ML20147E821
| ML20147E821 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 04/25/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 NUDOCS 8801210225 | |
| Download: ML20147E821 (45) | |
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.2E7ESTIGATIVE INTERVIEW OF RICHARD J. CRISHOLM
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DATE.- TWUESDAY, APRIL 25, 1985
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CR22 66 2.1 1 3RT/dnw I UNITED STATES OF AV. ERICA 2 NUCLEAR REGULATORY COM.'!ISSION 3 OFFICE OF INVESTIGATION 4
5 GPUN Ileadquarters 100 Interpace Parkway 6 parsipanny, New Jersey 7 The Investiga-ive Interview convened at 1:00 p.m.,
8 Richard A. Matakas, presiding.
9 PRESENT:
10 RICHARD J. CHISHOLM, Interviewee
, GPU 11 l j RICHARD A. MA AKAS, Investigator 12 i Region I.
-' Nuclear Regulatory Commission I3 h King of Prussia, Pennsylvania U RO3ERT C. LA GRANGE Section Leader 15 ' EQ Branch Office of Nuclear Reactor Regulation 16 '
'7 18 19 I
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21 22 i
23 .
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22862.1 2 BRT 1 PROCEEDI NGS 2 MR. MATAKAS: The date is April 25, 1985, the 3 time is 13:01. Present for this interview are /self, 4 Richard A. Matakas, investigator, U.S. NRC; Bob LaGrange, 5 section leader in the NRC EQ branch, office of NRR; and 6 Mr. Richard J. Chisholm, manager of electrical power and 7 instrumentation.
8 The purpos e of this interview is to discuss facts and 9 circumstances leading to GPUN submittals to the NRC 10 involving the environmental qualification of electrical 11 equipment at TMI Unit 1.
12 Mr. chisholm, do you have any objection to providing 13 this information under oath?
14 THE WITNESS : No.
15 Wh er eupon, 16 RICHARD J . CHISRulJ4 17 was called as a witness and, having been first duly sworn, 18 was examined and testified as follows:
19 EXAMINATION 20 BY MR. MATAKAS :
21 O Mr. chisholm, for the record would y: give us 22 your full name and business address, please?
23 A My name is Richard J. Chisholm. I'm with GPU 24 Nuclear Corporation, Parsippany, New Jersey.
25 0 And telephone number, please? Business.
22862.1 3 BRT 1 A 299-2081.
2 O Would you please give us just a general overview 3 of ycur education and work history?
4 A Okay. I have a degree in electrical engineering.
5 I have been working in that field since 1948, which is --
6 2 A long time.
7 A Several years. I have been working in the 8 nuclear industry, well, with this company for 14 years. I 9 have had about another five years ' previous experi ence in 10 the nuclear industry.
11 0 What I would like you to specifically address is 12 regarding the environmental qualification program. your 13 interf ace with it. What were your responsibilities 14 towards it -- you know, when you s ta rt ed a nd when you w er e 15 with that position, if it cha ng ed -- over th e yea rs ?
16 A I'm not sure I can give you the specific dates.
17 0 Generally.
18 A My sense of chronology is not too good.
19 0 Okay.
20 :. But sometime, and I don't know when it was -- I 21 guess when the EQ program started, this 7901 B -- at that 22 time : did not have this job, but it was picked up by my 23 predecessor as having responsibility for equipment 24 qualification, and I think it started off in a very 25 low-key ma..ner.
22862.1 4 BRT 1
When I took the job there were, I think, perhaps one or 2 two people in the group that were working with it. There 3
were some outside contri-* ors which were working cr. i'.
4 And most of the activity was being done outside.
5 At some point -- and I can't remember when -- G erry 6 Maus was brought into the group and he was designat ed as a 7
manager, being responsible for equipment qualification, 8 and I don't remember the precise date.
9 Q And you would have been his supervisor?
10 A It was a couple of years -- several years ago.
11 But I was his, right, his supervisor.
12 KR. MATAKAS: I think he indicated to us that 13 was April 1981.
14 HR. LA GRANGE: Some.'here around there.
15 THE WITNESS That could be.
16 BY MR. MATAKAS:
17 Q But you were already in your current position at 18 that time?
19 A At that time I was .
20 Q And acting as his supervisor and his prede:essor's 21 supervisor? If he had a crede:essor? Mr. Maus' 22 predecessor?
23 A When Gerry was brought in I was the manager of 24 that group.
25 0 Exact ly what .re fear responsibilities :r
22862.1 5 BRT 1 relation to the environmental qualificatior. program as 2 Mr. Maus' supervisor?
3 A W e '.1, I guess I had general resper.s bili *y for 4 what he did. At that time I was not, you know, closely 5 involv ed in the details of what was going on. I tried to 6 stay current, in general, with what was going on, but, you 7 know, I had sort of at least administrative responsibility 8 for what he did.
9 I think later on when activities started to get -- when 10 things started to get a lot more active -- there were more 11 people involved, th en I was -- I did get more actively 12 involved in it. That was probably -- I can't remember 13 dates, again -- but it was maybe a year and a half, two 14 years ago, perha ps . Something lik e that .
15 0 Was this af ter the UCS petition that you are 16 talking about, when you start ed getting imore people 17 involv ed?
18 A Probably. I think it was -- it was about the 19 time that Bob LaGrange and the people from the Commission 20 had cone up to do the auditing and had the neetings ap l
l 21 there. That was about the time I got actively involved.
22 O That was April 20 and 21st, 19847
- 23 MR. LA GRANGE
- March 20 --
l l 24 BY KR. MATAKAS:
i 25 C I'n s orry. 1:trch 2: and 21st?
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22862.1 6 BRT 1 A It was about that approximate time frame. Tha:
2 was about the time. It didn't, you 'know, happen over t?.e -
3 course of one day. 't was gradually increased --
4 Q What other responsibilities did you have during 5 that time period? I'm talking about 1981 through 1984. I 6 just want to get an : dea of what you were responsible f:r ?
7 A Well, I'm responsible in general, you know --
8 over the course of the years, there were probably 9 something on the order of 20, 22 engineers in the group.
