ML20147E629
| ML20147E629 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 04/24/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 NUDOCS 8801210183 | |
| Download: ML20147E629 (54) | |
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-W 8801210183 880106 O
NATIONWTCE COVERACE
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CR22861.1 1
BRT/dnw.
I UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION i
3 OFFICE OF INVESTIGATION 4
5 GPUN Headquarters 6
100 Interpace Parkway Parsippany, New Jersey 8
The Investigative Interview convened at 1:00 p.m.,
9 Richard A. Matakas, presiding.
10 P RESENT:
11 PAUL E.
BOUCHER, Interviewee I2 EQ Section 1
Engineer 3, GPUN 13 i
i RICHARD A. MATAKAS, Investigator Id i
Region I l
Nuclear Regulatory Commission 15 i
King of Prussia, Pennsylvania 16 ROBERT C.
LA GRANGE Section Leader I7 l EQ Branch Office of Nucelar Reactor Regulation 18
]
19 i
20 I
21 22 i
I 23 i-d e
ei meconen. inc.
25 it 1.
2286101 2
BRT 1
D ROCEEDINGS I
2 MR. MATAKAS:
The date is April 24, 1985 and the 3
time is 13:03.
Present for this interview are myself, 4
Richard A. Matakas, investigator, United States Nuclear 5
Regulatory Commission, Bob LaGrange, section leader in the 6
NRC's EQ branch, Office of Nuclear Reactor Regulations, 7
and Mr. Paul E.
Boucher, GPUN, engineer 3, EQ section.
8 The purpose of this interview is to discuss facts and 9
circumstances leading to GPUN's submittals to the NRC 10 regarding the qualification of electrical equipment at 11 Three Mile Island Unit 1.
12 Mr. Boucher, do you have any objection to providing 13 this information under oath?
14 THE WITNESS:
No.
15 Whereupon, 16 PAUL E.
BOUCHER 17 was called as a witness and, having been first duly sworn, 18 was examined and testified as follows:
19 EXAMINATION 20 BY MR. MATAKAS:
21 Q
Mr. Boucher, for the record would you state your 22 full name for the record, please?
23 A
Paul E.
Boucher.
24 O
And business address?
25 A
99 Cherry Hill Road, Parsippany, New J ers ey.
l
2286101 3
BRT 1
Q And telephone number, please?
2 A
299-2106.
3 0
Would you give us a general overview of your 4
education and work history?
5 A
I graduated from the University of Maine in 1957.
6 I worked for the General Electric small engine division in 7
Lynn, Mass., Curtis Wright Aeronautical, in Lodi, N ew 8
Jersey: Westinghouse Astronuclear, in Elizabeth, 9
Pennsylvania; Curtis Wright, in Caldwell, N ew J ers ey r New 10 York Telephone in New York City; I had my own business 11 from 1970 to 1978r and I came to work for GPU in 1978.
12 Q
When were you assigned to the EQ section, 13 environmental qualification section?
14 A
I'm going to have to guess.
15 Q
Fine.
Approximate time?
16 A
Approximately three years ago.
I'm guessing at 17 that.
18 0
It would have been 1981, time frame?
J 39 A
Yes.
Something like that.
20 0
Who assigned you to that?
What were the 21 circumstances surrounding your assignment to environmental 22 qualification?
23 A
I was -- my prior assignment was procedures and 24 standards and I asked to be transf erred out of procedures 25 and standards.
They were creating a new department and I i
4
22861.1 4
BRT 1
felt th at it was time for me to go do something else.
(
2 O
During the time that you worked for 3
environmental qualification, who was your immediate 4
supervisor?
5 A
Gerry Haus.
6 O
And he reported to Mr. Chisholm?
7 A
That's right.
8 Q
Who reported to Mr. Cronenberger?
9 A
That's correct.
10 0
Who reported to Mr.
R.F. Wilson?
11 A
That's correct.
12 Q
What were, or what still are your 13 responsibilities within the environmental qualification 14 section, specifically relating to Three Mile Island Unit I?
15 A
Primarily to take from the systems in the 16 electrical section in combination with the environmental 17 qualification section and determine what parts belong on 18 the EQ lists or what are not on tho EQ lists, and we 19 establish environmental qualification documentation.
20 Q
Are you f amiliar with 10 CFR 50.497 21 A
Yes, I am.
22 O
IE Bulletin 79-01 B7 23 A
Yes, sir.
24 O
DOE guidelines that were an at tachment to that 25 bulletin?
r L
22861.1 5
BRT 1
A Y es.
2 O
And NUREG 0588?
3 A
Yes, sir.
4 0
Was part of your responsibility to have the 5
environmental qualification program for Three Mile Island 6
Unit 1 to be in compliance with that bulletin and related 7
documentation?
8 A
I'm a working engineer.
I followed -- within 9
the time restraints and work yes.
10 0
okay.
What, basically I'm getting at, were you 11 told that that would be part of your responsibilities?
12 A
Y es.
13 0
Who would have given you that assignment?
I 14 A
Gerry Maus.
15 O
During 1981, up until 1984 time periods, did you 16 have any other responsibilities besides environmental 17 qualifications?
18 A
No.
19 0
What I would like to show you is two documents 20 that were submitted to the NRC from GPU Nuclear.
I would 21 like to introduce them into the record.
22 The first document is dated February 10 -- I'm sorry, f
23 the first document is dated May 20, 1983, the GPU letter 24 number is 5211-83-157.
It is to office of Nuclear Reactor 25 Regulation and the document is signed by Mr. Hukill, who
\\
22861.1 6
BRT 1
is director of THI-1.
It's a two-page letter and it has
~
2 attachments to it.
3 I would like you to take a look at the document and ask 4
you if you recognize it?
5 A
I had not seen this particular letter, but I am 6
familiar with the equipment.
7 Q
But you had not seen the May 20th letter, prior 8
to this date?
9 A
No.
That's correct.
10 0
The second document I would like to show you is 11 a GPU Nuclear letter dated February 10, 1984, and th e 12 control number is 5211-84-2038.
It is also to NRR.
It's 13 from Mr. Hukill, but Mr. Toole signed for him.
And it has 14 attachments to it, as listed.
15 If you would take a look at that document I would like 16 to ask you the same question, if you recognize the 17 document?
18 A
I had seen this one.
19 Q
What were the circumstances surrounding your 20 review of that document?
21 A
I helped put it together, some of the 22 information.
Not all of it, but I helped put it together.
23 Q
Okay.
Specifically what I would like to ask you 24 about is in the May 20th document there's a statement, and 25 I'll quote:
"The additional information we submit t ed in
?
L e
22861.1 7
-BRT 1
our letters dated May 3, 1982, and May 16, 1983, support f
2 our conclusions that the componen*.s listed are qualified 3
in accordance with DOR guidelines dated November 1979."
4 And, in the February 10 letter, the last sentence which 5
states:
"It is GPUN's position that TMI is currently in 6
compliance with environmental qualification rule 10 CPR 50.49
(
7 as applicable to TMI-1."
8 Prior testimony indicates that both yourself and 9
Mr. Maus were responsible for those -- that input to both 10 of these letters.
Is that true?
11 A
That one; yes.
12 O
"That one" meaning the February 10 letter?
13 A
Y es.
February 10.
That one I'm not sure.
It 14 could be.
15 Q
Then the February loth, you did review this 16 response before it was submitted?
17 A
I inputted to that letter.
18 Q
Okay.
