ML20147E544
| ML20147E544 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 05/08/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 NUDOCS 8801210150 | |
| Download: ML20147E544 (28) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION OR/G WA IN THE MATTER OF:
DOCKET NO:
INVESTIGATIVE INTERVIEW OF PHILIP R.
CLARK, SR.
LOCATION:
pArg ppAn, Ngg ggngry PAGES:
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DATE:
WEDNEs:AY, F'J.Y 6, 1985 i
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NUCLEAR REGULATORY COMMISSION I
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....___.........__........X.
4 In-the matter of 5
INVESTIGATIVE INTERVIEW 3
'6 of 4
7 PHILIP R.
CLARK, SR.
_x 8
9 i
10 GPU Nuclear CorpOratich 100 Interpace Parkway 11 Room 308 Parsippany, New Jersey 07054
,l Wednesday, May 8,- 19 85 g
13 '
l 14 15 The Investiga*.ive Interview of PHILIP R.
CLART.,
j 16 S R. commenced at 9: 03 a.m. be f ore Richard A.
- Matakas, 17 j Investigator, Nuclear Regulatory Commission.
18 M,
ON BEH ALT OF THE NRC :
i 20 Richard A.
Mat ak as i
U.
S.
Nuclear Regulatory Commission
,) :
Region I 631 Park Avenue 22 Pennsvivania 19406 Kinc of Prussie, I
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MR. MATAXAS:
Okay.
The date is May 8th, 1985, 3
and the time is 9:03.
Present for this interview are myself, 4
Richard A. Matakas, Investigator, U.
S. N.
R.
C., and Mr.
5 Philip R.
Clark, Sr., GPUN President.
6 The purpose of this interview is to discuss f acts 7
and circumstances leading to GPUN's submittals to the NRC 8
involving the environmental qualification of electrical equip-9) ment at TMI Unit 1.
10 g Mr. Clark, do you have any objection to giving this 0
11 li information under oath?
i!
I MR. CLARK:
No.
12 i
l 13.
MR. MATAKAS:
Would you raise your right hand, i
1r ;
please?
1!,
(The witness, Mr. Clark, is sworn by Mr. Matak ar.
16 i Whereupon, 17 '
PHILIP R.
CLARK, SR.
L 16,
is called as a witness and, having first been duly sworn, l
l 10 l testifies as follows:
l 2
EXAMINATION BY I
21 '
MR. MATAKAS:
l 22 0
Mr. Clark, you started with GPU Service Corporation 1
23 i January 20 th, 1980: is that correct?
24 A
Yes.
4
.. mwom, w I 25 l Q
As Vice President, Nuclear Activities?
I
)
(.
3 1
A Right.
2 0
And then on November 25th, 1984 you becama Presi-3 dent, GPUN, your cur ent position?
z 4
A Yes.
In the interim, in January '80 I became 5
Executive Vice President of GPU Nuclear.
So,_from January 6
' 82 until November ' 83, I was Executive Vice President, and 7
in November ' 83 I became President.
8 0
That's right, Novembe r 25 th, 19 83 ?
9-A Yes.
I i
10 l
0 okay.
Wnat I would like to talk about today firs 11 is a GPUN Internal Audit that was conducted back in 1981 be-i l
tween, I believe, March 27th and April 1st of 1981.
12 I
13 The audit number is 81-02.
And the cover letter 14 on this audit is dated June 25th, 1981 and has a letter 15 number of QA/41-61.
i 16 The response to this particular audit could not b(
17,
located.
But what I was provided with is a OA response to is !
the Technical runctions response which in effect restates the i
I original response, what the original response was.
There is I
20,
also a cover letter on that dated June 25, 1981 and has a 21 ;
letter nummer of QA/41-86.
22 Followine that, there was a revised response by 23 Technical Functions.
The letter number is EP&I 81/0176.
And 24 that is dated August 21st, 1961.
u
.. m. w rwrt inc.
25 And then the last letter we will be talking about r
4 I
at this point is a memorandum dated April 4th, 1984, the 2
subject of which is Open Audit Findings for GPUN Internal 3
Audit 81-02, and it's f rom Mr. Guimond to Mr. Stromberg.
4 What I would like you to do is take a look at 5
these documents, if you would.