10 We were responsible for all of the design work :.n the 11 areas of electrical power and instrumentation and contr:'. .
12 We also have responsibility for some of the, you knov, 13 operation and maint enance activities at the plant, and 14 those things.
15 So, I guess, you know, up until this time when I beerne 16 more actively involved in EQ, probably 90 -- 95 percent of 17 my time was spent on these other activities.
18 MR. KATAMA5: Let's take a one-minute break here.
19 (Discussion off the record.)
20 MR. HATAK; I just had a phone call from 21 Mr. Hays and Mr. Chr stopher in Bethesda , so I'm going to l
l 22 have to take a couple of minutes' break.
23 The time is 13:10. If we could take probably about a 24 20-minute break?
25 (Discuss;.- off t'_.e record.)
i l . - _ _
22862.1- 7 BRT 1 BY MR. MATAKAS:
2 O Mr. Chisholm, before we were interrupt ed we were 3 talking about what other responsibilities you had, during 4 which time you were supervising the EQ program. If we 5 could continue with that, please?
6 A Yes. Well, as I said, I th i nk , you know, I was t
7 :esponsible fer the design functions and the
- elect rical 8 and ILC areas. I had one, you know, supervisor for each 9 of those two functions. And when Gerry Maus came on, then 10 he formed like a third group under me.
11 Q okay. What I would like to show you is an 12 interof fice memorandum, GPU Nuclear interoffice memorandum, 13 dated June 25, 1981. That's a OA number QA/4161. The 14 subject is audit 0-TMI-81-02. It is to Mr. Wilson from 15 Mr. Stromberg. And attached to the memo is the audit 16 report, 81-02. I notice you are on distribution.
17 I would like you to go ahead and take a look at the 10 document and ask you if you recognize it. With the 19 exception of some of the chicken scratchings, it's mine.
20 A I don't remember it. I remember the fa ct th ero 1
21 was an audit. I don't have any real recollection of what i 22 was -- I don't have any real, you know, specific 23 recollection of the content. I just remember the fact i
! 24 that there was this --
25 : I nttice there's 11 audit deficiencies -hat are
1 22962.1 8 BRT 1 noted; 1 through 11.
2 Before we get too much ahead of ourselves, did you have 3 any input regarding the response to the deficiencies noted 4 in the audit 81-027 5 A I don't ramenber that I did. Without reading it ,
6 that's what I'd have to say.
7 MR. MATAKAS: W ell , why don't we take a couple 8 of minutes' break and let you read Lt.
9 (Discussion of f the record. )
10 THE WITNISS: Well, this doesn't include the 11 response to the audit. Just looking at t.he audit findings, 12 I can't remember, you know, being involved in any response.
13 BY MR. MATAKAS:
14 0 Okay. There was a response, too, to these auda:
15 findings. But did you notice that either Mr. Cronenberg er 16 or Mr. Maus acknowledged the audit findings?
17 A Yes, I did notice that.
18 Q There was a response to that, but they cannor 19 find the response.
- 20 However, there is another document , dated June 25, 108;,
i 21 QA/4186, to Mr. Cronenberger, which ref erences the same 22 audit, which reiterates the response, and it gives a OA 23 response to the Tech Functions response.
24 I would like you to take a look at this document, and :
25 ask you if you recognize that.
22862.1 9 BRT 1 A This is from -- okay. This is the response --
2 this .s OA's response to somebody's --
3 : To Tech Functions' response, w'r *
. they :: 'd 4 not find?
5 A Okay. I don't r emember this .
6 : Do you recall talking to Mr. Cr:r.enberger er 7 anybrdy within the Tech Functions group re arding the 8 specific audit deficiencies?
9 A I remember some -- thes e general conversations, 10 you know, about trying to resolve the differences between 11 our response to it, which I presume must have come from 12 Gerry Maus, although I don't specifically know that , and --
13 b etw e e.; trying to resolve those responses and, you know, 14 QA's :issatisfaction with it. I r e=e=b er th a t --
some 15 discussions that I had with Mr. Cronenberger.
16 O Do you recall specifically audit Finding Number 17 1, which was very critical to management ? The finding was 18 "no e udence of management direction to c:rrelate the 19 int e rs ectional effort in establishing the master list and 20 qual: :ation documentation file." Do you remember 21 disc. .ng that particular?
22 A No, I don't.
23 O Do you recall attending any mee . r.gs during the i 24 1981, 1982, 1983 time period, even early 1984 time period, 25 whe:. .A was also in attendance? Mr. G u.: .: ..d , some ;mes I
-22862.1 10 1?.T 1 Mr. Stromberg, Mr. Bader may have been present at some of 2 them, and Mr. Hagitz -- where at least Mr. Guimond 3 expressed dissat isf action vi'~. the response to the audit 4 findings?
5 A I don't think I was ever involved in any of 6 thos e meetings. I don't recall being at any of them.
7 Q Do you recall meetings on the subject?
8 A No, I do not. I presume there must have been 9 some, you know, but I don't have any specific recollection.
10 Q Were you ever given any direction or 11 responsibility by Mr. Cronenberger, specific direction or 12 responsibility, regarding these audit findings?
13 A I can't recall it, except in a general way. I 14 r em ember tha t this audit -- you know, that there was some --
15 there was not agr a mnent between us - "us" being 16 engineering and design -- and QA on that. But I can't 17 remember any specific direction, you know, as to specific 18 audit findings that we should try to do something about.
19 I can't remember anything like that.
20 Q What I would like tr show you now is a 21 memorandum dated April 4, 19?4. The number on it is 22 PDA/84-107. It is from Mr. Guimond to Mr. Stromberg, and 23 the ref erence is "open audit findings." And, the subject 24 of which is, again, audit 81-02.
25 This is the first page. Y: can ignore this fi r s t page
22862.1 3,'
BP.T 1 here. When I got this copy the Xerox machine messed up, 2 so that's the first pag e a r.- this is the second page.
