ML20147E739
ML20147E739 | |
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Site: | 05000000 |
Issue date: | 05/08/1985 |
From: | NRC COMMISSION (OCM) |
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FOIA-87-696 NUDOCS 8801210209 | |
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Text
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~
ORlG N L
A UNITED STATES NUCLEAR REGULATORY COMMISSION t
IN THE MATTER OF:
DOCKET NO:
INVESTIGATIVE INTERVIEW OF NICHOLAS C.
KAZANAS r
l' LOCATION:
FAo; FFANY, NEW ;Easty PAGES:
- _ 43 DATE
WEDNESDAY, MAY E, 19E5 k
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ACE-FEDES.AI. REPORTERS, INC.
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
.--------------et---
X A
In the matter of i
INVESTIGATIVE INTERVIEW 6-of 7
NICHOLAS C. KAZANAS 3
.-----------------x 9 'l 10 GPU Nuclear Corporation 100 Interpace Parkway 11 1, Room 308 i
Parsippany, New Jersey 07054 12 I
Wednesday, !?.ay 8, 1985 13 i te
'3 The Investicative Interview of NICHOLAS C.
it KAZANAS commenced at 11:05 a.m. before Richard A. Matakas, 17 i Investigator, Nuclear Regulatory Contdssion.
15 i
j ON BEHALF OF TdE NRC:
20 Richard A. Matakas i
U.S. Nuclear Regulatory Commission i
21 Region I 631 Park Avenue l
2: I King of Prussia, Pennsylvania 19406 i
n~
A, 4
,. nw.mm im !
25 '
h e
Walch 2
1 (11:05 a.m.)
2 PgggEgglggS S
MR. MATAKAS:
The date is May 8, 1985, and it is 4
11:05.
5 Present for this interview are myself, Richard A.
6 Matakas, Investigator, U. S. NRC, and Mr. Nicholas C. Kazanas, 7
Director, QA GPUN.
8 The purpose of this interview is to discuss f acts 9(
and circumstances leading to GPUN's submittal to the NRC 10 involving the environmental qualificatro: of electrical 11 l equipment at TMI Unit-1.
I 12 Mr. Ka:anas, do you have any objection of providin; i
13 !
this infor=ation under oath?
it MR. KAZANAS:
Absolutely none.
't Whe re upo..,
16 NICHOLAS C. KAZ ANAS,
D was called as a witness, and having firs: been duly sworn 16 by Mr. Matakas, testified as follows:
DIRECT EXAMINATION i
2C BY MR. MATAKAS:
21 Q
For the record, will you please st ate your full 22 name an'd business address?
.x 23-A Nicholas C. Kazanas,100 Interpace Parkway, i
24 Parsippany.
w.' norm. sac 25 0
And telephone number?
t
3 1
A 299-2275.
2 O
How long have you been in your current position t
3 with GPUN?
4 A
As Director of QA?
5 Q
Ri ght.
6 A
Oh, '.et's see now.
I joined the Company on
.w. arch 7
6, 1978.
The accident at TMI was a year later, in '/9.
And 8
I went to my current position around November of '79.
9 j!
O What we are going to be talking about first s
f 10 g internal audit, 01. GPUN internal audit 81-02,and what : have -
11 h is original audit.
The response couldn't be located, Te:h 12 Punction response, but what we ha"e is OA response to Te:h 13 Functions response, which reiterates what they originally
't said.
Tech f unctions revised response, and an Aprl'.4 I t-me.morandan from Mr. Guimond to Mr. Stromberg regarding o er.
P audit finding.e of Audit 81-02.
IE For the record I will just identify them.
Origina; 1
audit was transmitted per letter cated June 25, 1981, letter 20 ' No. QA/41-61. QA response to Tech Function's response tc the i
21 audit was transmitted via letter June 25, 1981, letter Nc. OA 22 l 41-86.
I 23 '
Tech Punctions revised response dated August 21, 2d 1981, letter No. EP EI 61/0170, and April 4 th ' 84 memo 12ndus, e
-, a w.,m.inc t 25 1 subject of which was Open Audit Findings of Audit 81-02.
L
,,-e
4 1
That letter number is PDA/84-107.
2 I want you to take a minute and look those over.
[
3 (Witness peruses document) 4 A
You realize there are other correspondence on 5
the same subject which you don't have there.
These are just 6
a selected number.
7 0
Okay.
That is what we are going to be talking 8
about.
We will get into those other ones if you will bring 9j it to my attention.
I appreciate it.
10 Originally, what I had asked for is -- I believe i
11 I asked for a particular audit, and al' related responses 12 back and forth, and that is what I got.
13 A
I think there are other correspondence in the 14 audit file.
You know, I can't swear to this, but I seem to S
recall more documents thar. what you are showing me here.
16 0
If there is anything that is pertinent to what 17 l we will be talking about, bring it to my attention.
16 A
Okay.
C As or those documents themselves, you recognize --
20 A
Yeah.
21 0
- - all those documents?
22 l A
Vaguely familiar, but yes, I am somewhat aware t
23 of the analysis which was asked of OA, and we did the evaluati:r 24 l IE Bulletin 79-01, and this is documented in the
,e nuemm. nne l against o
25 June 25, 1981 re port.
I i
1 5
1 A number of problems were identified, and this 2
was some cf the responses that we did get into.
[
3 And as you can see from the dates, there was 4
obviously a lot of communication back and forth on a number of 5
these findings.
6 0
What is QA's responsibility in making sure that 7
audit findings are corrected?
8 A
What is our responsibility?
91, O
Yes.
What procedures were in ef fect, the procedun
!i 10 ': that was in effect at that time, to track the open audit h
11 findings?
12 A
I guess : -- OA provides an independent verificati:.-
i f
13 I and we obviously identified problems for action.
If the 14 problems are not satisfactorily resolved, then we continue to
't go after them.
le On a nere formal sense, I don 't believe we put 17 into place the actual response program.
You know, that was 16 one of the areas that we actually felt was deficient in our procedural house, and I think at a later point in t) ::c, :
20 [ believe in '83, early ' 83, we came out with a 1000 series 21 ! procedure, which indicated how an organization is
+.o respond 22 and what manner, in terms timeliness of response, and it 23 also indicates what happens when two parties don't acree on 24 what resolution has w take place, and we follow up with rais:...;
-.- m.mmn. inc. l e
25 ' or escalating the problem.
.=.__
6 1
There is another program which was put into place 2 l even later than that, and that would be the Management
[
/
3 I Escalation Program, but that didn't come into place until 4'
February of ' 84.
That is a nore recent thinc;.
5 I think that also formalizes the resolution 6
process in making sure that if there are problems and disagree-7 ment on how specific problems are to be addrested, that they e
are to be elevated quickly.
9 You have got to remenber, too, back then when 1..
U 10 p the '81 time frame, a lot of what we were reviewing, a lot of L
11 j what we were doing was being done in absence of any NRC 12 h requirements in terms of the -- the 50-54 requirements didn't i
i 13 :
come out until much later, June of ' 82, I believe, is the
't date --
'l O
Wher, you say, ' requi re me nt s, ' you are talking it about auditing requirements?