Did you have input into the sentence that 19 I read, "It is GPUN's position that THI-1 is currently in 20 compliance with the EQ rule 10 CFR 50.49, as applicable to 21 TMI-1"?
22 A
I had nothing to do with writing that; no.
23 Q
Did you have input into that s ta t ement ?
Not 24 actually writing it?
25 A
I had input into the status of the equipment I
2286101 8
BRT 1
that's attached to it.
{
2 O
Did you review the letter before it was sent out?
3 A
I am not sure.
4 O
Did you review the letter?
l 5
A I would have reviewed the attachments.
I'm not 6
sure about the letter, whether I saw the lett er or not.
7 O
Okay.
That's in both cases?
May 20th and the i
8 February --
9 A
I don't remember seeing it.
Maybe I did.
I'm i
10 not sure about that one.
11 That one, I know I reviewed the attachment because I 12 inputted t he attachment.
I know I looked at the 13 attachment.
(Indicating.)
14 O
Do you agree -- or, during that time frame, with i
15 what you knew at that time, or your understanding of the 16 program, and the May time frame and the February 4 time 17 frame, the May of '82 time frame -- to the best of your 18 knowledge, would those have been true statements?
19 A
Based on the fact that' we didn't agree with some 20 of the things that Franklin said, and we were not able to 21 talk with Franklin, we were in disagreement on some points 22 with Franklin.
And everything we said in the attachment 23 here is correct to the best of my knowledge.
24 0
We are talking about on the May 20th letter.
It 25 goes on to say that, and I ouote:
"Your letter dated i
22861.1 9
BRT 1
December 10, 1982 contained THI-1 TER, which okayed some f
2 apparent equipment qualification discrepancies.
In our 3
letter dated March 21, 1983" -- which, by the way, should 4
have been March 1st -- "we requested a meeting to resolve 5
these apparent discrepancies.
We would like to reiterate 6
that request at this time.
In the event any valid 7
discrepancies result from this meeting, we will resolve 8
them on a schedule consistent with the requirements of 10 9
CFR 50.49(g)."
10 Is this what you are talking about?
The meeting?
11 A
Yes.
12 O
This was prior to the May 20th letter.
13 In other words, you had some disagrnements or 14 misunderstandings, at least differences of opinion?
15 A
We weren't able to discuss it.
They s et up what 16 they felt was open items on qualification and we were 17 unable to discuss it with the -- Franklin.
18 O
Did you have a real good handle on the 19 documentation needed for environmental qualification?
20 Very honestly, now.
I really want you to --
21 A
Well, I did not attend any of the meetings 22 outside.
Gerry Maus attended -- well, I was the workhors e.
23 I did the work inside.
I got the input that way, and I 24 thought I was fairly well informed.
25 But, manpower-wise, we just tried to do as much as we
22861.1 10 BRT 1
could.
I 2
The EQ program exist ed befcre I got th er e.
3 0
In the February "Oth submittal, attachment 2 4
regarding ASCO solenoid valves, part B, th ere 's a 5
statement made that "ASCO solenoids will be replaced with 6
qualified ASCO solenoids by January 1984; therefore, ASCO 7
qualification test report and it then goes on to name 8
the report supplied.
9 Then, under part E, "Static 0 Ring Pressure Switch" the 10 statement is made that "These switches will be replaced 11 prior to June 1984 by qualified pressure switch" meaning 12 the switches now are not qualified.
13 How does that go with your understanding of the 14 s ta t ement :
"It is GPUN's position that TMI is currently 15 in compliance with the environmental qualification rule 10 16 CFR 50.49 as applicable to TMI-1"?
Doesn't that run 17 contrary to the statement made in the February 10th letter?
18 Or does it in your mind?
19 A
I have to try to remember.
20 MR. HATAKAS:
Why don't we take a couple of 21 minutes break and let you look it over.
22 (Discussion off the record.)
23 THE WITNESS:
This sta t ement would have been 24 true at the time it would have been written, but I'd have 25 to go back and -- I deal with too many parts.
So, to go
22861.1 gy BRT 1
from memory I'd have to go back and look at it and see 1
2 what the history was on this.
I know I looked at this 3
letter and it was correct, this worc'.ng was correct at th e 4
time.
5 BY MR. MATAKAS:
6 0
Okay.
But what I'm saying is, you are familiar i
7 with 10 CFR 50.497 8
A But there are ASCO and ASCOs.
There are ones 9
that were installed, some we put coils ont there were 10 different situations and I don't recall wh,at this 11 situation was.
12 O
But the point being, the letter says "We are 13 currently in compliance with 10 CFR 50.49."
And the 14 attachment to that letter -- I just named you two.
15 There's one more example that states:
We are going to do 16 things in the future.
In other words, we have things that 17
-- we are going to have to switch these with qualified 18 parts.
19 Is that contrary to your understanding of 10 CFR 50.49?
20 A
50.49 had to be in compliance by March of '80 at 21 that time.
22 O
March of '85?
23 A
Okay.
I'm talking about the application of DOI 24 guidelines.
25 Talking about being in compliance by March of '857 I'm
2286101 12 BRT 1
confused.
/*
2 O
I'm not trying to trap you.
3 A
I'm confused.
4 Q
I'm trying to understand.
What is your 5
understanding?
Is your understanding that 10 CFR 50.49 6
allowed for replacement in the future?
You could still 7
say you were in compliance if you committed to replacement 8
in the future, as long as it was before the deadline set 9
forth in 10 CFR 50.49, which was March of '85, I believe?
10 A
Yes -- I'd have to go -- well, the statements 11 that were made here were true at the time, whatever they 12 uaid there, once again, I'm not too familiar with the 13 cover letter portion of it.
But the statements on these 14 particular components were true because I checked them out.
15 o
I have no problem with that.
But what I'm 16 getting at is are those statements contrary to your 17 understandings of --
18 MR. LA GRANGE:
Let me try something.
19 BY MR. LA G RANGE :
20 0
Do you think it is accurate to say that a 21 statement that you were currently in compliance with 50.49, 22 while at the same time identifying equipment that had to 23 be replaced sometime in the future in order for it to be 24 qualified -- the statement as written here says "Currently 25 in compliance."
But the attachment that you worked on --
4
22861.1 13 BRT 1
A Yes.
l-2 0
-- says things still had to be replaced to be 3
qualified.
4 Is it consistent, in your mind, that if the cover memo 5
says "currently in compliance" and the attachment says 6
"Equipment has to be replaced in the New Jersey"?
7 A
No.
In my mind it's not consistent.
I'd have 8
to know why.
I'd have to go back and find out why those 9
pressure switches and ASCOs were being replaced; whether 10 we had -- if they were qualified -- we replaced a lot of 11 coils on the ASCOs and qualified them to the DOR 12 guidelines and whether they decided to replace it for a 13 completely qualified ASCO or not, I'd have to refresh my 14 mind on why -- what we did on the specific item.
I have 15 been involved with too many other things, Bob.
16 O
Okay.
Assuming that what was there could r.ot be 17 documented as qualified, and the reason was that certain, 18 either the entire piece of equipment had to be replaced or 19 parts of it had to be replaced in order to document that 20 qualification, then, in your opinion, that statement on 21 the cover letter would not be consistent with the 22 attachment in that case?
23 A
Where is the sentence here you are talking about?
24 O
The last sentence on the cover letter.
25 A
I'm trying to think of 50.49.
