ML20134K502
| ML20134K502 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/24/1995 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20134K135 | List: |
| References | |
| FOIA-96-351 NUDOCS 9702140058 | |
| Download: ML20134K502 (136) | |
Text
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ATTACHMENT 11 UNITED STATES NUCLEAR REGULATORY COMMISSION I REGION I IN RE: PUBLIC SERVICE ELECTRIC AND GAS CO.
SALEM GENERATING STATION-CALVIN VONDRA An Enforcement Conference was held at the offices of the United States Nuclear Regulatory Commission, Region 1, 475 Allendale Road, King of Prussia, Pennsylvania, on Friday, February 24, 1995, commencing at or about 10:00 A.M., before Carol L. Skipper, Court Reporter and Notary Public for the Commonwealth of Pennsylvania.
PRESENT:
JOHN WHITE DANIEL HOLODY, ENFORCEMENT OFFICER WAYNE LANNING, DEPUTY DIRECTOR 1 DIVISION OF REACTOR PROJECTS KARLA SMITH, ESQUIRE, REGIONAL COUNSEL LENNY OLSHAN MARK J. WETTERHAHN, ESQUIRE FOR CALVIN VONDRA l
l OR G A A_
9702140058 970211 PDR FOIA DNEILL96-351 PDR ALL POINTS REPORTING (215) 564-5380
2
. 1 MR. WHITE: Good morning Mr. Wetterhahn k
2 and Mr. Vondra. Thank you very much for making 3 yourself available for this Enforcement 4 Conference. We understand it is an imposition, 5 and we do appreciate your time here.
6 This Enforcement Conference is being 7 held by the NRC to review and assess the 8 circumstances of an alleged harassment and 9 intimidation of two PSE&G employees.
10 Specifically on December 3rd, 1992 two 11 SRG Engineers attempted to process a safety issue 12 in accordance with the station procedures by 13 submitting an Incident Report to you, Mr. Vondra, 14 the General Manager of Salem Operations at the 15 time, and tna Operations Manager, Mr. Polizzi.
i 16 The Incident Report questioned the safety related l
17 qualification of commercial grade air supply 18 pressure setpoint regulators which contro rface 19 water flow to the containment fan cooling units.
20 Conversations with SRG engineers; Mr. Vondra 21 essentially told the individuals to get out of his 22 office and threatened to have them removed from 23 his site, an action that was interpreted by these l 24 SRG engineers as harassing and intimidating. Upon j l
l ALL POINTS REPORTING (215) 564-5380
. 3 1 deliberation Mr. Vondra wrote a memorandum to the
(
2 General Manager of Quality Assurance Nuclear 3 Safety Review requesting to have the engineers 4 removed from any direct involvement with the Salem 5 station. Subsequently at the time we believe that 6 further discriminating action may have taken place 7 being directed against the individuals when the 8 General Manager of Quality Assurance Nuclear 9 Safety Review may have took action to reprimand or 10 counsel the SRG engineers relative to their 11 submittal of the Incident Report and their 12 handling of that situation. In conclusion, the 13 NRC investigation determined'information that 14 appears to support the finding that the SRG 15 engineers were harassed and intimidated by various l l
16 actions directed or taken by yourself and perhaps l l
17 other senior managers at Salem station. In '
18 accordance with our policy we are affording you an 19 opportunity to discuss these issues with us, to 20 provide your perceptions, and describe to us your j i
21 motivations on that day and your perception of the 22 incidents that occurred, why they occurred, and 23 provide us other information that we can use to 1
24 assess the significance of this violation and to l 4
l ALL POINTS RELsRTING (215) 564-5380
4 1 come to a conclusion relative to enforcement, if 2 that is required in this case.
3 With us at this' conference representing 4 the NRC is Mr. Daniel Holody, Enforcement 5 Coordinator for NRC Region 1, Mr. Wayne Lanning, 6 Deputy Director Division of Reactor Projects, Mr.
7 Lenny Olshan, Project Manager, NRR, Karla Smith, 8 Regional Counsel for Region I, and I'm John White, 9 Second Chief Division Reactor Projects.
10 With that, Mr. Vondra, I would like to 11 turn it over to you, and you can take it at any 12 point you want to, and what we are interested in 13 is what your perception is and what your 14 motivations were relative to this particular 15 occurrence.
16 MR. WETTERHAHN: Before we begin, let 17 me identify myself. For the record, my name is 18 Mark J. Wetterhahn, I'm an attorney with Winston 19 and Strahn in Washington D.C. and I am here today 20 representing Mr. Vondra. i i
21 MR. HOLODY: Just one other point ,
l 22 before we start. We did have a ecnference 23 approximately two weeks ago with PSE&G relative to 24 these issues with two other individuals. John ALL POINTS REPORTING (215) 564-5380
5 1 went over the findings, which were basically the 2 findings of ORI, which we provided you a copy of.
3 We also have the PSE&G investigation. Basically 4 we are looking to hear from you today. Those 5 three pieces of the puzzle will go into our 6 determination, what action we think is warranted 7 with respect to you as an individual, whether we 8 take action. The particular options that are 9 available to us I'll go over at the conclusion of 10 the conference.
11 MR. WETTERHAHN: Mr. Vondra was not 12 present, as you know, at the Enforcement j l
13 Conference for the company, so if you have a ,
l 14 question based upon that transcript I would ask 15 that you read that section of the transcript and I
16 allow him to comment on it. Okay. j l
17 MR. HOLODY: Thank you.
18 MR. VONDRA: Good morning, my name is 19 Calvin Vondra. I want to thank the Board here for 20 the opportunity to come before it and tell you i 21 what I know and what my involvement was in the 22 incident of December 3rd, 1992. I would like to 23 take a minute and tell you a little bit about 24 myself. I have been in commercial nuclear power i ALL POINTS REPORTING (215) 564-5380
6 1 since 1971. Before that I was in U.S. Navy 2 Nuclear Power Program as an electronics 3 technician. When I got out of the Navy, I went to 4 Iowa Electric Light and Power and worked my way up 5 through shift supervisor while going to night 6 school. I went to Public Service Indiana and 7 worked for a power plant called Marble Hill, which 8 was lat6r terminated, as the operations Manager.
9 I completed my degree in Nuclear Engineering 10 Technology. I came to PSE&G in 1984 as the 11 Operating Engineer for Hope Creek. I took Hope 12 Creek through the construction start-up and 13 testing in that role, and then when we went into 14 operations I was the Operations Manager. I left 15 PSE&G and went to TVA and was the plant manager of 16 Sequoia for about two years, when I was informed 17 that PSE&G would be interested in talking to me ,
R 18 about being back at Salem. We discussed that. I 19 took the job at Salem on March 30th, 1991, and was 20 in that role until February of 199^.
21 Regarding the incident, I would like to ,
1 i
22 make a couple of statements at the onset, okay. I !
l 23 am responsible for having lost my temper during 24 this incident, and I accept that responsibility.
1 ALL POINTS REPORTING (215) 564-5380 1
l
7 1 I am responsible for having allowed this incident 2 to leave my office not being completely resolved, 3 and I accept that responsibility. However, it was 4 always my intent to comply with our procedures, 5 and to the best of my ability during this time I 6 was trying to implement the procedures as I 7 understood them and how they had been employed in 8 the past. It was never my intent to stifle the 9 submission of a safety concern. It was never my 10 intent to harass and intimidate these individuals.
11 My knowledge of 50.7 at this time was that it was 12 an act, and my only knowledge came from our annual 13 training that we had and briefly talked about 50.7 14 as an act designed to protect people that brought 15 issues to the NRC and were subsequently harassed 16 after bringing those issues to the NRC. I never 17 felt that I was in a 50.7 situation at that time 18 nor did I have any more understanding of the law 19 at that time. I gained knowledge subsequent to 20 this time period about the effects of 50.7 on
. 21 management and chilling and some other things that 22 I did not know about. I thought we were in an 23 issue of behavior and normal company discipline 24 not in an issue of harassment and intimidation.
ALL POINTS REPORTING (215) 564-5380
l L 8 1 I have accepted responsibility for my 2 actions. I have been disciplined by my company 3 for losing my temper to the point that I was told 4 shortly after this event that it was felt
- hat I 5 could no longer be effective as the General 6 Manager and would be replaced in the near term. I 7 was replaced and demoted four pay grades. I did 8 apologize to Mr. Williams and to Mr. Craig, and 9 that is a sincere apology, and I mean that. I 10 also talked to all of the managers in the nuclear 11 department about what occurred and what my role in 12 it was and what I could have done and should have 13 done differently. I was given final step of our 14 positive discipline program, which is a final 15 written letter in lieu of termination, where I had 16 to develop a plan where I was going to make 17 changes, and convince the senior management of the 18 company that that plan was indeed appropriate and 19 meaningful, and I completed all of those 20 requirements. So I think that I have taken this 21 extremely serious, and I think I have had serious 22 consequences as a result of this.
23 Now I would like to tell you to the 24 best of my recollection what occurred on December ALL POINTS REPORTING (215) 564-5380
9 !
1 3rd.
( 2 MR. HOLODY: Before you do that, what i
3 is your current position in the company? I l
4 MR. VONDRA: My current position is !
5 Southern Regional Manager of Fossil.
6 MR. HOLODY: And you are located where? l i
7 MR. VONDRA: I'm located out of Mercer i e
8 Generating Station. !
t 9 MR. HOLODY: And that is where? :
10 MR. VONDRA: That is in Trenton, New '
11 Jersey.
l 12 MR. HOLODY: Okay. l 1
13 MR. VONDRA: On December 3rd, it was a j l
14 day that I had just received the results of our 15 Impo evaluation, the actual findings and i 16 description of how they were going to be presented 1 l
17 on the 4th to senior company management. I was in i 18 the process of preparing my responses to those as 19 I was going to be the key speaker at that meeting 20 on behalf of the company. I also needed to have 21 those responses done by 4 o' clock.to go over them 22 with my vice-president as a practice run for the 23 next day. I would say that I was under a lot of 24 stress to get this done and that the results of ALL POINTS REPORTING (215) 564-5380
10 1 the findings were not what I would like them to 2 have been. Salem Plant, since the beginning of 3 Impo has been rated a three, and I was hoping that 4 we had made enough progress to have moved to a two 5 but the tone of the findings was that we were not 6 going to get that. While I was doing this I got a 7 phone call from my Operations Manager Vince 8 Polizzi. He seemed very upset that he had a 9 problem that two people were trying to shut down 10 both units, and he had tried to deal with it and 11 he needed to come and talk to me. I felt that I 12 had to do that.
13 MR. WHITE: Is that the way he phrased 4 it, two people were trying to shut down both 15 units?
16 MR. VONDRA: Yes. In a few minutes he 17 walked into my office and closed the door and 18 commenced to brief me about his understanding of 19 the events. There were people out in the waiting 20 room to my office. I don't know who they were at 21 that time or much about this event. He came in, 22 and the reason that I wanted him to brief me is I 23 have not always agreed with Vince on how we 24 handled things, and I wasn't sure where he was and ALL POINTS REPORTING (215) 564-5380
)
11 1 what he was doing. I wanted to hear what he had !
( l 2 to say before we confronted another group of 3 people.
4 MR. WHITE: Was this an unusual 5 situation to be handled in this way?
6 MR. VONDRA: Yes. It was the first --
7 I mean at this time I didn't even know it was an 8 Incident Report thing. I just knew that there was 9 a problem concerning shutting down of the plant so 10 yes, it was very unusual. However, I was about to 11 find out what Vince knew. What he told me was 12 that an Incident Report had been taken to the i
13 Senior Shift Supervisor's office and that Mario l
14 Caventaros indicated that he was unable with the 15 information on that to make the decision that he I
l 16 needed to make, and he sent them on to Operations !
17 Management to get that information.
18 MR. WHITE: When you said that, what 19 does that mean, how did you --
20 MR. VONDRA: What I thought that meant 21 was that an Incident Report had been submitted to 22 the Senior Shift Supervisor.
23 MR. WHITE: Which is normal policy?
24 MR. VONDRA: Yes, which is way you ALL POINTS REPORTING (215) 564-5380
12 1 normally do that and that is in accordance with 2 NAP 6, there is a statement in there that talks 3 about if the Shift Supervisor:is unable to make a 4 reportability, and in this case it would be 5 operability determination.
6 MR. WHITE. Is that the responsibility 7 of the Shift Supervisor to make that 8 determination?
9 MR. VONDRA: With appropriate 10 information, yes. So, what the procedure says is 11 that if he's unable to do that he can ask for help 12 to get more information, and so I thought we were 13 in the mode of collecting additional information 14 to help the Shift Supervisor make the correct 15 operability report and decision, and that is the 16 way it was presented to me. What Vince then told 17 me was that he had contacted Mike Maroney about 18 these regulators. He told me what the regulators 19 did and that these regulators control the dampers 20 on containment fan coil units, and that they had 21 been tested through our surveillance test and all 22 modes satisfactory and that they were indeed 23 operating correctly. He told me that he had 24 contacted Mike Maroney and Mike Maroney had looked ALL POINTS REPORTING (215) 564-5380
)
I 13 1 up in the FSAR that these components were known i 2 not to be safety related but were engineeringly 3 determined to be appropriate devices for their 4 use. He also told me that he contacted Jay Bailey 5 and Jay Bailey had indicated that he believed 6 documentation was in place to confirm the seismic 7 installation of those relays.
8 - - -
9 ( Mr. Holody returned to the room. )
10 - - -
11 MR. VONDRA: Then he told me that he 12 had conveyed this information to these two 13 engineers and had asked them to put it on an 14 Incident Report, and that they had refused to do 15 that. And so I felt at that time that something 16 was wrong, but that this was going to be very easy ,
17 to take care of. We had a lot of information and 18 the motivation to accept this and do the right 19 thing was there. I felt this would be easy to 20 take care of and resolve. So--
. 21 MR. LANNING: Just a question. Is this 22 a second Incident Report that you thought or the 23 same one?
24 MR. VONDRA: No, this is the original ALL POINTS REPORTING (215) 564-5380
14 1 Incident Report. By the way, I had never seen the 2 Incident Report until two weeks ago.
3 MR. LANNING: Is it normal that you 4 update an Incident Report?
5 MR. VONDRA: If the information on it, 6 okay if you have additional facts, okay, that 7 would clarify the decision process for the shift 8 supervisor, yes, you would try and make it 9 complete and accurate.
10 MR. LANNING: And the submitters, ones 11 who originate the Incident Report, would be the 12 ones that would do that?
13 MR. VONDRA: It doesn't really say who 14 would do that. It implies that you go to the 15 Incident Report Coordinator, but that is an 16 administrative function that doesn't really have 17 technical knowledge. You would go to the 18 engineering group or the right people to get that J
19 information. It became apparent -- I can get to 20 that, sir. It became apparent when people came in 21 my office there was something else to this issue 22 besides submitting an Incident Report. At Salem 23 station on an annual basis we have submitted 800 24 to 1200 Incident Reports a year. Of that number ALL POINTS REPORTING (215) 564-5380
15 1 about 50 of them are configuration type issues 2 that result in the Incident Report is actually 3 voided and a DEF is filled out by the Incident 4 Report Coordinator and sent to Engineering because 5 that type of an event is not considered an off 6 normal event, and that is why they are voided and 7 turned into DEF's. And that is the process. I 8 have documentation to show that, and the number 9 was indeed about 40 to 50 that year based on a 10 quality assurance audit.
11 Anyhow, at that point I felt Vince had 12 told me what he was going to tell me, I invited 13 the rest of the people in my office and felt 14 confident that we were going to be able to resolve 15 this issue, and I want to tell you I didn't know 16 whether or not it would result in a shut down or 17 not eventually. It doesn't matter to me. What 18 matters is that the issue be accepted, 19 investigated, and acted on.
20 MR. WHITE: Did Mr. Polizzi in his 21 conversations with you privately -- Did you ask to 22 meet with him privately before?
23 MR. VONDRA: No, he walked into my 24 office and closed the door.
l ALL POINTS REPORTING (215) 564-5380
16 1 MR. WHITE: Did he express an opinion 1
(
2 to you, do you think he biased you in any way l
3 relative to your assessment of this particular l l
4 case?
l 5 MR. VONDRA: I had the impression from 6 Vince that something was going on here with these 7 folks, that they were -- This was very unusual 8 okay, and it was like that they were trying to do 9 some special auditing ongoing of an Incident 10 Report in progress and in compliance verbatim with 11 the procedures, which should not be done. An 12 Incident Report should be given to the Senior 13 Nuclear Shift Supervisor. The person lets go of 14 it in the process and then takes steps, but this 15 was very unusual, and it is the only one in my ten 16 years at PSE&G that I have seen, and I have been 17 involved with a bunch of them at Hope Creek and a 18 bunch of them at Salem station, and it is the only 19 one I've seen like this. It is the only one. And 20 every station in the country has an Incident 21 Report system. It is the only one I have ever 22 seen in 24 years of commercial nuclear power that 23 ends up in a General Manager's office like this, 24 so it is extremely rare that this happened.
ALL POINTS REPORTING (215) 564-5380
17 1 MR. WHITE: I don't want to derail you 2 from where you are going with this, but why do you 3 think that is? Why is this one different? It 4 seems to us that as you just described it very 5 straight forward this guy is writing this report, 6 ship it down to the shift supervisor's office, 7 there is a process for handling that. Why was 8 this one different than that; why was this one 9 handled differently than that?
10 MR. VONDRA: It appeared to me that for 11 some reason the Safety Engineers were not willing 12 to leave control of this go to the system, that 13 they were trying to push for something different, 14 and I couldn't get that out.
15 Let me go through, and I think you will 16 understand.
17 MR. WHITE: Sure.
18 MR. VONDRA: Anyhow, I invited 19 everybody into my room. Who came in was Burt 20 Williams, Paul Craig, and Jay Bailey. Burt 21 Williams I didn't know at all. I mean I saw 1'm.
22 I can tell you that is Burt Williams, but I never 23 dealt with him on any issue previous to the time
. 24 he showed up in my office for this. He was on ALL POINTS REPORTING (215) 564-5380
i 18 I
1 temporary assignment to the SRG, and I did not 2 know him from his past jobs in the company. Paul i
3 Craig I knew. He was a member of the Salem Safety 4 Review Group and we had, he had been an alternate 5 to SORC on many occasions, and so I knew him from t
6 that association there. I found him to be a 7 person who was very good at details, who pushed 8 issues quite a ways, but who was a reasonable 9 person to deal with was how I felt about Paul.
10 Jay Bailey was the head of our Engineering 11 Sciences Group. That is the group who would make 12 a determination on the seismic analysis of the 13 components and their suitability for use, and 14 their function as well.