D A
I am talking about the regulator's requirements IE,
in terms of the rules.
l 0
specifically over environmental qualifications.
~
2:
A For environmental qualifications.
21 '
so, a lot of the work was done against the i
22 i Bulletin.
I 23,
O The DDR guidelines?
24 A
The DOR guidelines, yes.
They came into play.
.. mme,wn me :
25 ' A lot of it was based on guidance, and not requirements.
b
7 1
So, I think QA's position back then is we were 2
reviewing it against the adequacy of the available docunen-3 tation at the time, and we didn't really have a forn.al rule 4
on EQ.
3 Q
What is the formal rule now?
4 A
10CFR 50.54, I believe --
7 0
50.49.
8 A
I am sorry.
50.49.
9!
Q And when was that effective?
i 10 A
Well, it was issued in June.
It was issued with
!--let'ssee, I believe it required submittal of what we call 11 I
12 our skew sheets, or evaluation data by February ' 83, and 13 full implementation would be by March of '85, t
't' And if you didn't have your equipren qualified 1
by March of
'65, you had to request specific extensions whict 4
could be granted up to six months under certain conditions.
'?
O 50.49 came out when, 1982?
16,
A June 1982.
For example, I guess a lot of the things that you are going to find in the 81-02 audit were not 20 '
formulated; in fact, when the final rule does come out, they 21 lessen the requirements.
1 2* 1 For example, mild environment is one of the 23 findings in here and I think OA was always promo-ing the posi-ir i
24 !
of we should have our prograr. in place for mild environnent, o
.. m.o=n W ;
25 and should take a much more extensive stand on mild environmen.
i 8
1 When 50.49 finally does come out in June of '82, 2
mild environment is not a requirement.
3 O
We are talking about specific requirements, but --
4 an overall programmatic findings of the audit.
Would it be fa.:
5 to say that they are critical of both the documentation to 6
establish qualification, and the lack of management direction 7
within the program?
[
8 A
That is, in essence, what the findings can be i
9 summarized to say.
We didn't have our, 'act together,' in l
10 terms of how we were going to proceed with this program.
11 1,.
Everybody had different ideas on what the design 12 l' of the program should be.
We were looking to cone up with i
13 an effective program.
I think we had a number -- we, GPU,
's and had put into place a number of programs prior to the ru'e coming out which we felt addressed those requirements, ic But they were really in absence of a hard and P
fast rule that you can go reasure them again.
It I can give you examples of that, too, but --
O Go ahead.
20 A
You know, as an example we were reviewing procure-21 '
ment documents, and we had to develop some rules on procureren-22 I prior to the rule coming into place.
i
)
23 '
O When you are talking about the, ' rule,' you are 24 talking about 50.497 o
.. awomn. x 25 l A
50.49.
And, you know, we had recognized the need t
n
6-A 1
for special warehousing requirements.
Tagging identification.
2 And there is evidence of a number of discussions and programs 3
being put into place.
4 TMI had put in a special EP procedure.
I 5
believe it is -- I have a reference number to it -- 1407-2 6
was put into place quite early.
September '81, which deals 7
with preventive maintenance requirements for environmental 8
qualification equipment.
9I It was subsequently revised again af ter the rule
- j.
10 came out.
A number of warehousing issues, number of procure-11 h ment issues.
We have put out QA guidelines as early as li 12 i December of 1980.
13.
We have conducted other audits in addition to
't this 81-02.
We conducted an audit of environmental qualifi-cation on spare parts, which is identified as 61-05, and that it was done in, I believe, later on in 1961, somewhere around D
July if I recall.
It 0
The actual EQ program itself, who was the QA i
l auditor that was following the program?
Did you have 1
(
l 20 specific auditor?
21 A
We have many people following the program.
l 22 l Q
Basically until the rule came out they were 1
23 auditing against the IE Bulletin, 7901-B, which DOR guidelines i
?'
were attachment to that bulletin?
e w nw.mm w 25 '
A Pight.
t i
9 1
o Then when the rule came out, they were using 2 1 both documents?
I 3
A The only thing I want you to recognize is we 4
didn't have hard, f ast rules, and the NRC was still mak:ng up 5
its mind on terms of the implementation.
6 I think industry was saying hey, it is too hard.
7 And there was a lot of correspondence back and forth, and 8
there was a lot of backing off on various items.
Example 9i being mild environment and the position we were to take :n E
10 ? that.
11 h We find ourselves pushing mild environment well n Y into '82 'S3, and in fact -- I am not arguing that something i
i 13 has to be done with mild environmental equipment.
Howeve r,
I te there was no hard, f ast rule that required it.
That is all I at trying to picture for you.
ic 0
The program itself, you were following the I; a
program and you were basically using 7901-B, IE Bulletin --
It A
Per request from engineering.
i 1
O I have been given a copy of QA procedure 7-lE-;;,
2; and in Section 8.8, dealing with audit response, it says that if the response has been acceptable, the individual resp:nsib;<-
22 l for the QA audit subsection supervisor will notifv the audited 23 organization, delineating the reasons for the unacceptabil:ty.
24 ; and request a submittal of an acceptable response,
{
wm amomo w ;
25 So, what I would like to talk a little bit about
10 1
is the original response by Tech Functions -- first M all, 2
g they only address Findings 2 through 11.
3 It didn't address Finding 1, which had to do with 4
the lack of management direction.
5 Do you know why that was?
6 A
At this time, no.
7 0
Well --
8 A
I know that that subject had come up a number of 9: times.
But Finding 1, I see back here on April 4,1984, we 10 were still talking about the issuance of procedure 1000 Adir 11 ! 7317.01, or more ef fectionaly called Eoc 31, 12 That became the cornerstone of our program, and 13 although draf ts on that particular precedure were quite early,
il and by early I mean probably -- I am not sure.
I would think 4
it is :,r. the '82 time frame.
4 That procedure doesn' t get issued until weil P
D into '84, I believe.
The OA comments were resolved in 16 December of '83 on that procedure.
Agair., that procedure is somewhat advancing the requirements in terms of when it 70 has to be in place, but we are also arguing about all the 21 elements that go into this program.
t 22 i Q
Are you aware Mr. Guimond was the lead auditor l
23 2d '
A Oh, absolutely.
u
,. n.cor=,4. W 25 Q
And that he rejected all the initial responses by 1
11 1
Tech Punction?
2 A
oh, yes.
j 3
O And then in the revised response Mr. Magit: had 4
accepted the proposed corrective action to those -- to revised 5
response by Tech Functions?
6 A
Yes.
7 0
Why did Mr. Magitz review that revised response 8
and not Mr. Guimond?
9j A
Why?
Mr. Guimond reports to Mr. Magitz, and ye.
10 g Magitz is the corporate audit supervisor.
Mr. Guimend was 11 ; classified a lead auditor, you know, working for Mr. Magitz, i
12 Mr. Magitz doesn't do all the audits.
You know, t
13 l we have a select number of people and any one of ther -- I id '
think the procedure also permits that, and they can close i:
'i out.
