ML20198H787
| ML20198H787 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1984 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20198H622 | List: |
| References | |
| FOIA-85-59 NUDOCS 8605300558 | |
| Download: ML20198H787 (110) | |
Text
_. - -. -
t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
Investi ative In Mo)
Docket No.
i Location: Arlington, Texas Pages:
1 through 79 Date: Monday, February 27, 1984 TAYLOE ASSOCIATES Euit, :=
?O/A-25-59 8605300558 860513 1625 I s PDR FOIA Wuhimpos. D.C. 2206 GARDE 85-59 PDR Cc21 s M 950
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I UNITEO S A IS OF IEERICA i
2 I
NUCLEAR REGUI.ATORY COMMISSION I
l s
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _x l
i l
l In the matter of:
4 5
Investicative Interview of 6
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 7
8
~
Suite 835
'~
Ell'Ryan Plaza Drive
}
l Arlington, Texas Monday, February 27, 1984 i
11 The above-entitled interview co-caenced at
{
12 1:35 p.m.,
pursuant to notice.
13
' 337933 14 H. BROOKS GRIFFIN, Investigator DONALD D.
DRISKILL, Investigator
'S Office of Investigations l
U.S. Nuclear Regulatory Co::=ission i
16 i
Region IV Suite 1000 II 611 Ryan Plaza Drive Arlincton, Texas 76011 IS I
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l i
19 20 21 l
22 l
1 I
- 3 24 O
e 6
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P,R, O C E E D_ I [.C,5 l
2 MR. GRIFFIN:
For the record, this is an inter-i 3
view of who is employed by Brown I
4 and Root, Incorporated --
5 That's correct.
6 I
MR. GRIFFIN:
-- at Comanche Peak Steam and Elec-
)
l l tric Station.
The location of this interview is the HRC 7
6 hegion'IV Office of Inv'estigations in Arlington, Texas.
9 Present at this interview are s
i 10 Mr. Charnoff and Mr. Jordan,
>cth attorneys for 11
.n this matter, --
12 I
MR. CFARNOFF:
Yes, that's right.
I i
13 MR. GRIFFIN:
-- Don Driskill and Brocks Griffin 1
(9 14 for the NRC; and, of course, the court reporter, Judith 15 Tcberman.
l 16 This interview is being transcribed by a court 17 reporter.
The subject of this interview concerns, among i
is other things, 19 20 l
Before we go into the interview
- 1 i
22 I want to ask you some cuestions about your atterneys.
23 Are you represented here today?
I 24 Yes, sir, Ia.
25 MR. GRIFFIN:
Who is'your representative?
1 e
I
~
3 l
- y representative?
2 l
MR. CHAEKOFF: -Can he answer that in the plural?
l 3
MR. GRIFFIN:
Yes.
4 Both of these gentlemen, 7.r.
l Jordar an$i Gerry.
5 6
MR. GRIFFIN:
Mr. Charnoff, do you agree with l
7 hat you are representing him as'an individual 8
in this proceeding?
9 MR. CHARNOFF:
That's right; absolutely.
1 10 l
MR. GRIFFIK:
Are vou also retained as counsel to 11 3rown and Root?
I 12 MR. CFJ.RNOFF :
Yes, from time to time.
Q 13 MR. GRIFFIN:
Are you presently, at this time, re-14 l
tained?
15
{
MR. CHAREOFF:
Yes, on matters not related to 1
16 Comanche Peak I am, yes.
17
- 13. GRIFFIN:
Mr. Jordan, do you perscnally repre-18 sent individually in this matter?
Yes, I do.
20 MR. GTCFFIN:
Oo you also have a continuing 21 business relationship as counsel to Brown and Root?
22 MR. JOROAN:
Yes, I do.
23 MR. GRIFFIN:
o Mr. Charnoff and 24 Mr. Jordan -- is it your understanding that they represent 25 you individually?
l t
I
+
1 Yes, it is.
2 MR. GRIFFIN:
Has anybofy told you or instructed 3
j you to have Mr. Jordan and Mr. Charnoff as your personal i
l representative?
4 5
No; not by name, no.
6 MR. GRIFFIN:
What instructions did you receive l
1 7
regarding counsel?
8
.s b e s t' -I recall, it was las:
9 l
Thursday John Merritt told me that I needed to get my own 10 counsel; that the TUGCO lawyers would no longer be involved.
I 11 I think that was Thursday.
12
]
MR. GRIFFIN:
How did you select your counsel?
13 Through an appeal to our Project l
Managere through Doug Frankum.
14 I
15 i
MR. GRIFFIN:
You asked Mr. Frankum what?
I 16 I said I needed some legal 17 counsel.
18 MR. GRIFFIN:
Did he recommend Mr. Charnoff?
19 No, he didn't; he didn't recommend anybody.
91 MR. GRIFFIN:
Then could you expand on that a 22 little bit; how did you go about picking your counsel?
Then I got a call from Sill.
24 Bed:Ean, who is a Brown and Root attorney.
He said that 25 Mr. Jordan would be giving.me a' call.
.'d l
1 ME. GRIFF:K:
So Brown and Root arranged fcr your 2
' counsel.
3 fir. Bedman did, I assume; yes.
l 4
MR. GRIFFIN:
Obviously, you are aware of Brown i
5 and Root's position or commitment regarding construction and 6
licensing proceedings at Comanche Peak.
As this interview l proceeds, do you believe that the advice that you will re-7 i
i 8
~ceive from'Mr. Charnof'f'or Mr. Jordan would be' representing i
9 Brown and Root or representing you?
What is your 1
\\
10 understanding?
11 l
They will be representing me.
12 MR. GRIFFIN:
If a conflict of interest er a 13 potential conflict of interest were to arise between Brown
))
14 and Root policy or what is good for Brown and Root versus 15 what is good for you, what is your understanding with your 16 attorneys?
17 If there was a conflict of 18 interest, they would be obligated to report that conflict.
i 19 MR. GRIFFIN:
To whom?
l To Brown and Root, if something 21 i
I did was in conflict with Brown and Root.
22 MR. GRIFFIN:
I'm sorry; you've misunderstood 23 what I said.
If there is a conflict between their repre-i 24 senting Brown and Root and representing you, what have they 25
~
told you will be their advice to you?
e w-
~
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' ~~
C 1
I don't know that we've discussed i
2 that.
The only conflict of interest that I'm aware of is if l j
i 1
3 i
I did something that was not in the best interest of Brown 4
cnd Root, then they would be obligated to inform Brown and-5 Root about it.
6 MR. GRIFFIN:
So they are representing Brown and i
7 Root here today?
l
~~
8
~
They're representing me today.
9 MR. GRIFFIN:
But you just said that they would I
l 10 be informing Brown and Root of the conflict.
Now, are they l
11 reoresentinc you, or are they re=resentine Brown and P. cot i
12 today?
13 4
They are representing me.
14 MR. GRIFFIN:
And you think if a conflict should 15 arise that their advice will be in behalf of Brown and Root 16 l
or in your behalf?
II It should be in my behalf.
18 MR. GRIFFIN:
Mr. Charnoff, what is your under-19 standing; should a conflict arise, what would be your course of' action as relates to 21 MR. CHAPSOFF:
Let 'e answer that but also tell m
22 you what I told Mr. Hutchinson this morning.
One is I did 23 advise that was free to come to see you 24
~
with his own attorney, that is, not anybody furnished by Brown and Root is free not' to see you if lects not to
see you; is free to use us and we would be I
ttorneys 2
furnished by Brown and Root; that we are also counsel to 1
t 3
Brown and Root and if there were.a conflict of interest that l we would see, we would have to withdraw from the case, and 4
l we would so tell at that point.
5 I
6 One of the purposes of the preliminary interview 7
this morning was to determine if there is or is not a con-l flict.' We' have deterinined so far that there is no conflict.
~~
B I
9 I think that answers your question.
10 MR. GRIFFIN:
Mr. Jordan, what is your under-11 I
standing of potential conflict of interest between inquiries 1
12 we might make of versus your position as a 13 Brewn and Root attorney?
n 14 MR. JORDAN:
My position and understanding is the 15 same as stated by Mr. Charnoff.
I 16 l
MR. GRIFFIN:
What would you do if you perceived I,
II l
a conflict of interest in the course of this interview?
I 18 I
What would you individually do?
i i
19 MR. JORDAN:
In the course of this interview?
MR. GRIFFIN:
Yes.
21 MR. JORDAN:
I would ask for a recess and I would-22 advis at that moment that I had just learned 23 of a possible conflict.
I would explain to him what 24 i
legal rights were with respect to this interview and go for-ward from there based on what desired to do.
O e
l
i 3
MR. GRIFFIN:
So, these twc gentle l
2 men represent you in this matter, but you also realize that 1
ltheyareretainedbyBrownandRoot?'
3 4
Yes, sir.
5 MR. GRIFFIN:
Who is going to pay for their ser-6 vices as relates to their work here today?
Are you going to I
l 7
pay for their services?
8 That-hasn't been discussed.
l 9
l MR. GRIFFIN:
And these two gentlemen were selected l
l 10 l as your counsel by Mr.
11 Yr. Bedman.
12 MR. CHARNOFF:
Let ce make it clear, I hope Brown
)
13 and Root will cav us for our services.
l
' ~
k 14 That hasn't been discussed.
l 15 MR. CHARNOFF:
Let's be clear.
Brown and Root is I
16 l paying us to provide the services t so long I
17 i
as
- ants our services to represent IS MR. GRIFFIN:
would you please 19 rise and raise your right hand?
We're going to swear you to 20 the contents of your testimony.
21 Whereupon, 23 was called for examination and, having been first duly s, worn, 24 was examined and testified as follows:
.y, I
l
i "E
I 1
_I _X _A _M _I _N _A _T _I _C _N i
2 BY MR. GRIFFIN:
j I
3 l
0 I would like to begin ray questions for you, y asking you how you are currently er. ployed?!
4 5
A I am for Brown
'6 and Root.
9 L
That's correct.
j 10 l
0 ktat duties are involved in your work?
What are l
your duties?
11 I
12 A
I'm directly responsible for three groups, 13 9
14 L
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15 4
Who is your immediate subordinate in 16 17 g
16 i
0 What is his title?
18 L
l 0
Who is your immediate supervisor?
21 A
Presently, it's What is h title?
O 25 C
And that is Texas Utility' Service, Incorporated?
s:
N 3
L Yes.
2 l
Q do you have direct supervision 3
over the employees of the 4
L I have that supervision throuc ves.
I 5
0 In the course of your daily activities, do you 6
ever give instructions to individuals in the Document Control 7
! Center?
8
~
L' Not as a r'le,'no; but it does happen, yes.
9 Q
Are you f amiliar with the daily activities of the 10 Document Control Center?
l 11 A
l l
I've got a lot of people to look after, a u
5))
l lot of different groups, and I know essentially what goes en; 13 D\\
14 not to the nuts and bolts level, no.
15 0
Are you aware of the contract by T*JGCO -- that is 16 Texas Utilities Generating Company -- their contract with 17 j
Cygna?
Are you familiar with this contract?
I 18 L
No; I know that one exists.
19 O
Mo, but you know one exists?
l e
20 L
I'm not fEmiliar with the nuts and the bolts of 21 the contract.
22 g
I'm not asking you about the nuts and the bolts.
23 Are you familiar, are you aware that there is a contract be-j tween.TUGCO and an audit group called Cygna?
24 1
25 A
Yes, I am.
e
~.0 l
9~
1 O
As relates to the Docume..t Control Center, do you 2
know what the contract entailed, generally speaking?
3 A
I knew that that was part of the verification 4
i effort they were going to do when they came down the first 1
5 time.
They' vere going to look at the Document Control 6
Center.
Beyond that, I don't know.
I 7
O So one of the functions of the Cygna review was can I'use the word, audit the Document Control Center; is 8
to, 9
I that correct?
10 L
Correct.
I 11 l
C What was your knowledge of the origins 1lpjgE)
I i
12 Cygna contract?
Were you aware that they were going 43Pbe 13 retained before the contract was given?
14 i
No.
15 C
Were you consulted by anybody in TUGCO?
I 16 L
ge, 17 G
When did you become aware that Cygna was going to 18
.do an audit of the Document Control Center?
19 A
Probably, just a few days before they came.
They 20 came in July, O
Are you aware of wh'at the Cygna representatives l
21 22 did during their July visit as relates to Document Control?
23 L
I know generally what they did, yes.
- 4 O
Could you tell me what that is, briefly?
15 L
As I recall, they looked at design change logs e
131 1
and verified or tried to varify that the master logs in DOC l matched other logs that were kept up by the file custodians.
2 3
0 Are you aware of the satellite concept implemented 4
! in the spin-offs from the Document Control Center?
~
5 A
Yes.
6 O
Did Cygna's review in July involve auditing the 7
capacity or capability of the satellites and their' function?
boyouunderstandwhatI'msaying?
8
^
8 A
Yes.
When Cygna was there in July the satellites 10 were in the infancy stage; they weren't set up yet.
II j
G Did Cygna make any inquiries or did they'" attempt 12 to evaluate that system?
I 13
^
A As I recall, they may have asked some questions, I4 but I don't know about any evaluation, you know, "Where are 15 you going with it?"
16 I
O Document Control was, I believe, in a state of I
change from the centralized system Document Control Center to 18 I
l this satellite concept at that time; is that right?
19 A
That's right.
20 0
If their audit involved reviewing Document Control, 21 i
l then they would necessarily ha6e to evaluate the system that was being prepared.
I'm asking you:
were they tasked with 23 evaluating the satellite concept and its implementatich?'
~
24 A
liot that I'm aware of, no.
25
~
g As relates to Document Control, did the Cygna
f22 1
review invcive evaluation of the computer system?
2 MR. CEARNOFF:
Again, we're in July 1983?
3 MR. GRIFFIN:
Yes.
4 THE WITNESS:
The only computer system they could 5
have looked at then would have been the one that had the I
i 6
. drawings on it.
I 7
BY MR. GRIFFIN:
8 O
Was that part of their review?
9 A
I don't recall.
1 O
Cygna also returned in November; is that correct?
10
}Areyouawareofthat?
11 12 A
In November?
l 13 0
Yes.
l 14 A
They were back in October.
15 j
0 What was the purpose of their October visit then?
l 16 A
As I understood it, they were there to re-verify 17 some of the findings they had in July, to make sure that we 18 had the satellites in position and set up and that we had 19 merged the design change logs into a computer base.
20 0
So they were evaluating the satellite system and 21 the use of the computer for keeping up with --
22 A
-- design changes.
23 0
Design changes only, or did the computer system 24 also contain the design drawings?
i.
25 A
The computer system for the drawings is already in e
w,
i 4
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1 2
place.
