ML20138P876
ML20138P876 | |
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Site: | Wolf Creek |
Issue date: | 06/03/1985 |
From: | NRC COMMISSION (OCM) |
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NUDOCS 8511140017 | |
Download: ML20138P876 (49) | |
Text
- . ORIGINAL *C UNITED STATES OF AMERICA /d /J ($~
NUCLEAR REGULATORY COMMISSION '
Fusucsuunini500M 85 0CT 11 P3:12 In the matter of g,g .3 COMMISSION MEETING CLOSED MEETING (Exemptions 5 & 7)
DISCUSSION OF PENDING INVESTIGATIONS -
Docket Nob -
h.
Lo nt Washington, D.C.
- . Monday, June 3, 1985 Pages: 1 - 48 ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.
Suite 921 Washington, D.C. 20006 (202) 293-3950 9511140017 050923 i PDR ADOCK 05000402 T PDR
1 UNITED ST4TES OF AMERICA l 2 NUCLEAM REGULATORY COMMISSION l ,
l 4 OISCUSSION OF PENDING INVESTIGATIONS A CLOSED MEETING .
7 (Exemptions 5 4 7) l ,
l . . .
- g 9 Nuclear Regulatory Commission 10 Room 1137 1717 "H" Street, N.W. *-
11 12 Washington, D.C.
I 13 14 Monday, June 3,. 1985 15 l
16 The Commission met'In closed session, pursuant to 17 not6ce, at 1:37 o' clock p.m., NUNZIO J. PALLMOlNO. Chairman of 18 the Commission, presiding, l
i 19 COMMISSIONERS PRESENT 20 NUNZIO J. PALLAOlNO, Chairman of the Commission l 21 >
THOMAS M. ROGERTS, Meetser of the Commission I
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22 JMMES K. ASSELSTINE. Member of the Commission i 23 FREDERICK M. BERMTHAL, Member of the Commission
! 24 LMNOO W. ZECH, JR., Member of the Commission i
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8 muOIENCE SPEARERSi 9 R. MARTIN 10 H. DENTON ,
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CHAIRMHN pnLLADINO: Good afternoon, ladies and
$ 2 3 gentlemen. The purpose of this afternoon's meeting is for the 4 Comm6ssion to rece6ve a briefing on pending investigations at S Wolf Creek, sen Hayes will make the presentation.
6 I understand from Ben that information that he will 7 give during the meeting is very sensitive. Therefore, any 8 discussion of this 6nformation we receive from Sen beyond the g people who are present for this briefing should be carefu,Ily 10 controlled. .
11 This is not meant to exclude discussions with 12 persons whe have already been apprised of the information.
i 13 However, if there are persons in the room who belleve that l -
14 others have a need t o k n ow , Gen would like to be consulted 15 before any of the information is disseminated.
16 Commissioner Roberts is delayed. He will be here 17 shortly. Do other Commissioners have any opening remarks?
13 (No response.)
tg CHAIRMHN PALLAOINor Let me turn the meeting over to 20 Gen Hayes.
21 MR. CHILKr I think General Counsel wants to say 22 something.
23 CHAIRMMN PALLADINO: All right.
24 MS. KAGAN: Yes. Mr. Chairman, we have a petition i
25 from the Sovernment Accountability project that was filed on i
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Felday asking that we open this meeting.
However, the General l 1 i
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2 Counsel feels that the meeting should remain closed and will ;
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advise Government Accountability project after the meeting if I 3 1 I
0 4 4 you agree. ;
i 5 CHAIRMAN PALLAOINO: All right. Any objection to s i j 6 that? , ;
i j 7 (Chorus of no's.) !
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S CHAIRMAN PALLAOINOi Thank you. All right. Let's j
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1 l 10 INo response.)
11 CHAIRMAN PALLAOINO: All right. Gen.
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! 12 COMMISSIONEM ASSELSTINEt Although I guess I have N 4 13 one question that we can talk about later on and that is to
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14 the extent to which Sen, your activities involve the kinds of [
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20 MM. HAVES: The 2.2067 ,
21 COMMISSIONEM ASSELSTINEt That's right. It seems to l
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2 MM HAygt: On the Friday prior to the three-day 9 holiday, the reg 6onal administrator in Region IV mounted a 4 review of the Quality One files at Wolf Creek and asked for 01 5 assistance in reviewing the wrong doing (60ee in the Quality l 6 One progr am. '
7 We seeigned two investigatore to assist in that 8 inspection and last week we looked at 112 allegations l
I 9 contained in appronimately 75 filee. That is, one file would to contain more than one allegation obviously. ,
l 11 CHalMMHN PALLnosNO: How many allegatione?
l 12 MM. HAYgSe One hundred twelve. The break =down goes 13 semething like this harassment / intimidation, 45 allegations, la falso documents, 19 allegatlone, drugs, 21 all'egations t 15 leaving a balance of 27 which at this point unclass6 fled or l
16 m 6 er.e l l aneou s . That totale the 112 allegations, 17 Our revsew of the files and that le all we did, we le just reviewed the documentd within the files, we took 19 exception to 77 allegatione in terms of the GI findings and no 20 enception to 25, i
21 COMMISSIONER HSSELSTINEt Do you want to emplain 22 what you mean by that?
23 MM. HAYES: The bottom line la when we looked at the 24 desument a t ion our observa t ions were that those people that did {
25 the interrogations were really not trained in the question and
I 11 1 answer area, Some leads were not properly followed. Scme 2 information in the f6les was unused even though it was an the 7 441ee.
4 Some of the conclusions that were in the f6fe, wo 1
5 could not see from a data standpoint how they could get from 6 point "H" to point "g." We are not saying that the 7 conclusions are necessarily wrong, it la just that we have no 4 beste from looking at the files to have any confidence in 77 9 of their allegatlana as to whether they were or were not 10 pursued adequately. .
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11 CHMIMMHN PALL 90lNO Old you say anything to them 12 about that?
l 11 MM, HHYE5t No. We did not, Naybe the staff did l
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14 in their close-out with the applicant that Friday, but we did l
15 not close out weth them. We furnlehed data to the staff of 16 the inspection report.
17 If I could continue, I will give you a flavor as to 18 some of our concerne and some of the drug related matters as 19 to who is involved and the documents that are alleged to be 20 falso and it might give you a better feeling for the 21 situation.
22 CHelMMHN PALL *0lNOi What I was trying to get at for 21 the moment la there undoubtedly will be mention made of their 24 Of program and we may want to ask them about the degree to 25 which they follow-up,
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- 13 t Was there any discuss 6on weth them. Sou?