16 I 'hink -- I also would believe, or I would like D
to believe, and I think at least what my manager is telling 16 re, the manager of QA program involving an audit, he is i
telling me there was specific guidance and there was a lo of 20 communications back and forth between Guimond and Magitz a:
21 the time.
They should have been reasonably satisfied.
22 That is not to say they wouldn't disagree on 23 l something, but I think in many cases you will find guidance 24 established in the files by Mr. Guimond and Mr. Magi:: jus e
.. amorws im 25 verifies that these things are in place.
l c
12 1 j I don't think that is unusual, 2
O Okay.
The reason I ask that is that under Audit j
3 Responses, No. 2, Corrective action responses shall be evaluated 4
by a lead auditor.
5 A
Well, Mr. Magitz is a lead auditor.
6 0
Isn't it normally done by the lead auditor, the 7
initial audit --
8 A
It is a matter of circumstances, and convenience --
9, you have to respect the fact that we have a three tier progra.
10 I We have an inspection function, a monitoring function, and 11[ an audit fanction.
You have lots of people that are involved.
k 12 h Mr. Magitz, under Mr. Markowski, who is the 13 ! manager of QA program as result of an audit, is responsible t
't' for the corporate audit program.
't I also have a supervisor at TMI who is respons bit 16 for the Unit-1 audits.
I have another supervisor at TMI-2 U
who is responsible for the audits at Unit-2.
18 So, you know, they all have their respon.sibilities,
and how they use their staf f is, you know, is specified.
I 20' think the requirement is that we have a lead auditor to 21 close findings.
I 22 :
O Okay.
Is it normal -- is it in the normal schent l
23 l of things --
24 A
As a practical matter, yes.
As a practica. matter e
. namorwn. x 25' you normally would call in the lead auditor who does the job
13
(
1 and ask his advice and counsel and make sure that you are 2
I getting at the specific problem.
3 0
In this particular case, do you know why Mr. Magitz 4
closed it out and not Mr. Guimond?
5 A
I do not know.
But again, I don't find that 6
unusual.
7 0
- okay, s
Nor is it contrary to the procedure requirement.
A 9j O
Were you aware that back in 1982, in August of 195;.
10 l';
I that Mr. Guimond attempted to draf t a memorandun to Mr.
t b
11 r Croneberger, -- did draf t a memorandum to Mr. Croneberger, the.
p 12 i; subject of which was Proposed Corrective Action to Audit 81-02, 13 wherein he essentially states that as far as he is concerned,
't Finding No. 1, No.
3, 6-A, 10, 11.4, 11.8 and 11.14 -- excuse me, rinding 5-A also, he considers them to renain open.
le I would like to show you this draft and ask you a
if you have seen this before.
It is to Mr. Croneberger.
It it,
was draftec by Mr. Guimond.
~~
(Witness peruses paper.)
20 l A
There is a response to Mr. Croneberger.
It may i
1 21 '
deal with some of the same matter.
In answer to your question i
22 l Very specifically, I would not see a draft like this if it 23 ldidn' t get approval of the responsible people.
2d !
O Were you aware that this was done?
That this a
w n eo,wn. w '
25' draf t was -- this letter was draf ted by Mr. Guimond, and that
14 1l it was never -- apparently it was never sent?
2 A
I am aware of it in later time frames.
At the tire l
3 in which it was issued, or attempted, or whatever you want tc 4
call drafted, developed, I certainly was not part of the 5
discussion.
6 I becane aware of it later.
In fact, you know, 7
I end up signing into a letter to Croneberger following up 1
this particular audit, and it is much later in time.
8 9
0 When did you becone aware that this letter was 10 draf ted and not sent?
II (
A Exactly when, I really can't say.
There was some
'?
times when I think Mr. Guimond would come into my of fice, 13 in time frames after and would indicate we had a particular
't problem with one aspect, or how the prograr was going, et cetera, et cetera.
It O
The EO program?
i)
A EQ program, yeah.
I think in all honesty Mr.
15 Guimond was somewhat frustrated at times that things were not going the way he wanted them to go.
20; O
Who told you about this letter?
21 A
I can't exactly tell you who.
I wasn't aware of i
22 -
the letter having been draf ted back in this time frame.
I 23 '
O I understand that.
But within the procedure back 24[ at tha t tine, in order to bring this to Tech runction's o
.. m.co n n iac !
25 i attention, wouldn't it have been proper just like it was in l
l l
i I
15 1
1984 -- it is essentially the same letter -- finding the same 2
audit findings open, wasn't it proper to send this letter?
3 Would it not have been proper?
4 A
You know, at that particular tine I can't say it 5
was my decision.
That letter didn' t come up to me and say 6
here is the merits of that letter, and we, in fact, should 7
send it.
8 We did send a letter in 1984.
I signed into it.
9j I looked at the merits related to that, and we indicated we i
10 ; had to go back and get some additional resp:nses at the time.
1:
11 l We are getting closer to the implementation date as required I
12 by the rule.
We had some additional matters that we had 13 to get resolved.
It '
So, the letter was eventually sent, and how mu f.-
'5 different this letter is than the other one.
really car. ' :
16 say.
I have not studied this letter.
You are showing i: ::
i7 me, and that is fine.
16,
I became aware of the letter that went out in l
'84, in having signed into it.
20,
O Did it not concern you that an auditor tried to i
21 t address audit findings in his initial audit, and followed l
22 procedure, apparently, and he gave it to his supervisor, and 23 that the letter was not allowed to go?
24 A
re ah, but you are assuming that I know that the re 4
..neewn.w.
I 25 is a le t te r --
16 1
O You were informed about it some time later.
I 2
A Some time later, yes, I became aware of it.
[
3 0
Didn' t that concern you that it wasn't brought 4
to your attention earlier, or that it, in fact, happened at 3
all?
6 A
well, let me put it this way:
When I became aware 7
of the various factors that related to this, I did act know 8
that there was a letter that wasn' t to be sent.
I 9.'I If you are asking me did I squelch a letter, the I,.
10 answer is, no.
11 b:
Q I understand that.
I am not even trying to inply b
12 ;.
that.
What I am trying to determine is how you found out abo :
r 13 !
this letter, and did it concern you, and did you look int: the 7
matter when you did find out?
A 2 guess I looked at it in the individual mer :s h
at the tire when the letter was sent in ' 84.
At that tire D
I thought it was prudent, and I thought it was required.
16,
We developed the letter and we sent it.
I did I
not go back and question should something have been sent 20 earlier.
21 You have to remember that throughout this whc'e 22 time frame, in ' 83, we are working with Tech Punctions, we 23-are working with administja lon, warehousing, procuremen:
7' people, engineering people, plant engineering, in develo,:;ng 79 AGOOrWrg, tric.
25 these program requirements.
17 i
1 The things that are going or, the program is l
2 being put into place.
3 The letter talks about the. formality of these 4
-- the program results, and you can have the top to your 5
program, and if you don't have anything underneath, that is 6
not very good either, 7
I think these things were concurrently being 8
worked on.