15 What I did, I've known Jay Bailey for 16 quite a while as well, in years, nud what I did l 17 then was ask Burt and Paul to tell me what was 18 going on in their words, and they indicated that 19 they had received a report from HPES that these 1
20 regulators were in a safety related function but j l
21 were not manufactured safety related, and that ;
1 22 there was a concern for whether or not they would 23 function properly and whether or not they were 24 seismically qualified. At no time during the time ;
i 1
ALL POINTS REPORTING (215) 564-5380 l
19 1 in my office was anything brought up on 2 configuration. However, I had the feeling it had 3 been brought up in Vince's office because he took 4 the time to tell me about the surveillance reports 5 that were done, and that the things were 6 functioning, which meant that the piping had to be 7 set up right for them to do that.
8 MR. WHITE: So, as you understood from 9 Vince their finding was also that the 10 configuration, the piping, plumbing for these 11 things was different?
12 MR. VONDRA: When they tested them for 13 the surveillance test, I don't know if they're 14 different modes, they worked.
15 MR. WHITE: But the finding that Vince 16 understood from the SRG engineers was that the 17 configuration, the way that the piping was 18 established, was different than some design or the 19 specification?
20 MR. VONDRA: No.
, 21 MR. WHITE: Okay. So what do you mean 22 by configuration?
23 MR. VONDRA: That is what I mean. I 24 meant in my office, okay, Vince took the time to ALL POINTS REPORTING (215) 564-5380
20 I tell me that the surveillance was run so that
( these components would function in as best of the 4
2 3 conditions as we were able to simulate for test 4 and that they did indeed pass those tests, so he 5 was telling me that the piping configuration for 6 these regulators was such that it would work, so I 7 thought configuration was an issue, but it was 8 n.ever bought up in my office. I'll cover the 9 issue of configuration later in the day though.
10 What came out in my office with the 11 folks, all of the people in the room, was that an 12 Incident Report was generated from an HPES report. )
13 There was a concern about these things not being !
14 safety related, when they should be, and there was I
15 a concern about them not being seismically l 16 qualified as well.
17 I asked if the engineers were aware 18 that they were listed in the FSAR as having been 19 qualified for their function for safety related 20 use, and they indicated that they were with Mike 21 Maroney when he looked that up and that they knew i i
I asked if they were aware that our 22 about that.
23 engineering science group, Jay Bailey, believed 24 that they had documentation available to show that .
l ALL POINTS REPORTING (215) 564-5380 -
qh
I l
. 21 l
1 they were seismically mounted and q"alified, and 2 they indicated that they knew that. And I said 3 well, then if you know that why can't that be on 4 the Incident Report? And they felt that the 5 Incident Report should be delivered as it was 6 written to the Senior Shift Supervisor and he 7 should act on it based on that, and I thought it 8 already had been delivered to him, and he said he 9 couldn't act on that he needed more information.
10 MR. WHITE: So you thought the Incident 11 Report had already been delivered?
12 MR. VONDRA: That is the process, yes, 13 and they told me they had been to Cafanteros so I 14 thought they had been there with an Incident 15 Report. That is the process, so I thought we were 16 a little further into the Incident Report 17 procedure trying to get the right information to 18 make a reportability decision, and in this case 19 reportability would be determined by operability.
20 If the components were operable, then there would 21 be no report, and if they were inoperable there 22 would be a report. And if they were inoperable 23 there would be a shut down of both units, but that 24 was okay.
ALL POINTS REPORTING (215) 564-5380
22 1 MR. WHITE: But again, that type of 2 decision making is Operations?
3 MR. VONDRA: Absolutely.
4 MR. WHITE: Not the SRG's jurisdiction?
5 MR. VONDRA: I'm not aware until I read 6 the final investigation two weeks ago that anybody 7 was asking the SRG to make an operability 8 determination, only to put all of the known facts 9 on the Incident Report.
10 MR. HOLODY: So what facts would you 11 have wanted on that report?
12 MR. VONDRA: That there was a question 13 about the safety relatedness of the components, 14 that there is a question of the configuration, and 15 there is a question of the seismic qualification 16 of those components, and that, okay, the FSAR 17 indicated that they were looked at for safety l
18 related, that the engineering sciences group '
19 believed that they had documentation for the i
20 seismic issue, and that the surveillance testing 21 showed that the components would work, okay.
l 22 MR. HOLODY: You went through two l 23 things there, one what the concerns were of the 24 SRG engineers, and then second the three pieces of
- 1 ll ALL POINTS REPORTING (215) 564-5380 I l
23 1 information that in your mind would have allowed I i
2 you to conclude that these components were
? operable?
4 MR. VONDRA: Actually I didn't care 5 whether it was a conclusion of operability or 6 inoperability in that it was facts that we knew 7 about these components that I thought was 8 necessary to make the decision.
9 MR. HOLODY: Were they facts that the 10 SRG's knew?
11 MR. VONDRA: They indicated to me yes 12 that they knew tnat.
13 MR. HOLODY. So they had met 14 individually with the three groups where they 15 looked at the FSAR, they met with the engineering 16 group?
17 MR. VONDRA: I know they had met with 18 Vince Polizzi. I know they had met with the 19 Senior Shift Supervisor, and I knew that they had 20 met with Mike Maroney. They walked into my office 21 with Jay Bailey of the Engineering Sciences Group, 22 so I thought they also had met with him, and when 23 I brought that issue up about seismic 24 qualification Jay Bailey was affirmative, and they ALL POINTS REPORTING (215) 564-5380
1 4 24 i
J 1 were there, so I think they knew that information. f 2
k ;
2 MR. WHITE: Was it essential in the ;
i
- 3 process for them to document anymore on that '
Ir i 4 Incident Report than what they already had j
3 5 documented? ,
i i 6 MR. VONDRA: No. They could have just f t
7 dropped that Incident Report off to the Senior j
- i 1 8 Shift Supervisor. Had they followed our l 1
9 procedures and turned that into the Senior Shift ;
10 Supervisor, those things would.have happened l
11 automatically.
4 12 MR. HOLODY: Didn't they go to see the
+
13 Senior Shift Supervisor and weren't they directed r i 14 to go see the Op Manager? l 15 MR. VONDRA: Because he needed more 1
) I e
j 16 information. I didn't think we were talking about i
! 17 accepting the Incident Report,- I thought we were t !
18 talking about getting the Incident Report to have
{ 19 the accurate information of the known facts at the
~
20 time. l 2
I 21 There was never any intent on my part l 22 not to work on this. In fact, you will find out
- 23 that I had asked Mike Maroney, actually told Mike
! 24 Maroney to do an investigation, and that night he ALL POINTS REPORTING (215) 564-5380
25 1 indeed walked down those panels and submitted 2 another Incident Report that the piping 3 configuration was wrong, and that Incident Report 4 had gone to Operations and an operability 5 determination was made that these components were 6 operable, and I couldn't go to bed until I knew 7 this was done and right. That night I got a 8 telephone call at 8:00 from Mike Maroney that he 9 had done this, and he walked them down and 10 submitted another Incident Report. If I had a 11 problem with putting in the first Incident Report, 12 why would I not have a problem with the second 13 Incident Report? I didn't have a problem with 14 putting that Incident Report in at all.
15 MR. WHITE: That is our problem.
16 MR. VONDRA: No problem, John, with 17 putting that Incident Report in at all. I thought 18 we were trying to get accurate information. What 19 happened then was --
20 MR. WHITE: By the way, at this point 21 what is your mood with them?
22 MR. VONDRA: I'm talking to them like I 23 am you.
24 MR. WHITE: So you are not angry?
ALL POINTS REPORTING (215) 564-5380
26 1 MR. VONDRA: I am not a violent person.
2 I don't move to anger quickly. I don't think you 3 will find too many people that see me angry.
4 MR. WHITE: What was Vince doing?
5 MR. VONDRA: Vince was listening.
6 MR. WHITE: Individuals were acting 7 professionally as far as you could tell in 8 explaining their basis?
9 MR. VONORA: Except unusual in that 10 they were confronted with information from manager 11 of our Technical Engineering Group of the station, 12 they were confronted with information from the 13 manager of the Engineering Science Group, and they 14 were unwilling to accept that information to put 15 those facts down. That was unusual.
16 MR. HOLODY: Was there some written 17 information they had gotten from each of those 18 individuals that would test the acceptability?
19 MR. VONDRA: No.
20 MR. HOLODY: It was basically they came 21 in, when they came into the plant and they first 22 approached the senior, the information that you 23 just indicated they were unwilling to put down, i
. 24 had they had the information at that time? l l
l ALL POINTS REPORTING (215) 564-5380 l l
l l
i i .
' i
. 27 j i
1 MR. VONDRA: I don't believe so. ,
l (' 2 MR. HOLODY: Who did they get that -
1 I
-3 information from?
I 4 MR. VONDRA: Mike Maroney showed them f 5 in the FSAR that information.
I 6 MR. HOLODY: That was done when?
I
. 7 MR. VONDRA: Sometime between then and l 8 when they showed up at Vince's office was my .
9 understanding. At the time they were in my ;
l !
i
! 10 office--
11' MR. HOLODY: They didn't get that. !
- i j 12 information from Vince? l l
l 13 MR. VONDRA: No, they got that i
l 14 information, to my knowledge, from Mike Maroney. !
4 15 MR. HOLODY: How about the other pieces .
16 of information?
I :
i 17 MR. VONDRA: They got that directly l 18 from Jay Bailey.
19 MR. HOLODY: Vince had that information i
i 20 also, correct?
21 MR. VONDRA: Yes.
22 MR. HOLODY: And you had that 23 information?
{
24 MR. VONDRA: No, I got it from Vince.
4 W
ALL POINTS REPORTING (215) 564-5380 I
s 28 i
1- MR. HOLODY: When they came ultimately 2 that day into your room and you had the discussion ;
3 with them, you then ultimately got that (
1 4 information? !
i
)i 5 MR. VONDRA: Yes, f i
I 6 MR. HOLODY: Okay, and there was a f
- i
! 7 concern that they were not willing or did not feel j 1
j 8 comfortable or whatever to put that information on !
4 9 this Incident Report? f
- l 10 MR. VONDRA: Nor would they let anyone l 11 else.
, s 12 MR. HOLODY: They could have gone back j l
l 13 down to the shift supervisor and followed that j
- t
, 14 procedure, could they not, and handed that r
15 Incident Report to the shift supervisor? !
1 16 MR. VONDRA: I thought they had done !
- - 17 that already. I don't know why they didn't. If f 18 you follow our procedure, you fill out the j i
~
19 Incident Report. There is electricians and f 20 custodians, and all kind of folks in the nuclear i
21 plant with different levels of knowledge. I don't
- 22 expect a custodian to know the intricacies of l
- 23 engineering decisions, so he would fill it out to {
24 the-best of his ability to be complete and ALL POINTS REPORTING (215) 564-5380 L :
29 1 accurate and give it to the shift supervisor, and 2 then we would go forward and get the rest of the 3 information and complete the investigation and 4 take the action.
5 MR. HOLODY: How would this be 6 different if the custodian, the janitor, anybody 7 had somehow raised a concern on an Incident Report 8 regarding these components, for whatever reason, 9 and given it to the shift r2pervisor as the 10 procedure said, would the shift supervisor say I 11 don't have Enough information from you to make an 12 operability determination, so go see the Ops 13 Engineer?
14 MR. VONDRA: No, he would not.
15 MR. HOLODY: So why wouldn't he accept 16 it in this case from the individual, especially 17 after the meeting with you, if he had gone back 18 down to the shift supervisor, he could have given 19 him that report--
20 MR. VONDRA: The shift supervisor I 21 believe if the guys would have said this is all I 22 can do, he would have accepted it. I think the 23 shift supervisor asked them as a favor that there 24 is not enough information, would you be willing to ALL POINTS REPORTING (215) 564-5380
30 1 go back and get that for me, okay. And I don't 2 think the shift supervisor would do that if a 3 custodian or mechanic, but these are two degreed 4 engineers with a lot of experience in our company, 5 these are not just some person that doesn't k'now 6 anything. These are folks that are experts on the 7 Incident Report systems. If you read their 8 responsibilities in the technical spec they 9 evaluate all of the Incident Reports. They should 10 be intimately familiar with how these procedures 11 work.
12 MR. HOLODY: So the shift supervisor 13 is, you indicated was looking for them to gather 14 some more information as a favor, and they took it 15 up to the Ops Manager, and then it ultimately 16 landed in your office in a discussion?
17 MR. VONDRA: That is my understanding.
18 MR. WETTERHAHN: You didn't know that 19 at the time though, that they had not filed it?
20 MR. VONDRA: Nc, I thought it was 21 filed. I thought this was an Incident Report that 22 had been submitted to the shift supervisor, he had 23 asked for help, and we were trying to get him some 24 help.
ALL POINTS REPORTING (215) 564-5380
31 1 1 MR. HOLODY: At the time of the meeting
( 2 when you were having your discussions, did you 3 know then when Mr. Williams and Mr. Craig 4 ultimately left your office after this meeting; 5 did you know at that time that a report had been, 6 they attempted to file this report with the shift 7 supervisor?
8 MR. VONDRA: I thought they had filed 9 the report with the shift supervisor.
10 MR. HOLODY: So, what is difficult for 11 me to understand--
12 MR. VONDRA: Let me qualify myself. I 13 didn't even know the Incident Report was with them 14 in my office.
15 MR. HOLODY: It was your belief that it 16 was--
17 MR. VONDRA: That it was going to go 18 through the process.
19 MR. HOLODY: So if the SRG's are not 20 responsible for making an operability
. 21 determination, the operations, the shift 22 supervisor is responsible with making that 23 determination and he needed more information and
, 24 you believed that he had the report and you and ALL POINTS REPORTING (215) 564-5380
32 1 the Ops Manager had the information that allow you
( 2 to conclude that it was operable, why did the 3 SRG's even have to be involved anymore at that 4 point; couldn't you have gone back down to one 5 shift supervisor, you or the Ops Manager and said 6 take that report anc write on the information that 7 you had independent, not you but the Ops Manager 8 had, it is my understanding he had independently 9 obtained?
10 MR. VONDRA: The feeling that I had was 11 the SRG engineers were unwilling to let this 12 report take its normal process, that they were 13 going to follow it through and verify that the 14 decisions that were made that they agreed with.
15 That is the part that is extremely different.
16 MR. LANNING: What was said that made 17 you believe that?
18 MR. VONDRA: The fact they didn't want 19 to let control of the thing go. I didn't ask them 20 to put that information on the Incident Report. I 21 would have been willing to put the information on 22 the Incident Report. I think Vince would have 23 been willing to put the information on the 24 Incident Report. They were telling us that we ALL POINTS REPORTING (215) 564-5380
. 33 1 were not allowed to do that.
( 2 MR. HOLODY: I thought you could do 3 that since you already in your mind you already 4 had the report, the senior had the report?
5 MR. VONDRA: These folks were, in my 6 mind, trying to run an audit on the incident 7 system at that time, and I didn't know where they 8 were, so what I did was I said well, if you don't 9 want this information on the Incident Report then 10 why don't we attach a DEF to the Incident Report 11 and process it with this information on the DEF, 12 because I know, and they should have known, that 13 this Incident Report, once it cleared the Shift it Supervisor's office, was going to be voided and 15 turned into a DEF, because it did not meet the 16 definition of an off normal event.
17 MR. HOLODY: Why was that?
18 MR. VONDRA: Because it is described in 19 attachment to the procedure as being the type of 20 document that would become a DEF. It is 21 specifically, there is a definition in Attachment 22 Two that covers this situation, and the Incident '
23 Report Coordinator takes that definition, converts !
24 the thing over to Engineering for a DEF and voids 1
ALL POINTS REPORTING (215) 564-5380 l
34 i i t 1 the Incident Report. That is the past practices. '
i L
{ 2 And now, in retrospect I found out that they were l
. 3 .actually voiding out the Incident Report, like it i ,
j 4 never existed, and they had done this for a number i
5 of years in the past. That was the practice. t 6 MR. WHITE: Who is they in this case? ;
i 7 MR. VONDRA: The Incident Report i 8 Coordinators that process these documents. I E 9 would not have done that, and I changed it when I ;
i
} 10 understood that, that you no longer void the l i
3
- 11 Incident Report you keep it open until the DEF 12 gets closed. That is the more appropriate way to 4]
{l 13 do that, but past practice had been, that is the ;
! 14 way it had been. l I f 15 MR. WHITE: Do you think the SRG's !
j 16 understood what past practice was? l a
17 MR. VONDRA: I got a quality report ,
j 18 that says they reviewed every Incident Report, and i
- j. 19 I think they should have been aware of this. I ,
20 thought that was their responsibility per tech )
i 21 specs.
22 MR. WHITE: I guess I still need to try !
23 and clarify something, that is regardless of what 24 you thought the SRG engineers thought about the I
l ALL POINTS REPORTING (215) 564-5380
I 35 1 process relative to this other information that 2 Mike Maroney and your seismic engineer had 3 developed relative to qualification, why was it 4 essential in your view or Vince Polizzi's view 5 that they put this information--
6 MR. VONDRA: It wasn't. Eventually I 7 concluded that it wasn't necessary.
8 MR. hIITE: And regardless of what 9 their understanding of the process was, you 10 understood what the process was, all they had to 11 do was put this Incident Report into the Shift 12 Supervisor's office and the process really 13 burdened Operations Department with the ;
14 responsibility and authority to process that 15 Incident Report and make the operability 16 determination as appropriate, right?
17 MR. VONDRA: It is not a burden, it is 18 part of the job.
1 19 MR. WHITE: It is the responsibility of j 20 the Operations Department?
l 21 MR. VONDRA: It is the responsibility, l l
22 yes, however, the Shift Supervisor, Senior Shift 23 Supervisor is usually a pretty knowledgeable 24 person, could quote you most of the technical ALL POINTS REPORTING (215) 564-5380
l 36 1 specifications verbatim from the top of his head, 2 very familiar with the FSAR, sometimes an engineer 3 sometimes not an engineer, okay. He cannot make 4 all correct operability determinations to any ,
5 question that could just walk in the door without 6 help, and this is to be expected, that he have 7 help. The DEF process is one of the processes 8 that provides that help for him. I could ask 9 questions, I could sit there all day and ask 10 questions that a Shift Supervisor can't answer.
11 MR. WHITE: Let's keep to the SRG's 12 right now. What is their responsibility; what is 13 the responsibility of the SRG engineers in your 14 estimation?
15 MR. VONDRA: Not, not, okay, to do the 16 investigation of this type of Incident Report.
17 MR. WHITE: Their responsibility then 18 is to audit?
19 MR. VONDRA: I felt they never should 20 have got it, John.
21 MR. WHITE: Follow up on an item, if 22 they find something that looks out of spec they 23 write up an Incident Report, that is their job?