3 A This is 1984. I -n't r em emb er it.
4 Q Was it ever related to you by anyone that they 5 were dissatisfied, or that anyone was dissatisfied with 6 the way the individual comr- .ents within the scope of i
7 environmental qualificatior. were docu=ented as "qualified" 8 in the files, or the lack of documentation for 9 qualification in the files?
10 A Well, yes. That certainly came up at some time.
11 I'm not sure -- you know, it was, I thi nk , a finding of 12 the NRC audit that our files were not adequately auditable.
13 O Essentially, Find *ng Nu=ber 3, which was still 14 open as of April 4, 1984, s - a t es that, according to 15 Mr. Guimond, "existing GPUN engineering standards and 16 procedures do not provide appropriate guidance in the 17 development and maintenance of the EQ documentation 18 file."
19 Do you know of any reaser why this audit finding, which 20 was originally written in U , continued to remain open 21 in April 1984?
22 A No. But that's ne: the same thing that you said.
23 That finding sounds like it relates to the proceduras, not 24 the condition of the files. But -- but I don't know any 25 reas n.
22862.1 12 '
BRT 1 O What the finding is addressing is the 2 requirement -- s t a t ed in Finding 311 -- it says "NR2 order 3 dated 10/24/6 . order fcr modif.:ation of li t er.r e 4 concerning environmental qua'.ification of saf ety-related 5 electrical equipment, page 5, paragraph B stat es in part, 6 'by no later than Dec ember 1, 1960, compl et e a r.d auditable 7 records must be available and maintained at a central 8 loca tio n. Th er ea f t er, such records should be updated and 9 maintained current as equipment is replaced, Barther 10 tested or otherwise further qualified. '" sort of a 11 general finding. General, but it states the requir ement, 12 and the general finding is that there is not a program in 13 place for tha t .
14 A Well. I guess there was -- you know, we 15 certainly changed our criteria for what is meant by 16 *auditability" about the time the NRC had their audit. ,
17 You know, whether something is auditable or not, you know,
, 18 is subject to some interpretation.
19 0 Did either Mr. Maus or Mr. Boucher ever express 20 to you that th -
needed assist ance in accomplishing what 21 was required ci them for the en uronmental qualification?
22 A I don't know of any specific requests.
23 Certainly, at one time, you know, at sometime when we 24 decid ed that we needed to upgrade the files and do a lot 25 mere -- a mort ecmplete job in car documentatier., : was i
2286201 A3 BRT 1 evident that we did need help. But I don't recall any f 2 specific identification of that, much prior to that.
3 0 When you say "specific," io y ; mean written?
4 A Well, not necessarily. But -- by "specific" I 5 sean something more than somebody would say, you know, 6 "We've got a lot of work to do," er "We are overloaded,"
7 or something lik e that.
8 In fact, there was the perception, at least on my part.
9 that the EQ program was not going to last forever.
10 Perhaps we had -- perhaps I had a wrong perspective on it.
11 And, you know, at that time -- and I'm talking about a 12 couple of years ago -- we were almost thinking in terms of 13 what vet 1d happen if the thing phas ed out -- what would 14 people be doing?
15 So, I, at least, was not conscious -- say in 1982 er '83 16 or something like that -- that th er e was a need for a lot 17 of people, a lot of additional people.
I 18 0 Do you recall attending a meeting durine the 19 first part of 1984, a meeting where I believe Eruce 20 Alatary from OA was taking notes -- then published those i
21 notes -- and you made a com=ent ab: the possibility of l
22 GPU contracting out for EO assistance?
23 A I don't recall that comment. You know, th ere 24 were several meetings with OA during that period. And 25 certainly going outside for assist: .:e was being l
i i
I l
2286201 14 BRT 1 considered in that period.
2 You are talking about early in 19847 ,
3 O Jar.uary 19E4; prior to the NRO audit.
4 A Well, that was about --
I don't know. Yes --
5 but I don't specifically recall.
6 0 We are talking about the UCS petttion?
7 A It's pos.sible, but I don't specifically 8 recollect making that.
9 Q The reason I asked is I ' m trying to locate the 10 minutes for that meeting.
11 A I see.
12 O A meeting that Bruce Alatary, if that ringss a 13 bell, took notes of and published?
14 A As I say, there were a nunber cf meetings, in 15 f a ct , a lot of meetings during that period, with QA. I 16 don't specifically know which one.
17 0 What were the meetings about? Can you narrow 18 down the time period of that a little better? You said 19 "during that time period."
20 A No, I cannot, without going through my own 21 calendar -- or someplace.
22 O what would have been the character of those i 23 meetings with OA7 24 A Let me think. The main subject I remember was 25 the one of au ditability as te -- you know, what I
22862.1 15 BRT 1 constituted an acceptable t aadard for that. I remember 2 that being a subject.
3 0 Was OA tel.1.ing that they felt the files were 4 not auditable --
5 A Yes, they wer e.
6 0 --
in accordar.' . i-h DOR guidelines or 10 CTP, 7 50.49. I don't know if - 'v mentioned those to you.
8 A I don't know wr.sther or not they mentioned those 9 specifically or whether those things give any guidance on 10 what constitutes auditat;'ity; but I know in their opinien 11 they felt our files shoul. be better organized and more 12 open to an audit.
13 0 Did anybody d:r pree on the Tech Functions s:de 14 with that? .
15 A Well, I guess -h ere was at least a disagreement 16 at that time in -- you knr., sort of a relative 17 disagreement on how audi- = rle it would be. We certainly 18 were not in agreement, c: - h ere would not have been 19 discussions like this.
20 BY MR. LA G RAN 21 O Was the disagre just on auditability, or 22 was it on lack of docume.- .on to establish qualification?
23 I want to get --
24 A I'm -- yes - not sure. There were probably 25 a lot of specific thingt .o; know, it was one large i
22862.1 16 BRT 1 general subject. I can remember that. There may have 4
2 been s ume disagreements on documentat:cr. as well.
3 0 I ;ast want t o mak e cl ea r t?.a - there's a 4 dif ference between auditability of a file and contents.
5 A Yes, I understand the dif ference.
6 BY MR. KATAXAS:
7 Q When you speak of auditabil:ty, what are you 8 speaki.mg of ?
9 A I'm speaking of the ability of somebody to go in 10 and track down where the data is, what the suppceting data 11 is for eenclusions drawn in the file.