EP-31 had several revisions, many, many revisions F
9 before, in fact, the plant got accepted and signed into, li 10 [
.Tn fact, when EP-31 was -- ve had resolved the II ; QA comments in December of ' 83, and I dcn' t think the dnumen I2 llh hit the street until much latter than that.
Well into '84.
13 And the reason' was there was additional comments coming cut of the plant on just what these requirerents were and how they impact their warehousing program, or when tney 16 reordered spare parts, what was tne criticality, the nature I?
of getting the right parts, what they had to do, what the 'do's 16 and don'ts' are of ordering a spare part so you don't destroy i
the qualification.
20 There are a number of things that are going on.
I:
21 - is a moving target.
22 O
During the 1981, 1982, and 1983, were your 23 subordinates, I am talking about Mr. St:o= berg, Mr. Chisholn --
24 I am sor ry, Mr. Stronberg, Mr. Magitt, Mr. B ade r, Mr. Ala ta ry,
o
,, m.oorwei.ine 25 did they bring it to your attention that they were not satisfied
18 I
with the E0 program in the areas of documentation to support i
1 2
qualification, and management direction.
Were they bringing
[
3 this to your attention?
4 A
Are you talking about the documentation files 5
themselves?
6 Q
Righ t.
7 A
Yeah, I think there is a number of instances where 8
diat was, again, brought to my attention.
You spoke to Dr.
9 l! Long.
I know that sonewhere along the line also brought it l
10; to his attention as well.
f 11 Q
When you answered yes, it was brought to your 4
il 12 h attention, it was brought to your attention during the ' 81 I
i 13 i through ' 83 time period by Mr. Stromberg, Mr. Bader, Mr.
't' Alatary, Mr. Guimond, is that correct?
f A
That makes it sound like -- well, the way you are 16 asking it it makes it sound like they are continuously bringir.;
D it to my attention.
The answer is no, to that.
16 There are times when people come to me and say:
You know, we still have a problem.
20 0
Can you give me some type of feeling for that?
21 A
Yeah.
22 O
During that time period, now.
Let's talk about i
23 that for now.
1 I
24 A
You know, I think we had many meetings witt. the g
. n e e m m.ine 25 principal engineer, who I guess was Gerry Maus at the time, and
19 1
there were a number of meetings where I personally got involved, 2
and said we have to get these things straightenci out.
3 I would bring Gerry into my office and go over 4
these various problems with him So we would get a series of 5
indications that yeah -- you know, Gerry is also interested in 6
seeing this is done.
7 We develop an action plan and we would <;o out 8
and try to implement it.
After a while, you come back and il 9 H mavbs 'a while' can be three months later.
I don't know, at I!
d 10 varicus times.
And it may have strayed off course again.
11 h O
Did you discuss these matters that were being r
12 f brought to your attention by your ow7, people with Mr. Chishol 13 and Kr. Croneberg and Mr. Wilson?
Did you discuss with ther
't the fact that your people were identifying the problem of i
first cf all a lack of documentatier ;r. the files to supper:
'e qual:fications?
P A
Yes.
You know, there are a number of instances 16 where this is, out you have got to aisc rememoer another thir.p.
and you say lack of doeurentations, cany times, you know.
t 20 ;
turns out that the lack of documentation is not as bnd as ry 21 audito.
my inspector, my OA engineer is sensing it.
22
'he position that I think Gerry Maus took initially i
23 '
when he.. ueveloping the files is to use worse case conditio?s i
24 on C.1 pieces of hardware.
A
'W RWomm. Inc '
25 And this is the simpliest thing an engineer can d:,
(
i
s l
20 1
of course, because if he uses the worse case, you know, the 2
hardware component passes the environmental requirement, then 3
you know, he doesn't care about where it is in the plant.
4 Now, this proves many, many times a very bad 5
formula, because, in fact, as the detail of the qualification 6
results pertaining to a piece of equipment become known, it 7
turns out the piece of equipment cannot function, operate in, 8
and continuously operate in the worst environment.
9 ';;
So, then there are other factors that have to be I
10 looked at.
Where in the plant is the piece of hardware?
What 11 h kind of exposure?
Should we really be that much concerned abeu-12 the radiation levels?
i 13 I think in many cases the inadequacies that my
't guys are sensing and feeling is because they are looking at
't a very conseryhtive approach at the qualification.
le O
Do you feel that your auditors were more critica; P
of the EQ program than let's say the NRC or FRC during theit it inspections and reviews?
A You are going to have to tell me what is FRC?
20 Q
Franklin Research Center.
21 A
Okay.
You are talking about the TDR that was 22 issued.
Iet's say, I think to a large extent they are mere
(
i 23 critical of the approach that was taken.
24,
We took right from the start much too conservative 4
- v. aworm. im
- 25 an approach, and you know, we are still continuously revising
21 i
the radiation maps, revising where is the balance between 2
mild and harsh environment.
g 3
You know, there are a number of pieces, or the 4
exact shutdown logic tree that is being used to determine 5
whether a piece of equipment is in f act, or has to be environ-6 mentally qualified.
I think that has been proven over time.
7 I daink we had a case where through the -- through 8
the ' 81 through '83 time frame, the target is changing.
You 9
know, the engineer is getting smarter in how he analyzes the i
10 thing.
11 He is also getting to recognize that all equipment l'i f doesn' t need the worse conditions that can be presented, and I
13 l I think he also -- I think he is benefitting frot his own 9
experience in putting the packages together.
Sc, you know, every time a guy comes up tc rs ar.d it gives me a snapshot of how it looks, you have to bear in mind
'. 7
-- this in f act happened in December of ' 83, we were -- we did 16
-- I brought in some addi tional people.
I brought in noy Liscomb from TMI and and John 20 Solakiewicz from Oyster Creek to look at a specific number of 21 files.
I forget the exact number.
But to work with Guimond.
2:
They worked with Guimond, and did another assessment on i
23,
particular files.
2' They found the files were a hell of a lot better e
=> m mom, w '
25 than they were during that terrible period of tice back in ' 81
22 1
when the original assessment was made, but they also found i some problems.
And that was in '83.
2 3
Now, as we find these problems, Gerry Maus and 4
Tech Functions engineers are fixing a lot of them.
They 5
are analyzing and saying this one we are going to fix this way, 6
and this one we are going to have an additional analysis, anf 7
this one we are going to do this and that.
8 We ended up doing additional work-ups, additiona.
i 9,
TDP.s, and a lot of these problems go away.
They are not h
10.
problems.
11 j O
But weren't some of those the same problems they
(
U *i identified, and they even cite that assessment --
l b
l 13 '
A Some of them were.
'I O
--- problems that were identified --
1 A
Some of ther were.
But again, it is a renewed interest and a co:=itment to try to resolve these problems again.
IE And this continues.
We issued an update I belie:5, if I remember -- let's see, I believe in May of
'84, is that 70 right?
Let me just check.
I have some notes here.
21 (Witness peruses documents.)
