ML20215F072
| ML20215F072 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/31/1985 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20214X072 | List: |
| References | |
| NUDOCS 8610160071 | |
| Download: ML20215F072 (22) | |
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U1Niltu STATES NUCLEAR REGULATORY COMMISSION
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-IN THE MATTER OF:
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I 0FFICE OF INVESTIGATION INVESTIGATIVE INTERVIEW
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MR. JOHN S. MARSIDLLL
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LOCATION: DALLAS, TO(AS ricus:
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DATE:
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OfsaalReportes 8610160071 860722 444 North CapitolStreet PDR ADOCK 0300 S
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BEFORE THE I
2 UNITED STATES NUCII.AR REGULATORY COMMISSION 3
OFFICE OF INVESTIGATION 4
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9 10 INTERVIEW OF 11 JOHN S. MARSHALL
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21 REPORTER:
Cynthia clay y
22 DATE:
July 31, 1985 24 I.
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2 MR. GRIFFIN:
For the record, this is an 3
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interview of John Marshall, M-a-r-s-h-a-1-1, Licensing 4
- u-Supervisor for TUGCO.
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And you're represented here today by e
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Robert Wooldridge?
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MR. MARSHALL:
That's correct.
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MR. GRIFFIN:
Okay, and for the NRC, H.
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P Brooks Griffin, Investigator.
10 The locatioin of this interview is 2001 Bryan
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Tower, Dallas, Texas.
12 2
The date is July 31, 1985, and it is 3:07 y.4 13 p.m.
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Present at this interview are' John Marshall,.
15 Robert Wooldridge and H. Brooks Griffin.
16 17 This interview is being transcribed by a
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18 court reporter.
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Mr. Marshall, I need you to rise and raise o
20 your right hand.
I want to swear you to the contents of 21 your testimony.
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23 JOHN S. MARSHALL, having first been duly sworn to tell the truth, the whole 24 25 truth and nothing but the truth, testified op his oath as f
follows:
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3 3-4 Before we start talking about the subject
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that we came here to discuss, I want to ask'you about your
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e Does he represent you for the purposes
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A Yes.
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Did you have any choice as to whether he, 7,
10 represented you for purposes of this interview?
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Yes.
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S' And.he is your choice of a representative?
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I just wanted to inform you that, you know, 3
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under the _NRC policy you are entitled to have a representa-
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It can be anybody that you like.
It's important
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A I understand.
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Mr. Wooldridge, as Mr.
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Marshall's represdntative, if you. perceive a conflict to v
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aris's between Mr. Marshall's interests and the interests
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of TUGCO, how would you resolve such a conflict?
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By' conversations with the 25 j
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And would you be amenable 2
to removing.yours~ elf if you found that that conflict went
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'MR. WOOLDRIDGE:
I.would -if there were
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.to be a conflict to exist, which I do not anticipate, I p
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-would not continue to represent both parties.
MR. GRIFFIN:
All right.
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And that's been explained 10 to Mr. Marshall and he understands.
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That's correct.
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Okay.
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John, your title.is Licensing Supervisor 15
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That's correct.
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_ And you've been in TUGCO for six years?
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Yes.
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0 And your inneh.at 4 supervisor is John Beck?
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A That's corm.ct.
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a Who was your immediate supervisor in May 4
I8 of 1985, when the MAC Report, which is what we're here 23 to discuss today, was identified or located?
24 A
John Beck.
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25 3-O John, were you involved in the prudence g-i bl
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. audit currently being performed, which led to the 2
identification of this MAC Report?
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.t hhat was your part in that audit?
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To provide that information that we had in "f.f our files on the licensing of Comanche Peak.
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Do you know who discovered the.MAC Report,
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8 do you know which individual?
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L Of my direct knowledge, no, I don't.
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Okay.
11 Did you have any contact with the decision 12
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~made by TOGCO to produce the document to ASLB and the NRC?
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In May,'857
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Right.
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No.
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Were you interviewed by Mr. Wooldridge as 17 9!
part of his preparation or response as to how or why the 18 q!
MAC Report was not produced in 1980 during the Intervanor's I,-
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request?
Has he interviewed you?
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Has Bob here interviewed you as part of 22 f
his investigation as to why the MAC Report was not produced 23 in 1980?
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Yes.
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In 1980, did you work in the licensing
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A Yes.
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.G Who was your immediate supervisor in 19807 4
L Mr. Homer Schmidt.
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Were yo6 involved in any ph'ase of formulating Pf 8
'the Applicant TDGCO's response to the Intervenor's request, 4
7 which Mr. Wooldridge in his notice to the NRC described
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as CASE's, (CASE is the Intervenor) interrogatories and 8
8 requests produced dated July 7, 19807 Were you involved 10 in formulating that response?
