ML20205Q506

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Forwards Congressman Markey 861120 Request for All Documents Provided to NRC by Milam Re Allegations Concerning San Jose,Ca Facility.On 861212,NRC Will Allow GE to Review Matl for Proprietary Claims Per 10CFR2.790
ML20205Q506
Person / Time
Issue date: 11/25/1986
From: Shoemaker E
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To: Beverly Smith
GENERAL ELECTRIC CO.
Shared Package
ML20204B851 List:
References
REF-QA-99900403 NUDOCS 8704030548
Download: ML20205Q506 (92)


Text

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/ o g UNITED STATES

~8 o NUCLEAR REGULATORY COMMISSION c j WASHINGTON,0. C. 20555

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NOV 2 51986 l

Darton A. Smith, Esq.

General Electric Company Nuclear-Energy Operations Legal Operation 175 Curtner Ave., MC 602 l San Jose, CA 95125

Dear Mr. Smith :

Pursuant to our telephone conversation yesterday, I am enclosing in this letter a copy of the November 20, 1986 request from Congressman Markey to Chairman Lando W. Zech, Jr. of the Nuclear Regulatory Commission for all the documents provided to the NRC by Mr. Sam A. Milam III relevant to his allegations concerning the General Electric Facility in San Jose, California.

Based upon our March,1986 conversations concerning the proprietary information agreement executed between the General Electric Company and the Government Accountability Project,it is our understanding that some of this information may be considered proprietary to the General Electric Company and it is further understood that the General Electric Company may wish to make a claim pursuant to 10 CFR 2.790 of the Commission's regulations that all or some of the requested information should be withheld from public disclosure. Accordingly, the NRC will allow the General Electric Company to review the requested documents at any time during normal business hours at our Washington offices and the NRC will allow the General Electric Company until close of business on December 12, 1986, to file any documents it might want the NRC to consider in relation to the public release of the subject documents.

The contact person for viewing the documents is Mr. John Craig, Inspection and Enforcement, 492-9043. The contact person for questions regarding any withholding claims is the undersigned.

Sincerely, i

Edward C. Shomaker, Attorney Office of the General Counsel

Enclosure:

As stated C704030548 PDR 870323 GA999 ENVGENE 99900403 PDR

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, WASHINGTON, DC 20615 November 20, 1986 ~

The Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission 1717 B Street, N.W.

Washington, D.C. 20555 -

Dear Chairman sech:

It has come to the attention of the '5iubcommittee that the NRC has information regarding allegations made by San A. Milan, III, of program deficiencies in the Design Control, Quality Assurance /

Quality Jose, Control program at the General Electric f acility in San California.

potentially involve a large number of plants and equipmentThese alleg critical to the safe operation of' these plants. Adding to the seriousness of these allegations is the f act that the alleger is a former engineer at the General Electric f acility who had access to extensive files on the QA/QC program. For all of these reasons, we think it is important that these the Commission and reviewed by the Subcommittee.

allegations be investigated by In order to enable the Subcommittee to understand the potential import of these allegations in general, and their potential impact on the Perry plant in particular, we request the following:

1. Please supply the Subcommittee with all the documents provided to the NRC by Mr. Aga A. Wl==, III relevant to his cliegations concerning the General Electric f acility in San Jose, California and any other General Electric facility.

2.

Please supply the Subcommittee with any documents the ctaff has prepared during the course of the NRC investiga': ion.

Include all summaries of investigations, eithdrltritEen or type-written, any analyses of the documents turned over to the Commission by Mr. Milam, all drafts of the investigation report, and investigation.

the any other documents prepared or obtained in connection with 3.

Provide the Subcommittee with a list of all the~ people the staff has interviewed in connection with the investigation, cnd the date of each interview.

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3 I

j The Bonorable Lando W. Zech, Jr.

'Page 2 November 20, 1986

4. Please provide the Subcommittee with a list of those plants that could potentially be affected by deficiencies in GE equipment. .,

In addition, we have reviewed an October 24, 1986 letter from the staff of the Government Accountability Project to Harold Denton,-Director of Nuclear Reactor Regulation. (See enclosure.)

This letter asks several questions regarding the Commission's adherence to the pending NRC Manual. It disturbs us that this manual has been in Limbo for such a long period of time.

Moreover, it appears the Commission could use the non-binding status of the Manual as an excuse for not adhering to its principles. In order to help clarify the situation, we urge you to respond immediately to the GAP letter and address fully the four questions it asks, and to supply the Subcommittee with a copy of your response.

In order to help the Subcommittee review this material in a timely f ashion, please supply this information to the Subcommittee

.by December 4, 1986.

With best wishes, Sincerely,

\J Edward J. Marke%' DeEnis E.1cliiar'h Chairman V Member of Congress Enclosures i

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l ENCLOSURE 5 TRANSCRIPT AND CORRECTED TRANSCRIPT OF MR. MILAM'S INTERVIEW  ;

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UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:

INVESTIGATIVE INTERVIEW OF SAM A. MILAM III e q 2gviSep M Av C2 , 19 8b CoegecnonS yADE By Sm A.Mt'Aa.E L

I LOCATION: SAN JOSE, CALIFORNIA PAGES: 1- 86 l DAH* WEDNESDAY, APRIL 16, 1986 ACE-FEDERAL REPORTEFS. INC.

offw=IRennen 444 North CapitolStet Washmgton, D.C. 20001 (202)347-3700 NATIONWIDE COVERAG

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1 UNITED STATES 2 NUCLEAR REGULATORY COMMIESION 8

)

4 )

In the Matter of: )

5 )

INVESTIGATIVE INTERVIEW )

6 )

(CLOSED MEETING) )

7 ---------------------------------)

Room 422, 8 Holiday Inn Park Center Plan 9 San Jose, California Wednesday, April 16, 1986 10 '

13 An investi.3-Five interview was conducted 12 this data with SA< a. .4.-.AAK III, commencing at 5:00 p.m.

13 P.c . . . " -

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14 For :ne Nuclear i<a sl u x -) Core. mission:

15 ROBERT L. PETTIS, JR.

RICHARD P. MC INTYRE, and 16 PETER J. PRESCOTT Office of Insp ction and Enforcement 17 Washington D. c. 20555 agger ca-se 18 For the Government Accountability Project:

19 LOUIS CLARK, Esq.

1555 Conneciticut Avenue, N. W.

20 Washington, D. C. 20036 21 28 .

24 25 J Aass e W . Hes esses vemam mpossi 37 STATES STTEET #23 SAN FRANOBCX1 CAUFOfMA 94114 (415] 621-2400

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g Q N,I E_ E I E 2 WITNESS:.

I PAGE SAM A. MILAMX N gIII o Cc W7a1 A

~4 Examination by Representatives of the NRC 4 5 .

FOR IDEN- IN 6 EXHIBITS: TIFICATION EVIDENCE 7

(None) 8 9

10 11 12 13 14 15 16

17 18 19 20 21 22 23 24 25

-, . _ . . _ _ . _ . _ _ _ . _ . , , , r_. . . . _ _ , , _- - _. . . _ . . _ . - , . - _ . - _ . __ .-

~

l 3

l 1 PROCEEDINGS l

2 6:20 p.m.

~

3 MR. PETTIS: On the record.

4 I would like to introduce myself. My name 5 is Bob Pettis, with the Office of Inspection and Enforce-6 ment, Vendor Program Branch, located in Bethesda, 7 Maryland.

8 This is Richard Mc Intyre (indicating) and 9 he is also with the Vendor Program Branch; and Pete 10 Prescott, who is also with the Vendor Program Branch.

11 What I would like to do is, ask Mr. Milam 12 some general questions concerning his work activities 13 during the time of his employment from March 1978 to April 14 1982, which correlates to his work record; and basically 15 focusing on that five-year period rather than his total 16 ten-year employment at GE.

17 The NRC has in its possession documents 18 furnished by the Government Accountability Project. Those 19 records include a report prepared by Mr. Stokes for the 20 Government Accountability Project, which is entitled 21 " General Electric's Record in Nuclear Safety." This

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12 report summarizes your work record over that period of 3 five years: from March 1978 to April 1982.

24 Also in our possession is a package of 25 Engineering Review Memoranda and Engineering Change The t.dle. . t the. reg ..+ , a s a i s s w. , o n y cog , , 3

  • A, I,4qe dast Std .f G6's Nuacer C.,M ad psgemme.M.,

pqartmd Ba.se.A y, k harh . E N. Saw m a.~ asa w ie

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, 4 I Notices that were changed after your signature and while 2 you were working under Mr. Cobler from the period March 3 1980 to October 1980. They are approximately one-half 4 inch thick. ,

5 We also have several thousand.pages of your to 6 work record, which cover your employment from March -er 7 1978 through April 30, 1982. These are grouped in six 8 categories spanning that five-year time span.

' In- addition, we also have a package of 10 Deferred Verification Memoirs, which were written by Mr.

II Milam; and, your report entitled " Deferred Verifications,"

12 which is approximately one-quarter inch thick. That was 13 generated, I believe, in July 1983.

14

Whereupon, no c ~ A 15 SAM A. MILA y III 16 was called -

O .. O O,- EN ' - - ~ ' ' - -"

-~ -- andr 17 having been first duly affirmed was examined and testified II as follows:

I' EXAMINATION 20 BY THE REPRESENTATIVES OF THE NRC:

21 BY MR. PETTIS:

22 am just describing those documents to you Q I

- 23 .This has all so that you will understand what we have.

24 been furnished to us by the people at GAP.

25 One of the questions we have is based on 1

5 I that information, based on the work records, and other 2 information I just described.

I Did you then, or do you now, have any safety 4

concerns that you would like to discuss with us? If you 5 could, please be specific.

8 A' My answer to that might well lay some groun-7 dwork for the rest of this discussion. I have tried to I 8 make this clear to everyone I have talked to since this

' situation began.

10 I am not prepared to say that some specific yteh\em Il piece of equipment has some particular safety -fur.;ti;n.

12 What I am claiming is: There was -- and possibly there 33 still is -- a design control system, a design change 14 control system, that is, in some way, deficient. I am J

15 talking about generic inadequacies in a design control 16 system.

17 It is my opinion that -that , at least 18 eat Hself.

potentially, tis a safety problem in it; ;;1f. I am not 19 prepared to point to some specific piece of hardware and 20 say that hardware has a safety defect. I think it is kind l 21 of important that we understand the nature of the thing l 22 that I am trying to address here. We might or we might 23 not have safety problems in a particular piece of 24 hardware.

25 The point is: I don't believe -- and when I l

6 I say "we", I am going back in time now and speaking as if I 2 were at GE. I don't believe that we can prove how we 3 se%:_ned d: g something-- I don't think we can prove what we 'did 4 not do by way of verification or design change, or did 5 because I think a lot of information was ' lost, design 6 verifications that not get may not have happenedK did I recorded; or the record, if it was made, was lost. I just 8 that we have a good design history or good don't think

, cfc.ord af Msh de:ign record.

~

-I don't think that we can prove that o r-10 something is safe or is not safe, -and was done a certain l

II way.

Il That I think is the problem. It is a a n d h e.

33 e neric malfunction is the design change control system,.+-

1 I4 design verification system. I think that is a very 15 different kind of allegation than pointing to a pump and 16

-tk e saying that est pump won't start when it should.

II BY MR. MC INTYRE:

II physically Q When you say " lost," do you mean I'

lost or lost in the tracking system?

20 A I mean both. There were tracking systems 21 when someone that were not used, or that did not work j attempted to use them; and there was information that 23 a never actually was put into retrievable storage

! 24 location. Information that maybe was embodied only in a l

memo rather than a design record file, and was stored on I

L

7 y tho 4mr corner' of someone's desk, rather than in a 2

. documentation system.

5 So,Imean'thatinbothsenses)(itwaslost.

I personally tried to track down a record of verification and ended up in exactly that situation. The s .

dera ena.

information just became a -deedend. It was fairly common.

BY MR. PETTIS:

~

Q Was there any specific time frame in which-these concerns may be more predominant? In'other words, 10 would they be earlier on in your work record, or later on j II '

in your work record?

12 awareness the- problem grew. The A My of II reason I was not aware of it during my first five years --

I I*

which you have rightly chosen not to look at -- is, thag('

my first five years was rather academic. I did a lot of 16 scoping analyses and computer prcgramming, and things that 17 did- not relate to anything that was necessarily being 18 built right then.

19 When I moved into C&I, then I was in an area 20 where we were designing a product that was being built and 21 it was a different type of environment. There was much 22 more immediacy to the design and to the need to verify 28 things because they were being built. In fact, they were -

24 being shipped even as we designed them.

25 But when I arrived at C&I, I was not aware I

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. 8 j I 'even that most of the rules existed.. I was-aware, really, 2 only of design record files. I did not know much about i.

I-LECNs. I did.not know what an ERM WAS, I did not know that.

"Nw.cl ea r i 4

the nuclear safety related drawings had to say  :::1:::

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f ty on them. No one told me that. I learned I those. things gradually-sb it it P just simply all 'of' encountering the requirement in one way or another.

8 Of ccurse, the more I learned the more I

' realizeo there were things that I did not know. It took a-10 period of time to learn that.' That process continued II throughout my last five years. Eventually, the things 12 that I-became aware of were, to me, sufficiently important' 33 that I guess that is why things just did not continue to 14 between me and GE. But it was a continuous

.) work out 15 process of ' learning, becoming aware of things that I

.16 perceived as wrong.

of hat gg as II So there isn't any one periodtwhere I r::10- .

more concerned than any other period. Just 4m-continuously, through that last five years, I became 0 increasingly concerned with the nature of things.

21 I would like to point out that, the first Q

22 five years of your work record, we did not choose to pass 23 over. The first five years of your work record, we don't i 24 have.

25 Very probably, then, I chose not to give it A

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, . 9 I to GAP because, at the time, I probably decided it wasn't

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2 really of any significance to this issue.