It's been in place for several years.
2 g
so the system contained the ongoing changes re-lated to these drawings that were already in the ecmputer?
3 i
I 4
A Say that one more time.
I 5
g so their' audit or evaluation had to do with the 6
design changes of the existing drawings?
7 The computerized portion of the design-changes, 8
yes.
9 0
Do you happen to know if Cygna's review also in-I 10 l cluded design verification?
.l 11 A
I'm almost sure that it did, but beyond that I E
12 don' t know what -- I know they went up and I think they 13 talked to the DCTG Group.
14 g
Was it during this second visit that we're speak-15 ing o: right now that you were given the list of drawing l numbers that Cygna wanted to review?
16 I think you were 17 j allegedly given this list on October 24, 1983; is that 16 cc eeg7 19 L
That's correct.
{
20 0
Who gave you this list?
21 A
Nancy Williams.
22 O
Who is Nancy Williams?
23 A
She is with Cygna.
24 Q
Do you know what her capacity with Cygna is?
26 A
She was in charge of the audit.
4
i d14 1
O The whole audit or just the part that pertainef
! to Document Control?
2 3
L I think she had the whole thing.
4 0
Where were you when Ms. Williams gave you this 5
l list?
i 6
L I was in my office.
7 0
On-site'; is that correct?
8 L
That's right.
~
~
8 0
Do you remember what time of 6ay it was on the 24tl,'
10 A
Some time in the afternoon.
11 k
l G
Prior to Ms. Williams giving you this list,
- r. c c l you received any information or any notification from anyone 12 i
13 that this list was going to be provided?
I4 L
No, none that I recall.
15 0
Had you discussed with any of the Cygna repre-16 sentatives the need to receive this list?
17 L
I don't recall having discussed it, no.
18 0
Did you know in advance of her providing you the 18 list of print-outs that they wanted to look at it?
Did any-to body in any manner -- what I'm asking you to do is to tell 21 me whether you had any knowled'ge whatsoever that you were.
22 going to be provided with a list of drawings that Cygna 23 wanted to look at.
24 L
I don't reca.11 anybody discussing it,at all.
25 C
So when Ms. Williams came in and provided you l
d s
23 l
l 1
with this list, this was unplanned as far as you knew?
i 2
A As far as I knew, yes.
I 3
0 What was Ms. Williams' explanation regarding this 4
i list?
t l
l 5
A As I recall, she gave me the list and said, "This
~
I 6
is what we need to see.
We'll be back tomorrow," or some-7 thing to that effect.
8 0
H,ad you on any occasion piior to tha't time re-1 l
11 A
No, not me.
l 12 0
In their previous on-site audits, had they ever 13 l
provided you with similar requests for documentation?
11 14 7.
I don't recall any list in the July audit.
I 15 j
think they provided one in August when they were back for i
)
16 some sort of effort in August.
But not to me; I was gone j
17 that week.
18 g
But you heard from some third party that they 19 provided a list in that instance?
20 A
Yes.
21 0
Do you know, from y6ur information that you re-e,
~~
ceived after you returned from vacation, what the contents of 23 this earlier list were or what it requested?
i g4 A
No, I don't.
But you just heard.frbm somebody that there had O
17 J"16 3
been a previous request?
l A
Yes.
2 I
3 0
Who did you hear this.fror.?
I A
I don't know.
4 1
I l
0 Do you have any information or ahy notes, third 5
6 parties that you can talk to who might jog your medory as to 7
who told you that -they had previously requested a list?
8 MR. CEARNOFF:
That they previously requested a 9
list?
10 MR. GRIFFIN:
I'm asking him if there is anything, l
11 i
any place he can go, anybody he can talk to, who could --
12 THE WITNESS:
I could talk to some of the people 13 that would be in DCC, Frank and some of his people, and ask 14 them about the list.
'15 BY MR. GRIFFIN:
16 1
0 So they might be able to fill in the name?
17 A
Yes.
18 0
on the day that you received the list from Nancy 19 Williams, did she give you any explanation as to what the 20 list was when she handed it to you?
21 A
Nothing more than telling me that 22
- e j
23 O
Describe the piece of paper she gave to you.
24 A
It was a handwritten list.
25 0
What did it contain?
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1 A
As I re~ call, it said she needed the co=puter print-outs for the distribution of the drawing and for the 2
I 3
change made.
4 C
Just the computer print-outs?
5 l
A That's all it said, as I recall.
Then it listed, l
6 you know, a series of drawings.
i 7
0 Were the drawings, categorized in any manner?
Were 8
they grouped, by the various disciplin.es?
Did t' hey have any 9
kind of divisions?
Or was it simply a list of numbers?
I 10 A
To me it's just a list of numbers.
I'm not clcse 11
- enough to it to recognize drawing n' umbers.
A list of drawings 12
, is a list of drawings.
I l
13 l
0 Did it have any headings above the list of numbers, 14 like " Electrical"?
i i
15 l
A Not that I recall, no.
7 i
i 16 C
Just drawing numbers?
f 17 A
Just a list of drawings..
i 18 0
Was there any other writing on the page other than 18 the drawing numbers?
20 j
A I don't recall any, no.
21 g
And you say it was handwritten, this list?
22 A
Yes.
23 0
What did you do with this list?
l 24 A
As I recall, I picked it up and I started down the 25 hall with it.
I had some meetings to go to.
You mean what i
~
i 1
d.d do with it ultimately?
I ga'e it to l
0 When was that?
2 i
l 3
i A
It was some time in the afternoon.
i 4
0 What were your instructions to 5
gave he list?
6 A
I gave he list and I said, you l
l j
7
~
8 1
1 9
i 0
Did you tell that this was a list provided by 10 Cygna for what was to be reviwed on the following day?
i 1
11 A
I don't recall anything significant about the con '
i l
! versation at all, no more than passin in the hall.
12
]
13 0
Did you instrue at this was a list 14 provided by Cygna?
I 15 A
I don't recall.
I really don't.
l l
16 i
0 Did you characterize the list in any manner?
In i
I.
I 17 that you said it was just a series of numbers, did you give 16 ny explanation as to what the list was?
19 A
Nothing more than:
this is what Cygna wants to look at tomorrow.
21 0
And then you instructed to make sure that 22 these were available and in order and what else?
23 A
I don't think the instructions went that far.
2 0
Where were you when you talked to 25 A
Somewhere in the hall.
O
.'9 1
G Was Mr." Strand present when you provided l
2 ith the list?
3 L
No, not then.
4 0
was Mr. Strand made aware during that afternoon g
5 of your instructions to 6
L I don't recall talking.to Frank at all about it I
7 that day.
~
l 8
C So if I go ask Frank about the list being trans-9 ferred.between you to you don't think he will q
10 k
have any recollection of having witnessed the transfer or the i
g 11 i
instructions you gave?
i 12 i
L I don't know what Frank would say.
i 13 g
But you have no recollection of him having been I
f 14 5
l there?
l I
15 g
go, 16 C
Did you tell that the list contained 17 1
the packages that Cygna was going to be reviewing 18 specifically?
I 1
19 L
No.
I don't recall saying anything about M
packages.
I really don't know what Cygna wanted to look at.
- 1 I didn't know whether they wanted to look at packages or 22 design changes.
23 0
or print-outs.
k A
Print-outs is the only thing that registers with 4.
me.
s--
- ~ ~ ~ ~
~~ ~ ~~~
U.
1 j20 1
O So the numbers represented print-outs?
2 A
To me, yes, print-outs.
3 0
Did you ask
.o make copies of the list?
4 A
I don't recall asking hat, no.
5 0
Did you instruct o provice copies of s'
i 6
this list to the various satellites?
7 l
A No..
~
~
O'
'Did 8
ever' return this list'to you?
9 A
I don't recall ever getting it back.
10 0
Do you presently have a copy of this list?
11 A
Yes, I do.
12
{}
O Is it the original copy, or is-it a Xerox?
(MY g
13 L
It's a Xerox copy.
14 0
Who did you receive this from?
i?ho gave you this 15 list back?
I i
16 i
A I honestly can't answer that.
17 l
0 Do you remember when you received it?
18 I
A I
As I recall, there was one other meeting that took 19 place that Tuesday morning.
20 MR. CEARNOFF:
Is that the day after you met with 21 Es. Williams?
22 THE WITNESS:
The day after.
I was down in Dan 3
l Hicks' office --
24 BY MR. GRIFFIN:
5 0
Who is Dan Hicks?
O g
,e.
e
.s l
j21 1
A At that time he was the Procurement Control I.
2 Manager.
3 O
Okay; go ahead.
4 A
He was also in charge of the computers and some-5 other groups.
I remember he'and I talking about that list.
6 At some point during that discussion Nancy and Dave walked in, 7
MR. CEARNOFF:
Dave who?
8 c
. David Wade, who was with TUSI.
qHE WITNESS:
9 As I recall, Nancy said she'had to leave and if 10 we had any problems with it, we could reach her at the Lake 1
11 Granbury Motor Inn.
l 12 BY MR. GRIFFIN:
1 13 I
O You say this is the following day, this being 14 the day that Cygna did their audit of these print-ours?
15 A
This would have been Tuesday morning, the 25th.
isl 16 0
That was the day that Cygna was to do the audit; II that right?
18 A
That's the day they were to come in, right.
18 l
0 Had they already completed the audit when you had 20 this conversation with her, with Hicks and --
21 A
I don ' t think they -had even started yet.
22 0
Okay; go ahead.
23 A
That's about all I remember from that meeting.
It 24
~
was very brief.
That's all I recall.
g DidyouhaveanyconhersationwithMr.Eicksor 25 I
4
4 lo
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[
l j Ms. Williams or Dave regarding the list that you had been l
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t k
3 A
I don't recall anything significant.
I was down 4
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to talk to F.icks primarily about computers, the computer L
i i
5 i problems.
k_
t l-6 0
What was your understanding on October 24 of the i
br 7
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nature of that par'ticular audit that Cygna was requesting --
8
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t let me rephrase that.
What wa's your understanding of areas F
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17 G
Are you saying that you had been informed by C.vena F
18
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representatives in July that you had deficiencies in the n
E 19 P
I packages or on the computer, which?
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O This is the manual logs that were in the satelliteO e
w 23 p
A We didn't have the satellites set up then.
The 24
[
manual logs in DCC list all the d,esign changes.
What they w
25 F
did, I think, was get that copy and go to one of the five W
T e
M
\\
$23 1
l custodians and say'*,
2 3
4 5
0 At all?
l l
6 A
No.
7 O
Just to~make sure,I have an understanding of what
~-
6 you're' comparing here,'youre comparihg logs with packages; l
9 is that what --
l 10 A
It was manual log against manual log.
11
~
i Do you understand how the concept was set up back i
12 l then, 4
i i
l 13 l
i O
I thought I did.
I 14 A
-- before the satellites?
15 l
0 I thought I did.
You're comparing one manual log i
16 l against another?
I l
17 A
Yes.
{
18 0
Can you tell me the difference between the two 19 manual logs?
A If they're kept properly, ther'e shouldn't be any 21 difference.
22 O
So you had duplicate records?
- ~--
25 i
4 O
The ones in DCC and the ones in the field should 5
be exactly the same?
6 A
They should.
I 7
l G
Basically the same; contain the same design 8
changes?
l
(
9 A
Yes.
10 0
I think I do und'erstand.
11 A
That's what the satellite thing was supposed to 12 have done; it was to remove the file custodians out of it i
l 13 l
and limit the number of people that could handle the 14 drawings.
15 G
Who was tasked with implementing or incorporating 16 the design changes into the drawing?
17 I
A Whose responsibility was that?
I guess ultimatelt7 l
18 it is under a group called TI;E, TUSI Nuclear Engineering.
19 O
So it's an engineering group, actually?
i N
A Yes.
21 0
By this October mee~ ting with the Cygna represen-U tatives, was the system in place by then, the computerization l
23 of the design changes?
24 A
I think, as I recall, our target date was to have f
y it up and running by the 15th of' October.
s 26
$25 1
c so it das in effect at that time?
i.
2 A
Yes; we may have beaten that a little bit.
3 0
The print-outs that Cygna was requesting involved
~
4 retrieving this information from the computers; is that right:
I 5
L Yes.
6-0 So was a purpose in the October visit to receive 7'
examples or sample's of what the computer contained for each 8,.
package.-- what is now no longer a package but a computer 8
read-out -- regarding drawings and changes against those 10 drawings?
11 A
What I understood they wanted to look at was,if we i
12
' gave them a print-out that says "these are the changes that 13 occursed and here's this drawing," then he was going to take 14 that and go somewhere within the satellite system and verify 15 l that they had that same piece of paper out there, or that it 16 could be at Jeast pulled up on the screen.
17 0
Would it be fair then to characterize their re-18 view or their auCit an a: Document Control audit then, if it's 18 supposed to b-lr C and it'.s supposed to be in a corre-j 20 sponding satellite?
21 A
Is that a Document Control audit?
Well, you 22 should be able to exhibit that you've got the same set of 23 records in both places, yes.
It would be a form of control, 24 I
yes.
O Did part of thb.ir audit, to your knowledge, involve
$26 j
1 design verification, meaning that the design changes had been 2
incorporated on the drawing?
3 A
That wouldn't have had anything to do with me.
2 4
don't know what they did up in DCTG.
t 5
O So your only part of it had to do with comparing I
6 DCC documentation with satellite documentation?
7 A
Yes.
'That's whaE th'ey were' reviewing.
8 0
1 9
A Yes.
10 0
When you received the list of packages -
- packages, 11 I suppose, is the wrong word -
print-outs is it?
12 A
The list of drawings.
The list of drawing numbers that Cygna wab+=A 13 0
t 14 review the following day, did it occur to you that this was 15
-- and I use this word in quotes -- pre-notification?
16 A
No.
17 0
That didn't occur to you?
18 A
I didn't treat that list any different than any 19 other. list.
A drawing list is a drawing list.
30 g
Based on your knowledge as a supervisor, if I gave 21 you a drawing number right now and said I was going to come 22 look at it tomorrow, do you have the facilities to review 23 what is computerized against that drawing, the changes and 24 the revisions to the changes: what should be there versus 25 what is there?
Do you have that. capacity?
9 w.
2E I'm asking you:
could you audi: yourself if 2 427 1
l gave 3ou a particular drawing number?
2 3
A.
Me, personally?
4 O
Yes.
5 L
po.
Do your subordinates have that capability?
6 0
7 i
A.
Yes, th'ey could do it.
so if you gave one of your subordinates that's in 8
g g
this area a drawing number, could they pull up that dravring 1
9 on the screen of the contents of that drawing number, 10
- number, the cenputer from DCC and show what should be the proper re-11 visions for the va.rious design changes that are supposed to 12 13 be contained under that number?
l i
14 A.
Yes.
e Are your subordinates capable of spottine deficien-15 0
cies or missing documentation if they had a read-out of what l 16 l
was contained in DCC versus what was contained in the 17 16 satellite?