12 O Were there discussions on what was needed to be 13 qualified ?
14 A I cannot --
as to what needed to be qualified?
15 Q what I'm saying is, the question of 16 documentation - lack of documentation.
17 A Well, what needed to be qualified is a dif f eren-18 sub j e::, I thi nk .
19 Q Well, I'm talking about lack of documentation, 20 basically.
21 A I v: ;1d just be really speculating if I tried to 22 say that. I can't remember the specific things that came 23 up in those meetings.
24 o Did Dr. Long ever talk to you about the 25 envir: menta'. qualification program?
22662.1 37 BRT 1 A Hot that I recall. No; never.
2 (Discussion off the record.)
3 BY MR. KATAKAS:
4 Q These meetings that we are talkir.; about -- at 5 what level were the people in attendance? ss 6 Mr. Cronenberger there? Was Mr. Wilson t'r- s at some of 7 these meetings, on your side?
8 A I can't remember that Mr. Wilson was ever there.
9 Mr. Cronenberger may have been. We are talking about a 10 number of meetings over a length of time of a couple of 11 months, and that's kind of like a general a..swer.
12 O I just want to get some idea --
13 A Yes.
14 Q --
and on the QA side would it
. e beer.
15 Mr. Stromberg and below, on that level?
16 A No. At tha t tLae I don't think S t romb erg wa s 17 involved. I think it was mostly Alatary. de had some 18 people working for him. I ' m no t sure I re- -ber who all 19 of them were.
20 0 Bader, Magitz? g, -
21 A No.
I don't thi,nk Magitz .
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2 %; '
. 1()
23 Bader -- I don't remember exactly who he is 24 o Are you familiar with December 1: . 1982 NRC SER 25 that t rar.s ;tt ed TRO/TER deficiencies to 0. .
417 C,_ <ao
2286201
.3 BRT 1 A I guess I am familiar wit'.i the fact that th er e s
2 was a t: smission of this TER: right. I don't know the 3 date.
4 o What actions did you take to assure that the 5 deficie: .es were corrected, if any?
6 A : wasn't actively involved in responding to t .at.
7 so I der remember any specific actions.
8 Q Was there any supervision above Mr. Maus that 9 was actively involved, to your knowledge, in responding to 10 that?
11 A No. He was working pretty much, you know, with 12 licensin at that time. He was not getting a lot of 13 supervir.on from me, or, you know, from anyone in the 14 techniet organization, that I k now o f .
15 Q In talking with Mr. Maus, he advised that in the 16 summer cf '83, that QA did an audit -- or he didn't call 17 it an au'it --
18 MR. LA GRANGE: A "look- s ee . "
19 BY MR. MATAKAS:
20 Q -
a look-see int e TER deficiencies and EO f. . +s .
21 Are you e of any such le:k-see?
22 A .:o . I don't remember that.
23 Q Do you have any information at all regarding 24 this par .cular audit and the follow-up on it -- if it was f 25 ignorei. .: why ' the deficiencies stayed open for such a
22002.1 19 BRT 1 long time? Do you have any information at all ir. that 2 area?
3 -
A No, I don't.
4 Q What I would like to show you now is two letters 5 sent f rom GPU to NRR. I would like you to take & look at 6 them.
7 "he first document is dated May 20, 1983. 7..e letter 8 number is 5211-83-157. And it was signed by Mr. Hukill.
9 It was writ '.en by Licensing out of Parsippa::y.
10 The second one is a February 10, 1984 letter, letter 11 number 52211-34-2038, signed by Mr. Toole for Mr. Hukill .
12 Both of them are in regards to environmental cualification 13 of electrical equipment at TMI-l?
14 A Y es . Yes, I have look ed at these.
15 Q Okay. First of all, regarding the May 20, 1983 16 document, did you have any input into that document?
17 A It says here I did.
18 o When you say "it says here you did," are you 19 looking at --
it just looks like a memo dat ed May 16, 1983.
20 It looks like it's signed by a Mr. 2.E. Ha rtma n - or that 21 cc . ment --
I'm sorry, signed by Mr. Smyth: S-m ';-t-h, who 22 is in Licensing out at the site, TMI-l?
23 A I have looked at this and I don't recall having 24 any input to it. I don't recall anything like this.
25 0 Did you ever discuss th s. - documen: .u - Mr. Maus
2286201 20 BRT 1 or Mr. Boucher?
2 A I don't have a specific recollection talking 3 about it. I might have. No rmally , if something went out 4 like this and I had to - you know, I had to look at it, I 5 would, if it was this or some other subject, I would get 6 the person who was immediately responsible for it and at 7 least try to understand what it was that was going out.
8 Q Do you know what that was in response to, th e 9 May 20th document?
10 A Well, I'd have to read the letter, and -- j u s t 11 from the contents of the letter -- but of fhand, without 12 looking at it again --
13 0 The first paragraph sort of spells it out.
14 A Okay. It's in response to an NRC letter of 15 Karch 30, 19837 16 Q I think it goes a 1.it';1e - that 's part of it.
17 And more so in response to 10 CFR 50.49(g), was the actual 18 r ,,irement.
19 A Okay.
20 0 But you don't specifically recall?
21 A No.
22 O What would your normal review consist of? ,
23 A It depends on how closely I was involved in the 24 subject. I think in nost cases, you know, I would talk to 25 the person who prepared the input or, if it was not
i 22862.1 21 ,
BRT l
1 prepared by him, if we were responsible for reviewing it, t
2 I would have the responsible person review it and try to 3 understand, you know, what the bssis of what we say in the 4 lettar was.
5 Q At any time did either Mr. Maus or Mr. Boucher 6 express to you that they were having problems trying to 7 understand what was needed for qualification, 8 documentation? What documentat[ ion was needed for 9 qualification of certain components within the scope of 10 the environmental qualification program?
11 A I don't recall that.
12 O If you would look at the February 10, 1984 13 letter -- did you have any input into that letter?
14 A so. I don't recall any.
15 0 Do you recall reviewing the letter prior to it 16 going out?
