ML20147E758
| ML20147E758 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 04/25/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 NUDOCS 8801210213 | |
| Download: ML20147E758 (84) | |
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OR22862.0, .
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, UNITED STATES OF AMERICA 1
NUCLEAR FIGULATORY COMMISSION OFFICE OF INVESTIGATION e
GPUN Headquarters 100 Interpace Parkway Parsipanny, New Jersey The Investigative Interview convened at 9:05 a. .,
.ichard A. Matahas, prc5idi..g.
PRESENT:
F. GERARD MAUS, Interviewee ,
Engineer, GPU U RICHARD A. MATAKAS, Investigator Region I Nuclear Regulatcry Co:nmission King of Prussia, Pennsylvania ROBERT C. LA GRANGE
'I Section Leader EQ Branch Office of Nuclear Reactor Regulation e.
w .- Repows -
_ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .~
88ee8 0 BRT- 2 I
EEEEEEE1EEE MR. M t.~ ' !' A S : Th e da t e i s A.: ril 25, 1985, and the time is 9:05. Present for this interv:ew are myself, 4 Richard A. Matakas, investigator, Uni ed States Nuclear 5
Regulatory Commission; Bob LaGrange, stetion leader in the 6 NRC EQ branch office of NRR; and Mr. F. Gerard Maus, engineer, in eng;:.eering assurance for GPUN. Th e pu rpos e of this int ervie .s to discuss facts and -.rcumstances 9
leading to GPU submit tals to the NRC involving the 10 envirormental qualification of el ec trical equipment at TMI 11 Unit 1.
12 Mr. Maus, do you have any objection to providing this information under oath?
14 THE WITSESS: No. Absolut e.'y not .
I
.5 Wh er eupon, 16 P. GERARD MAUS 17 was called as a witness and, having been first duly rworn,
.3 was examined and estified as follows:
19 EXAMINATION 23 BY KR. TAKAS:
2 Q Mr. Ma. before you came here to:ty were you 22 given any instruc-ions on how to testify or nat you 23 should say or shouldn't say?
24 A Inst ru e- ions ? No. We have a st andard format.
25 I have testified before for GPU.
4
22862.0 B P.T 3 1 O Who do you meet with? Did you meet with someone 2 before you came here?
3 A I didn't neet wi anybody. I spoke to -he 4 lawyer over the telephone. He asked me if I had any 5 questions.
I asked him spe: fically what you gentle =en 6 were going to discuss. All richt?
7 0 Did he give you a. y inst ructions on telling the 8 truth?
9 A Yes. A regular -- we have a standard 10 instruction format; y es .
11 O Which states essenti?.lly what?
12 A Tell th e truth, ans er all the questions, 13 cooperate fully. That's the company's position.
14 O All right. For t'.e record, would you agair.
15 stat e your full name and business address, please?
16 A F. Gerard Kaus , GPU Nuclear, 100 Interpace 17 Parkway, Parsippany, New Jersef.
18 Q What telephone number can we reach you at?
19 A Area cod e 201-299-206 3.
20 0 Would you give us a general overview of your 21 education and work history?
22 A I have two degree: I have a degree in 23 aeronautical engineering, I have a degree in physics. I 24 have taken a couple of gradast e programs at Stevens 25 Institute of Technclogy. : : eve over 20 years' exper:ence
22863 0 4 BRT 1 in the nuclear industry. Before I came to GPU I worked on 2
nuclear controls for sub.srines and a i r cra f t carriers.
3 O Specifically wi-h GPU, when did you start with 4 GPU and when were you assigned --
5 A May 20, 1974.
6 0 okay. How did you become involved in the EQ 7
program and what were your positions in that program?
8 A When GPU decide to start an in-house -- I guess 9 the word " s ta rt " is not correct. When they changed the 10 for=atting of the internal group, which was in April of 11 1981, they asked me to replace the then-current supervisor 12 of the group.
13 0 Supervisor of the envirormental qualification 14 section?
15 A Yes, sir.
16 Q That was in 19817 17 A Yes, sir.
18 0 Do you know the approximat ely time period?
19 Month?
20 A April.
21 Q And your title w EQ supervisor?
22 A Manager. Before ae go any further, I don't know 23 if you want me to say this for the record or not, I would 24 like a copy of this trans:ript. Is that agreeable to you 25 g entl emen?
22062 0 BRT 5 1 0 That's agreeable to us unless we are instruc ed 2 to do otherwise.
3 A When would you know the - ?
4 0 You know, certain circumstances, there have :.een 5
occasions -- I don't know that it will happen in this 2 s e, 6
but there have been occasions whe.- th e U . S . Attorney ' s 7
taken control of case in which cas e we are instructed .st 8 to give transcripts out. I'm nc- saying that it wil.
9 happen in this ca s e , but there are situations where it has 10 happened.
11 A Okay.
I would also lik e to make this avai1Crle 12 to the company.
13 0 What you do with your transcript after we s .3 14 it to you is your business.
15 A I just want to state that for the record. :
16 intend to do that.
17 0 Getting back to April 1981 time period, whe.. you 18 were assigned as EQ manager --
19 A Yes, sir.
20 0 -- how did you formulat e your section? or d. 3 21 you have any say in who would be < -king for you and v 22 would their responsibilities be?
23 A The section had already been established; al.
24 right?
25 0 And when you took over , what did it consis- f?
22862.0 3RT 6 1 A What do you mean "what did it consist of?" Are 2 you talking about p~rsonnel? Facilities? Or what?
3 0 Well, y- had two nuclear facilities, you had 4 TMI and you had Oyster Creek.
5 A Tha t 's correct.
6 0 How did ou cover those facilities with the EO 7 program with the pt:ple that you had?
8 A Well, the: was not th e start of the EQ ef forts.
9 The EQ ef fort had s tarted years before. It's back to 1978.
10 What I took over was a continuation and completion of 11 the EO ef fo. .
There already had been files es tabli sh ed ,
12 personnel had been assigned to the two facilitius, th e 13 program was --
14 0 Then wha- program did you take over? Would ycu 15 describe it to me?
16 A The completion of the environmental 17 qualification. Th e environmental qualification was no*
18 complete for either facility at that time.
19 O So, what did that program look like when you 20 took it over in April? How many people did you have 21 working?
22 A How many people? There were two people, at that 23 time in April, two people full time.
24 0 Would y: identify the= and what their 25 responsibiliti es w "e?
~22862.0 7 BRT 1 A Yes. We had a responsible engineer for TMI.
2 His name was Paul Boucher, and a responsib;e engineer for 3 Oyc t er Cr eek . At that time -- it w- Scot- I;moniz.
4 0 What were your responsibilities as the EQ 5 supervisor?
6 A To complete the environmer.? al quali fication 7 pr ogram for those two facilities.
8 Q What did that entail, to your understanding?
9 A As I said, submittals had been made for both 10 facilities, and we indicated tha t there were it ems for 11 which the environmental qualification had not been 12 completed.
13 We had'also indicated in the submittals whether we 14 planned to try and qualify the existing corp:.ents or 15 whether we intended to replace th em .
16 0 In other words, to qualify the corponents 17 important to saf ety within the guidelines cf IE Bulletin 18 79-01 3, 10 CFR 50.49 and --
19 A Wait a minute. You are going toc fast. Okay?
20 At that time it was, as f ar as TMI was con =erned, it 21 was IE Bulletin 79-01 B. As f ar as Oyst er Creek was 22 concerned it was a SEP topic; 79-01 5 did not apply to 23 oyster Creek at that time. It didn't apply to any SEP 24 plant.
25 2 : tried to restric- my ques
- ions : day t: TMI-1?
l
22862.0 2 BRT 1 A Well, you asked about both f6cilities. If you f 2 vant to talk strictly abon TMI-1, f u. e .
3 0 From 1981, Apr '. when you - -k s over as E2 4 manager, up until -- well, how long did you remain in a 5 position as EO rsnager? h' hen were ycu taken out of that 6 position or when did you leave that position?
7 A July of '84.
5 0 Between April 'c1 and July i4, did you have any l
9 other responsibilities other than EQ?
l 10 A No.
11 0 What I would like to show you is two GPU Nuclear 12 letters to the Of fice of Nuclear Reactor Regulation. The 13 first letter is dated May 20, 1983, a..5 the GPUN lett er 7 14 control number is 5211-82-157. With '.e exception of the 15 handwritten notes in some of the margins and some of the 16 markings, I would like you to take a look at it and ask 17 you if you recognize the document?
18 A I recognize it.
l 19 0 The second document is dated February 10, 1984.
20 It's also a letter from GrUN to the of fice of Nuclear l
2~. Reactor Regulation, the G: UN control nu ser is 5211-84-2038, 22 I would like you to take a look at tht letter and I ask 23 you if you recognize it.
24 A Who did you sa; might objen o the transcript 25 being given to us?,
22862.0 9 BRT 1 O I'm not saying anybody may object.
2 A Who did you say might?
3 O As an example I gave the Just ice Department .
4 A Justice Department. Okay. I forgot to make a 5 note of that.
6 Yes, I recognite this document .
7 O Do you know whc, dra f ted both of these document s?
8 A No. I don't know who cra f t ed both of th em. I 9 know who drafted one of them.
10 0 Which one?
11 A February 10, 1984 document.
12 O Who draf t ed that document?
13 A As f ar a s I k now, Roy Harding.
14 O Did you have a conversation with Mr. Harding 15 regarding this February 10 document?
16 A Y es .
17 O What was -- what did that conversation entail?
18 What input was he asking you for?
19 A Many and various.
20 Q would you tell us, plet. e, what he was asking 21 you to input?
22 A What the status was with respect to answering 23 the TER questions.
24 0 What did you inform him? Did you inform him 25 that the TER deficiencies had been answered?
22562.0 3 ERT 1 A We answer ed -- my respons e to him was on a 2 component-by-component basis. We tried to group then nto 3
sect i cns ; our responses group e.: into sections accord;..; to 4 the way the deficiencies are numbered in the TER. But 5 there really is no blanket answer.
6 O The last s entence in this February 10 letter 7 states: "It is GPUN's position that TMI-l is currently in 8 compliance with the environmental qualification rule 10 9 CFR 50.49 as applicable in TMI-1.
10 Did you provide input to Mr. Harding, where he would 11 get that impression and draft that information? Or did 12 you specifically tell him that you were in compliance with 13 10 CFR 50-49?
14 A could you rep ea t the first part of that qu es t i on 15 about Mr. Harding's impressions?
16 (The report er read the record as r equ es t ed . )
17 THE WITNESS: I will answer the question. I 18 can't answer for Mr. Harding's impressions; okay? Tha t 's 19 subjective. I can't answer that question.
20 I teld him that as far as environmental qualification 21 engineering was concerned, the information we had, we were 22 in compliance, from an engineering standpoint; yes.
23 BY MR. MATAKAS:
24 Q Then it was your intention to -- well, let ne 25 ask :.a: a different way.
1 l
22862.0 11 BRT 1
l 1 At the time, did you agree with this stat ement, "It is 2 GPU's views that TMI is in complian t with" -- et cet era .