You could.'t do it by looking at the screen.
19 A.
0 How would you do it?
As part of the norr.s1 procedure, before design
- 1 A.
they'll punch drawings are issued from satellites, you know, n
lists all those design-the button and get the print-cut that 23 I
changes on it.
Then they start building a package.
They take the drawing and take each cne of these design changes 25
. ~. - -. -- -
$28 1
and put with it.
l Part of what they're supposed to do is look at the 2
1 3
design change and make sure that it is, in fact, against that 4
i drawing.
If it's not against that drawing, then they've got 5
l a number to call up'in DCTG to say that "I've got C and C E
l 6
j so-and-se and it's not against this drawing.
What do I do i
7 i
with it?"
8
. That's in Ehe case of a clear-cut error.
0 But if 9
you provided your satellite with a drawing number that per-i i
! tained to their area that thev're resconsible for, they could 10 i
11 pull up on the screen, frc= DCC, what is supposed to be con-l 12
! tained in that package; is that right?
Then they could pull 6
13 the package that the craft uses in its day-to-day and they 14 i could check to see that all those documents, all uhose l
15 j changes, were contained in that package; is that right?
16 l'
A They could do that, yes.
I 17 O
Is it fair to say that by Cygna providing you with 18 a list of the drawing numbers that they were going to be 19 looking at on the following day, you could be able to, if you 20 wanted to, require your people to conduct an advanced audit 21 to make sure that all those packages contained all the re-22 visions on design changes they were supposed to contain?
Is 23 that correct?
M A
That could be done, yes, but that's against my 25 nature.
G e
e
- e
i f29 1
i 6
Did you tell anybody to do just that?
Did you 2
tell anybody to make sure -- well, I'll stop for a minute.
l 3
In your earlier comments regarding your instruc-4 tions to I think you said that when you gave 5
the list you instructed o make sure all these were avail 6
able and in order or something to that effect.
l 7
A To make'sure that we were all right, yes.
~
8 Could a pebson interpret all right" to mean that O
r 8
they were proper and correct and complete?
't 10 A
I suppose you could.
11 0
Do you think could have interpreted it that
<s(G 12 wa3' ?
13 A
Yes.
14 0
To pass the audit whct the computer showed should 15 be contained in the packages would have to be contained in i
16 the packages or deficiencies would be found; is that correct?
17 A
Those packages are supposed te be checked before 18 they go out, checked and --
MR. CHAPl10FF :
To the craft.
TiiE WITNESS:
Yes.
- 1 BY MR. GRIETIN:
O Are you saying they audit the packages each day?
23 L
Yes.
~
24 G
So they pull the contents of the packages up on 25 their screens, they check that the contents listed for that
- 2:
drawing number -- that all those documents are contained in 1
i I,
2 the package?
l 3
L Yes.
4 0
Every day for every package?
l 5
A That's procedure, yes.
i 6
l 0
Even if the package is several inches thick?
i 7
I L
It does~n't matter.
8
~
~
C'ARNOfF:
That's*every day that*a craft re-
'MR.
d
~
l 9
l quests a drawing; not all the drawings in inventory.
You e
10 understand that?
11 l
BY MR. GRIFFIN:
i 12 0
If a craft person requests a drawing number, if I
13 he provides the satellite with a drawing number, he gets a 14 package; and the package is supposed to contain all the desigu 15 changes that have ever been =ade against that drawing?
16 A
Not all of them against the drawing, n'..
There 17 are two different sets of design changes or two different 18 screen readings.
One of then is what we call the Open and 19 Current, which tells you all the design changes that are 20 currently against that drawing.
Then there is another list-21 ing that tells you the history *of that drawing, every design 22 change that has ever been written against it.
23 g
Let me state it back to you and you ca5 tell ne if 24 I'm correct or not.
A package contains the drawing and all
+.
g 25 its correct revisions, and it also contains the design D
, -= e..e. e s w e e
22 I
j31 1
l changes against that drawing and all those revisions.
i 2
A The design changes and the current rev. would be 3
in there.
t 4
i G
So you have revisions of the drawing itself and-5 revisions of the changes.
6 A
The current revision of the drawing and the current 7
revision of the de' sign change, the latest revisions.
~~
~
~
8 G
And that's what the packa'e contains that craft g
9 gets?
10 A
Yes.
11 0
And they receive the whole package to go out into l
the field; is that right?
12 13 A
Correct.
14 O
Let me ask you this:
in that Cygna, in that 15 F. s. Willians orovided you a copy of those design drawing 16 I
numbers that they were to review the following day, it did 17 provide you with an opportunity, if you chose to do so, to 18 request an audit prior to their looking at it.
You had that 19 option, didn't you?
20 A
Yes, the option ~is there.
21 0
You :r.ay have alread'y answered this question, but 22 is it possible that interpreted your ins m_m...
23 to to do just that, to conduct an in-house audit to make 24 sure that those packeges were true, complete and correct and l 25 that they would be 100 percent ~ accurate when Cygna looked at l
l j32 1
them the next day?
2 A
I don't know whether id or not, but that was i
3 l not my intent.
4 O
Did you ever get any feedback from 5
any of your subordinates to indicate that that is what they 6
had done or that that's the way they interpreted your in-7 structions to 8
L' Since then "I've been niade aware that~ thct could 9
l have happened.
)
8 10 0
You have received information from somebody to i
lindicatethat that did happen; is that what you're saying?
11 i
12 l
A That's what they told me, yes.
l
(
13 MR. CHARMOFF:
Can you put a time frame on that?
14 THE WITNESS:
That was last Saturday.
i 15 BY MR. GRIFFIN:
l l
16 C
This is somebody that has made inquiries since 17 this has become an issue?
18 g
- yes, i
19 g
gu.ing your October 24 discussion with Mancy 20 Williams or any subsequent discussions that you personally 21 had with Ms. Williams, did you discuss the implications of 22 this, what I will term, " pre-notification"?
Did you ever 23 ask her anything about it, or did she ever make any comment 24 as to why they provided ycu this' list?
25 y.m asking you to be expansive here.
I'm asking 9
7
~
34 f33 1
you to tell me if pou know anything.
i 2
l A
I recall -- I was at the hearings last week, 3
l Monday and Tuesday.
I heard Ms. Williams say that she gave t
I 4
! us the list because she understood it took an inordinate 5
amount of time to piepare this list, so she gave us sobe 6
advance notice to get the computer print-outs ready.
7 0
I'm not'asking you what you heard in hearings.
-Me personally?
8 A
8 O
I'm asking you during this time frame, the 24th 10 or 23 3 __
l 11 MR. CHARNOFF:
October.
i 12 l
BY MR. GRIFFIN:
l 13 0
Yes, thereabouts; did you and Ms. Williams ever 14 discuss --
l 15 l
A Not that I recall, no.
i 16 O
When Ms. Williams provided you with this list, did it occur to you that you had the option of conducting your 18 own audit?
19 L
No.
I don't do business that way.
O So her providing'it to you, you took it that you were a party to the audit in th'at you were going to be able 22 to evaluate what your subordinates there -- whether they had 23 been ecmplete in their duties?
24 5.
As a manager I need to:know that.
If I've got 25 something screwed up, I need to know it.
e e
,,-4
, -. - - -, - - -.----g
,,-,,w-
jM 1
l 0
In that same light or that same sense, did you 2
view your comments to as being a manager reviewing 3
the output or work or status of her employees under her?
I 4
A I don't know if I know what you mean.
5 0
I mean if Cygna cut you in on what they were going 6
be locking at and you cut in on what was going to 7
be reviewed -- at the time that you gave the list 8
you say you didn't give it to het as pre-notifi~ cation; you i
l said that was not on your mind.
9 Were you presuming that basgoingto 10 11 pass this on?
12 L
I didn't expect her to do anything.
I hope that I
]
13 I promoted that attitude, I think; you know, one of being C\\
14 honest.
There is nothing to.be gained by -- it is just com-15 i pletely. out of character.
16 0
What did you expect to do with this 17 list?
18 A
I didn't expect her to do anything with it.
If 19 I would have wanted her to do.something, I would have given 20 her some specific instructions.
0 I thought you told domakesureeverythingwas 21 22 okay and was available?
23 L
By that I mean the computers.
That's the only 24 part of the whole thing that concerned me.
25 0
What do you mean by computers?
e op o.
6 m==
ee m
40 f35 1
A.
That t. key are working.
2 0
If you give list of drawing numbers, what 3
does that have to do with computers operating?
4 A.
If got a problem with the computers, it's-5 up to to tell Frank or myself.
~
6 0
I understand that.
I've read your testimony at 7
the hearings.
I don't want to confuse this transcript we're
~
~ making' today with that type of test 5faony.
The reason is, I 8
~
I 9
l know how to turn on a computer, and that's got nothing to do 10 with drawing numbers.
You don't need a list of drawing i
11 I
numbers to turn on a computer.
A computer either is werking l
i I
12 or it's not.
You don't need a list of drawing numbers to 13 know whether a computer is workinc.
So let's not confuse k
14 that too much.
15 g.~h then, if you gave this list _and 3
16 you told to make sure everything was okay or in c.
er 17 whatever terms you used to what did you expect to de 18 with this list?
19 A.
I didn't expect to do anything with it.
20 0
Then why did you give it to 21 A.
I thought about this a hundred times -- unless it 22 l
was to keep informed as to what was going on.
23 0
That's a little too general.
Surely, you hcd-24 something on your mind when you p,rovided it to Cygna
.....d i t m,- -. h..
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,0.
m
=m
37 i
j36 i
1 j had some purpose in mind.
2 L
(No response.)
3 0
And you say subsequently somebody gave you the 4
! list-back.
Do you know why they gave it back to you?
5 L
No.
The only other time I remember that list is 6
that Tuesday afternoon when the guy from Cygna came into 7
Frank's office and'we sat down and talked about the list again.
9 0
In what sense?
10 A
What was on the co=puter and what was on the 11
- manual logs, for one thing, and how he intended to go about t
02 i
doing his audit.
13 0
Which day was this?
14 L
Tuesday afternoon; the next day.
15 C
So that was the day after you received the list?
16 A
Yes.
I l
0 Had they already ccmpleted their audit at that II i
16 time?
19 A
As I recall, I don't think he had even started it.
20 0
When did they conduct their audit?
21 A
I think it was that' Wednesday.
22 O
Did anybody other than Nancy Williams, who was 23 part of the Cygna review team -- did any of them ever make 24 i
any allusions or statements regar, ding you having been pro-25 vided the list in advance?
e O
8 e
li
[37 i
I i
Not that I'm awcre of, no.
i 2
0 The reason I ask these questions in so many ways
] is because all the parties that are going to be interested in 3
4 this natter are going to expect some kind of explanatien as' 5
to why this list was provided' in advance.-
6 l
Is there any way I can phrase my questioning that 7
, will open up an av'enue for you to answer this question in a lwaythateverybodyconcernedwillunderstandwhyyouhadthis 8
9 list given to you in advance of the audit and why you passed i
10 I
it to your subordinates?
Is there anything that you'have not 11 told me; is there any more information that I have failed to 12 ask you that would shed light on this matter?
i 13 A
No.
Believe me, I've thought about this thing l
14
,1 hard and I just can't -- I'm telling ~you everything I can l
15 re e_3er, 16 l
0 How many meetings did you have with Cygna repre-17 sentatives on the 25th, which I think you said was Tuesday?
18 A
As I recall, that one that morning with Nancy and 19 then the one that afternoon with Steve Bibo, 20 0
Could you spell Bibo?
21 A
B-i-b-o, I think.
22 c
could you briefly give me a narrative en the con-23 tents of each of the meetings, starting with the corning -
4 meeting?
25 A
The one in the morning -- like I say, I was in 4
4 ev-;--,-m
-.7
~.-.
y-
-m
i 39 3
j38 l
1 l Dan Hicks' office 'and Nancy and, I think, David Wade had i
2 stopped in just briefly and said, you know, Nancy had to leave 3
and if I had any problems that she could be reached at 4
Granbury Motor Inn.
Very brief; just two or three minutes..
5 Then the one in the afternoon with Steve, I was 6
in Frank Strand's office and Mike Strange was in there..
7 0
Let me ' understand the characters.
You're saying 8
Frank Strand.--
9 A
Strand.
~
10 0
S-t-r-a-n-d?
11 A
Yes.
He's a supervisor.
E O
And who is this other fella?
13 A
Mike Strange.
He's the guy that's, I guess, ulti-14 mately in charge of the data base as it relates to design 15 l changes.
16 0
Is that with the Engineering Group?
17 A
The Engineering Group.
18 O
Okay.
Go ahead.
18 A
As I recall, Steve walked in and gave us -- he had i
20 the list.
I don't remember what he did with it, but he had 21 the list.
22 We sat down and we had some discussion as to 23 which one of these were manuals and which ones were on com-24 puter logs.
That meeting, too, wa's very brief.
25 g
So you're saying this is Steve Eicks that had --
.= =
~
~
43 I
A Steve Bibo.
2 0
Steve Bibo.
3 A
He's with Cygna.
4 0
So he had exactly the same list that you received 5
from Williams?
6 A
Yes.
7 0
Was it'a copy of the same list?
8 A
A. copy of the list.
~
9 0
But you had actually been given the original, 10 handwritten, is that right?
11 A
I think I had a copy of it.
I don't recall having 12 the original.
13 0
Okay.
You think the copy you gave to was 14 a Xerox or was it a handwritten original, pen and ink, 15 pencil or --
16 A
It was a Xerox copy.
I'm almost sure it was.
17 0
Okay; go ahead with that meeting.
18 A
Like I said, that meeting was very brief.
I 19 don't remember that much more.about it.
20 0
What were Bibo's comments related to the contents 21 of the list?
What questions did he put to you?
22 A
I don't think he quizzed us that much about the 23 list.
24 0
What information did he give you reg,arding it?
25 A
As I recall, most of our conversation centered O
9
-e I
w
41 i
34C-s, 1
l around satellites.'
I understood he'd been on a tour that day q
l 2
You know, go out and look where they were, find them and make 3
sure he could find his way back the next day.
4 0
So they'didn't begin the audit that day; they were 5
just walking around looking where the locations were?
6 A
That's what I recall.
7 0
So you received the list from Ms. Williams on bonday and' they conducted their audit on Wednes' day?
~
8 9
A.
As best I recall, yes.
10
.v.E. CHARNOFF:
Could you tell Brooks everybody who 11 was in that meeting rcon with Strand and Strange?
Was there u
anybody else there with Bibo?