2 MM MAMTIN; I am sob Nortin fecm Region IV. There '
3 was a close-out meet 6ng with them after the team that was there'last week rev6ewed all 750 f6les, not f6 lee, but !
a I S allegatione. The total package within the quality program ;
6 conalets of about 750 separate allegations wh6ch ten has'been 7 descr6bing a subset of those.
! 4 During the close-out, we did point out that there i 9 were some concerne from the investigative aspects of how they i
l 10 locked into certain issues and we made it clear.that we would l
11 be pursuing those things further in those areas where we 12 thought there were some soft areae without being very 11 descriptive of what kind of follow-up that that would 14 cenetitute, 15 CHAIMNAN PALLAOlNQi Were any of the leaues that you 16 took onseption with or that Of took onception with, do th9y 17 have signifleant safety implicatione at thee time 1 Do they' 18 bear on our decision today9 19 NM. HAMTINt That is a difficult question per se to 20 answer. It depende on if there were harassment and l
i 21 6ntimidation cases and if they inadequately followed up on 22 them and if that was a problem and proved to be perveelve.
21 that could have a safety impact 4 24 There are many steps to be gone through before 1 25 could answer that abeelutely defInittwely. From the
13 1 atendpoint of perhaps a perspect6ve that m6ght assist you en 2 that area, any one who comes to the Quality One program, a 3 part of the6r program is follow-up w6th the individual The 4 and6veduals also presumably know that they can come to us or 5 come to other levela of management if they are not sat 44 fled 6 w6th Quality One. -
7 We have not had people subsequently come to us who
$ clalmed that they were unhappy with the Q1 disposition, i 9 don *t know that is of itself a bench mark but at least it is a 10 data point ,
11 COMMISSIONER HSSELSTINE: Why don't we let Een go 12 ahead and talk about some of the details 7 19 MR. HAYES: All right. Some of the areas of the la falso documents, we have a list and some of the areas in the 15 alleged drug allegations we have a list of people 6nvolved in 16 those.
17 it might be interesting for us to run through that.
18 On my right is Bill Hutchison, a member of my staff, who has le the data, Gill, 20 , NR. HUTCHISON: To give you a flavor of the kind of 21 personnel we are talking about in the area of drug use and 22 drug sale and that is both on and off the instal ation.
21 incidentally, we seem to be finding that it is mostly in the 24 eoft drug area, marijuana and that type of drug.
t 2S There was an incident where allegations and these 1
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14 1 were' allegations, were made against ten Daniel's construction E QC and QA managers and supervisors. We had instances where 3 allegations were against pipe fitters, construction workers, 4 start-up engineers and in fact, an allegation against start-i s 5 engineers and others within the start-up group.
6 We did not have any allegations against reactor 7 operators.
8 In the area of falsification of records to give you 9 a better flavor of the kinds of falsifications that we are 10 talking about, there were etch test records, Daniel's weld
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11 records, Westinghouse pump house inspection records, ent les 12 on various drawings. TMI procurement documents, 13 instrumentation and calibration records, Daniel's hanger heat 14 and traveler documents, start-up records, NCR' disposition 15 records, the stamreing of quality stamps on threaded rod 16 hangers, changing drawings in the area of structural steel, l 17 quality control, rebar records, maintenance records, cadwel.1 i
18 inspection reports, quota records, MT tests, mechanical QC
'19 inspection records, BSB inspection records, cheating on
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20 qualification exams for QC. inspectors, TMI inspection records 21 and work packages to give you an idea.
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l 22 That is not all inclusive but it will give you a i
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23 good idea. These were allegations that were made concerning 24 false' records.
25 MR. HAYES: I guess our bottom line is we can't give
15 1 the Commission any more s er.s e than what we have. It is 2 undetermined as far as we are concerned as to the adequacies 3 of the Q1 in the wrong doing area. That may throw out a 4 policy concern that we have had since we have gotten involved
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l 5 with Q1 from a generic standpoint.
6 I am not sure we have a regulatory framework that 7 requires an applicant to notify us of matters of wrong doing S identified on the site unless it is a 50.55(e) situation or a 9 part 21 or there is any Board status where a BN would be -
10 appropriate. ,
e . . . .,
11 1 have done my research and we wrote OGC on it last 12 December, I believe, and got a report back in January. That 13 is my reading of OGC's response. The Q1 program is not a 14 regulatory requirement, it is something that the applicant 15 initiated. I talked to them about it when I personally j 16 visited the site last year as to do they notify Region IV of 17 these matters of wrong doing and they said, "No," that the e 1
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l 18 files are available'to us if we want to come in and examine 19 them, that it is a generic concern.
20 CHAIRMAN PALLADINO: The question of reporting it to 21 NRC-is.one thing. The reason I mention it as one thing is 22 because i don't want to discourage them from their voluntary 23 program but their voluntary program ought to be a good one.
24' That is what concerns me.
25 You-give me the sense that maybe that is not the
16 4 1 case.
2 MR. HAYES: I can't stand before you this afternoon 3 and say that the conclusions are inadequate. What I can say 4 is that the files in our view are in such a state that we 5 cannot come to the conclusion that they did with the
.6 documentation in the file without additional work. We need to 7 do more, We did a review during the five days and that is our 8 bottom line.
9 COMMISSIONER ASSELSTINE: Let me put the question 10 that I think the Chairman is asking to you in ma.ybe in even a 11 little more pointed way. When i visited the site.1 was told 12 that we have this terrific program. It has highly qualified, 13 competent trained people doing the follow-up on these 14 allegations.
15 Each allegation is investigated thoroughly and a 16 report is prepared and then our investigators go back to the 17 people that have provided the allegation and explained whate 18 our conclusions are and have'gone through the details of what 19 we have found and determined whether those people then are-20 satisfied with what we have done.
21 It is a very comprehensive, very thorough. very 22 detailed program That is the way it was described t o me .
23 Does your review of those reports support ~that?
24 MR. HAYES: No It does not support that at 4 25 least in the areas of wrong.doing. The bulk'of the files deal
17 1 with technical concerns obviously but not in the wrong doing 2 arena.
3 COMMISSIONER SERNTHAL: I guess I missed something.
4 In the wrong doing arena though there is just sort-of'nothing 5 there, is that right?
6 MR. HAYES: In some instances --
7 COMMISSIONER BERNTHAL: I guess I am losing the 8 forest here. I have heard a lot of trees so far or seen a lot 9 of trees.