Providing -- it l
j
2286101 14 BRT 1
was my feeling that providing -- my personal feeling --
i 2
that providing that we flagged what we were going to do 3
prior to March of '85, then we would be in compliance with 4
50.49; as long as we let you know.
5 0
As of February 10, 1984, you would be in 6
compliance with 50.49?
7 A
We were a nonoperating plant and we were going 8
to replace them by June '84.
We would have been in 9
compliance by ' arch of
'85.
10 0
Are you saying, then, you think it would have 11 been more accurate to have written that sentence such that 12 restating that, "We would be in compliance af ter the 13 equipment was replaced"?
14 A
I, personally, think that that would have been 15 better wording, but I think the intent of the law was 16 there.
From my point of view, what we were saying there, 17 we were going to have the equipnent in compliance prior to 18
- restart,
). arch of '85 was our goal.
19 BY MR. MATAKAS:
20 Q
Okay.
I just wanted to get what your 21 understanding of that was.
22 A
Okay.
23 0
It is your testimony that you did not provide --
24 did you provide input which would lead -- did you have any i
25 meetings with Mr. Harding, regarding these two submittals?
J 1
2286101 15 BRT 1
A Y e s., I did.
This one -- I can't remember this
(
2 one.
That one, question.
3 0
10 CFR 50.49 specifically says that you have to 4
make this reply.
This was a reply to 50.49, this May 20, 5
1983 letter.
Were you aware of that?
That 10 CFR had 6
that requirement?
A Today I can't remember.
8 0
okay.
If you see the document, may that refresh 9
your memory?
10 A
10 CFR 50.497 11 MR. MATAKAS:
Yes.
Why don't we take a couple 12 of minutes break and I'll show you the document.
13 (Discussion of f the record. )
I 14 BY MR. MATAKAS:
15 O
I have given you the opportunity to read 50.49(g) 16 which states:
"Each holder of an operating license issued 17 prior to February 22, 1983 shall by May 20, 1983, identify 18 th e. setrical equipment important to safety within the 19 scope of this section, already qualified, and submit a 20 schedule for either the qualification to the provisions of 21 this section or for the replacement of the remaining 22 electrical equipment important to safety within the scope 23 of this section."
Then it goes on.
24 Does that refresh your memory regarding why the May 20th 25 response was made?
If it doesn't e
22861.1 16 BRT 1
A No.
It really doesn't.
f 2
O No problem.
But you do remember getting some of 3
these attachments together or revi ewing them?
4 A
Yes.
I helped with the inputs; yes.
5 0
And you remember meeting with Mr. Harding 6
regarding these documents?
7 A
Harding one.
The other one I don't -- for some 8
reason I don't remember the other.
9 0
Which one?
10 A
This I don't remember.
11 0
The May 20th document you don't remember?
12 A
I might have -- I might have seen the referenced 13 documents.
I'd have to look at those.
And th es e I looked 14 at, 15 0
February 10, 1984?
16 A
And I worked on the attachment.
17 O
But you did not provide input which would lead 18 one to conclude that "It is GPUN's position that TMI-l is 19 currently in compliance with the environmental 20 qualification rule 10 CFR 50.49 as applicable to TMI-1"?
21 In other words, did you tell Mr. Harding that you felt you 22 were in compliance?
23 A
I don't remember.
All I remember is the 24 attachments are correct.
I don't remember -- I don't 25 remember.
2286101 17 BRT 1
(Discussion off the record.)
2 BY MR. LA G RANGE :
3 0
Did you have any input, Paul, to attachment 1 4
that identifies the TER deficiencies? to the 1
5 Febr uary loth letter?
6 A
Yes, as of making sure that -- trying to proof 7
it to see if this was an agreement with TER.
These are 8
basically TER items.
9 Q
You actually proof ed these to make sure all the 10 X's were on in the proper place and it corresponded with 11 the TER deficiencies th a t were identified.
12 MR. MATAKAS:
Before we go further, why don't 13 you indicate what those X's signify?
14 MR. LA GRANGE:
Okay.
For the record these 15 deficiencies correspond to the deficiencies identified in 16 the Franklin Research Center technical evaluation report 17 of December
'82.
And this attachment 1 states, the title 18 of it is "Equipment Quali fication Deficiencies" and it 19 ref erences the TER numbers for the equipment as identified 20 in the Franklin TER.
21 MR. MATAKAS:
And each X represents an area of 22 deficiency?
23 MR. LA GRANGE :
That's right.
Each X represents 24 a different category of deficiency as identified by the L
25 Franklin Research Cent er in their review.
')
l
2286101 18 BRT 1
BY MR. LA GRANGE:
I 2
Q Paul, were you made aware af ter this submittal 3
was made, that we had found seme errors on attachment I?
4 A
There were a lot of errors on it.
I'm not sure 5
whether it got out first and we looked at it -- there were 6
a lot of errors on it.
7 Some of these lines were actually -- there were typos, 8
misplaced, but I don't know where and when they were found --
9 before or after -- I have nothing to do with when they 10 were sent out.
Whether they come down to me -- this is a 11 licensing document.
We found errors in them.
12 O
Before it was sent outt right?
13 A
Found a lot -- well, I'm not too sure what th e 14 time scale was.
There were a lot of items -- some of 15 these things were actually, a lot of typos.
There were 16 X's on the wrong line.
17 O
To the best of your knowledge, were any Franklin 18 TER-identified deficiencies left off attachment 1 for any 19 reason?
20 A
This was supposed te be identical to the TER.
21 It was supposed to have been *
- en out of the TER and put 22 here for something quick to di.-st.
It's supposed to be 23 identical to the TER.
24 We didn't agree with all of it, but it was supposed to 25 be identical.
22861.1 19 BRT 1
Q I understand.
I know you are not -- you stated
{
s 2
you aren't familiar with the May 20, 1983 submittal.
3 In that submittal, as Rich has indicated, there is a 4
statement here concluding that "Components listed are 5
qualified in accordance with the DOR guidelines. "
6 Subs equ ent to that, on the February 10, '84 submittal, 7
included in that submittal on the attachment there is 8
equipment that is identified as requiring replacement at 9
some future date.
t 10 Is it consistent that a later submittal identified 11 equipment requiring replacement when the May 20th, '83 12 submittal had stated that the components were qualified in 13 accordance with the DOR guidelines?
What would have 14 happened between those two submittals, where the May 20, '83 15 submittal concludes they are qualified and the February 10, 16 1984 submittal showed they had to be replaced?
17 A
To this day I don't feel that any of the ASCOs 18 had to be replaced.
We could have replaced coals.
The 1
19 ASCOs -- the NRC originally asked us to look for ASCOs l
l 20 within containme-- and none of these ASCOs are within 1
21 containment.
So they could all have been qualified to the 22 DOR guidelines.
i 23 0
Well, the DOR guidelines address high energy 24 line breaks outside containment.
It wouldn't make any 25 difference to us whether they were inside or outside.
21861.1 20 i
BRT 1
1 They would have to to be qualified for different 2
environments.
t 3
A I don't re. ember why -- I thought that we hadn't i
4
-- if we had steam data, as I recall, on the ASCOs, on the a
5 old ASCOs, then we could have qualified them, if we had 6
steam data.
I'd have to refresh my mind and get back to 7
it.
8 You could use analysis, except for steam.
The NRC 9
required that we had actual test data for steam 10 environment.
+
11 O
Mr.. Boucher, getting back to this February 10 12 letter and the last statement that GPUN feels they are in 13 co'mpliance with 10 CFR 50.49.