13 THE WITNESS:
I think was there too.
14 I think ame in later.
15 BY MR. GRIFFIN :
16 0
Do you remember any comments made by 17 during that meeting?
18 A,
1;o, I don't.
19 0
You don't remember.any participation --
2 A.
I re.2 ember her coming in.
Like I said, the thing 21 didn't last very long.
22 O
Let me go back a little bit into the meeting --
23 let's go back to the time where you gave Hatley the list'in
~
24 the first place.
25 Did you tel to destroy the one copy 0
42 1
or copies of the list that you gav.e after had done 2
whatever was going to do with it?
3 A
No, I don't recall that.
4 0
No instructions to destroy the list?
5 L
No.
6 Q
Would you remember that if you had said something 7
.-like t. hat?
8 A
Im sure I would.
9 0
I think I've already asked you this several times.
10 Let me ask you one more time:
do you know what id 11 with the list that you gave 12 A
I've learned some things last Friday or Saturday.
)
13 MR. CHARNOFF:
A week ago Saturday?
Today is 14 Monday.
15 THE WITNESS:
The 18th.
16 BY Pa. GRIFFIN:
17 0
But nobody told you anything--say within a week or 18 two after you gave he list, did anybody give you any 19 feedback af. to what did with the list?
20 A
No.
21 0
Nobody?
E A
tiobody.
23 0
What did you learn a week ago, briefly?
What were M
you. told?
3 A
That perhaps some of those manual logs had been 9
9
-,f
42 l
\\
j42 1
1 l copied or some of the logs that were in the satellites had 2
been thrown away and new ones put in.
3 0
I'm a bit confused on that.
You say logs.
4 A
Manual logs.
You see, there are certain of the 5
drawings that are kept on the computer, the design changes, 6
and certain of them are kept --
7 O.
Still l'ogs?. -
8 A
Yes.
8 0
So you retrieve the packages either through the 10 computer or through the log, depending on whether -- the ones II that are in the log have not been computerized yet; is that right?
13 A
You can build the packages either off the manual 14 logs or those drawings that the logs exist for, or you could 15 build them off the computer logs.
All the drawings are not 16 in the computer.
All the design changes against the drawings, 17 0
Now, to rephrase what you were telling me you 18 heard; that some of the logs had been removed?
19 A
Some of the manual logs, yes.
Some of those draw-20 ings that are still -- the design changes.
21 0
In what context did you hear this; that the ones 22 that had been removed were now contained in the ccmputer, or 23 once. removed, gone forever?
24 A
The exact statement -- or not the exact, but what 25 I remember was one of the girls that worked in a satellite
_ _ = _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _
44 1
told me that, had uc throw all these logs away and put new ones in."
2 3
0 Containing the same information?
Was that the 4
implication?
5 A
Well, what they led me to bel.ieve was that, you 6
know, the manual logs that were in that particular satellite 7
._r mayb.e all satel' lites were not correct.
So if a guy came o
8 in to look at the manual logs in the satellite it wouldn't 9
look like the ones in DCC.
10 0
Did this person telling you this indicate that the 11 throwing away of the logs had occurred during the time Cygna u
was conducting its audit?
13 A
- yes, 14 0
Did this person tell you the reason?
15 A
She said something to the effect, you know, "I
16 don't know why we did it because 7.here was nothing wrong with 17 them.
Just because house is' screwed up doesn't mean 18 ours is," or something close to that.
19 That bothered me.
That scared me.
20 0
So you think that based on some of the feedback 21 you have received recently, that there might be either missing 22 documentation or alteration of documentation in some of the 23 satellites?
24 Ifeellikethatmayhkveoccurredrightbefore A
25 Cygna got there; yes.
~
G r-
45 N4 1
g But vou had no knowledce of any such thing?
2 A
I found out about it Saturday.
3 0
Has anybody indicated to you in this inforz.ation 4
you recently received that F.r. Strand had any knowledge of.
5 any alteration of the* logs?
6 A.
I think Frank found out about it about the same 7
time I did.
f s
0 I'm aware that either th'ere has been or there is 9
an ongoing internal' investigation by TUGCO or TUSI into this 10 matter.
11 Does this information that you have received re-12 cently fall out from that ongoing investigation?
13 A
Well, the investigation first started in a matter 14 not even related to Cygna.
It was when I terminated 15 16 Then I had reason to suspect that maybe par-17 ticular satellite was, you know, a little bit screwed up in 18 terms of documents.
19 0
Which satellite was that?
21 O
what division was that?
Was it Electrical or one 22 of the --
23 l
A..
It was,primarily the Mechanical satellite; mechani-24 cal and structural drawings.
['
25 0
What was your knowledge of the problems in that
,g,
.mo O
~-:
'j 4 5 1
l satellite?
1 l
A.
We have what we call a DCC monitoring team.
They 2
l 3
- are two people who do nothing but' just go from satellite to t
7 0
What were they finding?
l 10 MR. CHARNOFF:
h~nat time frame was this?
I 11 THE WITNESS:
This was -- I guess it got started l
12 probably 13 or first week in February.
Q 14 BY MR. GRIFFIN:
15 0
And this prececed termination, right?
16 A.
Yes.
l 1.
O All right.
Go ahead.
I 18 A.
You know, I just didn't like what I found.
Then I
i i
U 0
Eave you conducited a similar review in the other U
i satellites?
e o
e 8
C 1
0 Di or any of your other subordinates 2
ever -- prior to the time Cygna conducted its audit or, say, 3
the October meeting or prior to January, do you ever remer.ber 4
any of your subordinates ever telling you that this was an.
5 ongoing problem in the satellites, 6
7 8
~
9 A
The only time I recall it being a problem were 10 the packages that came out of I didn't seem to have 11 that problem with the rest of them.
At that time that was 12 the only one that was in doubt.
13 0
Was esponsible in part for setting up I g
14 the satellite system?
15 A
had a large hand in setting them all up, yes.
16 0
Was there anybody on site more familiar thar 17 bout the creation and the implementation of this 18 system?
I 19 A
Frank Strand probably had better knowledge.
20 0
Since you first received this information, have 21 you ever received an explanation, or do you have an explana-22 tion for how this particular
.alking about l
23 why satellite would be in any worse shape than any of 24 the other satellites?
b.
25 A
It was very puzzling.
I can't answer that because
\\
e -
I.
1 you know, as got at least as many documents as
- .ay !
!beevenmore, and it has more traffic than 2
3 0
Was a supervisor over all the satellites?
4 A
When we first put them in plac as superviscr
)
5 l of all of them, but I guess as time went on just slowly 6
digressed int 7
0 was reassigned?
8 No, e
9 0
In January when your suspicions were aroused abou:
10 ormance, was still supervisor U
L By title, yes.
13 MR. CHARNOFF:
B'ut not in practice?
14 THE WITNESS:
But not in practice.
I guess 15 had resigned to
.lmost exclusively.
16 BY MR. GRIFFI!!:
17 0
Was this something id on wn or was 18 assigned to do so by either Strand or yourself?
19 A
I didn't assign to do it and I don't think 20 Frank did either.
I don't know.
21 O
Is this information you received later, what you 22 are repeating to us now about onduct of business o.
l 23 assignments?
A About lowlygoingiinte No, I noticed that myself.
goe..ee u w e e 4
i.
45 l
q:
3 s
1 C
At this' tine, was
.till responsible for 2
review, evaluation or overseeing 3
A.
I think Frank had probably taken a more acti e 4
role in it than he had in the past.
We were also in the 5
process of setting up another one.
6 G
Another what?
7 L
Another' satellite.
6 0
I-think you may get the gist of where I'm going.
9 You said tha had the title.
had the authorit,
10 apparently.
Did ave the responsibility to still review i
11 these other satellites other than 12 A.
I don't think that had been taken away fror L
13 no.
k 14 0
How were you, or whoever provided you this info'r-15 I
mation, how were they able to -- how was a decision arrived l
1 16 at that was responsible for the lack of documenta-17 tien in ow was this decision cade?
131at evidence l
18 supporte'd the decisien that was responsible?
19 How was singled out?
20 A..
Well, to begin with, like I said, on pape
- 1 was at least still the supervisor for all of them.
Sine 22 had slowly resigne I felt like it wa responsibility.
24 0
WhenIgooutonthes[teandIinterviewall
~.
y these Document Control people, are they going to -- I'm
-49 I
asking just your opinion, your speculation, at this peint --
i 2
are they going to tell me that the deficiencies of records 3
contained in these many packages'that craft handled on a 4
daily basis was shortcoming; it was fault 5
i that they were in the condition they were in?
6 I'm just asking your opinion.
7 A.
It's probably going to depend who you talk to.
If l you talk to an electrician, he won't know how to answer that 8
i
~
9 because --
l l
10 0
I'm talking about people in the satellite offices.
I 11 The people that work in the offices, the satellite offices, i
12 where these documents are contained, are they going to tell 13 me that s responsible for the lack of documenta-14 tion in all those packages?
w 15 You mean if it's not in there before it goes out i
a I
16 i
to the field?
I don't know what they'll say.
17 C
Go ahead and tell me how ycu decided that 18
'as responsible for the lack of documentation in these 18 packages.
e 20 You say you fired her.
How did you arrive at the 21 decision that was responsi5>1e?
22 A.
A lot of it was based on what Frank had discoveref 23 through conversations with some of these girls.
I guess the 24 overriding factor was some of those audit reports we had 25 that showed us just how bad it was.
e e
% e e
e
- .g
.- W o===
p
- f. 5 0 i
1 l
C.
Internal audit reports?
)
2 L
Yes.
3 O
Did these audit reports point to as i
4 l being directly responsible for the missing documentation?
I 5
i A
No, they didn't come right out and say l
6 misplaced this;
.isplaced that," but, to me, i
! was in charge of that satellite and it was screwed up, then 7
8 it was
- fault, responsibility.
~
9 0
So it was your decision that as terminated?
10 A.
It was a decision that was reached jointly by i
11
! Frank and myself.
Then I discussed it with Frankum.
1 12 G
Who made the ultimate decision to terminate J
13
]
l' A
Bottom line, it had to be re.
If somebody said
~
14 "Let's do it," then it was me.
b i
15 i
0 Were you encouraged to do it by any of your i
i 16
{ superiors?
17 A.
No.
18 g
Did Mr. Tolson ever have any input into 19 termination?
20 A
No.
21 0
You never discussed situation with him?
A.
No; Tolson never had anything to do with that I 23 know of.
~
C Were there any other Neasons, besides those, the lack of documentation in that led you to believe that i
E2 I
1 services were no longer needed?
2 A
Well, based on some of the things that Frank had 3
discovered from talking to some of those girls, it appeared i
4 to me that the system was being undermined; that as 5
making an attempt not to follow procedure, not to do things a 6
certain way.
7 0
Do you have any evidence that has specifically 8
come to your attention that would support this contention?
9 A
Some of the things Frank told me about in-l 10 i structing the girls not to call the 611 number if they found 11 an error on the screen or a design change that didn't look i
12
' like it belonged there; that bothered me.
13 0
Did he give you any explanation for having 14 given these instructions to ubordinates?
15 A
Did Frank give me any explanation?
I 16 0
Yes.
l 17 A
I don't know why did it.
18 0
Are you convinced yourself that id?
18 A
Yes.
O Based on?
21 A
Based on talking to Frank.
I've also talked to 22 some of the people in the DCTG.
O Do you happen to know if this particular series of events that led up to erminayion, is that also included 25 in the ongoing TUSI investigation?
O G
4 9
e iiiiiiiiiiiiiiiiii.,
i'
..3:
A 52 s
i I
A I don't~ think so.
I don't know.
l 2
0 I know TUSI is committed to informing NRC of its 3
findings, and I was just wondering if this was going to be 4
included.
5 A
I don't know.
The investigation I set in motion 6
had nothing to do with Cygna.
It was already set in place 7
before a s e'v e n f i r e d.-
8 0
I agree.
We're talking about a different issue
~
9 here.
10 Did ever, prior to January 1984, v_ ice 11 l
any concerns to you, personally, of deficiencies in work i
12 packages contained in the satellites?
13 L
I honestly can't answer that.
I
(,
14 0
You don't recall any such --
(hg 15 A
I'm sure there were occasions, but I don't recall !
i 16 any.
17 l
0 What I'm getting at here is the NRC is not com-l 18 pletely -- this is not our absolute first inquiry into this 19 matter.
We have other testimony and we will be gathering a 20 lot more in the future.
21 What I'm driving at is,.I want to know if you have 22 23 24
j53 1
I A.
I.cc.n recall you know, complaining about the i
2 task forces.
And at some time, I don't remember when, I i
had some of the TJGCO site auditors or a surveillance team, 3
i l
4 i
I think, is what they call them, I had those people go in and f
I 5
look at the task forces to find out what kind of shape they 6
were in; but I don't remember when that was.
I really don't.
I f
i 7
G Have yo'u received any~ feedback, prior to January 8
1984, f rom any of either your subordinates or members of -
i i
9 these audit teams in which they told you,that indi-l l
10 3
i 11 A
Like I said, I'm sure I've gotten it.
I just 8
i 12 don't remember whether it was prior to January or not.
\\
l 13 l
0 What I'm driving at is:
l i
14 gem I
15 trying to determine from you whether through anybody, j
'N 1
15 through any source that might be available to you either 17 directly or otherwise, informed you or had given you a con-l 15 l
tinuing series of updates as to the deficiencies contained in 19 these packeges.
Because I think there is going to be a 20 i
mountain -- I'm-just guessing, you understand, but I think 21 I
there is going to be a mountain of testimony to indicate that I
n 23 24 25.
9
- =
,n, s.
55
$54 As it r' elates to desig.. changes in the computer, I
A i
i
! yes.
I know that.
I don't think we'll ever get all that 2
l i
3 I cleaned up.
4 0
What was terminated for?
~
5 L
termination had nothing to do with the compute:
6 design change base.
That'is something that is beyond my con-7 I
trol and 8
0 That's in DCC, right?
9 l
A DCTG.
I 10 0
They do the input.
i 4
11 A
At that point in time.
i 12 O
Uhat they show on the computer is supposed to be i
l contained in the packages; is that right?
13 14 i
A Yes.
15 0
And you fired for deficiencies of changes 16 i
contained in the packages; is that right?
I 17 A
That was part of the reason; for something not 18 l
being in the package that should have been in the package.
19 I wouldn't call it a deficiency.
M 0
How many instances,or how many packages and how
'l many instances in those package's were you able to document as 22 a basis for the termination of 23 A
I can't answer that.
24 0
Was it hundreds, thous, ands, one?
25 A
You'll have to look at some of those audit reports.
..e.
- ===**N**
i i-j 55 1
I can't answer that.
I don't know.