10 MR. HAYES: We reviewed 75 files l o o k i, n g at 112 11 allegations in those files Our investigators took exception 12 to about 60 allegations out of there, 60 percent of the 13 allegations. That is, the files were inadequate for us to 14' come down to where they came down They would close it out 15 and we could not understand why. There was no follow-up on 16 leads They would get an allegation about individuals doing 17 dope on site and it would be turned over to security and that 18 would close out the file.
19 We are not saying that if we went back and did our 20 own investigation that we may not end up there where they did, 21 but we certainly cannot endorse the product from the documents 22 that we looked at.
23 You just can't get.there from where the state their l
24 files are presently in.
25 COMMISSIONER ZECH: Isn't this a program that was a 1
- 18 1 utility initiative, as I understand it They explained it to me when I was out there, too. As I understand it, it was a 2
3 utility initiative program. It was above and beyond our 4 regulations. It was their initiative to have a Quality First 5 program, is that right? That is my understanding. Do you 6 agree with that?
7 MR. HAYES: Yes, I do.
3 COMMISSIONER ZECH: What you are telling us, I 9 guess, is that your review of their program would lead to a 10 different conclusion than they have come up which is they
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11 think it is an excellent program and is on their initiative 12 and they have pursued it.
13 You are saying that your conclusion is that it is 14 not that good a program.
15 MR. HAYES: No. The program from a technical 16 standpoint, we have no position on it and that is the bulk of 17 the files. We looked at only 75 files out ofs3OO-some files, 18 those dealing with just the matters of wrong doing.
19 COMMISSIONER ZECH: So from a technical standpoint, 20 you have no problem with their program? ,
l 21 MR. HAYES: We didn't look at the technical side of I
22 the house, Commissioner. We just examined the allegations 23 that appeared to have matters of wrong doing.
1 24 COMMISSIONER ZECH: Then you have no comment on the 25 technical side, I. presume.
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19 1 MR H4YES: That is right.
2 COMMISSIONER ZECH: So you are just talking about 3 the wrong doing side?
4 MR. HAYES: Yes, sir.
5 COMMISSIONER ZECH: In that case, you have concluded that your' conclusion would be different from theirs. Is*that 6
7 what you are telling us?
8 MR. HAYES: Our conclusion is that we cannot 9 conclude from the documentation in their files how they 10 reached a specific positions. The QSA's are inadequate.
pursuing the investigation was inadaquate in our view. All 11 12 those files might be absolutely correct.
13 MR. HAYES: They may be. What we are saying is that 14 there is nothing in the file that we could hang our hat on to 15 come to the conclusions that many of the files came to.
16 COMMISSIONER BERNTHAL: For about a third of the i
' e 17 ones that you looked at?
d 18 MR. HAYES: About two-thirds.
19 COMMISSIONER ASSELSTINE: One- third looked okay and 20 two-thirds were questionable?
21 MR. HAYES: Yes, sir.
22' CHAIRMAN PALLADINO: Is this-an area that we should 23 explore further with them in the open meeting? Is there any 24 problem doing so? I look to either Bob or you. Ben, or both.
25 MR. HAYES: It wasn't an investigation as-far.as we-
L 20 1 are concerned. It was a review of the files from an 2 inspection standpoint We only have one ongoing anvestigative 3 matter so I don't think it would impinge upon 01 4 CHAIRMAN PALLADINO: They apparently knew you made 5 this review.
6 MR. HAYES: Absolutely, 7 CHAIRMAN PALLADINO: Apparently you talked to them 8 and I forgot what you told them, that it wasn't quite 9 adequate? ,
to MR. MARTIN: I paraphrased but at the. exit meeting 11 it was described to them that we would be pursuing en these 12 particular areas more information with them.
13 MR. DENTON: There is quite a bit of information we 14 can talk abcut that doesn't deal with the wrong doing part 15 that Bob's people-put in a massive effort to review the files 16 from a technical standpoint.
17 We were staying away from t ha t ' t h i s ' morn i ng bu t 1.*
18 think that this is a generic _ issue that the Commission needs 19 to focus on. There are several more plants coming to you that 20 have Quality First programs.
21 Ben did not review because it is a voluntary program 22 the adequacy of their procedures from an investigatory sense.
23 So I am_ concerned that maybe when Fermi gets here or Watts 24 Bar, are there going to be questions about how good was their 25 program.
21 1 1 think if the Commission wants to be sure that the 2 quality of the investigatory side of those programs for wrong 3 doing meets Ben's standards, Ben needs to get involved and 4 issue some sort of guidelines.
5 With regard to the technical adequacy of these 6 programs, they were inspected four or five times by the 7 regional people so the Region did its normal inspection of 8 the program to be sure that it had met the technical sort of 9 standards, but we are in a different posture with them wi_th 10 regard to wrong doing standards.
s... .
11 1 just want to put that on the table on how you want 12 to face it for the next plant.
13 COMMISSIONER ZECH: From a technical standpoint, you 14 say that the staff does have confidence in t h'e i r program?
15 MR. DENTON: I will let Bob, who conducted the 16 program, speak for himself in this. I think the answer is ,
17 yes.
18 COMMISSIONER ASSELSTINE: I think that is an open 19 item.
20 CHAIRMAN PALLADINO: Ben didn't look at that but Bob 21 did.
22 '
MR. DENTON: At the same time, it is disconcerting 23 not to find here at this eleventh hour that Ben is happy with 24 the qual'ity of their wrong doing investigatory program. So-to 25 the extent that there are questions there and I think as 1
' 22 b
-1 read ~ Ben, he is saying that from the documentation that he 2 reviewed, he doesn't know if the Quality First program pursued A
3 these things adequately or not.
4 What we do know is that they did not involve company 1
5 employees by in large. There were only one or two individuals 6 tagged in all of those programs and none of them are SRO*s or j
7 operators. I think there might have been one or two employees 8 that were touched -- one employee. All the rest: ware contract 9 personnel 10 CHAIRMAN PALLAOlNO: Ben said that he,could not 11 comment on the technical aspects. Could Bob or someone else 12 connen t on the technical aspects.
13 COMMISSIONER ASSELSTINE. Why shouldn't they do that 14 in the open meeting.
15 COMMISSIONER BERNTHAL: That is not a closeable-item j 16 in my view, 17 CHAIRMAN PALLADINO: That is.why I asked the e d
18 question if.there was a p'roblem in discussing that in the open 19 meeting.