3 Did you agree with that part of it?
4 A Yes.
5 o Did you provide this input o Mr. Maus --
6 A Wait a minute. I am Mr. Ma us.
7 0 -- with Mr. Boucher, wh en y ; wer e talking with 8 Mr. Harding about the EQ program?
9 A Did I discuss the conclusien?
10 0 Did you discuss -- yes, your conclusions? Was 11 Mr. Boucher present in th es e conversa-ions with 12 Mr. Harding?
13 A About my conclusion?
, 14 0 About the EQ program, when you discuss ed l'5 whatever you discuss ed with Mr. Harding?
16 A Y es . On many instances .
17 Q Okay. A ft er the February 10 letter was dra f t ed ,
18 did you have an opportunity to review it?
19 A Yes.
20 Q Did you see any problems wi '- th e let t er ?
21 A There were sone typos in it ;t no ma jor 22 problems; no.
23 0 on the May 20, 1983 letter, do you know why 24 this --
25 A Just a minute, please. C'<. r. .
k
22562.0 12 D?:
1 O on the May 20, 198 3 let ter, do you know what 2 that was i:: response to?
3 A :h. I hones-ly -- I still don't know.
4 Q Are you familiar with 10 CFR 50.497 5 A Y es .
6 MR. MATAKAS: Why don ' t we tak e about a couple 7 of minutes break here.
8 s ascussion cff the record.)
9 MR. MATAKAS: During that break I showed 10 Mr. Maus a copy of 10 CFR 50.49, specifically section G.
11 BY MR. MATAKAS:
12 O Mr. Maus, after reviewing that section, de you 13 recall that the May 2D, 1983 response was in resp:nse to 14 10 CFR 50 . 49 ?
15 A Would you be a little more explicit, plea s e?
16 Q Well, the first paragraph of the May 20, 1983 17 letter says, "In accordance with 10 CFR 50.49(g) and NRC 18 letter dated March, 1983, GPUN is supplying the f:llowing 19 information to identify electrical equipment import ant to 20 saf ety within the scope of section 50.49(g) that is 21 already qual fied, and to submit schedules for 22 environmental qualification or replacement of the 23 remaining equipment that is important to safety as defined 24 in 10 CFR 5: .49. "
25 A T:ay. We have talked about 10 CFR 50.49
22862.0 13 BRT 1 paragraph G. We have not discuss ed this NRC letter. I 2 don't know what this letter is.
3 0 Okay. I don't kn . what the let t er is ei th er .
4 A Fine. Then how --
5 O Do you know that this response -- it is very 6 clear in 10 CFR 50.49(g) that it says you have to respond 7 by May 20, 19837 8 A Okay.
9 O Do you know that this was at least in part a 10 response to 10 CFR 50.49(g)?
11 A Okay. Yes. I would say it is.
12 O Did you know that -- have you ever reviewed this 13 document?
14 A No.
15 O Were you ever ask ed for input into it, that you 16 recall?
17 A Not that I'm aware of.
18 O And you never reviewed it subsequent to the 19 document going out?
20 A Subs equ ent to it going out?
21 0 That's correct. Within the immediate time 22 period of May 20, '283?
23 A No.
24 MR. MATAF. AS : Let 's take another couple of 25 minutes break.
22862.0 14 BRT 1 (Dir.cussion off the record.)
2 BY MR. MATAXAS:
3 0 I would like t c. o back te -h e Fer rua ry 10 4 letter.
5 A Sure.
6 O Do you know wha-
- hat was :n rescons e to?
Why 7 that letter was drafted?
8 A It was in respor.ae to the SER of December 10, 9 1982 for TMI.
10 0 Okay. I would like to show you another document, 11 it's a March 1, 1983 letter, GPUN to the Of fice of nuclear 12 Regulatory Regulation -- Nuclear Reactor segulation. The 13 letter number is 5211-83-254.
14 I would like you to tak e a quick look at thi s letter 15 and I ask you if you recognize it? ,
16 A Yes, I do.
17 Q Did you have any input or did you make any 18 requests or r equ es t to have this ' 1etter dra f ted? If you 19 would, just generally, wou'd you just give me Obe 20 background, what you know about this letter?
21 A When we received -he SER and the TER, we went 22 through every TER item and = tried to understand exactly 23 what the deficiencies were and we could not do it.
24 Some of the categories, for instan:e, used i= the TER 25 could be multi, ele defici e.- -i es and ~ ey were .ot
22862.0 15 BRT I identified as to which of the ? xact deficiencies they were 2 talking about. So, we could not u nd e r s t a r. enough of the 3 comment s in the TER on our s. n so we requa ed a meeting 4 with the NRC to get additional information on exactly what 5 was meant on th ese deficiencies .
6 O Did you have that meeting?
7 A No, sir.
8 O Did you have a meeting with the ..nC on October 5, 9 19837 10 A I ' m not sure about th e da t e . I know we had a 11 meeting with them. I don't recall the exact date, but we 12 did have a meeting.
13 0 Was it approximately October 5?
14 A Yes, sure.
15 Q Did you discuss the TER deficiencies?
16 A Y es .
17 Q Did you air your questions?
18 A Yes.
19 Q Were your questions answer ed?
20 A Yes.
21 O After this meeting, what specifi: ctions did 22 you take to assure that the TER deficiencis that were 23 identified were corrected? I'm talking ab ut between the 24 October 5th meeting -- well, let's go all r.e way back to 25 December 10, 1992, wh er the SER/TER was !- ed. You ha$
22862.0 16 BRT 1 the meeting on -- in october or thereabout s , 1983.
2 A Yes.
3 o A r.5 th en you had another NR insp ect ion in March 4 20-21, 1984.
5 Between that time what actions did you take to assure 6 that each of these TER deficiencies were ccrrected?
7 A We continued to get additional 1. format ion on 8 items that were not qualified, from vendors. We got later 9 test reports, whatever information we needed to complete 10 the qualification. We made internal calculations, such as 11 Arrhenius calculations. And the results of this work were 12 reflected by revising the SCEW sheets and the master list 13 and resubmit ting these to the NRC.
14 0 Did you personally go over ea '.. co=ponent file 15 to assure that the TER deficiencies were corrected?
16 A No. "I" did not.
17 0 who did you assign that responsibility to?
18 A The lead engineer; Mr. Paul Boucher, basically.
19 However, I did review a number of them. And also a number 20 of these were reviewed by Mr. Harding, in I,icensing. But i
21 I couldn't swea r that I went through every one.
l 22 MR. LA GRANGE: Gerry, you said the SCllW sheets I
( 23 were resubmitt ed to the NRC. Knen did that occur; do you l
l l 24 recall?
25 THE ;;:TNESS: In wha
- tire frare? Whar *ime
22862.0 17 BRT 1 period are you talking about?
2 BY MR. LA G RANGE :
3 O That.'s what I was int erest ed i r. . You said the 4 SCEW sheets had been revised and the master list had been 5 updated and the SCEW sheets were resubmit t ed to the NRC.
6 A What time period are you ta' king about, Bob?
7 Q W el l , th e same time period you were just talking 8 about.
9 A Okay. All right. You are right. I guess we 10 didn't have any -- that 's when you told us we didn't have 11 to submit any more: right?
12 O That was the SCEW sheet modification you were 13 talking ab:ut? So, actually, they never did get suomitted:
14 right?
15 A You are right. That's right. After that time 16 period, that's right.
17 Before that time period we had resubmi* t ed tb am.
18 Q Yes.
19 A Okay. We are just talking about the time period 20 between --
21 Q Between the TER and --
22 A Oh, no. The TER we submitted many times or a 23 couple of times after we received the TER.
24 BY MR. LA G RANGE :
25 0 Aft er you submit ted the TER fou submitted new
22862.0 is BRT 1 SCEW sheet s ?
j 2 A Yes, revise. SCEW sheets. Yes. les. A r.i a 3 mas *rr list.
4 O So , be tw eer. D ec emb e r 10 , '82, subsequent :: that 5 you .ade new submitta'.s of SCEW sheets?
6 A And master ;;sts; yes.
7 ; ; don't re:'_11 ever se'ing e them.
8 . Well, I'm _.e if you guys wan: ..e dates ::
9 those letters you could get then from Licensing.
10 BY MR. MATA~GS :
11 0 Would you have submitt ed th em te licensir.; for 12 submittal to --
13 A Yes. Lic er.s ing nak es all our submittals.
14 BY MR. LA 3?ANGE:
15 0 Do you know for a fact that licensing sen- th em 16 to th e NRC7 17 A Absolutely.
18 ; were they b;; packages of a lot Of revised 3CIW 19 sheets, do you recall? Or was it one or twe SCEW sheets?
20 A Big packages . A lot of th em, likt NU REG 70 .- ~ .
21 We ht a big submitta'. :n that. Did you ev . s ee thc s . :
22 Q Onc e th e ru . came out we were basically 23 interested in the 197 equipment. Instead of calling it 24 tTURE 3 --
25 A No, I'm jur- trying to think of *.ings th!-
1 22863 0 19 i BRT l
1 might help you recall if you had seen them or not. l 2 BY MR. MATARAS:
3 : Do you rera:1 that at the mee ing in October 4 1983 or thereabouts --
5 A Whatever. Sure.
6 0 --
that you were asked to respond once again to 7 the TER deficiencies?
e A Yes.
9 Q Do you correlate that with the February 10 10 submittal? .
11 A Yes. Y es .
12 0 okay.
13 A Yes. That was the int ent .
14 0 So, basically, then, you were relying on the 15 limit ed inspection that you did of the documentation 16 within the files, input from Mr. Boucher to you regarding 17 what he had been doing with the files, and Mr. Harding 18 himself had looked at some of the files?
19 A I did more than a limited inspection. I just 20 didn't do 100 percent on everything; okay? "Limit ed " is
- 1 nc- a good characterization of my involvement. It was
.2 much more than limited: okay? But it wast.'t 100 percent.
23 0 But basically that was the basis for this 24 February 10 letter ar.i the feeling that you were ir.
25 cc.mpliance with 10 CFR 50.497
22862.0 20 ERT 1 A That's correct. That's right.
2 O Who was your supervisor during the '83 '84 time 3 period?
4 A My direct supervisor is Richard Chisholm.
5 0 And he reported to Mr. Cronenberger who 6 ultimately reported to Mr. Wilson?
7 A That's correct.
8 0 What active participation did Mr. Chisholm take 9 in the EQ program between 1981 -- between the time period 10 that you were involved in EQ?
11 A He had the overall responsibility that the 12 department met its goals, what th ey were suppos ed to do; 13 that we had adequate resources.
14 O Did you conf er regularly with him on the status 15 of the environmental qualification program?
16 A Yes.
17 0 Could you give us some idea of what that 18 entailed and what those discussions entailed?
19 A Primarily, what we discussed with him were the 20 problem areas where we had problems with equipment and 21 what the course of action might be.
22 O Did you have any such conversations with 23 Mr. Cronenberger?
24 A very seldom; but, yes.
25 O Do you recall a meeting in the early part of 1
l l
l
22862.0 21 BRT '
1 1984, I believe OA also attended the meeting, where Mr. --
2 A A meeting where, Rich?
3 0 Mr. Alatary, from QA, took the notes and the 4 physical location of the meeting I'm act sure -
5 A But it was a GPU meeting? It wasn't a meeting 6 with the staff or anything like that?
7 Q Right. It was more of a QA/ Tech Punctions-type 8 meeting?
9 A okay.
10 Q And Mr. chisholm made a commemmt about the 11 possibility, raised the possibility of hiring consultasts 1 *2 to assist in the EQ program. Mr. chisholm made that 13 statement - I'm sorry. I don't remember what I said.