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A Yes.
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Could you,give me kind of a narrative of
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' 15 My job was to take that set of interrogatories 18 and get it to the right people, produce the information, 1
17 the answers, and identify those documents that would be n
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Do you remember being contacted to get that j
information?
Q 21 A
organizational 1y' yes.
Quality Assurance y
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Department and members of management.
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Do you remember any specific names of 24 individuals you would have submitted, either verbally or 25 in written form, a request for what might be produceable?
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would be the person that that document would be addressed to 2
3 In the case of Quality Assurance, it would be t;he manager 4
of Quality Assurance.
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A At that time it was, yes.
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What other division heads would'have been _
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Mr.. Merritt would have gotten a copy of it; 10 Mr. George, as members of a management team associated 11 with Comanche Peak.
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Any others?
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No, not offhand.
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What they do with that internally is as much up to them as to me.
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would normally contact to prepare such a response?
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That's--
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If you received--thinking back, if you 24 received this response, did you write a request for informa-25
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tion or identify the documents--how did you--
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I have a standard writing sheet.
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indicate on there the name of the individual that's to D
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an organization.
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Now my recollection serves me, that request 3:4 i
e covered a number of areas, the people that I have just 7
identified, project management, project engi-8 G
Who is that?
8 A
That's Mr. George, Project Engineering r
10 l-Management, Mr. Merritt.
Quality Assurance organization, I believe that set of questions also ha~d some financial 12
.i qualification discovery requests, so it would have gone 13 to financial qualification persons as well.
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I don't recall precisely who got that.
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Okay, did Merritt--
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Did Merritt, George and Chapman respond 20 to your request for input or--
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I got input for all of those questions.
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I don't think 23 so.
I don't recall.
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Q For-the' ' division.
3 When you received the responses from these c
various divisions, do you recall whether the 1978 MAC Report was listed as a rep ~ortable item?
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No.
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.was, something you should consider as a reportable item under 5
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the Intervenor's request?
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Verbally that was communicated to me, yes.
11 By who?
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I don't recall precisely who the individual
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It would probably have come from Quality 17 Assurance.
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It was verbal?
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L Yes.
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Did you factor this verbal information 21 e
into formulation of your response?
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I didn't formulate that re'ponse initially.
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Did you transmit the compilation of these 24 responses into a document?
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A Did I do that personally, no.
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Who did?
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A The initial response was drafted by the 1
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Debovoise and Lieberman.
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But you were the focal point for all this-
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responses; is that correct?
As to what was produceable?
A We've got a disconnect here.
The kind of 11 information that was.given to me was, these are documents 12 that could be considered in this category.
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A The persons that were trying to fespond 18 to these questions did not understand.
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Are you talking generically la
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I think you're getting confused.
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MR. GRIFFIN:
Let's go off the record a f
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minute.
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21 IDiscussion off the record.]
22 MR. GRIFFIN:
On the record.
3 23 We've just discussed off the record the intention of the NRC in pursuing this investigation, and 3
conveyed to Mr. Marshall our intent to gather all the 4
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information he has ori the subject and he said that he
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3 BY MR. GRIFFIN:
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Just a minute.
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were being evasive before, and I don't think that's the
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16 MR. GRIFFIN:
Okay.
11 If I. conveyed that, it was not my intent.
f.j 12 Mr. Marshall, and Mr. Wooldridge are being totally coopera--
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16 is and in furtherance of that he is hopefully going to fill 2
B, 1 us in on everything he knows on the subject.
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Thank you.
That clarifies t ':
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20 BY MR. GRIFFIN:
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John, can you tell me what you did with the 22 W
input that you received from the various divisions who were 3
23 responding to your request for information in the Applicant's 24 preparation for rgsponse to the.Intervenor's request in 25 1980?
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There were a number of documents identified 2
that were without question produceable as a result of her 3
interrogatories.
4 There were other documents that were d.
5 questionable about whether they should or should mot have
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a been in the record, or put in discovery.
The specific
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7 one that I remember was the MAC Report; it was only y
a mentioned to me as a possible; with that knowledge, when 8
it became time to produce documents I asked my management f
was that a document that had to be produced--
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' Who specifically did you ask?
12 L
I don't recall precisely who I asked
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It would have been Mr. Ecmar Schmidt or Mr.
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Law fikar, one of those two individuals.
That document I didn't hold, had never seen, e
16 didn't know what it was, didn't know what even the acronym, 17 I
as it turns out, stood for.
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they conveyed to me that that was not a document that 20
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fell within the realm "of her discovery request.
G Do you know which request--which one of 22 these managers. conveyed that information to you?