1 20 COMMISSIONER ASSELSTINE: I would like to understand !
21 B er. what it is about'what you discussed that is related to an 22 ongoing investigation?
23 MR. HAYES: .Nothing.
24 COMMISSIONER ASSELSTINE: -Then l-don't-think that 25 this discussion should be in-closed session either.
,. - . . . - ~ , , . . , . . -..:...,.-...,..... . . - , .- , . . . . - . -
23 1 CHHIRMHN PALLHDINO: That is why I asked the 2 question.
3 COMMISSIONER ASSELSTINE: I think according to the 4 General Counsel's office, this should not be a closed m e e t i n g '.
CHAIRMAN PALLADINO: So far, on this item. We will 5
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6 have to review the transcript.
7 COMMISSIONER ASSELSTINE: The back door should be S open if this discussion is going to continue.
9 CHAIRMAN PALLADINO: I was going to suggest that we to bring it up in the open meeting but there are other pending l . . . . .
11 investigations, I presume.
12 MR. HAYES: No,' sir We only had that one. We had 13 closed out two enquiries which we have given the results to to 14 the staff.
15 CHAIRMAN PALLADINO: Which ones are they?
16 COMMISSIONER ZECH: Could I ask Ben to just 17 summarize what you have told us?
'18 MR. HAYES: .That the Office of Investigations has 19 very little confidence in.the files of Q1 as they relate to 20 matters of. wrong doing in the resolution indicated in the 21 file. The documentation in.our view does not support to the 22 extent that we feel comfortable their conclusions.
23 COMMISSIONER ZECH: Is that-what you are telling us?
24 MR. HAYES: Yes, sir.
25 COMMISSIONER ZECH: You are not comfortable with
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24 1 their conclusions in the cases of wrong doing*
MR. HAYES: Yes, sir.
2 S COMMISSIONER ASSELSTINE: You don't know if they are 4 right or not?
5 MR, HAYES: That is basically it. Commissioner.
6 COMMISSIONER ZECH: Could be right or could b e' 7 wrong?
3 MR. HAYES: Yes, sir.
9 COMMISSIONER ASSELSTINE: But the files themselves 10 don't demonstrate that they have.done a quality, thorough job c... .
11 in investigating the wrong doing issue.
12 MR. HAYES: That is correct.
i 13 COMMISSIONER BERNTHAL: Let me ask this. This whole 14 transcript may and up being open and I don't know whether this 15 is closeable or openable. Do you have a sense for the kind of 4
16 people that were carrying out.these investigations? I presume 17 that they were not professional i nves t i ga t or s'. Is-that true?
18 MR. HAYES: That is true. There was one person who 19 was an ex-FBI agent in the program.
20 COMMISSIONER ASSELSTINE: I have to say though that 21 when i vis'ited the plant one of the big pitches from the
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22 utility was that these are top-notch professionals, these are 23 people who undesstand these wrong doing issues, that can 24 thoroughly investigate the matter.
25 in fact, they highlighted just that point. We have
25 1 an ex-FBI agent on here. These guys are a cracker-jack 2 bunchy of guys and they know how to do this job. So the 3 representations at least were just the opposite.
4 COMMISSIONER SERNTHAL: One other question. Did you 5 follow up any particular cases? Granted the documentation is 6 inadequate. You can draw no conclusion on the documentation.
7 From what is in the documentation files, the investigatory job 8 appears to be substandard. Did you follow up on any of those 9 though to seek beyond what is in the files to try to determine 10 whether there had been informal actions perhaps,or other 11 follow-up that for some reason or another wasn't in the 12 files? After all, as Lando points out, this was a 13 company-initiated action and one can imagine that in some 14 cases they may or may not have pursued something and v'erbally 15 an investigator tells his superior, yes, I have checked that 4
16 out and there is noth6ng there or maybe there is something
- e 17 there. <
18 Did you try the testing of any of those cases? l l
19 MR. HAYES: No. Many of the investigators are no l 20 longer on the site. The program is really almost in remissien ,
at this point because they are so close to full power. I 21 l
22 think the program was initiated in March of 1984 and we made I
23 our first visit in September of 1984 and we prepared a paper i l
1 24 of our views at that point of Q1 and presented it to the i l
l 25 staff. l l
o 26 This was just more of a formal presentation. tJe 1
2 worked with the staff on this particular review.
COMMISSIONER BERNTHAL; So it is a fair point to be 3
4 made that there are no regulatory requirements imposed on 5 file keeping or otherwise for a company-introduced program, 6 but it would be interesting to know whether there is anything 7 informal beyond what appears in the adequate formal files or 8 their rather inadequate formal files that'they kept, 9 MR. HUTCHISON: Sir, it was not just the formal, 10 files that concerned our investigators, not merely the fact 11 that the files do not reflect information. It was also the 12 way the investigations,were run that were reflected in the 13 files that gave us problems.
COMMISSIONER BERNTHAL: I understand that, yes.
14
'15 MR. HUTCHISON:
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Basically, the interviews.
, 1 COMMISSIONER BERNTHAL: Substandard techniques, I 16 17 guess would be the word.
18 MR. HUTCHISON: Insufficient questions to solicit 19 the answers they needed and when they got.the answers, they 20 failed to follow up.
l 21 COMMISSIONER BERNTHAL: My question was, do you know 22 that there was in fact'rus informal follow-up? You didn't 23 pursue any of these to say well now .did you really do anything 24 or is the file everything you did on this' case? Did you do 25 that with any of these cases?
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' 27 l 1 MR. HUTCHISON: We did not go beyond the files 2 because it was an assist to inspection as opposed to an 3 investigation.
4 MR. HAYES: We only had five_ days.
COMMISSIONER ASSELSTINE: presumably in those cases 5
6 where you have problems with what is in the file, that is you 7 saw the interviews, you saw what questions they asked and 8 you saw flaws in that, there.is probably a lot higher degree 9 of confidence that that accurately reflects everything that ,
10 was done. ,
11 MR. HAYES: We have no indication that the files 12 were purged or phonied or anything of that nature.
13 COMMISSIONER ASSELSTINE: If they didn't ask the 14 right questions, it is unlikely that they went b-ack and asked 15 the right questions later on. That contains the file of what 16 was done in the investigation and at the end, it says based 17 upon this, we have closed this out, it is very unlikely that le someplace else there is some cure to that problem in that 19 particular one, i 20 COMMISSIONER BERNTHAL: Was there in every case the formal step-that Jim is alluding to? Do all these files say 21 22 that-this matter has been closed?