14 Do you recall any such meeting? If you don't recall -
15 we are on the record.
16 A I ens't understanut yamer apuesthem.
17 Q That's fine. We don't have to go off the record 18 for that.
19 A Okay. j 20 0 I'll repeat the question.
21 A Just the beginning part of the aguestion.
l 22 O Do you recall attending a meeting -- let's 23 forget who-all attended -
i 24 A I do not recall attending such a meeting.
25 0 -- where Mr. chisholm made that statement?
- 1 I
22862.0 22 BRT 1 A Yes . However, it is possible that.I was at that
! 2 meeting; all right? But, in all honesty, I don't recall 3 attending that meeting.
4 Q Did Etr. Boucher ever bring to your attention 5 that he thoogtit the 30 %, or his function la EQ was more 6 than 'ae could handle and he needed help?
7 A Yes .
8 Q Bow of ten did he bring that to your attention?
9 A Pariadiently.
1D Q Detween the tiano you were manager of EQ7 11 A Yes .
12 Q Did you personally feel that he needed help?
13 A Yes .
14 Q Did you inform anybody of that fact?
13 A Yes.
IS W h dEd 34mm lad m e r 17 A Mr. thishots.
13 Q And how often did you inform him of that feeling?
19 A occasionally.
20 0 From -
21 A Well, when we reviewed schedule commitments and 22 things like thatt that we needed more help.
23 Q Did you feel that Mr. Boucher understood what 24 was needed for qualification, as far as documentation went, 25 that was in the files?
22862.0 23 BRT 1 A Yes.
I 2 O At what point, if any, do you feel that 3 management became involved in EQ program, as far as 4 yetting the assistance and actively taking an active look 5 at what the program was all about? i 6 A That 's more tha n one question. Do you want to 7 split th em? I'll answer each one separately.
8 Q At what point, if any, did you feel that 9 management took an active role in the EQ program?
10 A From the beginning of the EQ program.
11 Q And what did that participation consist of?
12 A I was not involved at EQ at that time. How ev er ,
13 initially management made a decision to go to an outside 14 contractor for EQ at TNI. That's the way it started.
15 Q But I'm talking about when you were EQ =anager.
15 m metive part.icipation did managestent take in the EQ 17 program, during the time that you va; w 4Q msnager?
18 A They periodically reviewo
- ua tatus of the 19 program. They made sure that we hat prope meadures in 20 place for the program.
21 Q At what point did they start s. m *- you some 22 assistance in the program?
23 A Do you mean additional assistance? Is that what 24 you mean?
25 O Other than Mr. Boucher and Mr. Banua?
I I
i 22862.0 24 BRT 1 A Whht was done during that period of time, if we 2 had an immediate need, an engineer would be assigned from ,
1 3 another department to assist us.
4 Q Then are you saying that when Mr. Boucher 5 requested assistanca, and you relayed that requ est to 6 Mr. Chisholm, that you were given assistance? l 7 A No. On occasion; yes.
8 0 Not always? Is that what you are saying?
9 A That's a better choice. Not always.
10 0 Were you asking Mr. chisholm for permanent help?
11 Did you ever?
12 A Yes.
13 0 Were you ever giv n permanent help?
14 A No.
15 Q What I would like to show you is an interoffice 16 memorandum, GPU Nuclear interof fice memorandum dated June 17 25, 1981, QA/4161, to Mr. R.F. Wilson from Mr. Stromberg.
18 And, attached to that is a QA audit report number 19 0 -TMI-81 -0 2 . I would like you to take a look at it.
20 Again, ignore any of the handwritten notes, but I ask you 21 if you have ever seen that audit before, and the cover 22 letter.
23 A Y es . I have seen these documents before.
24 0 I would like you to take a look at page 10 of 10, 25 und er "Reco=menda tions . " tiumber 1 says : "Document ed
22062.0 25 BRT 1 direction be generated in order
- assure meeting the 2 requirements of the bulletin to alude organisations, 3 departments, sections, and indi. als, (headquar ers and 4 site personnel). This should ine.ude interface 5 responsibilities and define the cporate position on the 6 bulletin."
7 Do you recall that pa rticula r commendation?
8 A Yes.
9 0 What was done about thc- recommenda tion?
10 A A procedure was generat ed to make sure that we 11 complied with it.
12 O What procedure was tha-13 A EP-31. '
14 0 Was that proc edu r e ace ed by quality assurance?
15 A Yes.
16 Q I would lik e you also t o tak e a look at finding 17 number 1, 1 of 11. It says: "N: evidence of managenent 18 direction to correlate the effor- of intersectional 19 effort in establishing the master ist and qualification 20 documentation file."
21 was this finding ever resolve.
22 A I'm not sure. I don't c4cw what th e cu rr e r.: ,
23 status is on that finding.
24 0 To your knowledge you not know if it was e.er 25 resolved,or not? Was it ever re ' ved before you depa.- ed
22862.0 26 BRT 1 the EQ section?
4 2 A I don't know. I could find out but I do.. ' t know.
3 Q Well, let me show you a r e.*is ed r esponse to 4 audit 81-02. It's dated August 21, 1981. The number on 5 it is EP&I 81/0176. Audit finding 1 of 11.
6 Do you recognize that document?
7 A Yes.
3 Q What is the corre:tive ac::en on there?
9 A You want me to read what this says? -
10 Q Is this your signature dow: at the bottom as th e --
11 A Yes.
12 0 Under "Corrective Action"?
13 A Yes.
14 Q It again references -- is that engineeri ng 15 procedure 0-31?
16 A 31 -- y e s . It also mentions that this is to 17 become a corporate procedure. Yes.
18 O Did you personally take th;s corrective action 19 to Mr. Magitz for sign of f ? How did does that work?
20 A No , I did not pers onally take that to Mr. Magitz.
21 That would have beer, given :: Mr. Magitz by Mr. Stromberg, 22 who was his supervisor.
23 Q Did you ever have '.neetings with quality 24 assurance during the time period tha: you were EQ manager 25 regarding the corrective action on findings 1 through 11?
22062.0.
37;T 27 1 A Y es .
2 O Who attended those meetings from QA? I realize 3 it's going to be different people attended differer.t 4
meetings, but essentially what is the'same core of people?
5 A No.
6 0 It wasn't essentially the same core?
7 A Essentially it was not the same core of people.
B Q Did you have meet i:.;s where Mr. Guimond at t ended?
9 A Yes.
10 0 Was Mr. Guimond the team leader for aud:t 81-027 11 A Yes.
12 O Did he voice his dissatisfaction with the 13 corrective action of audit number l?
14 A Yes.
15 O Did he voice his dissatisfaction with' the 16 corrective action on any of the other audits?
17 A Yes.
18 0 Were you aware of any documented memorandc=s 19 that Mr. Guimond may have sent through his section.
20 voicing such dissatisfaction?
21 A I'd say "yes."
22 0 Why were.'t his recommendations followed?
23 A Because we didn't believe they were correct or 24 we believed we had followed -hem.
25 0 What I would like to show you is another
._. __ _ _ - - - _ _ _ . . _ _ _ _ _ . _ - = _ . . - _ _ - . - - .~ . . _ . . . . . . - . - . _ .
22862.0 28 BRT
- 1 memorandum. If you would excuse this first page. This is 2 et.a t I was sent, so ; got a cl ean page -- this is page 1.
I 3 A Okay.
4 O But it's ,ted April 4, 1984. The number on it 5 is PDA/84-107. It 's to Mr. St romberg frora Mr. Guimond.
6 I would like you to take a look at that.
l 7 A Okay.
8 ; Do you re ;;..1:e this memorandum?
9 A Yes.
i 10 Q Just for the record, Mr. Guimond states in his
! 11 memorandum that findings 1, 3, 5a, 6a, 10, 11.4, 11.8, and g
- 12 11.14 are still considered open.
13 What I would like to ask is why had it taken so long i
14 for Mr. Guimond 's findings to be closed? They were still 1 15 not closed as of April 4, 1984, and they were id enti fi ed ,
1
! 16 back in April - let me see, March and April of 1981. t
- l 17 A The overall answer to that question is: I ;
i i
18 honestly don't know.
I
)
' \
19 I 2o 21 22 l 1
- i i 23 i
! 24 1
25
. - - .n - - . ._
22862.0 29 BRT 1 A All right. So it wras after that. Se, then my 2 original answer stancs: ! really don't know /.3 i* t o ol-3 this long. '
4 0 You mentioned earlier that you didn't agree with 5 some of his findings. Wasn't he stating all along that 6 the documentation was not adequate and there was no 7 ma na g ement direction during these meetings that you had? l B A That was his ep:. ion.
9 0 You didn't share that opinion?
10 A Absolut ely not .
11 Q During the October 5th meeting that you had with 12 th e NRC , October 5, 1983 --
13 A Yes?
14 0 -- didn't they tell you that your d:cumentation 15 was lacking ?
16
- I ' m not sur e wh eth er th ey said that or not. I 17 don't recall.
l l 18 O Prior to the October 5th meeting he indicated, 19 at least in your March 1st letter, March 1, 1983, that you l
1 20 didn't understand what the TER wat requ es ting?
1 21 A Some of the TERs. Some of it.
22 Q Some of what the TER requests. Was that in the 23 area of the documentation?
l 24 A Yes. That was One area.
25
22862.0 3 *,
BRT 1 BY MR. LA GRANGE:
, 2 O As a result of the dise. ions that took place 3 during the October '83 meeting wi- :s, did you then 4
realize that additional documentat;-n would be necessary?
5 or that some equipment would have - be replaced?
6 A At that meeting?
7 Q As a result of the discu ;ons that took place 3 at that meeting?
9 A No.
10 could we take a creak? I heard -he coffee bell.
11 (Discussion off the reco 3.)
12 MR. MATAKAS : When we fir . sh ed , Bob, you were 13 talking to Mr. Maus and I believe ; wanted to finish 14 some questions?
15 BY MR. LA GRANGE:
16 o Y es . I ask ed a f es minu* es ago whether, ba s ed 17 on the discussions that took place at your meeting with us la on October 5, 1983, you felt that
..f additional 19 documentation was needed or that a: equipment would have 20 to be replaced to mak e sure dh e eq - ent was qualified.
21 I think you said "no."
22 A I can't recall that we -- .s -- ba s ed on tha t 23 meeting, that anything was apparent.
24 0 Was any work done to the '; es? Or did the 25 qualification status of any of the aquipment change?
. cw. . . . -
31 BRT 1 E- ween the October 5, 1983 meeting and the March, I 2 b*.lieve it was March 8, 1984 meeting?
(. 3 A Yes. The answer to both -- both things were 4 e: yet.
5 0 Why was work done on the files in between that 6 p.riod of time?
7 A Because we had not complet ed the qualification 4
8 or all items.