In that time frame, in that 14 February time frame, did you honestly feel that you were 15 in compliance with 10 CFR 50.49, regarding environmental 16 qualification at TMI-17 17 A
Based on the attachments to these, and the 18 replacement equipme r.?
that was called out, we would have 19 been in compliance tc the best of my knowledge.
20 0
Okay.
Nov. we already discussed in the May time 21 frame, it the May 2:
you reit erate a request for a 22 meeting, ;ecause yo.
.ad some reservations regarding the TER?
4 23 A
That's correct.
24 0
The Decenter, I believe it was December 10, 1982 25 TER: is
- hat right, r ob?
i I
22801.1 21 BRT 1
MR. LA GRANGE:
Yes.
l 2
er'MR. MATAKAS:
3 0
Okay.
December 10, 4
In October 5, 1983, did you not meet with the NRC, with 5
Mr. LaGrange, yourself, Mr. Harding, Mr. Maus, Mr. VanVliet?
6 A
That's correct.
7 O
Did you go over the individual TER items?
8 A
I believe so.
9 Q
Were you told that you were lacking 10 documentation for the TER items, in different, various 11 areas?
12 A
I believe so.
13 O
The other day I talked to you and we went over 34 several different TER items.
I believe I talked to you on 15 April 11, 1985.
Do you recall that?
1G A
That's correct.
17 0
The first items that we went over were TER items 18 11 and 15, which involved Limitorque motorized activators?
19 A
Yes, sir.
23 0
It states "The licensee has at. identified the 21 motor manufacturer for this motorized valve actuator."
Do 22 you recall that?
23 A
That's correct.
24 O
And the NRC March 20-21 inspection, the results 25 of that inspection stated that "The files should document
22861.1 22 BRT 1
the motor manufacturer."
Same deficiency.
Do you recall i
2 that?
And we went over how it was resolved and you 3
mentioned, now, the motor manufacturer is a class B motors, 4
installation, 60 Hz 460 volt for out of containment usage.
5 It is documented in TDR 658.
And what wasn't listed on 6
the SCEW sheet, you obtained the information from a 7
walkdown and the TMI EQ style is EQ 79-104.
The TDR 8
wasn't it included?
9 A
The EQ package 104 had a letter in it from 10 Limitorque, stating the order number of the Limitorque, 11 and saying that -- those two Limitorques, I believe they 12 were EFV l-A and 1-B7 13 0
I'll give you the documentation, if that will 14 help.
Why don't we take a couple of minutes break.
He 15 can look it over.
16 (Discussion off the racord.)
17 THE WITNESS:
The EQ package, T1-104, had a 18 letter from Limitorque stating that these two motor 19 operators were qualified to B0003, which, B0003 states 20 that they would have to have a qualified reliance, or 21 peerless, I'm not sure it was peerless -- there was two 22 motors in that report.
23 In other words, that letter stated that these two 24 Limitorques were qualified by their records, their 25 procurement records, Limitorque.
22861.1 23 BRT 1
BY MR. LA GRANGE:
f 2
O What was the date of that, that letter?
Was it 3
after March?
Was it dated af ter the inspection?
4 A
It's in the package.
I'd have to look at that 5
date.
I can call and get a date.
6 Q
Well, if it was in the package we wouldn't have 7
the same deficiency noted in the NRC audit as we did in 8
the TER; is that correct?
9 A
I notice, when we got to the walkdowns, that 10 this walkdown sheet said, called them "motors," as a 11 "Limitorque motor."
That didn't look right.
And 12 following my interview with you I called Limitorque and 13 gave them this information.
14 Limitorque researched their files and found that these 15 are commercial grade motors.
They are not qualifi ed, in 16 both of these units.
And they have since sent me a letter 17 saying that their prior letter was an error and their 18 records, based on this serial number, that these are 19 nonqualified motors.
20 I have, now, that letter in the file.
21 O
You heard recently?
Since April 11, '85?
22 A
The meeting I had with him, I notice, did not 23 say "reliance."
Did not -- Limitorque does not make 24 motors.
I followed up and called Limitorque to find out 1
25 what this meant.
Their letter said that we had a f
22861.1 24 BRT 1
qualified unit.
I wanted to know what I had for a motor,
[
2 because B0003 has two motors on it; I didn't have enough 3
to tell me which one it is.
4 BY MR. MATAKASt-5 Q
So, in any event, during the NRC inspection in 6
March, it did not have the motor manuf acturer listed; is t
7 that correct?
8 A
That is correct.
9 O
Okay.
What I'm getting at now is that between 10 the TER in 1982, which identified the same deficiency, and 11 the April inspection which -- I mean the March 1984 12 inspection, which found the same deficiency, what was done 13 in between that time to correct that deficiency so GPUN 14 could state in their May 20, and February 10 letters that 15 they were now in compliance?
16 A
Based in the Limitorque letter, we had assumed 17 that it was qualified.
The walkdown, we had not done 18 100-percent walkdowns.
The walkdown conducted July 27, '84 19 provided the nameplate data on the Limitorque motor, and I 20 had not been involved with this until I talked to you and 21 noticed that.
22 O
What I'm getting at is:
This is af ter the March 23 1984 NRC inspection?
24 A
But we had a letter from Limitorque saying that 25 that actuator was qualified.
22861.1 25 BRT 1
0 But it didn't have the motor manufacturer on it
{
2 and that's exactly what the deficiency said?
3 A
That's correct.
4 0
So, we have this~ deficiency going from 1982 to 5
1984.
What was done on that deficiency between that time?
6 Was anything done on it, to your knowledge?
7 Answer this one question first:
Was anything done on 8
that deficiency?
9 A
I don't know.
10 0
To your knowledge, was anything done on that 11 deficiency?
12 A
I have nothing documented today that anything 13 was done, in my files.
14 BY MR. LA GRANGE:
15 0
When did you find out that the motor in there --
16 we are talking about EFV-1 A and B?
17 A
That's right.
18 0
When did you find out the motor just said 19 Limitorque and did not identify it?
20 A
The meeting I had with --
21 MR. MATAKAS:
April 11, 1985?
22 THE WITh2SS:
That's the first time I looked at 23 that walkdown and saw it said "Limitorque motor."
24 BY MR. LA GRANGE:
25 0
Then you got back with Limitorque and they f
i
22861.1 26
'BRT 1
researched their records and what did they tell you?
'[
2 A
They told me that the motors, they did not have 3
sufficient information on those motors to qualify them.
4 They didn't know what the installation -- they did not 5
have the documentation to show the motor installation.
6 O
This is very confusing.
Very, very bothersome 7
to me personally.
Okay.
8 When we did our audits of the EFW files, and as you are 9
aware, we did five audits, we did one on June 25th.
Okay?
10 One of those audits.
And we looked at the file, EQ -- at 11 that time it was designated EQ TM104, it covered DFVl-A 12 and 1-B.
13 In the file at that time it contained a listing 14 generated using maintenance records of valve actuators, 15 motor manufacturers, insulation class, and current type.
16 Now, as I recall at that time when we looked at that 17 file, that would have indicated that, ba s ed on th e 18 maintenance records those motors were qualified motors, 19 qualified by B0003.
20 Now, let me go on.
In a subs equ ent audit, August 6, 21 1984, we looked at that file again.
At that time it was 22 designated EQ T1, 1004, and we found that substantial 23 changes had been made to the contents of that file since 24 the June 24, 1984 audit.
One change had been removal from 25 the file of the listing previously discussed based on i
22861.1 27 BRT 1
maintenance records.