24 MR. VONDRA: Any employee, any ALL POINTS REPORTING (215) 564-5380
37 1 employee, any visitor can write an Incident 2 Report.
3 MR. WHITE: That is right.
4 MR. VONDRA: Okay, and that applies to 5 the SRG as well. However, I don't understand why 6 the SRG ever got the HPES thing, why that wasn't 7 sent to an engineering function to get 8 investigated, because it is not the job of SRG to 9 investigate engineering issues. Okay, they're to 10 do reviews and audits of programs that are in 11 place, so like they could have come back after the l
12 fact and reviewed whether or not we did this 1
13 right, but they wouldn't do engineering reviews. ;
l 14 MR. WHITE: Is the SRG independent of 15 you?
16 MR. VONDRA: Absolutely.
17 MR. WHITE: So they don't report to you 18 at all?
19 MR. VONDRA: No.
20 MR. WHITE: So what their assignments 21 are relative to their job is a different 22 management climb?
23 MR. VONDRA: Yes, but this is my plant, 24 and I am responsible for Section 6 of the tech i
ALL POINTS REPORTING (215) 564-5380 l
38 1 spec to operate this plant safely, and they do not
( 2 have the responsibility for making engineering 3 decisions. This investigation should have been 4 done by Engineering not Safety Review is what I am 5 trying to say.
6 MR. HOLODY: If the senior had accepted 7 the Incident Report, which as you indicated 8 anybody could have written?
9 MR. VONDRA: I would have never seen it 10 MR. HOLODY: What would have happened?
11 MR. VONDRA: It would have gone through 12 the process, Engineering would have gotten i 13 involved, the shift supervisor based on facts from l l
14 Engineering would have made a determination of l 15 operability and reportability, it would have been 16 forwarded to the Incident Report Coordinator, he i
17 would have voided the Incident Report out, sent it l
18 to Engineering, he would have generated a DEF. )
19 MR. HOLODY: That would have been done 20 that day?
MR. VONDRA: Very closely. I'll tell j 21 22 you what, it would have been done a lot faster 23 than the way it was done.
24 MR. HOLODY: When he got it, was there 4 l ALL POINTS REPORTING (215) 564-5380
~
39 l l
1 questions regarding the operability of the 2 components? I thought that is why he sent it 3 back, that is why he wanted help.
4 MR. VONDRA: There was not enough 5 information for him to make a decision on 6 operability. There was a question, okay.
7 Somebody says I think this is not safety related.
8 That is essentially what this report says. I 9 think this is not a safety related component. I 10 could ask those questions all day, okay, but I 11 don't move the plant up and down on questions. I 12 find out if it is safety related, that is what I 13 find out, then I do the things to the plant. I j
l 14 mean, and it is not unusual, Salem units were 15 built before safety relar.ed was a way to go. We 16 designed the plant before, safety related was like 17 back fit. If you go back into the '80's, Salem 18 was designed in the 60's, built-in the 70's, last 19 unit was put on in the '80's, '81, I think one of 20 the first plants after TMI to come on line. The 21 cafety related didn't go back in history, so we 22 went back and identified systems that were safety 23 related. If you open up a cabinet, okay, on a 24 speed controller for a charging pump and you go in ALL POINTS REPORTING (215) 564-5380
40 i there and there is a transistor in there on a 2 board, okay, I can guarantee you that that 3 transistor was probably not manufactured safety 4 related, so you can say, somebody who has 5 knowledge of components can look at that 6 transistor and say that transistor is not safety 7 related. That doesn't mean that transistor wasn't 8 reviewed or the way it is put in that panel and 9 the way it is used wasn't reviewed by our 10 Engineering group, okay, and that it is qualified 11 to do the job. It goes back to the switch over 12 from commercial to safety related, so it is not I
13 unusual to find those components.
14 MR. WHITE: Regardless of why they were 15 doing this investigation or whether it is 16 Engineering or not, they wrote an Incident Report 17 which was legal for them to do, legal for anybody 18 to do?
19 MR. VONDRA: Absolutely.
20 MR. WHITE: They knew the process for I
21 how Incident Reports are to be handled? !
22 MR. VONDRA: Yes.
23 MR. WHITE: If they did not agree with l
, 24 the way that operations was going to handle that J
ALL POINTS REPORTING (215) 564-5380 k< \
l
t 41 l
- 1. Incident Report, what other mechanisms or 2 processes are available to them to dispute, you [
3 know, operations handling? If they believed it is 4 part of their function that operations treatment j l
5 of this Incident Report was not appropriate; what l 6
6 would be the normal thing that you would expect l l
7 that they_would do? l l
8 MR. VONDRA: They could generate a }
9 safety review report to senior management, okay, f l
10 having audited this and said it was not handled l 11 correctly and fully expect them to do if it isn't. f
{
12 MR. WHITE: So, again, why were they in )
i 13 your office; what was your understanding as to why 14 they were in your office on this issue?
i 15 MR. VONDRA: My understanding is that )
16 they were in my office because they didn't want to 17 put all of the --
they didn't want to allow the 18 process to take its path and put the information 19 on.the Incident Report. They were interfering 20 with the process.
21 MR. WHITE: Did you come to that 22 conclusion yourself based on your own assessment, 23 or is this something that Vince Polizzi told you, 24 or is it possible that Vince Polizzi brought these ALL POINTS REPORTING (215) 564-5380
42 1 ladividuals down to your office instead of 2 allowing them to process them to the shift 3 supervisor, or did he carry them down to your 4 office; did you even know?
5 MR. VONDRA: I can tell you that Vince 6 Polizz brought the people to my office. I can't 7 tell you what went on in Vince's office, other 8 than what he told me happened, and that I have 9 already relayed *o you, that he tried the same 10 tact and was unable to do that. I think I went 11 further in trying to accommodate these, I was 12 concerned. This is an independent Safety Review 13 Group. I tried to call Larry Reiter at the 14 beginning of it to have him come over here and be 15 here with us for this. I called him immediately 16 after as well. He was busy and couldn't give it 17 the time, and he sent another fellow who treated l 18 it quite Ir.ckadaisical in my opinion, Ed Leiden.
19 I tried to get senior independent management 20 involved before this ever started. I went to 21 them, to get back where I was, I asked the folks 22 why they would not allow this to happen, and they 23 felt --
g 24 MR. WHITE: Allow what to happen?
ALL POINTS REPORTING (215) 564-5380 1
43 1 MR. VONDRA: The information to be put 2 on-the Incident Report about the seismic 3 qualification and the safety related information.
4 MR. WHITE: Why did you believe they 5 had any control of what went on in this report or 6 how they treated it; why'did you believe they had 7 any control over that?
8 MR. VONDRA: I don't believe they had 9 any control over it. I was trying to accommodate 10 them, because they are the Safety Review Group. I 11 was trying to help them.
12 MR. WHITE: So it wasn't essential that 13 they agree with you or not; is that right?
14 MR. VONDRA: I was going to take this ;
i 15 safety incident and have it investigated and do i
- 16 the right thing by it regardless of the--
17 MR. WHITE: Regardless of what?
l i 18 MR. VONDRA: Absolutely, but I did not i
4 19 want to turn these guys off. I wanted to i
20 accommodate them if I could and bring this to a l ,
21 successful conclusion, so since they were not 22 accepting having this information put on the 23 Incident Report I said, you know, this is really 1
le 24 going to be a DEF, and I said how about we i 1 I
ALL POINTS REPORTING (215) 56s 1380 l I
44 1 generate a DEF and attach that to the Incident 2 Report, and I was immediately told by Paul, by 3 Burt Williams that he had submitted a DEF before 4 and it took 18 months to get it done and that he 5 had no faith in that process. Well, that is great 6 except that is our process. The DEF procedure 7 covers all nuclear department personnel. This is 8 h.ow we handle this type of an issue, so I said 9 well Paul, or Burt, I'21. guarantee that this thing 10 gets investigated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. I will make 11 sure that that investigation is complete, and I 12 fully intended to do so, and he said no, that is 13 not acceptable, and I asked what is acceptable, 14 and what he said was what was acceptable was for 15 the senior shift supervisor to make a decision 16 based solely on what was on the Incident Report in 17 its current form, and I said that ir not 18 acceptable. Okay, and he said then I am going to 19 write you up on a safety concern, and that is when 20 I lost my temper. I said you're going to write me 21 up on a safety concern, you're threatening me to l i
22 write me up on a safety concarn to do something 23 that you know is wrong. I said, don't threaten
- 24 me, go do it and get the hell out of my office.
I l
ALL POINTS REPORTING (215) 564-5380 i
. 45 1 Then I called up Larry Reiter and asked him--
2 MR. WHITE: Were those essentially your 3 words?
4 MR. VONDRA: Essentially, yes, I felt 5 they were threatening me for some reason. I tried 6 to be accommodating here, well beyond what my 7 responsibility was to be accommodating. I could 8 have just said the Incident Report is up there.
9 That is where I thought it was, we'll just process 10 it, and you guys go away. I tried to do what I 11 could to bring a resolution that they could accept 12 as well, and I couldn't get it done.
13 MR. HOLODY: About how long were they 14 in your office?
15 MR. VONDRA: About 20 minutes I would 16 say. After that point the conversations were, you 17 know, up until the point they told me they were 18 going to write me up on a safety concern the 19 conversations were not much different than they 20 are right now.
l 21 MR. WHITE: Once they said that?
22 MR. VONDRA: I lost my temper. That is 23 the first time I can remember losing my temper in
. 24 years.
l ALL POINTS REPORTING (215) 564-5380
F 46 1 MR. LANNING: Are safety concerns 2 directed at people or to a safety issue?
3 MR. VONDRA: They can be. It depends.
4 MR. LANMING: It is your recollection 5 that they said you, Cal Vondra, is going to be the 6 subject of this safety concern?
7 MR. VONDRA: Oh, yeah, and that was 8 subsequent to that I believe that was Jay Bailey.
9 There was one fellow in the room who sort of 10 didn't really have a lot to do with this, and he 11 came over to give his information about seismic, 12 but he was not involved in the operability
' 13 decision. He was not involved in the processes or 14 anything, and that was Jay Bailey, and my 15 understanding of his recollection of this time 16 period was that he perceived it as a threat to me 17 as well, that I was being threatents to be written 18 up. It wasn't that they were going to write up a 19 safety concern about how it was handled, they were 20 going to write up a safety concern about me. I 21 took that as a threat that they were going to try 22 to make me do something that I thought was unsafe.
23 MR. WHITE: Is it fair to characterize 24 it that when they made that statement that you ALL POINTS REPORTING (215) 564-5380
47 1 took it as a personal attack on you?
2 MR. VONDRA: Yes, I did. I thought I 3 was being threatened to do something. In order to 4 get their way and do something that was incorrect 5 against our procedures they were threatening to 6 write me up on a safety concern, so yes, I would 7 say that was personal. So I told them to get out 8 of my office. I called Larry Reiter again. He 9 was unable to come. He sent Ed Leiden. I told Ed 10 Leiden what happened, and he just left my office.
11 He didn't say nothing, he just left my office and 12 that was it. I 13 MR. WHITE: Leiden had no comments?
14 MR. VONDRA: No.
15 MR. LANNING: Can I go back and make l 16 sure that I understand what it is that they l
17 thought that you should do that you didn't do that l l
18 resulted in this safety report? I 19 MR. VONDRA: I asked explicitly what it 20 was. I was told by them they wanted the shift 21 supervisor to take the Incident Report as they 1
22 submitted it and make an operability 23 determination, and they fully expected him to 24 declare it inoperable based on what was on that ALL POINTS REPORTING (215) 564-5380
48 1 form. They said if they had to do it they would 2 also declare them inoperable.
3 MR. OLSHAN: So the shift supervisor 4 would not have been able to consult with anybody 5 else?
6 MR. VONDRA: That is what they were 7 trying to do I couldn't understand why we were B hera doing tnis.
9 MR. LANNING: That is contrary to your 10 procedure, is it not? The procedure would say 11 that after it is submitted to the supervisor it is 12 out of the hands of the person that prepared it 13 and that the shift supervisor would get what 14 additional help he needs to make the operability 15 determination, even if that includes bringing in 16 other organizations to help him make that 17 determination?
18 MR. VONDRA: Absolutely, he has to, 19 he's not all knowledgeable.
20 MR. LANNING: Is it your opinion that 21 the SRG folks didn't appreciate or understand the 22 existing procedure?
23 MR. VONDRA: Yes.
24 MR. LANNING: These are the same folks ALL POINTS REPORTING (215) 564-5380
?
49 -
l 1 'that provided audits of the procedure and how the 2 ' things are done, correct?
3 MR. VONDRA: Correct. I also felt they l 4 didn't understand the DEF procedure, which they l l
5 should have as well, because they also audit those l i
6 kind of things. The DEF's are part of their !
7 responsibilit; . I I
8 MR. WETTERHAHN: What didn't they j 9 understand about the DEF process? {
i 10 MR. VONDRA: That the type of event l 11 that they had was not an off normal event per the l 12 definition of NAP 6, that it was indeed a DEF, in 13 reality an Incident Report need not to have been l i
14 generated, a DEF should have been generated per l 4
15 our procedures. That is what it would take you. ;
16 That is what happens with these when they are 17 submitted by someone who is not knowledgeable. If 18 a person who is not knowledgeable would have 19 submitted it, it would have gone down to the 20 Inc.ident Report Coordinator, he would have voided 21 it handed it over and got a DEF generated. That 22 is what would have happened. These folks should 23 have been knowledgeable about that.
24 MR. LANNING: Did you try to explain to 4
ALL POINTS REPORTING (215) 564-5380
50 1 them the fact that an IR should not be submitted
~
2 and instead they should submit a DEF?
3 MR. VONDRA: The best I recollect is I 4 tried to tell them we could attach the DEF to the 5 IR process, and that in my mind, I was trying to 6 appease these fellows to get on. I didn't want 7 them to walk out of my office thinking that we 8 were not going to do the right safety thing with 9 this, okay, and that we were going to do something 10 wrong. I wanted them to go out of my office 11 knowing that we accepted this issue, we were going 12 to investigate it, and we were going to bring it
. l l'
13 to a conclusion and do it in accordance with our l 14 procedures.
15 MR. LANNING: If the DEF was the proper 16 vehicle, why was it so important to add this 17 additional information to the IR?
18 MR. VONDRA: The IR, once submitted, 19 the shift supervisor has to make an operability 20 and reportability determination. I thought it had 21 been submitted and the shift supervisor was asking 22 for additional information on the IR to make that.
23 MR. LANNING: So an IR is required for i l
24 this type of situation? ;
)
i ALL POINTS REPORTING (215) 564-5380
i
- 51 I 1 MR. VONDRA: No, you could have 2 submitted a DEF in the first place and that would ,
i 3 have handled it, and it would have been done. You 4 could have submitted an IR to the shift supervisor 5 and walked away, and that would have handled it 6 and it would have been done.
7 MR. LANNING: Would the operability 8 determination have been made in the same manner as 9 the two type of vehicles?
10 MR. VONDRA: There is a flow chart in 11 NAP 18 that shows how the DEF gets processed and 12 since that is a configuration issue it is not 13 expected the shift supervisor would have that kind 14 of knowledge, an engineer makes the determination 15 of whether operability is a concern. If 16 cperability is a concern the DEF generates an 17 Incident Report to the shift supervisor telling i
18 him that operability is a concern. That is the l I
19 process.
20 MR. LANNING: Typically how long does 21 that take; is it more of a delayed process than an 22 IR?
I 23 MR. VONDRA: You have to do some amount 24 of investigation. In either one of these you have ALL POINTS REPORTING (215) 564-5380
52 i to do an investigation. You're not going to shut j
( 2 the plant down on a question, you're going to shut 3 the plant down or leave it continue to run based ,
i 4 on facts not a question, and what we had here was !
l 5 not a fact, we had a question. You got to 6 understand that.this was not a fact that these 7 things were wrong, in fact they were right, okay, l r
+
8 and what we had was a question as to whether or 9 not they were right, and that has to be 10 investigated and the DEF process has like a 24 l 11 hour period in there to get it investigated, and 12 when it is at the immediate engineering supervisor ,
1 13 level he has 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and he's responsible in that 14 time period to determine whether or not there is l 1
15 an operability issue, and if there is to issue an 16 Incident Report to the senior shift supervisor.
17 MR. LANNING: So there is no difference 18 in the timing or the determination of the 19 operability between the two?
20 MR. VONDRA: It would have gone faster 21 if a DEF was submitted.
22 MR. LANNING: Help me understand that.
23 MR. VONDRA: An Incident Report would 24 be done, the shift supervisor would try to make a ALL POINTS REPORTING (215) 564-5380
53 1 determination of operability, if he wouldn't be 2 able to, he would ask for help, okay. A DEF would 3 then be generated, he would get the help he needed 4 to answer the question. All right, so, if you 5 made the DEF in the first place it would be 6 quicker, because you wouldn't go through this 7 process, and if you read the Incident Report 8 procedure it leads you to the DEF program, and if 9 you go into the DEF program it really gets you 10 back if there is an operability concern to the 11 Incident Report program, and I thought in the 12 interest of appeasement let's put them both i together, let's use them in conjunction, you know, 13 14 and get it done. I just wanted to get the right l 15 investigation done and get this done. l l
16 MR. LANNING: If it would result in the 1 17 same thing, then what was the threat if you knew 18 you were so correct?
19 MR. VONDRA: The threat was that they 20 thought that they could get me to change my mind 21 by threatening to write me up on a safety concern 22 to do something that I thought was wrong, okay, 23 and that they thought was right. I think they 1
4 24 really believed that these components were l l
l l
l ALL POINTS REPORTING (215) 564-5380
i 1
1 54 j 1
1 inoperable and that both units should be shut )
( 2 down. I really believe that is what they l
l 3 believed. I believe they were sincere about that.
4 MR. LANNING: Let me understand now.
5 You interpreted their statement about the safety 6 concern report as a threat to make you change your 7 mind at the time of the discussion?
8 MR. VONDRA: Yes.
9 MR. LANNING: As opposed to a threat 10 whereby the safety concern would be reviewed by 11 upper management and would come back at you in an 12 adverse way?
13 MR. VONDRA: I'm not sure I see the 14 difference between those two sir.
15 MR. LANNING: Well, in one hand it was 16 a threat that says if you don't change the way we 17 process this today right now I'm going to do the 18 safety report. That is one way of looking at it.
19 The other way of looking at it, and that could be 20 considered a threat to you, I guess. The other 21 threat you could perceive from this statement 22 would be they're going to do the report anyway, 23 and then my upper management is going to look at 24 that report and come back at me because I didn't ALL POINTS REPORTING (215) 564-5380
55 :
?