9 O But the discussions that took plane at the 10 october meeting, October '83 meeting, had nothing ta do 11 with the additional work that was done on the files at 12 that time?
13 A No. I wouldn't say that. What we got at the 14 meeting was guidance on how to proceed on certain items.
15 U. i that certainly would affect th e files -- did af f ect 16 the files.
17 0 I thought you said that it was your opinion that 18 n: additional documentation was needed as a result of the 19 0: ober meeting?
20 A At that meeting; directly at that meeting. You 21 k- .
there was apparent lack that, you know, we needed .
22 a. .-ional documentation for this item.
23 I don't recall that anything specific was said.
24 For example, I don't recall that somebody said: You 25 d:n't have the latest Limitorque report. That's what I
ev- m m _ _
BRT-32 1
thought, you were asking - es t type of question. Maybe :
2 misunderstood your questi:n.
I 3 0 W el l , maybe I s- aid rephrase it.
4 A Okay.
5 0 When you came back from the October 1983 meeting, 6 ased on what you had -- :. e guidance you were given
', 7 during the October '83 me. ing, did you believe that
- B additional documentation s necessary to show the 9 , equipment was qualified?'
i 10 A I'd say yes. Yes.
I 11 KR. LA GRANGE: Okay.
12 BY MR. KATAKAS:
13 0 Just to clarify -hat a litt le bit more --
14 A Surely.
15 0 -- what I have '.sre, I received this from 16 Mr. Harding. It was in the file regarding the the meeting 17 that you had with the NRC on October 5 th. I'll just read 18 from it, then I'll show it to you.
19 A Sure.
20 0 It was identified to me as your notes that had 21 been retyped and it appea rs to be your signature, the 22 signature that says "F.G. a s " on th e bot tom?
23 A Right.
24 0 It says, "Based n our meeting we now know how 25 to respond to closecut deficiencies. These deficiencies
33 BRT 1 are in regar. o documentation and t est:ng and should not 2 result in any quipment changcs." I fon't know if that 3
refreshes you. memory -- go ahead and take a look at the 4 document.
5 A Okay. I recognize this.
6 O Jus- basically what you told Mr. LaGrange --
7 A : p. ss ! mi sunderstood Mr. LaGrange's question.
8 But th er e v er Sther occasions when we were told that we 9 really don ' t think you have the lat est documentation on 10 this item: or we were made aware of this by things like IE 11 bulletins. There is additional documentation.
12 Also, in the TER, Franklin Research sade reference to 13 documentatier
- hat we did not have; that was generic 14 documentation that they had.
15 So, we kne. there was additional do:cmentation 16 available.
17 BY MR. LA GRANGE:
18 o Did that letter that was just shown to you, that 19 you signed , wi - all that work completed prior to the 20 February 10, 1934 letter being drafted?
21 A To - best of our knowledge. To the best of 22 our knowledge es. Yes.
23 (Dit assion off the record.)
24 BY ";. LA GRANGE:
25 0 As a result of the second meeting we had with
22862o0 BRT 34 1 you, I believe it was March 8, 1984, did you as a result i
2 of discussions that took place during that meet i..; --
did 3
you feel after that meeting that all the document ation 4
necessary to establish qualification of the equipnent was 5 currently in the files at that time?
6 A Y es .
7 0 You said oreviously you had not known about the 3
May 20, 1983 let er, antil sometime after it had been sent 9 out?
10 A Y es .
11 Q Do you know who dra f t ed that letter?
12 A I do not know for sure.
13 o You. were net, obviously, asked to concur in that 14 letter?
15 A That 's corr ect. '
16 o There is a statement in that letter, something 17 to the effect that GPC 's - .T 'll quot e f rom the l ett er :
18 "Additional information we submitted in our lett ers dat ed 19 May 3, 1982, May 16, 1983, support our conclusions that 20 the components list ed are qualified in accordance with the 21 DOR guidelines dated November 1979. "
22 That was a statement in the May 20, 1983 letter.
23 Would you have concurred on that statement?
24 A Yes.
25 0 In your February 10, 1984 let t er, there is
ddmd .4 35 BRT 1 eg; pment identified as needing to be replaced. I think 2 there's at least three items, three places in that letter 3 where equipment will be replaced by, I believe, June 1984.
4 1 can point them out to you.
5 on page 2 of the attachment to the February 10, 1984 6 letter it is stated that "ASCO solenoid valves will be 7 replaced with qualified,ASOO solenoids by June 1984."
8 :.. page 3 of the attachment to the letter, with regard 9 to static o ring pressure switch, it states "These 10 switches will be replaced prior to June 1984 by qualified 11 pressure switches. "
12 On page 6 of the attachment to the February 10 let t er ,
13 "Sq;ar e D switches . The MUPS480 vill be replaced by 14 qua* ified pressure switches by June 1984. "
15 Given that this letter was submitted af ter the May 20, 16 1983 letter, in which it is stat ed that th e equipment is 17 qualified in accordance with the DOR guidelines, does it 18 see: consistent to you that a later letter identifies 19 certain items of equipment as requiring replacement with 20 qualified equipment?
21 A Yes.
22 Q Could you expand on that?
23 A This happens because we find out, when we take a 24 closer look at some of the data involved with the 25 qualification, ve were not satis fied that the t
f7662.0 36 BRT 1 documentation proved they were qualified.
2 O You have the statement in the May 20, 1993 3 let ter that clearly said the equipme nt was quahfied in 4 accordance wits. the DDR guidelines?
5 A That's correct. The documentation we had at 6 that time, we believed that it d emo ns t ra t ed th ey w er e 7 qualified.
8 0 You ere saying you went ba:k again ar.f lockei -
9 the documentation and changed your mind later oc?
l l 10 A I would say we went back and relooked at th e l 11 documentation, or got additional documentation and based 12 on that, we may have come to that conclusion.
13 0 would not you have had to have had the 14 documentation prior to May 20, 1983, that showed th ey wer s I 15 qualified?
l 16 A Yes.
17 Another thing that may have happened is that we may 18 have taken another look as to exactly how long they wer e 19 required to function to mi-igate design basis event, and 20 come to a different conclusion.
21 One area where this happened was generically concerned 22 with pos*.-accident operability, we had some guidance fro.?
23 the Staff on h: to look at post-accident op erability, and 24 we may have changed our minds based on that.
25 0 I don't think that these three items voeld be --
i __ ---- - -
22862.0 37 BRT 1 A It may not have been. I'm talki generically; 2 okay?
3 0 The point I ' m trying to mak e is: dould not all 4 this review and evaluation by GPU have has. s have been 5 complet ed by May 20, 1983, in order to mak e
- hat statement?
6 A Yes.
7 0 I think essentially you are say. it wasn't?
8 A I ar not saying that. I'm say; Sat somebody 1
9 took another look at it, and specifically w;at the reasons j 10 were on these three items, I can't tell yo that by m emory .
11 Q Does it seem reasonable that th e response to 10 12 CFR 50.49 dated May 20, 1983, would have b. n issued 13 without your concurrence as manager of th. :?
14 A I can't answer that question. E .ause what's 15 reasonable to you may not be reasonable t: a. Do you 16 want to rephrase the question, I ' ll answ er t.
17 BY MR. MATAKAS:
18 Q Let me ask one thing. Are you i : liar with 19 licensing procedure 002?
20 A Yes.
21 O Wou' - that call for you to conce at least to 22 have input into a letter such as this?
23 A Somebody would have to.
24 0 What do you mean "somebody"?
25 A Somebody would have to -- somebe' would have to
4dGB6.v 30 BRT 1 concur.
2 Q Someone where? In the EQ section? What I'm i'
3 asking --
4 A Someshere in the chain for the EQ section.
5 Q And you are talking about from Cronenberger down?
6 A You got it.
7 BY MR. LA GRANGE:
8 O It's still your opinion that the stat ement t'.at 9 th e equipment was qualified in accordance with the DOR 10 guidelines was a valid statement?
11 A with what we knew at that time; yes.
12 Q Even in light of the fact that a later submittal 13 identified equipment as requiring replacement with 14 qualified equipment?
15 A Yes.
16 Q And mothing occurred at the March 8, 1984 17 meeting, to change your mind?
18 A on these three items?
19 Q on the status of EQ in general.
20 A Nothing occurred at that meeting that --
okay --
21 that changed -- that would have changed my mind. However, 22 as a result of that meeting we took a c1:=er icok at th e 1
23 documentation and af ter that we were awar s of some 24 deficiencies in the documentation. As a result of that 25 meeting, yes, we changed documentation.
._ _ _ _ g BRT 1 O As a result of the october 1983 meet ing, based 2 on .the guidance given to you at that time with regard to I
3 resolving the TER deficiencies, would you still be able to 4 support the May 20, 1983 statement that the equipme.. was 5 qualified? By that I mean, that you had all the 6 documentation necessary to show it was qualified?
7 BY MR. MATAKAS:
8 0 He's talking about in retrospect. He's r.:t 9 trying to trap you. In retrospect , bas ed on what you 10 learned from the October 5th meeting, what was expect ed of 11 you.
12 A You only have limited resources; okay? You car 13 only go back so far. And =y answers would be that, you ;
14 know: My beliefs at the october 5th meeting, bas ed upon 15 the information they had then, were correct. The 16 statements we made were correct. As also were the 17 statements made in the subs equ ent letter.
18 It's the information we had at that time. What we knew 19 about it at that time. You can always go back and take a 20 second look 21 BY MR. LA GRANGE:
22 O I understand. But in 7/etrospect, ba s ed on the 23 guidance you were given in the October 5 meeting and the 24 March meeting, could you still support the statemer.: made 25 in the May 20, 1983 letter, that the equipment was
22862.0 40 BRT 1 quali fi ed in accordance with the DOR guidelines?
2 A Yes.
3 MR. Mk.' A); AS : Let me e.zh --
4 BY MR. MATAKAS:
5 0 I seem to remember, correct me if I'm wrong, 6 that you made a statement -- th er e wa s a tape-recorded 7 conversation, wasn't it? In March 8, 1954 meeting?
8 A I don' think so.
9 MR. LA GRANGE: The meeting was trans crib ed .
10 There was someone there taking minutes of the meeting.
11 THE WITliESSi There was?
12 MR. LA GRANGE: No, it was in Bethesda.
j 13 THE WIT:?ESS: Oh, B et h esda . Okay. All right.
14 BY MR. HATAKAS:
15 'O I seem to recall you making a statement 16 something to the effect that you had been audited and 17 internal audits made sure that --
18 A Y es . We had internal audits; yes.
19 Q Before, when I talked to you about audits, 20 specifically meetings that you htd throughout the period 21 that you were EO manager, with Mr . Guimond , that you 22 didn't agree with is findings?
23 A Some of them; sure.
24 0 Wasn't he telling you all along, in the '80 -- '91 25 audit ar.t throughout this time that he was not satisfied
22862.0' 41 Br<T 1 with the documentati:r.? He did not feel it was f 2 satisfactory?~
3 A I ' d say "yes . " He was telling us that.
4 O And you stated that "We did not agree with some 5 of his findings"? '
6 A Yes.
7 0 Was it your decision not to act on some Of the 8 oper. audit items?
9 A No.
30 0 Whose decision was that?