J 23 MR. HUTCHISON: No. !
l 24 COMMISSIONER BERNTHAL: They were just sort of f 25 sitting there in other words. .
1
o,
+
$ 29 1 MR. HUTCHISON: Some of them reflected that the 2 matter had.been closed.
3 COMMISSIGNER BERNTHAL: Questionably open or closed.
4 MR. HUTCHISON: Some of them were merely left.
5 MR. DENTON: I think you need a bigger answer to 6 that question. My understanding was that they went back'to 7 essentially all of the people who had raised allegations and f
8 you said that they didn't go back, but I thought that was one 9 of t he pr i nc i pN es that program was founded on was feedback to 10 the people who raised the allegations.
11 MR. MARTIN: If anyone identified that they wanted 12 feedback, part of the closure of this system included feedback 13 to the individual There were some I understand, a number of 14 individuals, who indicated that they didn't want feedback.
15 My staff is telling me that in some of these areas 16 and remember the regional staff are not investigators, but in 17 some of these areas that they looked into as bart of the i r '
18 routine follow-up during:the course of the program, that there l 19 are in answer, partial answer, to your question, Commissioner, 20 that there are sources of other'information elsewhere in the 21 company.
22 1 don't know what standard they might adhere to or 23 the satisfactory nature of them but there is places in some of 24 these areas elsewhere in the company where there is additional 25 information contained.
I i
29 1
The adaquacy of that issue is precisely the issue 2 that Ben and I had a very brief conversation on and we 3 identified to the company that we are going to have to look at 4 those some further to assure ourselves collectively what 5 action if any is appropriate for us to take.
6 MR. THOMASON: I think I would like to add in that 7 regard the focus of this program was set up not to look at 8 wrong doing and drug abuse and those type items. It really 9 was to look at the safety concerns and that where wrong doing 10 was identified, they would either refer that b a c.k to the 11 contractor for appropriate action in accordance with their 12 agreed plan to address wrong doing or to the General Counsel 13 where it was KG&E employees or whether it was to the physical 14 security folks.
15 So there are records that may be available that were 16 not evaluated at this particular time. I would add that where 17 the standard that at least we looked at when we were looking 18 and going back to the quality of the technical review was 19 whether or not the KGSE program resulted in actions which we 20 would have been satisfied with if the allegation had been 21 brought to us.
i 22 In all cases in the past review the answer was 23 fairly clearly yes. There were a couple of cases where we 24 went back to do field work, to check up on the field work, to 25 make sure that we were still satisfied that the program did
H
. 1 30 !
I produce the type of results that we thought it would on the 2 technical issues and where this particular program fell down 3 to the extent that it fell down was the fact that they did not 4 have the quality of investigators that we do today in our 5 Office of Investigations.
6 1 doubt that many utilities have that quality o'f l
7 investigators. I don't think that they are readily available S to the nuclear industry so I guess I am not totally surprised i
9 that that program did not meet the standard that we would,if to we had asked Ben to do that type of investigation.
11 COMMISSIONER BERNTHAL: I think you are right on 12 point, Hugh, and in fact we are in a dilemma, it seems to me 13 because in a sense when companies and I have no doubt we are 14 going to see more of this, when licensees initiate programs
?5 like this in one sense it is helpful to use aside from being 16 helpful to them but then if we suddenly. start trying to hold i
17 the employees that they are able to get to a /tandard that Vou 13 would expect of a federal agency that carries out major 19 investigatory activities, the solution for the licensee is 20 very clear to me. We ain't going to do that anymore and 21 somehow you don't want that to hapraen either.
22 it is a tough call. You would like them, of course, '
l 23 to be able to hire the very best and most talented i
24 investigators they possibly can but if they don't do that then 25 are you going to conclude that this is a lousy program and
91 1 therefore the licensee is not doing a good job of managing its 2 affairs. I don't know. It is not an easy problem it seems to 3 me and I am sure we are going to hear more of this kind of 4 thing as we go on to some of these other plants.
5 MR. HAYES: Just a little background, Commissioner, G we recognized this last year and that is one of the reasons we 7 went to Wolf Creek to get a sense as to what Q1 was about S because we have it at Fermi We had it at Waterford, River 9 Bend and around the' country. -
10 This was ostensibly to not grade themabut to 11 determine whether'or not we could rely upon their 12 investigatory product to endorse it on behalf of the
- \
13 Commission to save us resources. That was the thrust of our 14 first visit.
I j 15 CHAIRMAN pALLADIN : Are you implying that we are j 10 relying on these? To wha t extent are we relying on these Q1 e ,
17 type processes?
13 MR. HAYES: From a wrong doing standpoint, we are.
19 not at this particular' point. We have yet to formulate some 20 national policy and direction as to what we should or should 21 not do in this area.
22 COMMISSIONER BERNTHAL: In fact, your message here 23 is that you simply find that we cannot rely on a large number.
s:
24 .MR. HAYES: .At least with respect to this particular 25 unit at Wolf Creek we have some concerns. it may be different
32 1 at Fermi Cur game plan was last year to hit two construction
-2 sites and one operating reactor to try to get a feel to better 3 come back to the Commission and say that this is our sense of i
4 what is going on out there. We may or may not need some 5 additional regulatory standards.
1 6 COMMISSIONER ZECH: It seems to me that we hav"a two 7 things to consider. One is here-is a company that initiated 3 the program that they perhaps felt was in their best interest 9 and would be he l pf u'l to them as well as to us and that is a 10 commendable effort in my judgment.
6 . , , .
11 On the other hand, if other utilities have similar 12 programs thinking that-they are doing something helpful to
+
13 themselves and to the regulatory program.. that is something we 14 ought to encourage as far as I am concerned.
15 But if we don't have a policy on those programs, 16 perhaps we should have a policy that would be helpful to state l
17 our views on how those programs fit in and to'give them some 18 kind of character, some kind of overview.
19 It seems to me that we probably have a larger issue
-. 20 'to face.
- 21 The second' thing though I think here today, we have 22 to try to conclude whether the plant at Wolf Creek has i
23 problems that the Office of-Investigations is. telling us about 24 which would bear on a Judgment to provide us with reasonable 25 . assurance that the public health and safety would be protected
??
1 before we authorize full power 2 It seems to me'that we have those two separate 3 problems to address and we need to know, I guess, from Of of 4 they feel in the second case whether there are serious 5 problems here that should be looked into. We need to ask that 6 question. .