1 2
We issued an update -- it was somewhere around 22 l May of ' 84, but on
- on that particular set of files, and during that time I had Bruce Bader, who was Joe Magitz's menaarm n 25 :
supervisor, go down and positively verify some of the problen.I l
1
23 1
and some of the updates.
/
2 And again, we have the moving ta rge t.
I didn't 3
want to issue a report that reported things as they were bach 4
then, but I wanted an update.
I wanted to know that the 5
problems, in fact, that were promised to go away, had, in f act, 6
gone away.
7 And Bruce came back and told me at that time things 8
weren't as bad as Guimond was depicting ther.
96 O
And that is in what time frime?
10 A
That was af ter the Fall of ' 83 fcilow-up, between 11 ! Lipscomb, Guimond, and Solakiewicz, and it was probably in and 12, around the May time f rame,
i 13 O
But that is after the NRC audit?
March 20-21, i
it 1984.
A Okty.
Yeah, there were a series of NRC sud:ts,
lo that is correct.
It was some where in that time frame.
He D
is saying they are fixing a lot of the proble=s that were 16,
identified back then, i
But we did issue an update.
20 0
What -- when he said the problens weren't as bad, i
21 Guimond exaggerated, or was he saying that the problens are 22 l being corrected?
I 22 ;
A Or, going back to what I said before, the very 24 conservative approach that was initially used was proven wron;.
-. nwomri Wi 25 and in f act they used a somewhat more realistic approach.
i l
A
24 1
Q When you say was proven wrong, 2
A Worse case conditions, so you don' t have to vorry 3
about location of particular article in the p) ant, and tie 4
actual radiation leveis that it sees, and you just apply 5
that to the worse.
-6 Q
Those requirements have been dropped?
7 A
No, no.
You get radiation data, or you get a more 8 l realistic approach toward the seven or eight environmental l
9 ;; factors that you have to consider.
h 10 {
Siesmic requirements are not the same anywhere,
11 but if you take a worse case approach you are obviously going F
12 " to be much more conservative in your design.
i 1
13 0
Is that always more conservative, or is that
'd sometimes the easier approach because you don't have to 4
retrieve documentation?
'e A
I would love te say that this piece of hardware u P
good anywhere in the plant.
That is pretty easy fro: an 16 engineering sense.
How would I do it?
I would have to subject it to 20 the worst environment possible, and then say Does it f unction:
21 And that would be the easiest approach.
22 i Now, when you find out through testing and analysit 1
23 l and through the DOR guidelines and what not, that it doesn't 24 f work then you are backing of f and saying:
Why didn't it work:
4
-. = =. n W ',
25 ' What f actors contributed te its malfunction, and then you are
25 i
1
-- you know, you are looking for engineering and focusing much 2 l -- a lot more on actual conditions.
l 3
And I think that was a lot of the problem we j
4 were seeing.
5 o
To get back to what I am getting at, when you 6
use the term, 'the most conservative approach,' that could 7
be very unrealistic and can be taken because it is the e
easiest approach.
I 9,:
A It can go the other way, and in fact -- well, I L
10 think I was reinforcing my thinking, because somewhere along 11 I the line, I guess, it was around May of ' 84, Wilson understands li 12 !
that:
Hey, we have some personnel problems with -- you know, r
13 the way the project was being run, and Wilsa) elected to make
'l some Chir.geS.
~!
But he recognized that, hey, we had sonebody here it who was not being careful.
The files were not being very D
religiously documented in detail to the requirements that 1E proved beyond any doubt, that in f act, we don' t miss something.
t And as you said, something which we think would 20 be okay, and we were taking conservative approach, would late:
21 ' prove out to require some modificatior.s of the piece of 22 hardware.
22 I think a number of interf aces was identified.
24 Somewhere along the line Wilson asked DA, he said I want you i
n norm =
25 to do a hundred percent review, I want to repackage everything,
26 1
I want to put it-together good.
i 2
He brings in a new team of people to kind of work 4,
3 cn these packages and get them up to speed.
Get them so they 4
are, 'auditable,' and really starts working them in.
5 And then he wants QA in line on all the packages 6
that go through this process, such that af ter Tech Punctions 7
says they are okay, OA looks at them and they don't have any g
problems.
They sign off.
t Tha is when I get Bruce Alatary involved in the 9,
jo '
process.
That is June of ' 84.
And we are n00 ting Hhd Review, i
11 l which I guess was June 26th of '84.
e 12 [
We are looking at the packages.
At that particular 13.
time we also bring in a couple of consultants.
I bring in a consultant to work with Bruce Alatary to be sure we get the job done, and this consultant has been involved in man'; othe:
u EO looks, and his comments to me are we basically have the str.c pieces of equipment that everybody else has, and the equipre..:
ig is good.
Generally speaking the equipment is good.
It is 7-going to meet the environment.
What we didn't have at the tirt 71 is the detailed, rigorous look at it, programmatic look at it 27 ' to make sure, in fact, that these requirements were, in fact, 73 satisfied.
24 So, even as late as the June time frame we are c
.,nammm W 25 aaking a substantial number of changes to che EO files, to make I
i
27 1 I sure they were in order.
(
2 That the realistic approach is used in the analys s, and we are doing -- we are satisfying not only Tech Function, 3
4 but we are satisfying QA, the packages are right.
5 Q
Do you think that Tech Function responded to QA --
6 I don' t know what other word to you -- but in a responsible 7
manner in the correcting of the deficiencies and the problems 8
that QA was finding and reporting to you?
I 9 j, A
I think the answer to that is overall, yes.
I 10 think we had a lot of trouble, especially initially, in 11 h.getting Tech Function to recognize that they were not doing 12 a ' professional, careful, programmatic look at the files. '
13 That took a while.
't I think they were fighting it, despite how much 4
we were elevating ii., in their house it was clear they Men it co ing back and poo-pooing it, and indicating that it was..'t P
as bad as we were saying it was.
In fact, a lot of times 16 they were saying it is just improving the software.
It is not really as bad as you suggested.
2*
So, I think overall, you know, when I look at the 2
whole thing, when I look at it with respect to the rule, we 22 '
have a lot of good support f rom Tech Functions.
23,
O What is the purpose of Corporate Quality Assuranet 24 Review Committee, or QARC?
F A
- e Reporterb l'tC 25 l A
What is the purpose?
I can' t say it functioned as t
28 1
perhaps it should have, but the purpose of it is an advisory 2
group for me.
3 It is a group of senior personnel at each of the 4
locations which evaluates some difficult scenarios and looks 5
at -- in terms of when and where we should escalate various 6
findings, to get more immediate action.
7 0
And when was that founded?
When did that start?
6 A
Early, I believe, in '83.
I 9'
O I have the Minutes of the meeting wh;ch took placc o
h 10 on February 18th 19 83, and the date of the Minutes is March 2, i
f I
l 11 1983, the day it was written up.
I 12 A
Ri gh t.
13 i 0
The first subject, the first agenda item is Lack
't of Control of Procurement Installation of Class :-A Electrira:
Equipren: Requiring Environmental Qualification.