17 A I have no specific recollection.
18 O Sp ecifically , the two statements in these 19 letters that we are concerned about: in the May 20th 20 letter the statement that "the additional information we 21 submitted in our letters support our conclusions that th e 22 compor.alts listed are qualified in accordance with DOR 23 guidelines dated Nove:nber 1979; and then the February 10, 24 1984 letters the last rentence, which states: "It is 25 GPUN's position that TMI-1 is currently in compliance with
22862.1 22 BRT 1 the environmental qualification rule 10 CFR 50.49 as 2 applicable to THI-1."
3 Is there any information you have now where you would 4 question any of those statements?
5 A I think we -- I think we believed those 6 statements at the time.
7 You know, certainly there were -- the degree of 8 documentation and the degree of auditability that, you 9 know, was subsequently agreed to be required, was not met 10 at that time.
11 Q Okay. You are saying that th ere wer e 12 auditability requirements that came about after these 13 letters that were not in ef f ect when thes e letters came 14 out?
15 A I would say y es .
16 0 what would those be? What requireusents?
- 17 A I'm not talking about r equir ement s . I ' m talking i 18 about the auditability of the files where, you know, 19 certainly they were done at a different level than they 20 existed at that time.
I 21 O I'm afraid I don't understand what you are 22 saying. There is the DOR guid slines. They have been the 23 same since November 19797 l
l 24 A Yes. But I'm not sure that there is specific 25 guidance in the DOR guidelines for what cons ti-t u t es
2286 23 BRT itability. Perhaps there is, but I don't know it.
3 Is there specific guidance now?
A In the DOR guidelines?
Q I don't know. From anywhere.
A I don't know. All I ' m saying is -- I ' m not ing that the requirements changed. I'm saying that t we did change and the criteria that we u.s ed for itability and documentation are different now than they e th en .
O What was that a result of? What tr e th es e nges a result o f?
A It was a result, I think, primarily of the NRC's
> satisfaction with what we had.
O I'm looking at pag e 7 of 10 . of th e 81 -0 2 au dit .
Under number 1 it says, 'No evidence of direction for I reviet of qualification data. This conceru is related the extent of GPU review, com ent , resolution of ments, approval and incorporation of vendor documents.
unples of evidence examined which caus es concern are -
I it lists A through F.
Number 2, "IE Bulletin requires that ongoing programs uld exist at the plant to review surveillance and ntenance records. to assure that equipment which is ibiting age-Yelated degradation will be identified and laced as necessary. There was ne document ed evidence e
s
~
22862.1 24 BRT 1
in the central file of a schedule (s) to assure that 2 equipment which has been identified as being susceptible 3 to significant degradation due to thermal and radiation 4 aging are replaced as necessary."
5 And, number 3 : "IE Bulletin requires that complete and 6 auditable records must be available and maintained at a 7 central location and must be updated and Saintained 8 current as equipm ent is replaced, furth er t es t ed, or 9 otherwis e further qualified. In reviewing existing GPU 10 procedures ( engineering standards and engineers procedures ),
11 th ey do not provide appropriate guidance, nor is th er e a 12 program initiated to meet this requirement. " That's 13 really saying the Etne thing?
14 A so, it does not.
15 Q What's the same thing?
16 A I think the subject you are talking about there 17 is the replacement of equipment at the plant. Not a file 18 to demonstrate qualification.
19 0 Which one of those are we talking about?
20 A The last one you read.
21 O "IE Bulletin requires that complete and 22 auditable records must be available and maintained at a 23 central location - "
t 24 A Oh, I ' m sorry. When you read it you read the 25 whole thing as one. I put it in the context -- yes, I
22862.1 25 BRT 1 would say they are talking mostly about --
I would 2 interpret this that they are talking mostly about the 3 r epla c ement program at the plant .
4 Q The first sentence under namber 2 does state 5 that. But it goes on to say there is no document evidence 6 in the central file --
7 A Of a schedule to assure that eq uipment which has a been identified as being susceptible to degradation are 9 replaced as necessary.
10 Q In the first place they are talking about a 11 program at the plant and in the second place they are 12 talking about documentation and document ed evidence in the .
13 central file of schedules. And the central file is here 14 in Parsippany; is that correct?
15 A Yes. But w e ' ve switch ed subjects a little bit.
16 we started out by talking about the documentation to 17 demonstrate that equipment is qualified. And here they 18 are talking about documentation or evidence that we are .
19 replacing things at the plant as required, which is really 20 a different subject, I think.
21 O Well, getting back to number 1, the examples ,
22 given: "EDS calculation" -- gives a number, "revision 0, 23 is not properly signed and reviewed by EDS."
24 "EDS project instruction in volume 1 A are not signed l 25 and approved by EDS . "
22862.1 26 BRT 1 What they are talking about is documentation, if you 2 want to read the examples under number l?
3 A I think there they are probably tal'r.ir.g about ,
4 you know, quality control and establishing reviews and so 5 forth, rather than establishing documentation.
6 0 We can go on to page 8 of 10. To me, under 7 number 5 it says, "IE Bulletin requires that compl et e and 8 auditable records must be available *'or qualification; and 9 to be considered valid, these records should describe th e 10 qualification method in sufficient detail to verify that 11 all the guidelines have been satisfied. Deficiencies 12 found in completeness and acceptability are as 13 follows -- and they go on to list that. They go on to 14 talk, in the rest of that, documentation. It's s o rt of 15 the central issue in all these findings .
l 16 Did you review the NRC audit that was trananitt ed to 17 the utility on April 25, 1984?
1 18 A Yes. I think I did.
1 19 0 It sounds to me like very similar findings. If 20 you look at the attachment, the pac 9 you are looking at i 21 there, under number 1 it says, "EQ files show no l
l 22 indications other than SCEW sheets, some of which were in 23 the process of being revised and some handwritten sheets, 24 that the documentation had been reviewed by GPU nor that 25 it had been con:luded by GPU that the equipmen- is
22862.1 27 BRT 1 qualified."