Ignore the scribblings in the 6
margins on some of these.
7 I would like to ask if you recognize them.
And 8
the reason that I am presenting these to you is that I notice 9
you are on distribution on the original audit and the revised 10 :
response.
II.
lI (The witness is looking at the documents.)
11 I
Well, I don' t have any recollection of this audit 12 A
i 13 report or, say, I am typically on distribution for all of the 14 audit reports.
I usually -- you know, I am not assigned 15 action.
But I have chosen te get ther to keep a general 16 l sense of what the audit results are.
t l
17 ;
I f requently look through the audit reports and
)
i 16,
i f the re is some thing that I particularly want to call atten-It tion to, I may direct some comments or questions arising f rc:
I 20 '
the audit report to either QA or the people involved.
I do t
21 not have any particular recollection of this audit report.
i 22 o
okay.
You mentioned that you f requently review l
1 1
I j
23.
the audits in case you have a question -- throughout the e
24 history of this particular audit, and what I mean by history l
j
-r m.=mn. inc.
l 25 l
is the responses and revised responses and memorandum, ref errin t
i l
l i
f:.
5 1
to this particular audit, did you have occasion for any
}-
2 reason to get in contact with either QA or Tech' Functions 3
regarding the subject of the audit?
4 A
I don't recall having done so.
It has been almost -
5 this starts almost four years ago, and probably two audit 6
reports a month.
7 O
At any time, have you had any discussion with 8
members of either Tech Functions or QA regarding environmental 9
qualification?
i 10 0 A
Certainly, yes.
I think the strongest recollecticns 11 i
of that are during the last year where there has been a lot l'
12 of focus on environmental qualification.
I guess early in 13
' 84 focused on TMI-l emergency feedwater and then broadening le '
out, you know, from that.
15 O
Prior to 1984, do you have any recollection of 16 ;
such discussions?
17 j A
No.
I don't, although clearly environmental it,
qualification has been a long standing, regulatory requirement I
W or concern.
And I would think that the re, you know, would 20 '
have been some discussions.
i 4
21 I certainly was aware of the environmental qualif;-
22 [
cation rule and the f act that we had efforts underway to deal l
23 ;
wi th i t.
I suspect that there are budget activities which,
l 24 you know, deal with work on environmental qualification.
v.. n oori.. inc g
25,
So, I'm sure, you know, there were some discussions I.
6
)
but I don' t really remember any particular one back much s
2 '!
earlier than last year.
. (' -
3 Q
Okay.
Also, did you state that you do not recall 4
seeing either the revised response or the. responses regardin-5 this?
6 A
I had only looked at the audit.
Okay.
Why don't we just take a 8
two minute break at this time for you-to look at these?
1 9j (The witness is looking at the documents.)
i 10 WITNESS CLARK:
Okay.
I have attempted to skir l
4, 11 l
all of them.
(Continuing) 13 Q
Okay.
If you would, do you recognize any of these le documents?
'5 A
1 don't per se.
I see that at least on two of 1
16
- them I am lis ted on the distribution.
These are typical of 2
i 17 ;
things, you know, that I would be sent copies of.
j I
15 Q
At any time, either be f ore or af ter 19 8 4, did you ever have any discussion with Dr. Long about the TMI EQ l
2C program?
21,
(Pause.)
i 22 A
I'm not certain in terms of discussions directly 22 with Dr. Long.
I'm inclined to think that probably in 19 84 24 where I did have, because environmental qualification then vu we num,m is q
25 -
getting a lot of management attention -- I don' t recall the i
7 1
specific conversation but I would think it likely that I did.
/
2 Q
Okay.
What I'm getting at is, information has
\\
3 been provided to me that Quality Assurance had approached i
4 Dr. Long with some problems regarding the EO program at TMI-1.
5 What my question is, do you recall Dr. Long relat-6 ing either that meeting or the contents of that meeting to 1
7 you?
s A
No, I don't.
My strongest recollection of people 9
identifying problems with EQ is Mr. Wilson a number of tires -
10 and I'm going to say starting in early 198',, identifying in l
staf f meetings to me and the rest of the staf f that environ-11 c
12 mental qualification needed a lot more attention, needed sup-13 port f rom the plant divisions in particular, in addition to
(
l 14 his own people.