There were quite a few. l O
What would I have to do when I go on site this 2
l 3
next week to get those audit reports that contain a listing 4
of all these deficiencies s responsible for 5
being deficient in those packages?
I l
6 A
Just ask for them.
1
'l I
O Ifno do'I go to?
YoucansebmeerFrankStrand,eitherone.
8 A
9 0
And you can provide them?
10 A
Yes.
If I can't find them, I can make sure that 11 l
you get them.
12 1
0 You said you went to Frankum, or Frankun had in-13 put, did you say, regarding ermination?
14 A
Well, it's part of Brown and Root procedure that 15 j
if we terminate people for certain reasons then we have to i
16 I
have the Project Manager's approval to do that.
1 l'
I i
0 Did you have extensive discussions with Frankum as 16 to the reason for your decision to terminate 19 A
I wouldn't say extensive.
I outlined to him what 20 my problems were, what I fcund and what I felt needed to be 21 done.
22 0
Did he agree with your --
23 A
Yes, he did.
O He agreed that she be terminated?
2.
A Yes.
4 P..
I
l jS6 I
I don't know if you have this information: I want l you to tell me if you do.
Is t'7e ongoing investigation 2
1 3
i being conducted by TUSI into the Cygna matter going to incor-l{ porate the deficiencies identified in these audits, or --
4 5
A I don't know, i
6 l
is it separate?
0 7
A I don't'know..
q.-
e.
8 1
0 Back to the Cygna list for a moment.
The list l
9 I that Killiams provided to you,,is that the same list that the 10
, Cygna auditors -- are the drawing numbers contained on that i
11 list -he same ones they reviewed on that Wednesday?
l 12 A
I don't have any way of knowing that.
I 13 l
0 Has anybody ever told you that?
10 y
14 A
no.
15 0
So the list that you provided to you don't 16 j know if that's what Cygna looked at?
t l'
t A
I have no way of knowing.
I 19 0
Back to your termination of When you 19 bas fired did you give n explanation for wh3 l being terminated?
21 L
Yes.
22 O
Did you cite specific examples of deficient 23 records or deficient records that were supposed to be in' 24 packages?
25 A.
I don't think I g'ot specific with it, no.
I told
.e*
- e-
- up,
"***h*
" * *+* * * *
- -i I
enerally why I had some problems with I
2 O
Can you state in your own words what you told 3
i A
I told that Frank and I had a lot cf work in 4
getting those satellites set up; that, you know, I had some 5
problems with nd what was going on in and that week 6
that as gone on vacation that I put the monitoring team 7
into o find out, you know, how bad it was; that I wasn't B
very pleased.with what I found; that right now it was in a 9
position where I didn't know what drawings were in the field 10 or who had them; that there were some procedures and specs 11 l
that were up in some of the departments that hadn't been up-l j
l l dated, some of them as far back as Aucust.
12 13 I also asked about some absentee records, 14 which had made a comment.about earlier that week or the
.! week before about how valuable those absentee records would 15 16 be in somebody's hands.
I asked bout that and l
C What are absentee records?
17 15 l
e g
ge ve got a departmental log that shows every day 1
19 that everybody's here or there, how many hours they work and 20 that sort of thing.
- 1 I've got another suit pending now for a girl I i
22 terminated for excessive absenteeism about a year ago.
23 I explained those thoughts to what my prob-24 lem was, and utematically wep't on the defen.sive.
I saie. g ehis is not very pleasant.
25 It's not something 4
4 e m e.e
====w 4
w
ib j58 I
that i really like'to do, but based c.. the facts that I've i
1 got in hand, I've got to terr.inate you."
2 3
said, "Well, I'm going to the NRC.
I'm going 4
l to the Labor Board.
I'm going to the newspapers.
I'm goin'g 1
5 l
to Brown and Root in Houston.
I'm going to Texas Utilities" --
6 O
Then you went ahead and. terminated i
7 A
Yes.
l
. Based on information that you have received 8
l 0
I l recently as fall-out from this investigation or whatever your S
1 l
source, are you saying that you have received infc mation 10 T
Q 11 i
that records have been altered, changef or disposed of ?
L 3'
12 A
Through hearsay, yes, I've heard that.
I I
13 0
Do you recall who told you that?
3 14 L
A girl named Judy Dickey.
15 i
O What is her title or job?
Who does she work fer?
16 A
She works for Brown and Root.
She's in charge 17 'i; of satellite 300, 301.
l IE O
Did she indicate what the source of her informa-19 tion was; personal?
20 A
Personal, yes.
21 0
She knew of it throdgh satellite 30l?
22 A
It's a combination; 300, 301 and 302 are all 23 together Service Start-up, Civil Engineering and INC.
24-Qir.Hutchinson]areyopfamiliarwiththeresults O
25 of the Cygna report?
Have you ever read it?
1
i ~,
j59 1
I've read the DCC portion.
i 2
O Are you aware, then, that as a result of the Cygna I
i 3
review, that they found a number of deficiencies, six or 4
! seven, I think?
Does that sound familiar?
l I
l 5
A.
Six or seven in DCC?
6 0
Yes -- well, 7
MR. CHARNOFF:
Irnat is the date of the Cygna 8
report?
I
~
9 i
THE WITNESS:
I don't think it has been published l
l 10 i yet.
I think it's still in draft form.
I I
11 l
MR. GRIFFIN:
The last date I see on here is i
i 12
- 11/5/83.
13 MR. CHARNOFF:
So it's follo.cing the October visit.
14 THE WITNESS:
Yes.
15 EY MR. GRIFFIN:
1 16 l
0 Is it your understanding that they did find de-l lI ficiencies in the review, in their October review?
18 A.
The DCC?
As I read the report, they didn't find 19 anything.
O I'm not going to go into this because this is a 21 little beyond -- I'm not famil'iar with either the original 22
~ Just let me read a sentence here contract or the results.
and see if this jogs your memory.
(
23 i
1
El 1
iCC 1
This was substantiated by re-2 l view of 18 drawings, seven specifications and approximately l
3 1 100 associated designs.
The discrepancies are as follows" --
4 and it looks like there is about eight.
5 l
Is that the same thing that you reviewed?
f 6
MR. CHARNOFF:
Could you show it to him?.
7 MR. GRIFFIN:
I would rather not.
~
~
'THE WITNESS:
Is that'605; is that number on there 8
9 i somewhere, specification?
That's the July report.
10 MR. GRIFFIN:
The reason I'm reluctant to give i
11 this to him is I'm not sure it is for public release yet.
I k
i 12 l
THE WITNESS:
That should have been the July one.
13 BY MR. GRIFFIN:
14 O
Are you saying that based on Cygna's review which 15
. occurred that Wednesday, you don't think they found any 16 deficiencies?
17 L
I think they verified that the systems were in 18 place and working.
As to what Bibo did, I dont know.
19 0
Would you normally have been a recipient of the 20 results of the review on DCC?
21 A
I don't know if I wo'uld have normally been or not.
22 I saw the report.
I saw the Cygna report when it came down.
23 0
Then did it basically conclude that the system'
~
24 was in place and in good working order?
25 A
As I remember reading the thing, you know, he 3 _--
.. e 1
s 1
! verified tha what he came to look for was there; the l
i i
2 i satellites were up, the computer thing was working.
i I
3 0
So that is October.
In October of '83 Cygna did 4
its review of what is contained in the logs versus what is 5
contained in the packages,'and you --
.6 A
I don't know whether they did that review or not.
l l
0 Well, they gave you what, 32 drawing numbers on a 7
B list handed to you by Nancy Williams; is that right?
I 9
I L
Yes.
10 0
And you say you have no knowledge of this, but it 11
' is my understanding that Cygna then came in on Wednesday and 12 reviewed those same 32 drawing numbers and all their revis-1 4
13 l ions.
And you said the results of the Cygna report for that 14 review was that everything was in good shape.
15 i
i L
That's essentially it, yes.
I l
16 O
Then what, two months later you fired 17 l because these packages, of which those 32 drawings were to be l 18 a representative sampling, had numerous deficiencies for 19 which you ultimately held her responsible; is that a fair 20 assumption?
L 21 g
yg.s not, not really.
~,
O Where have I missed?
What's wrong with my U
' reasoning?
24 Her termination was ph marily based on what I L
25 found in satellite ore than anything else.
G 8
... __.....-- ~ _ -
(2 O
Well, hpresume was included in the Cycna re-I view, was it not?
Were ary of the satellites omitted from 2
3 their --
L I don't know where he went.
I don't know what 4
l i
5 path he took.
I i
6 i
C
'Why is it that the Cygna representative review is 7
l proper, perfect, no problems, so to speak, and such a short i
]tinelater'youhavemassdeficienciesthatlead'tothetermin--
8 i
9 j ation of the person who set up the system in the first place?
i 10 j
Can you offer any explanation for that?
8 11 L
I can't.
I wish I could, but I can't.
j g
Do you have any reason to believe that between the 12 I
13 i
time that Cygna's review took place and the time she was 14 terminated, that somebody systemmatically destroyed or in-i 15 vaded the system and made it grossly deficient?
16 A
I think I can state that something was wrong in i
17 yes.
18 O
Did it go wrong between October 26 and January
{
19 whenever it was that you terminated 20 A
It went wrong be' fore I terminate
- Now, 1
21 when it went wrong, I don't kn6w.
I would have to go back 22 and look at all the audit reports.
I'm sure we've got some 23 that go back that far.
j O
Did you have internalyaudit reports before the N
25 Cygna report?
9 I
.m.
i 64 5
j63 1
A As I remember, the audit reports started probably 2
. in September of
'E3, August or September.
The team was in 3
place by then.
There was some form of auditing going on 4
then.
5 0
These same people?
.6 A
Yes.
i 7
0 So you 'ay you can give the NRC access to those s
8 audit reports.?
9 A
Yes.
I have no problem with that.
l 10 O
Based on the fact that you did so well in the Cygna 11
! review, do you happen to know whether these earlier audit t
12 reports are going to show the system as being in good shape 13
-g in September?
O
\\s 14 I
g yell just have to-look at them and see.
I don't ON 15 l know.
I don't recall that many problems.
I 16 0
Do you happen to know where b'as f or l three weeks prior to ermination?
17 16 A
was on vacation one week.
19 D
I don't want to bel' abor this point, but between 20 the October Cygna review which found everything okay and 21 January when was terminates, s ent three weeks on 22 vacation; is that right?
U A
spent one week on vacation.
O One?
Just one?
,'f 25 A
Yes.
I don't remember which week that was either.
1 8
9
j64 1
I think it was the' week beginning January 29.
e t
2 O
Let me ask you again:
did anybody -- not directly,I 3
necessarily, in the chain of ec.-aand of Brown and Root,,but 4
did anybody above you in TUGCO or Brown and Root direct you 5
to terminate 6
A No.
7 0
Was it'a decision that you arrived at en your own?
8 A
Yes.
I don't think'anybody in TUGCO' even knew I
9 i
about it, or TUSI, until after it was over with.
I don't re-i 10 call having discussed that with anybody in TUGCo.
11 O
Let me jump back one more time to the day that you, l
gave the list.
When you provided khelist, did 12
()
13 you tel pecifically that Cygna was coming to look at h
14 these documents the following day?
I 15 L
I don't recall making that statement, no.
16 O
And you don't recall why you gave the list?
17 g
yo, 18 0
You just gave it to 19 A
Yes.
And I though't about it, believe me.
.v.R. GRIFFIN:
Pir. Charnof f, I den ' t know if I'm 21 going to repeat Judge Bloch's request.
I doubt if I can re-22 peat it accurately since I was not at the hearings, Ididnotl l
23 hear it, nor do I have a copy of his statements made during 24
-5'
~
the hearings over there.
But it's my understanding that 25 Judge Elech requested that any contact between applicant or I
cc g
i fE5 1
representatives of the applicant -- and I don't know exactly.
2 what that entails -- with
. hat any such con-1 3
l tacts regarding Cygna be documented either through tape or i
4 l through written statement.
1 5
l Do you know if this is being done?
Are you aware 1
6 of this?
7 MR. CHARNOFF:
I'm not aware of that; but I think B
you can. correct me on this It is my impression that 9
they are not talking t t all; indeed, that is i
10 really why we are involved, because following that order, as-11
. I understand it, it is understood that the lawyers for TUGCO i
i 12 anc others who are involved in that other investigation were i
13 1 not going to talk to at all.
\\
14 But I can't answer your specific question.
es s
15 Do you know?
Have there been any contacts with i
l 16 them at all since, I think it was, Wednesday --
t 17 THE WITNESS:
They instructed me not to talk to anyh 1
18 body that worked for TUGCO, TUSI or talk to any of the girls l
19
^ in DCC or any of that stuff.
BY MR. GRIFFIN:
I O
The only reason I me'ntioned it is because prior to 22 our interview today the Judge talked to Trebe, an NRC repre-23 sentative, and asked that we remind you, as his representa-24 I
tives -- I cannot characterize whe't his original. intentions 25 were, but if you're sure that you're in compliance, then --
O G
e e
I j66 j
1 A
I'm absolutely sure.
In fact, Frankum told me last 2
l week to leave and not come back.
I don't know if I can do I
i 3
i that or not, i
4 MR. CHARNOFF:
I don't think the order excluded I
l 5
l you from doing your business.
As I read the transcript, I 6
think it, in effect --
7 THE WITNESS:
The conversations I've had with any-I -
8 I body at the site have been very, vers few and v'ery, very 9
l limited.
I 10 MR. CHARNOFF:
On this matter I don't think you 11
- should talk to anybody, but I think you are entitled to do k
I 3
12 k<s l the work.
ps 13 l
MR. GRIFFIN:
If there is any question I would I
14 l encourage you to call Judge Bloch, because it is important to I
15 him.
16 BY MR. GRIFFIN:
17 O
our interview today so far has 18 raised as many questions as it has answered in my mind.
18 Obviously, all you can do is say what you know to be the 20 tru th.
21 This interview is c~nducted at this time because o
22 your testimony before the hearings was suspended, leaving a 23 lot of questions unanswered.
~
24 A
I understand that.
~
25 0
The Office of Investigations will probably be
____M
4 i
$67 1
actively involved in the investigation of this whole affair i
I 2
in the coming weeks.
I want to put this in the record; that 3
I ar. almost positive that we will need to interview you 4
again because normally we don't start in the middle; we start 5
at the beginning, and we haven't started at the beginning yet, 6
A Okay.
7 MR. GRIFFIN:
Don, do you have any questions that houwouldliketoask 8
in this matter?
9 k
MR. DRISKILL:
Yes, if you don't mind there are l just a couple of questions I would like to ask, 10 i
11 i
BY MR. DRISKILL:
12 0
Going back to earlier in the interview, you said 13 that on the 24th of October this Ms. Williams presented you I4 with a list of drawing numbers; is that correct?