However, except for identification 2
of the motor manufacturer, the file still contained the 1
3 same information, only it was based on the results of a 4
field walkdown the licensee performed nubsequent to the 5
previous audit.
6 Identification of motor manufacturer was also 7
determined during that walkdown.
And the results were 8
used, again, to establish the fact that these motors were 9
qualified by the test reports referenced in that file.
10 Now, I'm sitting here today and I can't understand what 11 has happened since the time that you concluded they were 12 qualified and we looked at the documentation and concluded 13 it was qualifi(d, and suddenly now I'm hearing, earlier 14 this year, all the motors were Limitorque and now 15 Limitorque said it's not qualified.
16 I don't understand it.
It doesn't make any sense to me.
17 I can't figure it out.
Do you have the previous walkdown 18 results?
I personally would like to see them.
I just 19 don't understand it.
20 A
That matrix that you had seen was an unofficial, 21 unchecked data on Limitorques.
Also had a maintenance 22 book on Limitorques, which was also unchecked.
23 0
Well, I know at the time of that final audit in 24 August that we looked to make sure that everything had 25 been reviewed, checked, and signed of f.
I
22861.1 28 BRT 1
A I wasn't part of that audit.
(
2 MR. LA GRANGE:
Let's go off the record for a 3
second?
4 MR. MATAKAS:
Yes.
5 (Discussion off the record.)
6 THE WITNESS:
Could I finish of f the record here?
i 7
The motor has since -- those motors have since been 8
determined by the systems people that they are not 9
required to function after an accident.
They are normally 10 in an open position and failure of the motor would 11 maintain them in an open position, and therefore they are 12 not required, and we are changing the SCEW sheets to show 13 that th e Limitorque, the basic Limitorques are qualified 14 with th e exception of the motors, which do not -- th e 15 motors are not required to be qualified on those because 16 th ey 'll fail, leavin-the actuators open, which is the 17 position you want them in.
18 BY MR. LA GRANGE:
19 Q
From a safety standpoint that's good.
There's 20 no safety problem involved.
But I still can't understand 21 why the records at that time seem to indicate this was 22 qualified and now, earlier this year I'm hearing that they 23 weren't identified properly.
I don't understand.
24 There were several walkdowns, I know.
And now I'm 25 hearing that the walkdowns weren't even reliable.
That's
22861.1 29 BR" 1
what bothers me.
~
(
2 A
The only walkdown that I have seen was the one 3
that was in this package.
That's only -- other walkdowns, 4
I would have had documented, a letter from the field, if 5
there had been a walkdown.
And I do not recall having a 6
letter on those two motor operators in my files.
7 BY MR. MATAKAS:
8 O
That one walkdown actually identified the motor 9
manufacturer as Limitorque?
10 A
That 's the only one I saw.
11 O
And that was subsequent to the March '84 audit?
12 A
You have the date on the walkdown.
13 O
It was subsequent -- May, I think it was.
I 14 BY MR. LA GRANGE:
15 O
The records I saw in those files indicated the 16 manufacturer of the motor and the manufacturers are not 17 listed as Limitorque.
They were reliant, they would have 18 been peerless, they would have had a specific motor 19 manufacturer?
20 A
That was in the matrix.
That was based on the 21 information we had at the time, without walkdown.
22 O
Now, the first matrix was based on maintenance 23 records, I understand; okay?
The second, during the 24 August 6, 1984 audit, there was a -- results of a field 25 walkdown in there.
2286101 30 BRT 1
MR. MATAKAS:
The field walkdown wa s on July 27, l
2 1984.
3 MR. LA GRANGE:
Right.
4 MR. MATAKAS:
And it lists the manufacturer, 5
which was the deficiency noted in the TER and your March 6
1984 audit, as Limitorque.
7 MR. LA GRANGE:
Right.
That would have been the 8
manufacturer of the motor operator itself.
It was a 9
Limitorque actuator.
10 THE WITNESS:
I was unable by looking at that to 11 know whose motor it was, so I had to look into it.
That's 12 when I found out that it was a commercial grade motor.
13 BY MR. MATAKAS:
14 0
That's exactly what the deficiency states, 15 "Licensee has not identified the motor manufacturer for 16 this actuator."
17 MR. LA GRANGE:
But the motor manufacturer would 18 not have been Limitorque.
19 MR. MATAKAS:
But that's what it's identified 20 here.
21 THE WITNESS:
Limitorque claims that th ey 22 assembled some motors in that early period.
They bought 23 stators and they assembled some motors.
That 's why that 1
24 tag says "Limitorque."
But they were commercial grade.
25 They have no documentation on those motors.
That's why 4
'22961.1 31 BRT 1
they are tagged "Limitorque."
i 2
BY MR. MATAKAS:
3 Q
But they are actually tagged "Limitorque"?
4 A
That's what they are actually tagged 5
That's what the field walkdown showed and 6
that's what they confirmed, and Limitorque admitted that 7
they had made a mistake when we had asked them to go 8
through that order.
That was their -- their prior letter 9
was in error; that the motors were not qualified.
10 BY MR. LA GRANGE:
11 Q
In the TMI-l EQ files, have you kept information 12 that has been replaced in those files?
Do you --
13 A
I have tried to.
We have had a lot of ads, I 14 have tried to.
I believe I can reconstruct any file 15 because the original revisions were sent to the Island, 16 and I believe I can reconstruct any file, with time.
17 BY MR. MATAKAS:
18 O
The next TDR was TD item 51, involving 19 Westinghouse pumps.
The TDR stated "The motors require 20 qualification for steam / pressure exposure.
The Licensee 21 has referenced WCAP-8754 as evidence of qualification.
22 "This report concerns qualification of motors located 23 outside containment and therefore does not contain any 24 steam or pressure testing.
25 "Only the stator insulation system is qualified to 200
22861.1 32 BRT 1
Mrd as stated by WCAP-8754.
The Licensee has not
(
2 referenced any documents as evidence of qualification for 3
the motor lead insulation, motor lead splicer bearing 4
lubricant."
5 In the March 15, '84 inspection it stated, "The file 6
does not contain information to establish similarity 7
between these motors and the motor Jead wires and 8
insulation.
A March 15, 1984 letter from GPU to 9
Westinghouse requests the information needed to establish 10 that similarity.
A response to this letter should be 11 pursued and placed in the filia."
You showed me a letter, 12 Westinghouse letter, dated March 21, 1984 that was placed 13 in th e file.
My question is:
Between 1982 and the NRC 14 inspection, what attempt was made to resolve the TER item?
15 We have all the SCEW sheets and all the items in the 16 file as attachments, if you would like to take a look at 17 th em.
18 Let's take a break.
A copy of the letter is in there, 19 too.
20 (Discussion of f the record. )
21 THE WITNESS:
I did have a prior letter in the 22 file, a telecon from Westinghouse, saying that.the lead 23 wires were part of the motorette testing.
I don't recall 24 what the date was.
25 BY MR. MATAKAS:
22861.1 33 BRT 1
O Was it prior to the inspection, the NRC
('
2 inspection in March 1984?
3 MR. LA GRANGE:
Do you want me to say something?
4 MR. MATAKAS:
Yes.
Bob?
5 MR. LA GRANGE:
During the first audit we found 6
a March 15, 1984 letter from GPU to Westinghouse 7
requesting the information.
8 THE WITNESS:
Can we go off the record for a 9
second?
10 BY tiR. MATAKAS:
11 O
If it's specifically about thi s, it has to be on 12 the record.