)!,
And also a discussion that we -- QA was involved.:
16 auditing, you know, the files and helping, you know, had 17 l identified a number of deficiencies which they were address-16 ing.
ic Q
Do you recall when he brought this subject up a l
1 2;.
the staff meetings?
Was it af ter the UCS petition?
Was it l
21 before the NRC March 20-21 audi t?
I l
i 22 '
A I don't remember timino relative to the UCS peti-I 23 l tion.
I don't, you know, even really remember when that was.
5 24 0
I t was J anuary ' 84.
3 i
= anoms w 1
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l 25 A
Okay.
I remember, you know, kind of early
'84, and l
l r
i
)
I 8
J1 I believe there were such discussions before the NRC March 2
action.
3.
O Was there any discussion in these staf f meetings 4
that GPUN may contract out for assistance in the area of 5
environmental qualification?
6 A
I certainly. was aware that we were proceeding to y
do that.
I don't remember the exact time, but the sense was 8
that we recognized somewhere, let me say, in the Spring of 9
' 84 roughly that the ef fort required on environmental qualif:-
10 cation was substantially greater than we had previously under-11 l
ntood or planned for.
I 12 That in order to do it and do it in a timely way 13 we were going outside.
And I remember Wilson talking about it i
le was going to take twelve, fi f teen, twenty people te really er 15 focus on it.
And then a number of, you know, calibrations 16 !
with Wilson during, I ' m goi ng to s ay, mi d ' 8 4, includine an
l 17 te am, I guess, a couple of times to audit files.
And I me t 18 with them one time at the end of that.
And I believe we had, ic,
I believe it was probably IMPELL, the people we contracted i
i 20 wi th,
i I
21 Q
Okay.
That was sort of my next ques tion.
Was ther 22 a specific point in time that af ter you became aware that 23.
there was a problen in the area of environmental qualifica-I 24 '
tion at TMI-l?
we amorwn w f l
25 A
I would say kind of a -- my own sense is a growin:
9 f
I recognition through early Spring of '84 that there was, you
[
2 know, a problem.
And the main input that I recall was fror
[
t 3
Wilson in terms of discussions of that.
4 I think at one point -I had a comment from NRC, I 5
think probably Ed Case during or after a meeting down there 6
where he said that his people felt they really we ren ' t ad-7 dressing EQ properly.
And I came back and discussed that a
with Wilson.
9 And subsequently, as I recall, May or June time-10 frame we made some major changes with -- in the people withir i
11 i
GPUN who are responsible for dealing with the EQ program.
l And reassignments and, you know, adding additional efforts.
12 i
13 I'm not sure, within a month or two, you know, of what I'n 14 saying but my sense is this was during the early Spring of u
'64.
u C
Was it ever pointed out to you that certain inte:-
i 17 l nal audit findings as well as TDR deficiencies had stayed open for an extended period of time?
16 l 1:
A
- think that during that same time period whcr. we 20 were, you know, focusing on where are we, why is there se 21 !
much left to do, there was discussion of the f act that earl c:
i 22 audits had identified problems in that area.
l I
i 23 '
O Okay.
Earlier on, would that be internal audits i
24 A
Yes.
i we mwenm =
l 25 0
And who was providing you with this information?
>.I i
10 1
A I don' t remember whether it was Wilson.
It might j
2 have been Dr. Long.
It could well have been in one of the 3
staf f meetings where we talked about this where they would 4
typically both have been present.
5 0
Is there anything that stands out in your mind 6
that was related to you or that you have learned through 7
observation or whatever as a major problem or problems with 8
the environmental qualification program that relates to the i
9:
early stages or the problens that were first identified to 10 6 you?
11 A
My recollection goes something like this.
Initial?
17 !
it was thought to be, and it was described, as a documentatier 13 problem and that the problem was accumulating in one place, 14 the documentation of the environmental qualification in an 15 auditable way; that as time went on that the following ac-16 ditional elements began to appear:
one, that the relian:c 17 which had earlier been placed on vendor certification was, you 16 know, not acceptable, and that in addition to simply hav n; I u
letter from the vendor saying he had qualified t that we ougr :
i 20 '
to be getting the test report, reviewing the test report, 21 basically doing more review ourselves.