3 Thinking back on it, that first five years 4 probably only occupies one or two binders. At that time, 5 I was mostly recording information that would say what-6 project I had worked on. I don't believe I was recording 7 any relevant details of the work itself. And, at the 8 time, probably,KKthiMing hsch : it , the reason I kept 9 that record was just so I would be able to tell on my 10 weekly reports what projects I had worked on. There 11 wasn't anything particularly controversial or significant.

12 That changed a lot in C&I. I believe you 13 can see that if you know to look for it. As you go

) 14 through that first volume, where I worked with Chuck Hart, Yes can $ct 15  : ;:nt h;;h :nd ;;;d thr;ugt it ;;;;atly, ir pre; riag 'er 16 thi: .: ting, 2nd, mhr- : ;;;d th;;.,h it thi, l ;t tin;,

17 _; : re ef 2, T

upp;;; j;u ;;;;d .-1, an improvement 18 in my perception of what was important to record. Between 19 the beginning of that first volume, and the end of it, I 20 think that the relevance of what I recorded improved .

21 tt;;;;h tyrt <irst ;;;;;; _

22 ([5After the first volume, the nature of what I usss of 23 recorded -assa't-based _;; rrch on a changing awareness 24 what was importantX, L t j;;t en th; h...gia; ;;;;:ncre :f 25 st;; ;;; 33;;; 33;;;;g;;t th; ;;;;;;;,,9 ;;;;;;;,

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Q Iwouldliketogoover,onemoretime,what\ '

2 it is we do have just'so it-is clear in your mind.

I We have six separate folders of your work.

4

. history, which began March 1978 and end at April 1982.

5 A Let me say that 4het would be' Chuck Hart, 6 Lee Cobler, Bob Reghitto. I divided it up by the manager l -

7 at the time. I believe after Bob Reghitto was Arnie 8 Koslow, that is four. Tom Wortham was the last one. I

' don't believe I left out anybody. Probably the other one 10 would be the Reactor Mode Switch Volume. I am trying to II remember what is there.

II Th'ese are six specific time frames--

Q 13 A George Stramback, that is the one I left 34

f. out.

15 Q So, George Stramback--

16

. 4Rs A George Stramback fi4= between B'ob Reghitto 37 and Arnie Koslow. That would be the six periods of time II and six different managers during that span of five years.

U Q And you are saying that the last--

20 A The last one covered a period of 30 days, 21 Tom Wortham. Of all of those managers, he possibly was 22 8*

the best. But I only knew him for 30 daysf9 4e.it is 23 really hard to say for sure.  !

24 Q Based on the work record that we have, and the documents that I mentioned earlier, which comprise the

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regovt on deferred verification memoirs and the- cp;;t; cf deferred 2

verifications based on that, do you have any other I

documents in addition to those already furnished to GAP,

  • or contained in your work record, that may affect the safe 5 of a. nuclear power facility either domestic of operation foreign?

7 have one volume that you did not mention A I 8

that deals with the reactor mode switch, and it is an extraction,from those six volumes,of pages from the record 10 that dealt specifically with that issue.

II We have that. I failed to mention that; Q

12 but, yes, we have that. We have the reactor mode switch.

II A I can't recall right now any other volumes Y'" Y** and-

' 14 that 4Hunkdid not mention. 4 hey mentioned the ERMs 15 deferred ECNs that were changed; 4 Uke mentioned the

' verifications, reactor mode switch.

Q And a report by Mr. Stokes.

18 I believe that is everything.

A O Could you briefly describe your present 20 .

position?

' A I am an auditor. That is brief.

22 Do you want me to be not quite so brief?

23 You can be a little more MR. MC INTYRE:

24 specific.

25 audit manufacturing areas THE WITNESS: I

~' 12

) 2 I and  ;;g:r'ia; manwfachur'n q Suffork' avta1 crer: ef the.  ;;;;f;;t ;ing in the semiconductor industry. I verify compliance with military I

specifications, with our corporate policy documents, and 4

with the areas own controlling documents.

5 That is, in a nutshell, my charter at the I present'.

I BY MR. PETTISr I

Q Have you reviewed the report prepared by Mr.

Stokes for the Government Accountability Project?

10 A I reviewed it.

II O It summarizes your work record during that 12 five-year period.

33 A I reviewed a draft of the report. I did i I4 receive another copy'that I expected was going to be- a 15 final version. But, I believey it turned out that- I 16 somehow ended up with another copy of the draft.

I7 MR. MC INTYRE: There is no date on the copy 38 that we have.

I' THE WITNESS: Look at the title. Does it 20 say Control and Implementation Department?

21 BY MR. PETTIS:

22 Q Is this the report that you reviewed?

23 (The document was proffered to the witness.)

1 24 A Yes. This isn't final because this isn't the correct name. -I ::ll;d thc_ "C?" en thi; i -; . It I

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_should ..t_s111..5-Instrumentation Department. I found in 2 this version that there was some typos, misspelled words

- 3' and things. I reported back the ones that I found to 4 Billy. And I have seen no other version since then.

5 BY MR.'MC INTRYRE:

8 But basically, the format of the report is Q

7 the same?

8 A Let me thumb through it.

' (After a pause.)

10 It looks very much like the report that I II saw. I mean, not reading every word; but, in general, it-A 12 does look very much like the same report based y on +he 60-33 second glance at it.

) 14 If it were drastically different, I am sure Q

15 you would recognize that.

II A Yes.

I BY MR. PETTIS:

II Q Could you describe your job capacity or job I'

description while employed at General Electric, San Jose 20 also, during your work during the time period before and, 21 record? d u m, 3

A Well, as I mentioned earlier,ithe time 23 before the work record, the first five years, I <

period I worked in a part of the organization that was doing some 25 advanced fuel designs. They were not designing fuel that i

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14 4 r I was presently being built; they were examining such things 2 as the benefits of using a nine by nine fuel array instead I

of an eight by eight fuel array. Whether the fuel channel m*s is - f'8 815 4 or 100 eM4e thick; should be 120 eH4e- thick, that sort 5 We did of thing. 'And, as I said, it was pretty academic.

a lot of computer analysis. We took a lot of numbers aut 7

of one program and put them into another and we kept 8

' design recor'd files. But that was really the only kind of 9

documentation that we had to worry about. We were not 10 in the sense of assembly drawings or changing drawings yy- so we didn't iAst ECN's.

connection diagrams, n 20".;, er rrySix;. We weren't 12 issuing any drawings so we did not use ERMs.

is I SPS"*

Th;t ir err ;tisl'; the entire first five

' I4 years ! :;:-M doing that kind of work.

15 When I went to C&I, my first assignment was 16 c: lf ;;11 in an organization that was doingy  ! ;;rrr m 17 4t the mechanical design of the control panels. We were is N '

not designing the circuits.  ;;e h;d ;rrpl; c:.11ri systems l_ engineers h:re ch: did that. But we took their elementary

l. So diagrams and, with the help of our dr&C ing department, 21 produced panel designs tLat inclad w e sembly drawings 22 that showed the layout of instruments and switches on the panels hopefully arranged ;;;:9' r such as to natisfy + -

24 J h f*"EIALS9*5 MSchic W divisional separation requirementsy,fconnection diagrams, j wire lists, that sort of thing. We did both design and I '4

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)~ design veri'fication of those designs.

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MysecondassignmentKK.hich,iuvident:11j,

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.r'rn;. .hil'e ! ..; ;;;hing ft: th, _;;.; --- ;;; rheut 4 ;p 3;,g _ ...j p, gy, gy,.._3 3 _g 3;7,3;_, ,.

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.chcr;:d ;nf I ::nt t;, ch:t th i :21106, the production

, In that i following. 19nHe job I was assigned to be responsive to l 7

problems that arose during the manufacture of the panels.

8 I think that was where I really hit the steep part of my learning curve.on things that concerned me. I was helping 10 panels.

people who were' trying to build the 4e4emme% I was trying II to document changes that I had to make during the assembly 12 process.

II ' I was encountering problems that, in many 14 cases, ,

had not been solved when unit one was built. And 15 it appeared that I had to solve them over again on unit 16 t w o ,' and 8***- D * '-

I was puzzled for eemeetme- over why that 17-happened.

18 But, at any rate, I was providing all kind 19 of engineering support during the assembly of the panels.

bff # ##' 9 20 That included Tthe welding of the structures together, 21 installing the instruments, installing the wiring; d;ing-22 all of the QA inspecting, 4-..uw th; t m. hen th; 0?.

23 in:;;; ting : r h;pprri g, clear up to shipping and -th;;;;h-24 the final touch-up operation on the paint. I was 25 providing engineering support for that entire range of

- 1 e; I

operations. And, in fact, I was involved in occasionally 2

changing purchased part drawings, which dealt with things 3 the. ganels that were relevant before we even welded -4t- together, 4

buying some of the pieces that it took. p 5

(So I provided engineering support for- the 4 New paragraph whole range of assembling the panels. The next assignment was -in the technical licensing unit. I went through my I

remaining four supervisors in that assignment.

Originally, that unit was supposed to 10 provide technical lic:.:ing support to the licensing II organization; primarily, the review of FSARs against the yg cttStomer S W tlanS design documents, and responses to sustemees and NRC II questions. It turned out that we also had some occasional I*

temporary design and design verification responsibilities 15 that I thought we should not have had.

A P*d But that was- p rt of the job.

" That set of responsibilities occupied _ my 18 last, I guess, three years. I am not sure exactly how many years that represents. And that was the last 20 assignment.

21 Q When you mentioned the word " panels," are 22 these panels that would be eventually shipped to a nuclear 23 facility?

24 A Yes.

25 o would they be control room panels?

i

17 A Yes, control room panels and some local

'} 1

c; 2 panels, or remote panels; + Lote... yL.;;; j; But 3 they were f c.nb1 room L primarily centr:11in; panels and they would 4 house control systems or safety systems. I worked on both 5 kinds. Some PGCC and some non-PGCC panels--

6 Q- Could you describe the PGCC concept?

7 A It stands for Power Generation Control 8 Complex. It was a different way of hooking the panels 9 0;fer: 7000, ;hich is why r ;11 it e ner together.

10 fGCC, .. did net mok. . Jietiuw ien, th;.. . We did not 11 have a name for the distinction before we made the 12 distinction. Aher we M 3 2n ma % M " PM:

u e.m j v Si n e n - PGCC -  %

in:t, befe. n:n-PGCC panels were set up in 13 14 the control room separately, the wires were installed 1

15 point to point, wire by wire, by hand. The PGCC concept 16 was that the wires were not run from point to point on 17 strips. They were run to connectors. So we terminal wires. We l

18 would have wire bundles instead of individual l

19 would fabricate the wire harnesses, or the wire bundles, l

20 in the same facility where we made the panels. We would 21 ship the panels and the wire bundles and just simply plug them 12 4H> in . It reduced the amount of work that had to be done 23 at the utility. ine* ' ling th: thing. It also enabled us, 24 in theory, to stage the whole control room and test it all 25 at once gewwkme by not having to actually wire everything

. 18 m

I up. We could just simply plug it all in over in a 2

building, which we' called PGCC.

I But that .was the main difference. The 4

panels themselves were not all that different except, 5

instead of terminal' strips, there were connectors. And we 6

had wire harnesses that went with the panels.

7 Q You referred earlier to unit one and unit 8

two. Can you expand on that?

A I suppose, in theory, unit one and unit two, 10 on a particular project, were supposed to be identical. ,

II The reason I referred to it, the reason it is relevant to 12 me now in this discussion, is that, so often they were not II identical, and, soK often I would encounter some problem 14 3L during assembly that would requireather change in the 15 drawing in order to make the panel. buildable.

16 b* "I #3 Interference problems or marker ;12t: h;l;; what were a

" different distance apart than the holes in the panel where 18 the marker plate mounted. I puzzled over how they built unit one for a long time.

20 It turns out, there are all kinds of wayq( 21 12

% that they can get unit one shipped -eek without changing the drawings. But, what I would have to do is to 23 call the field,  ;;11 1h site, then have somabody tell me -

24 # ** W \

what unit one 4eehe like so that I could change the 25 drawing and make unit two look the same way.

"W*Wf' eY w eew& W-- 4-e ,w --e-rre w . Tr e -y . gym --w<-4 .gyw--y m,- g, y-p----r-y 9-y--y-w- -wyyyiyye--,g-.-p-.g---..n,r- w ww wyvir ge--- --7mvM'-

l

- 19

) I It was a little bit embarrassing, as an .

I 2 engineer, to have to do that. But the fact is, unit one 3 and unit two did not always look alike. It was a 4 situation where I knew something had to have been changed 5 because they could not have built it the- way it was carn S4 rat Maybe there would be a crit :t...% channel and 6 designed.

7 a stiffener that interfered with each other. And when 6anstrat 8 they got ready to put the :.it :trurh channel on the

' panel, they couldn't because the stiffener was in the way.

haA done d'idn 't 10 So what they ::: f:ing in -e-unit one, I-f 't know. The 31 drawing did not indicate any kind of a change.

12 BY MR. MC INTYRE:

13 Q They did not make any changes back in the 14 home office on the drawings?

15 A No. Well, of course, that particular 16 assembly problem would have been resolved while they were 17 building the panel. So, when it got to the field, nobody 18 was the wiser.

39 But, when we got ready to build unit two, 20 e.ncou niered that and we <meeenteam the same problemp h was when I became 21 puzzled about what we did on unit one.

12 I remember one example of the utility outlet 23 that was supposed to be on the back of an enclosure. I ,

24 think it was a local panel. I don't remember the number.

25 cut *wt And there was no-cut cut for it. The assembly drawing

20 I showed the utility outlet; th: . :t d::;in; did n:t M 2 ,3,,; 3;; ;g;j ;;;; ;t.'- The enclosure drawing did not show I

c.w%O a -cut : t. Now, different things happen on different 4

a ding $ cubuh drawings. But the enclosure d ;;ing show the cut : te; 5 the assembly drawings showed where to put the hardware.