Go ahead.
13 A
There was a ' letter in file, a record of a verbal 14 conversation and it was not found acceptable.
We 15 officially wrote a letter to Westinghouse asking for 16 documented reply.
17 0
It was not found acceptable by who?
18 A
It was a verbal -- the -- I believe by the NRC, 19 that he wanted a documented response and not a verbal -- a 20 record of a telephone conversation 21 BY MR. LA GRANGE:
22 0
But we didn't do our first audit until 'the 20 th.
23 The letter was dated March 15?
24 A
That requesting the information, we had already 25 had a letter in the file, a record of a telephone L
l
4 22861.1 34 BRT 1
conversation.
2 BY MR. MATAKAS:
3 0
You met with the NRC on October 5, 1983, and 4
again on March 8, 1984.
Do you remember when the NRC 5
found this letter and found it unacceptable?
Was it 6
during one of those visits when you went over TER items?
7 A
I don't recall.
8 O
Do you remember who in the NRC?
9 A
No.
10 0
Okay.
Let 's go on to the next TER items.
The 11 next TER items are -- refer to Foxboro transmitters, and 12 they are TER items 78, 79, and 81.
13 The TER stated that "TER items 78 and 81 were noted as 14 deficiencies for similarity between equipment and th e test 15 specimen equipment; deficiencies for aging and criteria 16 regarding test sequence and, 4,
test duration margin."
17 Number 79 was just deficient for similarity between 18 equipment and the test specimen, and aging.
19 The NRC, March '84 inspection, found that:
"The EQ 20 documentation reviewed does not resolve the deficiency 21 identified in the TER for these transmitters.
- However, 22 the SCEW now ref erences the WYLE test report 45592-4 being 23 used by GPUN to establish qualification of transmitter FT-791, 24 779, 782 and 788 (model NE 13 DM.) GPU stated that the WYLE 25 report is used only to address aging and qualified life 1
22861.1 35 BRT 1
for these Ell mod els.
2 In order to resolve all the deficiencies for thes e 3
transmitters, including aging and qualified life, GPU 4
should determine the applicability of the Wyle report for 5
qualifying these transmitters.
6 Regardless of whether the Wyle report is used, GPU 7
should document in the file the resolution of the TER 8
deficiencies.
If it is determined that the Wyle report 9
can be used, the following comments are applicable in 10 addition to those above for model NE13 DM transmitters."
11 What was done between the time of the TER and the time 12 of the NRC inspection, in 1984, to correct all of the 13 deficiencies noted in the TER?
Was there an attempt made 14 to address all the deficiencies noted in the TER for these 15 transmitters, to your knowledge?
16 A
That was to March of '84?
17 O
The inspection was 20 and 21 March, 1984.
18 A
Going frna memory again, I believe there was a 19 letter.
We had a letter from Foxboro, identifying twe 20 reports that were applicable to those early transmitters.
21 And we did have a B&W report, it's an analysis report 22 showing a parts breakdown so that we get a service life 23 out of those transmitters.
24 MR. MATAKAS:
Let 's go of f the record for a 25 second.
22861.1 36 BRT 1
(Discussion of f the record. )
2 MR. LA GRANGE:
In GPU 's May 31, 1984 response 3
to th e NRC 's audit findings from the first two audits with 4
regard to these Foxboro transmitters that we are 5
discussing, one of the responses is that the SCEW sheets 6
are being updated to reflect the foregoing reports, and 7
calculations will be contained in the EO file.
8 I can only stand by the audit results, that the 9
deficiencies were not identified, were not resolved, and 10 that quite a bit of subsequent work was done after that 11 first audit.
12 MR. MATAKAS :
But we don't have records of 13 exactly what was in the file?
14 MR. LA GRANGE:
No.
But we can look at th e 15 dates of that information now.
16 MR. MATAKAS:
As f ar as qualifications now?
17 MR. LA GRANGE:
Right.
18 MR. MATAKAS:
But no sir, as far as what was an 19 attempt to qualify before?
20 MR. LA GRANGE:
Tnat's right.
21 BY MR. MATAKAS:
22 O
What I would like to do now is go on to TER 23 items 106 and 107, which are noted as EO -- GPUN EO TIlli, 24 which is the same as the Kerite cable, TER it em 106, EQ, 25 109, which refers to Anaconda cable, item 107.
22861.1 37 BRT 1
Both these item were noted as deficiencies for adequate 2
similarity between equipment and test specimen established, 3
and in the not es, in the TER not es, it st ates that "The 4
Licer.see has not provided suf ficient information to 5
establish that the equipment described on the SCEW sheet 6
is the same as the equipment described in the referenced 7
report."
8 The NRC March 21 audit states "The file contains no 9
documentation to establish similarity between the cables 10 tested and those installed.
The files must contain either 11 a letter from the manufacturer that establishes the 12 applicability of the test report, or documentation 13 describing how GPU has determined that the installed cable 14 is similar to the specimens tested. "
15 And, as a result of our April 11 meeting you showed me 16 a May 31 letter that ref erred to a February 15, 1984 17 letter for number 107, and a letter dated May 16, 1984 for 18 TER item 106.
19 Why don't you take a look at this file before I ask you 20 any more questions.
(Handing.)
21 (Discussion of f the record. )
22 BY MR. HATAKAS:
23 O
Basically, you have had an opportunity to look 24 over the documentation.
What I would like to know is, 25 between the time the NRO SER TER was issued on De:er,ber 12, f
38 2286101 BRT 1
1982, and the time of the NRC audit in March 20-21, 1984, l
2 what was done to correct the TER deficiency, to your
\\
3 knowledge, as stated in the TER?
4 A
We had primarily two purchase orders for cables 5
at TMI-1.
one was for Kerite cable snd the other was for 6
Anaconda, or Continental cable.
7 Our records, basically, just were based on those two PCs, 8
without walkdowns or anything else.
9 O
But that existed in December
'82, as it existed 10 in March '847 11 A
Those Pos, original plant.
12 O
But what was done in between that time to 13 correct the deficiency, to your knowledge?
14 A
I don't know.
15 O
Mr. Boucher, what active participation did 16 Mr. Chisholm take in the EQ program, to your knowledge?
17 A
I ' m not sure.
I don't know.
I report to Gerry 18 Maus and I don't know what his arrangements were with 19 Mr. Chisholm.
20 0
To your knowledge, what active participation did 21 either Mr. Cronenberger or Mr. Wilson have, in the EQ 22 program?
23 A
The same thing, I don't know.
I got my 24 instructions from Mr. Maus.
25 O
Did either you or Mr. Maus ever indicat e -- did k
22861.1 39 BRT 1
you ever indicate to anyone that you needed. help to handle
[
2 the EQ job?
3 A
Yes.
I indicated that to Mr. Maus several times, 4
that it was just too much work.
5 Q
Mr. Maus?
6 A
Yes.
7 Q
During what time periods?
8 A
From the time I start ed the job.
9 Q
Did he indicate to you that he had passed that 10 information on to his supervisors?
11 A
I don't know.
I don't r em emb er.
12 o
Do you recall what his response was to you?
13 A
I guess, basically, to continue doing the items 14 that had to be -- that were identified currently and not 15 to go ba ck.
16 Q
What do you mean "identified currently and not 17 to go back"?
18 A
The EO file existed when I got th e r e.
I could I accepted the file as received 19 not go back to find out 20 when I took it, when I started working on it.
And I could 21 only do what I could on the new items coming up.