22 l Second, somewhere -- in addition to that, some-l 23 '
where around April or May of '84, as I recall it, there was 24 recognition that the rule applied not only to lists of equi;-
ermooma =
4 25 '
ment required for safe shutdown, but that you also had to I
i
i r
11 1
nddress other equipment in connecting systees, and you also
('
2 had to address equipment which while not requi red for safe 3
shutdown, if it failed could mislead the operator.
4 understanding is that that was viewed by us as 3
a considerable expansion of the scope of the EQ requirements 6
beyond what we had understood before.
7 Q
And when you say "an understanding that we had" 8
are you talking about information from Mr. Wilson, Tech 9
Functions area?
10 !
A The primary source of information to me, as I 11 recall, was Mr. Wilson.
But it was a number of discussions it.
l the staff meetings which would then have had Dr. Long or a 12 I
i 13 representative if he couldn' t make it, and other people in l
14 '
the re.
u Now, I think aise my current reccllection is ui probably coAored a little bit by the f act th at in March of p
this year as we came down to the March 31st date on the EC n,
rule, and we had a lot of focus on Oyster Creek, you know, l
); '
we have gone back and I've had prepared for me kind of a i
20 chronology of EQ at Oyster Creek.
You know, that highlights i
21 !
some of the dates.
22 And I think there is a May NRC letter on EQ or
(
23 l bulletin which addresses the scope of EQ and particularly 24 I addresses this question of connected systems and indications 4
4.- mnomn w 25 which could mislead the operator.
I recall some thing around
12 r
1 1
April or May from NRC on that subject.
So, you know, I have i
i
[
1 2
been looking back over the history of E0 at Oyster Creek here i
j 3
within the last six weeks.
4 And so probably some of my recollection is kind cf j.
5 based on that recent look.
i l
}.
6 Q
Is that April or May --
I t
5 j
7 A
.Yes.
[
b 8
Q
-- 1984 NRC letter?
9 i
A Yes, as I re call.
t j
i 10 l Q
And was this something new added to the program?
j i
11 A
My understanding is that th at formali:ed an expar.-
l li
)
12 sion of the EQ program beyond what we had previously under-l I
13 stood, formalized it for everybody and really picked up thinp l
q f
t I
i 14 which had been discussed shortly prior to that as we worked j
1 1
f with the staf f on the TM: environmental qualification prograr
]
e i
16 i So that as we worked on TMI there was discussion 17 !
that, gee, you ought to be addressing these other things,
j t
6 16 which we had not been, and that at some point there was this,
i I am going to call it a bulletin -- I don' t remember the ferr - !
I 20 '
which said, something out of NRC, th at this clarifies or do: -
i i
21 ments, you know, interpretations of EO requirements.
22 O
Were you told, or are you telling me, that this vn j
23 !
the cause for previous deficiencies in the program, i.e. t r. +
j 2d lack of documentation to qualify components?
.. nw.mn im 25 A
My understanding is that prior to, I will say, Spr;:
l i
. n-13 i
i 1
of ' 84 roughly, our understanding of.the reguirements was j
2 that they were more limited in terms of what had to be ad-3 dressed, in terms of the requirement for how f ar the utility t
4 had to go to verify the - vendor information; that our under-i 5
standing of the requirements I believe was much more limited, t
t 6
and our understanding the scope that was desired increased t
7 th rough that pe ri od, I'm going to say, f rom early ' 84 to
[
8 mid ' 84.
i 9
0 okay.
I understand that.
But are you saying to 10 me. that it's your understanding that you were addressing what D
you knew to be the scope, or what you thought to be the scope,
I 12 of the EQ program at TMI prior to this letter or bulletin ir.
i 13 a satisf actory manner, and there was no lack of documentatior.
i 1
14 based on Tech runctions' knowledge of the program?
15 A
No.
I wasn' t trying to say quite that.
I think 16 !
perhaps my understanding goes in twc parts.
I l
17 one is that as we addressed it in early ' 54, it
]
15 was clear that the documentation wasn't in adequatc shape evs:
i 1
lt j
on the scope that we had understood.