6 CE* d E* I " $+3 II You had to have a ::t cut t; put the hardware.

7

  1. ' E " I And, -I ::id, "';;;11 7 I 4en't know. Maybe

'M' 8

they-Md not even in-trH the utility outlet)(.

' So', I called the site. The guy went out and to looked and said, "Yes; there is a utility outlet there."

II I said, "Can you measure where it is for 12 me?"

IS And he measured and I said, "I am going to 14 CE*

  • on that enclosure put the cut cut :n that location
5 M *.t d.itbe.'in h drawing 2nd put it en the same place on unit two."

16 is just an example of how I know they That I7 had to have done something to the enclosure when they made ,

is it, but they did not change the drawing.

BY MR. PETTIS:

20 Was this within your area of responsibility Q

21 while working at GE, to make these changes?

22 was my job to resolve engineering A Yes; it 23 The fact that some of the problems during assembly.

24 change problems should have been resolved earlier did not 25 the fact that it was still my job to resolve them.

_ - - _-.-_--,-m_ - _ . . . . , . . _ _ , _ . - , . , , _ . . - ,.----,

21 I

l I o Could you describe the training afforded you 1

2 during the period covered by your work record?

I A Well, a lot of it involved learning things I 4 by doing them wrong - and finding out about it somehow.

5 There was, I guess, an unspoken resistange among the 8 engineers to going to classes. Most of the classes were 7 sort of tedious. Most of the managers did not really 8 encourage engineers to go to classes because it took _them

' away from their jobs for a certain period of time. And 10 there wasn't a whole lot of incentive to take any classes.

II And, initially, I did not take any. Initially, I avoided 12 them like everybody else. But, e ve ntu ally, I came to 33 realize that there were a lot of things that I did not 14 know.

15 BY MR. MC INTYRE:

16 So, when you went over to C&I, you said Q

17 there were a lot of systems and drawings that were new to 38 you: ECNs and ERMs. You did not have any formal training I' when you first moved over?

20 A No; there was none at all. In fact, at one 21 point, I told George Senn, who was the manager of the 22 whole manufacturing organization, y ju;t-h.pper.;d tc :::t-25 p. 4 ,_g;__3 ;;;;j gggg ;g y;; 3;;;;; ; g; 3; ;g, 33 24 that

-I get ir.t; : di:: rrien er.d I told hi=- I learned how to 25 And it was the gospel fill out an ECN by doing it wrong.

22 I truth. That' is the way I learned.

2 Now, there were classes available that were I not offered very often, and they were over at the Tenth 4 Street fac* La re;'"y.

_y. But CnI did not offer classes on DeH-or E C N 's ERet's 5 1Rfh or design record files, or design verification, any 6 of those things.

7 Q So you had to go after the classes?

8 A E v e n tu ally , I started going after the

' classes, and I started requesting them. But that was 10 probably, % my last year, maybe my last year and a II half.

12 There was one class that I never was able to 13 get into. That was the one one J ~ ;; it i; 10 C.F.R.

fCondihonsh

, 14 21, Potentially Reportable- Crzfitien type tr.in; . I never 15 e ; _ H- ot into that. I guess I did not last long enough.

he.

16 But % training wasn't common.

17 At one point, when I was in the technical 18 licensing suff;ed :_ ;ni.; tion,SN4 we had, I don't know, eight or I8 nine engineers, I guess -- most of whom were not long-term 20 GE people; they had been hired from outside. There was 21 only me and one other fellow who had been with GE long 12 enough to understand very much about how the documentation AnA 23 system was supposed to work. *N9-these guys were writing 24 ECNs and opening design record files not really knowing 2( how to do it.

)

1 23 1

At one time, I complained to Dave Reigel, 2 who. was the q subsection manager. I don't remember

- I n e.

the name of the subsection, but it was ci::tzenic, c; the  !

4 .al;; nte;3 d;;ign elementary diagram people.

bh I told eem 5 the engineers did not know how to follow these GE 6 procedures. He said, "These are all engineers with 7 degrees. We have confidence that they know how to do 8 things.

9 I said, "I am sure they are great engineers, 10 butMdon't know how our documentation system works.

11 Sn\ d And he ::y:, " W ell, there are classes that 12 they can take over at Tenth Street.

13 And I said, "Yes, maybe once every six 14 months, or maybe once a year they will offer a class.

15 But, in the meantime, tT.I[" don't know what to do.

16 -

And he said, "Well, I don't know."

17 You know, he just kind of shrugged it off.

Is Q Would these by job shoppers?

19 A No; these were permanent GE-type engineers.

20 They were the ones who were providing . the technical 21 responses to the licensing unit that the licensing unit 22 was then taking to the customers and to the NRC.

23 BY MR. PETTIS:

24 Q Could you discuss the method used by GE to 25 control deferred verifications?

- 24 1

MR. MC INTYRE: I know it is c o n f u sin g, 2 but--

3 THE WITNESS: That is real hard question to 4 answer. Because, while I was there, I did not see any even k tlly-5 evidence that any method was being used. Iidiscovered 6

that there was a method.: restr-"n I started coming in a 7 little bit early and going into the boss's office and 8 reading the procedures manuals. I discovered a lot of

' things -dsin; that that I had not known before. I 10 discovered something called a design verification status 11 change notice that I had never heard of before, DVSCN.

12 I disgovered thaty whenever you did a design d6trete 13 change with ajverification, you were supposed to fill out 14 one of these forms and send it over to Ken Dawley's people 15 at Tenth Street and they were supposed to be keeping track 16 og th _k t mthing e _

17 I went in and asked the secretary for one is and she did not know what it was; she had never heard of 19 it before. That makes me think that probably no one else 20 had ever asked her for one. I never saw anyone else use 21 one.

22 So I got the EOP manual and showed her the 23 picture and showed her what it is. And she did not know 24 how to get it.

t 25

~25 I BY MR. MC INTYRE:

2 Q You did not have your own copy of the EOPs?

I A No; there was one in the boss's of fice.

4 There was no particular incentive for any of us to use it.

5 There were a lot of procedures manuals other ,than EOP.

6 Q- So you were doing' design verification' and

.7 were involved with them, but had never read the EOP on 8 independent design verification?

9 A Only to the extent that I went and looked at 10 it myself. There would be references to it in letters.

11 People would say we are going to do such and such per EOP

12 often without any reference to which EOP ' number. And it 13 was about two volumes about so thick (indicating ) . That 14 was another of the disagreements I had during this time in 15 the technical licensing unit. I told you that we had

)

16 occasional temporary design responsibilities that I felt 37 we should not have.

38 Mana9emed i -Th:y would write a letter saying, for a c ze -tam - "

sp' tems and p roie45 19 certain period of time, and for - ryettre, :: cre 20 g :1..g t: :nf fer :  ::tcin - 7mj :-t )(y the design

' to 913.

  • 13 responsibility will be transferred -f :: component ^^,"2 KX

' 22 q ger g 777 73;; g t ;;; ;;: t ;;;; ;;; et _ tg; ti;;

e 28 per EOP. Aed I complained to my manager at the time thattncy

! 34 should have at least said which EOP, since there were quite i

25 a number of them.

i l

l

26 I MR. MC INTYRE: That makes sense.

2 THE WITNESS: That was the kind of use that I was typically made of the EOP. It was something to refer 4 to when you wanted the authority to do something.

5 BY MR. PETTIS:

8 So what method did you use to control Q

deferred verifications?

8 W ell, e ve ntually, I started trying to use A

DVSCNs. But there is more to it than that. I first had 10 to learn how to tell if my source document had a deferred II It wasn't visible.

verification.

12 The drawings had a certain little bitty "A

33 letter right on the corner called an ICER CODE. I

  • I"means 'Incomple.k he hkenal reasons ." . "c%e an s *c.ve.4e".

14 g;, , , 7,, g g;;g; ;;; ; g .. ,, ;

. ., a ..

  • f.' rneans "Inc.omplek he este.cnal etasons.* "A" mean s 'a Ige.qt.4, e t;. m .::d: ti.at I de .'t  ::::ttr, n:r, -t.;t th:y x;;;.

16 he b W hiccol and edernal r cas .a s."

But it dealt with the completion stage of the drawing.

I And I eventually--

' BY MR. MC INTYRE:

I' Q The design drawing, you are talking about?

20 A Yes; the elementary diagrams, conne ction I diagrams, assembly drawings, enclosure drawings, marker 22 The all had the ICER CODE right down at plate drawings.

25 the top of the revision block.

h* M

  • 24 I eventually learned that %ee- had nothing 25 The fact that the drawing to do with verification status.

27 I had a "C" on it, did not mean that the design was

]

2 verified. It simply meant that that drawing was complete I and you had to look somewhere else to find out about the 4 And that was an important piece of verification status.

5 knowledge because I wasn't doing any deferred 6 ve rifications before. I had no real reason to do a 7 I would simply go get my changes deferred verification.

8 verified by somebody. But, when I realized that the ICER Cebe.

-Geet- did not tell me anything about the verifications 10 status of the design, I looked further and I discovered II that in EIS they had something called a SUN Code. That VS%esus a Leemplek d.-ed."

12 stood for, S-U-NK.I :' O n ' t I;;; hrr --het they "S" ;t;;d 33 -f e r ; :nd I d;n't rer :b;r ch:t Luc "n" sLved for, but the 14

'tf' mean$ " unver'.f. el o r de(erred design ", "ti" m ea* 5 not en laid ed ii nn

gu; ;g; ;;.;;g;;g;;. You could not tell by looki'ng 15 at the drawing whether it was verified or not. You had to 16 go run, I think it was, a DI program in EIS--

17 Q So this is the other--

y, *o dermahen A This is the computerized engineeringtsystem, I'

which isn't, well, it isn't a retrievable document system 20 in the sense that it is re vision controlled. It is -+-

21 current information. And, when some particular piece of I

data in the EIS is updated, the old data isn't retainedg 13 to It 9e- my knowledge 7. M is just simply updated. So it is a 24 current type data base, and it tells you the drawing 25 application, drawing revision, unincorporated ECNs, that b

to It is a wonderful l I sort of thing. It is very useful.

2 system as long as it isn't misused.

- 3 -Bott, I learned that you could go look in EIS

's 4 %sre. skedo r 4 and was a "U" 4w the drawing, in the design status 5 column of that output, then you knew 'that there was on 6 record some incompletion in the verification. So I began docw% EMS ko ht 7 to consider those ' :::::t, th t they x::: unverifiedy h 8 i , in f:;t, : c;;ified. And, when I used one of those as 8 a source, the change that I made, using that source, I us A S LJ aS 10 ;;;ld ;;t; := an unverified change. My theory t;ing that II couldn't use an unverified source to make a verified change I-eew&4 12 no matter who looked at it and verified it. It matched bee anse

" 13 what I started withy, -Beeeeee what I started withy was i

. 14 unverified.

15 I was hoping to, by then, escalate this 38 deferred verification thing, or snowball it, to the point I 17 where they could not keep ignoring it. And, single 38 handedly, it was kind of hopeless, looking back .on it.

38 I eventually realized that even EIS wasn't a 20 completely reliable record. Because a lot of the deferred And, 21 verifications never made it into that record.

22 was eventually, what I learnedy -ead that I had to do, 23 request every ECN and every ERM that had ever been written A b'"' '"3 "N "

24 against --th:t _rtring, 2 "5 #'% *and look individually at each one; e.a c.h and on eta 25 look at the verification statement on h ECN, :: ;; th:t i

i I

1 l

l

-.ru.._-______

29 cas.h I ERM, and see if h particular change had been properly 2 verified. And I-found, then, deferred verifications for I which there was no record at EIS probably because nobody 4 had filled out a DVSCN and sent it to Ken Dawley, whose-h 5 job it.was 4ep get the record into EIS. So it turned out 6 that there' were very high proportion of drawings that had I deferred verifications that were not only not visible, but 16 kesk 8- were sort of hidden, hard to findy, helt a lot of work to i

' request all of those ECNs and wait for them to come back 10 and, theng look through them.

II After that, I tried to use DVSCNs. That was 12 near to the end of my time at GE. It was one such episode

(

II that, in my opinion, sort of contributed to the end of 1

34 things. I had changes that I was making on a particular 15 set of drawings that included a source that had a deferred 16 verification somewhere in its history. I completed my

' DVSCN. ' d '_ f T. s t ;"t,  !  :

.;hin; 2 chin; i"-

'I  ::" rr Ok;y. I was issuing eppH s*'rn, I g::::, ::

I' new drawings, making a change in application based on 20 another set of drawings for another project. The other 4

21 set of drawings for the other project had a deferred i

' verification. So I wanted to make sure that my new set of l WM I.am-trying to i

SS drawings also was known to be unverified.

24 I

snowball it.

25 You have seen the picture of the little l

l I f 4

30 l

l 1 aouse flipping off of the Owl. That is what it was, I

}  ;

2 _ guess.

3 MR. PETTIS: We will take a recess at this 4 point.

5 Off the record.

6 (Whereupon, a brief recess was taken.)

7 MR. PETTIS: On the record.

8 Where did we leave off?

9 THE WITNESS: I was just telling about my 10 efforts to use DVSCNs.

11 BY MR. PETTIS:

12 Q I just want to ask you -one thing: Is there 13 a specific time that we are talking about right now when 14 you first encountered this deferred verification problem?

15 A That probably began within my last year at 16 GE. It was fairly near to the end that I started 17 realizing the situation with deferred ve rifications.

18 hest.

was while I was doing some of -4Me. temporary design and 19 design verifications assignments.

20 One thing I should mention is: When we, in 21 the technical lic ensing unit,. received a temporary 22 a s sig n m e n t of design r e s p o n sibility , that design 23 r e s p o n sibilit y would often be farmed out to a 24 subcontractor immediately. We would retain the 25 verification responsibility.

i l

l

31 I The whole thing, to me, at the time, seemed 2 kind of " flaky."

was C.F. Braw one .f 1%e subcovdr Ac4or s 7.