I did 22 not go back and find out what th e reasoning is for how --
23 why the records existed the way they were.
24 O
Did you find some of those records -- some of 25 the original records that you inherited as being
22861.1 40 ERT 1
insufficient for qualification of the components?
2 A
I had so -- my time was dedicated to the current 3
preblems, what I was directed to do.
4 O
Did you review the past?
In other words, accept 5
th em a s it is, does that mean if they said it was 6
qualified you accepted the component as qualified?
7 A
I accepted them the way they were.
I did not 8
have time to go back --
9 O
And review them?
10 A
-- and r evi ew th em.
I reviewed them only if 11 they were brought up as a problem.
12 Q
Looking back, knowing what you know now and what 13 you knew over the years since 1982, during the
'83, and '84 14 time period, did you understand what was needed for 15 qualification for the dif f erent components?
16 A
No.
I think there has been a big learning curve.
17 Q
Getting back to the February 10 letter, you said 18 you didn't recall participating with licensing, meaning 19 Mr. Harding.
20 What was your input that you - call to Mr. Harding?
21 A
only to answer the spe ic questions that they 22 had.
They had a document they wanted to go out -- put out 23 with.
And mine was providing the documentation that we 24 had in file for them.
25 I had the records.
41 22861.1
- *7 1
O okay.
Did, regarding the actual letter,
(
2 February 10, were you asked to review and concur on that 3
letter?
4 A
I was asked to review and concur on the 5
attachment.
6 o
You were not asked to review and concur on the o
7 letter?
8 A
That's correct.
9 Q
Did you review the letter, though?
10 A
I believe I have seen it.
I'm not sure.
I 11 believe I've seen it.
12 O
Let's go forward, again.
13 At what point, if any, did management become actively 14 involved in the EO program?
15 A
Management was always involved because we had a --
16 they were spending money.
The amount, the effort is a 17 different question.
18 0
okay.
Let's talk about effort, then.
I think 19 we talked about this a little bit on th e lith.
20 Let me ask you this:
Do you recall the UCS petition 21 coming out?
22 A
Y es, I do.
23 0
okay.
Do you recall sometime in the January 24 1984 time period, a meeting, I think QA attended, Tech 25 Functions down to the E0 level attended th e meet i ng --
i
~
22861.1 42 BRT 1
Mr. Chisholm making a statement to th e effect that 2
raising the possibility of hi~ ring outside contractors?
'l 3
A I don't recall that meeting.
4 0
Do you recall anyone making that s ta t ement in 5
the early 1984 time period or late 1983 time period?
6 A
Will you ask that questjon again?
7 0
What I'm get ting at is:
When did you first 8
learn GPU was considering the idea of going outside and 9
hiring contractors to come in and assist on the EQ program?
10 A
Well, you have to realize I'm way down on the 11 ladder.
12 O
I understand that.
13 A
I believe it was in May of '84.
14 0
okay.
I 15 A
They had contractors back in -- when the program 16 first started, that established the original program.
17 Then a new effort, I believe start ed -- I really don't 18 know what the negotiations were.
19 O
At what point did the EQ Staff begin to expand 20 beyond you, as far as TMI-1 goes?
21 A
I believe it was in May.
22 O
May of '847 23 A
Yes.
24 0
I know you couldn't bef or e wh en I a sk ed, but can 25 you give me an approximation of, at a given point when it
2286101 43 BRT I
was at its maximum, how many people were working on the
/
2 TMI-1 EQ program?
k 3
A I can't, because a lot of the work was beir.g 4
done at IMPELL.
We had, I believe, five contractors 5
in-house.
I'm only talking TMI now.
Because we had two 6
joint efforts going, we had oyster Creek going also.
7 0
Right.
8 A
We had five in-house, plus whatever effort IMPELL 9
was doing.
10 0
Were they revamping the record, so to speak, at 11 IMPELL?
12 A
Yes.
And we had contractors for five contracts, 13 basically reviewing what IMPELL was doing as they came in 14 for sign-off.
15 0
Okay.
16 A
And then wc had myself and Gerry Maus was still 17 there.
18 O
Are you familiar with internal audits that were J
19 conducted on the EQ program back in March and April of 20 1981?
I believe the audit leader was Mr. Guimond?
21 A
No.
22 0
- would like to show you an interoffice 23 memorandum dated June 25, 1981, QA/4161, which is sort of 24 a cover letter to an audit, internal audit, conducted by 25 th e QA section.
It is audit 81-02 I would like y : t:
4
22861.1 44 BRT l
l 1
take a look at it and just ask you if you recognize the
.[
2 audit or the cover letter?
If you would ignore the 3
chicken scratchings --
4 A
I thought you were talking about an NRC audit?
5 0
No.
This is internal.
6 A
Oh.
7 0
It says on this cover letter that (Indicating) -- should be contacted.
8 Mr.
9 A
Guimond.
I 10 I kn ew tha t this existed, but I had nothing to do with 11 closing it out.
12 O
Okay.
13 A
Now, I may have done some of the work.
I was 14 directed to do certain tasks which could have been 15 involved with this thing, but I had nothing to do with 16 closing this speci fic --
17 0
Keeping that in front of you, th er e, I would 18 like to show you what is the ultimate response -- not the 19 ultimate response but a response, one of the responses to 20 this audit.
It is dated August 21, 1981.
It has a 21 control number of EP&I 81-01-76.
It is signed by Mr. Maus.
22 And it has the individual nonconformance findings, 1 23 through 11.
I notice that it appears to have your 24 signature.
25 I would like you t o take a look at th em.
If you recall
1 22861.1 45 B P.~
l 1
1 signing those documents?
[
2 A
Yes.
I remember them now.
3 0
What did you do for the correction on those?
4 Why did you sign those documents?
5 A
I believe the correction was documented on each 6
one of them that we signed.
t 7
O Did you actually -- what did you have to do with 8
the correction?
For instance, audit number 1:
The 9
corrective action is "Procedure EP-031 is scheduled to be 10 issu ed on 9/1/81. "
11 A
I helped write that document.
12 0
Do you believe that it satisfied this audit 13 finding?
Or the finding in the recommendation?
14 A
I signed it, so I must have believed it.
l 15 Q
Well, I don't know.
I'm asking you?
16 A
Yes.
If I signed it I would have believed that 17 that was what was requir ed.
Anything I signed I believed 18 that I was correct at the time that I signed it.
19 Q
Did you have any meetings with any of the QA 20 people -- did you attend ar.y meetings between Tech 21 Functions and QA where the
-solutions to these 22 deficiencies were discusse.
throughout the years?
23 A
I don't recall.
I didn't r em emb er this, to tell 24 you the truth, until you 3ast brought it up.
So, to go 25 of f th e top of my head, I don't remember.
22861.1 46
'BRT 1
O Did you ever have any conversation with the OA
[
2 people regarding the EQ program?
\\
3 A
In trying to resolve some of these things I did:
4 yes.
5 0
Who did you have the conversations with?
6 A
It would have been with Ray Guimond.
But 7
basically I was a support rather than a lead on it.
8 Q
Okay.
Did Mr. Guimond ever state that the 9
documentation in the files was not ad equat e?
10 A
Yes, he did.
11 0
Did he state that throughout the years?
12 Throughout from '81?
13 A
I think there was a couple of items that he was I believe this is still not clos ed out, according to 14 15 Mr. Guimond.
16 Once again, you are getting it from hearsay because I 17 haven't been directly involved, other than with the 18 documents that I signed off on.