Second, and separate I
i 20 (
f ror that in a way, is that the scope became greater than we l
i 21 had unders tood it to be.
I think it's f air to say my under-f t
}
l 22 standing and belief is that we were not alone, that many j
l 23 utilities also found that the scope of the -- or the interpre-i 24 l tation of the scope of E2 became greater than they under-
[
j r amom<i. im 25 '
stood it.
t i
i
(
14
)
For example, in March of '85 my understanding is
{
2 there were people coming in with revisions to their EQ s
3 program as the March 31st date approached and adding stuff 4
to the list in the last week.
5 0
This was the second extension; is that correct?
6 It was originally extended from December 1980 to March 1985, 7
and now it has been extended again?
8 A
I think the March '85 was not the first date.
I 9
l don' t remember what any prior date was.
And the March of 'E5 10 g was, you had to have in -- either be in compliance or formall) l request extensions which by and large were requested through II 1
12
{
November 30th, '85 I think, by a number of people includin?
13 us.
l 14 0
During the time period when you started becoming 15 more involved in the E; program, was it ever brought to yo;r 16 i attention that there was also a problem in the area of manaps-I 17 :
ment direction?
That is, assigning of responsibilities, whc 15 should be doing what?
4 A
I don't recall anything exactly like that.
B;-
20 what I do recall is that somewhere in April or May of ' 84 a 21 l conclusion communicated to re by Wilson that he and his 22 people under him -- I'm not sure who -- had decided that our 23 management had not been what we needed and that there was
?d re as signment of responsibility at that point.
.. n.= wi, w 25 And the only thing dif ferent f rom what you've said, 4
15 l
i
)
I don' t remember his saying that the assignment of responsi-l l
- - {
2 bility wasn't clear.
I have more a sense that he felt that 3
the person who had been assigned it hadn' t carried it out.
4 0
I'm talking about specific audit findings.
For l
3 instance, back in 19 81, the audit 1981, in both recommenda-6 tions and findings.
7 A
I really don't recall any specific discussion of 8
that point.
9 O
What about in the area of training of the Tech 10 Functions people?
Was it ever brought to your attention.that I
11 l
that was needed?
12 A
Given a sense that in order to complete the EQ i
13 program, that we had to see that the people doing it really i
te -
uncerstood the scope and what was required and, you know, th a t j
13 this was different than we nad previously understood.
i
)
le <
think there clearly was a sense that we ' ve got to get people a
i 17 l up to speed or knowledgable with regard to the requirerents l
16 ao we can finish this up properly.
I i
i M
0 Why is Mr. Wilson now signing E0 correspondence ::
l 20 l NRF. instead of Mr. Hukill?
i j
21 -
A I think that's part of the general approach that a
22 I' ve been taking, trying to take for awhile, which is that ir d
t l
23 our organization, you know, as reflected in the tech specs, j
24 :
as in the GPU Suelear basic organization, the to=hnical engines q
- v. amorwn. im !
25 ing work really is not under the direction of Mr. Hukill or i
4 i
a 16 1
Mr. Feidler (phonetic) at Oyster Creek.
And that while the 1.
2 practice in the early days was that the Plant Director signed l
3 all the correspondence going to and fnxn NRC, so that it was not 4
appropriate any longer for that to be the case.
5 So, for example, we have Mr. Heward (phonetic) 6 signing some correspondence which is strictly radiation con-7 trol or environmental.
I g
i Q
Mr. Heward?
i 9 C A-H-e-w-a-r-d.
He is the Director of Radioloaical i
k 10 and Environmental Controls.
It goes not only to NRC but the i
b 11 k State Department of Environmental Resources, that where the 12 subject of a letter is entirely or almost entirely within the 13 area of responsibility of somebody other than the Plant Dire::c !
I i
le that we have been looking to have that person sign the cor-
\\
r 15 rescendence.
i f
16.
Tne concern is that you want the Plant Director I
i j
I? (
to have an awareness of everything going on that ef fects his 1
i 16 :
pl ant.
So, there is still a tendency for the Plant Directer j
l j
"4 to sign mos t o f i t, and in particular if there is something j
l l
2D !
which involves several parts of the organization you typically i
i 21 !
have the Plant Director signing.
l 1
I 22,
O But in the area of environmental qualification, l
I E
23 l then this is essentially and has been part of the control l
I
]
24 '
responsibility of Tech functions?