CHAIRMAN PALLADINO In connection with your 7 l 8 question, I thought I heard and perhaps it was Harold or Hugh 9 that said that the people involved with regard to the wrong 10 doing issues that you have looked to, involved contractor 11 people and that there were no RO's or SRO's involved.
12 MR. HAYES: We are very sensitive to drug 13 allegations with licensees including reactor operators and the 14 files did not contain an allegation that one Ef our licensees 15 d6d on-sit or off-site narcotics, marijuana or what-have-you.
16 none of that.
COMMISSIONER ASSELSTINE: What about start-up '
17 18 engineers?
19 MR. HAYES: There was an allegation that a start-up 20 engineer group utilized marijuana off-site and sold it 21 on-site.
22 COMMISSIONER SERNTHAL: What did that particular 23 file look like? Do you remember?
24 COMMISSIONER ASSELSTINE: Joe, could I ask you what 25 your i n t era t i on is with ref erence to the 2:30 meeting?
- Ta 1 CHRlRMAN PALLHDINO: I was going to suggest that as 2 soon as possible we cut thes off I would ask OGC to rev6ew 3 the transcript to see what was closeable and what was not 4 closeable and that which was not closeable, then we would make 5 avatlable and do whatever is legally required to do.
6 (Comm6ssioner Roberts entered the meeting.)
7 COMMISSIONER ASSELSTINE: Is there anything that 3 OOC thinks in the d6scussion that we have heard apart from the 9 initial discussion of the one open investigation that is, 10 closeable? .
11 MS. KAGAN: I am not sure.
12 CHAIRMAN PALLADINO: I was going to suggest that we i
13 not ask for a snap judgment and let them look through it.
14 COMMISSIONER ASSELSTINE: I would l'i k e to pursue 15 this discussion at the 2:30 meeting.
16 MR, HAYES: Let me raise one 6saue, Mr. Chairman. I 17 think our review and Bob, help me on this, our review of the 13 Q1 files, was it under the proviso that we would maintain some 19 degree of confidentiality with those files?
\ '
20 MR. MARTIN- . The only confidentiality understanding 21 we have is to protect the confidentiality of the individuals, 22 not the existence of the system or the general 23 characterization of the number of concerns but we are 24 sensitive to the Individuals' confidential status within that 25 program.
35 1
The company has always kept the files open to us i n, 2 general including the names of individuals. We have just been 3 sensitive to making sure that we don't. broach the 4 confidentiality they granted to their own people, 5 COMMISSIONER ASSELSTINE: But there has been no 6 discussion at least in terms of the meeting that we have'had 7 now on individuals.
3 CHAIRMAN PALLADINO: That's right.
MR. MARTIN: That is correct. I have not spotted 9
10 anything that would violate that. .
~....
11 COMMISSIONER BERNTHAL: Could you answer the 12 question that I asked you. Do you have the information here?
13 MR. HAYES: Yes. File number QC-1, 84-71, is KG4E 14 start-up group, allegation received July 1984." The allegation 15 is basically that this particular set of individuals did drugs 16 on-site and off-site and in fact sold on-site. The Q1 17 closed it out to the security chief. The secdrity chief 18 closed it out for lack of information and no subsequent 19 investigation.
20 Those are just my cryptic notes. I wouldn't take 21 that to the bank, Commissioner, without the file in front of 22 me.
23 COMMISSIONER SERNTHAL: Who locked at that file?
24 MR. HAYES: Two of my investigators.
25 ' COMMISSIONER SERNTHAL: They aren't here though?
36 MR. HAYES: No, ser 1
COMMisslONER BERNTHAL': It seems like they would 2
3 stand out in their minds.
4 MR. WARD: Commissioner, I also looked at that file l
5 and found similar information when I reviewed it back in 6 probably the October time frame.
7 The interesting thing is many of these drug S allegations would have the notation referred to security.
9 However, for your information the security department at Wolf 10 Creek has no investigators.
11 CHAIRMAN PALLADINO: Has no investigators.
L 12 MR. WARD: Has no investigative personnel assigned 13 to them. I did a cross-check on that because the question was 14 raised earlier about perhaps the completion is elsewhere. As 15 of again approximately October, I counted a rough count of 16 about 14 allegations that I felt were' drug oriented. The 17 security chief had four-that were referred to'him. So there 18 are ten in limbo.
ig MR. MARTIN: Only for the sake of perspective, under 20 the Alcohol and Drug Abuse program of KGSE if.there is an 21 instance of-an allegation of drug or alcohol abuse by 22 contractor personnel, the company's policy and their~ alcohol f
23 and drug. abuse program turns the lasue over to the contractor 24 and allows the contractor's alcohol and drug abuse program to 25 follow up on that.
.,,c .,w - .,- - ,y-- - . . , , , , - - _ . , . - - ,, , _ v ---
, ,,,---,v, r-,.,,m.,
37 1 One of the weaknesses that was identified with Ben's 2 help and through my own staff, a combination of the two. es 3 that'the close-out and feedbeck mechanism from contractors 4 back to the Q1 program is weak in that regard. That is one of 5 the areas that they are going to have to address strengthening 6 up.
7 l just wanted you to understand that their not 8 investigating it is consistent with the program that they,'in 9 fact, have in place. You might not recognize that the ,
start-up test group was a contractor organ iza t i c.n . Those were 10 11 contractor personnel, not KG&E people.
l I
12 COMMISSIONER ASSELSTINE: What.that tends to show is 13 that there is a flaw in their fitness for duty program by not 14 assuring-that those things are' properly closed out to their 15 satisfaction.
16 CHAIRMAN pALLADINO: I think when we get into 1
17 fitness for duty, we are straying quite a long way.
I b
18 MR. MARTIN: I~ don't know whether to agree with you 19 sir as to whether that is a flaw since we haven't really 20 specified what we measure that flaw against.at this moment.
21 COMMISSIONER ASSELSTINE: It is another flaw in 22 these voluntary programs that the industry.is urging us 23 to adopt in lieu of a requirement.
CHAIRMAN PALLAOlNO: I think the fitness for duty 24 l
25 question is an appropriate'one to ask In,the open meeting.
. 33 1
think we are straying quite a ways from pending 2 investigations. I am going to suggest that the fitness for 3 duty questions be discussed in the open meeting and we may 4 want to bring up questions of the staff with regard to how 5 they evaluate the Q1 program.