3 Q "cr thi: th: ::::t 4 A No; I don't believe it was Y :: th t  :: M 5 C. F. Braun that was involved in that. C. ' F. Braun was 6 involved earlier in some C&V design work, I believe. Q 7 _ ;;;;; 7, 93;; ;;g ;3;; ,;;.; ,

q__

8 L Ciiuuk ::::5* I am not aware of C. F. Braun doing any

' subcontract work for ' the technical licensing unit. But 10 Omtec was one of the companies that dig,-i>ue. I don't s%er II remember the other names of thetcompanies right offhand.

12 But it was during that period of time that I became aware I3 of deferred verifications as I now perceive them. And,

, 14 during the last year, I learned more about them and became 15 -more determined in my efforts, well, not only to use the 16 system as it wa% but to try to improve it. DVSCN's we 17 There.wa.gs some problems with 9VeeN-even if II For one thing, did not have any kind of were used.

I' they an issue cycle; and -46 did not have any kind of a number N"

20 and bl it *; :'t *"4retrievable in any way. When-h Ywent to Ken 21 Dawley, it was his job to log them into EIS and, then, 22 And, whether or not you could ever have file them.

23 retrieved a particular one, I think is very questionable. -

BY MR. MC INTYRE:

25 Q You would log it into EIS but it did not

=,y,m_,.%g,y,,..,,.,.._,,,me. . _ _ _ , . , . , _ , . . . _ , , , , , , , _ , , . _ , , , , , , , , _ ,_ _ _ _ , _ _ _ _

. l 32 I

have a number on it?

2 I think -he gave it some kind of number just A

in his own filing system. But I never tried to retrieve a DVSCN, so I don't . know if it is possible. But they did

' not have any kind of an issue cycle like any'other kind of 4 Ead DVScN a design document. -Et required a section level signatureg, 7 m Ot 5 AseM manager they would usually rubber stamp it if ree had initialed it.

9 That leads me to the next part of my story.

WM 10 As I eak going through this effort to change gg . Was things, I guess it de inevitable that a few people would 12 get mad at me. And it happened that, once while Reigel II was out of town, Bob Reghitto was a cting for him.

34 mad m e.

Reghitto was one of the people who was made at eew because 15 of another problem that had been going on.

16 Subsec.h e n W hile he was the a cting -:::ti;; level 17 manager, I happened to finish this particular project that 18 I was going to tell you about a moment ago that included a 19 I did not put a deferred verification. I wrote a DVSCN.

i 20 l

l design record file reference on the ERM because the

! 21 Aid then verification was not complete)(9 T . . c. . was no work to 22 Afiv support the verification in tti%r design record file. One i 23 l of the things we histo rically had problems with was

! 24 referring to something in the design record file that l 25 .

turned out not to be there when the auditors went looking l

l l

l l

~ _ . . . . . - - - - - . . - . . , _ _ - , , . , . . - _ . _ - . . _ _ , __,__.____...,.--..--_..____._.._____...__._...__m~,,. . . _ _ . , - . _ _ . _ _

33 I

) for it. So I was careful about that. So there was no 2 design record file reference, but there was a DVSCN. That l 3 was in accordance with N original requirements as 4 specified in GE's procedures.

5 r. handed the package to my . nianager and it -

6 was routed to Reghitto. Because of the DVSCN it had to 7

have Ba rre n tin e 's signature. Reigel normally just 8 initialed them and gave them to Barrantine, and Barrentine

' But Reghitto did not. Reghitto drew a big signed them.

10 Redundants nd 9 )ced diagonal line across the DVSCN and said "t!;t rey ired, ;;;

(See EoP v2-6.00 g>a rapp h 9.g ,2 g 4 II -eor 42-0.00 I den't rc..ea.t:- *e)r -"r- th: SOr ... L. --

12 and sent it on back to me. He also included an II instruction to add a design record file number to the ERM.

14 I, to a certain extent, lost my cool and 15 sent a note back to him and said, "Yes; in fact, a DVSCN 16 is required. In the future, cith: read the procedures 37 more carefully before you mark up my work, ::, .i;; L..vr/

I' so that I do not have to do it over again." And, I guess, I'

that just made him madder than he already was.

20 But I wrote a new DVSCN; I started over. I 21 instructed my manager that I did not want a design record 22 file *;f'"'A  ;;;;g,"" I did not want a reference to an existing 23 one put on the ERM because there wasn't any supporting 24 calculations or information of any sort in any design 25 Supped the. ch6n$a record file that would b .h ;; rhat ac A., Juin g. I gavc i

34

~

I it to my manager again and he sent it to Reghitto again.

2 It did not come back. I started watching, along the way, 3 in the issue cycle and I saw the work go by the drafting 4 department without the DVSCN and with a DRF number on it.

5 So I just took -it and -- I don't remember 'if I did that 6 again or not. I may have done it again. I think I made a 7 new DVSCN, started over with a clean ERM; went back and'

8. got the signatures on it, without the DRF number on it, 9 and put it into the cycle again. A second time, I had to 10 retrieve it in drafting when I saw it go back with a DRF II number added and without a DVSCN on it.

12 At that point, I misfiled it in my file 13 cabinet and, thenK waited. On Wednesday of the week when .

14 the work was due, my boss came around and asked me if the 15 package had ever been issued. And I said, "No."

16 He said, "Well, are you going to issue it?"

I7 Aed I said, "No."

II He said, "Why not?"

I' And I said, "Because of what is happening 20 here."

He 21 1.nf he said, "But it is due Friday."

Tk 11 .hna--I said, "Yes, I know. took me.my- three 23 months to do it. You can start with a new engineer or do 24 And you have two days to decide."

it my way.

they 25 Friday, they came around and said that e i

- - - . -l . - -

35 l

w.M A

-] I

.ws&- do it dm way. And they did it my way. But the 2 first of the next month I got laid off, so I did not ever  !

I get to finish the battle or the DVSCNs. That was the last

" one I ever tried to use.

5 BY MR. MC INTYPE:

4 Q And your way was following the procedures--

7 t A My way was following the requirements for l 8

both DVSCNs and design record ' files. And the design record file was not required for every design change. A 10 design record file was intended to be used for anything Il that was not otherwise retrievable. You could put your 12 entire support right on the he. ECN, if you wanted to.

13 And, in fact, it was bad to use the design record files 14 too much, because they were not conveniently retrievable.

15 sn&stidusil And ECN was retrievable bi it; ;;5j;*;t. You could just 16 '5 -

requestffrom the drawing room by ECN number and get that II ECN.

I' Th. C; rig . r;;;;d fil:, ::--*' ;; th y we. ; -

I' An use4s *ed- entire file cabinet could be one design record 20 file. But a design record file was only retrievable as an

21 entire design record file. You could not retrieve a page 22 of it. So it was not really a very convenient way to 23 store something that you might want to get back again 24 unless you opened a new design record file for every 25 particular thing. And, as I said, this procedure, 207 C-Go f 12.-10.0 0 , DCSIS n ke cord I ' ( e 5 3 3 a's d h3+ tka. deGgs

( co d 'n n.x om ik he>+ fage}

36 I mi..d of ;;;;;ing; ! ea 'iad ;f 3u.. sing. I:-

] -1 e -- I .

2 _n t ;;;e_ y r :;;t;; thc;; ;; t;;; _

3 -

Lot the pre ed .: : id that the d:-tr -

4 record file did not necessarily have to be used. I wasn't 5 required to use a design record file by the procedure. I 6 was required to use a DVSCN by the procedure and that is 7 what I tried to do, and it wasn't very successful.

8 BY MR. PETTIS:

' Q Are you aware of any components or activity, 10 manufacturing activity, within General Electric which may II involve a high number of deferred verifications; is there 12 one area that maybe more prone to having more deferred 13 verifications?

, 14 A Systems Engineering _ Design organization, -

% A 6 n c 6 ve. 6 f'.c 3 h . 4 15 under Dave Reigelb W might be kind of hard to find;

/

16 they are not very visible. But I think there are a lot of 17 I think raost of the elementary diagrams will, them there.

II somewhere in their background, have at least one deferred I'

verification that was never finished.

20 0 When you say " Deferred verification that was 21 not finished--

12 I mean an ECN.

A 23 You don't have any, you can't recall any Q

24 closeout mechanism for that duferred verification; or is 25 it just your understanding that it hasn't been closed?

i

37

) I A Wen, I can give you an example of one that 2

I tried to track down once. And I can't remember the I

drawing number, or the system number; I just remember that 4 ~

I tried to track down this particular verification and see

~

5 if it had ever been done.

" This particular change had been made by --

maybe his name will come to me in a minute. It was one of 8

the people who was involved in doing some support for production. He worked for Bob Parker. Larry Chamberlain, 10 his name was Larry Chamberlain. He had made this change.

II He had not shown it to the system engineer who was 12 responsible for the system. At least there was no II evidence that he had shown it to this system engineer.

I*

There was no system engineer signature on it. W ell, U

normany a system engineer .;; 1f n;t H e y would have verified the change. I am not sure that h is proper

' eith e r, but that is the way it was done. The system engineer would have verified the change the production support engineer that4 had been made to the system. But 20  %

4 was a deferred verification. There was no signature i 21 there.

22 The lead system en ineer over at Tenth 28 O '

Street had not signed " N-it eitheg.4+heee he would normany 24 have signed it 4: " ?. " . Larry Chamberlain had signed it.

25 So, reany, he and his boss were the only i.

a - , . - - - - , - - - - - - - - - - - - ,, -,e- .-,e -r v

.$ s ona.s y

.ene. who had ever seen this change. It was quite a long 2 ECN and it made some technical changes to the panel. And the.

I I wondered if e- def erred verification had ever been 4 cleared up.

5 So I went to him and asked him, and he said, 6 "Oh, yes; we had a design review meeting that verified the 7 whole. system."

8 I said, "Was there any kind of a record made

' of that meeting?"

10 He said, "Yes; we issued a memo."

II *nd I said, "Do you know where it is, how I 12 can get hold of it?"

He L Cet1 13 A..d 1.e was able to find -ene on his desk 14  ::::wh::: in th; t;;h ;f stuff and showed it to me. -And It quemem.

15 44 was a short memo with an attachment.+het said that we, 16 the design review team, M have reviewed this systemyX 37 3na w b n t.W c. Att.v.he.4 0;; ef th:::- action

d it list;d ;;;s
;tien it
::.

WIU E 18 items are closed end the system 4e considered verified.Y I' I said, "Were the action items closed?"

20 He said, "I don't know. They were all 21 assigned to different people." And the list was on the back.

23 I looked, and there were about 52 action 24 items, I believe. *nd I checked the first one and it had 25 been done; the thing that needed to be done had been done.

39 1

I checked the second one, and it had not been done. *ed. I 2 AM * * ""

did not check enymeee after that. It was just a deedeady, 3 bd eue it had sufficed to convince whoever was in authority that needed to be convinced that the thing had been 5

ve rifie d. They had a design review meeting and they issued a memo. And, if the a ction items never got followed up, well, that was the fault of the people who 8

did not follow them u p. It wasn't the design re view committee's fault.

10 That kind of illustrates how difficult it II can be to track down whether or not a deferred 12 verification was ever closed, especially when there isn't II any good record of the deferred verifications. If you can I4 find them, and find out what particular changes had a -

15 deferred ve rifica tion, it is difficult, maybe impossible, I

to go back and find if they were ever closed. Because there isn't any kind of traceability anywhere with respect is to deferred verifications. There is no traceability to k DVSCN if one was used.

The ECN is really the only specific record of a pa rticula r deferred verification. And, if the 22 ve rifica tion was ever completed, there won't be any traceability from that ECN to that completion, wherever it 24 might be. Because, if the completion is done, the ECN is 25 isn't modified. At one point, I made a suggestion that

40 I the DVSCNs should be issued with the same number as en. ne.

2 '

ECN; and, when the verification was closed, that' the DVSCN I

go to.the documentation area and be attached to the 4

original ECN as an extra page. At least, that way, when 5

you requested the ECN, you would get the DVSCN with it; 4

that would have helped. But they did not want to do that 7 So 41

>._y for some reasong -eet there - was a la ck of .yx 7- to 8

retrieve that information, assuming it is there.

I ~

BY MR. MC INTYRE:-

10 Q You could not find that in the EIS that you II had mentioned earlier, that you could look in that system 12 to find--

II A EIS would give you the current revision of I4 the document and 'it. would' notify you of the existence of 15 any unincorporated ECNs, but that is all.

' 'Q It would not include a DVSCN?

' A No, no; I never saw a DVSCN listed in the l

18 l EIS. They did not even list ERMs -- and that was another 19 problem.

20 An ERM could be used to make a change in 21 application, which meant that you might have a parts list 22 calling out a particular drawing for a particular project, 25 when, in fact, there had been an ERM issued that changed 24 prei u.t afgri u b .% f., t b t a w N v the Njo that thee drawing did not apply and 25 another one did. And the ERM might not be incorporated

. .~ .

41 9arkt l'd 9 ad s % st

, -) I into the A t; yet. So ~you- might have a d::riz; that 2 listed a number that was an incorrect number and you would I not know that the ERM existed because the ERMs were 'not m EIS 4 listep An unincorporated .ERM was 'not listed in the EIS.

5 . And I tracked down the reason for that. .

was ud a' N co g 5 ISM 6 The _ reason h the Bett numbersg eeneseh6ef 7

of two letters and five numbersy,and ERM numbers consisted

, %e.

8 of three letters and four numbers. 6 format in the O EIS was set up to take two letters and five numbers, not 5 Arid 10 three letters and four numbersy, *nd they did not have the Il resources to have a programmer go change that to some sort alp h t u m e.ric.

12 of e& gee 6thm6e format. So they just did not include ERMs 13 in EIS. That is a typical reason.

14 -Q And you never saw any documents listed in EIS 15 the T: cyst .-. that would be consistent, verified?