11 A I'm not aware that such a decision was made. I 12 think we responded t: every item. I don't know what the 13 current status is, whether they are all closed out.
14 0 Well, I ca.'t remember, did you mention that you 15 had observed this or you had seen this April 4, 1984 --
16 (Handing)?
17 A Yes. I had s e en thet r y es .
18 0 Okay. In that letter from Mr. Guimond dat ed 19 April 4, 1984, he str.res that the last corrective action 20 was received on 2/5/1982. And he states that findings 1, 21 3, Sa, 6a -- et cetera. I have already read them --
22 remain open.
23 Why weren't those acted upon?
24 A I can't anrwer that question. Th e q u es t i:r.
25 really is: Why were they still open? Not why th ey i
22362.0 42 3T.7 1 weren't acted upon. They were acted upon. They were 2 still open.
3 O During these meet.ings throughout this ti.- :s 4 far as findi ngs 1 and 3 I believe 3 has to do with 5 documentation. The r equir ement , NRC order dat ed 10 ' 3'80:
6 "order for modification of license concerning 7 environ = ental qualification of safety-related ele: :: 21 8 equipment, page 5 paragraph (b), states in part: _ .0 9 lat er tha n D ec emb er 1, 1980, complete and auditable 10 records must be available and maintained at a central 11 location. Therefore such records should be updated and 12 maintained current as equipment is replaced , further 13 t e s t ed , or otherwise further qualified.
14 "Finding, existing GPU procedures, engineering 15 standards and engineering procedures do not provide 16 appropriate guidance nor is there a program initiated to 17 complete the above r equ i r em ent s . "
18 Basically what he's talking about is documentata::.
19 And that is one of the audit items tha t remained oper 20 until at least \pril 4, 1984. I don't know if it has 'een 21 closed yet. A can look here. That is finding 3 of '.
22 and in 6/29/1984 it was closed out.
23 A Rich, I've told you three or four times, ! .on't 24 know why it took so long and I can't answer that q.t. ;on.
25 If you are asking in my opinion did it tak e mui- ?
2286200 43 BRT 1 long, the answer is: Yes. It did.
2 O Well, w.ien you were having these meetings with 3 QA, and they wer- telling you about these problems all 4 along, why weren't they acted upon is what I'm trying to 5 figure out. Did you take it upon yourself --
6 A As far as I know, whatever engineering inputs 7 were r eq uir ed , we r e generat ed.
6 Did I take 1: .pon myself? Yes. I even had a meetir.g 9 with the head of QA, Mr. Kazanas , about closing out these 10 open items. I initiated that meeting.
11 Q When did that take place?
12 A I believe it was early in 1984. I'm not 100 13 percent certain.
14 0 Was this af ter the UCS petition?
15 A I don't recall.
16 Q War e you dir ect ed to have tha t meeting?
17 A No. I insisted on a meeting because I felt 18 these open items were just open too long. There was no 19 reason for them to be open. They should have been closed 20 out.
21 Q Finding number 1 of 11 says, "No evidence of 22 manag ement direc .on." And the finding is acknowledged by 23 Mr. Cronenberger. I believe that's his signature.
24 A Yes.
25 Q Was th e re any discussior. with Mr. Cronenberger
B P.7 1
or Mr. Wilson or Mr. Chisholm regarding that pa rt icu la r 2 audit item?
3 A Discussions among whom?
4 Q With yourself and those individuals?
5 A Yes. Y es .
6 o Was there any discussion that that i t e= va s too 7 critical to management?
8 A Too critical? I don't quite u..d e rs tand what you 9 mean by that, Rich.
10 o Well, was this -- I noticed -- I don' t have th e )
i 11 dir ect response to audit items 1 through 11. They cannot 12 be found.
13 I have -- l et 's tak e a one-minute break.
14 (Discussion off the record.)
15 BY MR. MATAKAS: -
16 Q Before we went off the record we were talking 17 about audit finding number 1. Throughout these documents 18 regarding audit 81-02 I noticed that the original 19 findings, audit numbers 1, 3, and 11, were signed for by 20 Mr. Cronenberger and the remaining of the 11 findings were 21 acknowledged by yourself, Mr. Maus.
22 A That sounds -- that agrees with my recollection.
23 Yes. Okay.
24 O And I was asking you if there was any discussion 25 about audit number 1 being too critical on management.
22862.0 45 BRT 1 A Right.
2 O I noticed thct -- I was telling yoa before that 3 when I a t t empt ed to get Tech Funct ions ' rernonse to the 4 original audit it could not be located, however they gave i 5 me a memorandum dated June 25, 1981, QA/41-86, which, in 6 effect, reiterates the ini+ial responses of Tech Functions 7 regarding the audit findings. And I notice that in 6 reviewing this docu..e..?, QA/ 41-66, that f;:..ang number 1 9 is not addr es sed.
10 What I would like to ask you is: Do you have any 11 information as to why it was not addressed? Was it 12 addressed in the initial response back to quality 13 assurance? Or was there so.he agreement not to address it
, 14 at tha t time?
15 A I don't know why it is not addressed in this 16 document QA/48-16. I don't know of any agreement as to 17 how it was going to be disposed of, other than we would la generate a procedure for environmental qualification work.
19 O And that. was engineering procedure 0317 20 A That's correct.
21 O And, subs equ ent conversations with Mr. Guimond, 22 who was the audit team leader, he i;sagreed that that 23 satisfied the requiremer.: of the audit finding; is that 24 correct?
25 A Partially. !
2286200 46 BRT 1 0 What do you mean "partially"?
! 2 A It did not completely satisfy the aufit
? r equ i r ement - -he audi- findine.
4 Q Do you recall what part it did not satisfy and 5 what part it did satisfy?
6 A No. EP-31 has been through several revisions in order to get this satisfied and a lot of thts is o sub]ective: ;t's in the eyes of the revir.er, as to 9 exactly what the words mean.
10 0 We were talking a little bit before about the 11 April 4th letter from Mr. Guimond to Mr. Stromberg where 12 he states "The last propos ed directive action was dat ed 13 February 5, ' .982. " You menticned that you did contact 14 Mr. Ka:anas in early 1984, 15 A I believe it was early 1984. I ' m not --
16 0 We are still talking about an approximate 17 two-year time period, where I'm trying to determine what
- 8 was done to c rrect thes e deficiencies, spectf
- : ally audit 19 deficiencies 1 and 3, which remained open as of April 4, 20 19847 21 A Well, specifically with regard to 1 a procedure 2: was written, .ssued, revised, commented on, implemented.
23 I would say tr. regard t.o finding number 1. Mr. Guimond did 24 not fe+1 the the procedure answered this finding 100
.5 percent, i
22862.0 47 BRT 1 O And there was disagreement in that?
2 A That's an opinion. That was his opinion.
3 O Finding 3 not ed on the April 4, 1984 letter says 4 "Existing GPU engineering standards and procedures do not 5
provide appropriate guidance in the development and 6 maintenance of EQ documentation file."
7 How was that acted on between 1982 and 19847 3 A The composition of the file was changed in that 9 the file was divided into separate sections for TMI and 10 oyster Creekr the documentation was changed to be based on 11 a component basis rather than a vendor basis t the 12 documentation into and out of the file was on a controlled 13 basis through DRFs, documentary release forms.
f 14 0 Were those changes covered in GPUN standards and 15 procedures? The finding says "Existing GPUN standards and 16 procedures do not provide development guidance in the 17 development and maintenance of EQ documentation file. "
18 A I'm not sure what the latest revision of that 19 procedure shows whether it reflects all of this.
20 In addition to the procedure there were lee. ers 21 generated by Mr. Cronenberger that define how the file 22 should be changed.
23 0 I noticed on proposed corrective action in the 24 Augurt 21, 1981 memo that we had talked about from 25 yourself to Mr. Stromberg, that on 1, 3, and 11 audit
22862.0 48 BRT 1 findings, numbers 1, 3, and 11, that corrective actica was 2 provided by yourself and Mr. Boucher, and not 3 Mr. Cronenberger.
4 Why is that? I mean, was it -- was that responsibility t 5 delegated to you, to answer those audit findings?
6 A Yes.
7 0 Who delegated that responsibility?
8 A Mr. Cronenberger.
9 Q Did he give you any direction? ;
10 A No.
11 0 Did he review the corrective action --
12 A Not to my k nowl edg e .
13 0 -- on 1 through 11? I was going to finish my 14 question.
15 A I ' m sor ry .
16 Q Did he give you any direction regarding the 17 corrective action on findings 1 through 11; 18 Mr. Cronenberger?
19 A Yes.
20 0 What was that guidance?
21 A You'd have to be more specific. It was 22 different for each one.
23 We sat down and we discussed, you know, an approach to 24 closing these out.
25 0 okay. How about finding nunber 17 i
2286200 49 BRT 1 A He, initially, took care of finding number 1 1 2 himself. At a subs equent point in time he said as f ar as 3
he was concerned that finding was -- the information was 4 available to close it out. Make sure it's closed out.
5 Q Was that proc edur e, 031, engineering procedure 6 031?
7 A Yes. That 's corr ect .
8 At t? tt time it may have been a corporate procedure.
9 It may have been changed to a corporate procedure. It's 10 known as 031: okay?
11 O In any event, were you advis ed that that 12 procedure was not --
that OA, namely Mr. Guimond, th e 13 audit team leader, did not accept that as the corrective
, 14 action?
15 A once again, he did not acc ept it as being 100 16 percent corrective action. 5carever, that procedure was 17 accepted by his superiors. It was concurred to by his 18 superiors.
19 0 Then why did it remain open until April?
20 A I cannot answer that question.
21 O Was there a meeting that that was concurred upon?
22 How do you know that?
23 A It's signed off; the signatures on the procedure.
24 0 It's signed off as accepting the procedure, but 25 was it signed off as accepting the procedure for the i
22862.0 BRT 50 1
corrective action on this audit?
l 2 A No.
3 0 The procedure was accept ed?
4 A The procedure was accepted by OA supervision:
5 y es .
6 0 But it wasn't necessarily accepted as the 7
corrective action to this audit finding?
8 A I don't know how they viewed it.
9 Q so, what I said before on audit finding number 1:
10 Mr. Guimond -- there had been meetings that were attended 11 by Tech Functions and OA, where it was discussed that this 12 was not acceptable; engineering procedure 031, in the eyes 13 of CA7
, 14 A No. In the eyes of Mr. Guimond. Not in the 15 sy es o f CA.
16 Q Who in QA said it wa s acc eptabl e --
17 A That the procedure was acceptable?
18 0 -- as corrective action to that audit finding?
19 A I don't know.
20 0 Did anybody, to your knowledge?
21 A I don't know.
22 O You mentioned before that, as far as 23 Mr. Cronenberger was concerned, it was the answer?
24 A Yes. Yes.
25 0 Did he tell you this?
22862.0 51
-BRT 1 A Yes.
2 Q When did he tell you that? <
3 A I'd say the first quarter of '84.
4 Q How did the discussion even come up? Because it 5 was still an open item?
6 A Discussion about what?
7 0 Audit finding number 1. And the procedures 8 stated as corrective action -- propos ed corrective act .on?