I satisfactorily resolve this issue, I guess. I'm !
( 2 just trying to see where between those two {
3 extremes, how were you threatened? l 4 MR. VONDRA: I took it the fist way 5 that you mentioned, as a personal threat to try 6 and make me change my mind to do something that t
7 they wanted that I felt was wrong. I didn't care ;
8 if they did write up a safety concern. I told 9 them that don't threaten me with it, go do it, .
10 okay, I'm going to do the right thing here f 11 regardless of your threat, and that is what my 12 intent was. So, when they left my office I called :
t 13 Larry Reiter. He sent Ed Leiden over. I went 14 through what happened with Ed Leiden. He left and i i
15 he didn't say nothing. I then called Mike l l
16 Maroney, I thought the Incident Report was up at l 17 the shift supervisor's office. I told him to 18 complete this investigation and get it done and 19 let me know whether or not we have an operability 20 concern here, because I thought at that point that 21 it could come out that the plants had to be shut 22 down. I didn't know. All I wanted to do was to 23 get the investigation done, so I called Mike 1
24 Maroney and toA2 him to do that. He called me l l
ALL POINTS REPORTING (215) 564-5380 l
l
56 1 back about 7:30 that night at home, told me he did i
2 a personal walk down at the panels himself, he was l 1
3 comfortable that the panels were operable, and I 1
4 that coupled with the fact that the FSAR sala that )
l 5 they were the right components for the job, and 6 that the Engineering Services Sciences Group said 7 they were seismically qualified. In my mind met 8 all three conditions that they could go ahead and 9 fix anything else that was wrong with it as part 10 of the process.
11 MR. LANNING: When did you first learn 12 that the IR had never been submitted?
I 13 MR. VONDRA: A long time after the 14 fact, okay.
15 MR. LANNING: Do you recall under what 16 situation or what was said?
l 17 MR. VONDRA: Yes. When I got to see ,
1 18 the executive-- I only got to see the executive I
19 summary of the investigation that was done 20 sometime later on. After this I went to the Impo 21 Senior Managers Course. When I came back from the 22 Impo Senior Managers Course this investigation was 23 in full swing. The investigation concluded
- 24 sometime in the spring or summer. I was given an l
ALL POINTS REPORTING (215) 564-5380 l I
l 57 1- opportunity to read the executive summary of the l
( investigation, and there is when I found out that I
2-i 3 the Inci. dent Report had not been submitted. j 4 MR. LANNING: 1So it was a period of 5 months?
6 MR. VONDRA: May or something like
~
7 that, yes.
s 8 MR. LANNING: I guess I don't quite 9 understand why given the episode in your office 10 you wouldn't wonder about what the outcome of the l 11 IR was? i 12 MR. VONDRA: I did. I got a call that 13 night from Mike Maroney that he had taken care of 14 the IR.
15 MR. LANNING: I thought you said he had 16 generated a second IR?
17 MR. VONDRA: I know that now, I didn't 18 know that then. When he called me that night, 19 okay, he indicated that the walk down was done, 20 the things were complete, and an IR had been
'21 submitted. I didn't know whether it was a second 22 IR or not at the time. I know now that it was a 23 second IR, but at the time I didn't know that. I
- 4. 24 thought it was the same IR.
ALL POINTS REPORTING (215) 564-5380
i
~
58 1 MR. LANNING: I thought-you indicated 2 that you thought that the IR had been submitted ;
3 and by him saying he submitted another IR that f j 4 would be the second one? l 5 MR. VONDRA: With the information to i 6 the shift supervisor to make the operability ;
7 determination and reportability determination, and l f
4 i
' 8 that was done later on that night, okay. So I j l 9 thought what he did was went and walked down the t 10 panels, got the information necessary, got it on !
- t 1
11 the IR, and had the shift supervisor make the l jl I
, 12 operability and reportability determination. I :
1 !
.. : 1
'13 didn't know a second IR was submitted. l 14 MR. HOLODY: When did this meeting take 15 place?
16 MR. VONDRA: Which meeting?
t 17 MR. HOLODY: The two individuals in your i i 1 18 office, mid-afternoon, early afternoon? i i
i 19 MR. VONDRA: I thought it was <3arly l
- )
l 20 afternoon or late morning.
I 21 MR. HOLODY: If the two SRG engineers 3
I 22 had put down on the report everything that you 4
23 wanted them to put down, this other information 24 that had come from these other individuals j i i s
1 ALL POINTS REPORhING-(215) 564-5380 i
59 1 Maroney, Bailey, et cetera, and then had given you 2 the report, what would have happened then?
3 MR. VONDRA: It would have gone to the 4 senior shift supervisor.
5 MR. HOLODY: He would have made an 6 operability determination at that time?
7 MR. VONDRA: Yes.
8 MR. HOLODY: And everything would have 9 been fine?
10 MR. VONDRA: Everything would have been 11 fine if they did that. If they had given it to 12 the operations manager, I think it would have been t
' 13 fine. I got a little question about that after 14 having read the complete investigation here. I 15 have to tell you that, or had they left it with 16 the senior shift supervisor to begin with at that )
17 point it would have been fine. Thousands of these )
18 get done without going through what happened here 19 without any problem.
20 MR. HOLODY: What confuses me is that )
l 21 these engineers don't have to make an operability 22 determination. In fact, it is not their job to do 23 that? l l
24 MR. VONDRA: Didn't ask them to. )
1 ALL POINTS REPORTING '215) 564-5380
60 1 MR. HOLODY: This could have been left 2 with the shift supervisor; all of this information 3 that you wanted them to put on there, somebody up 4 the operations chain could have put on that 5 Incident Report, correct?
6 MR. VONDRA: Yes.
7 MR. HOLODY: And as you just said a 8 determination would have been made that the 9 components were operable. If that is the case why 10 was there even, since you had all of that 11 information and it was only a case of the SRG's j 12 not wanting to put that information on the report, 13 why did Maroney have to do this work that evening?
14 MR. VONDRA: Because I wanted it done.
15 There was an issue out there. I didn't know it 16 was going to get resolved by these folks. I was 17 quite concerned about these folks who are supposed 18 to be very knowledgeable about our Incident Report 19 system, our DEF system, and have a safety 20 conscious about how our plant works I was very 21 concerned that these folks were not doing things 22 in accordance with our procedures, and they were 23 off doing whatever they wanted, and I felt that 24 there was a problem in them not following our ALL POINTS REPORTING (215) 564-5380 00
d 61 1 procedures.
2 MR. HOLODY: I thought you said in that 3 meeting you felt that you had all of the 4 information needed?
5 MR. VONDRA: I did.
6 MR. HOLODY: To say that the component 7 was operable, and if they would have simply put 8 that down that they accepted that, these people 9 that you, yourself, just said you really thought 10 that they conscientiously believed that those
- 11 components were not operable?
12 MR. VONDRA: I believe that.
13 MR. HOLODY: But you believed that you 14 had all of the information that you needed?
15 MR. VONDRA: Yes.
16 MR. HOLODY: To say they were operable; 17 if that is the case, why was any additional work 18 needed that evening by Mr. Maroney?
19 MR. SMITH: Don't you think Mr. Maroney 20 provided the additional information; is that what
, 21 you thought?
22 MR. VONDRA: No, the additional 23 information that Mr. Maroney brought was a part 24 that really never came up in my office but Vince ALL POINTS REPORTING (215) 564-5380
62 1 eluded to me when he talked about the surveillance 2 test and that had to do with the configuration, 3 okay, and subsequently I found out that Mr.
4 Maroney's second Incident Report didn't deal with 5 seismic qualification. It didn't deal with the 6 component qualification for safety related, it 7 only dealt with configuration, which I was told 8 later was an issue that these folks were concerned 9 was missed, so at the end of the day when Mike 10 called me at 7:30 that night I understood that the 11 seismic issue, qualification of the components for l 12 safety related, and configuration of the i
13 components were satisfactory. ;
14 MR. HOLODY: You knew that at the end i 15 of the day?
16 MR. VONDRA: At 7:30.
17 MR. HOLODY: But you didn't know that 18 at the time of the meeting; configuration was an 19 issue?
20 MR. VONDRA: They didn't bring it up.
21 MR. HOLODY: You were not aware, you're 22 saying, during that meeting that configuration was 23 an issue?
24 MR. VONDRA: Right. i l
ALL POINTS REPORTING (215) 564-5380
l
- 63 1 MR. HOLODY: So the only, if the two 2 other components weren't an issue, you felt there 3 was significant information to resolve those .wo 4 issues and therefore conclude that the components 5 were operable.
6 MR. VONDRA: With the addition of the 7 fact that the surveillance tests were run and were 8 satisfactory, which would be a configuration 9 issue. So I wanted three pieces of information 10 for the shift supervisor that I thought were known 11 and facts. That is that the components were 12 qualified to do the job, that the seismic 13 qualification existed in engineering, and that the 14 surveillance testing had been done and was 15 satisfactory on these components. That is what I 16 wanted to add to the Incident Report for the shift 17 supervisor.
18 MR. HOLODY: How did Maroney know of 19 the configuration issue; you directed him to do 20 this walk down, right?
21 MR. VONDRA: I asked him to do the 22 investigation. I thought he would get the 23 Incident Report, okay, and go do whatever had to 24 be done. Af ter the fact I found out that he never ALL POINTS REPORTING (215) 564-5380
64 1 had the Incident Report, he acted based on the !
2 knowledge he had with the seismic and the FSAR and -
3 then did the configuration check himself. <
4 MR. HOLODY: How did he knew that was ,
-5 an issue, the configuration issue? ;
i 6 MR. VONDRA: He found it when he walked F down the components is what I got from him. He 8 actually opened up the panels, looked at the 9 piping, determined that the piping was not in 10 accordance with the drawings but was satisfactory.
11 MR. OLSHAN: When these gentlemen came 12 into your office yo.u assumed at that time they had 5 13 already submitted the Incident Report to the shift 14 supervisor?
15 MR. VONDRA: Yes.
16 MR. OLSHAN: You were asking them to 17 take it back and make changes?
18 MR. VONDRA: I thought the shift 19 supervisor requested them to provide additional 20 information so he could make a reportability 21 determination, and I think, in effect, that is 22 what he was asking.
23 MR. OLSHAN: And that kind of thing 24 would normally be done on the original Incident ALL POINTS REPORTING (215) 564-5380
65 1 Report?
2 MR. VONDRA: Normally, yes, it would 3 be, but it wouldn't be done by these Safety Review 4 Engineers, they would let go of it and it would go 5 up to Vince or someone in his organization who 6 would contact engineering, and they would do the 7 investigation and that stuff would be given back 8 to the shift supervisor in the form of a DEF, and 9 a decision from engineering that it is done.
10 MR. OLSHAN: And you wanted that to 11 happen but they didn't want it to happen?
12 MR. VONDRA: That is the feeling I had.
13 MR. OLSHAN: So you wanted to talk them 14 into allowing that to happen?
15 MR. VONDRA: I wanted to put all of the 16 facts that were known on the document.
17 MR. OLSHAN: But you could have done i
18 that anyhow; the normal procedure--
19 MR. VONDRA: That is what I thought I ;
20 did. After we came to an impasse, they left my 21 office, I called my technical manager, gave him 22 direction to do this investigation, so I thought I 1 23 did direct him to take care of this and handle 24 this process without them, so I thought I did i
ALL POINTS REPORTING (215) 564-5380
66 1 that.
2 MR. HOLODY: Did the shift supervisor 3 in your opinion when they came to him the first 4 time, did he do the right thing or should he have 5 accepted that report?
6 MR. VONDRA: I think he should have 7 accepted that report and called management himself 8 and generated the process.
9 MR. HOLODY: In which case --
10 MR. WETTERHAHN: Excuse me, I think 11 there is a factual gap here. When they originally 12 went to Mr. Cafanteros they didn't have an l 13 Incident Report generated, that was the problem.
14 That is the clear finding of the investigation, 15 and I'm not sure what is in your investigatory 16 report, but I'm sure that is clear.
17 MR. VONDRA: I didn't know that. I 18 thought they did, because it was presented to me 19 that an Incident Report was written, and then when 20 I found out quite a bit later that it was right 21 there in my office, that the Incident Report had 22 been given to Vince Polizzi, and it had been taken 23 back from Vince Polizzi and it was in their hands 24 when they were in my office, it was never offered ALL POINTS REPORTING (215) 564-5380
67 1 to me or told to me that that Incident Report was 2 with us.
3 MR. HOLODY: So if it was given to 4 Vince Polizzi he could have taken it down to the 5 shift supervisor?
6 MR. VONDRA: Absolutely.
7 MR. HOLODY: Should he have done that?
8 MR. VONDRA: I think so, but my 9 understanding is that they requested it back, he 10 gave it back to them. I don't know why. I can't 11 answer that. That stuff happened before it got to 12 my office, and all I was trying to do was get a 13 safety issue documented in accordance with our 14 procedures and evaluated in accordance with our 15 procedures. I was trying whatever mechanism could 16 do that to get that.
17 There is a couple of things I would 18 like to read you from documents that I have.
19 Okay, I have a letter written by Jay Bailey, all 20 right, and this is dated 12-3-93, you probably 21 have this. It says, " Summary of Events 22 SW-223IR/DEF." It says that, this is concerning 23 what happened in my office. "Burt stated that if 24 Cal and Vince would not accept the IR he would ALL POINTS REPORTING (215) 564-5380
f 68 1 leave and initiate a safety concern and escalate
( 2 the matter. Cal perceived this to be a threat."
3 In parenthesis he has "It sounded like one to me."
4 So he was sort of an impartial person, and he 5 believed that it sounded threatening, and he 6 documented that after the fact. I don't know if 7 you have that information or not.
8 Okay, I also have-- There was something 9 going on very unusual here, that this thing was 10 not delivered to the shift supervisor, let go of 11 and handled in accordance with our process, and I 12 don't understand why, but I have a letter that was 13 written on I believe the 4th by Burt, a n -3 I'm 14 trying to find it.
15 MS. SMITH: What year?
16 MR. VONDRA: 1992, December 4.
17 MS. SMITH: Okay.
18 MR. VONDRA: And, let me see if I can 19 find this. Okay, ( Perusing docLments ) "I had 20 tried to convince people to put additional 21 information on the Incident Report to help the 22 shift supervisor. That not being acceptable I 23 tried to convince people to tie the Incident g ,
24 Report to a DEF and submit it that way."
ALL POINTS REPORTING (215) 564-5380
1 l
l 69 1 MR. WHITE: The people yo's are talking 2 about here are who?
3 MR. VONDRA: The people that were in my 4 office.
5 MR. WHITE: So you're talking about 6 Craig and Williams?
7 MR. VONDRA: Yes. The next day Burt 8 Williams writes this at 10:00 A.M. on Friday, 9 December 4, 1992. It is letter to Bill Cianfrani.
10 It says, "I'm proposing for your consideration the 11 following guidelines for responding to situations 12 such as occurred last Friday when we tried to 13 discuss an IR and to issue an IR to Operations.
14 1. We should issue a DEF to resolve an 15 Incident Report."
16 They knew that for this particular 17 thing, that we should issue a DEF, but he said 18 "Not as a means of putting a genuine safety issue 19 on hold." I agree with that, - was not trying to 20 put it on hold, I was trying to follow our 21 existing processes.
22 "The point is a DEF has the effect of 23 taking the matter out of our hands." That tells
. 24 me that they were trying to control this situation ALL POINTS REPORTING (215) 564-5380
70 1 beyond which they were responsible for it and 2 interfered in the process that would normally take 3 place, and that is how this thing got to my 4 office.
5 Okay, now they could have done it out 6 of the best of intentions and after two weeks ago 7 I read the total investigation I think they did.
8 I don't think there was any malice on these men's 9 parts. I think that they just misunderstood the 10 program and was trying to do something that he 11 they believed in, but it wasn't in accordance with 12 our procedures. That is what I believe. And, 13 when I read the whole thing, the whole thing, I 14 believe that there was some really poor 15 communications, because I went into that meeting 16 with the idea that an Incident Report had been 17 submitted and we were doing information. They 18 went into the meeting with the idea that the 19 Incident Report had not been submitted but they 20 had one, and that never came out in the course of 21 going through the process. So, I felt really bad 22 about that. I should have been able to draw that 23 out somehow and maybe that would have cleared some 24 things up, I don't know, but I thought this was ALL POINTS REPORTING (215) 564-5380
71 1 going + be a very very simple exchange, where you 2 come in, you put the facts on the table, you 3 follow the procedure, and you get it done, okay, 4 and the outcome is what the outcome is, and that 5 is not how it turned out, and I think there were 6 some things that influenced it that I didn't know 7 about, had no way to know about, but I tried to be 8 as diplomatic as I could to get it done. I never 9 ever meant to harass these employees for 10 submitting a safety concern. I never ever meant 11 to intimidate these employees for submitting a 12 safety concern, but when it was all done, based on 13 where I was I had a sincere concern about these 14 employees behavior and knowledge of the procedures 15 that they were responsible for auditing and had 16 safety concerns about it, and I had a letter 17 drafted --
18 MR. WHITE: That is the next step we 19 ought to move to.
20 MR. VONDRA: I had a letter drafted.
21 MR. HETTERHAHN: The memo from which 22 Cal read to you was tab 13 of the company's 23 report, the references.
24 MR. VONDRA: Tab 13 in mine.
ALL POINTS REPORTING (215) 564-5380
l 72
]
1 MR. WETTERHAHN: So you are in 2 possession of that.
i 3 MR. WHITE: Thank you. !
l 4 MR. SMITH: That is the December 3, ,
5 1993 or December 4, 1992?
6 MR. VONDRA: December 4, 1992.
7 MR. SMITH: You also mentioned a 8 December 3, 1993 letter.
9 MR. VONDRA: I thought this was the 30 one, it was the next day.
11 MR. SMITH: So we are only talking 12 about one document?
13 MR. VONDRA: Yes.
14 MR. WETTERHAHN: No, there were two 15 documents that you referred to.
16 MR. SMITH: That is what I thought.
17 MR. VONDRA: Yes, the first one was Jay 18 Bailey's letter.
19 MR. SMITH: December 3rd, 1993?
20 MR. VONDRA: That is what it is dated.
21 I got this after the fact, a long time after the 22 fact.
23 MR. SMITH: I'm not sure we have a copy 24 of that.
ALL POINTS REPORTING (215) 564-5380
73 1 MR. WETTERHAHN: You may not. You did 2 interview Mr. Bailey. I believe his recollections 3 are consistent with his earlier statement.
4 MR. SMITH: Yes, they are.
5 MR. WETTERHAHN: Do you want to take a 6 break?
7 MR. VONDRA: Yes, I could use a glass 8 of water.
9 MR. WHITE: Off the record.
10 - - -
11 ( A brief recess was held at 11:35 A.M and 12 reconvened at 11:40 A.M.)