16 A W ell, ,I am sure there were documents that 4

17 were probably verified. I don't mean to imply that all of 18 them were unve rified. But I think a lot of them, maybe '

18 most of them, were unverified, :yi , depending on how 20 hard you look for the deferred verification. There might 21 also have been cases were you might question whether a i:

! 22 verification was in fact a verification or not, depending Fe e e.r a m 9 k.

23 on the statement. Th:::  ::: thi..v. Zh- an ECN might say 24 something like : verified by review to appropriate 25 'And you wonder: Is that really a strong documents. '

l i

L

,,,,.,.._..._m- - - , .

42 enough verification statement to convince somebody that it i j was really verified. It might. be questionable.

~

BY MR.-PETTIS:

4 Q Do you have any knowledge of any component, i.

5 specifically that was shipped to a domestic or foreign ,

6 nuclear power plant, which contains a known defect.

7 ,

A Are you also interested in foreign plants? '

s BY MR. MC INTYRE:

9 Q If it would be a generic concern.

10 A It is hard to say. I remember one panel, but I am not going to be able to tell you the project or l 12 the panel number. It might be possible to dig it out of 18 my work record. But I may not have it recorded it. I don't- know.

15 I do remember one panel where there was a 16 h ut. A hof CR2940 switches,thorizontal row of them, that was ,

17 above a horizontal stiffener and they were too close to 4

1s IS the stiffener. ..d, if they rotated slightly in the hole, 19 the screws could touch the stiffener. I wanted to cut the 20 stiffener out and weld it in a little lower. But I was 21 being transferred 'to the technical licensing unit at about 22 so that timeg, ee. I did not have the opportunity to follow 23 through with that and one of the other engineers took it 24 over. '

25 I heard a rumor thaty what they did was,

/

r aw -v ,e --e w a ,r-- , - , - , e-ne ,-wn,,w---------- -- - - - - , , - - - - ~ . . , - - . -we - - - --,e - . - - - - - - ,

3  ;

43  ;

) I' just tape a layer of mylar to the top of the stiffener and 2 shipped . it. So that.might an example of what you are I talking about. But I don't remember the panel number. I 4

did ask if they thought to include the mylar on the parts 5

e

,g ,

list for the benefit of the next unity M they said no.

6 I mean, that at least would have been the minimum amount I

of documentation; at least change the drawing to show that' 8

of you have to tape a strip f mylar to the top of the stiffener.

10 Q So, as far as you know, they shipped that II

panel?

12 A As far as I know, they shipped it with the 33 strip of mylar taped t'o the top of the stiffener. .-

! 14 Q And that would be the fix?

15

, A That would be the fix to keep the screws 16 from shorting out. 'I never saw it; I was transferred out 17 of the job. But that was what I heard from someone who t II worked down there.

I' BY MR. PETTIS:

20 Q Could you explain the term "bootle g " and 21

" mortgage"?

22 A Yes. Those are interesting terms. We kind 23 -

of made those up. .

" Bootleg" means t P. L, done without ,

authorization'ahd without any record. An example would be .i i

l

-..,.+--..--.----,.--v.---..s -

44 l

1 A -l _ marker plate holes in the "f ab shop." Well, marker plate 2 holes in the assembly shop.

3 When it came time to install a marker plate, 4 the holes in the panel were not the right distance apart.

5 What you ' do is: - you go off somewhere, and .you borrow an 6 electric drill, and you look both ways and make sure 7 nobody is watching; you drill a hole, you.put the drill 8 Lack, and then you install the marker plate. And it is a

' bootleg fix. That is what I call a bootleg fix.

10 Q Even though there were procedures that Il probably prohibited that type of activity?

12 A Well, I considered that to be a de facto 13 design change.-ay:;1f. The panel doesn't match the 14 drawing.

15 Q Were these manufacturing personnel at GE on 16 the manufacturing floor taking it upon themselves?

17 A Yes; that sort of thing would happen.

II BY MR. MC INTYRE:

19 Q And they would not document these changes?

20 A No, no.

21 Did this happen quite often?

Q 22 A W ell, it happened often enough that I 23 worried about it. That was just an example. It is easy 24 to remember.

25 I remember another example that involved a e

v w- g- - p-+-. ,,, , , , - -

,.,wy- -------,p-,g g g --y- p,n.,e ,n , --em - - - , - - - ----g ,-,,y y

45 GaritNi Sub n'sah

\ I guy named Bernie C;; net'1, and a woman named -Bebia4es -I.-

2 pe__a ; et gg;  ;;;, tu a b it ;;s "abick. She was I a QA Inspector and she was worried that some surface -- I 4 don't remember what the surface was; but she was worried 5 that it was mounted too close to the top ,of the power 8 supply 'and was going to interfere with the air flow, the 7 cooling. It was + convection cooling - tib thing- through 8 this power supply.

' She asked Bernie about it. Bernie said that an'i s t rwi.

10 it was mounted on the anit ;truch- channel and to just II slide it up a couple of inches and do it that way; and, he.sa' A ,

12 then, when you inspect it,qit won't match the print.

13 Write up an inspection report and we will say: accept as 14 is.

15 And I said, "Not on my panel, you don't.

16 Let us change the design." But that was kind of the way 17 they worked.

I' The thing may not be a real important design I' The fact is: it is a change; but, then again, it may be.

20 departure from the documented design. And the intent from 21 the very beginning was that the drawing was not going to 22 be brought up to date.

23 It was when I saw things like that happening 24 that I started to realize how it was that I was fixing 25 problems on unit two that had to have been accommodated l

1

46 N I somehow' bn unit one; but the drawing was not changed.

1 It 2 was ." bootleg" fixes.

~...

5 BY MR. PETTIS:

4 Q Did you feel obligated to raise this with 5

your management, that this activity was going on?

4 A Yes. Mr. Cobler reany did not want to hear 7

things like that. He would usuaHy sit there and sort of I

keep reading something while I explained it to him. He would then say: Wen, thank you, Sam; you are doing a 10 good job. And that was the end of it.

II Q Would you explain the term " mortgage"?

12 A That came from what we caHed MRB. It dealt 33 mostly with mith:r, 2:11, purchased things. MRB d e alt I4 almost exclusively with purchase things, either equipment 15 that we bought, parts, meters, switches, power supplies, 16 S O '* M 'k*

or enclosures that were made at fer.T.;f rut." fab shops.

I7 The biggest problem was the enclosures.

18 They would come back with variations from the design. A I'

good example is a case that I recan where there was a 20 built in interference between a channel and a stiffener.

They had to go past each other and the designer just did 22 not notice that, actuany, they had to go through each other with the dimensions that he had provided. And we 24 had three enclosures built to the same design, and I think 25 ~

they had been built by two different subcontractors.

47 i I In one case, the subcontractor had chosen to c.h esen 2 cut the stiffener; the other case they ohese to cut the

-  ! So, what we had was two different bootleg channel.

4 Sama solutions to thefproblem. And I was puzzling over what to 5 But, for that sort of thing, because of the do about it.

6 intense pressure to get things through receiving as 7

quickly as possible, there wasn't time to write an ECN.

8 Usuany the engineers would, on the inspection report, say

, . 4W.s does vs.t affe.d something like .th::: i: n:t,  :::;t form, fit or function; 10 accept as is. And they would send it right through and II not change any drawings at an.

12 But, occasionany, they would do something II that they would can mortgaging an ECN. This means they a, p a r4licula r-34 would say this problem wiH be corrected byfECN n urh e r, 15 and they would =Sh t w_tr an ECN number that they got off the I"

log. The ECN was not written yet. The intention was that 17 maybe tomorrow they win get around to ri;6* h /'Y'

' '...Sg the ECN 18 And, if because the number is reserved and mortgaged.

I' they were real conscientious, they might write the ECN and 20 Because, once the panel was c.. -th:

maybe they would not.

21 through the receivingg inspection, then, the pressure was 22 off to do anything about it and the pressure was on to 25 solve the next problem.

24 A So I suspect ee- lot of mortgaged ECNs 25 probably did not get written and there would be no way

48

' that anybody would know about it. Because, the inspection 2

report was never attached to the hardware. It just went 3 m into a file-and the record center and would never be seen 4

again. There was normally no record made of the 5

in s p e c tio n report number on any pie c'e of design 6 A documentation. So the inspe ction report was just ee 7

vehicle for getting discrepant things through receiving 8

end. inspection, and filing the inspection report. It was 9

essentially not a retrievable document because nothing 10 A Nh* h TA-referred to it by numberg f.ith;9;;bf it had a numberK.-it 11 could have been retrievable if they had, somewhere on the 12 refer rel to that nweer drawing, indierted d: rin; :sfMird 5; in:;rrMr; Ice;;t I

cunt;r, or aemomhi;;; jeu kner, ;;ncl recepted .;it h 14 N di:: reps :ics. - But they never referenced :n; thing so it became a nonretrievable document.

16 Also, when it was used to make what I 17 thought of as a de facto design change, where it allowed a l 18 departure from the design to h:;; n, I ::::id;;;d that, in 19

-f f =ct, t; h- 2 d==4 0n changa L.;;;;; th; panel une 1 20 dif f; r - a +- wh== it .:: cd f;r thstr I considered it to 21 be a design change that did not have a proper review cycle  !

22 I like an ECN. We were*#hre'S quired to verify design changes i 23 3 commensurate with theidesign under 10 C.F.R. 50, Appendix 24 B. And I considered these irs to be occasionally used to 25 make design changes without verifications. Because they

.- - . . l

49-N. . I did - not have the same kind of scrutiny that an ECN would 2 have. They did not go through anywhere near the same o r-3 issue cycle, -e. review cycle, that-an ECN would go 4 - through. Yet, they would accommodate a change in the 5 hardware. And I complained about that to no avail.

6' I only lasted a week on MRB and, then, I 7 went back to my other assignment.

8 Q What is "MRB"?

9 A Material Review Board.

10 Q Where was QC all of this time?

are.

II A Well, that- I don't know. I guess there 4e 12 a lot of ways to answer that, and probably I would hsve to 13 give all of the answers before it would really be the li whole answer.

15 Part of the problem, I think, is: the 16 manager of QA reported to the manager of manufacturing. I 17 think that was the problem. Ferguson reported to George II I think he should have reported to somebody on a Senn.

W.Sh er-I' level 4ewee than George Senng ;; !. I don't think QA 20 really had the authority that it needed because of the way 21 the organizat' ion was structured. I think, also, QA may 22 have been worn down , in some respects, to a state of 23 apathy just because they got so little engineering ,

24 support.

25

< There were a lot of little ways in which

50

\ I that was manifested. One kind of amusing example was the 2

fellow named Bill Trader, who was one of the production I

engineers ~with me at the time I worked for Cobler. He and 4

Cobler went back a long way together. He, Cobler and 5 b4"*N 0;;nctti, in fact, went a long way together with GE. They 6

were old buddies.

But Bill Trader had an interesting technique 8

for dealing with the CARS from QA. He had a whole list in his head of quick answers to CARS like: Does not affect 10 form, fit or function; use as is. Or, check for current II revision %,m _ , . . . . . _ _ _ - . . _ _ _ _ _ . . . . . _ . . . . . And when he 12 received a CAR from QA, he would put down one of these II answers, not always, but often; then shoot it back to QA I*

as resolved.

15 A couple of days later, another CAR would 16 .

come back from QA with the same problem on it referencing 17 the previous CAR, and saying that your answer is 18 unacceptable; this problem really does exist.

19 In the m e a n tim e , Bill would have been 20 researching the problem. So, when the second CAR arrived, 21 he had the answer and he would put the answer on it and 22 send it back. And he got credit for very fast response to 23 twice as many CARS as I could handle. But that did not 24 endear him to QA.

k -

1 QA did not get very much support from

]

)

51 I

i N I enginsering. In fact, I discovered, at one point, that l 2 the fab shop wasn't getting any' support at all from 3 engineering. I sort of took it upon myself to provide '

4 some support. But I had to do it under cover because I 5

had not been told by my manager to support .the fab shop.

I So I had to kind of sneak in the support. But I had ,

7.

discovered that there had grown into place a gentlemen's 8

agreement'between the fab shop people and fab shop'QA where, if they encountered a problem in the design, they i 10 would just simply' fix it and then QA would accept it and II sign 'it off. Because they despaired of getting any 12 support from engineering and there was really nothing else l 33 they could do.  !

14 I started giving 'them some support and 15 making some changes in the drawings that they needed for 16 A. wkd le .

.y g g 17 Q All done under the procedures of the GE?

18 3"I

A Well, the ch
7.;;d that I made, I made using 19 N N ECNs. I did it t4teg6 way 4 hey should have been done. At 20 one point, somebody told me that the manager of the fab 21 shop QA people had told his people that, if they had a problem, not to go to Cobler and try to get anything 25 through the system, not to try to get help through system; but just go straight to me because I would help them. But 25 it was all sort of unauthorized. But they needed some

! l

)

l

52 I

engineering support.

2 But that is part of the answer, like, where I

was QA? QA was there, but, for a variety of reasons, QA 4 ~maybe wasn't very effective.

5 Q Well, QA, QC; I was more interested in QC 6 sinc e they may have had the responsibility to follow 7 through some type of a traveler system and know where 8 these panels were at any stage during the manufacturing.

' A They did not know where the panels were. I 10 don't know if you notice that in record. But there was

!! one sequence of time where I explored that issue and I 12 discovered that production control, who were the people were.

13 who7 supposed to know where the panels were, did not know 14 where the panels were. I would ask them where the panel 15 was and I would go look there and it was not there. I 16 would search for it and maybe, eventually, find it; and I7 maybe not.

II There were cases where they told me that a

" panel had not been started yet. And I would find it in 20' the paint shop finished. There were cases where they told l

21 me that unit one had been shipped and unit two had not 22 been started. And I found both of the panels both labeled 08 25 MI don't know what to sayy3 -Bet- it is unit one.