9 I notice it wasn't closed out until June 29, Inm4, based 10 on 031 being issued as 1000 ADM-7317.017 :
11 A Besides Mr. Guimond 's comments on the proced ;re, 12 there were othet crimmer ts on the procedure like, from th e 13 site itself. This procedure was revi. sed under the 14 personal direction of Mr. Cronenberger. It was his 15 conclusion that this procedure satisfied what was open 16 against it --
both site comments and QA consents.
17 Q Okay. Was there a response made? I take it QA 18 somehow has to close their books on this audit finding, t
19 They have a responsibility to follow up on that audit 20 finding?
21 A So far as I know, that 's correct.
22 Q Was there something documented and sent to C' 23 telling them: Hey, we don' t agree, and this is why?
24 A I don't know.
25 Q Oka' > .
, Audit finding number 3. This had to f: s 1
22862.0 52 ,
BRT '
1 with the finding "Existing GPU procedures do not provide 2 appropriate guidance nor is there a program initiated to 3 meet the above requi r ement s . " The "above requirements" 4 ref erred to "Complete and auditable records must be 5 available and maintained. "
6 Did Mr. -- either Mr. Chisholm or Mr. Cronenberger or 7 Mr. Wilson giVe you any guidance concerning this 8 particular audit finding?
9 A Yes .
10 0 What was that?
11 A Mr. Cronenberger wrote a couple of menos as to 12 shat the composition of the file would be.
13 0 Who did he write th e memos to?
, 14 A I don't recall.
15 Q Are they filed anywhere?
16 A I 'm sur e th ey ar e .
17 o Where woul they be filed?
18 A I don't know.
19 O The obvious question is, you know --
20 A I don't know where Mr. Cronenberger files his 21 correspondence; okay?
22 O Well, he had to write them o somebody. And, if 23 they wer e for action for someone else to take they should 24 be filed somewhere, and that's what I'm asking. Where can 25 ! find them? I take it he wrote the- to EO, i f th ey 4
22862.0 BRT 53 1 involved EQ files.
2 A That's a logical assumption.
3 o so, my question is: Did you file them somewhere, 4 were they written to you? or were they writt en to 5 Mr. Boucner?
6 A As I recall they were not addressed te either 7 myself or Mr. Boucher.
8 0 Who were they addressed to?
9 A I don't r ecall .
i 10 would you like me to tell you what those memos were?
11 Identify them?
12 O Sure.
13 A Fine. I can do that. I don't have that 14 information with me, but I can do that.
15 MR. MATAKAS: Let 's go of f the record for a 16 second.
17 (Discussion of f the record. )
18 BY MR. MATAKAS:
19 Q During any of the meetings with Tech Functions 20 and quality assurance, after those meetings or during 21 those meetings, or was there ever any agreement in those 22 meetings that Tech Functions, specifically EC, could 23 ignore or put aside the audit findings that were noted in 24 audit 81-027 25 A Nc.t to ry knowledge.
22862.0 BRT 54-1 0 Did you ever even get that impression from any !
/ 2 of your supervisors?
I
- A No.
4 Q Whose responsibility was it to correct these 5 audit items?
6 A I would say it was a mutual responsibility between quality assurance and environmental qualificatien.
6 Q Specifical., whc? Bodies?
9 A The bodies chang ed . At one time -- specifically 10 at one time Mr. Cronenberger assumed responsibility for 11 finding number 1. Later on he passed that on to me. Okay?
12 O Okay. Any other? What about the remaining, 2 13 through 11, findings? We can go through these one at a 14 time, if you want, or you can just go ahead and explain it 15 to me.
16 A W ell , what you don't realize, that there were 17 chang es in assignments as to -- in the EQ department and iS in the quality assurance cepartment and the 19 responsibilities shif t ed when these assignments were 20 cha ng ed .
21 O When? You ready told me that Mr. Cronenberger 22 assigned you a short time af ter the finding came out, 23 audit finding number 1.
. 24 A Right.
25 0 What about sudit findings 2 through 11? Were I
22862.0 55 BRT 1 they your responsibility with tsny exceptions? And, if
( 2 there were exceptions, what were they?
3 A Well, in the beginning I think, as the record 4 shows, there were three that Mr. Cronenberger was going to 5 take care of, right? And I don ' t know how many of thos e 6 rcmained open that weren't clos ed out. The rest were my 7 responsibility.
8 0 Okay. Did those three e.entually get passed on 9 to you?
10 A I don't know.
11 0 Did number 1 eventually get passed on to you?
12 A Yes.
13 Did number 3 eventually get passed on to you?
0 14 A I don't recall.
15 Q on the revised response, for the corrective 16 action dated 8/31/81, your name and Mr. Boucher's name are 17 typ ed in.
18 A Okay.
19 Q Do you have any knowledge of why they are typed 20 in? Were you, in fact, acknowledging that finding or did 21 someone else type your name in?
22 A No. We acknowledged that this was the 23 corrective action for that finding.
24 0 The proposed corrective action?
25 A The proposed corrective action.
23562.0 56 BR7 1 O You do recall that?
.[ 2 A Yes. I recall this.
3 Q Does that mean that this is your responsibility?
4 The responsibility had shi f t ed from Mr. Cronenberger to 5 you?
6 A I'd say "y es . "
7 O On audit finding number 11; th e same E.hing.
8 A Okay. I'd say "yes," then, the responsibil;ty 9 had shifted to me.
10 Q You don't recall him verbally giving you that 11 responsibility?
12 A No. The only one I recall verbally was on l? finding 1. And there was one other finding, which I can't J4 recall which one it was. But he verbally gave me the 15 responsibility in those two findings; one of which was 16 finding 1.
17 In fact, th e responsibility was not verbal. H e pu t it 18 in a memo.
19 Q Were you aware that prior to February 10 --
20 prior to the February 10 submittal, February 10, 1984, 21 that both the DOR guidelines and 10 CFR 50.49 required 22 that complete and auditable records be available for l
23 qualification? l l
24 A Yes. !
25 O Did you have complete and auditable records on l
22862.0 57 BRT 1 March 20 and 21, during your inspection, in retrospect?
1 2 A I am not going to answer any retrospect 3 qu est ions .
4 O Did you have complete and auditable records on 5 February -- on March 20 and 21st, when the NRC audited 6 your files?
7 A In our opinion, yes.
8 0 Who is "our"? Are you speaking for someone else?
9 A I am speaking for the environmental 10 qualification department.
11 O Were you replaced in your position as 12 environmental qualification manager? Or did *;ou ask to be 13 replaced?
14 A I was replaced.
15 0 Why were you r eplac ed?
16 A I don't know.
17 0 Who replaced you?
18 A Mr. Cronenberger.
19 O Testimony that I have, and inspection and audit 20 reports by the NRC and by -- by the NRC, indicate that you 21 did not have documented auditable files when you were 22 audited on March 20th and 21?
23 A That's not my recollection. My recollection is 24 they said the information was there. It was not in an 25 easily retrievable form. That's my recollection. And l
l
l 22862.0 B ERT 1 that's what was put in writing, as far as I rect'.. .
2 MR. LA GRANGE: That doesn't agree wie. wha 3 r e c t '. 1 , G er ry .
4 You've got a lette't from the NRC dated April 25 th, 4, 5
where the attachment to that letter indicated deficie- 5 6 that we had found in the files; things that had =ct 'r .
7 addressed, inadequate documentation in our opinio...
8 : oes that sound like --
9 THE WITNESS: Is that the letter as a result i 10 the first audit?
11 BY MR. LA GRANGE:
12 O This letter?
13 A Yes.
14 O This letter is a result of our first a:dit:
15 that 's corr ect.
16 A And what's th e sta t ement on th e first pa g e .-
17 that?
18 O The first stat ement says --
19 MR. MATAKAS: Why don't you give it to Mr. '- .
20 MR. LA GRANGE: Well, I can read it to him.
21 BY MR. LA GRANGE:
22 0 "In general we believe that the files conta:
23 documentation that can be utilized to provide the basi 24 for demonstrating that the EFW equipment is qual f ei n 25 one exception. The exception is noted as the Sq:are
22862.0 59 BRT 1
1 diodes." ;
.I 2 A That's the statement I'm referring to.
O "Most of these detail comments were provided to 4 GPU Staf f during the audit or at the exit int ervi ew . We I believe that the comments pertain to the EFW system should 3
be expeditiously resolved." It goes on.
~
Then the letter goes on to talk about EQ files a containing "no indication other than SCEW sheets and brief 9 handwritten sheets that the documentation has been 10 r evi ew ed by GPU . The handwritten material is neither 11 sign ed nor dated. The files are not identified as 12 requiring post-accident operating time."
12 It goes on further, "On each item of equipment that was --
14 for which documentation was r evi e.* ed by th e NRC a t that 15 time"; and gives fairly specific comments about the lack 16 of documentation in those files or comments on the 17 documentation in those files.
15 You have seen this?
1:- A Yes. So you are saying that in the detail you 20 don't agree with the statement made in the opening 21 paragraph?
22 C No. I agree with the statement made in the 23 opening paragraph.
24 A Okay. Fine.
2? O And that statement means that there was 1
22862c0 60 BRT 1 documentation there that can be utilized to provide a 2 basis for the qualification of that eq uipm er.t .
3 A At this point in time this was still a common 4 file. What th ey look ed at were files that contained 5 information on both TMI and oyster Creek. And it was 6 difficult, you know, to go through those fil es and pull 7 out the germane information for TMI-1. I ad=it that.
8 Subsequent to that we changed the setup of the files.
9 O But subsequent to that, Gerry, wasn ' t a massive 10 amount of documentation added to the fil es to address 11 thes e comments?
12 A No.
13 0 That's --
that --
14 A can I explain t/.at?
15 0 Yes.
16 A okay. What happened was tha t w e had , for 17 example, we had a file on Limitorque metor operators, 18 which contained the documentation for -- the qualification 19 documentation for most of the Limitorque motor operators.
20 That was a file by vendor.
21 When we changed the file over on a component basis, we 22 had Limitorque operators in containment, Limitorque 23 operators in the auxiliary building; Limitorque operators 24 in the intermediate building.
25 Each one of those files had the majority of the
22862.0 6.
BRT 1 Limitorque documentation in that file that was in one 2 folder to begin with. Now it's in three folders. It has 3 'oeen repear ed . And that's why the files appear to be so 4 massive right now.
5 Q I disagree.
6 A Fine.
7 0 If you look at those files you'll see a lot of 8 information in those files dated much beyond the time of 9 our first audit.
10 Why would that documentation have been added?
11 A Clarification.
12 BY MR. MATAKAS:
13 0 Mr. Maus, I sat down here on April lith with 14 Mr. Boucher and on approxi=at ely 8 to 11 items, TER it ems.
15 stated what th e TER said ; what the NRC inspection said --
16 A Tes .
17 0 -- which was the same thing, lacking in one way 18 or another, mainly in documentation --
19 A Okay.
20 0 -- and ask ed him: What do you have that now 21 qualifies this in this particular area?
22 A Yes.
23 O And in each case it was a letter -- I shouldn't 24 say "in each case," but in the majority of cases it was a 25 let t er or some document or some e.'ent that took place i
I
22862.0 62 BRT 1 subsequent to the March audit.