4
.. mnems x I
25 A,
Yean.
They've had the lead to de i t, and I thinr.,
i l
1 I
i 1
l 17 i
1 you know, that's an example of areas where we have been loor.-
2 ing to have the Division Director, with the primary responsi-f 3
bility whose people have done the bulk of the work, sign the l
4 correspondence as being more appropriate than asking the j
5 Plant Director to sign it.
1 6
Q Af ter you realized -- or, af ter several problems 7
were identified to you in the area of EO -- I'm talking at 3
TMI-1 -- did you attempt to determine the cause of that l
l 9'
probler or specific problems?
I i
10 !
A Yes, in the sense that, you know, I h ad a numbe r I
i 11 of discussions, some with hin initiative, some at eine, witt
[
t 12 ]
Wilson as to what the problem was, why, what he was doing 13 1 about i t.
I
'e' In addition, the discussions included, altheur? :
M don't think it was at my initiative, the f act th at the QA 16 was heavily involved in reviewing the EO situation, and 17.
17 :
the sense checking that we were satisf actory bef ore we made 15,
further sub :ttals or were subjected to further NRC audits i
M on the sub)ect.
20 So, I say I don' t recall if that was particu.'.arb, 21 '
my initiative but I was aware of the f act that that was be n:
22 done.
l 23 ME, MAT AKAS :
Why don ' t we take about a two minutt 2d i break?
we nowws. sm 25 (Pause.)
18 1
BY MR. MATAKAS:
(Continuing) 2 l
0 Mr. Clark, what I would like to show you is two 3
One is signed by Mr. Hukill and is 4
dated May 20th, 1983; the letter number is 5211-83-157, thc 5
subject of which is Environmental Qualification.
6 The second letter is dated February 10, 1964; 7
the letter number is 5211-84-2038, and it's signed by Mr.
8 Toole for Mr. H ukill.
O I would like for you to take h minute and lock 10 over those documents.
11 I (The witness is looking at the documents.)
li 12 1, A
Yes.
e 13 i o
If you will note, the attachments on there are th t
'e review of correspondence that was provided to me cy ei the r Mr.
'I h ui; _ a l o r Mr. To le.
le A
I would e:cect those would be in the file witr t..+
17 le t te r.
IE (The..tness is looking at the documents.)
All right.
I have reviewed them.
20-0 Mr. Clark, do you -- you have had time to reviev 21 bo th do cume nt s.
D: you recall ei ther document?
2 *-
A No.
22 O
Did you have any review regarding ei ther resocr.sc 24 before it was submitted?
e
.. n morwi i m 25 A
I don't believe so.
I dor.'t recall ar.y.
I
i 19 i
1 Q
Any discussion with anyone about either response I
2 af ter its submittal?
3 I tell you, let me ask you that in a dif ferent way.
[
4 Did you ever become aware -- or, when did you become aware of 5
the allegations that these two submittals contained f alse 6
statements?
7 And, specifically regarding the May 20th document, r
s the statement in Section 1 under Safety Related Electrical f
9j Equipment, I will quote, "The additional information we sub-d 10 '
mitted in our letter dated May 3, 1982 and May 16, 1983 sup-11 port our conclusions that components listed are qualified ir.
a D
13 g accordance with DOR guidelines dated November 1979."
i N
13 j And then the February 10 letter, this statement, I l
i
'e quote, says:
"It is GP!;S's position that TMI-1 is currently
)
15 in compliance with environmental qualification Rule 10 crE
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i 16 !
50.49 as applicable to TMI-1. "
i 17 l A
My recollection is again in early ' 84 as we ad-j 15,
dressed the environmental qualification issue that signi fi c ar.:
1 1
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further work apparently was to be done on that subject, and I
l t
2; the question arose -- and I don't renen6er a particular err.-
21 versation, whethe r or not, but in discussion of environmenta; 22 !
qualification that there were prior submittals by the Company 23 and the fact that we were now, you know, submi tting additior.t; 24 information was clearly scing to cal; into question the earh:
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s ubmi ttals.
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Q Okay.