6 COMMISSIONER ASSELSTINE: And Of CHAIRMHN PALLADINO: 1 include -- excuse me, 01, in 7
case somebody thinks you are not also staff. I didn't say EDO 8
9 staff. ,
10 COMMISSIONER ASSELSTINE: All right. .
11 MR. THOMPSON: Mr. Chairman, I have one point of 12 information that might be helpful that I think is more 13 appropriate for the closed meeting.
14 It is my understanding that the GAA' organization 15 does have 6n its possession a nu.r.5 e r of the files, the QI files, that have been gathered by this organization. They 16 17 probably obtained those either through some cfandestine or '
18 some leak but you should be aware that those files are 19 available into the intervenor organization.
20 COMMISSIONER BERNTHAL: I just want to say that i 21 think Lando has made a good point a few minutes ago. There 22 won't be any programs like this if we don't go on the record 23 with what we are going to expect from such a program if it is 24 initiated. .
25 I am inclined to think that the question you have to l
i L. =.
TO 1 ask yourself is would we and the utality and we as regulators 2 I guess for emphasis be better off if they had never done 3 anything.
4 Maybe the answer to that is yes and if the answer is 5 no then somehow here we don't want to drive such programs out 6 of existence because that just means that sooner or later at 7 s osae po i n t there won't be any files at all and enstead of 3 having an incomplete file to deal with, Ben will and up having 9 to start from scratch. That is not good either.
10 CHAIRMAN pALLADINO: I do think we have to be
' . . . \
11 careful in our questioning but I think that it is appropriate 12 since the staff did make an evaluation of what they thought to 13 get that feedback and I think Bob's point that they want to 14 discuss it further with them is a good point. I do not know 15 what else to draw from this.
16 Each person has to decide whether or not it impacts 17 on start-up of this plant.
13 COMMISSIONER SERNTHAL: May I ask one last question, 19 Joe?
20 CHAIRMAN PALLAOlNO: Surely.
21 COMMISSIONER SERNTHAL: Why is it that we had five 22 days on this at such a late date if these files existed for so 23 long? Is that our fault or how did we get in this spot?
24 MR. MARTIN: perhaps I can try to explain that if 1 25 can. During the course of the Q1' program from the time,it m _
?
40 1 began we have inspected it somewhere between five and seven 2 times-- eight times.
3 We had looked at roughly 50 percent of the files.
4 We had looked up until prior to last week at some 50 percent 5 of the files including field follow-up, including versfication 6 that work was conducted by technical staff members, not 7 by investigators, but by technical staff members.
8 Then late in the prior week, not last week but the 9 week before, late in that week some interest was. evidenced by 10 I guess Congressman Glickman assisted by Dr. Henry Myers. We 11 received the 2.206 Petition which claimed that this was a 12 cover-up. Region IV was in cahoots with KSSE in covering up 13 serious safety deficiencies.
14 I perceived myself in a position of somebody asking 15 me could I have done more to look at Q1 and the answer 16 obviously is yes since I had only looked at half of it. So i 17 asked for the offices to provide me support, (S E , NMR, Regidn 18 IV and 01, so I could send out a combined team. I sent out an 19 SES Olvision Director to lead 16 people starting on Monday, 20 the holiday, at 8:00 o' clock in the morning and they looked at 21 one hundred percent of the files, all of them.
22 in some half a dozen cases the staff through a 23 systematic review process identified about half a dozen items 24 which the file looked a little weak on technically and if it 25 wasn't resolved well could have been a concern to the staff on
i .
P 41 1 full power licensing-2 They went out and did further field inspections to 3 make sure that that was okay. So if you would, that is the 4 genesis and the background of the review knowing that this 5 meeting was coming up and trying to give you a stronger 6 position in light of the questions that were raised t han- l 7 felt I was in a position to do earlier with just a 50 percent G review.
9 COMMISSIONER BERNTHAL: But there had been no ,
10 understanding that ran throughout the period of,this Q1 11 program and I don't even know when it started, there had been 12 no understanding from the day of its inception as to how an 13 allegation which perhaps the licensee felt it could not handle 14 or an allegation which it felt was a significance, perhaps 15 even public health and safety significance, how the interface 16 would be handled then between the licensee's voluntary program 17 and findings and your office? Is that a fairestatement? .
18 MR. MARTIN: There was the understanding that those 19 files were open to us in their entirety at any time we wanted 20 to walk in.
L 21 COMMISSIONER SERNTHAL: At any time. Oh, tnere was.
22 MR. MARTIN: There was no stipulation that anything 23 they found would be handled in any other fashion. That is I
24 open information with us. We looked at them as to whether or 25 not they reported them to us, if they were required to be
42 1 reportable under the reporting regulations, information and 2 names. There was a very open dialogue with such things as 3 enforcement would have been handled the way we handled any 4 enforcement case given it is a program where the licensee 5 identifies and takes appropriate corrective action.
6 COMMISSIONER BERNTHAL: I have to say that aside 7 from the fact that maybe the licensee was overly enthusiastic 8 in appraising its own program if we have had access to those 9 files from the very beginning, one licensee might do a program i
10 that is better than our own 01 could do and another licensee 11 might do one half as good and another licensee might barely l
12 scratch the surface of collecting complaints and putting them 13 in a file and saying, "There they are, NRC."
l 14 It is not clear to me aside from the apparent flaws l
15 in self-appraisal perhaps that the fault doesn't lie at least 16 in part at our doorstep if we have had five days in the last 17 week to do all this.
18 CHAIRMAN PALLADINO: I was thinking of doing the 19 following during the.open-meeting. At what looks like the 20 appropr ia te time I would state that I understood that there 21 had been a review of the Q1 program and ask Bob Martin to give 22 some background on that such as he..just did and then ask Ben 23 to give his comments.
24 .
COMMISSIONER ZECH: May I ask Ben just one more _
25 ' question? ,
49 1 CHAIRMAN PALLADINO: Surely 2 COMMISSIONER ZECH: Ben, as i understand it. you are 3 telling.us that in the case of wrong doing in the Quality 4 First program. .you are not satisfied that it was either 5 complete and you can't give us any conclusion in their wrong 6 doing allegations?
7 in other words, you are tellirg us that you are not S sure whether they were good or bad and you can't give us any 9 conclusions, is that correct? ,
10 MR. HAYES: That is partially true. My statement to 11 the Commission is that the files that we have reviewed 12 certainly did not reach our understanding as to what a 13 competent investigation would entail
. i 14 COMMISSIONER ZECH: I understand that, right. But 15 do you know of any wrong doing, do you know of any reason in 16 your-area of responsibility that'this plant-should not be 17 authorized to go to full power?