- says:
16 Tne results of the Committee's deliberations were:
Under 7
Item 3, the last of a complete file of auditable records shcu' d 16 be escalated to the Director, Quality Assurance; and 4, all l
e organizations that have responsibility in that environmental i
20 qualification program do not have procedures that clearly defir e 21,i these responsibilities,
t 1
22 And then gives examples.
And below that it says :
I 22 ' Note:
Items 3 and 4, preceding, are considered escalated by 1
2d !
~e nwomn. w) virtue of this communica tion.
l r
25 i Again, that goes right back to the same findings l
29
)
and recommendations that were cited in 81-02.
Are you i
f 2
familiar with these meetings -- Minutes.
Do you recall i
3 these?
4 A
Yes.
5 0
We are not talking about a single auditor.
We 6
are talking about the QARC.
Again, bringing this same proble.-
7 to your attention.
8 Did you take any action as a result of these 9
ninutes?
10 A
You know I sat down and met with them.
11 h 0
Tech Functions?
r il 12 i A
No, with the QARC.
And they asked -- that to me i
I 13 was the old escape route.
You got to remember now, and you indicated yourself that it is only the second meeting.
QA P.:
't S
at that time was trying to identify itself, and they were 16 having some problems.
U We worked up a couple of -- I am slipping over my 16 word -- responsibility matrix in terns of what it is that the-i I
should be doing for us.
<?
At that time, the initial meeting.
In the second 21 meeting, and even probably the third meeting, were not up to ;t:
2 *-
in terms of what they should be doing.
23 I wrote back to the OARC members and sat with 24 ; them to go over what I thought was missing.
In looking at o
.. w n..
w i 25' that letter, I think you have to agree that -- well, a couple
30 1
of things, i
2 One, I certainly got the feeling in reading the g
i 3
minutes of that meeting that all they were doing was dumping 4
the problem in my lap, and hadn't necessarily exhausted the 5
means, the nornal means of getting problems resolved.
6 You know, they talk about --
7 0
What would those means be?
8 A
The follow-ups in terms of responding to the 9,
findings, the resolution of problem areas.
We had some n
10 " quality deficiencies that we had to look at.
It is all in tr.c i
11 process of nor=al means of elevation, b
12 o Before I am going to take this up with a directer i.
I 13 !
or vice president of a unit, I want to make sure that we haver. ':
't missed anyone in terms of, you know, getting some attention and horsepower that was required to res:1ve so e of these le problems.
~. '
I think what they had provided me at that par:1cu'1:
16 time was incomplete, and I largely attribute this to -- you I
know, it was a new committee and they were really having tror't 20 identifying what it was they were supposed to be doing.
21 0
Did you eventually take these same subjects up wit?.
22 )
Dr. Long on March 8, 1984?
I 23 A
Yes.
Some of the same subjects were Mdressed and i
28 were followed up, w
w newws. sne 25 0
Items 3 and 4?
I i
-31 1
A Well, let me go back and look at your 3 and 4.
2 The complete file of the records should be escalated, yes.
g 3
That was, in fact, taken up to Bob, and we made -- we apprised 4
him of where that particular one stood, and why it stood.
5 0
A d then Item 4?
That has to do with the 1000.
6 A
Yeah, that has to do with the 1000, which was-'t 7
out, at least at this particular juncture in time.
8 0
Okay, you stated you didn't want to bring it :g 9,: at this time until all avenues were exhausted, and you did a
10,
bring it up to Dr. Long on March 8, 1984.
i t i-;
A Oh, yeah.
II
- i.
O What transpired between that time, where you at r
V 13 that time, in March ' 84, did bring it up to Dr. Long?
't A
What transpired?
O In other words, were every avenue exhausted?
A Well --
M O
Could they not get things done through Tech 16 runctions?
I A
In my -- I guess my summary of the whole thing was 20 we were getting things done.
It wasn't quite as black as, i
21 perhaps, they were indicating.
There were a number of things i
2:-lthathadbeendone.
22 I did meet -- in f act, I personally met with some 24 l of the position VPs on the importance of getting an EF-31 ou:
e no necom em '
i 25 ' at the sites.
i I
32 1
A number of things had been, in fact, going on.
t 2 1 And if they had problems with it, with the various items in 3
EP-31, I was trying to use my organization to try to get some 4
of these problers smoothed over and resolved.
5 Q
The purpose of taking it to Dr. Long escalated to 6
his level?
7 A
The purpose in my mind was; one, to give him,a 8
heads up; two, to make sure that again in my mind that he felt 9 q comfortable that the problem was real, and I wanted to have i
10 ; various members of my group come in and show, black and white --
11 !!
O Weren't you satisfied that the problem was real?
11 12 1 A
Yes, I was.
I wouldn't have been pursuing it h
13 - otherwise.
't Q
That is right.
But what I4 getting at, you
~5 thought, back when you received these mtnutes, you wanted tc le make sure that every avenue had been exhausted.
I am sure D
Dr. Long felt the same way before you brought it to him.
16 A
Oh, absolutely.
That was one of his first quest:::
7 Q
Between these two times, was every avenue 2C exhausted?
Did you try to get this probler corrected through 21 Tech Functions, and was it not corrected?
22 A
I think we were -- obviously it was not corrected.
g i
23 We were bringing it to his attention to make sure he was awart i
24 j of it, and that he would, in fact, discuss it with Mr. Wilsor..
- n. m =nm.im 25 ' because the thing with EP-31, in fact, had to ge t on.
Just t
33 1
had to get on with that program.
2' I think Wils-on had shown evidence that he u. der-3 stood the importance, but we wanted to make sure there was 4
pressure to get the thing resolved and get it out.
5 So, it wasn't so much to ask his help, but to make 4
6 sure he was aware and sensitive to the issues in hand, h.ad 7
some firsthand observations in front of him that he could get 8. a feeling and a sense of the thing, and that he would p= sue 1
9 l, it in an informal way, perhaps, with Mr. Wilson, b
10 0
And on your same level over in Tech Tunct:,0..s ths 11 would have been --
II *i A
Mr. Cronebe r=er.
e.
I-13 :
O Had you brought it to his attention prior t:
-- between this time period?
l
'f A
Oh, yeah.
- think we had talked about it a
.un:: t r it of times.
D 0
Did you also offer assistance in implementir.g the 16 EQ program with your QA people?
A Absolutely.
In fact 20 0
Did they take that advice?
21 A
Well, yes, he heeded the advice in terms of getu.;
22 I as much help as he could frem us, and in fact, there were tints I
23 -
there where I think guys like Guinond might have spen: 2: h urs i
i 7' I a week over in Tech Funcuons working with the files e.:i t
e we n
<wn, i=. >
25 j
working with Gerry Maus and company to try to get prob'ers i
i
34 l
1 resolved.
2 Other assistance was we helped the plant resolve 3
a number of their procedures.
4 Other assistance was we conducted training 3
sessions.
6 Q
What I am trying to get at, though, is the probler 7
obviously wasn't resolved, and you didn't get it resolved
.I 8
through your efforts with your level of communications with 9
Tech Punctions.