15 L
Correct.
16 0
What did she tell you about those numbers when she II gave you the list?
18 A
About the list?
l8 0
Yes; what did she tell you it was?
20 A
She said, "These are the documents we need to see,'
21 or "These are the drawings we ne'ed to see;" something to that 22 effect.
23
~
C Tomorrow?
24 A
Tomorrow.
"We'll be in.': tomorrow."
25 0
And she handed you a handwritten list?
i O
l m
l
~
l
-fi 1
1 j
A Yes.
2 O
Which contained 32 numbers?
3 A
Yes.
Have you fellas seen the list?
l 5
MR. DRISKILL:
I haven't.
6 MR. GRIFFIN:
No.
7 BY MR. DRISKILL:
l -
. You were in your office when you received this?
j g
8 I
9 A
That's correct.
l l
10 0
And then she left?
I 11 A
Yes.
12 O
Then what did you do?
b{G 13 A
I picked up the list, I started down the hall.
I 14 had to go to a meeting.
I was trying to get sc..e clerks some 15 wage ad ustments.
I had a session with John Merritt and J
16 Frankum.
17 At some point during that afternoon I bumped into 18 in the hall, I think it was around the drafting area, l
18 and gave the list.
20 g
would you repeat again what you tol when you 21 gave that list?
22 A
Sorrething to the effect of "Make sure we're all 23 right.
Make sure everything's running.
Cygna is going to be 24 here tomorrow."
f 25 g
So I would be correct in assuming that ould si i
70 j69 1
have acceptef that list with the upderstanding that these i
2 l were documents that Cygna wanted to look at?
i i
3 I
A Yes.
Yes, that should be a fair assumption.
i 4
0 You talked to, you said, Merritt from TUSI and 5
Frankum from Brown and Root that afternoon.
Did you tell 6
them that you had received a list of these things?
7 A
2 don't recall discussing the list any more that 8
day.
I lef t-early that day.
~
9 O
I realize this was,just an audit being conducted 10 l by an outside group of people, and I know that at Comanche I
i lPeaktheyhavealotofaudits,ornotalot, but scme audits '
11 I
12 conducted -- they have a lot of internal audits by TUS:,
13 TUGCO, Brown and Root and so on, various additors from those 14 different groups, 15 i
But it is not all that commonplace to have an auditi 16
. by someone from outside one of those three groups; would that IY i be correct?
?
16 A
An audit is an audit to me.
i i
19
'I O
That's right.
But this one had received some I
20 publicity in the newspapers; it was a known fact that NRC had 21 required TUGCO to have this audit performed.
So I'm assuming 22 that -- were managers instructed to do whatever they could to i 23 l get along with these people?
Did you have any sort of meet-i 24 i
'I j
j ings prior to Cygna coming in back in July or sometime to l
i say, " Hey, help these people out.
Try to make this thing r
L
~
i70 i
l cc=e eff as smoothly as you possibly can"?
2 i
I don't recall receiving any special instructions.
(
3 l
0 You don't recall att'ending any meetings where the i
i 4
i fact that Cygna was doing this audit was discussed?
5 l
A I remember at some coint in time somebody saying
}
6 j Cygr.a was coming in to do this review and that was about it.
7 As far as I'm cone'erned, nobody put that much emphasis on it.
8 l
g
'It wasn't any big deal'.
I 9
l' L
No; no big deal.
10 0
So you received this request from Ms. Williams on I
\\
II
!'the 24th.
You didn't tell your boss that you had receivec tne' i
u request; you didn't tell -- did you tell, what was this guy's I
13
,i nane, Frank, your direct subordinate over at DCC?
14 i
L Frank Strand.
15 O
Frank Strand, you didn't tell him you had received l 16 i
l i it?
l 17 A
I don't recall telling him either.
i 1
18 0
And you received the impression that Cygna was i
19 going to look at these documants the following day, on the
)
l 25th?
21
/(
A Yes.
22 0
In fact, they didn't then until the 26th.
23 A
That's my recollection.
Didyousayanythingtf O
on the 25th n
\\
about "Did you look at those documents," or "Did you get those
72
'j71 1
docu:.ents ready for those people?"
2 L
No.
3 G
Cr "Did you have any problem finding them?"
A Nothing to that effect, no.
4 l
0 Let me ask you one other question.
You said here 5
6 later on in your conversation with Brooks tha 7
was only the or the records keeper for one of 8
several satellites; right?
9 L
tarted out as a 10 i
0 But you said here in the last couple of months l
11 '
she had pretty much restricted her activities t is that i
U
' not Correct?
13 L
Yes.
n 14 0
Was that true in October?
i 15 A
{
I wouldn't think that would be true in October, no.l 16 0
So in Octobe
.as pretty much 17 j
18 A
D G
That was the reason you gave the list, becausel lasummuummer 21 A
All I can do is asstime, you know, if they were 22 coming to look at the satellites, then needed to be aware 23 of it.
24 I
O Why did eed to beIaware of it rather than somebody else?
t 8
6 9
O
i j72 i
1 A
Well, TUGCC OA had been in a couple of weeks before that and there were some questions about did we have these 2
j
) things secure enough.
"Do you have the right kind of barriers 3
i i
4 l up to keep pecple from interfering in the files" and all thet.
5 And those had' pretty well been instructed not to allow 6
anybody, you know, Tom, Dick or Harry, to just wander in.
7 l
I don't know.
This is just assumptions-now.
I
~
8 didn't want to b5'biindsightedby a bunch of people 9
I coming in and wanting to look at stuff.
10 0
You mean by giving that list to someone else and 11 l then having them go look for the records?
i 12 A
Well, if somebody walked into a satellite and said, 13 you know, "I want to go behind the counter and look at all l this stuff," as a matter of rule they wouldn't be allowed to 14 l
15 do thc-.
9 i
16 0
Would I be correct in assuming -- maybe I've gotten'
~
l f the wrong assumption here all along -- the intent 1:s. Williams' 17 l
18 l had when she gave you that list was that you gather these 19 documents up and have them in.a stack for her to look at or 20 her or someone to look at the next day?
21 A
I don't know whether that's what she meant for us to do or not.
She really didn't tell me.
23 0
Let me ask you this then:
how long would it take, 24 ff y give you a list of 32 drawing numbers right now -- I'm 25 in your office, I give you a li t and say "I want to see
74 s/J these."
1 2
i You want to see the drawing and all the changes?
i i
3 0
Isn't that what she was asking for?
t 4
L She was asking for the print-outs, the computer i
5 print-outs.
i' 6
0 If I give you a list and tell you I want to see 7
the print-outs, hoW long is it going to take me to get them? I 8
L' If everything is working, it should b'e inside of an I
i 9
hour.
If the system is not loaded, you punch it up and it 10 prints; you punch it up and it prints.
It shouldn't be that 11 big of a deal if that's all you want is just the print-outs.
12 0
Am I correct in assuming that all these numbers 13 l
she c. ave.vou were not on the ecm. outer?
14 L
Yes; some of the.were not on the computer, f
15 l
0 How long would it have taken me to get a list con-1 16 l
taining 24 that were on the computer and eight more that I
l 17 I
weren't?
l l
18 l
A That still should have been able to be.done in an ;
l i
18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
l
(
20 0
Have you had any of these type audits before where 21 somebody ccmes in and gives you a list of numbers?
i 22 L
Yes, we get lists all the time.
23 0
Do they usually give you a day in advance to l
24 gather these things up or print them out or whatever you do l
l 25 with them?
75 l
j74 1
A I can only tell you what -- not firsthand 2
l knowledge, but we get a lot of lists from the TUGCO auditors:
3 we get a lot of lists from your people.
If they're looking
} into something particular, they'll leave us a list and say '
4 i
l "How about running these for me?"
Then we get them ready and 5
6 we'll take them to them.
7 O
So it w'ouldn't be unco = mon for them to get those a 8
day in. advance?
i i
1 9
l A.
No, it is not unco.T. mon.
10 0
Is it uncommon for your people to review those be-s t
11 fore they take them to the people that have requested them i
l to make sure they are in order, contain all the information?
12 13 A
The only review they would probably do was to makei 14 l
l sure that whatever is on that log is also in that package if j i
l 15 that's what they wanted was the package.
I 16 i
O What if it wasn't?
I i.
17 A
Then they just punch the button and it prints a 18 copy of the manual log.
There wouldn't be any review going 19 on, no.
20 0
You said that in July they found some shortcomings 21 in the Document Control system, in the program; is that 22 correct?
I 23 A
Yes.
e4
~
O A lot of deficiencies?
25 A
There were quite a few, yes.
I I
-w
j75 1
g How did you find out about that?
e t
2 A
I think that was through a session with some of 3
the Cygna people and some of the DCTG people and also some of 4
my people.
l There was a little confusion as to, you know, 5
6 which group was responsible for which.
7 0
Which d'eficiencies?
8 A
Yes.
9 O
Did your supervisor ever talk to you about it or 10 I
ask for an explanation of why these problems existed?
11 A
Did my supervisor?
8 i
12 O
Yes.
13 A
I recall him being part of some of those discussions 14 But as to why these deficiencies exist, I don't recall that 15 question.
16 0
You mean it was no big deal?
1.
l A
Mo; we knew we had those problems in the file cut-IE todian versus the DCC; that's why we set the satellites up, 19 one reason.
20 g
Did you expect to have some problems with those 32 21 that you wer.e given on October'24?
22 A
No.
23 0
You didn't expect to have any problems with those?
A No.
~
t N
O Why?
77 l
'j76 s
1 I
A.
'I felt like the system was working.
You know, we' I
2 l
had had from whenever we started the computer base, either 3
late-July or early-August, we had from then until Octcher 15 4
to get the two systems merged and get the bugs out of it.
5 We even beat that date a little bit.
I was confident.
6 MR. DRISKILL:
I don't have anything further.
7 BY MR.' GRIFFIN:
s
~
O.
g as I said before, th'e office of
~
8 6
Investigations, I believe, will be getting into an investiga-10 tion on some of these issues.
We haven't actually defined 11 all the areas that we're going to be going into.
12 I personally consider today's interview a prelinin, l
l ary interview with you.
I think there might be areas that we ;
13 14 have not discussed.
I can't help but believe there are addi-l 15 tional points or areas of inquiry.
So I think you can expect l
16 to be contacted by us again.
17 One of the things that I am going to request of 16 you is that once the investigation begins I probably will 19 come down and ask you for those internal audit reports that i
20 i
you were saying were available.
21 When the tine comes'that we need to interview you 22 again on this matter, should we contact your attorney or you 23 1
to set up the interview?
24
~
MR. CHARNOFF:
I thin}[ y' ou ought to contact Carl 25 Jordan and set it up with him.
j77 1
MR. GRIFFIN:
All right.
4 2
l BY MR. GRIFFIN:
3 0
do you have anything you would O
4 I like to add to the record as an explanation for -- like I
(\\
5 l said, there are many questions lef t unanswered.
Is there l
6 i anything more that you would like to add?
7 A
Yes, a ' couple of things; one being that the envirod-
~
bent in. this, kind of inte view ~ is quite a bit b'etter than 8
9 what I went through in the hearings up there.
That is not 10 verv oleasant.
Now, that's out of the way.
l t
f This whole thing is against my character.
To have 11 12 I
even been associated with having rigged anything or set up 13 anything, that is just not my nature.
In fact, if I suspected 14 that anybody had done that sort of thing, I would have fired 15 them without hesitation.
16 I have been out there eight years and I have put I
a lot of time and a lot of effort in that plant.
18 It is just not my nature to do anything like that.
18 I hepe this investigation bears thtt out.
I'm as anxious as 20 anybody to get to the bottom of this.
{
21 G
Today's inquiry and ' subsequent interviews of you m
will be just concerning the facts in the case.
23 I presume that your statements to day have been 24 truthful.
Can we count on that?.
J 25 A
They have, to the best of my knowledge.
1
?
have I or any other 1:RC represen.
2 tative here threatened you in any manner or offered you anv 1
1 (O
3 i
rewards in return for this statement?
4 A.
No, you have not.
I l
0 Have you given the' statement freely and voluntarily:
5 i
6 l
7.
I have.
i MR. GRIFFIN:
Thank you.
7 i
I, (Witnese excused.)
8 9
(Whereupon, at 3:35 p.m.,
the interview was i
l concluded.)
10 li i
_o_
i n
1 12 i
13 i
14 15 i
16 l
l I
17 18 l.
19 l
20 21 22 23
~
24 ob -
I i
l CERTIFICATE OF PROCEEDINGS 1
l l
2 This is to certify that the attached proceedings before the 3
I NRC COMMISSION 4
In the matter of:
Tnvestigative Interview of gs l
M i
l Date of Proceeding:
Monday, February 27, 1984 6
l l
Place of Proceeding:
Arlington, Texas l were held 'as herein ap. pears, and that this is the original 6
I i
transcript for the file of the Commission.
9 I
10 l
Judith A.
Tobe man 11 j
j Official Reporter - Typed 12 13 g
.., ~
a
}g Official Reporter - Signature 15 I
I i
16 l
17 i
18 19 20 21 22 1
23 l
TAYLOE ASSOCIATES REGISTERED PROFESS [ONAL REPORTERS.
2.5 NORFOLK, VIRGINIA e
1
yL kY
?
f
.t 0 I
F.ere is anotner one wnere I was told if I couldn't co it he would get somebody else 3
~
that would do it.
4 You have got some CCW surge tanks and they are 5
definitely O.
6 MR. GRIFFIN:
What is CCW?
I Circulating water. These are 8
hanging frem tne ceiling and eney are pretty neavy.
They o
weigh lixe 40 tons apiece and wnen tney are full eney 10 weigh like 70 tons.
Well, you have got some anchor bolts II up here that suspend them in tne air, you know.
la Okay, they bolt it up they are supposed to go 13 up ana meet concrete. This is your anchor bolt embedded in
\\
~
I4 tne concrete.
It is supposed to go up real snug and they
)
J I*.
are supposed to torque it to foot-pounds.
16 MS. ELLIS:
Do you Know if snose are hilty I
bolts?
8 ey are procaoly some type of 19 7 301.,,
- 0 MR. HERR:
Why don't you label that.
21 That is concrete, tnis is U
steea. and tnat is your bolts rignt nere, and that is your
'3 tank. That is your plate there, like your base plate which a 4 is on top.
U MS. ELLIS:
What are these?
TAYLCE ASSOCIATES 1625 stat:7. N.w. - surT too4 v
WASHINGTON. D.C.
20006 bf (2o2: 293 29so F0/A 5')
BLw
LJ I
There are stiffeners rient lc nere tnat suppert your tank.
he nas to come in and add more. stiffeners anc add a plate up nere.