Now that's a matter of what is your under-
.[
2 standing of additional requirements, but. I'm talking about 3
other than that particular matter.
We sort of talked about 4
this earlier whe.re you separated thir. - into two parts.
S What I'm talking about is the f act that even with 6
the understanding that existed prior to -- and I'm talking 7
about the understanding of the individual components which 8
needed qualification, prior to the March 20th,19 84 NRC audit,
9N these same allegations pertain.
In other words, to lack of i
10 l documentat? on to -- or lack of documentation of the individun Il l components that had already been identified and were being 12 addressed by the TMI-l EQ Branch.
13 A
I didn't follow the question.
I le '
O In other words, basically both 50.49 and DDR 15 guidelines require that dccumentation and auditable files os le maintained on individual components to establish qualifica-l 17 l tion.
15,
Okay.
Prior to the NRC audit the re was TDR de-i ic '
ficiencies that were noted, there were internal audits and er 20 individua2 components which, even in the early days, the EC 21 Program or the individuals managing the EQ program knew these t
22 i components had to be qualified, that there was documentatior.
23 lacking on those individual componer' l
24 l And what I ' m talking about, related systems or --
(
y.- ne:nnm ine 25 that 's what I'r talking about, these statements pertain tc i
21 1
those particular components, not anything th.at was introduced
- [
2 as a result of an NRC letter or bulletin in April of 1984.
3 A
See if this addresses it.
I think somewhere early 4
last year, I became aware of the f act that what we had in our 5
files was not judged to be satisf actory in terms of organiza-6 tion, completeness, but in particular in terms of having 7
vendor information in our possession as opposed to having a, 8
if you will, letter f rom them.
The question was, we might 9y have a letter f rcm the vendor but that we wouldn' t have the I
10
- test report.
c l
So, it clearly was a sense that the documentation 11 12 on that equipmenc was not complete.
I don' t recall any sense 13 at that point that there was equipment which in f act was not I
1e qualified which we had thought was qualified.
15 You know, the focus in the discussion was or th e 16 documentation and the need to comr'.ete that, or to get i t ir 17 some cases, and on what I will call the increased scope of 16 equipment which had to be addressed.
1:
That's my sense and recollection of what I under-20,
stood about it.
21 0
Are you aware that certain components in fact 22 I'n talking about hardware items -- did have to be changed, 23 that they we re n ' t, in fact, qualified for one reason or 24 l ano the r ?
-e R wo,wi i n: j j
25 '
A I'n aware that certain equipment was changed.
I
22 1
guess I'm not certain that any was changed because it was 2
concluded that it was not qualified as opposed to a' conclu-3 sion that the documentation that it was qualified didn't 4
exist and it was easier to change it than to prove it was 5
qualified.
6 I guess I wouldn't make a fla; statement that 7
there was none that was found to be unqualified.
I don't 8
know, but I don' t recall that.
9!
The thing I do recall is the conclusion that there l
10.
was equipment demonstrating it was qualified with a full i
11 N documented file that was -- it was judged to be harder or net i
l 12 i
worth pursuing as opposed to simply replacing them.
So I I
13 1 am aware of that.
1 le o
But you do understand that both the DOR guideliner 15 and 50. 49 do require that in order for a component to be 16 qualified there must be documentation establishing qualifica-17 l tion?
16 A
Yes.
O Have you looked into the matter regarding these 20 allegations, and have you made a determination of the validit 21 of the allegations or mitigating circumstances or whatever?
22 A
In terms of what I will call an investigation 23 [
similar to what I' ve done in other areas, no.
1 24 !
n You mean, no, you have not conducted an investigs-i; we= n nemn. s ns '
25 tion?
1 23 1
A No, I have not conducted an investigation.
I 2
think you recognize that there are certain awkwardnesses ir 3
our conducting a concurrent and parallel investigation into 4
a matter that we know NRC is investigating at the same time.
5 And while I've done it in a number of areas, I 6
judge that I would not do it on this one.
7 0
Okay.
Is there anything else that you would like 8
to say?
9[
Do you have any other statements?
10 A
I guess I've got a question which I would like tc 11 hear an answer to before I see if I have anything further tc 12 l
say.
Nothing comes to mind.