18 MR. HAYES: That is very difficult because with 21 19 allegations of narcotics or what-have you where we feel 20 uncomfortable with the intimidati>n/ harassment files, the
-21 falso documents, we have a litany of false documents and l' am 22 not sure what the criteria-Es for a full. power operation.
23 24 1
25'
- 44 1
2
?
4 5
6 7
8 9
10 investigations? Do you have any other investigations that you 11 think ought to be started?
12 COMMISSIONER BERNTHAL: That is the key question it 13 seems to me.
~
14 COMMISSIONER ASSELSTINE. That is r i g h t'.
15 CHAIRMAN PALLADINO: That is why I asked it.
16 COMMISSIONER ASSELSTINE: It focuses on those 77 17 files that they have looked at. If I underst&nd what you have 18 been saying, Ben, it is that in the case of 77 of these files 19 dealing with wrong doing, there are-allegations of wrong doing 20 involving harassment / intimidation,' falso documentation and 21 drug abuse and'you can't tell whether those have been ;
22 satisfactorily resolved.
23 MR. HAYES: That is correct.
1 24 COMMISSIONER-ASSELSTINE: Based upon the 'information 25 you have now, those may well.be open questions about this
t-
- 45 1 plant.
MR. HAYES: That is correct. On the other hand, we 2
3 have searched our memories to determine whether we have 4 regulatory authority here for those people to notify us of 5 these issues. We find a very large void there.
6 COMMISSIONER BERNTHAL: For what people to notify 7 us?
8 MR. HAYES: The applicant. In fact, when I was on 9 site and I saw these matters of wrong doing, I said, "Who,n do 10 you notify the region that you have received an, allegation of 11 false documents?" They said, "We do not."
12 COMMISSIONER BERNTHAL: That is precisely the point 13 I was making earlier but we were free to walk in anytime and
~
14 look at those files.
15 MR. HAYES: Absolutely.
16 COMMISSIONER BERNTHAL: We didn't do it until a week
' e 17 ago.
l 18 MR. HAYES: There have been half a dozen inspections ,
19 conducted by the staff of the Q1 files.
20 COMMISSIONER BERNTHAL: Of Ol's staff?
i 21 MR. HAYES: No, Region IV, since last year.
22 COMMISSIONER BERNTHAL: Nevertheless, here we are 23 the last week, right, and the fact is and I think we should 24 get back to Joe's question if I may because it is the key f 25 question,'now you have gone through the files and you have
- I e
- 46 1 looked what is in them and what isn't in them. Is there 2 information there that would lead you to open investigations?
3 MR. HAYES: What our game plan was as of this 4 morning when we got briefed by our-two investigators'who did 5 the review is that I am scheduled to go to Region IV in two 6 weeks and I want to sit down with the staff and go over their 7 notes.
S We don't have the detail of their notes and they 9 made detailed notes of the review of every file'to determine 10 whether or not there was such a matter there that we didn't 11 think was oursued that was significant and we may open up an 12 investigation just to close those particular matters out.
13 As Bob Martin said, he and I have struck an a
14 agreement to meet with the applicant on some of these issues I 15 and we may find it necessary to protect the Commission here to e
16 do our own investigation to validate if nothing else the l
17 applicant's conclusion there.
1 i 18 COMMISSIONER BERNTHAL: I will quit talking here.
19 it still seems to me -- !
20 CHAIRMAN PALLADINO: We are opening up a can of i 21 worms. j i
22 COMMISSIONER BERNTHAL: When was your office first a
23 asked to look into these files?
24 MR. HAYES: The Friday before the holiday.
25 COMMISSIONER ASSELSTINE: Before Memorial Day.
__._j
. 47 MR. HAYES: Before Msmorial Day.
1 COMMISSIONER SERNTHAL: So we are talking about 2
3 whatever it is, ten days ago at best or something like that.
4 It seems to me that the licensee would have a legitimate 5 complaint because these files have been open from the very 6 beginning.
COMMISSIONER ASSELSTINE: That may be but don't 7
8 forget that the genesis of this kind of program really came 9 in urgings by us and by the staff to licensees that they bad ,
10 better gee involved and they had better set up effective . . . . . .
11 programs to identify these concerns and make sure they are s
12 resolved.
13 The warning was that if you guys don't do it and we 14 get to license decision day and there are still all these 15 things that are still open that are questionable that haven't 16 been resolved, then you have a problem.
I 17 So whether we should have looked at'the files befdre l or not, the applicant had an obligation to set up an effective l 18 I crogram to lay these issues to rest. That is what they told 19-20 us they were doing.
4 21 CHAIRMAN PALLADINO: But they c aim they have.
COMMISSIONER BERNTHAL: Or at least to bring to the 22 23 attention, if they weren*t going to do it if there were open
{
24 issues that anyone could see, for example, the drug issues 25 that either by their own inadequate personnel or whatever it l
- ~. _ _
- 49 1 might have been they are unable to resolve, then one would 2 think that they would have preferred to' step forward and bring 3 our attention to files even though we might not have on our 4 own initiative gone in and looked at them.
5 1 think there is a problem on both sides here, 6 CHAIRMAN PALLADINO: I am going to suggest that we 7 terminate this meeting. We do ask General Counsel to review S the transcript to see that only the closeable material remains 9 closed and then to do whatever is appropr#2te on the o t h e,r .
10 Anything more to come before us at this time?
11 (No response.)
CHAIRMAN PALLADINO: All right. We w i l l adjourn 12 13 this meeting and reconvene in about five minutes which should 14 give the audience a chance to come in.
15 (Whereupon, the Commission meetfhg was adjourned at 16 2:33 o' clock p.m., to reconvene at the Call of the Chair.)
17 t,'
18 19 20 21 f
22 33 m:
24 25
7,
. 1 5
. l i
1 t:ERTIFICATE OF CFFICIHL REPORTER 2
3 4
5 Th6s is to certify that the attached proceedings 6 before the United States Nuclear Regulatory Commission in the 7 matter of Commission Meetilig - CLOSED e
(Exemptions 5 & 7) ..
9 Name of proceed 6ng:
Discussion of Pending Investigations
' ' ' ~ '
10 11 Cocket No.
t2 place Wa3hington, D.C.
17 cate: Monday, Jund 3, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the Un6ted States Nuclear 17 Regulatory Commission.
13 (Signature) %4g yq giw (Typed Name of Report 4r) Marilynn Nations 20 El 22 23 Ann Riley 4 Associates. Ltd.
24 25 c