I 10,
Is that why you went to Dr. Long?
l 11 lj A
I think you -- in retrospect you are probably rig.'.
Il 12 L on that score.
I think as lona as the head guy at Tech Punct::
I l
13 -
who it was, it was going to be a long fight, and it was really I
l
'I a recognition, or for management to recognize, tha t reaybe the.
i j
ought to conside making some changes.
)
lt j
And by the way, I would also add a cou le of ::ra
~7 l
even by initiation with Dick Wilson, or by myself -- you know, i
j 18 Dick would ask me:
How was the prograr. going?
I And I would tell hirn that it could be going a lo-i 20 smoother.
You got somebody t. hat is constantly fighting it.
I 21 0
Did you find Mr. Maus difficult to get along with i
i 22 ; at times?
i s
ww mecow i j
l
( ~ 0, pA: >
i i
l
35 1
Q Do you feel that he thought he was right in your 2
l c nversations with him?
3 A
Absolutely.
I can't say that he felt ar.ything but 4
being right.
d 5
Q Are you familiar with GPUN's May 20th 1983, and 6
February 10, 1904 submittals to the NRC regarding the status 7
of the environmental qualification program?
g A
I am more f amiliar now than I was a while ago, 9 ;; yes.
IC- ;
O Did you have any review prior to the s:bndttals?
11 g A
Not those particular subnittals, no.
l:
12,'
Interestingly enough, we did have some input and I
13,
some review in some earlier submittals, the Rev. 6.
We had
'e a QA review of that back in April of '82.
i 1
C I ar net f ar.iliar with that one,
What is that?
It A
That was Rev. 6 to the skew sheets.
guess we
.?
had from time-to-time revised the skew sheets as mere evaluattor.:
16 were performed, i
So, there were some updates.
??
O Prior to, or just subsequent to either response, 21 was it ever brought to your attention internally by any of you:
2; ! QA people that, hey, these statements that were ma$e in these 23 responses aren't factual based on what we have been seeing?
3 2:
A No.
Unequivocally no.
ml j
o
, a.oom :
25 O
In your observation, other than Mr. Ma s, what
3C 1 j other supervisor, at the supervisory level, Tech Functions, i
2
(
actively got involved in the EQ program?
3 A
Dick Chisholm.
4 Q
"ne did he actively get involved?
1 5
A I know ne sat in on a number of meetings.
6 Q
Are these the meetings when you were telling ther.
7 about documentation?
s A
That may have been one.
He certainly set in on 0
9 the exits.
10 '
Q Of the audits?
11 i A
Of the audits.
I think he was involved -- in fac:
12 1 he was Gerry Maus' supervisor.
13 l.
Q I mean arsessment that took place in December of i
't 1953.
Was there an exit?
I know that wasn't an audit.
Ths; i
j
't was ;us: an assessment.
't A
Yes -- : an. saying yes, n:: because I was in l
+>
attendance, but you know we hardly do anything without an 16 exit.
l O
It is my understanding that information was 2*
basically just provided to Maus.
Is that inconsistent with t
21 what you know?
22 A
It may not be inconsistent.
I didn't -- but i
23 generally speaking we do have an exit, and it may have been 1
74 just with Gerry Maus,
4
-, n =o m, me '
[
1 25 ;
Q
! hadn't seen anything in documentation regarding l
L
37 t
I assessments as opposed to audits.
2 i
I know you are very specific about post-audit 3
meetings and everything as far as audits go.
I haven't seen i
4 anything that covers assessments.
How does that differ from 3
an audit?
6 A
Well, it just doesn't go through the formal 7
rigamarole.
You see, we had early -- I say, 'early.'
It was 8
late in '83 at one of the meetings that we had with Gerry ll-9 ;; Maus and Ray Gr.imond, as a matter of fact.
Ray was in n
10 ; attendance.
"[
I can recall sitting down with Gerry, and d
,. 'l "3
indicating really that this program was a lot bigger than jus-13 looking at your files.
And the question of the moving target, and Gerry t
vent inte a icn; description on nov that was taktng place.
5;-
Gerry also had expressed a lot of genuine concers of the inadequacy of the program in the field, and he was -- and aga...
M the time f rame was late
'83, and in fact led to the December assessment.
M We indicated there would be three parts to this to an overall assessment of the program.
.I 2d Part I would look at the engineering files and t
22 documentation, ar.d how well they were being put toge ther.
And 24 i
that would be a CA-led item, with Ray Guinond, and Roy Liscom; i
4 y awome,i m 25 1 and John Solakiewicz.
l 1
i
-3E Item 2 would look at the warehousing problem, 1
i.
2 l and Gerry, I believe, indicated that he would take the lead 4
3 5! on that one, assess how well we maintained storing equipment, 4
spare parts, shelf life, all of the considerations for E0 and 5
how well they were being done.
6 And he would take on the leadership role, and we 7
would supply an individual to that assessment.
In fact, the 8
individual that was named was Tom Graham from TMI-1 site f rcr 9
quality control group.
10 The third piece would look at the maintenance activities, and Gerry himself wanted to be, you know, the leaf M
on that one.
! think No. 2 was led by Paul Boucher.
I don't 13 know if you have talked to Paul or not.
O Yes.
2 A
And Grru; I was led by Gerry, and we were 9:;nt te look at the whole progran and kind of put it together, s:
the assessment that was made was kind of modeled af ter the li agreements made at that meeting.
We did our piece quite early.
It took over a 2:
year to get the site implementation pieces done, pieces tha:
2I were led by Tech runctions.
2:
Q You mentioned problems in the field, that you and 2?
Gerry mentioned that.
Isn't that one of the things you were 2'
pointing out when you said there needed to be written managenent a
.e newws m II direction or guidance?
I
39 1
A Absolutely.
j 2
I O
rield is not going to volunteer to do anything i
3 unless sonething is written.
Telling then what to do and 4
what they have to do.
S A
Yeah, and part of that was EP-31.
A good part 6
of that was EP-31.
A good part of it was recognition by the 7
plant division that Tech runctions could specify conditions li 8
which affect and impact the operation of the plant in a J
9 very meaningful way.
10 0
- s that why it was made a corperate procedure?
11 A
Absolutely.
Absolutely.
Tech Punctions could MI specify that you have to change out o rings every year and 13 a half, and the plant has to meet that condition in order to have continued operation.
Tns has te be identified in a ::p leve'. do:uren.
't O
Was there lack of any type of cooperation in the field by --
It A
Oh, no.
In fact, they wanted to get on with the program, and many times they didn't have the information they
?!
needed.
21 O
You mean field did not.
22 A
Field did not have all the information.
TMI-1 or
??
Oyster Creek.
Did not have the engineering information down U
to the specificity that they needed in order to impact the u
.. a.co mi im 25 PX pobs, I
i
40 1
i Q
Basically, again, that is what is now called the
(
2(1000AdminProcedure, 73-17 -- I don 't know the exact nunhar, it 3
A Yes.
You are doing well.
That is the number.