(
.nibit No. 11 follows:)
5 6
8 9
10 11 12 13 e
14 15 16 17 18 19 20 21 22 23 24 05 TAYLOE ASSOCATES 1615 i STRIIT. N.W. - $UITI 1004 W A3HINGTo*f. D.C.
200 %
(202) 291.1950
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1 Tnis is wnat your product is 2
supposes to look lixe.
ell, vnen we got down there to ao w
r.
3 our rework on it and just add some extra _ stiffeners and
__.../
some extra plate, Iseenwner[
houpcosein here and the 6
pattern.
I So instead of them plug welding tneir nole up h
I r and oeat 5
pJa ey started
}m is A' Gkf 8twtW N'
le A
nonnu c
g fi
% % 5/oTR.D 6 951. feart p h0W h,,
11 g 7qg)q txgav58dd. %i$ is mocqbly I'hL tney was II g 73L,g5 @[s
- Icating).
II r
14 leal, out i
1':
to get it 1(
rou can stil' G'
17 f;5#
see it prcbacly right now.
18
.%S. ELLIS:
So the enes tnat were ---
19 The ones that were straight U
is damaged because tney were stretched.
Now I know this, 2I that we had to come back and put plates on nere, 22 stiffeners.
So I told tne men, I said just take one off, 3
put a plate on, put it back up and weld it out and tnen 24 take another one off.
That way your tank won't come down 3
because it hac all sinds of stuff welded to it.
TAYLOE ASSOCIATES sazs i stun. N.w. - sum too4 WASHINGTON, D.C.
20004 (2021 293 3930 1
\\
~
~h
. ji s
so he\\re come cae of my crew and I saic now it I
i 2
nas got to be torqued.
Every se many foot pounds it 3
supposed to ce torques. He said we are torquing out oefore 4
we ever get up.
In other words, here is a not down here 5
torquing out oecause all the threads are stretched on it.
6 Tney ' stretched the threads here and galled it when they I
backed off.
I told him, I said get you as chaser nut and 8
run ot*er 1.
1.a t is une only tning you can do anc go in 9
anc snug it up.
But, anyway, I told g I saic man, I said 10 11 tnat whole tank needs to come cown anc we need to move t.$e 12 hole ove::.
'we snould have put a pull test on the stud anu 13 checked the strength to see if it would withstand a 14 certain ' amount of poundage.
15 That is wnen he said, if you can't do
- nat, I will get somebody stiat can, you know.
He don't 16 17 like me te bring up pro'lems.
So it is still tnere.
c 18 That iE very simple. All you have got to do is 19 go down and tane a flashlight and shine it and you can see
^
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Also, you are supp O DE M a Certain ...
f amount of.clate here for ex.cansion, and I am sure.vou will s
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know how rar you want to get into this, you know, as a h
3 fine line.
Are you talking about extremely bas. Lixe the 4
condensers, for instance, we took air hammers and sledge 5
hammers and Deat tubes.
That is a no-no. Anybody would 6
know.that. You take a copper-nickle tube about as thick as your wedding band and you take a 16 pound sledge nammer i
8 an drive them.
ide put ice on to shrink tnem and put tnem 9
in the condenser.
Inat is a no-no.,You are supposed to g
10 j
ease tnem in witn our hand so they can expand.
6 II MR. GRIFFIN:
Was that particular instance in 12 your testimony or in your affidavit?
I3 No.
y, 14 MR. GRIFFIN:
That is new?
15 No, it is all new. We split 16 tuoes, belling.the tubes and flaring them.
We split tuce 17 sheets.
I reported a tube sneet split to Westinghouse.
18 They said on, my God, you know, yeah, yeah, yeah, anc all 19 tnis stuff.
The next day we had a meeting and we all went 20 there ana enere most have been 45 or 50 people.
21 MR. GRIFFIN:
Hnen was this?
22
$ t oj y \\
Tnis was a couple Of years 23
- ago, 24 MR. GRIFFIh:
Where are these tube sheets?
25 ti:
They are in the condensers.
l
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1 But anywsy, we hac a problem.
So we got tnere with 0
hestningnouse, and tney go snat is not a Westinghouse proolem.
What proolem? See, the day before tney had a 3
4 problem that a tube sheet was cracked.
Then all at once 5
they con't nave no more problem because they called their home office and tney probably said you idiots, don't tell 6
So they said the only problem we have is the tubes
~
rnem.
8 are not rolled up tight enough.
I said, we are cracking tne tube snests already and tney are rollec at a minimum 9
10 and not a maximum. I said we would be in trouble if we had 11 to roll them to the max, or if we had to roll them over 12 tne max, s u p e r r o l l,,,t n e m.,
. r,,
1 13 (At,this point in the proceedings @ #
h is refe,rring to Exhibit 1.)
14 II Bere is your water boxes right here and your condensers.
All rignt, in condenser A on tne inlet end on 16 4.ne west box and it is in three sections.
You have got I
I8 some cracr.ed tube sheets in here.
Back there you have got some cracked tube sheets. You have got overrolled tubes or 19 20 barely overrolled.
They are supposed to be rolled 069, 21 tnousand is a pe,rfect roll inside reading.
They allow us Ke went up 90-some tnousands.
22 to go to 071 tnousano.
I nad one hand come tell me and say my 23 Manually ne rolled it so tight the 24 expander run out.
expander and motor jumped off.
They just pop them just 25 TAYLOE ASSOCIATES 1625 I STREIT. N.W. - SUITI 1004 WA5HINGToN. D.C.
20006 (202) 293 3950
~
35 I
lige popcorn.
It is tne wrong type of condenser for the 3
wrong type steam generator to start of f with. It was a $10 4
million goof-up.
Westinghouse said wait a minute, I thinx 5
we can straight this proclem out since it is air 6
condensers, which they went bankrupt and are no more in
~
f.he concenser business. They decided they had to B
intergroove a tube sneet.
They toer, an inch anc a cearter 9
tube sheet and they cut it in half.
Tney should have used 10 two tube sheets if they were going to do that and mace it II twice as strong and not half.
U MR. GRIFFIN:
Are tnese things still tnere?
13
,9 They are still there, yes. All 14 you got to do is go in tnere.
Itjks really terrible. What 15 I would suggest doing is on the big ones lixe 90-some 16 tncusand is cutting the tuoe out and look at your sheet.
l.
b There is a spider wed crack.
I showed the people the' 18 crack, and that is wnen I first starting getting the 19 pressure, this is about three years ago, after I reported 20 this stuff.
I kept on insis.'ng on tnis crack, and then 3
21 everyoody would go oo;i, and 6, he would go, you gi U
know," g, I am not for sure they are cracked.
I would 23 go I am not. You know, you can throw a cat tnrough it, and 24 he goes no, no, no.
25 Well, undoubted TUGCO told nim to back off.
TAYLOE ASSOCIATES i
1625 i stun, N.W. = SUM 1004 WASHINGTON, D.C.
20006 (2021 293 3950
_ l
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kneyweretalkir.;acout several years er rework and I
2 n.illicns of collars.
So they are talxing aoout time and 3
tney oon't want nothing to stop this plant.
M) 4 These tubes are titanium tubes and enere 5
should be twice as many support sheets in tnere and all 6
that stuff.
So they intergrooved the tube sheet and they I
still have got leaks over there on this section here and 8
we are not supposed to nave no leaks at all.
9 MR..iERR:
Sne can't see "rignt tnere" --
10 (Indicating the reporter).
So whea you say section one, II identify wnat you are pointing to.
)
Okay. Condenser B, Unit 1, 12 13 west disenarge,. water h.oxiand you have got a cracxen tube a.
w 14 sneet.
Also, tne tuoes are overrolled severely.
15 On the east water box, condenser B, discharge And, you are heavily overrolled and you undoubtedly nave f
16
/
l 17
/ got cuite a few cracks in it.
I can swear to that. Iknow/
18 you do because it swelled up so big.
19 Overroll on the west box, condenser A, Unit 1, 20 discharge end.
21 East water box, discharge end, condenser A, 22 you are still leaning, and overrolled.
23 Tne more you rell, tne more tney leak.
They 24 more they leak, the more you roll, and the more your roll, 25 tne more damage you are doing.
They just went nuts with TAYLOE ASSOCIATES 1625 I STRHT, N.W. - SUITE 1004 WASHINGTON, D.C.
20006 (202) 293-3950
26 i
it.
2 Condenser A, Unit 1, intake box, tne west box,
~
3 u nave got cracxed tube sne It is very simple to checx because 1 put 4
5 little plugs in tnere. You can just take a wrench and just 6
screw your two nuts loose and pull the plug out and look 7
at it and put it right back in.
It wouldn't take five 8
minutes to loo 9
ust referred to 10 follows.)
11 12 13
~
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l' g did anybocy intimidate you P.R. GRIFFIN:
2 into overrolling tnese tnings?
3 h
he had an engineer there from 4
TUGCO saying get it a little more, get it a little more te my people. I went and tolo @ I said they are killing 6
that water oox.
Nobody had ever did the tube work before I
and nobody knew.
They are experimenting with an item.
8 In the first place, the condenser wasn't a 9
very good cesigned condenser, in my opinion. I have werne:
10 on them since I was 15 years old.
These was I woulo say II between 1 and 10 aoout a 6, you know, a so-so condenser.
12 Wnen tney intergrooved tneir sheet, they macc the sheet 13 real, real thin.
A 14 MR. GRIFFIN:
But did anybody tell you or 15 instruct you to do that?
16 S
I was instructed not to stop II leaxs, for instance.
I was rolling tubes and I was 18 stopping the water box from leaking.
I have got a water 19 box over here leasing and it is still leaking.
I go tel_1 20 Tanley, and Tanley says how does that box lo,o_k, and I said o
21 it loons good but the otner one started leaking again, and I have got to get it.
He goes goddamn, @, I can go 22 23 tnere any day and maxe things better than tney are.
I 24 don't want you to do tnat.
I go I am just trying to stop 25
- ne leans, you Know.
You ain't supposed to have leans.
~
TAYLOE ASSOCIATES 1625 i STRI!T, KW. - SUITI 1004 WASHINGTON. D.C.
20004 (202) 293 3950 l
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{ste 1
Your river weider*1eans into, you know, snat 1 - ~~~
generator and you can't allow no river water inside, lage 3
water.
So it is still leaxing. My problem was I of course 4
couldn't do a good joD.
A MR. GRIFFIN:
You are saying it is still 6
leaking-today or it was still leaking when you left?
I was still leaking wn 8
left and it is still leaking tocay because they didn't 9 (reworsit.
~
10 ER. HERR:
Who was th neer?
11 12 MR. HERR:
Let me cet one thing straight.
13 Excuse me for a second.
and were
/
14 r Umy7our supervisors?
Q 15 was my 16 supervisor.
i 7.
17 MR. dERR:
hhat was his title?
18 was the superintencent of 19 tne millwrignt department.
20 MR. HERR:
Who was the other guy, Wnat 21 was nis job title?
22 f) e was a tnrN striper. I 23 don't know where he come from.
he don't know anything. He 24 is supposd to be a millwright tnree striper.
23 MR. HERR:
What is a three striper?
TAYLOE ASSOCIATES 1623 i STRUT. H.W. - SUITI 1004 WASHINGTON. D.C.
20006 (202) 293 3930 3
e S
2 l'
N.en nn come down tnere and told my men if tney didn't 2
pusr. a snocsand by the next day tneir ass was going out 3
tne gate, and he is on the radio every five zninutes all 4
tne.next day.
I pushed to lunchtime and we got a nur. dred.
This is g O.3 5
MR. GRIFFIN:
6 C
and he cussed and raised hell anh he,said their ass is going out the gate, 7
a, s
He says you can stand here and tell me a hundred reasor.s 9
way tney won ' t go, out he saio if them sons of bitenes 10 ain't in there and you don't put a thousand of tnem in 11 there tomorrow your goddamn ass is going out that gate.
12 Tnat is wnat he told them.
13 So ne sledge hammers and he beat them and he s
.em, gotairgunsanddebeatthem.
He put ice on them. Be 14 15 knows nothing about condensers.
You don't do that stuff.
m 16 MR. HERR:
Who did he tell?
17 3'
Joe Snookhouse and Johnnie 18 Kinham.
19 MR. HERR:
Anybody else?
r 20 Ll.
Well, they was working a bunch 21 of laoorers.
22 MR. HERR: These two men that he tcld, did they 23 do wnat he said to do?
24 Tney tried to. I was down 25 tnere witn them and we tried to push a thousand in or else TAYLOE ASSOCIATES
(
taas a sTauT. N.W. - SUM 1004 WASHINGTON. D.C.
20004 (202) 293 3950
~
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(L) 1
.v.R. GRIFFIN:
you cidn't discuss tnis 2
particular proolem in your previous afficavits?
h 3
No, I didn't discuss it with 4
anybody because it seemed lixe when you bring up a probler 5
it is covered up.
In my opinion, it 'is not corrected at 6
all.,
That is the reason I wanted to bring it out and I 7
woulo like to snow people.
They stuff here coulcn't have 8
been covered up except by paperwork be euse you can g:
9 cown :nere any day of the week an6 read the inside 10 diameter of your tube and you know you are overrolled.
11 Everytning that I could actually put my finger 12 on, like the letter, they automatically agree, Just lixe 13 tne lignt poles, you know.
That is a 15 cent item.I e
14 brought up.
Well, they jumped on that with both hands and e
15 both feet and made a big deal out of it.
They really 16 cleaned tnat up.
~
h 17 u.
fvell, you trave got som spray pipes 1so down 0
18 in there. Kell, it is going to be a bigger job to cut them d
19 loose to do it.
They haven't even mentioned that, see. I 20 think I mentioned that one in my affidavit.
Tnat goes in 21 tne fuel pools. -You have got four spray pipes tnat go down 22 in there.
The holes of it was undersizeo and tne pips 23 department went in there and redrilled them and they used I
i 24 cutting material, luce oil or some type of cutting oil and 25 they just pulled it off and tnere it was.
TAYLOE ASSOCIATES 1625 i STREIT, N.W. - SUITE 1004 WASHINGTON, DI. 2C006 (202; 293 3950
64
[l concerns us, and one of the,tnings that concerns us aoout 2
any follow-up of tnis.
We woulc much prefer that someboc; 3
other than tne, Region..IV. inspectors go out and follow-up 4
on this.
5 on your inlet tube sheets.
6 They are 1/32nd flush, the tubes, and tney are flared.
If 7
they are sticking out, you get a builo-up between your 8
tunes.
So when we flared these we busted a lot of tueer, 9
or cuite a few of them as a matter of f act.