24 And, for those panels, I documented in the work record.

25 have panel numbers written down.

c,

' I Q That are in your work records?

2 A They are in the work record, yes.

I Q Were you aware, during this time frame, that 4

there was such a provision called 10 C.F.R. Part 21 where 5

you could report defects or noncompliance ' direct to the O

NRC?

A Even now, I am not aware that, as a GE g could employee, Im report directly to the NRC. GE procedures.

9 prov'ided pr: tid:- that I rsport it through the GE chain of command.

10 I think it would have been very dangerous for me to try to II report something directly to the NRC.

12 Q So you used the mechanism within GE to II report?

I4 A Only one time did I do a PRC. That was on 15 the reactor mode switch. And it took three months before I"

they could deliver it to the licensing organization.

Q Were you satisfied with the response for the 18 PRC?

A No; I wasn't satisfied with anything about 0

it. I felt AMee that the way they handled that PRC was in itself a PRC. But I did not report that one. I was in 22 enough trouble already. But I thought they had lost it 25 for a while. Ba rrentine said they he had sent it to 24 be hadn't licensing, aed licensing ined- received it; and nobody knew 25 where it was. I don't know where it was. Eventually it i

54 I turned up and got sent to licensing.

2 You are talking about the request?

Q I

A My report, that I felt that this was a

  • potentially

~

reportable condition, had to go to my section 5 And it was his job to report it to the level manager.

4 licensing people, whose names I don't remember any. mo're.

i Q Could you briefly explain the circumstances 8

surrounding the mode switch issue?

, w a,s A . Well, there WMPe= a variety of things wrong N with the mode switch. And, in my opinion, some of them II were kind of little things. But, the thing that prompted whew 12 -When I discovered that it was me to write the PRC was/ c.,uas o, possible to desynchronize the text::t unit so that tthe I4 switch selector handle in some specified position, you did 15 not get the contact closure that you thought you were getting. And the way that you achieved that-17 desynchronization was very similar to the steps you had to 18 go through to in assembling the switch. So it is entirely 1 . feasible that an operator, messing around with getting it 20 put together, could desynchronize those contacts and not 11 know it. And there was no functional test for that 22 switch, for that function, at any time that I could find 2S in any test instruction.

24 And, in I considered that to be a PRC.

combination with the other less important things that I 4

4

--..,m _.--m . -_,e 7, y, - - - , , ~ . - ,-,,,--r---.g~_,, - --

55 1 I felt were wrong with the switch, I decided that was enough 2 to write a PRC. So I didK. %

I BY MR. MC INTYRE:

4 That issue was part of the evaluation in the Q

5 PRC, wasn't it, with the desynchronization?

8 A Yes; they decided that the reactor mode I

switch did not have any safety significance. _ _ _ _ _ _ _ . . _ ,

8 3;. gy? m7 gg;7, g; ; 7,;;;3;;; h h had a two- or.

' three-page letter that made t'ha case for that. I had to 10 accept it because those fellows know a lot more about the

'II systems than I did, about the control systems and what 12 they controlled.

II MR. PETTIS: Were you aware at the time that 14 there were procedures in effect such that, if you were not 15 sa tisfie d with the r esults of the PRC evaluation, you 16 could, then, resubmit it to the safety and licensing?

II A .No; I don't believe I was aware of that. I II am not sure that GE had any such procedures. Maybe they I'

did, but I was not ware of them and I am still not. I do 20 know that, at the time, I was struggling real hard .with a 21 lot of these issues, and, you know, I just did not have r

the resources left to pursue that any further. In fact, I 28 got a bad appraisal for pursuing it after I should have c i

24 l stopped pursuing it. The issue was stD1 open when I was transferred from production f ollowing ep- to technical i ., - , . . - , _ . - - . . . . _ , - - _ - . _ - . . . - - - - - - - . - . - . - - - - . . - - -

ec w w w g licensingy un%.

2 One of the comments that Reghitto made on my 1

first appraisal was that, I was, I think he used the word 4

" preoccupied" or " overly occupied." I think he said 5

preoccupied with concerns outside of the' unit. And I 6

asked him what he meant by that. He indicated - that I 7

should quit pursuing this mode switch thing and get on with the job that I had been assigned to do in M new 9 osibo p% n .So I was under some pressure from my current manager 10 to leave it alone.

11 I did pursue' it after we had a design review 12 meeting, a couple of problem review meetings, and done 13 some design changes on th'e way the switch was assembled and wa y it was supported.h I did not thin tYere 15 adequate, necessarily. But I was outvoted by the design 16 review team. So there wasn't too much more that I could 17 do beyond that.

18 BY MR. MC INTYRE:

19

O Were you aware of the fact that, in the end, 20 they did make some modifications?

21 A Yes; as I recall, they used a thicker gauge 22 of metal. Are you familiar with how the mode switch goes 23 together?

24 11 4t i; a o ... i l J ,  % is purchased as 25 non sa,(eAy something that they call a CAM switch, a er2fety related j

a r--,- ,-y -

--e , --- --, .e . , - - - - - - - , , - - - - ,,g- --- w- -- -

e 57 I

unit. And' then it gets assembled into a box, a metal box.-

2 And they. call that assembly the mode switch. And th'a t 5

assembly is considered to be a nuclear safety related 4

assembly.

' ~

One of the things they changed was the 6

thickness of the metal that is used on one portion of that 7 Thert, box.

Scent:: th c re were little fasteners called avdelsy ~

g e , vet n.ds) ww se.k w er e cr'i mpe d y

it-te{ sort of like : ::uted n ut. Ye" crire it- into the me cal and th ,_pgi;;; ro v'.d e.d jr" some threads to put a screw in.

10 But the metal gauge that we were using was a 11 little thin and these avdels had a tendency to spin. They 12 B NfP W3 were not  :::. piny the metal. One of the changes was to 13 use thicker metal.

l 14 i They also made a change in how the box was '

15 held onto the switch. And I don't remember the details of 16 what they changed. But the result was that it was no 17 longer necessary to remove the screws from the' front of 18 the switch. Originally, the front surface of the metal 19 box was attached with the screws that held the switch 20 together. And that was the problem with the 21 becuse, desychronizationx, ecc2u:: you had to take these screws

! 22 Thew yea out, which loosened the front of the switch,and :: would 23 put the box on and you would put longer screws back into f

24 the switch.

25 The way you desynchronize the contacts was

58

~.'

)

I to loosen the screws, pull the front. surface a little, and 2 click it; then, put the surface back on. And that would I cause the contacts on the inside to not be in the right 4 position anymore. That sequence is very similar to the 5 sequence that might happen when you were putting the front 6 of the box on the switch. Because you take the same 7 screws loose. That is why I was concerned about it.

8 So one of the changes they made was to 9 redesign the box so that you did not have to take the 10 screws loose in order to put the front of the box on. But II I don't remember how they made that change. That was a 12 good change.

13 Q They did this on -- what, present and all 14 future designs?

15 A Yes. I don't know if there was any old 16 intention of retrofitting it to a+1- d e sig n s; alth oug h ,

17 that is one of the things that I said he+ I thought II should happen. They changed the way they supported the I' rear of the box, also, on the newer designs. They did not Cokrede.5.

20 change it on Kuo Sheng and Afr;nd;;. And I think they l

21 should have.

l 22 The reason is: the neck of the switch, C'*35 23 where it went through the panel, was a rather thin 4Hmme-24 section. And I saw one switch broken during the assembly U SEC '-

25 The assembler had it -stru:h through the hole process.

l l

l

59

- ht .

. I and they just kind of lifted the back and snapped the

~'

nac.k.

2  :::hr. It was fairly f ragile. And that neck was being 3 used to support the front of the switch. I did not think 4 it was seismically a good idea. And they changed the way 5 they supported the switch.

6 But, even after they made the change, they 7 did not change the way they supported it on the Kuo Sheng Cofreni.es 8 and-Cefr;nde- I don't remember where they are. I think tkd C.4rente s 9 -the C:fr:nd;; is in Spain, and -t-he-Kuo Sheng somewhere in 10 the Far East. I don't remember now.

Il M I wasn't e ntirely sa tisfie d with the bd 12 resolution of the mode switch problems)( -But I had to drop 13- it because I was in a new job and the new boss did not 14 want me to keep pursuing things from the old job.

15 //

16 //

17 //

ts //

19 //

20 //

21 //

22 //

23 //

. 24 //

t 25 //

l l

l I

&O

' 1 BY MR. McINTYRE:

2 Q So in the end, moving over to the new group 3 really killed any effort that you had in trying to resolve 4 that.

5 A I think that backfired on them. They moved me the p re dach ion 6 out of that pr;j;ct support job into what I believe they 7 considered would be a safe place for me. I think they were 8 trying to get me away from where the panels were being 9 manufactured because I was creating a lot of ruckus there.

10 The reason it backfired was that they put me into an area 11 that was just as volatile because we were providing 12 technical support through the licensing people and legally had 13 it was no better off than the panel shop M been. So I 14 think they tried to move me into a safe location 15 and just did not f oresee how it was going to work out.

16 That move wasn't my idea by the way. They suggested that I 17 move. "t . '. : p p; .. ; d *'a r ---it ir attribut:d to : :: e f-18 -t ' e fci;;.d; th2t I h'ad . A lady I knew named Sophia Renda Skt.

19 came to me one day and she said that -tswy thought they were j 20 going to find a new job for me because somebody she knew l CoWc.c i 21 heard Bill Marklein talking to fy\ in the hallway, M andhe.

hob "

22 said that we ought to find Milam a new -ehep. ,;cm needr Mubl(s n 5 %Sesh d that m e, ,

23 .. j:t and t: m if Reghitto would like to have -hte:

She.

24 And she said based on that little thing that -we- overheard I

25 that maybe they were going to suggest that -yew go work for l

l L

l 1

61

%.,-. 1 Reghitto. And I said -- well, that is interesting. And 2 about three days later Lee Cobler came to me and said --

3 Sam, I- think we've found a real opportunity for you. There 4 is a job opening up with Reghitto in the licensing organi-5 zation: I think it really would fit your skills well. -And 6 I : id cll, xd I tried to pin him down; I tried to get 7 him to tell me whether he wanted me to leave or not, and he 3 would not say whether he wanted me to leave or not. He just p said he thought ,it was an opportunit;. for me, so I left.

10 But it was arranged; I never even applied for that job 13 through the posting system. It was just offered toime.

swy one.

12 And I had been applying for jobs and hadn't got anyone that 33 I applied for, and then that one fell in my lap.

14 BY MR. PETTIS:

'. o s t am.e 5 15 Q Are you aware of any 4*eM4etee, in which a 16 potentially reportable condition was not properly evaluated 17 by G.E. a s required under 10 C.F.R. 21, and also G.E.

13 procedures?

19 A I think we could probably make a case for 20 that since, as I understand it, the potentially reportable

'm l 21 condition is not just a safety defect-ae4 a piece of l

22 hardware, but also a violation of any rule or regulation 23 Precedure or requirement, et cetera: -i t 's all r;quir ci O

%s 544h EI5 EE  % %s h dt w w nW& . y =  %> . w 6 A&&j b> M 25 *im s = f f e"- - u ink M n- 2" "~~ Mid ;; Til, I' P

_ - - _ , ~

G2 1 n,, a u  ;

3 1 _thii 5:' using unverified documents to support the FSAR, I

J or '

2 and the sspport things that we sent to customers 4se. things

. 3 that we sent to licensing might be sufficiently fraudulent 4 to be considered a reportable condition. -

5 Q Could you be a little more speci.fic?

6 A When we compared FSAR's .to KK th t  : re des %n 7 de ig .cd documents %)( and found some disagreement, we 3 needed to resolve that disagreement. And depending on 9 which document needed to be changed, we would either 10 propose a change to the text ee the FSAR, or we would make 11 a change to our design documents. The way that we would 12 make a change to the design document was with an 13 engineering change request. It was written on an ECN form.

14 We would send the engineering change request to the 15 responsible engineer as request for a change. We would 16 send.a copy of it, or maybe just the numbcr of it, to the 17 licensing people with our statement that the design 13 documents did, in fact, support the FSAR. The licensing 19 people would take that statement and the engineering change 20 request and go to whoever they needed to go to in the NRC, 21 or a customer, and say -- yes, the design documents do 22 support the FSAR.

23 Meanwhile, the engineering change request was 24 not tracked by any kind of system -- did not go anywhere R

~25 retrievable -- end- j u s t went to the engineer, and he could

G 63 s 1 either do it, or do some of it, or throw it away. And we 2 never told licensing that. Now, I told Bob Strong that once in licensing, but it was unofficial; it w a's just a 3

4 conversation I had, and he was perplexed by it, but I am 5 not aware that he ever followed up on ity.-e+ I think that MaMw3 6 is the case.;;trnti;11/ nking-a false statement, saying 7 that the design supported the FS AR when, in f act, the 3 design change may never have happened and we did not follow 9 up on it. Now, I don't know, maybe you can make a case of 10 that being a reportable condition, I don't know.

ij There were times with the answers to cust.om-

  • r evieuas 12 ers' questions and FSAR refurrd where we used NEDO-type documents to support things. Now, those were like public 13 to e'a cd 14 documents or licensing typic 1 reports -- that ' sort of thing. They were not controlling documents; they were 15 16 descriptive documents. Nothing was made according to those 17 documents, or inspected according to those documents. They redsnon 13 did no t have any kind of defined system of ef ficirr $

19 control or any kind of review or issue cycle, but they were Th e. h co.,t r. ny to p '.cM used. i.ic=:ing typir:1 report was a good example. They 20 21 were used to say that things were a certain way, that 22 certain design features were there, that certain statements 23 in the FSAR were supported, and I don't think that was 24 proper either. I know that if we used an unverified 25 document -- and by that I mean a document with a deferred

s 64

's 1 verification -- if we used an unverified document in 2 support of any of these statements,- we did not tell' the gren 3 licensingfthat it was unverified. We just let them assume 4 that it was, in fact, a verified design; and I don't think 5 that h was right either.

