ,

I:

i 1  ;. Yes, they certainly have that-authcrit ;.

2 o Just one other area and'I don't know how much you 3 'might really know about'it. One of your quotes was, with '

4 respect to one of the questions that Brooks asked was, 5

aputting' dollies on the wall and conducting scratch tepts." .

6 I wanted to ask you ab'out the scratch test because 7

it was something that came up a long time ago and it just 8- clicked something in my mind.

9 '

Has that, as far as you know, been a standard 10 test that has been used here for a long time, or since the 11 coatings program began? -

12 A No, it's only required -- the proper term is 13 "tooke gauge." It is only required when you have some reason 1

14 you want to go back and neasure primer thickness and top coat 15 thickness.

16 Q Would you describe how that test is performed?

17 A I have never run one, but I will do my best. It 18 is some kind of a small -- I would presume -- device where 19 you can scratch the coatings down to the base mAtal and a 20 lighted boroscope or micrometer-type device where you can ,,

. 21 distinguish ' primer thickness from top coat thickness, and 22 measure to a certain degree of precision both.

23 '

O Well, I will say that I may have misunderstood 24 what a scratch test was. -I was going back and thinking about-25 an explanation somebody was giving me about taking like a

'N

l  !

I E2 I

1 pocket knife and cutting an ":' _r. a coat of paint. '

2 A That sounds like willful damage to coatings.

3 (Laughter.)

4 THE WITNESS: It could be that a picket knife is 5 used to get the scratch. I don't know, I am not that 6 familiar with the technique.

7 MR. DRISKILL: I have no further questions.

8 BY MR. GRIFFIN:

9 Q Mr. Tolson, have I or any other NRC representative 10 here threatened you in any manner, offered you any rewards 11 in return for this statement?

12 A No, sir.

13 Q Have you given this statement freely and 14 voluntarily?

15 A I was asked to appear, and I am here.

16 Q Okay. For the purposes of this phase of the 17 inquiry, is there anything further that you would care to add 18 to the record?

19 A Not at this time, no, sir.

20 MR. GRIFFIN: Thank you.

21 (Whereupon, at 11:50 a.m., the interview in the 22 above-entitled matter was closed.)

23 24 25

\

l l

CERT 1rICATE OF PROCEEDINGS 2

3 This is to certify tnat toe attached proceedings of the 4

Interview of RONALD G. TOLSON before the Office of 5

Investigations at Texas Utility Generating Company, 6

Comanche Peak Steam Electric Station, Glen Rose, Texas 76043, on Friday, December 2, 1983, commencing at 10:20 8

a.m., was held as'herein appears, and tnat this is the 9

original transcript for the files of the Office of 10 Investigations, Region IV.

Il 12 s

I3 Mary C. Simons 14 15 Official Reporter - Ty. ped 16 17

_----_d ff h -_--___--

I8 Official Reporter - Signature 19 20 21 o,

2.3 21 25 TAYLOE ASSOCIATES 1625 I STALET, N.W. - SUITE 1004 1 WA5HINGTON, D.C. 20006 (202) 293 3950 r r +- - - - -i,-

l f I .

i  ;

1 TABLE 07 CO::TT' ;-

2 WITNESS: EXIO!INATION BY MR. GRIFFIN: MR. DRISKILL 3

Ronald G. Tolson 3 50 4

53 5

6 7

8 9

10 11 .,

12 13 14 15 16 17 18 19 80 21 22 23 24 25