2 I don't think it 's necessary to --
3 A Fine. I stil) = tick by what I said to Bob.
4 Many of those items are just clarification. That's all.
5 Q You were hangi : very heavily in the first 6 s ta t em ent in the April 25th letter to --
7 A Do you want te change that word "hanging"?
8 Q Stressing ver) ..ach the first s ta t ement , and I'.-
9 very aware that UCS was stressing that first statement too.
10 But if you read the document it's very clear that you were 11 not getting a clean bill of health as a result of that 12 audit.
13 A Which document are you referring to?
14 Q The April 25th d ocument .
15 A Okay.
16 Q And what bothers me is partly what Bob just read 17 on the attachment to that letter, number 1 states that:
18 "The EQ files contain no indication, other than SCEW 19 sheets (some of which were in the process of being revised) 20 and some brief handwritt- sh eet s , that the documentation 21 had been reviewed by GPU ar" -- "that the documentation 22 has been reviewed by GPU, nor that it has been concluded 23 by GPU that the equipment is qualified.
24 "2, Most of the handwritten material in the files is 25 not signed or dated and - ows no indication that the i
)
l
22863 0 63 BRT 1 statements /information :ontained on these sheets has ever 2 been verified by a checker, or approved."
3 In going back to internal audit 81-02, in March of *951,.
4 on page 7 of 10 --
if you would like to look at it --
5 under number 1 it says: "No evidence of direction for GPU 6 review of qualification data. This concern is relat ed to 7 the extent of GPU review, comment, resolution of comme..t s ,
8 approval, and incorpocation of vendor documents. Examples 9 of evidence examined which cause this concern are - " and 10 it goes A through D.
11 "A. EDS calet lation -- is not properly signed and 12 approved by EDS.
13 "B. EDS project instruction in volume 1 A ar e not 14 signed and approved by EDs.
15 "C. Limitorque reports number 600198 dated 1/2/69 is 16 not prcperly signed and approved by Limitorque for the 17 motor operators.
18 "D. GE report EPA O-047 (qualification data for 19 radiation) on the electrical penetration assemblies model 20 FOl is not signed and/or approved by General Electric.*
21 And on, IE Bulletin requires that the complete and 22 auditable records must be available and maintained at 23 central location and must be updated and maintained 24 current as equipment is replaced, further tested, or 25 otherwise further qualified. "
22862.0 64 BRT l'
What I have looked at here is an internal document and I 2 subsequent to your later NRC inspection, that's really 3 t elling you the same thing.
4 A okay. As that document you just read said, the 5 only thing that they found that were up to date were the 6 SCEW sheets. At the time of that audit we were r equir ed 7
under law to submit those SCEW sheets for the docket. As 8 f ar as we were concerned those vere the legal docu=ents 9
that demonstrated the qualification of the components, and 10 that information that was ref erred to on those SCEW sheets 11 was in our file system.
12 Q And when you say "as far as we were concerned" 13 are you talking about as far as you?
, 14 A GPU Corporation was concerned. The basis for 15 the documentation for any component was the SCEW sheet and 16 the repcrts that were listed en the SCEW sheet.
17 O And you didn't have to have the reports or --
18 A The reports were in a file. Th ey wer e not in an 19 EQ file per se.
20 For instance, if a calculation was ref erred to on the 21 SCEW sh eet, it was in our calculation file, not in the EQ 22 file.
23 Subsequent to tha t , we have changed our file system.
24 The calculations are now in a component file. That's 25 something els e that builds up the size of those files.
, ~ -
22862.0 65 BRT 1 BY MR. LA GRANGE:
2 O But a lot of those calculations and information 3 are dat ed well beyond .'iarch 20-21?
4 A And a lot of them are dated before. That's 5 right. Both ways. We made some subs equ ent :alculations.
6 BY MR. MATAKAS:
7 Q Made some s u cs equ ent walkdowns to identify motor 8 manufacturers?
9 A Y es .
10 BY MR. LA GRANGE:
11 0 Determined subs equently that the EFW pump motor 12 terminations were not qualified.
13 A Would you read the whole thing? That dcesn't 14 make sense to me.
15 Q During the opening GPU's review of their EQ 16 docamentation, while the NRC was reviesing and addressing 17 th e U CS 2.206 decision, GPU determined that the EPW pump 18 motor terminations were not qualified.
19 A Okay.
20 0 Would that review not have been required to be 21 done prior to then, i: order to determi:. . that those 22 terminationa were qualified?
23 A Okay. As far as field walkdowns, prior to that 24 point they were done on a sanpling basis. They were not 25 done 100 percent.
i
22862.0 66 BRT 1 O I don't think this had anything to do with the 2 field walkdown, though?
3 A I'm sorry. Then I don't understand your 4 question, Bob.
5 0 Well, the point is that there was a lot of work 6 done subs equ ent to the first meeting in Bethesda on 7 October 8, 1984, to document the qualification of the 8 equipm ent at THI-1. And if it 's your opinion that in May 9 20 , 1983, th e equipment was qualified for the DOR 10 guidelines, what was the purpose of all the work that has 11 been done on those files since october 8, 19837 12 A There are a couple of purposes. One was to 13 a s s embl e th e information by component package.
14 0 Is not a lot of the information in thera dated 15 fairly recently? I can go to the files right now and 16 point out calculations and analya(s and reports and 17 letters that are very current and necessary, and I want to 18 emphasize " n ec es sa ry , " to document the qualification of 19 that equipment.
20 A Okay. And the word "necessary" is in your 21 opinion.
22 O It's in my opinion. That's correct.
23 A Okay. Fine. All right.
24 0 In your opinion, th en , for instance, on 25 Limitorques, when we came up here the first time and found 1
22862.0 67 BRT 1
that the profiles that had to be -- that were generated to 2 show what the temperatures would result -- t empera t ures 3 and pressures that would result from accidents, and to 4 which that equipment must be qualified, analyses to show 5 that that equipment was qualified for those profiles was 6 dated fairly recently.
7 Would that analysis not have had to have been in there 8 in order to show that was qualified, back in May 20, 1983 9 or at any time previous to that? And, if not, why not?
10 A Do you want to give =e those questions one at a 11 time?
12 O The major point is, G erry , I still want to get 13 back to the question of why, back in May 20, 1983, was it 14 stated this equipment was qualified in accordance with the 15 DOR guidelines?
16 A Becaus e we believed it was.
17 0 Iten you believe that all the documentation put 18 in those files subsequent to then is unnecessary to 19 demonstrate the equipment is qualified?
20 A No.
21 0 There seems to be an inconsistency in the two 22 s ta t em ent s .
23 A You have defined some additional information 24 that you wanted to see in the file that, as far as I 25 recall --
I l
J
22862.0 68 BRT 1 O I'm asking your opinion, though. You don't feel
[ 2 that information has to be 3 n there in order to shs. that 3 equipment is quali!!ed?
4 A I didn't say that.
5 0 Wha t would you say, then, with regard to all the 6 additional documentation that's now in the files?
7 A Some of it is required to show -he qualification 8 to the extent that you are looking for a today, ..;ch is 9 not the extent tha t you were looking for back ir. 1983.
10 0 I don't understand. What has chang ed?
11 A Post-accident time.
12 O I don't understand what's cha ng ed . Are not the 13 r eq u i r ement s , th e criteria for TMI-1 for a large majority 14 of equipment in that plant, the DOR guidelines?
15 A Yes.
16 0 Have they changed since May 20, 19837 17 A The DOR guidelines? No. Have you issu ed 18 clarification on them?
19 0 Not since May 20, 1983.
20 A What clarifies what you want fer post accident 21 operating time? Where is that s tat ed , tht: you should 22 show that? :
23 O Post-accident operating time was shown on the 24 SCEW sheets that were issued with IE Bulletin 79- ' . B.
25 A Which were subsequently taken outr right? As a l
1
22862.0 69 BRT 1 sample?
2 O No. The SCEW sheets, sample SCEW sheet s were
[
3 a tta ch ed to 79-01 B --
4 A You deleted that; right? You deleted that 5 attachment later on.
6 O Not tha t I'm aware of.
7 A : believe so.
S O : simply want o know or.c e again --
9 A Yes.
10 0 --
if there was any necessary documentation in 11 your opinion that has been added to that file to show that 12 equipment was qualified subs equ ent to May 20, 1983, then 13 what was the stat ement in the May 20, 1983 letter, ,
14 ref erring to when it said all equipm ent was qualified in 15 accordance with the DOR guidelines?
16 A Becaus e we had no guidance previously to that, 17 as to the degree of information you were looking for in 18 the files.
19 0 Would you agree that documentation would have to 20 be in those files to show that the equipment is qualified 21 for the temperature and pressures it would see during an 22 accident?
23 A Yes.
24 O Do you agree that the subsequent evaluations in 25 the Limitorque files to address that issue were l
l
22862.0 70 BRT 1 unnecessary to show that it was qualified?
2 A don't know.
3 0 I know you don't want to answer questions in 4 r et ro sp ect . You stated you are -- don't want to --
5 A I am not going to answer any questions ir.
6 r e t r o s p ect . I made that s ta t em e nt .
7 2 wouldn't it be fair to say based en what you 5 kno. today that that s ta t ement on the May 20, 1983 letter 9 could not be supported by the documentation in the files?
10 A I will not answer that question.
11 (Discussion off the record.)
12 BY MR. MATAKAS:
13 0 Mr. Maus, what I have here is an extract from 14 the meeting in March 1984. You were pres ent, Mr. Le.
15 Mr . lag rang e wa s th er e , and Le makes 'a statement, and I 16 quot e: "Any defici ency identified in this, page by page, 17 we expect that you have the answer to those deficiencies.
18 When the inspector goes out there, the TER will serve as a 19 guide to inspect." He's ref erring to the TER.
20 "Mr. Maus " I quote: "That has been our premise.
21 That is what we tried to do, to be sure that we had the 22 information in the file.
23 "Mr. Le: Did you mak e that commitment? If you made 24 that com-i ment , then we will proceed.
25 "Mr. Maus : We even had a trial assess =ent on our file
22Ei ~ .0 71 B P.T .
1 by our own OA to make sure that this kind of _information i 2 is in there. We had independent verification, if you wil'." .
3 I have asked for all the OA audits from 1984 ba:k o 4 1981. And the only thing that comes close to this tbee 5 period is the April 4th letter here which may have beer. as 6 a result of an earlier look-s ee by Mr. Guimond, into the EO 7 files.
E Is there another audit that I'.- not aware of? Or wr.a t 9 audit were you referring to? or what look-see --
10 A Does it say "audit" there?
11 O What "look-see"?
12 A There was another "look-see" I was referring to.
13 0 What, by whom, and when was that?
,. 14 A It was joint ly done by OA and T ech Funct ier.s .
15 It was, as best I recall, in the summer of 1983.
16 0 By whom?
17 A Specific individuals?
18 Q Yes, sir.
19 A Mr. Guimond, Mr. Maus, Mr. Boucher -- there were 20 a number of people involved. There were upwards of 10 21 people involved in this.
22 O Mr. Guimond -- did he say the files were daem 23 adequate?
24 A No. In his opinion.
25 0 Well, what's the use of having a OA look see,,
22862.0 72 BRT 1 you -
a, if you are not going to agree with what he says?