2 It goes on to state, "Mos* f the handwritten material 3 in the files is not signed c- s t ed a nd shows no 4 indication that the statement s information contained on 5 the sheets, has ever been ver ind by a checker or 6 approved." Very similar to I e of th e findings in the 7 audit?
8 A Yes. Again, that a sort of a quality control 9 comment which do es n ' t necessarily relate to the extent or 10 the adequacy of the documentat ion. It ma y -- i t does ask 11 questions about wh eth er th es e things were reviewed and 12 that sort of thing. And, I a r ee --
13 0 It's talking about .acumentation, is what I'm 14 saying.
15 A Documentation is -- you know --
16 MR. MATAKAS: Did yea have any questions, Bob?
l 17 BY MR . LA GRANGE:
l 18 o I just want ed to s; there are findir.gs 19 throughout this audit 81-02, .at talks about inad equat e 20 documentation to show the eq. ent is qualified. On 21 various findings -- finding 4 .he finding concludes aise 22 lack of document qualificatic - in the central file for 23 these components."
24 If you go through these y: . 11 see examples of where it 25 vent beyond just the auditar .ty and the procedures, int:
22862.1 28 BRT 1 the actual documentation in the files.
2 With regard to the May 20, 1983 letter to the NRC, and 3 the February 10, 1984 letter t o the ::RC, you said you did 4 not concur in those letters prior to their being issued to 5 the NRC7 6 A I didn't say chat . I said I had no recollection 7 of any input I had into those letters.
8 If I concurred with th em, it would have been to, you 9 know, have Gerry Maus look at it and we might have 10 discus s ed it with him to see that he was satis fied with 11 what was in there.
12 0 would that be unusual, for you not to have been 13 a sk ed for input into letters such as these?
14 A I may have been asked for input, but that 15 doesn't mean that I personally prepared the input. It 16 would mean that I probably would assign it to somebody who l
17 was knowledgeable about it.
18 o Did you ever personally review any EQ files at
! 19 any time?
20 A Not in this time frame; no. Later on when the 1
21 files were being updated, I did upgrade it.
22 O Prior to -- well, at any time, did you provide 23 guidance to Maus or Boucher as to what constitut es 24 adequate documentation?
l 25 A or.ly a.f r er the period where I be:are more l
22962.1 29 BRT 1 actively i rolved in this, which was, I guess, cometime 1
1 2 early in , 4.
3 0 . o r t :> t. hat t i .- . e , would it be an accurat e 4 s ta t ement s say that EQ was not a high visibility, hot 5 item, so - : peak, in which you spent very little if any 6 time invo: 1 with?
7 A om my personal point of view, I did not spend 8 much time . EO .
9 Q Did Mr. Maus, in his capacity as EQ manager, did 10 he keep you informed of problem areas and discuss with you 11 possible er rses of action to resolve problem areas in EO?
12 A : guess in a general way; yes. I can't reme=ber 13 any speci: . problems or any specific discussions. But we 14 had, you -
periodic discussions, in a general way, as 15 to what was going on.
16 Q ::d you inform Mr. Maus that he was no longer C 17 manager whin he was r el ea s ed from that position?
18 A . think Don Cronenberger did that. Y <
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22 A ..ething lik e that .
23 0 .: you know why he was taken off that job?
24 A . 1, I think there were a number of reasons. M
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11 "M1h 12 BY MR. LA GRA.NGE:
13 . But you are fairl, aware, new, of what is in the 14 c u .- +nt TMI-1 EQ file?
15 A Yes, I am.
16 0 Is it an accurate statement to say that a lot of 17 that docu:nentation in the files is dated subs equent to the 18 f1: - NRC audit, May of '84 --
March of '84?
19 "Is dated" did you say?
20 A lot of the docu entation is dated subsequent 21 to March NRC audit?
22 Yes. The files w- e completely redone 23 sui quent to that.
24 Would you say tha- in your opinion that 25 de- entation currently i.. -here is d:c.=entation Oi
2:54 2.1 BR7 1 necessary to establish that the equipment is qualified?
2 A I don't know. I can't say that everything i r.
3 there is necessary. By th e criteria that w e ha v e me.-
4 a g r e ed to -- a nd I ' m not interpreting the regulations --
5 we agreed, internally, that we were going to require
- 6 certain documentations and a certain level of completen-7 in the files. And by those criteria, it is r equi r ed .
8- Those criteria, you know, didn't exist, or at lea st 9 didn't have agreement on them in 1982 and 1983.
10 Q If that more r ec ent documentation was renov ed 11 from those files and did not exist, do you feel that the 12 filea would still contain ad equate evidence that the 13 equipment is qualified?
14 A Again, you know, you have to establish and a c .-
15 to what the criteria is for adequate evidence. You kno-16 it's not crystal clear from reading the regulations. Ar.
17 it's certainly open to a lot of interpretation, what 18 people will accept.
19 I guess we came to some conclusions about what people 20 would accept and we upgraded our files to meet that.
1 l
l 21 BY MR. MATAKAS:
22 O Were you aware of any deficiencies that relate l 23 to qualification that were noted in the TER that were ne 24 corrected by the time the NRC inspected in March, ?? -21 :
l l
25 1984, regarding aging or similarity, which is a definit <
22862.1 32 BRT 1 r equir ement for qualification? Where the documentation i
2 just did not exist?
3 A You know, things are just not that cut and dried.
4 I have been an engineer for a long time. And the kind of 5 evidence and the kind of almost legal basis for 6 :::clusions that were established in this EQ program are 7 .c. to me. I have never seen anything like it before. So 8 things are not that cut and dried. And I have repeated 9 four or five times that one has to establish criteria for, 10 ,ou know, what people will accept.
11 Once ve accepted those criteria we updated the files.
12 BY MR. LA GRANGE:
13 o You are familiar with the audit findings as 14 id enti fi ed in the April 25, '84 letter?
15 A That was the NRC letter?
16 Q Right.
17 A Y es . I am.
18 Q There were some specific findings in the 19 atta chment to that letter. Do you have think that those
- 20 findings are unreasonable?
21 A i
I can't --
I would not use the word "unreasonable."