13 - - -
14 MR. WHITE: Back on the record.
15 MR. VONDRA: John, if I may, I would 16 like to clarify where I was at that meeting.
17 MR. WHITE: Sure.
18 MR. VONDRA: I thought I was trying to 19 implement our procedures as I understood them. I I
20 was confused by the whole thing as to why it ever 21 got to my office to begin with. I was confused as i l
22 to the position that the men had taken about this, 23 but I was convinced to go forward with the 24 investigation on the safety concerns and bring it ALL POINTS REPORTING (215) 564-5380
74 1 to a resolution for the safety of the plant. And, 2 that is really where I was at that time.
3 MR. WHITE: What about Vince Polizzi; 4 he was in this meeting also?
5 MR. VONDRA: Yes.
6 MR. WHITE: Did he add anything to it?
7 MR. VONDRA: Not much. In reality, 8 B.u r t did most of the talking. I was kind of 9 surprised Paul Craig did very little talking. I 10 tried to get him to-- I wanted some help to get 11 this to a point where yeah that is what we ought 12 to do or something, and I couldn't get anything.
13 Burt seemed to be in control of that side of it.
14 He answered everything. And sc Vincent and Jay 15 Bailey didn't say very much at all.
16 MR. WHITE: Did you get the impression 17 that Vince brought these SRG engineers down to 18 your office or that these SRG engineers wanted to 19 come down and see you?
20 MR. VONDRA: No, I had the impression he 21 brought them down to resolve the problem that he 22 was unable to resolve, and at the conclusion I ;
23 really thought we had reached similar things in I
l 24 separate offices, similar places. He, likewise, I j ALL POINTS REPORTING (215) 564-5380
.=
l 75 1 had full confidence in Vince's desire to do the i
( 2 safe and conservative thing in the operation of l
)
3 the plant, he had never demonstrated not. l 1
4 MR. WHITE: Is this a problem that you I 5 think that Vince should have been able to take 6 care of himself without your involvement?
7 MR. VONDRA: I would have thought so.
8 The end result was that I wasn't successful 9 either, so in retrospect I would say that he had 10 as misch dif ficulty as I did. Now, I know his 11 relationship after the fact. At the time I didn't 12 know that there was a problem with his 13 relationship with the SRG, and that he had 14 previously trashed an Incident Report. Regardless 15 of what his reason was, it was the wrong thing to 1 16 do, and had I known that I would have had an 17 investigation done and disciplinary action taken 18 if that was warranted. I don't think that that 19 behavior was appropriate from what I understand. ;
I 20 MR. WHITE: What was your relationship 21 to SRG? I i
22 MR. VONDRA: I thought it was pretty !
23 good. I thought I got along well with Bill and l 24 Paul. I thought that they added a lot, some of it i
ALL POINTS REPORTING (215) 564-5380 l l
76 1 was --
2 MR. OLSHAN: Do you mean Burt?
3 MR. VONDRA: Bill Cianfrani and Paul 4 Craig was his principal engineer backup, and I 5 dealt mostly with those two men, and I thought our 6 relationship was pretty good. There was many many 7 investigations that I asked them to do on issues 8 that came up in the plant from their skill, and I 9 didn't always agree with the results, but I always 10 knew that they did what they thought should be 11 done, so I felt pretty good about them, but then I 12 read the investigation of the company, and I found 13 Bill Cianfrani didn't have the same regard for me 14 after the fact.
15 MR. WHITE: Did you have an 16 understanding about what Vince Polizzi's 17 relationship with SRG was?
)
18 MR. VONDRA: No.
19 MR. WHITE: At this point?
l 20 MR. VONDRA: I didn't think it was any )
l 21 different than my relationship, okay. I had had j l
22 some complaints from people at SORC that Bill and 23 naul were not meeting the SORC principals of 24 safety issues, okay. In other words, SORC ALL POINTS REPORTING (215) 564-5380 j
77 1 requirement is to review specified material with a 2 safety hat on as to the whether or not this is 3 going to adversely effect the plant, and there 4 were some complaints that they were dragging out 5 things about stuff that were not of safety '
6 importance, voting for things no after being asked 7 if there were any safety concerns.
8 One of the things that I had instituted 9 in SORC was that before you took a vote you polled 10 the panel to see if there were any safety concerns 11 about this, nkay, because if there were a safety 12 concern and an individual had a problem we should 13 re-listen to it and try to get the consensus, then 14 we would vote, and usually unanimous at that 15 point, because before we get to a vote if there 16 was something wrong it would get thrown out by 17 consensus, and there were a lot of votes on the l l
18 SRG that were no after the fact for issues that !
19 were not safety issues, and the opinion of some of 20 the SORC, in the opinion of some of tne SORC 21 members. I defended them. I felt it was well 22 within their right to do that. I felt also that 23 the fact that they made deliberate long on some 24 issues that if any of those issues saved one ALL POINTS REPORTING (215) 564-5380
78 1 problem that it was well worth the time spent, all 2 right, and I felt their mechanism of thinking was 3 somewhat different than ours. I thought that was 4 healthy, having a different perspective.
5 MR. WHITE: So you understood what 6 SRG's role was?
7 MR. VONDRA: I think so, and I 8 supported it and I used it.
9 MR. WHITE: Operating from the open line 10 organization?
11 MR. VONDRA: Yes, and that is why I 12 called senior management when this occurred, j 13 because I thought this was significant. I was l 14 quite surprised senior management didn't feel it i
15 was as significant as it was in my mind. !
l 16 MR. WHITE: Senior management here 17 being Ed Leiden?
18 MR. VONDRA: Ed Leiden, I would say 19 Larry Reiter, and after the fact the managers. I 20 made this well known after the fact what happened, i 21 and what was done, because I thought it was l
22 significant.
23 MR. WHITE: Maybe that is the next point 24 we should move to then is the meeting; you told ALL POINTS REPORTING (215) 564-5380
79 1 these individuals to leave your office?
2 MR. VONDRA: Yes.
3 MR. WHITE: And they did so?
4 MR. VONDRA: They did so.
5 MR. WHITE: Go ahead, what happened 6 next?
7 MR. VONDRA: Everybody kind of left. I 8 called Larry Reiter and got a hold of him at Hope 9 Creek. He said he couldn't con 3 over even though 10 I explained what happened. He sent Ed Leiden. Ed 11 Leiden came over sometime. I went over what 12 happened with Ed Leiden. I don't remember if 13 Vince was there or not at that time. Nothing was 14 said, and Ed Leiden left. I called Mike Moroney, .
15 asked him to continue with the investigation and 16 make sure that it was done before he went home 17 that night. He called me that night and told me 18 he had, so I was confident that we had accepted 19 the issue and done the right thing. I also talked 20 to Vince Polizzi, and I'm not sure whether it was 21 at work, it must have been because I had to be out 22 to the training-- it was at home, I had to be at 23 the training center at 4 o' clock to go over my 24 presentation with Stan and identify if there was a ALL POINTS REPORTING (215) 564-5380 ;
l 80 1 problem and that we would talk about it more 2 later, because we had to get this done, and that 3 night when I got home I called Vince and asked him 4 to draft a letter to Larry Reiter describing what 5 occurred, okay, asking for these folks to be 6 reassigned, based on behavior and the behavior 7 there was also I think their knowledge level was 8 what I was concerned with.
I didn't really think 9 these folks knew what they were doing. I was 10 concerned. I thought here is people who audit 11 this process, and I didn't think they knew what 12 they were doing.
13 MR. WHITE: Why did you feel compelled 14 to ask Vince to do this?
15 MR. VONDRA: I was concerned about the i 1
16 next safety issue that would come to these folks !
17 as to whether or not they would do the right l l
18 safety thing for the plant, whether they would do 4 l
19 it correctly. 1 20 MR. WETTERHAHN: Was your question why 21 he asked Vince to do it?
22 MR. WHITE: Why did you feel compelled?
23 MR. VONDRA: I really felt that these 24 people had demonstrated in that meeting a ALL POINTS REPORTING (215) 564-5380 fj l
81 1 significant lack of understanding of our 2 procedures, their willingness to follow our 3 procedures and comply with our procedures, even 4 though they were independent Safety Review Group.
5 Those procedures applied to them as well.
6 MR. WHITE: Your request to Larry 7 Reiter in this letter was to have them removed 8 from this site?
9 MR. VONDRA: No, to have them 10 reassigned from Salem.
11 MS. SMITH: Why do you think he used 12 the word removed instead of reassigned?
4 13 MR. VONDRA: I don't know. Was that 14 the words in the letter?
15 MS. SMITH- Yes.
16 MR. VONDRA: I did not try to engineer 17 the letter. I read the letter, it pretty much 18 described events, and it described the behavior in 19 my mind. I probably wouldn't have used the word 20 abhorrent. I'm not -- I m sort of a small words 21 guy, but my understanding of that word is that it 22 is different, out of the usual, not normal, and 23 under those conditions I thought what occurred in 24 my office was indeed that.
ALL POINTS REPORTING (215) 564-5380
I 82 1 MR. WHITE: You mentioned your speci"ic 2 problems that you conveyed to Vince relative to 3 this letter was that you wanted to address their 4 behavior and you wanted to address--
5 MR. VONDRA: What actually occurred.
6 MR. WHITE: Their level of knowledge 7 and what actually occurred, their behavior; what 8 was the problem with their behavior in your 9 perception?
10 MR. VONDRA: They were confronted with 11 some information that was factual to the best of 12 my understanding, t. hat was necessary in accordance 13 with our procedures to have somebody do their job, 14 okay, and which was important to the safety of the 15 plant, and they were unwilling to use that in 16 accordance with our procedures, and that is what I 17 thought their behavior--
18 MR. WHITE: So that is the behavior 19 problem?
20 MR. VONDRA: Yes.
21 MR. WHITE: And the level of knowledge 22 problem?
i 23 MR. VONDRA: Was that they should have, 24 I thought they should have been the experts on ALL POINTS REPORTING (215) 564-5380
b i
83 l t
1 these procedures not people who were trying to use 2 them incorrectly, okay, since they do all of the .
3 auditing of those procedures.
4 MR. WHITE: It wasn't a technical level i 5 of knowledge, but it was knowledge of the process .
I I
G that you were having a problem with, their 7 knowledge of --
8 MR. VONDRA: Yes, this never got to a 9 point of anything about their technical ability as 10 engineers. It was they audit this process per the 11 technical specifications, they should be the -
12 experts in this process, and I felt that they !
1 13 should be wanting to follow these procedures more 14 than anybody, yet they were trying to do something 15 that I couldn't understand. That was the ,
i 16 difference. I couldn't understand why.
17 MR. LANNING: That is the point I want l 18 to pursue. Can you tell me, help me to understand
?
l 19 what they did that was contrary to procecare?
20 MR. VONDRA: The procedure says that if l
l 21 you find an off normal event, one they should have f 22 known that this was not an off normal event and an
]-
, 23 IR, and based on their knowledge of how we do 24 things they should have generated a DEF because i
! ALL POIN2S REPORTING (215) 564-5380 4-
84 1 they should have known all of the IR's of this 2 type turn into DEF's. Two, if they wanted to go 3 on with that and submit an IR:they should have 4 submitted the IR to the shift supervisor like the 5 procedures say and let it go. They should net 6 have, this is after the fact knowledge I didn't 7 have at the time, they should not have gone up and 8 said I think we'll write up an Incident Report, 9 what do you think. That is not what should 10 happen. What should happen is the person finds 11 it, goes to his supervisor, they determine there 12 is a problem, they write it up, they submit it to 13 the ser.ior shift supervisor. The senior shift j 14 supervisor then goes into our process, gets j 15 whatever information he needs to make an 16 operability reportability determination, and then ;
17 we take whatever action we deem necessary on that.
18 These folks should have let it go. I don't know 19 why they wouldn't let it go.
20 MS. SMITH: I thought at the time you )
21 said you thought they did submit the Incident 22 Report to the shift supervisor?
23 MR. VONDRA: I thought they had 24 submitted it. I thought we were at the point l I
ALL POINTS REPORTING (215) 564-5380
85 1 where the shift supervisor asked for additional 2 information. That is where we were et in my 3 office. I come to find out that is not where we 4 were. Had we been there, we might have been 5 closer to following the procedure than what we 6 were when we were in my office.
7 MS. SMITH: So what you thought they did 8 at the time was in accordance with the procedures?
9 MR. VONDRA: No, they shouldn't have 10 been there. They should have let it go.
11 MS. SMITH: That was in accordance with 12 the procedures?
13 MR. VONDRA: Yes, I did. I thought an 14 Incident Report had been generated, but I thought 15 it was very unusual that they were demanding the 16 content of that Incident Report after it had been 17 submitted. Once they submitted that Incident 18 Report they should have walked out of the picture 19 and let the process happen, but they didn't for 20 some reason. They ended up in my office. The
- 21 reason was they had not submitted the Incident 22 Report, and I didn't know that. Is that a circle 23 for you?
24 MS. SMITH: So why did you think they ALL POINTS REPORTING (215) 564-5380
86 1 were in your office then, if they had already 2 submitted the Incident Report to the shift 3 supervisor when they came to your office, why did 4 you think they were in your office? If they had 5 already done what the procedure said, which was to 6 submit the Incident Report to the shift 7 supervisor?
8 MR. VONDRA: I couldn't figure that 9 out.
10 MS. SMITH: Okay.
11 MR. VONDRA: Only that they were not 12 satisfied with the process as it is written, okay, 13 and they were trying to do something different. I 14 could not figure that out. I was confused as to 15 why they were in my office, why this first and 16 only Incident Report that ever walked in the door 17 of my office came this way.
18 MR. LANNING: I thought I understood 19 you to say that the only reason they were in your 20 office according to Polizzi was that they were 21 there to shut down the plant?
22 MR. VONDRA: I think that is what I 23 determined at the end when I got done with it.
< 24 That is how I felt. I tried to go through this ALL POINTS REPOP. TING (215) 564-5380
87 1 and give them an opportunity to understand where 2 they were, where we were, what was to be done, 3 what the procedures say, how you are supposed to 4 follow it, and at each point there was no 5 recognition that you follow this procedure or you 6 do any of this, it is that we are going to do as 7 we did and they're going to shut down the plant.
8 MR. LANNING: Let me go back to the 9 procedure.
10 MR. VONDRA: I wasn't going to shut 11 down the plant, these folks don't have the 12 authority to shut down the plant, and I know that,
- 13 and these folks don't make operability 14 determinations either, and I know that.
15 MR. LANNING: I want to go back to the 16 basis of the memo and procedural violation you 17 think they didn't adhere to. I'm still confused 18 as to what about your procedure that they did not 19 follow?
20 MR. VONDRA: At that time the procedure 21 says that if you submit an Incident Report, and 22 this is where I was, they submitted an Incident 23 Report to senior shift supervisor, if he needs 4 24 help getting that information that that ALL POINTS REPORTING (215) 564-5380
88
)
1 information be given to him and be put on the 2 Incident Report. ,
1 1
3 Secondly, the other procedure was that ;
l i
4 it was explained to them, and they should have 5 known that an Incident Report was not really the 6 appropriate mechanism.
7 MR. LANNING: That latter part is not a 8 violation of procedure, you indicated earlier you 9 could go either way?
10 MR. VONDRA: I would process that 11 either way, but these folks are not custodians,
! 12 they're engineers who are responsible for auditing 13 the Incident Report process. These are experts.
14 They know all of the other configuration type 15 Incident Reports get voided and ccnverted to 16 DEF's. That is what happens, okay, and they 17 should have been willing to accept the DEF as an 18 r.ppropriate mechanism for resolving the situation 19 in accordance with our procedures. It says it is 20 applicable to all nuclear department employees.
21 MR. LANNING: That is not contrary to 22 your procedures?
23 MR. VONDRA: That was not contrary?
24 MR. LANNING: By them submitting an IR ALL POINTS REPORTING (215) 564-5380
89 1 report is not contrary to your existing ;
2 procedures, your being PSE& G procedures?
3 MR. VONDRA: And I didn't have a 4 problem with it. I said that I did not have a 5 problem with them submitting an IR, and I thought 6 we were at a point where we were getting 7 additional information for that IR.
8 MR. LANNING: But your procedure also 9 doesn't require the IR submitter to provide 10 additional information?
11 MR. VONDRA: Didn't expect them to.
12 MR. LANNING: Well, it is my
! 13 understanding that you were expecting them to adC 14 information based or, conversations and other 15 information with other members of your staff?
l 16 MR. VONDRA: No. I thought we were 17 going to add the information and that they were 19 not going to allow it. They did not want that l l
19 information added to the IR that they submitted. I 20 MR. LANNING: But their procedures 21 doesn't give them any authority or a right?
22 MR. VONDRA: Absolutely.
23 MR. LANNING: Over that? l 24 MR. VONDRA: I agree, l
ALL POINTS REPORTING (215) 564-5380
1 90 l 1
1 MR. LANNING: So I'm still trying to go )
( 2 back and understand why you think they violated j
l 3 your procedure?
4 MR. VONDRA: Because they know that the i
5 procedure says that we are supposed to provide 6 that information to the shift supervisor and they 7 were obstructing us from being able to do that or 8 trying to obstruct us from being able to do that.
9 MS. SMITH: So the failure to provide 10 the additional information is what you are feeling 11 is--
12 MR. VONDRA: --Contrary to procedure.
13 MR. WHITE: How did they obstruct that?
14 You had the information, is that not correct; you 15 had everything you needed?
16 MR. VONDRA: Then why did they walk out 17 of my office? I don't know. I'm telling you I 18 have a document here that says that they didn't 19 want to let control of this go. There was 20 something going on here, more than meets the eye.
21 It wouldn't have ended up in my office if it 22 didn't.
23 MR. WHITE: But ultimately the only 24 person, only group, organization, that has any ALL POINTS REPORTING (215) 564-5380
91 1 effect on operation of the plant is you. The 2 plant would not be shut down without your 3 authority?
4 MR. VONDRA: Yes.
5 MR. WHITE: You were in control 6 regardless of whether they understood the process 7 or not?
8 MR. VONDRA: Within my organization 9 there are people that have the responsibility to l 10 shut that plant down under conditions without my 11 direct approval but they have my indirect 12 approval.
i 13 MR. WHITE: I understand that, I 14 apologize for that. Regardless of whether they 15 und(2 stood the procedure from your perception or 1
16 not, regardless of whether or not they agreed with ;
17 the fact that this other information that your 18 staff had gleaned from the FSAR and from the walk 19 down of the system, regardless of the fact that 20 they didn't want to recognize that; what
. 21 difference did it make to you ultimately, what 22 difference would it have made?