6 I am not sure that these circumstances are the 7 kind of answers you wanted to that question. If they are a not, ask the question again and I will try to give you a 9 different kind of answer.

go ~0 I was just: hoping that you could be more iy specific with the particular instance or activity, or 12 something a little bit more definitive.

~

33 A Could you give me a little more help about 14 what kind of thing you are looking for?

15 0 Something that might be related to a specific 16 plant, or something that may be related to a specific 17 safety-related ccmponent or piece of equipment, 13 A It is real difficult to remember which problem 19 went with which plant. I was involved with a lot of plants 20 -- a whole bunch of plants -- and the problem is that the 21 design documents all looked very much alike from one plant 22 to the next. Al'1 o f th e problems that existed on one 23 existed on several because they had all been made from some 24 earlier different one, and after this length of time I just 25 can't remembe r which plan t or which system had which

s 65

%, 1 -problen.- There were too many different ones I worked with 2 and_most ways they were too similar. So I just can't do 3 that without actually going back into the record and No 4 find some particular example that I might have recorded.

5 'That would be the only way I can remember that. I can only 4 remember the kinds of things that happened in a generic 7 sense.

8  !!R. PETTIS: Do you have anything further, Mr.

9 McIntyre?

10 M R. McINTYRE: No, not without getting into 11 specifics, Were (C Para.3neG TitEbut that would,be w rrN sss < hard for you to recall.

12- we to do that, I would have to spend some time searching 13 into the work record to find whatever specific thing you 7

14 were asking about, and it might be' reasonable to do that, 15 but I don't happen to have my work record with me right 16 now.

17 MR. CLARK: Are you willing to do that?

18 THE WITNESS: I don't mind doing it if it is 19 useful. I am not sure that it would be useful since what I s

20 am talking about is the generic misbehavior of the system.

i 1**^

21 I told At-I never intended to try to point to some specific 22 instance of a defect and say that it was in any way more 23 important than any other instance of a similar defect. I 24 am looking at it from the point of view that the system did To 25 not work right. +e me, $ that is what is important. The I

i f

7 -.

s .

A s

66 '

N I . system did not work right; it routinely did not work right:

2 for years and years it did not work right, and nobody was 4 3 able to change that. To me, that is what is important; and i 4 that fact that my efforts to change it and, my opinion, 5 resulted in me losing my job there and ending my career in 6 the nuclear industry, which is an industry I care for quite 7 a lot. I think if you want specific examples, pick a plant 8 -- pick a system -- and you will probably find specific 9 examples, s 10 MR. PETTIS: Well, we would need something 13 from you that was highlighted in your work record that 12 resulted in a specific plant panel involved in a safety-t2 related-type application. We are basically concerned with 14.. Jnly safety-related-type equipment.

15 THE WITNESS: Well, not all of my work was 16 with safety-related-type equipment. But the fact is the .

17 same design control system was used regardless of whether 13 it was safety or non-safety-related equipment. So any aned-19 generic malfunction in the system would effect; either 20 kind of equipment. We did not hav_ea separate design c.wirot sysic.m 1 21 -Ivil;;- for non-safety-related equipment. So I would 22 assume that any malfunction that I was aware of would 23 eventually come to bear on some safety-related system or 24 componerit .

25 li

,---,----.._.--..-...,-m _- .

67 BY MR. PETTIS:

] 1 2 Q Would it be correct to say that your concerns 3 are basically general?

4 A Generic. I guess general is a good word.

5 BY MR. McINTYRE:

6 Q Generic within the GE system you are talking 7 about?

sbe A 8 A I'm not speaking -4trr- any other participant in Aboat 9 the nuclear industry. I'm speaking only -dee GE and only Soat 10 fer- the San Jose facility. Maybe in Wilmington they have a 11 wonderful system -- I don't know. The only place I ever 12 worked was the San Jose facility and in fact it seemed that 13 C& I was probably worse than 10th Streete ;::plc. I don't 14 know why but, before I went to C & I, I had heard of the 15 place and it had a reputation as being the most screwed up 16 part of the whole company. And when I went there I came to 17 believe that that wasg. t ft:t, t- That was the way I 18 perceived it after I had been there awhile, but I don't 19 know why.

20 0 They were more production-oriented?

21 A It would be a shame to think that being 22 production-o riented necessarily means you have to be 23 screwed up. ,

24 MR. PETTIS: Well, if there is no other 25 comments or questions from any of the other members of the J

68 w;- 1 team --

2 MR. McINTYRE: Do you have anything you want

.. 3 'to ask, Mr. Prescott?

4 BY MR. PRESCOTT:

5 Q The only problem I have -- did, they tell you 6 that - - did a team come back and tell you that this PRC for 7 the reactor. . mode switch was closed out? Were you aware a that they had closed that out formally, and what they had 9 done to close it out?

10 A I was notified.by letter from Barrentine even-11 tually that it had been closed out. I don't remember $.he 12 date of the letter, but it was a good many months after I 13 wrote the PRC. I, perhaps naively at the time, thought 14 that a PRC had to be answered within a matter of days.

15 There is some provision in the Code of Federal Regulations, 16 I guess, and also in the GE procedures. I don't remember; 17 I think it is something like two to three days. But it 13 turned out they had a way of interpre$ing that. I guess 19 that they had .to respond within a certain number of days 20 after having decided that it was reportable er crrething 21 and they could take years to decide that if they wanted.

22 There was some kind of an interpretation that gave them, be.

23 what appeared to q a loophole that was in conflict with 24 the spirit of the thing, but they did not seem to feel that 25 it was necessary to respond within any defined l'ength of

e 69 1 time after I sent my letter.

-- ]

2 Q Were you aware that they made some design 3 changes to the actual switch?

4 A Yes; I was in on the design review team that 5 made those changes.

6 Q. Remember making that design change part of 7 your work record showing?

8 A Yes; it's there.

9 Q It i.s in your work record?

10 A My thoughts on the meeting are c part of the 11 record. I wrote that down in some detail. The easiest 12 place to find it would probably be in the volume of the 13 reactor mode switch, but you could find it h ))( near 14 the end of the Lee Cobler record, and the beginning of the 15 Reghitto record ,- if you wanted to look in those volumes.

16 But you would find it a lot easier to follow the history of 17 that issue if you looked in the mode switch volume because 18 I have taken all of the pages from the record, put them in 19 one binder and drew a circle around the item number on each 20 page of the item that is a part of the mode switch chron-21 ology. It would just be a lot easier to follow because, ony 22 often,fone-item on a page of half a dozen or so items would 23 relate tc the mode switch.

24 BY MR. PETTIS:

25 Q Do you feel the mode switch is the most

70 s; I significant part of your work record?

2 A No; I think the deferred verifications is, and 3 that the deferred verifications affects everything. It i Tht. .f 4 ;ith2r thr philosophf ee deferred verifications got down 5 into the production area too, but I did not recognize it at g the time because I had not thought about deferred verifica-7 tions then, but we had things we call conditional shipping 8 releases that we were supposed to us e. I gues s I wa s 9 becoming aware of deferred verifications even while I was 10 in the production area, and I began to worry about whether yy or not we needed a conditional shipping list for things 12 that were one way or another incomplete and did not have g3 something finished that they needed to have finished. But 14 I did not have it as well-defined in my head then, but 15 looking back on it I can see that the doctrine of not comple, ting something before you ship it was, in effect, 16 17 down in that assembly shop as well.

The doctrine is somewhat pervasive. You don't 13 19 have to complete anything before you are finished with it.

20 You just do what you have time to do, or what you feel like l 21 doing, or what you are capable of doing hy G Lcc;r th e l 22 Ci ~ .;t;nces that c:ue : it t: not be c m 1=% jK and then issue it or ship it just to meet the schedule. The billing

, 23 l

l 24 schedules were very importantf.Lhat i2 27 i;;;;c 25 Dates were very important with the drawings. But it is the l

\

71 4

1 same doctrine -- to meet the schedule.

2 BY MR. McINTYRE:

J 3 Q What did you call tha't -- conditional?

4 A Conditional' shipping release. It was supposed 5 to define what was wrong, or what wasn't there, or what 6 wasn't complete. It was another one of those systems that 7 you show an auditor to demonstrate that you are controlling 8 something. I imagine the DVSCN was probably generated for 9 the benefit of some auditor to show that we were control-10 ling deferred verifications and then just never used. That it was kind of a typical way of doing business. In fact, often 12 ir.d c. c d , there would already be a procedure in place, but o c s a vn a a n d. M.o v-i3 somebody did not know about it c;;;d:t, ++ would catch 14 them doing something they should not do, so they would just Ano Oner 15 wri te .a. pr oc edure , and then they would have people 16 violating two procedures instead of one.

17 BY MR. McINTYRE:

13 Q I have one other question going back to your I

in I c (C,

^

19 early years where you said you did not

20 have your own copy of the operating procedures -- the EOPs.

l 21 I was just wondering -- was that common practice for all of 22 the engineers?

23 A Certainly. Very few people had any EOPs. In 24 fact, there were a lot of other procedures manuals. I l

25 never was able to learn of all of the ones that existed.

l l

l

[-

l 72 I Toward the end I started trying to collect procedures

-]

2 manuals. There was a quality assurance procedures manual, 3 manufacturing procedures manual and manufacturing standard )

4 procedures. There was an engineering internal procedures 5 document, a drafting procedures manual and EOP, an NEBG 6 procedures manual, and I don't know what all else. I would 7 occasionally see one on somebody's bookshelf and ask what 3 it wa s. I. f ound ou t onc e tha t it was some licensing 9 procedures manual.and I tried to get a copy of that, but I got 3.

10 don't believe ! ever ded, There were procedures manuals 11 everywhere.

12 Q But the engineers did not have control 13 proceduresofKthe.\reosn$

desks Thert useatd 14 A Not at their . desk , no. Thrj :: : usually be artA in the etaees.

15 one ee- somewhere -- usually in the- manage r's 16 office.

17 Q When you first would come on-board with this 13 unit, would you be required to sit down and read through 19 all of these procedures and, say, sign off on them?

20 A No; never. In fact, when I moved into the 21 technical licensing unit, I went looking for the EOP and 22 f ound it in the bos s's of fic e. And if you look in the 23 -f a ; t Fr--abli the-first dozen or so pages of the 24 Reghitto record -- maybe the first twenty pages of the 25 Reghitto record, you are going to find where I made a note

73 manual 3, 3 of howmanyrevisionsoftheEOPweremissinginhis[ It  ;

2 seems to me that there were probably about ten revisions of

, 3 it that were not there -- had not been inserted -- and I 4 had to get them myself and insert them into the manual for 5 him. So nobody was even paying any attention.to it. Nobody 6 was even bothering to insert revisions. I made a record of 7 that. Eventually I volunteered to take over maintaining 3 that manual, which was basically a secretarial job.

9 Normally it was .some clerk or secretary who was delegated 10 the responsibility for just inserting revisions when they y3 came around, but nobody was doing it; nobody cared, and'I

%'. m 12 needed an up-to-date manual so I just told ;.hca I would be he. wE4td he.

33 glad to do this i f 5 n ::; r.: me to, and -they- said okay. So 14 af ter that they routed all of the updates to me, and I kept 15 their manuals up-to-date for them.

16 MR. PETTIS: Did you two have anything else 17 that you would like to discus s tha t maybe we haven't is covered that is foremost in your work record?

19 MR. McINTYRE: What you feel as irportant.

20 THE WITNESS: I don't know. I guess we could 21 probably sit and talk about this for hours. There were all 22 kinds of incidents that happened, but I think they probably 23 revolve around the same general principles that we have 24 already covered. In five years a lot of things can happen.

25 //

l l

l i

l 74 l 1 BY MR. McINTYRE:

].

2 Q -

Could you see any positive changes within the 3 five years in this system?

4 A Not really.

5 THE WITNESS: .Do-I need to be. careful about 6 quoting'four-letter words here?

7 MR. CLARK: No; feel free.

3 THE WITNESS: I don't know if I related to you 9 what Barrentine said to me in the hallway one day, did I?

10 MR. McINTYRE: No.

11 THE WITNESS: It is just an amusing statement 12 to look back on I guess.

33 BY MR. McINTYRE:

34 0 Barr'entine is your --

15 A He is the section level manager about three 16 levels above me I guess. I th .a I t:ld jet thi;  :*^ry A

17 nfL I $ Diane Taylor and I had written .4e- PRC jointly 13 and simultaneously gave it to our managers--

19 Q On your reactor mode switches are you talking 20 about?

21 A Yes. She was in QA, I was in engineering, and 22 we weren't really supposed to be cooperating, but she knew 23 a lot about the QA record center and test instructions that 24 were relevant to the issue, and I knew a lot about the 25 engineering documentation. So on this particular issue,

75 I our knowledge was sort of complementary to one another. So 2 we jointly researched this in each general area of 2 expertise and we put together this PRC4 Cd - Ot; itc .

4 But a few days later, Barrentine stopped me in the hallway CSM Comt.

5 and I ws.am.e. c l o s e t o qu o t i n g w ha t h e s a id - - m a yb e n o t 6 exactly, but he said, " Sam, you have demeaned yourself as 7 an engineer by even allowing these QA pricks to be involved 8 in your work," and that is sort of the attitude that was 9 coming down to us I guess. That because I cooperated with 10 a woman in Q A to write a PRC. It can have a chilling 33 effect on a lot of things -- like cooperating with QA.

12 BY MR. PETTIS:

33 O There was a stctement in your work record that 14 indicated testing of panels to elementary diagrams.

15 A That's an interesting area. I'm glad you 16 mentioned that.

17 Q Would you kind of expound on that a little 18 bit.

19 A Well, it was fairly common to have very 20 similar elementary diagrams for different projects. And in order to save draf ting man-hours, make one connection f 21 22 diagram to satisfy more than one elementary diagram. Now, 25 the connection diagram shows where to run the wires point 24 to point within the panels in order to achieve the circuit I

f 25 functions that are specified on the elementary diagram. So l

i

76

'- 1 if you had elementary diagrams with variations on the same 2 circuit, you end up with a connection diagram with 3 variations ~on the wiring. And you can't show that on one 4 connection diagr am.