22 And I certainly can't characterize any of them without 23 ' :-oking at them specifically.
l 24 I'm saying that, in general, the level of specific 25 e.udence that's required to draw conclusions in this
22862.1 BRT 33 1
program is without precedent, in my opinion. But, once we 2 accepted that level that was required, we tried to meet it.
3 I can, in my ord: ry dealings as an engineer, : can 4 draw conclusions, you know, based upon my knowledge and 5 some evidence and so forth.
6 If every design that was done around here required the 7
kind of backup that this program did, you know, it would 8 never get done. I'm not saying that's unreasonable, it's 9 just different. And it is difficult now, from this 10 perspective, to go back two or three years and try to 11 defend what we did th en , because the perspective is 12 different. The criteria are different.
13 (Discussion off the record.)
14 BY MR. M.ATAKAS :
15 Q I think one of the main problems I see is tha t 16 back in 1981, t. hat particular audit that identified very 17 similar programmatic problems that later on, in subs equent t
18 audits, and even in that audit, identified specific 19 instances that fit into those programmatic proble=s, such 1
l 20 as the overall probic of documentation, tney gave a lot 21 of similar -- a lot c specific examples, as did later 22 inspections by the NF .
23 What did it tak e to make a commitment by GPU to turn i
24 this program around?
25 A :t took C - realization tha- what we ha d was not l
l
2'2862.1 36 BRT 1 if the recommendations are not going t o be followed?
2 Tha t 's wh a t bothers me. I don't k no e , if you want to 3 comment on -?
4 A I really can't comment on that.
5 Q Be ause they were looking at the same paperwork 6 that th e EC section was. And they were making 7 recommendations bas ed on that paperverk which was the IE 8 Bulletin, tne DOR guidelines. I don't think 10 CFR 50.49 9 came out yet?
10 MR. LA GRANGE: In our first audit they did .
11 MR. KATAKAS: On your first audit; but not back 12 in 1981.
13 MR. LA GRANGE: That's correct.
14 ME. MATAKAS: Do you have any other questions?
15 MR. LA GRANGE: Yes . Are you aware of what 16 activity took place following receipt of the NRC's SER, 17 bas ed on its evaluation of the response to 79-01 B7 Th er e 18 were deficiencies identified in there.
19 A I'm sorry, I didn' t understand. Which --
20 0 Prior to the Franklin TER being issued --
21 A Y4 .
22 0 --
eith the December 10, 1952 SER, from the NRC, 23 there had been a previous SER provided to GPU based upon 24 th e NRC ' s e.aluation of the 79-01 B responses.
25 Are you .eare of what activity or: rred as a result of
i l
22862.1 37 BRT 1 that SER identifying deficiencies?
2 A No. I don't remember.
3 0 Did you ever personally review the T 9.lin TER?
4 A I might have looked at it 5 BY MR. MATAKAS:
6 0 Did either Mr. Maus or Mr. Boucher, +cen 7 recently, talk to you about the May 20, 1983 d: : ment ?
8 A Recently?
9 0 Y es . or at any time, as recently as this 10 morning? or any time before this morning?
11 A No. I haven't had any discussions with anybody 12 about this document recently; I mean, "recently" being the 13 last, you know, six months or anything like C..a .
14 0 okay. Do you recall any discussi:ns ith 15 Mr. Maus or Boucher, regarding the May 20 document during 16 the time it was issu ed?
17 A I don' t have any specific recollection of 18 talking to them about it. I may have talked :: th em a bou t 19 it, reviewing it before it went out.
20 0 Do you have any specific recollectier f talking 21 to either of those individuals regarding the Fe try 10 22 document, of 1984?
23 A No.
24 Q Are you aware of anyone either inter. . :nally 25 lying or attempting to deceive the NRC, relat:- te either
'22862.1 38 BRT 1 of these documents?
(
2 A No.
3 O Just one other quick question. When you s t a rt ed 4 contracting this program out, environmental qualification 5 program, approximately how many people did you have 6 working on it? And I'm talking about TMI-17 7 A What time would this be?
8 0 I'm not sure. When you started contracting it 9 out.
10 A Well, part of it had always been contracted out, 11 I think. I 'think IMPELL or their predecessor company did 12 a lot of work in the early stages.
13 0 I'm talking about after the NRC audit?
14 A Early in 1984?
15 Q Mid-19 -- yes.
16 A Well, at one time we -- a nd I don ' t know what 17 that point was -- but we had a lot of people working on it .
18 We had almost --
let's see, my group is about 20 - s om e- od d .
19 There were times during that period where over half of the 20 people were working on it.
21 O In retrospect, looking at the work that was done 22 under what you agreed to, do you feel that during the time 23 that Mr. Maus and Mr. Boucher were working on that project, 24 they could have completed that same work?
25 A No.
22862.1 39 BRT 1 MR. MATAKAS: Any other questions?
2 MR. LA G RANGE : Let me think just a second.
3 :Discussior, off '.e r eco rd ., )
4 BY MR. LA GRANGE:
5 0 Bas ed on your knowledge of what is currently ir.
6 th e TM I-l E 2 fil e s , do you feel what you had in there 7 previously was adequate to document qualification of the 8 equipment?
9 A Again, I'd have to say it depends on your level 10 of -- what your criteria is for an acceptable level of 11 documentat on.
12 0 : think I'm just asking for a personal opinion.
13 A You know, I can't give you a personal opinion 14 other than that. You can't, you know, a s k tha t out of 15 cont ext .
16 Q W ell, I ' m not sure what that means.
17 37 MR. MATAKAS:
18 0 Was this thing se confusing at first that a 19 person could not understand what was needed to qualify the 20 individual components for the requirements that were l 21 listed? And I mean require.ents like aging, radiation, 22 and whatever? I'm not an engineer. I'm asking you.
23 A No, it is not confusing, but again, it is not l 24 obvious frca looking at the regulations alone, you know, 25 that the le. el of documert s-ion that we now have is
(
)
t
22662 1 40 BRT 1 r eq uir ed .
f 2 O In your review of files, specifically TER 3 deficiencies, or th se components that may have bee..