23 MR. VONDRA: It didn't make any
, 24 difference except I'm here. I continued with the l ALL POINTS REPORTING (215) 564-5380
92 1 acceptance of the issue and the investigation of 2 the issue in accordance with our procedure to the 3 best of my ability, but there had to be a closure.
4 These guys walked into my office, there was 5 something that they wanted. I tried to 6 accommodate them and bring out that information 7 and understand them, reached a point where we 8 c.ouldn't get accommodation. At that point I felt 9 they threatened me to get it another way, all 10 right, but that didn't deter me from doing my 11 responsibility, to investigate and to accept this 12 thing and to get it done. It wouldn't. My i
13 responsibility is the safety of that plant, and 14 that is where it lies. That is what I did. f I
15 MR. WHITE: Okay, so after they left
)
16 your office you had a perception that their l 17 behavior was inappropriate?
18 MR. VONDRA: Extremely abnormal, I got 19 to tell you.
20 MR. WHITE: They failed to displace a 21 level of knowledge relative to how the process 22 worked in accordance with your understanding of 23 the policy?
24 MR. VONDRA: That is right.
ALL POINTS REPORTING (215) 564-5380
. 93 1 MR. OLSHAN: Was their threat to you 2 part of the reason you had that letter written?
3 MR. VONDRA: Yes. I thought that was 4 very inappropriate to try and get me to do 5 something wrong by threatening me with another 6 process. I thought that was very much wrong.
7 MR. WHITE: Why did you perceive that 8 as a threat?
9 MR. VONDRA: I thought they wanted me 10 to change my mind and shut down the units. I felt 11 they wanted the units shut down for some reason.
12 I think they were sincere about it. In retrospect i 13 I think they really wanted the units shut down.
14 They believed that they needed to be shut down, 15 and I believed that not enough investigation had 16 been done to warrant that at that point, but some 17 information was available to warrant that maybe it 18 did need to be done, and all I wanted to do was 19 get the facts out to the right people in my 20 organization to make the right decision.
21 MR. WHITE: Are you still angry? I 22 guess you were still angry when you were at home 23 and called Vince Polizzi?
24 MR. VONDRA: Was I still angry? No, I ALL POINTS REPORTING (215) 564-5380
94 1 don't think I was angry.
2 MR. WHITE: So you were thinking 3 coherently? I take that back, you were not, you 4 were in control of your emotions when you called 5 Vince?
6 MR. VON 9RA: Yes. I think what I was 7 really cor cerned about was future safety issues 8 and whether or not they would be handled right.
9 Again, you know, my life has been around nuclear 10 plant safety, and it is in all of the decisions 11 that you make.
12 MR. WHITE: So, when you called Vince 13 and asked him to draft t h 2. s letter and you gave 14 him some perceptions of what you wanted to include 15 in that letter I take it?
16 MR. VONDRA: Yes.
17 MR. WHITE: You knew exactly what you 18 were doing, what you were asking Vince to do?
19 MR. VONDRA: Yes.
20 MR. WHITE: You knew what you were 21 requesting that these guys, whether or not your 22 intent was to say removed or not, your request was 23 I don't want these SRG engineers on my site?
l 24 MR. VONDRA: For reasons of future ALL POINTS REPORTING (215) 564-5380
95 1 safety considerations that they may get involved 2 with. It wasn't that I, Cal Vondra, didn't want 3 them there. As a matter of fact, I could have 4 seen Burt Williams tomorrow and not been upset 5 with him, but that wouldn't change my opinion that 6 this person didn't really know his job as well as 7 he should, and I was concerned if a real safety 8 thing come up whether or not he would recognize it 9 and take the right action.
10 MR. WHITE: Is there anything else you 11 could have done other than write this letter? I'm 12 not saying that the letter wasn't appropriate, but 13 is there any other action --
14 MR. VONDRA: I was trying to raise this 15 issue to the attention of senior management. This 16 letter, as far as I was concerned, was to remain 17 confidential. I thought I could trust Vince to 18 write the letter and give it to me for my 19 signature and this letter would go to Stan 20 LaBruno, Stan Miltenberger, and Larry Reiter only, 1 21 and that it would escalate this issue to the 22 attention of senior management. I had nothing i
23 here to hide. I felt I was doing all of the right I 24 things. I thought I was following the procedures.
^
l ALL POINTS REPORTING (215) 564-5380 1
l l
96 1 I thought I had a problem with some people's 2 behavior, I didn't think that -- I had no concern 3 with the issue, the issue would get done and 4 follow through.
5 MR. WHITE: When you asked Vince to 6 draft this letter did you also indicate to him 7 that you would consider this letter as 8 confidential?
9 MR. VONDRA: I don't know. I think it 10 was understood that it is confidential.
11 MS. SMITH: Why did you think it was 12 important for senior management to know about 13 this?
14 MR. VONDRA: I think you, the SRG group 15 should be a group staffed with the best people you 16 got. They're going to help you out, and that when 17 line management and SRG are at different issues 18 there is something wrong, and I thought senior 19 management should be aware of that and should be 20 pursuing a resolution, because I was trying to.
21 So, there is something wrong there when you get to 22 that, that is not right. These guys should be the 23 best people that you got and should be the most 24 knowledgeable people that you have. I was ALL POINTS REPORTING (215) 564-5380
i i
l 97 l 1
1 concerned that they weren't.
2 MR. OLSHAN: Instead of removing them 3 from their position did you consider training them j 4 or giving them counseling'and letting them stay 5 there? l 6 MR. VONDRA: I thought the letter would 7 give Larry Reiter and I to get together and come f 8 up with some way to resolve this. l 9 MR. WHITE: I want to jump in here. !
10 Let's move in steps. What happened next? j l
11 MR. VONDRA: Okay, the next morning I l l
12 rode up on the train to Newark with Stan LaBruno.
- 13 I told him pretty much in detail what happened. I ;
14 think my recollection of the report says he j 15 doesn't remember a lot, I'm pretty confident I ;
i 16 told him everything that happened, and I told him l 17 I had a letter being drafted, and he didn't seem I l 18 expect more of a response than what I got. ,
19 MR. WHITE: So you told Stan you had a
- 20 letter being drafted asking that these individuals i >
l . 21 be removed, so Stan was aware of that at that s
22 time? ,
i I- 23 MR. VONDRA: Yes. ;
[
- 3 24 MR. HOLODY
- Did you give him a reason? v ALL POINTS REPORTING (215) 564-5380 {
98 MR. VONDRA: Same one I gave you, I l 1
2 , didn't think they were capable of doing the proper 3 safety things. I was concerned about it because 1 4 they didn't follow -- j I
5 MR. HOLODY: I heard that before. Was 6 that because you felt that they were a threat to 7 the site, a safety concern being on the site?
8 MR. VONDRA: I thought that a 9 significant safety issue could show up and they 10 would not recognize it as such. I didn't think 11 that they -- I was concerned that they did not 12 know what they were doing.
13 MR. HOLODY: Was it limited to that? )
1 14 MR. VONDRA: Was it limited to that?
15 MR. HOLODY: Was that the basis for the ,
16 letter?
l 17 MR. VONDRA: Their behavior in my 18 office, okay, and, yes, I think that is it, their 19 behavior, and then how they acted with our l
20 procedures.
21 MR. HOLODY: And you passed that, 22 basically those concerns on to Mr. LaBruno?
23 MR. VONDRA: Yes.
- 24 MR. HOLODY
- On the train ride up?
ALL POINTS REPORTING (215) 564-5380
. 99 1 MR. VONDRA: Yes.
2 MR. WHITE: Yout letter was directed at 3 both Williams and Craig?
4 MR. VONDRA: Yes.
5 MR. WHITE: You believe that based upon 6 this one meeting that you had with them and the 7 way they behaved in that meeting you had the 8 perception now that these individuals, and I don't 9 want to put words in your mouth, but had 10 demonstrated to you a behavior that you now 11 believed was questionable and that they could not 12 be relied upon to perform adequately?
i 13 MR. VONDRA: That was a concern. My 14 issue now, remember I said Paul Craig didn't say 15 much, but he was in the role then of SRG
'a management, and I thought he should have spoke up.
17 MR. WHITE: Your perception of Craig up 18 to this time, as you indicated earlier, he pushed 19 details, he was reasonable, you had a good feeling 20 about Craig and his behavior?
21 MR. VONDRA: Yes.
22 MR. WHITE: Up to this meeting?
23 MR. VONDRA: Yes.
- 24 MR. WHITE
- This meeting changed that ALL POINTS REPORTING (215) 564-5380
100 1 perception of Craig as well as Williams; is that 2 right? i 3 MR. VONDRA: Yes. Also, that Paul Craig 4 knetw that the DEF was the right thing to do. He 5 even had one partially filled out, yet when I 6 brought that up in my office there was no mention 7 on his part that he knew that. Now this came out !
8 after the fact. It has a bearing on why I for 9 such a long time felt that I was right on this 10 process, was that he knew that the DEF was the 11 right thing to do. He had it filled out and he 12 could have offered it and he could have directed !
I t 13 it. Burt knew that this was inappropriate 14 mechanism to use here, but he didn't, he didn't 15 say anything, and Burt the next day knew that the 16 DEF was the right thing to do. He said so in his 17 letter, but he didn't want to lose control. There 18 was more going on here than there has been with 19 any Incident Report I ever dealt with before.
20 This was not -- because the rest of them you can't 21 process 800 to 1200 of these a year and not say 22 that there was something different about this one, 23 when you in the course of my life I must have 1
24 dealt with four or five thousand of them.
ALL POINTS REPORTING (215) 564-5380 N
i 1
1 101 1 Something was different about this, and it wasn't 2 something that I broke out of the side here to 3 make it different. It happened that way. It came 4 into my office. I tried to resolve it in 5 accordance with our procedures and I failed. I 6 take that seriously. I lost my temper and I 7 should not have, and I kicked those guys out of my 8 office, I should not have, and I was unable to 9 convince those guys that the right way to use our 10 procedures, and I should have been able to, and I 11 know that, but I couldn't and I tried. Other 12 people believe that they could and maybe they 13 could. I wish I could have.
14 MR. LANNING: You indicated that the 15 threat to file a safety concern was part of your 16 motivation for issuing the letter. To me employee 17 threatening, their removal from the site, for 18 filing a safety concern report could be construed 19 by other people on the site as if you make one 20 such a report you're going to be removed. I would 21 guess that that is contrary to the purpose of the 22 program and why it exists?
23 MR. VONDRA: I was not trying to have 24 them removed for filing a safety Incident Report.
ALL POINTS REPORTING (215) 564-5380
102 1 That was not the issue at all, and I was not 2 trying to make this common knowledge throughout 3 the organization. I was trying to resolve a 4 difference of how I thought somebody else's 5 employees had behaved to me in reporting it back 6 to that person and asking him to take action, and 7 I thought the appropriate action was to not have 8 them involved with me in the future, because I was 9 concerned about their capabilities, but not i
10 because they submitted a safety concern. Anybody !
l 11 has a right to do that any time, and I have an 12 obligation to follow through on it and would do l
13 that. If they run it to the plant managers they 14 run the risk of getting thrown out of the office.
15 That is what occurred here. Hundreds of people i
16 come in and out of my office every week and don't l 17 get thrown out of my office.
18 MR. LANNING: How many of them are 19 proposing to complete a safety concern report? l 20 MR. VONDRA: None. But how many of 21 them bring up issues dealing with safety and 22 decisions that had to be made like shutting down 23 the plant when you have inoperating diesels all of 24 the time? The fact that the Incident Report ALL POINTS REPORTING (215) 564-5380
103 I doesn't give the information about that and the 2 need to take action does --
3 MR. HOLODY: Where these people on your 4 staff that come in.
5 MR. VONDRA: Anybody. Engineering 6 people.
7 MR. HOLODY: What generally occurred 8 was the majority, your staff that would come into 9 your office or were there a fair number of times 10 outsiders that would come in?
11 MR. VONDRA: The thing that was in the 12 paper the other day, it was in the Salem Sunbeam, 13 probably not a big paper around here, but they 14 talked about cooperation between the Diablo Canyon 15 and Salem with having a problem with Allstate 16 Protection System and involving us. That is not 17 the first time that happens. An engineer had read 18 something and come in to my office and said Cal, 19 we have a problem here. We investigated it, and 20 it requires us to shut down the plant. It 21 happens. It happens more often than I would like 22 it to, but that is what you do when that happens.
23 MR. OLSHAN: In retrospect, you said 24 you regretted the fact that letter had become ALL POINTS REPORTING (215) 564-5380 l l
l
104 1 public?
2 MR. VONDRA: Yes.
3 MR. OLSHAN: Is that the only regret 4 you have about that letter?
5 MR. VONDRA: Yes, it is the only regret 6 I have.
7 MR. OLSHAN: Would you have written 8 that letter and have the guys removed from the 9 site but in somewhat a less conspicuous matter?
10 MR. VONDRA: If I had to do it over 11 again, I wouldn't write the letter.
12 MR. OLSHAN: Why not?
13 MR. VONDRA: Because having written the 14 letter it becomes an instrument that is a lot more 15 powerful than I ever intended it to be. I could 16 have tried to talk to senior management and their 17 organization and mine about it without having 18 written the letter.
19 MR. HOLODY: What do you mean when you 20 say it became more powerful? What did you intend, 21 and what happened beyond what you intended?
22 MR. VONDRA: The investigation of that 23 letter that I read from the company indicates that 24 that letter is physical proof of my intent to i
ALL POINTS REPORTING (215) 564-5380 ,
i l
105 1 harass and intimidate these employees, when in 2 reality that letter to me was physical proof that 3 I was trying to do the safe thing with regard to 4 the station in the long term and was trying to 5 bring the issue to senior management's attention.
6 Had I not written the letter, it could not have 7 been interpreted to be that, but I did feel that 8 something needed to be done. Something was wrong 9 that it ended up where it did.
10 MR. HOLODY: You retracted this letter?
11 MR. VONDRA: Yes.
12 MR. HOLODY: Why did you do that?
13 MR. VONDRA: I looked at where I was in 14 my office with these folks, and I felt I was 15 providing them with a lot of information and they 16 refused to take it. In retrospect after that, I 17 was being provided with a lot of information and I 18 wasn't going to refuse to take it. I was provided 19 with information that my actions, although not 20 intentional, could have and maybe did violate 50.7 21 and that was never my intent. And so, with that 22 plus many experts telling me that my letter was 23 the wrong thing to do I took their advice and 24 retracted it, because I did not want to not accept ALL POINTS REPORTING (215) 564-5380
106 1 the professional advice I was given. I believe 2 that these folks know what they're talking about.
3 MR. HOLODY: So you retracted it 4 because someone told you to do it?
5 MR. VONDRA: It was the right thing to 6 do, yes, sir. I believe strongly that I was doing 7 the right thing. You got to understand that. I 8 thought I was doing the right thing. I was not 9 harassing you. That letter, I was not harassing 10 these folks but I was concerned about the long 11 term safety of my plant and was trying to do the 12 right thing not harass them. Harassing to me i 13 seems to be a long term issue. You call people up 14 on the phone 15, 20 times. I was not harassing 15 anybody. I was just trying to do the right thing.
16 MR. OLSHAN: In retrospect you said you 17 wouldn't have written the letter?
18 MR. VONDRA: No.
19 MR. OLSHAN: Would you still have tried 20 to have those gentlemen removed from the site?
21 MR. OLSHAN: Personally what I would 22 have liked to have happened is when I called Larry 23 Reiter he came over to my office when this whole 24 thing started, and I think it could have had a ALL POINTS REPORTING (215) 564-5380
107 1 different outcome, but in lieu of that I would 2 have liked to have been able to talk to Larry and 3 tell him what happened, and hopefully we could 4 have reached some conclusions as to what the right 5 thing to do was, and maybe someplace along there 6 somebody would have told me about 50.7 and some of 7 this other stuff I didn't know about.
8 MR. LANNING: Did any of your staff try 9 to convince you not to send the letter out prior 10 to the ultimate time where senior management 11 intervened?
12 MR. VONDRA: Yes. l I
' MR. LANNING: Can you share with us why 13 14 you didn't take that opportunity or why you felt 15 strongly enough to continue with the letter?
16 MR. HOLODY: And can you tell us who j 17 tried to talk you out of doing that?
18 MR. VONDRA: Okay, after the 19 presentation on Impo I was flown by helicopter i
20 back down to the site to give the results to my '
21 managers, and I did that. I was due to go on 22 vacation that night, so I went over the Impo 23 results, Vince came in my office before I left and 24 gave me a draft of the letter, and I think I ALL POINTS REPORTING (215) 564-5380
I 108 1 changed a couple of words, but only on the front 2 page, nothing to do with the abhorrent behavior 3 which I know is an issue, before and I signed the 4 back page of the letter. I think he corrected 5 those two things. I gave the letter to transmit.
6 When I got back from vacation about ten days, all 7 right, Vince came to me and said he did not send 8 the letter, he thought that I might want to 9 reconsider, and so he gave me the letter. That 10 was probably one of the worst mornings of my life.
11 I came back Monday morning, and I found out that 12 Sunday night we had an enunciator system total 13 failure, and by the end of the day AIT was coming, 14 and I finally got around to looking at the letter, 15 I reflected about my feelings at the time I left, 16 what they were then and what they were now, and I 17 still felt that these folks, their knowledge level 18 and behavior was wrong, so I sent the letter, and 19 I signed the letter and put it in a manila 20 envelope with two copies attached to it and gave 21 it to my secretary to forward, and I believe that 22 it was the right thing to do.
23 MR. WHITE: It then went to Larry 24 Reiter?
ALL POINTS REPORTING (215) 564-5380
109 1 MR. VONDRA: No, it didn't. My 2 secretary took the letter and issued a copy to Mr.
3 LaBruno and Mr. Miltenberger, and she thought the 4 folder was empty and never sent the original, 5 Larry Reiter I guess got the letter a long time 6 after the fact from Steve Miltenberger.
7 MR. WHITE: Once you sent the letter 8 did you get any feed feedback from any of those 9 people who it was distributed to?
10 MR. VONDRA: No Stan knew about the 11 letter, told me I should get it resolved. I also 12 asked Jules Hagan before I sent the letter. He
' 13 was the General Manager at the time at Hope Creek.
14 I told him what happened. He recommended I not 15 send the letter, just the fact that I was -- he 16 thought that it was the wrong thing to document on 17 paper and recommended that I not send it, but I 18 really felt strong about my beliefs and I thought 19 for the safety of the plant it was the right thing 20 to do long term, and I sent it.
. 21 MR. WHITE: When did anybody ever 22 contact you about this letter?