13 What exactly is the scope that you are pursuing i
le '
herc?
What is it that you are investigating so I can thin):
15 about whether there is anything further I, you know, would 16 I want to tell you?
17 '
O Basically the allegations that the statements made 18.
in these two documents state that GPUN, number one, is in ii qualification with -- or is in compliance with DOR guidelines -
20 ;
and in the latter letter, that it's in compliance with er.-
21 vironmental qualification Rule 10 CFR 50.49.
22 1 And audits subsequent to these two submittals,
I 22 according to the people conducting the audits, have indicated 24 o the ra i se.
q
. n. m n.
i,c 2!
And what I'm looking into is why this happened and l
m.
24
)
who is responsible.
2 A'
Well, my general senso of that is that the environ-
{
3 mental qualification requirements which had been around for 4
'a long while in one form or another have, in f act, evolved 5
both in terms of scope and detail and that as a result of that 6
our understanding, full understanding, of what is now wanted 7
came late.
That it in particular came in '84 at a management 8
level, which I have in mind Dick Wilson, for example, who is 9 l the main interf ace that I have.
And that I suspect the rea; i
10 i
element of this investigation is going to go to the extent to which what was said was good f aith belief at the time the II 12 statements were made.
13 Q
Well, I think it's more than that.
I think it 's I
it both a good f aith belief and if that's the case, you know, vr-9 did it happen?
16 Was it because the program wasn't defined wela 17 ;
enough?
Or was it --
16 A
S ure.
I wasn't ruling out the f act that it might be more to it.
I'm saying that I think that that is going ::
20 be a major element in a complicated subject which extended 21 over a number of years and, you know, is not finished yet ir 22 '
some respects in environmental qualification; that I don't i
23 know whether there aren' t earlier submittals on environments; 24 qualification than '83.
A.
- a Reponto IN k
25 '
When I was reviewing the Oyster Creek one I found l
1
25 1
the 1977, if I remember right, submi ttal on environmental 2
qualification, reviewed by the staf f and my impression is 3
that, you know, that was kind of viewed as an acceptable re-4 sponse at that point.
5 0
If there is any mitigating circumstances or any 6
documents that you would like to present at any time, I am 7
more than willing to accept them and discuss them.
8 A
I don' t have any documents.
I don' t know whether 9
you have asked us to go through my files and provide anything 10 l
that I have on this or not.
I 11 !
Q No, I haven't.
I A
And I haven't.
And I'm not at all sure there would 12 13 be anything in there.
I typically don't try to keep my files 14 of formal correspondence.
You know, there are people who 15 keep them.
I typicall threw ther away.
16 So, I'm not aware of documentation that I have 17 l that would be helpful.
J 16 0
I think I probably do have all the documentatior II.
that has cone on between --
I
~
20 l A
Ye ah, I would think so.
Thare are better places,
j 21 I you know, more complete places to get that than anything 22 that I would keep.
23,
O But what I'm getting at specif cally is there is I
l 24 I a lot of correspondence, and I'm not going to sit here and e uwnm. w.
25 say that I've read them all.
What I'm getting at, there is l
f
26 1
something -- if there is something in particular that you 2
would-like to bring to my attention --
3 A
I'm-not aware of'any._-I would think as you talk 4
to other people who were more deeply involved than I was,
5 they may be aware of some.
6 Q
Ok ay.
Anything else?
7 A
No.
8 Q
Okay.
Did you appear here today voluntarily?
9 A
Yes.
10 li MR. MATAKAS:
Okay.
The time is 9:54, and this 11 will conclude the interview.
I 12 (Whereupon, the interview is concluded at 9:54 a...
13 j this same day. )
i 14 15 16 i l
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24 A
- a' Reporters IN.
25
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i l This is to certify tha: the at: ached procee:.i.- s ' c rore the 3
t i
.. n. - w.u.
o*cy i
I In the ma tter o f ' Investigative Interview of P. R. Clark, Sr.
s Date of Proceedine:
May 8, 1985 6
Place of Proceeding: Parsippany, New Jersey j
7 were held as herein appears, and that this is the origina' 1
transcript for the file of the Com.ission.
.I l
10 Mvrtle H.
ti Traylor Official Reporter - Typed 12 f.
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