4 identified in the TER, did you come across any component --
5 any documentation fer any component that was just 6 completely lacking? Where there did not appear to ha.e 7 been an attempt made to put anything in the file except a 8 SCEW sheet maybe?
9 A No. I don't recall I found anything like that.
10 BY MR. LA GRANGE:
11 Q Would you characterize any of the documentation 12 currently in the files as unnecessary?
13 A I wouldn't cha ra c t eriz e it as unn ec es sa ry .
14 Again, if your crit eria for documentation is at a c art ain 15 level, th en it 's necessary to meet that.
16 Q No, personally, do you think it 's unnecessary?
17 A You know, I can't give you a personal opinien 18 except that. I can say, to compare it to something else, l
19 that in areas other than EQ if you try to demonstrate that 20 a component in the plant is adequate to meet its function, l
21 you are not going to find that kind of documentation on
(
22 anybody's behalf. E ,cou could draw your own conclusiens.
23 EQ is different.
l 24 (Discussica off the record.)
25 l
l l
22862.1 41 BRT 1 BY MR. LA GRANGE:
2 O Would you say that documentation that is 1
3 appropriate and necessary to demonstrate qualification of 4 equipment is as defined by a corporate policy or judgment 5 of th e individual engineer?
6 A It should be defined by the corporate policy as 7 expressed in its standards and procedures.
8 0 Would you say that documentation would be -- the 9 amount of documentation necessary to demonstrate 10 qualification is as agreed to by the NRC or as determined 11 by th e individual utility?
12 A I think both of those conditions have to be met.
13 O Do you believe the documentation that exi st ed in 14 the files prior to the NRC's initial audit was adequate to l 15 determine documentation of that equipm ent?
1 l 16 A You asked me that before. I'd just have to give 17 you the same answer, which is: What's ad equat e? You know, 18 what will you accept? What was your criteria for ad equate 19 documentation?
20 BY MR. MATAKAS:
21 O Is there now something that tells you what the 22 criteria is for documentation?
23 A Yes. We now have a procedure which tells you 24 how to =ake up a file and what it should contain.
l 25 0 Who is responsible?
i l
1 2'2862.1 42 BRT l
j 1 A Who is responsible; that's correct.
2 O Is this a corporate position on the bulletin?
3 A You know, it's our internal procedures which l
4 reflect the corporate position.
5 Q I keep going back to this 1981 audit. It really 6 bothers me, on page 10'of 10, one of the recommendations 7 was "Documented direction be generated in order to assure 8 meeting the requirements of the bulletin, to include j 9 organizations, departments , sections and individuals l
l 10 (headquarters and site personnel. This should include 11 interface responsibilities and define the corporate 12 position on the bulletin.
13 "2: A complete review should be taken to assure that 14 the qualification documentation is complete to support l 15 adequacy of the quipment.
I 16 "3: Technical functions take the lead in establishing 17 a training program for corporate and site personnel in th e 18 requirements of the bulletin. "
19 It sort of addresses all of the problems that later 20 were addressed af ter, at the NRC audit, and the QA people l 21 had the same documents to work with that the EQ people had 22 to work with, as far as knowing what should be done, 23 although they clearly state that there should be more 24 direction -- I take that to be management directioc.
25 Has this been done now? These recommendations followed?
l 22862.1 43 BRT l
l 1 A I would say they have been. Those -- the 1 2 recommendations you are talking about now there is I 3 establishing the procedures, and I think they have been 4 established.
5 Q Corporate procedure 1000-ADM-7317.017 6 A I don't know.
7 Q Are you familiar with ernergency engineering 8 procedure 0317 9 A Is that the procedure for the EQ program?
10 Q That was the original one?
11 A Yes. Y es .
12 O And then it was issued as corporate procedure?
1 13 A Y es . I am f amiliar with it.
14 O So the corporate procedure is the one that 15 supers eded 0 31, is now the procedure that is now in ef f ect?
18 A Yes . I thi nk it's essentially the same 17 procedure with a diff erent number on it --
different 18 corporate number.
19 MR. MATAKAS: Any other questions, Bob?
20 BY MR. LA GRANGE:
21 O Up until the NRC's first audit you stated there 22 was really little interaction between you and the EQ group.
23 You actively got involv ed , essentially after the first NRC 24 audit?
25 A About that time or shortly before that.
J
22862.1 44 BRT 1 O okay. And, to your knowledge was there interaction 2 between the EQ group and any management level above you?
3 A Well, Cronenberger was involved in some degree.
4 I don't want to speak for him, as to what level. My guess 5 is probably his involvement was about the same as or was 6 less than mine.
7 0 lt's accurate, th en , to characterize EQ, the EQ 8 program at GPU for TMI-l as really receiving little 9 ma nag ement attention or direction up until the NRC's first 10 audit?
11 A Well, it received a lot less attention.
12 MR. LA GRANGE: I'm done.
13 BY MR. MATAKAS:
14 O Sir, did you appear today of your own free will?
15 A Yes.
16 Q nave any prenaises been made to you?
17 A No.
18 0 Have any threats been directed towards you?
19 A No.
20 0 Is there anything else you'd like to say or any 21 comments you would like to make?
22 A No.
23 HR. MATAKAS: The time is 15:04. This concludes 24 the interview. Thank you very much, sir.
25 e
2286201 45 BRT I (Whereupon, at 3 05
- P.m., the interviW was 2 concluded.)
3 4
5 6
i 7
8 9
10 11 12 13 14 15 16 17 18 19 I 20 l
21 22 f
23 l
24 l
25 l
1 1
CERTIFICATE OF OFFICIAL REPORTEP n
This is to cert:.f y that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY CO!OC5510N in the matter of:
NAME OF PROCEusING: Investigative Interview of:
RICHARD J . CH ISl!OL*4 DOCKET NO.:
PLACE: Parsipanny, New Jersey DATE: Thursday, April 25, 1985 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission, e
(siat A./
(TYPEDk /
f J o c '. Breit.ar Official Reporter Ace-redera' Res Inc.
Reporter's Af fiIorters, iation 4