23 MR. VONDRA: Larry Reiter called me in 24 mid December time frame to talk about this, a ALL POINTS REPORTING (215) 564-5380
110 1 couple of days after he got back from vacation, 2 and--
3 . MR. WHITE: Was he aware of the letter 4 at that time when he called you?
5 MR. VONDRA: He was aware of the letter 6 but I didn't know he didn't have a copy.
7 MR. WHITE: He was aware that you 8 r.equested that these individuals be removed from 9 Salem?
10 MR. VONDRA: Yes, and I was not aware 11 that Vince Polizzi had discussed the content of 12 this letter when I signed it at a SORC sometime 13 when I was on vacation. I never intended for that 14 to happen, but that happened. Anyhow, Larry 15 contacted me and we set up a meeting to get 16 together with the managers to discuss the 17 relationship of SRG and the plant. And I went in 18 there with the sincere desire to resolve this and 19 I was hoping that we could, and Larry came in and 20 started talking, and Vince lost his temper and 21 left the room, which I thought was totally 22 inappropriate. He accused Larry of not wanting to 23 take the right actions and some other things that 24 I thought was inappropriate, so I left the room ALL POINTS REPORTING (215) 564-5380
111 1 and called Vince Polizzi up told him to get down 2 in my office. I talked to him, brought him back 3 into the meeting, had him apologize, then we 4 listened to Larry and had feedback. A lot of the 5 rest of the managers had issues that came out at 6 that time with the demeanor of the SRG and some of 7 the things that they didn't like, and in some ways 8 I thought that was healthy. In other ways I was 9 surprised that there was so much discontentment 10 with that group.
11 MR. WHITE: Why did Vince lose his 12 temper at this meeting?
13 MR. VONDRA: He thought Larry had no 14 intention of taking any real action to correct the 15 issue.
16 MR. WHITE: Was this letter discussed 17 at that meeting?
l 18 MR. VONDRA: Not really, I don't think 19 so. ,
i 20 MR. WHITE: Was the issue of whether or i 21 not these individuals should be removed from Salem 22 discussed at that meeting? 1 23 MR. VONDRA: I think more the issue as 24 to whether or not anything should be done, period, j l
ALL POINTS REPORTING (215) 564-5380
112 1 not anything specific to be done. In other words, 2 the issue there was whether or not any action 3 should be taken at all. Okay, and if any action 4 was to be taken, what might be appropriate. So, 5 it was more generalities rather than specifics.
6 Nothing was resolved at the meeting.
7 MR. WHITE: That meeting?
8 MR. VONDRA: Nothing was resolved. I 9 wanted to escalate the issue to Mr. Miltenberger 10 and Larry didn't want to. I was still concerned 11 that it was a significant issue and wasn't being 12 given consideration that it should, and so then 13 eventually, you know, we got tied up in AIT and 14 this kind of less and less frequently.
15 MR. WHITE: Did you-- You and Larry 16 Reiter have any more conversations about this 17 letter?
18 MR. VONDRA: Yes, there were a few more 19 conversations and meetings and attempts to reach a ;
1 20 decision as to what to do.
21 MR. WHITE: Did you ever specifically 22 discuss with Larry Reiter whether or not he was )
l 23 going to have -- ,
1 l
24 MR. VONDRA: Yes, he said he would not l
ALL POINTS REPORTING (215) 564-5380
213 1 remove them. He said it was the wrong thing to 2 dc.
3 MR. WHITE: Did he ask you to retract 4 this letter?
5 MR. VONDRA: Yes.
6 MR. WHITE: And did you?
7 MR. VONDRA: Yes, when he asked me is 8 when I retracted the letter.
9 MR. WHITE: When he asked you?
10 MR. VONDRA: Yes.
11 MR. WHITE: The first time?
12 MR. VONDRA: Yes.
13 MR. WHITE: And by retracting the 14 letter then --
15 MR. VONDRA: But that was quite a long 16 ways down the road when he asked me about 17 retracting the letter.
18 MR. WHITE: When you retracted the 19 letter, is that essentially you vacating your 20 position on the need to remove these individuals 21 from Salem operations?
22 MR. VONDRA: Yes.
23 MR. WETTERHAHN: Did you come to that 24 conclusion before that time?
ALL POINTS REPORTING (215) 564-5380
114 1 MR. VONDRA: The preponderance of the 2 evidence was I was probably as much entrenched in 3 my spot as other folks were entrenched in theirs.
4 I recognized that I was getting a lot of feedback 5 telling me that my actions were not appropriate 6 either, okay, so, I felt that it was the right 7 thing to do. When you get a lot of people you 8 respect telling you that hey, this is not right, 9 then I got to start reflecting on let the emotions 10 go and you started going back on your logic about 11 where you are and what is the right thing to do.
12 MR. WHITE: What happened, you had Vince 1
13 Polizzi telling you I don't think you should send 14 this letter, you had Joe Hagan, someone who I take 15 it that you respected their opinion, telling you 16 don't send this letter, and you did it anyway?
17 MR. VONDRA: Yes. At that time they 18 felt that it was the right thing to do.
19 MR. OLSHAN: Today you say the only 20 thing that was wrong about it was that it became 21 public, that you still would have taken the same 22 actions to remove the people from the site?
23 MR. VONDRA: No, I think I would have 24 taken the action to talk to Larry Reiter and tell ALL POINTS REPORTING (215) 564-5380
115 1 him what happened and see what we should do about 2 it rather than being prescriptive about the 3 actions that should be taken.
4 MR. OLSHAN: What actions would you 5 have thought would have been appropriate between 6 you and Larry Reiter? In other words, you are 7 saying you would not have asked Larry to remove 8 those people from the site?
9 MR. VONDRA: I would have left it up to 10 Larry. I asked him in the letter to remove them 11 from the site, but I think had I not sent the 12 letter and talked to Larry about it and went over 13 I would have said what do you think is the right 14 thing to do? And hopefully maybe things would 15 have come out differently. I didn't want -- I was 16 not interested in a pound of flesh from these guys 17 or anything like that. I was really interested in 18 the safety of the plant. I had a concern still at 19 that time that the folks were not doing things 20 right.
21 MR. OLSHAN: You were interested in the 22 safety concerns of the plant; what could Larry 23 have told you short of removing these people from i 24 the site that would have convinced you to leave ALL POINTS REPORTING (215) 564-5380
116 1 them--
2 MR. VONDRA: For instance that I 3 totally misunderstood the situation that had gone 4 on in my office and that there was a 5 miscommunication, that they were not trying to 6 shut down the plant, that they were sincerely 7 trying to follow the procedures as they understood 8 them and you could interpret the procedures 9 somewhat in their direction.
10 MR. OLSHAN: You don't believe that 11 today, do you?
12 MR. VONDRA: I believe they sincerely 13 telt that, I do. When I read their report two 14 weeks ago, I sincerely believe that those folks 15 thought they were doing the right thing for the 16 wrong reasons in my mind.
17 MR. OLSHAN: But you today think they 18 really wanted to shut the plant down?
19 MR. VONDRA: Oh, I think they did, and 20 I think they had valid reasons to do that in their 21 own minds. I think they wanted to shut the plant 22 down, but I think they sincerely believed that it 23 was the right thing to do. At that time I didn't.
24 I didn't believe that they felt that it was the ALL POINTS REPORTING (215) 564-5380
i 117 ;
1 right thing to do, and I felt they knew better 2 than that, there was some other motive for doing 3 it, but after reading the complete investigation 4 and reading what Burt and Paul and everybody said 5 I think they were sincerely trying to do the right 6 thing in their mind but I didn't know that. All I 7 knew was the stuff I knew at the time, and even 8 after reading executive summary I didn't get that 9 information. It wasn't until I requested to read 10 the whole investigation that I got that feeling.
11 MR. OLSHAN: So you think it is likely 12 that Larry could have convinced you of that a i 13 couple of weeks after the incident?
14 MR. VONDRA: Yes, I do.
15 MR. LANNING: Prior to retracting the 16 letter, were you aware that it had been discussed 17 at the SORC meeting?
18 MR. VONDRA: No.
19 MR. LANNING: Had any of the other 20 direct reports and you discussed the letter?
21 MR. VONDRA: Mark Shedlock indicated in 22 the testimony that I read that I had prevented 23 that at a SORC meeting, okay, which was totally
< 24 not true. And, that is the only thing that I know ALL POINTS REPORTING (215) 564-5380
118 1 about that. Some discussions came up about it, 2 but nothing that I acknowledged or took action on 3 with anybody.
4 MR. LANNING: At the time is it fair to 5 say that the letter was probably general 6 knowledge, at least among your managers and 7 supervisors?
8 MR. VONDRA: I think after the fact I 9 would have to say that this is true based on Vince 10 having disclosed the contact to them, okay, and 11 also at some point Bill Cianfrani came up into my 12 office and requested a copy of the letter. And at i l
13 that time I still thought it was confidential, and i
14 I told them that was a letter from me to Larry 15 Reiter and that is Larry Reiter's letter, and if 16 he wants a copy of it he needs to get it from 17 Larry, okay. I didn't feel it was appropriate for l 18 me to be giving that out.
19 MR. LANNING: But the two individuals, 20 Craig and Williams, reported to Cianfrani, right?
21 MR. VONDRA: Correct.
22 MR. LANNING: He was, in fact, their 23 immediate supervisor?
24 MR. VONDRA: And Larry Reiter was his ALL POINTS REPORTING (215) 564-5380
~
119 i
^
-6 1 immediate supervisor. If Larry Reiter wanted him 2 to have a copy of the letter, that was up to Larry l I
- . 3 Reiter. I didn't want that letter distributed to l 4 anyone other than Mr. Miltenberger, Mr. LaBruno, f
- ?
5 Larry Reiter, Vince Polizzi, and Cal Vondra. That i
2 6 is where I wanted that letter contained. I didn't t
7 want it to go out to the general knowledge of i
1 8 anyone, and I felt that Bill Cianfrani needed a !
e 5 i
) 9 copy of that letter he could go to his boss and l l l 10 get it. Bill Cianfrani didn't work for me, he l
! 11 worked for Larry Reiter, and I think if Larry l 1 .
]
12 Reiter wanted to give him a copy it is up to Larry I <
j 13 not Cal. I didn't think I should give them that I l
ll 14 letter. ;
l i
- 15 MR. WHITE
- You indicated earlier, Mr.
$ 16 Vondra, that at the time this was taking place i
j 17 your understanding of 50.7 was that it related 18 just to individuals who have brought issues to the i
l 19 NRC and prevented harassment or intimidation --
I 20 MR. VONDRA: Yes. The only examples I
- 21 heard where people had brought issues to the NRC.
22 They went back to go their company and their j 23 company fired them, okay, and I think in Missouri
- 24 Calloway was one, that is the only example that I l
i ALL POINTS REPORTING (215) 564-5380 l
- - - - ___A
120 1 knew. I thought this was only applicable and as 2 presented in our annual requalification program 3 that is how it was presented. It was presented as 4 an NRC whistle blowers issue. Not as I understand 5 it now.
6 MR. WHITE: You have a lot more 7 understanding now of this entire case you read --
8 MR. VONDRA: Absolutely.
9 MR. WHITE: You know what has 10 transpired?
11 MR. VONDRA: Yes.
12 MR. WHITE: What is your perception now 13 in terms of what you now understand about 10 CFR 14 50.7 related to the actions that you took relative 15 to these individuals; do you believe that you 16 violated 10 CFR 50.77 17 MR. VONDRA: Well, yes I would have to 18 say as I understand the law and as it was 19 presented to me that I did violate 50.7 but I 20 didn't do it knowingly, I didn't do it to stop 21 safety issues from being generated. I 22 inadvertently did it. I thought I had a behavior 23 issue with some employees that reported to another 24 department, and that was my concern, and not that ALL POINTS REPORTING (215) 564-5380
\Y
121 1 I knowingly was trying to stop safety issues from 2 being brought up or the other part about a 3 chilling effect on the whole organization. I 4 never heard of that until February or March '93, 5 of chilling effect on the organization on safety 6 concerns.
7 MS. SMITH: Who provided the training 8 on the 50.77 9 MR. VONDRA: After the--
10 MS. SMITH: Not after the fact before 11 this incident occurred?
12 MR. VONDRA: Oh, it was.
13 MS. SMITH: You said it was provided at 14 the annual requalification program?
15 MR. VONDRA: Yes, but that covers 16 everything. That is what you have to do to get 17 unescorted access into the site. This was one 18 sentence out of all of the radiation requirements 19 that you have to know, and the tagging 20 requirements.
21 MS. SMITH: So there was no lecture in 22 front of the class that went over this in great 23 detail?
, 24 MR. VONDRA: No.
ALL POINTS REPORTING (215) 564-5380
123 1 MS. SMITH: There was something written 2 in the materials?
3 MR. VONDRA: In the book that you read 4 before you take the exam?
5 MS. SMITH: When you discussed this 6 with Vince Polizzi and Joe Hagan and perhaps 7 others before you sent the letter did they discuss 8 50.7?
9 MR. VONDRA: No.
10 MS. SMITH: Did they get involved?
11 MR. VONDRA: No, I don't think anybody 12 in our -- we had not had any exposure to 50.7 at 13 the island really at that time, I don't think 14 anybody did. If you want to know my honest 15 feeling, I think I was at the meeting when some 16 lawyers from our company presented 50.7 detail to 17 myself, Mr. Miltenberger, Stan LaBruno, and some 18 others.
19 MS. SMITH: When was that?
20 MR. VONDRA: Sometime in February or 21 after Mr. Doherty received the letter from Burt 22 Williams.
23 MS. SMITH: February of what year?
24 MR. VONDRA: '93.
ALL POINTS REPORTING (215) 564-5380
. 123 1 MR. WHITE: When you sought advice, for
( 2 example from Joe Hagan on this letter, I take it 3 you let him read this letter?
4 MR. VONDRA: No, I told him the content.
5 MR. WHITE: So, you told him what you 6 intended to do?
7 MR. VONDRA: Yes.
8 MR. WHITE: Did he discuss his 9 perception of this with you?
10 MR. VONDRA: It wasn't a long 11 conversation. It was he just recommended not l 12 doing it.
t 13 MR. WHITE: Did he give you any reason 14 for why?
15 MR. VONDRA: Yes, he thought I would 16 end up where I am.
17 MR. WETTERHAHN: Why?
18 MR. VONDRA: Because he thought having 19 the letter documented, his issue was documenting 20 the letter was the wrong thing to do. You could 21 do the same thing by talking to people, that by !
22 documenting the letter you are leaving yourself 23 vulnerable, but I felt I still had a safety 24 concern about the performance of individuals, and ALL POINTS REPORTING (215) 564-5380
124 1 I was trying to bring it to senior management k
2 attention and get it resolved.
3 MR. WHITE: Vince Polizzi was aware of 4 the letter; what were the rationale he gave you 5 for not sending this letter?
6 MR. VONDRA: He thought it would cause a 7 big stir in senior management organization while I 8 was gone and he didn't want to do that.
9 MR. WHITE: He didn't have any problems 10 with the content of the letter; he didn't want it 11 to hit it straight?
12 MR. VONDRA: I never asked him about I 13 that. That is the impression I got. I don't know l
14 what he said about it.
15 MR. LANNING: Which of your actions do ,
I 16 you think constituted the violation of 50.7?
17 MR. VONDRA: I think the letter.
18 MR. LANNING: The letter?
l 19 MR. VONDRA: More than anything in the '
l 20 letter because it became public knowledge, and I l
21 more than anything if I would say that there was a 1 1
22 consequence, was the potential for the chilling 23 effect on the whole organization. That is the 24 part of 50.7 that had the most potential damage l
ALL POINTS REPORTING (215) 564-5380
155 1 to. I don't know if that is right or wrong, but 2 that is how I see it after having had a little bit 3 of training on 50.7 4 MS. SMITH: You said you apologized to 5 the two men, Craig and Williams?
6 MR. VONDRA: Yes.
7 MS. SMITH: Exactly what did you 8 apologize for?
9 MR. VONDRA: I apologized for losing my 10 temper, okay, I think for kicking them out of my 11 office, and I'm not sure of my exact words, not 12 properly resolving the issue and carrying out any 13 responsibility. I have a written copy if you want 14 me to read it. I don't have it memorized but--
15 MS. SMITH: That is fine.
16 MR. LANNING: The disciplinary action 17 that you received, was that entirely the result of 18 your handling of this affair?
19 MR. VONDRA: Yes.
l 20 MR. LANNING: Your demotion and removal 21 from plant manager status, was that as a direct 22 result of this event?
23 MR. VONDRA: I was told that that is a 24 major factor. I think the fact that we had ALL POINTS REPORTING (215) 564-5380
136 1 several AIT's in my tenurr >
General Manager was 2 also an issue, but the major factor I think was 3 this. My new boss Joe Hagan was promoted to 4 vice-president, did not feel that I could be 5 effective in this role, he told me that about two 6 months after being made vice-president, and it was 7 just a matter of waiting for the right time to 8 turn over.
9 MR. WETTERHAHN: When was that; can you 10 put that in time approximately?
11 MR. VONDRA: I don't know. Springtime 12 of '93.
13 MR. WETTERHAHN: Ic that okay? Can he 14 summarize?
15 MR. WHITE: Sure.
16 MR. VONDRA: Just to recap, I have 17 taken responsibility for my actions. I am 18 sincerely sorry for the way this happened. I 19 think I have been significantly punished for my 20 actions. My actions were not based on 21 deliberately doing anything that were against any 22 rules or regulations or doing anything against 23 Rules and Regulations that I was knowledgeable 24 about. My actions were intended to comply with ALL POINTS REPORTING (215) 564-5380
127 1 the procedures as I understood them, and with the 2 concern for the safe operation of my plant. They 3 were not intended for the purpose of harassment 4 intimidation of employees in accordance with 50.7 5 but I understand how that happened. It would 6 never happen again. I am not a person who loses 7 his temper a lot, and, I don't think that there 8 would be another problem like this with me ever.
9 I think I can do a better job in handling this in 10 the future now --
11 MR. WETTERHAHN: Thank you.
12 M R ., WHITE: Any other questions?
13 - - -
14 ( No responses.)
15 - - -
16 MR. HOLODY: I want to take a break and 17 come back and summarize in about 5 minutes for us 18 to caucus.
19 - - -
20 ( A brief recess was held at 12:40 P.M.
21 and reconvened at 12:50 P.M.)
22 - - -
23 MR. WHITE: Back on the record.
24 Since the letter is a big part of why you are ALL POINTS REPORTING (215) 564-5380
i 128 1 here today, I would just like to make some 2 clarification as to some of the sentences on the 3 letter relative to what you intended them to mean.
4 - - -
5 ( Mr. White is perusing a document.)