4 Q
okay.
We got these two particular document 5
responses to the NRC, the May 20, 1983 and the February 10, 6
1984.
Has anyone indicated to you, anyone in the GPU 7
organization, that they knew it contained f alse statements 8 l prior to their submittal?
9 A
Absolutely not.
10 '
O And you yourself did not review or didn't have 11 I that --
M" A
No, we did not, and I believe you can check 13 exactly who has reviewed those documents.
O Does OA have any type of review function nov f t:
areas that ney cuht?
le A
We audit se tany areas.
You have
- remember also in reviewing so many areas, we were asked to be in review it in the development of the files.
But that was late in the g ame.
That was June of ' 84.
2; o
You had offered prior to that though, didn't you?
2:
A I ar not sure I particularly offered.
I of fered M
because it was important in our function to cover it in our M
audit progra and our monitoring program.
U We don' t normally ask to be put in line with
-. m e= = i m M
something like that.
We are in line on specif1: documents.
41 1
System design descriptions, installatien specs, 2
procurement specs, purchase orders.
There are a number of 3
things where we are in line.
~
4 other things, we just monitor and look at.
5 O
Prior to that meeting with Dr. Long, were you 6
informed by your own people that they had, in f act, offered 7
to be in line in the program?
8 A
No, I don' t think we ever ef fered.
We were content 9
to continue monitoring this thing.
That was a big job.
In i;
10 fact, when I did get in line, I recogn: zed that I couldn't II l6 do my nornal work and pick up this added work which consumed III a lot of hours out of Alatary and Cast:ri, the two primary i
13 ; engineers that did the reviews from my house, but I also had i
'I to bring in a consultant, Rich Condell:, from D. Venovetc S
& Sons.
Is tnere anything else you would like tc say or t
any other statement before we conclude this interview?
16,
A The only thing I want to say is EO is a difficult subject.
I think the organization took on a lot of things we'.
j 20 in advance of the rule; af ter the time f rame when the rule 21 came out, we made a lot of adjustments.
22 '
We pushed real hard.
There was a number of things,
i 23 I really think in the back of my mind it probably could have t
2d l gone a lot smoother if we had maybe not as much resistence r
.mne,m sm '
25 up front f rom Tech Functions, particultrly in the file area.
(
t i
l
42 1
You know, pulling together the engineering 2
files.
That was a horror story.
And it continued through 3
here and probably reflected on a lot of the other things.
4 We got cooperation, I think -- particularly good 5
cooperation from the Tech Function people on prograns else-4 where.
Perhaps not as much cooperation when we looked in their 7
house.
8 We had a management problem.
I think it has been le D
9 pretty well identified.
Management actions that had been 10,
taking place.
When those were taken place, you know -- and 11 Y finally, this was in the summer of
'84, you know, the r. e ve ry -
r
'2 ;
thing just started lining up, and actions really starting i
13 resolving.
't O
okay, but in the area -- specifically regarding th a; meno th a t was ir. the area of QA, that neme, tht was n;;
the men: fr:r Guimond te Croneberger, you d:..'
havt 4
sent any knowledge of that during that particular time period,
.?
16 of soneone saying not sending it, or to send it?
A The way I function, something like that I wou' dr.';
~
E sponsor unless my supervidor and my manager take it on and 21 say hey, this comes with our recommendation.
We feel it 2*
ought to be sent.
2.'
I think we --
j D
Q It would -- that could not have been sent without o
-. a.som.. is j
23 being brought to your attention in the normal schere of thingt,
43 1
is that correct, since you are on the same level with Crone-
{
2 berger?
i 3
A At the same level, yes.
But, you know, it is 4
not going to be the whims of an auditor without his supervisor's 5
support, or his manager's support.
I 6
0 That is what I am asking.
Was it brought to your 7
attention, do you recall, at that particular time?
8 A
It was not brought to ry attention.
You know, 9
sonewhere along the line, maybe -- we can only speculate at l
l 10 this point, but I guess I don't knw why it was brought up.
II i Eventually, some of the same matter does get brought up.
1 M
Q Every one of the same audit findings aSdressed l
13 l
in April of '84 has still open items.
l I
l t
A And again, you can spe: late at to the trang a:
i ths, punt.
Maybe at th a t pa rti c u', tr tir.e -- an d ! g ue s t n 4
are going back int Strorberg's time frame when he is r.an6g:.n; J
the section, that is not to say that he doesn't take on some H
of this himself it. terms of some escalation, some communicati::.
You know, we got a lot of promises throughout this 2'
whole thing, and unfortunately they didn't always follow 21 through, and they didn't always get fixed.
2' You eventually draw a scenario that hey, the only M
way we are going to get it done is we have got to escalate it.
I' That is when I sign into it to make sure Croneberger knows tha;
.v
. a.ww.i w 25 hey, I reviewed the matter and it didn't get done.
44 I
Q But the thing is you approached your appropriate 2
level.
To your knowledge, Stromberg approached h s appropriate 3
level, and we are talking about on the Tech Function side, and 4
things did not get done until a later time period af ter Dr.
5 Long _ was involved and subsequent audits and a whole lot of 6
events took place?
Is that correct?
7 A
That is correct.
I think it is also fair to 8
correct it is not just OA and Tech Functions.
Strcng 9
participant in YEP-31, this -- what was it, 73-17, doesn't get 10 f out is because even af ter QA has its say, it i
takes another 11 P four or five months to get the plant started up.
I:[
Q on procedure.
3 -
1 A
Yeah.
r O
The site has review authority over c:rporate procedure ?
't A
The way our corporate procedure prograr works, if j
?
in fact responsibilities are set for the organization in the j
16 1000 level procedure, it has been decreed that -- you know, r
~
Mank Eukill has get to sign into it, representing TMI-1 site.
M Q
And that was sent over to him some time in early f
2'
'84 time frane?
I 2 *-
A Ri gh t.
And before he would sign into it, of i
23 course, you know R:n Toole, and Joe Colitz have go to be l
24 satisfied that the program is there and they car. support it, t
4
. a.aom.i. m 25 If they are not being asked something unreasonable.
1 l
l 1
45 1 [
Q Okay.
Anything else?
1 2
A No.
\\
3 0
Did you appear today voluntarily?
4 A
Oh, absolutely.
5 Q
Have any threats or promises been made?
6 A
Threats or promises?
7 0
Yeah.
6 A
No.
9' MR. MATAKAS:
Okay.
The time is 12:18 p.m.
This 10 !
concludes the interview.
11 i-(Whereupon, at 12:1E p.m.,
the interview li 12 i concluded.)
r 13
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his is :o cert:fy tha: the at tached procee:h.
s. c f ore the 3
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. 3. w.
..s......
.....po v f
4 L
i 5
In the :.a::er o f '
Interview of Nicholas C. Kazanas.
l Date of Prc:eedi..g:
May 8, 1985 Place of Proceedi..g:
Parsippany, New Jersey.
were held as herein appears, and that this is the origi..a1 transcri:t for the file of the Come.ission.
s so Garrett J. Walsh, Jr.
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