2 What aave been going through here, it s e ems like for the 3 pas- ree years, everyone that looks at the files outside 4 of yce rself says that everything that I've seen says that 5 you - lacking in documenta: ion. And you sit there and 6 tell - : Well, that's their opinion. I don't understand 7 that:
8 A You can always imp:ove upon documentation. You 9 can always make it better. The question is: When is it 10 suff;::ent? That's the question you have to answer. And 11 that :s strictly subjective. Your opinion is different 12 thar. ne, which is dif f erent than Mr. Guimond's. And 13 it's - rictly opinion.
14 : But it appears that Mr. Guimond, of QA, and the 15 NRC, d aring this time period, has been saying that what 16 your opinion may be must not be adequate because they are 17 tell;..: you that you don't have adequare documentation.
18 A That's what they are saying.
19 ; Well, did you just say, you know: Well, the 20 hel; -h you guys, I think : do have adequate 21 docu- tion?"
22 A obviously not. As Bob says, we have been 23 upda ;..g the files. We have done it. We are still 24 updtt. .g the files .
25 : Since 1984.
22862.0 BRT 73 1 A Since 1980.
2 Q Since the audit in 1984.
3 A No. No.
4 Q That's what Bob was talking about, the 5
documentation subsequent to the March 20-March 21st audit?
6 A I'm talking about all updating of the files.
7 Those fil es are a dynamic thing. And , as I told you, 8 we ' ve chang ed th e composition of the files. The files are 9
now on a plant c w nent basis, which th ey w eren ' t befor e .
10 Q I understand this is a big job. This has been a 11 big job; EQ, or it wouldn't have had the deadlines 12 ext end ed lik e th ey have been extended.
13 A Right. And there wer e no, or very little firm 14 guidelines.
15 Dow familiar are you with the EQ program?
14 o I'm not a techr.ical person. I'm not sure.
17 A All right. Well, Bob will tell you there were 18 regional meetings, national meetings, individual meetings 19 with licensees. This is not a clearcut program. It's a 20 very complex program. It's a very difficult thing to do 21 and we are learning as we go along.
22 Q I am not trying to attack you as an individual, 23 Mr. Maus.
24 A Fine. I am not implying that you are. I am 25 trying to tell you why files have to change.
22862.0 BRT 74 1 Like today, we still get reports like: We have changed 2
I our qualification documentation froc somebody like 3 Rosement. This report that we gave you now, we would like 4 you to supersede this report. We've got a better report.
5 Q Could you have possibly accomplished what was 6 being asked of you by your owa QA and by the NRC with 7
physical -- with the physical resources that you had? Do 8 you feel that you could have possibly done it?
9 A Up to what point in time?
10 o Up to March 20, 1984.
11 A Yes.
12 O You feel that you could have?
13 A Yes.
,. 14 0 With you, Mr. Boucher, and Mr. Maus?
15 A I'm Mr. Maus.
16 Q Then Vay was Mr. Boucher asking for help and you 17 asking Mr. Chisholm for halp?
18 A Because we needed more help. I'm not just --
19 you told me you are directing your questions to TMI: right?
20 Q Y es .
21 A Okay.
22 O Well, you were asking for help for TMI: is that 23 correct?
24 A Yes. I just want to make sut e we understand 25 what we are talking about.
t
22862.0 75 BRT 1 There were some unscheduled items that yo; couldn ' t 2 plan for. Li" . c , for instance, th e UCS petit icr.. We 3 didn't know a'r,ut that ah ea d of t ime. That took a lot of 4 effort. That was unplanned work.
5 Q Wel) . even prior to the UCS petition, 6 Mr. Boucher had asked you for assistance; is that correct?
7 A Yes. Yes, he had.
i O An cu had relat e2 those concerns omto 9 Mr. Chisholm?
10 A Y es .
11 BY MR. LA GRANGE:
12 0 But when you say "unplanned work," had all that 13 equipment beer documented as qualified at the time the UCS 14 petition had been submitted, there would not have been any 15 need for subs equent work; is that correct?
16 A No. Because that s y s t em is being modi fiad . It 17 is still being nodified today. The system is not esmplete:
15 the environ =er al qualification of that system is not i 19 complete. The installation of that system is not complete.
20 Q Were 't at least the majority of those 21 components alt identified ir. response to 79H3;(B)?
22 A I'm ..ot sure whether a majority were or not.
23 0 Well, the majority had TER items?
24 A I'r not sure what's going to -- I'r really not 25 sure on that cuestion. I'm not hedging. I 'n not sure.
1
22862.0 76 BRT 1 O Well --
( 2 A That's a system that's gone through a lot of 3 changes and is still being changed.
4 O The paper trail associated with this 2.206 5 review will show that they do have TER item numbers 6 assceiated with th em; the na jority of that equipm ent .
7 That TER was issued December loth, with our SER. I 8 believe th e TEF. is dated Nc. ember 5, 1982. The UCS 9 petition was submitted approximately January ' 84.
10 Would not all that equipment as of May 20, 1983, have 11 been qualified to the DOR guidelines, therefore resulting 12 in no additional effort in response to the 2.206 petitiot?
13 A I'm telling you as of that date, and even to
/ 14 this date, the equipment in that sy s t em is not finaliz ed .
15 So the qualification of that system is not finaliz ed.
16 O Dut would the qualification of the equipment 17 identified prior to the 2.206 petition have been qualified?
18 A I'm not sure.
19 0 If you are not sure, then how come the May 20, 20 1983 letter says it's qualified in accordance with the DOR 21 guidelines?
22 A Once again, and this is the last time I'm going 23 to say it, that system is not complete. It was not 24 complete then, it is not complete now. We are just 25 repeating the same thing.
r 22862.0 77 BRT 1 BY MR. MATAKAS:
[ 2 O Mr. Maus, did you ever intentionally provide 3 false information --
4 A No, sir.
5 0 --
to --
6 A I'm sorry. I thought you were done with the 7 question.
3 Q --
to licensing, or k.w.angly allow false 9 information in any type of document generated by GPUN 10 going to the NRC7 Did you knowingly allow such a document 11 to go to the NRC? Both questions.
12 First of all, did you ever intentionally lie to 13 Licensing, specifically regarding information going to the 14 RRC7 15 A Is that th e end of the question?
16 Q Y es .
17 A The answ er is "no."
18 0 Did you ever review any licensing document going 19 to th e NP.C th a t you believed had false information and 20 al19ved that false information to be transmitted to the 21 NRC7 22 A No.
23 MR. MATAKAS: Do you have anything else, Bob?
24 BY MR. LA GRANGE:
25 0 You said previously tha- it was felt that you
r i 22S62.0 78
- - BRT 1 needed help in the EO area; you needed more resources.
! 2 Based on the additional work that has been -- knowing the 3 additional work that has been done over approxir- +;y the 4 last year on these files, could you and Mr. Boucher have 5 accomplish ed that work by yourselves without add i t ior,a1 6 resources?
7 A That's a retrospect question; right? : will not 8 answer that question.
9 Q In th e F ebrua ry 10, 1984 letter, where GPU 's 10 position is stated that the plant is in compliance, TMI-l 11 is in compliance with the requirements of 10 CFR 50.49, 12 based on your recent sta t ement here that the EFW system is 13 still being worked on, how could that statement have been 14 made on February 10, 19847 15 A Becaus e we have told you that th e EFW sys t em wa s 16 undergoing a major modification. There's other 17 correspondence on that. You are well aware of that.
18 C Would then all the individual -- all the 19 individual equipment it ems tha t are included in the 20 Franklin TER have been, in your opinion, qualifi+' as of 21 February 10, 1984?
22 A I'm not sure what our position was on all those 23 it ems .
24 MR. MATAKAS: Let 's take a one-minute break.
25 (Discussion off the record.)
22862.0 79 SRT 1- BY MR. MATAKAS:
i a 2 O Mr. Maus, correct me if I m wrong -- Bob, d i d n ' t.
3 you just ar- if all the --
4 MR. LA GRANGE: I a sk ed if all of the EFW 5 eouipment that had TER items associated with them, would 6 have been cualified as of February 10, 1984. I be; eve 7 G erry resp 0:.d ed h e 's not sure.
8 Bi MR. MATAKAS:
9 O And getting back to this meeting in March 1984, 10 cssentially what Mr. Le is asking you about TER items, 11 they expect te have answers to those deficiencies, and you ;
12 state: "That has been our premise. That's what we t ri ed i
13 to do to be sure that we had the information in the file. l
)
14 We even had a trial assessment on our file by our 2A, to 15 make a tre this kind of information was in th er e . "
16 Could you clarify why you were not sure that all the 17 information was not in there?
18 *A Because there's other correspondence tha-19 describes the changes on the ErW system, okay? And that's 20 on the docket, as to what the changes we made on that i
21 syst em were. snd when we would have the system in i 22 compliance v. th regulations, including EQ.
23 0 But he's talking specifically TER items now, TER l 24 deficiencies?
I I 25 A u- s talking EFW TEF defi:iencies.
, 22962.0 80 CRT 1 O Right. Which would have been --
2 BY MR. LA GRANGE:
3 0 Which would have been equipment that existed in 4 the plant and was included in the EQ program, at February 5 10, 1984, and May 20, 1983.
6 BY MR. MATAKAS:
7 Q But the deficiencies that existed back in '82 3 would remain the sasse deficiencies?
9 A No. That equipraent may not even be used in this 10 systemi today.
11 Q Then the deficiency is no longer valid; is it?
12 A That's right.
13 Q It's no longer a deficiency?
14 A That's right.
15 o But we are talking about the deficiencies. That 16 is one way to get rid of a deficiency; isn't it? To 17 replace the piece of equipment with a qualified -
18 A I didn't say "replace" it. I said "It's no 19 longer us ed . " That's not "replace."
20 Q Well, deleted or however you want to say it?
21 A The point is the system is under redesign: okay?
22 And the redesign of the equipment is not complete nor the 23 installation of the system nor the qualification of the 24 system. And I'm not going to change that s ta t em ent so 25 please don't ask it any more.
I l
r 22862.0 8;
. BRT 1 MR. MATAKAS: Bob, do you have any further f 2 questions?
3 MR. LA GRANGE: No.
4 BY MR. MATAKAS:
5 o Mr. Maus, did you appear here today of your own )
6 free will?
7 A Yes, I did.
8 Q Have any promises been made to you or have any 9 threats been directed towards you?
10 A Wo, sir.
11 MR. MATAKAS: Okay. Th e time is 11:55. This 12 concludes the interview.
13 Thank s a lot, Mr. Maus. -
14 (wh er eupon, at 11:55 a.m., the interview was 15 conclud ed . )
16 17 18 19 20 21 22 23 24 l 25
4 CERTIFICATE OF OFFICIAL REPORTER This is to certify . hat the attached proceedings before the UNITED STATES .WJCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: Investigative Interview of:
F. GERARD MAUS DOCKET NO,:
PLACE: Pa .ripanny, New Jersey t DATE: 7hnrsday, April 25, 1985 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regul,atory Commission.
(rigtN hYPEDh [
Joel Breitner Official Reporter Aco-Federal Reporters Reporter's Af filiation , Inc.
I I
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