5 I found one particular. example of a connection 6 diagram.that applied to TVA and Grand Gulf which, rh:x fu u-7 :A .m .11 t;;;th; , th;. o . t 1 ; ; ; t h _ l f A ,. m .. C:pd 8 -Culf; :nd 2 k =1 f-: d::rr T'J?.;; and they had revised 9 this connection diagram back and forth depending on which 10 plant they happened to be building at the time so that it 11 would satisfy the appropriate elementary diagram. In other 12 words, it had to agree with the TVA one month, and then 13 then would revise it to agree with the Grand Gulf elemen-14 tary so they could build Grand Gulf and then they would 15 revise it back to agree with TVA again because they had one 16 connection diagram and two elementaries. Well, there were 17 other consequences of this.

18 tn: ce..aequ;nce *a *k k intM* 4f *'; . .ner-T h ere.

19 tion ding::: a 11, there was at least one case where I 20 know that they tested a panel to the wrong elementary functional 21 diagram because of the pane 1K passed all of the 22 tests, and the connection diagram did not agree with the 23 elementary diagram f or the panel; it agreed with the 24 elementary diagram for the other panel, for the other 25 project. So the fact that the panel passed meant that the

77 I wiring agreed with the one they tested it to, right? So 2 they could not have tested it to the proper elementary 3 diagram or-it would have failed. I found the opposite --

4 that on one panel they could not get the panel to pass and 5 -t h: it turned out they were testing it to the wrong 6 elementary diagram, and they did not know it. The tester 7 did not know he was using the wrong elementary diagram. I 8 don't know what you say about a tester who doesn't know t\tme d rej

-9 which ;i n s t er diagram to use -- I guess he did not check 10 the number or something.

Il Q Did they have a procedure written by GE?

12 A They had a test instruction. They had a test n u m be.r s 13 instruction that listed the n =her of elementary diagrams.

14 This particular test instruction was to both numbers -- did 15 not say which number was for which project. And he just 16 happened to use the first one on the list, and it just He htdn' t read 17 happened to be the wrong one. A..d he 'd .esd d ;x-- On- the la title block where it gave the name of the project on the cle.mentary He efilyAm could not tell that from the test instruction, 19 d: .ing.

el c ,entaer chycam. Lt h e d',e or :

20 but he could have told it from the dr wing ~ut h; did look 21 at the title block; he just started testing. So that 22 situation led to a lot of interesting consequences.

23 Q' So what you are saying is that a panel for a 24 TVA could have been tested to a Grand Gulf elementary 25 diagram?

78 3 .- 1 A Yes.

-s 2 Q And it would have been apparent if the tester

, 3 had maybe looked down at the bottom of the title block and 4 saw that that elementary diagram was for the wrong plant?

5 A- Yes. Of course, maybe he did not know which 6 plant the panel went with. I saw instances where panels-7 had the wrong tags on them and production control did not avs. Rer 3 even -- in f a ct, that was -e th r game that production an 9 control would play. They had something called-e-10 inventory transfer notice that I supposed had originally 1

it been intended to transfer bolts from.one stock number to 12 another stock number when the bolts were identical and they SugeMer5.

13 had been bought from different ergplic: cr :::: thing; It 14 was for transferring that kind of inventory. They' were n s+:s e-t 15 using this inventory transfer -Metr to transfer panels from prQtch 16 one p: t, to another just because both panels happened to (for e samete) 17 beta G36P2. If they happened to need a Hope Creek G36P2 13 and they happened to have another one sitting there ir th:-

fae an other Pr*3e ct, 19 f:tch p, the y would just do an inventory transfer notice A4 g a n41s ms wd- be.

20 because it was a G36P2. But -th:y r27 1 :h the same.

21 They may have different cutouts or different arrangements 22 or things, but they would do it anyway, and it would become 23 a problem downstream that I would have to solve. It took 24 me a long time to realize that %e4 was happening. It 25 explains a lot of strange problems I encountered where

79

' I things did not add up right and I could see no reason why thepanal 2 44 did not match the enclosure drawing. Things were not 3 done in the right place, and I understood eventually it was

% ' n the sam eprye r.4 wh eve i

4 because +her probably did not start out 2: : ";p: Crc;h dr Suf905ed 5  ? -ended

^ 1. 4"It was pr;;;d to be an enclosure drawing to some 6 different project, so that was another peculiar thing that 7 used to happen and, as I told you, production control often 8 did not even know where the panels were.

9 I remember one panel -- I don't remember which hro to project it was -- they told me that it was 4n ghassembly and'en de 11 paint shop for a final touch up, and I finally found it 12 the fab shop, laying on its front being welded together, 13 and I don't know what panel + hey tim %t t "t p:n:1-had 14 actually gone through into the paint shop had been shipped, 15 but it wasn't that one.

16 0 Could you explain what panel we are talking 17 about?

18 A It could have been any panel -- any control 19 panel or any local or remote panel. It just --

the 20 inab lity to know where a panel was had nothing to do with 21 wha': kind of panel it was ; it seems to just be the way 22- tieir system worked.

23 0 Just for our discussion here, are we talking ,

24 about safety-related panels?

25 A Well, it might have been. Like I said, any

80 w -1 aspect of this system would apply equally well to either a faneh 2 safety or a non-safety [ in fact, most panels had something 3 in them that was safety-related. I would say almost any saftAy reW 4 panel would have somethingfin it because we had -- well, we 5 had divisional wiring in almost every panel. I don't know 6 if there's any panel that had only one division of wiring,

-7 so there was always at least divisional separation require-8 ments, and probably at least one nuclear safety-related A

9 something on the panel. -I t x;; au,  ; lot of what we 10 had was nuclear safety-related.

11 Q So what you are saying is that the panels 12 manufactured were all manufactured under the same QA, QC 13 program?

14 A Right.

15 0 So there was no identification as to --

if a 16 panel was on its way to a fossil power plant versus nuclear 17 power plant?

13 A Well, all we made was nuclear panels, but 19 there wasn't a separate system of control for whether it 20 was a safety-related panel or not. They were all treated 21 Pretty much the s ame. At least I am no t aware of any 22 difference in the system; not any documented difference in 23 the way that they were handled.

24 Q So it is your understanding that the 25 activities conducted during this time were strictly for

81 s I nuclear power plants?

2 A Well, the only thing we made was nucle:: :nd i 3 nuclear panels. There was one point where George Senn was l l

4 talking about getting into some other kind of industry, but 5 I don't believe it ever happened. The on1y thing I am 6 aware of that we ever made was nuclear panels.

7 0 So there is a possibility that other panels, 3 non-nuclear related, are manufactured at a different GE 9 facility? .

10 A Not by the nuclear energy division. The only 33 business we were in was the nuclear business, and we were 12 not making washing machines or anything. It was strictly a 33 nuclear energy division, or the nuclear energy business The.

14 group, depending on the point in time h name changed; but 15 it was always madcr the nuclear business. And that's all I 16 did; that's all we did -- nuclear work.

17 BY MR. McINTYRE:

13 0 What kind of a system did they have in place 19 down on the floor to follow the panels where you said that 20 they would not know where they were?

21 A I'm no t -e e f amilia r with how production 22 control kept up with where things were. I don't know how 23 they did that.

24 0 How would you go -- when you said you would 25 locate -- how would you go about finding them?

82 1 A Well,- I would ju st go a round phys ically 3 '

neeled +o 2 searching. If-I ~ " ' ' - " find one, I would go look for H.

3 4 hem 4 Q So you would not go through a tracking system?

5 A No; I would just -- the panels ' had little 6 tags, little metal tags on the bottom ~down on the inside 7 that usually told you the name and project of the panel, 3 but sometimes they were wrong. And there would also be esferwo r k.

9 -p ;;1: ;:rhi=; on. the side of the panel, or a label stuck And 10 on the panels somewhere. Awf. you eventually got where you 11 recognized the panels. I know that during my last month, 12

" - - I 'io; d)( af ter I had received my layoff notice and I 13 was spending most of my time over in the Placement Center 14 on Pullman Way, one day I was tired of writing resumes and 15 filling out job applications, and I went walking around through the back 4et of the building, just to relax, and they 16 17 had a bunch of old panels stored back therey, -and- I was 13 walking through this row of panels and suddenly'I stopped rewsnh el A 19 and I-::ia r:cognic: tha t- panely, eed I went around, I 20 looked in the back and I said yes, there are things I c.hangd Pan tl5 - Ye w chang:-; this is one of my y,.-.., .. .. , - g o t familiar with 21 b,learnal They were 22 them.))(y- .ccrr to recognize your own panels.

23 each individual, so you know that is how you find them; you 24 just know what you are looking for. I almost cried when I 25 saw that panel there because I worked so hard gettin ready

83 7 1 to ship, and there it was in storage. They terminated the 2 project or something, and it never got shipped.

, 3 0 Were you ever involved with any internal GE 4 audits in, say, the years of your work record?

5 A No; I never had the o pportunity to do any 6 auditing except just on my own. I was never part of.any 7 kind of audit team or audit function.

8 0 so you don't recall any audits of your areas 9 turning up any other concerns that you had?

10 A There were occasional audits; I don't remember

    • dWi%

11 any of them turning upf "ad f -; particul : ::nce: .;- 3 do 12 remember once, toward the end, some fellow from the Tenth 13 Street QA Group called me. He had been referred to me by 14 Al Barkley under whom I'd taken a class y -I dm..'t  :::: tcr-He to be 15 -th: T "/ ' 72-^ n: , but '.: was going ir t m...; auditing -e6- the huk 16 licensing organization and hetheard of me and he wanted to H e.

17 talk to me about things. 7.nd h: called me and asked me a 13 lot of questions and I told him a lot of things, and I 19 never heard from him again. I don't know if he went over Ad Mel b 20 and- rd:::d :: licensing or not, but that was the only time 21 I ever came close to being a part of an audit.

22 Q That was licensing, and you don't recall any 23 in the C & I?

24 A The problem is that everybody knew what the 25 problems were. It would not have been a matter of an audit

a 84

m. I uncovering something nobody knew about.

( 2 Q It would be documented though.

3 A Well, yo u s ee, those guys are experts in 4 providing responses to that sort of thing. That is how a 5 lot of those procedures came to exist. They were just 6 written to resolve an audit finding, but it doesn't change b w W ei k A-7 the way you do business. -Ycur right :f procedure to a resolve an audit finding and you promise to follow it and 9 the auditor goes.away, and the system of procedures is so 10 complex and there are so many of them that it is almost and 11 impossible for anybody to go in -aw audit and really prove 12 anything. You can always go into a procedure that you are rid and sq 4 13 following hK that you are-nee following7 14 GE is really an expert at surviving 15 audits, snowing auditors, blowing smoke in front of them.

16 They are really very good at it. If thc; -?er:  : gced ::

M 17 th;; :: )lp i s4 they were as good at running a design control 13 system as they are at surviving audits, there would not be 19 any reason to audit them.

20 0 So your biggest concern was the design to 21 deferred verifications systems I guess if you had to 22 pinpoint it down.

23 A I guess that would be my biggest concern --

24 that, and the fact that it sort of graphically illustrates 25 a philosophy or a doctrine of doing only what you have to i

85 1 do to get the thing issued or shipped, pretending that you '

.._, de vis*m aj 2 follow up .and do the rest later, and then diciding some ,

i 3 complex system for allowing it to get lost. That way of 4 doing things kind of recurs throughout the whole design 5 control system. And it is going to be very. difficult for 6 somebody from the outside to be able to penetrate that d;;k-7 and document ity,, e r de SwdV'9 Ab

  • d '** -

3 0 It is a complex system?

9 A ".d dc :n ; thing 2hrut it.

And the way they do 10 those things isn't the way they will tell you. Barrentine 11 ust. to have all hands meetings and talk to us about how it 12 was necessary that we followed procedures. But I guess 13 nobody took him seriously. hha t they say and what they do 14 are two -- well, rather different things.

15 MR. PETTIS: I would like to thank Mr. Sam 16 Milam and his legal counsel, Mr. Lewis Clark from 17 Government Accountability Project, and the'other members of 18 the NRC team for their contribution during this interview.

19 We would like to reserve the right in the future to have a l- 20 follow-up meeting if necessary.

21 MR. CLARK: Can I add something to the record.

22 Just as we discussed p-ir to th: begi....ir.g - O f thi ' ^ st 23 ma;

id _ y at the beginning of the session before it was O

24 on the record, we would like to request that the transcript 25 of this meeting not be sent to GE.

86

.( 1 THE WITNESS: And I guess we want a chance to 2 review it.

3 MR. CLARK: And for the record we would also 4 like an-opportunity.to see the complete transcript and make 5 any corrections that might be necessary, and make it more 6 accurate.

7 M R. PETTIS: Then that concludes the 8 interview.

9 10 11 12 13 14 .

15 16 17 18 19 20 21 22 23 24 25

.,. ,- . = , _ - _ . . . . .-- - . - - - __ - _

Thic is_to cortify that tho attachpd precscdinga boforo tho

.-UNITED STATES NUCLEAR REGULATORY CCtciISSION in the matter of:

' NAME OF PROCEEDING: INVESTIGATIVE DITERVIEW (CLOSEQ IiEETING)

DOCKET No.: NONE PLACE: SArt Jost, CALIFORNIA .

DATE:

16 APRIL 1986 ..

waro held as herein appears, and that this is the original tranceript theEsof for the fil.a of the United States Nuclear

~

Regulatory Corn:nission. ,

(Sigth .k .N-J (TYPED) /AMES W. H15G/SS J

. Official Reporter Reporter's Affiliation 9

g 9

41 3 e

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