6 - - -
7 MR. WHITE: Do you have a copy of the 8 letter?
9 MR. WETTERHAHN: Yes, we do have a copy 10 in front of us.
11 MR. WHITE: I'm beginning about midway 12 through the second paragraph, "Following this, Mr.
I 13 Williams and Craig presented the IR to Mr.
14 Polizzi." So Mr. Polizzi was in possession, at 15 least for a while, of the Incident Report. "The 16 concern was clearly identified, but there was no j 17 statement regarding the operability determination.
18 Mr. Polizzi requested a statement be made 19 regarding the operability question, but neither 20 Mr. Williams or Craig agreed to do it." In your 21 impression, Mr. Vondra, was it the responsibility 22 of Williams and Craig to make a determination on 23 the IR?
24 MR. VONDRA: Yes. What it was saying l l
l ALL POINTS REPORTING (215) 564-5380
129 I was Vince requested the information be put on the
( 2 IR that we talked about the seismic qualification, 3 the surveillance testing, and the qualification of 4 the components as safety related, and that they 5 would not allow him to do it. That is what I 6 believe that was saying.
7 MR. WHITE: So words that "No statement 8 regarding operability determination"--
9 MR. VONDRA: It wasn't he was going to 10 do it, it was that it wasn't allowed to be done.
11 That is how I read that. Again, I told you that I 12 didn't try to word engineer this. It pretty much 1 13 came from the content of what I was thinking about 14 and I never intended, I thought this letter would 15 just be a means of bringing discussion.
16 MR. WHITE: I understand, I just want 17 to make sure that this letter that we come away 18 with the same understanding that you have of this 19 letter. Further on it says, "
Mr. Williams and 20 Craig insisted that in accordance with the NAP 21 they must deliver the IR to the SNSS who will then 22 make the operability determination." When it was 23 further explained that the SNSS was not the right 24 person for this type of operational decision that ALL POINTS REPORTING (215) 564-5380
13"1 l 1 think I have learned a lot through this process, 2 okay, I think that I was responsible for failure 3 to control my temper. I was responsible for 4 allowing an issue of significant concern to get 5 out of my office unresolved. I was responsible 6 for possible chilling effect on my organization, 7 but I didn't know it at the time, and it wasn't 8 intentional or deliberate. My intentions were 9 always the safe operation of my station. It was 10 never to harass or intimidate any employee. And, 11 I would like you to understand that and to take 12 that into consideration. Also to understand that 13 I have had significant punishment for my actions, 14 and for those failures to accomplish those 15 responsibilities that have cost me my job and my 16 career, and I would like you to consider that too.
17 MR. WHITE: What is your understanding, 18 Mr. Vondra, in terms of your position with the 19 company, further career?
20 MR. VONDRA: At one time I thought I 21 was going to be vice-president. Now I'll probably 22 Dever ever be a General Manager again.
23 MR. WHITE: Is there any intention or 24 possibility on the part of PSE&G that you ALL POINTS REPORTING (215) 564-5380
130 1 something must be written on the IR Mr. Williams 2 said that he would indicate that the CFCE's were 3 inoperable. This was perceived as a threat and 4 totally contrary to engineering disposition."
5 There is nothing in this letter that refers to the 6 threat that you conveyed, that is that the threat 7 of a safety concern being generated?
8 MR. VONDRA: That is what I thought 9 that last sentence was saying, okay. I was not--
10 Again, I was not trying to get this that nitty, 11 you know, I thought what that last part was saying 12 that, the part where I said that I thought we were 13 at a point where we were trying to get information 14 on the IR to make the decision for the shift 15 supervisor, that is what I thought that sentence 16 was talking about, okay, and that there was a 17 refusal to do that, and then that there was a 18 threat, okay, and that is I thought that was close 19 enough. I was not trying to --
20 MR. WHITE: I see where you further 21 explained that in the next paragraph. Okay, we 22 don't have any further questions. I allow you to 23 make a summary statement if you wish at this time.
+ 24 MR. VONDRA: Well, my summary is I ALL POINTS REPORTING (215) 564-5380
132-- -
1 understand now that you will sometime in the k' 2 future be assigned to duty at Salem or Hope Creek?
3 MR. VONDRA: I don't know that that is 4 precluded, I don't think that is too likely, and I 5 don't know that that is precluded right now, but I 6 don't think it is going to happen.
7 MR. WHITE: Mr. Holody?
8 MR. HOLODY: Mr. Vondra, whenever we 9 are talking about potential deliberate violations y 1
10 of our departments or harassment, intimidation of j 11 employees, particularly someone in a senior 12 position, we consider those serious issues, and
. 13 that was the basis for the conference today. It 14 gives us an opportunity to hear your side of the 15 story prior to us making a determination in what 16 we think is the appropriate action, and also to 17 express to you our concerns regarding these 18 issues. What we will do now is re-evaluate, as I 19 said earlier, the CR report, the investigation 20 that was done by the utility, the actions that 21 have been taken by the utility with respect to 22 you, and what you presented to us today, and we'll 23 make a decision on appropriate enforcement. The
. 24 options available to us range from doing nothing l ALL POINTS REPORTING (215) 564-5380
l l
133 l
1 1 to a letter of reprimand, notice of violation, to 2 a civil penalty, to an order that could be 3 restrictive and somehow restrict your activities 4 in the nuclear field for some period of time.
5 Whatever action we do take we'll apprise you in 6 writing, and you will get a call from us, and I 7 would hope that would be out within a month, I 8 would not guarantee it. These actions generally 9 involve OI investigations in these type of 10 settings. They sometimes take longer, so it may 11 be longer in this particular case. I think that 12 is it. Did you have any questions of the process?
13 MR. VONDRA: No.
14 MR. WETTERHAHN: A couple of 15 statements. First of all, as you know, as we 16 discussed off the record, you know, statements 17 that were made are based upon Cal Vondra's 18 knowledge and his knowledge of the company's 19 investigation. We have not seen a copy of the OI 20 investigation, don't know whether the conclusions 21 are the same or there are additional facts.
22 Violation of 50.5 in my view requires 23 deliberateness. If there is any issues other than 24 we've addressed with regard to deliberateness, we ALL POINTS REPORTING (215) 564-5380
135 1 statement?
( 2 MR. VONDRA: They were not -- That 3 letter was not intended to violc*e any NRC rules 4 or regulations. It was intended to resolve an 5 issue and bring it to senior management's 6 attention.
7 MR. WHITE: All right.
8 MR. HOLODY: Let me just, and I'm not 9 going to put words in your mouth, but what I 10 thought I heard today was you felt that you caused 11 the company to violate 50.7 but you did not know 12 you were violating 50.7 at the time?
i 13 MR. VONDRA: That is correct.
14 MR. HOLODY: And you did not feel that 15 you deliberately violated 50.7?
16 MR. VONDRA: That is correct.
17 MR. HOLODY: And therefore, you feel 18 that you did not violate 50.5?
19 MR. VONDRA: That is correct.
20 - - -
21 22 23 24 ALL POINTS REPORTING (215) 564-5380
134 1 are willing to answer any questions to try to 2 understand your position and put our position on 3 the record with regard to that necessary finding, 4 other than what you might have asked previously. )
1 5 MR. HOLODY: Any other questions on 6 our end?
7 - - -
8 ( No responses.)
9 - - -
10 MR. WHITE: Yes, just one 11 clarification. Earlier I think I had asked a 12 question whether or not you believe now based upon j
. \
l 13 your perception that you had-violated 10 CFR 50.7, 14 I meant to refer to 10 CFR 50.5.
15 MR. VONDRA: No, sir, I never 16 intentionally have violated any rule or 17 regulations. I have never done that and would not 18 do that.
19 MR. WHITE: Do you understand your 20 actions relative to the letter? Do you believe 21 that they could be construed to be in violation of 22 10 CFR 50.5?
23 MR. WETTERHAHN: As a legal matter, no.
24 MR. WHITE: Do you agree with that ALL POINTS REPORTING (215) 564-5380
l 136 l l
1
( 2 C-E-R-T-1-F-I-C-A-T-I-O-N 3 - - -
4 5 I, Carol L. Skipper, hereby certify that 6 the testimony and proceedings in the foregoing 7 matter taken on February 24, 1995, are 8 contained fully and accurately in the 9 stenographic notes taken by me, and that the 10 foregoing is a true and correct transcript of 11 the same.
12 - - -
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18 THE FOREGOING CERTIFICATION OF THIS TRANSCRIPT DOES 19 NOT APPLY TO ANY REPRODUCTION OF THE SAME BY ANY 20 MEANS UNLESS UNDER THE DIRECT CONTROL AND/OR 21 SUPERVISION OF THE CERTIFYING REPORTER.
22 23 24 ALL POINTS REPORTING (215) 564-5380 12h
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UNITED STATES NUCLEAR REGULATORY COMMISSION lis REGloN I C,
p'[ 475 ALLENDALE ROAD
% KING of PRUSSIA. PENNSYLVANIA 19406 1415 April 11, 1995 l
IA 95-009 Mr. Calvin Vondra HOME ADDRESS DELETED UNDER 2.790
SUBJECT:
NOTICE OF VIOLATION (ENFORCEMENT CONFERENCE (NRC 01 INVESTIGATION 1-93-021R))
Dear Mr. Vondra:
On February 24, 1995, the NRC conducted an enforcement conference with you in the Region I office in King of Prussia, Pennsylvania, to discuss the circumstances associated with your alleged harassment and intimidation (H&I) of two Public Service Electric and Gas (PSE&G) Safety-Review Group (SRG) engineers. The conference was based on the finding of an NRC investigation by the Office of Investigations (01) which concluded that you took action that involved H&I of two Safety Review Group (SRG) engineers who were engaged in protected activities on December 3,1992. A similar finding was made by PSE&G in April 1993. A copy of the OI synopsis of the investigation was forwarded to you on January ll,1995.
, On December 3,1992, the two SRG engineers attempted to process a safety issue, in accordance with station procedures, by submitting an incident report (IR) at the Salem Station. The IR questioned whether the commercial grade air supply pressure setpoint regulators, which control service water flow to the safety-related containment fan cooling units, were qualified seismically, configured ;
properly, and classified properly as safety-related components. A heated discussion on this issue subsequently developed during a meeting in your office.
During this meeting, you attempted to persuade the engineers that either an incident report was not warranted, or information which would demonstrate operability of the components, and which you believed existed, should be included on the incident report. In addition, you discouraged the submittal of the i incident report by strongly recommending the submittal of a Deficiency Evaluation Form. After one of the engineers indicated that he would consider filing a Quality / Safety concern on the matter, you became angry and told the individuals to get out of your office and threatened to have security officers remove the two SRG engineers.
In addition, upon deliberation, you directed that a memorandum be written to the !
General Manager-Quality Assurance and Nuclear Safety Review (GM-QA/NSR), within i whose organization the SRG engineers reported. In this memorandum, which you ;
signed on December 4,1992, you indicated that the two SRG engineers had a lack l of professional understanding and displayed aberrant behavior, and you requested that they be removed from any direct or indirect involvement with Salem Station.
At the enforcement conference, you admitted that you harassed and intimidated these two individuals by your actions, which caused PSE&G to violate 10 CFR 50.7, although you contended that you did not do so deliberately. Notwithstanding your contention that you did not harass and intimidate the SRG engineers deliberately, you nevertheless sent the December 4, 1992 nemorandum to the GM-QA/NSR even though (1) you consulted with the then General Canager-Hope Creek, who cautioned
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- Mr. Calvin Vondra 2 i l
you regarding the implications of sending the memorandum, and (2) although you l signed the memorandum prior to going on vacation on December 4,1992, your )
Operations Manager (OM) did not mail the memorandum but returned it to you i following your vacation on December 14, 1992, which provided you another ;
opportunity to reconsider the appropriateness of your action. Despite these i opportunities to reconsider the implications, you persisted in your decision to !
send the memorandum to the GM-QA/NSR on December 14, 1992. Further, you took no l action to resolve or retract the memorandum until February 8,1993, after the !
Senior Vice President-Electric became aware of these events. The NRC believes l that these actions were deliberate on your part and caused the licensee to l violate 10 CFR 50.7 and, therefore, constitute a violation of 10 CFR 50.5. Since !
you were the senior person onsite .at the time and several supervisory levels ;
senior to the SRG engineers, the violation is classified at Severity Level II. l As the then General Manager of a nuclear facility, you were in a position that I conferred upon you trust and confidence in your ability to effectively manage and promote the safe operation of that facility. In that position, you were responsible for the appropriate resolution of all potential safety concerns, as {
well as professional treatment of all individuals who bring forward those !
concerns. Your actions did not adhere to these standards, and did not provide !
an appropriate example for those individuals under your supervision, or !
individuals of PSE&G's organization with which you interfaced. Rather, your !
actions in this matter contributed to the creation of a hostile work environment ;
for these two individuals at the Salem Station, and a potential chilling effect I towards other station personnel identifying safety-concerns.
],
Given the significance of your actions, I have decided, after consultation with I the Director, Office of Enforcement, and the Deputy Executive Director for <
Nuclear Reactor Regulation, Regional Operations and Research, to issue t:;you the ,
enclosed Notice of Violation. I also gave serious consideration as to whetr i an Order should be issued that would preclude you from any further involw l in NRC licensed activities for a certain period of time. However, I have ;
decided, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and l Research, that this Notice of Violation is sufficient since (1) PSE&G took prompt disciplinary action, after its own internal investigation at the time, including issuance of a reprimand letter to you, requiring you to give a presentation regarding the events to the senior managers, subsequently replacing you as the General Manager-Salem Operations, and assigning you to a position not involving NRC licensed activities, which resulted in a reduction in your pay grade, and (2) i you were candid and remorseful at the enforcement conference during which you j acknowledged that you had erred and had exercised poor judgement in this matter. l Based on the results of the transcribed enforcement conference, and in view of I the actions already taken in regard to your performance, no response to this ;
letter and the enclosed Notice is required. However, should you become involved ,
in NRC licensed activities in the future, you should provide a response to the l NRC regarding this Notice at that time to include your reasons as to why the NRC i should have confidence that you would not engage in such activities in the !
future. Any similar conduct on your. part in the future could result in further i enforcement action against you.
I i
1 i
Mr. Calvin Vondra 3 In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room with your address deleted.
A copy is also being provided to the President and Chief Executive Officer of PSE&G.
The enclosed Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.
L. No.96-511.
Sincerely, k
Thomas T. Martin Regional Administrator
Enclosure:
Notice of Violation 4
' Mr. Calvin Vondra 4 ;
cc w/ encl:
L. Eliason, President-Nuclear Business Unit ,
E. Ferland, President and Chief Executive Officer PUBLIC Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey State of Delaware 4
l
l ENCLOSURE NOTICE OF VIOLATION l
Mr. Calvin Vondra IA 95-009 Public Service Electric and Gas Company During an NRC investigation conducted by the NRC Office of Investigations, a violation of NRC requirements was identified. In accordance with the " General l Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, 1 Appendix C, the violation is set forth below:
10 CFR 50.5 requires, in part, that any employee of a licensee may not engage in deliberate misconduct that causes a licensee to be in violation :
of any regulation. I 10 CFR 50.7, Employee Protection, subsection (a), prohibits discrimination by a Comnission licensee against an employee for engaging in certain protected activities. Discrimination includes actions that relate to ;
compensation, terms, conditions, and privileges of employment. Protected i activities include, but are not limited to, providing information to an l employer on potential violations or other matters within the NRC's l regulatory responsibilities. '
Contrary to the above, you deliberately caused Public Service Electric and Gas Company (PSE&G) to violate 10 CFR 50.7 by discriminating against two employees for engaging in protected activities. The employees, ,
Mr. Bert Williams, and Mr. Paul Craig, who were Safety Review Group (SRG) I engineers, were engaged in a protected activity in that they attempted to file an incident report at Salem concerning whether commercial grade air supply pressure setpoint regulators, which control service water flow to the containment fan cooling units, were qualified seismically, properly
, classified in an information system as safety-related, and properly configured. Beginning on December 3, 1992, as the then General Manager-Salem Operations, you subjected Mr. Williams and Mr. Craig to discrete actions which created a hostile work environment affecting the conditions of their employment, as evidenced by the following:
- 1. During your meeting with the SRG engineers on December 3,1992, you were unsuccessful in convincing the SRG engineers to modify, amend or otherwise revise the IR. You angrily told the SRG engineers to get out of your office after one of them indicated to you that he would consider filing a safety concern if an incident report was not ;
processed. Your actions contributed to a hostile work environment '
directed to the two SRG engineers because your actions could have j had a chilling effect on those employees (or other employees who may j have become aware of or witnessed this event) raising safety concerns; i
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I Enclosure 2
- 2. You directed the OM to prepare a memorandum to the GM-QA/NSR for your signature, requesting that the. SRGs be removed from any involvement in Sales licensed activities, and. their aberrant behavior evaluated. Your actions contributed . to a hostile work environment involving the two SRG engineers because your intention to submit such a memorandum could have had a chilling effect on those employees (or other employees who may have become aware of, or witnessed this event) raising safety concerns;
- 3. You signed the memorandum to the GM-QA/NSR on December 4,1992, and mailed it on December 14, 1992 upon return from vacation, even though in the interim,
- a. The then General Manager, Hope Creek, cautioned you about the sending of the memorandum; and
- b. The OM did not mail the memorandum on December 4,1992, but held it until you returned from vacation on December 14, 1992, which provided you an opportunity to reconsider the action.
The memorandum contributed to the hostile work environment because it had the potential to inhibit the SRG engineers, and any other employees who may have become aware of the memorandum, from raising safety concerns; and
- 4. You did not retract the memorandum until February 8,1993, after the Senior Vice President-Electric became aware of the issue and initiated an investigation, even though the GM-QA/NSR had a number ,
of meetings or telephone calls with you to resolve the issue. l This is a Severity Level II Violation (Supplement VII).
No response is required unless you become involved in NRC licensed activities. If you become involved in such activities, you must provide a response which includes your reasons as to why the NRC should have confidence that you would not engage in activities that would create a hostile work environment or result in violation of NRC requirements in the future.
Dated at King of Prussia, Pennsylvania this lith day of April, 1995 i-
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Mr. Calvin Vondra DISTRIBUTION: l PUBLIC !
SECY 1 CA JTaylor, EDO JMilhoan, DEDR JLieberman, OE TMartin, RI JGoldberg, OGC Stewis, OGC WRussell, NRR ,
RZimmerman, NRR Enforcement Coordinators ,
RI, RII, RIII, RIV i RHuey, WCFO W8eecher, GPA/PA .
GCaputo, 01 '
D8angart, OSP DWilliams, OIG EJordan, AE00 MSatorius, OE DE:EA NUDOCS :
JStone, NRR l
SDembek, NRR VMcCree, OED0 CMiller, NRR MShannon, ILPB WLanning, RI d
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