10 Now tnis chart, and it sticks out, but we cut 11 them down like a half inch so it would look nalf way 12 6ecent.
But when we was flaring these tubes tney was 13 busting pretty bad, and the reason they was busted so bad in this one area is because tne counterbore in your tube 14 15 sheet where it allows the flare to flare out was way
'6 overboard.
So in order for us to flare it richt 4
enough we 17 busted a tube, and the ones tnat oian't bust we hadn't 18 flared it tignt enough.
When you don't flare tnem tight enough you get a build-up between your sheet and your 19 20 tuoes and it sats the tube off.
21 Just 11xe tne joo in North Carolina, we htc 22 holes in all the tunes before we ever got tne fuel in i
23 tnere. Tne first twc weeks it was eat up. So insteac of us 24 repairing it, we had several months before the fuel came 5
in, they went aneaa and poxled it in and used it as is and TAYLOE ASSOCIATES 1625 i STRitT. M.W. - Suf7I 1004 s.
WASHl% TON. D.C.
2C001 (202; 293 3930
~ -
~
9 a-Government, I would call ne Feoeral Government.
You call TUGCO.
I go well, I sai6 I triec to call you guys first 3
and you all weren't there.
Do you think we are going to 4
sit oy this goodaran phone and wait on you to call?
4-5 well, I guess you dre trying to discourage me to m'ake me quit.
Be said well, mayoe you are finally I
getting the loea.
I said, well, I will tell you, as long 8
as you sen cf a cit:n pay me general foreman's wages, I will sit in tnis little tool room forever. He saio we will see aoout tnat. So that next Monday morning they give me a 10 II encice.
12 FA. GRIFFI6:
So is it fair to cnaracterize 13 that wnen you first raised our concerns, tnat that is when
~
3' tne harassment started?
b)
The pressure started. The 15 16 first deal they thougnt tney had me controlled was the II cenoensers.
I wouldn't admit tnat tne tube sneer was not 38 cracxec.
I;veryoocy r.ept on saying that is a scraten, and 19 you r.now it is a scratch.
I said, no, it is a crack. I 20 n LP on it. I took a flashlight and snined it in e
21 one nele anc you coula see tnrougn it, tne spider web. But I never did ad: nit snat it wasn't n'cract.
So I started to 23 get rina of a little pressure then.
I guess Tanley told 24 them well, he is oxay, you know.
25 MR. GRIFFI6: Am I right in cnaracterizing your TAYLOE ASSOCIATES ts2s sTauT. w.W.- sum too4
(
WASWNGTON. D.C.
20004 (202: 293-39s0
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r.R. GRIFFI8:
1 Ininr. cur people will unaerstand it.
],,
Someshere down here tney nad a 3
4 nice thick tuce sheet to start off.
h is leafing through his 5
6 noteboost.)
7 This is a real good example.
These tube 8
support sneers came in.
We laid them on top of each other 9
and.ce put acwel pins in :nsm.
Scme of toe noles was 10 three-eigntns of an inch off from*the otners, you know.
ly 11 So I called @ ' and I told him, I said we 12 are going to have a problem here. These holes are way off.
13 hell, he calls Westinghouse and Westinchouse says ch, 14 tnere is nothing to it.
- says, they are just 15 three-eighths of an inch off.
I said well, you have got 16 three foot from the center of one sheet to the other, and 17 wnen you start off with three-eighths of an inch off you 18
' are off quite a ways when you get to tne otner ena, you 19 know, tne three foot.
20 If you go tnree-eighths of an inch off, over 21 nere you nignt be an inco and a half off, and cy tne time l
22 you turn it cack in then automatically you are going te i
23 head the other way.
So you are binding every sheet. You 24 are cutting into the tubes.
25 Tnese tube support sheets ars =r.dc with 4 l
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5 MR. GRIFFIK: J.
R., I think we havd 97t enougn 2
on that wnere our people can probacly go out and look at 3
these.
4
(
Oxay. We was welding the 5
condenser to the turbine.
Again, I hate to bring up 6
experi,ence, but when you are bringing this condenser up,
~
you set tne condenser igw, but when you set the turbine in 8
they can set it on the right elevation and not be in tne E
way of tne condenser.
10 When you get your turbine perfect within so 11 many enousandths, you bring your condenser up to meet. You 12 don't make a contact with your turbine. You come up like a 13 quarter of an inch or an eighth of an inch with your I4 expansion joints.
You have an expansion joint in bet;we it.
Then you tie them together.
16 Well, the condenser was so heavy when you load II it with tubes and ever'ything. It pronably weighs 600 tons.
18 hell, we toox all our jacks and put tnem.on one end so we 19 had to rack it up.
Of course, wnen you jack at one end it 20 tnrows it way in and then you pick tne other side up and 21 it enrows it way in.
U So I told tais general foreman, and I was just U
foreman then, but I told the other. foreman don't tie 24 anything to tne turbine to tne condenser.
I said we are U
going to go up and it is going to fall down, but when we TAYLOE ASSOCATES u2s i STRUT. N.W. - SUM 1004 WASHINGTON. D.C.
20006 (202) 293 3910
.)
1 60 I
orang the etnor cida up it will ctraigntsn back out cnd wa 2
will Keep werxing itluntil we bring it up.
3 Well, this general foreman, he gets there and he starts welding all gind of stuff to nold it to keep 5
from coming past it.
Well, what we.did.was we jacked the 6
turoine.over.
We went ahead and got it up. Well, instead I
of them mar.ing a final check to see whetner they was in 8
line or not, they just assumed tney were and they was three-eightns of an inen off.
So we welced it all 10 togetner.
U They took a reading and tney was three-eighths 12 of an inch off alignment.
So they went up here and they 13 took jacks and Oney started jacking and, ooy, jacked it 14 all tne way over to wnere they want it and they release 15 it, that little old expansion joint, and pulled it back.
16 The little expansion joint was'a one loop and it was an I
eigntn of an inen tnick and it had one little fillet welo 1
on eacn sics of it, real wear.
Tney put several, several 19 tons on it.
I will show you what it looked lixe.
20 Exnibit 5A and SB follows:)
21 22 23 24 25 TAYLOE ASSOCIA115 1615 i STRitT. M.W. - SUITI 1004 WA5HINGTON. D.C.
20004 (202; 293 3950
)
e 49 Il*
I MR. GRIFFIG:
wnere tnoro engineers involved in all tnis work?
h 3
No, a lot of it there weren't, 4
n o.-
5 MR. GR.t.i ilh :
Your crew was down there putting 6
this turbine on top of tnis condenser?
I i
Right.
J 8
51R. GRIFFIh:
Is tnis a non-Q area also?
9 Rignt, it is non-Q. We are 10 down here tnrowing tnat turbine back.
They started having 11 us jacx it.
We jacked it up and down putting all sind of 12 stress on it, and well sideways.
You i.now, you can tear 13 tnat little expansion joint out, fg 14 So I f.tnally told and tne general 15 foreman over the turbine that I weren't going to jack it 16 no more witnout tnem giving me written perr.ission to do'it II or telling me to do it in writing because I says I might 18 want to worn another joo somewheres, and I saic I will 19 never work for Brown and Roct again if we rip it out, but 20 I might want to worx anotner construction job, you know.
21 So finally tney quit jacking it then.
5 Also, as we jacked the condenser up, tne pipe 23 department was tied in with our pipe.
They was also 24 suppose 6 to tage a pipe up with us, wnich they didn't do, 23 and we put a lot of stress on the pipe.
TAYLOE ASSOCIATES 1625 13TILHT, N.W. - SUITI 1004 WASHINGToH, D.C.
20006 (202) 293 3930 i
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This right here is just snowing ID f the 2
hele, tne 03 of tne tune and OD of the tube and hat it is 3
supposed to me 1ike after we get through rolling it to be 4
a perfect roll.
5 MR. GRIFFIN:
The condenser tubes?
.h Right, on tne condenser. This 6
I is tne minimum we are supposed to roll tnem, the ID 8
reading.
MR. GRIFFIN:
Can we have this also so we can 10 give it to the inspectors?
11
[
Yes.
I2 MR. GRIFFIN:
We would appreciate that because l'
if tnese guys can go right to the stuff and look at it, it 14 will sure be nelpful.
15 hibit 6 follows:)
17 18 19 20 21 22 23 24 25 I
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If th'a rocctor overh cts one o anfoty valvo lif ts and it dumps water and it goes into this kind of a spray 2
tank and it cools the water down before it is dumped into 3
a further part of the system.
Well, at that time that system was not safety.
5 relat.ed, and why it wasn't we have never been able to 6
figure out.
Since the Three Mile Island incident, which 7
that is where the water went exactly out through that same 8
line only in a different type of plant.
So I suspect that 9
may have been upgraded.
10
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13 floor, about this high and about that big around --
f g
I (Indicating). It had factor repared end n it and it had 1
g3 N~ - -. -
l 16 just been wnacked off.
So we looked around and thgre
/
wasn't any other system that it could have come from g7 I
except that pipe that had just been welded in.
33 So we went down to see our boss and he got
/
_ quite disturbed that they didE't have any kind of a cut 20 authorization or anything. fSohegot to checking a D d 21
~
d found out the tning was not safety related.__ -
g (The reporter requested the dimensions of the g
pipe for the record.)
g It was about that big around --
3
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TAYLOE ASSOCIATES
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1625 i STattT, N.W. - $UITE 1004 FotA-8F Si WA1HINGTON. D4 2000.
(202) 293 3930 h
(Incicating.)
[. 8 3
MR. GRIFFIN:
I' don't know whien pipe this is 2
other than it is a non-safety related pipe.
3 9
MR. HERR:
t is about 18 inches in siamet 4
5 About.that, yes, but of course that is a couple, tnree or four years ago. It is somewhere 6
between this big and this big -- (Iridicating).
a e
e pe sor of 8
the QC people for Brown and Root, right?
9 "8*
10 MR. HERR:
And he wasn't your boss. How could 33 ne threaten to fire you?
g Well, I was n Brown and Root's 13 payroll.
g MR. HERR:
Oh. So this must have been back in l.
15
'77 tnen when tnis took place.
I see.
16 1
MR. dERR:
See, everybody that worked in that 3_
f fice worked for somebody othe-2 than TUGCO.
There were
'8 some people in there that worked for Gioson and Bill.
my boss, worked for Gibson and Hill.
Flect works O
for Gibson and Hill.
Is Fleet still out there, a concrete g
expert?
MR. GRIFFIN:
I don't know.
g He miht be gone by now.
He was g
TEDCO's concrete wizbang and he worked for Gibson and
,a.
TAYLOE ASSOCIATES 1625 i STREET. H.W. - SulTE 1004 WA$HINGTON, D.C.
20006 (202) 293 3950
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-y They stick those vibrators in e-there when they are between the forms and they shake all 2
that stuff so the concrete will go down. I have heard from 3
several people that yes, that in fact did happen. That was 4
before I got there.
There is another guy that needs to be 5
subpo.cnaed.
6 MR. HERR:
What is his name?
7
}
N: W,and Q - - = know this 3
9 guy.
MR. GRIFFIN:
If we ask them for somebody that g
knows about tne foundation.
11 p
- h Yes. He was working down there when he said they threw something radioactive in the lake
+
13 one night.
The NRC when I told them about it before, they :
g said, that is impossible. Nothing could be radioactive out 33 i
there at that time.
16 I was looking through my turbine book and I g
saw that they used tridium gas to inspect for leaks in the hydrogen cooling system, you know the generator.
They put i
tridium in there with the radioactive hydrogen to check g
for leaks in this hydrogen cooling system.
g As far as.I know, I was the only person on the site that could read, write and speak German, and the guys from the warehouse used to come up there twice a day to my g
office and say wnat is this thing or what does this mean TAYLOE ASSOCIATES 16231 STRitT, N.W. - Sulit 1004
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20006 (202) 293 3930 6, 23
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it on this package or box,. and I would go down and look at
~ - Ti-I and say it is a box full of gaskets or it is box full of
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it is part of a stream brow or something.
.t. : E bolts or i
3
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They had stuff coming in there for years.
It i
a g c.-
c 4
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- 1pC, all came from Germany and they hadn't the faintest idea
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what half of it was.
The Allis Chalmers people would come
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it and down and they would pick around through some of e
=;,pk, n
7 then they would haul,,some of,it up and they would start 7.':;:in.
8 putting the turbine together.
,n~-
think tnat possibly the Germans had sent
('i,(y' 9
Now I
- :~.-~.
some leak i' ' f;l 10 some bottles of tridium or something over, n
.Ji
,;."J detection system for that turbine and it turned out that 12 somebody didn't have a license to handle that stuff and
.; W:
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they pitched it in the lake.
That is a possibility. But
' ]; -
?
13
'G-this guy swears to be damned that they threw something
,j g
Ani 15 radioactive in the lake.
i::51 MR. GRIFFIN:
Who was this't g.]r 16
.(fjj 1
37
- m.cr 3 This is the same guy that knows L :.
m
'E.5.
about the overexcavation.
.Ii MR. GRIFFIN:
Is he the one that threw it in
- .3.
19 C.;
20 1/
J..b the lake?
I think he drove a cherry picker g i,.
.a g
ij, '
22 or something, or he drove a truck or he did something.
Did
- -[
g That sounds familiar to me.
MR. GRIFFIN:
28 you make a press release at one time about that?
,j, TAYLOE ASSOCIATES 1623111at17. H.W. - SUllt 1004 W ASHINGT ON. 0.C.
20004 (202) 293 3930 0
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against the cracks in the high-pressure turbine casing.
I g
l aim st got fired over that.
At that time the turbine 2
wasn't safety related.
I don't know if it is now or not, 3
or if it has been upgraded.
4 MR. GRIFFIN:
The turbines?
5 es, are they still not safety 6
related?
7 I
MR. GRIFFIN:
I don't believe so. If the 8
turbine goes out, and don't hold me to that because I 9
don't have any technical background, but I believe if the 10 turbine stops it just quits generating electricity, but I 11 i
don't believe that causes ---
12 l
Well, the problem is your heat 13 removal systems.
If that thing is going at full power and g
the turbine blows apart, then everything shuts down and f
g3 that heat removal system is not capable of removing all 16 i
that heat rignt off the bat.
37 MR. GRIFFIN:
It is my understanding they have gg some other systems that come into play.
Don't hold me to
,9 this, but I don't believe that ~ the turbines are safety.
20 But in any event, I found some 21 cracks in tne upper-high-pressure turbine casing.
I tak'e I
g that back.
It was the lower part of tne casing.
g i
I Basically nobody wanted to hear about it.
I g
brought one of the Westinghouse mechanical engineers up
,,5 h
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f TAYLOE ASSOCIATES ta2s a sta!!T, N.W. = Sulf t 8004 WA$HINGTON, D.C.
20004 (202) 293 3930 B 24
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