19 Q
Did Mr. Guimond say that he disagreed with the 20 resolution to these deficiencies?
21 A
I don't remember.
22 O
On pag e 10 of 10, under "Recommendations " it 23 says:
"Documented direction be generated in order to 24 assure meeting the requirements of the bulletin to include 25 organizations, departments, sections, and individuals
(
22861.1 4
BRT 1
(headquarters and site personnel).
This should include f
2 interface responsibilities and define the corporate 3
position on the bulletins."
4 Have you ever seen such documented direction?
5 A
EP-31 addresses some of it.
I don't know 6
wh eth er --
7 O
Does it address interface responsibilities and 8
corporate position on the bulletin, and requirements of 9
the bulletin to include organizations, departments, 10 sections, and individuals?
11 A
I don't remember.
12 O
Recommendaticn number 2 states that:
"A 13 complete review should be taken to assure that the 14 qualification documentation is complete to support 15 ad equacy of the equipment. "
16 To your knowl edg e, was that done?
17 A
Do you want to repeat that?
18 O
A compl et e r evi ew should be taken to assure that 19 the qualification documentation is complete to support 20 adequacy of the equipment, prior to March 1984; was that 21 ever done?
22 A
Not by me.
23 0
Recommendation number 3 says:
"Technical 24 Function take the lead in establishing a training prograr 25 for corporate and site personnel on the requirement s of I
l 1
r 22861.1 48 BRT 1
the bulletin."
Has there ever been a training program 2
established?
3 A
I don't know.
4 Q
What I would like to show you now is a 5
memorandum dated April 4, 1984, it's from Mr. Guim:nd to 6
Mr. Stromberg, and it's in reference to audit 81-02.
This 4
7 is th e first page of it.
This is the second page.
If you 8
would ignore this right here, got a new copy because it 9
was blank ed out.
I would like to have you tak e a look at 10 it and ask you if you recognize that document?
11 A
What is your question?
12 O
Do you recognize that document?
13 A
I haven't seen it.
I haven't seen that ;etter.
14 Q
Essentially what it states is that audit 15 findings from 81-02, findings 1, 3, Sa, 6a, 10, 11.4, 11.8, 16 and 11.14 are still considered open.
17 Do you know why it has taken so long to close these 18 audit findings?
19 A
I don't.
20 0
You mentioned before that Mr. Gui.:nd did tell 21 y:
that the documentation in the files war
- ade.;te.
22 A
I knew that he wasn't completely Estisfied with 23 th em.
24 Q
Did he tell you that -- was that at a meeting?
25 A
No.
It was just off the record.
I i
22861.1 49 BRT 1
0 Did he ever tell you it at a meeting that you 2
had attended?
Or did you ever tell anyone else --
3 A
Not at meetings.
I did not pa rt icipat e.
I 4
don't remember participating in any of these meetings.
5 0
okay.
Was it ever related or indicated to you 6
that you could ignore either the audit findings of 7
irternal GPU audits or TER deficiencies?
Were you ever 8
told to, you know, ignore them or if you don't have time 9
don't do th em, or anything to that effect?
10 A
No.
11 O
Both the DOR guidelines and 10 CFR 50.49 require 12 that complete and auditable records be available for 13 identification; are you aware of that?
14 A
Yes.
t 15 0
V. towing what you know now, during the late 1983 16 and le.te 1984 time period, were complete and auditable 17 records available for qualification?
I'm talking from 18 retrcspect.
Not what you knew at the time.
19 A
They were not.
20 0
T: your knowledge, did yourself c anyone else 21 inter:2onally lie on May 20, 1963, or the February 10, 22 1984 submittals that we have discussed, when they said 23 that, in the one case you were in compliance with DOR 24 guidelines and in the other case, in coa.pliance with 10 25 CFR 5;.497
50 22861.1 BR.
1 A
I can only speak for myself.
What I said, what 2
I provided was my best knowledgs, to my ability.
3 O
To your knowledge, did anybody else 4
intentionally lie?
You know, we have to tell than this or 5
else --
6 A
Not -- not that I know of.
7 BY MR. LA G RANGE :
8 O
Getting back to the..mitorque motorized valve 9
actuators, 1-A and B.
Did Limitorque tell you what the 10 reason for their mistake was?
When they had previously 11 told you in writing, from what I understand, that thes e 12 valves were qualified based on certain test reports?
13 A
Limitorque said that we had not given them the 14 Limitorque motor serial number prior to my calling them up t
15 and asking the= what that meant and, going back to that 16 serial number is how he discovered he had made an error.
17 0
What did he base his previous information on, 18 then, if he didn't hav e th e s er;al number at that time?
19 Do you know?
20 A
I don't know.
The e '
thing he had was his 21 order number.
And possibly t'
rial number of the
- 2 actuator.
23 0
Have you or anyone else connected with the 24 environmental qualification tii;rt at GPU with regard to 25 TMI-I ever traveled to Limi-rrr :e to audit their records?
l t
22861.1 51 BRT 1
A I have never traveled there.
I don't know about f
2 anybody else.
(
3 Q
You don't know of anyone else in the GPU 4
organization that has gone to Limitorque to audit th eir --
5 A
I don't know.
I can't answer that question.
6 There were people before me.
I didn't go.
I don't 7
know whether QA ever went.
I don't know.
8 MR. LA GRANGE:
Okay.
I guess I'm done.
9 MR. MATAXAS:
Why don't we take a two-minute 10 break here.
11 (Discussion off the record.)
12 BY MR. MATAKAS:
13 Q
Mr. Boucher, did you appear here today of your 14 own free will?
15 A
Yes, I did.
16 Q
Have any threats been made against you or have 17 any promises been extended to you for any testimony?
18 A
No.
19 0
Is there anything else, anything that you would 20 like to sa,.
regarding this :
erview or anything ym: would 21 like to say at all?
22 A
Just that th er e ' s an awful lot of information 23 tha t 's g e :e th rough th e y ea r s.
To 90 f rom memory, I hate 24 to say anything from memory.
I did -- have been doing the 25 best job that I have been ab le to do.
22861 1 52 BRT 1
Q Do you feel that you have received the support 2
from manag ement that you should have received to i
3 adequately complete this program?
Very honestly.
4 A
No.
But does any person feel that th ey a re 5
justifiably reviewed by their management?
No.
I have 6
been complaining for years, but everybody complains.
So I 7
don't know.
Management made a decision on how to operate 8
and I was just doing the work.
9 HR. MATAKAS:
Anybody else?
10 MR. LA GRANGE:
Knowing what you know now.
11 though, do you think it was possible that you and Gerry 12 Maus alone could have put the files in the condition that 13 they are in now?
14 THE WITNESS:
Nobody could.
Th e ti.me is 14 : 49.
This will 16 conclude the interview.
17 (Whereupon, at 2:50 p.m.,
the interview was 18 concluded.)
19 20 21 22 23 24 s
25 t
t
(_.
CERTIFICATE OF OFFICIAL REPORTER T
\\
This is to certify that the attached pro,ceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of NAME OF PROCEEDING: INVESTIGATIVE INTERVIEW OF:
PAUL BOUCHER DOCKET NO.:
PLACE:
PARSIPANNY, NEW JERSEY DATE:
WEDNESDAY, PARIL 24, 1985 t
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(siet1/Ap
< rrPEt()
~
/
Joel Breitner Official Reporter Ace-Federal Reporters, Inc.
Reporter's Affillation t
.