23 A
Mr. Fikar.
24 G
And do you recall specific conversation--
25 A
Yes, I do.
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--that'the MAC Report is not reportable 9
2 under this request?
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It does not fall within discovery request?
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Did you have any further involvement in 1.
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the response by-the Utility?
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I was one of the people that produced, LU.
. managed the showing of documents, keeping track of what -- -
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of thing.
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A That was my involvement.
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.that you could. assemble them? or ' oversee that scoebody else--
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The identification of specific documents i
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directly, no.
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Do you know if Schmidt or Fikar identified
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Did they actually review the list themselves?
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m They didn't produce a list, no.
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Who produced the response?
24 A
There's a diff.erence between lists, what's
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produced and what the response is, and I think if you went 1
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i back and read the response that might be' informative.
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There was not a list produced--
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Was there--
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-of documents that identified document by
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document.
It was--we would asse '
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e your review and you can review the:
That was conveyed N
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Brooks, that's what you've 1:*:
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l-e asked me to get for you and I'll get it for you, but it t..
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wasn't a formal response.
It was the documents that are l
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11 subject to~the request are available for inspection.
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That's correct.
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13 MR. GRIFFIN:
I just assumed that someone,
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L 14 somebody in the compastf, had to decide what was produceable'.E 15 and what waan't.
And that they would index those or j
1e where there were just two or three, they would identify 17 them somewhere.
And then everybody would know what was
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And I'm asking you what was-I A
To my knowledge it was not a list of specific l
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22 documents.
I think we may have put together at some u.
23 point categories of documents.
I'm thinking specifically, 1
24 TUGCO audits of Brown I, Root as a category, and those 25 are all--there is a list of those.
But was that list
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actually shown to the Intervenor3-I don't think so. '
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Not as a formal response.. She probably cited E.he'same 1ist 3-that we were using to keep track of those documents in the discovery room.
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Well, your function in assembling these 8
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' documents, was your part--did your part have anything to d
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he included, or excluded?
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--whether it was discoverable or not discoverable, iTJ g v.
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Did you sead in any request to any Brown
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& Root representatives for the audits of their QA progr'am s
16 that stay have been perf'rmed?
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A No.
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This was just strictly TUGCo?
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That's correct.
20 W-0 After you had tran==itted the results of 31 21 4l your responses to Schmidt and/or Fikar, did you subsequently 22 attend any meetings or have any discussions with Fikar or
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Schmidt as to what the final response would be?
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A The only discussion I had on the responses
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MAC Report.
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Did you see TUGCO's response to the
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3 Intervenor, the final response?
4 A
Yes.
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0 At the time, do you have any recollection MJ
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of noting if the MAC Report was, in fact, excluded?
7 A
Maybe I don't understand the question?
8 0
Well, there was a formal responne--
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That's correct.
10 MR. WOOLDRIDGE:
Reporting the document; l
11 I think that's the key.
12 THE WITNESS:
The MAC Report was not in A
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14 categories'of documents.
15 BY MR. GRIFFIN:
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At the time you discussed the MAC Report is 17 with Fikar, did he give you any explanation as to why t
f; 1s the 1978 MAC Report was not reportable under this particular L,
1e request?
20 A
Only that it did not fall within the i
2 21 scope of the discovery request.
22 MR. GRIFFIN:
Off the record.
23 Isomeone at the door for Mr. Wooldridge.]
24 MR. GRIFFIN:
Back on the record.
.3 25 BY MR. GRIFFIN:
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I think my question was--and I don't know 2
if you answered it--whether Fikar gave you his reason for 3
why he did not believe this was in the scope of the request.
4 Did he give you such a--convey to you that reason?
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5 A
only as I indicated before.
It did not 6
1 fall within the scope of the request.
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0 But no explanation beyond that?
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A No.
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O Did Fikar convey to you whether he consulted
'U anybody else in makihg this decision?
II A
No.
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Do you know if Fikar sought legal counsel's fj l
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opinion in relation to the MAC Report?
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No, I don't.
M 15 0
Do you know if anybody else in Licensing 1a
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consulted legal counsel in relation to the MAC Report?
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17 A
No.
1a O
Whether it should be produced.
I:
19 2
A It might be informative, nobody in Licensing 20
.had.& copy of that document or had ever seen it, so they j'
e 21
?j i really couldn't ask about something they didn't know anythinc 22 r
about.
si 23 4
All right, tliank you.
24 John, were you aware that in--I think it 25 V
was February 198.5, Region IV, Arlington, Texas, Office V
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4 18 of.the NRC,' wrote a notice of violation to TUGCO for,what 2
they perceived to be failure to audit the QA system.
Are i
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3 you familiar with this' notice of violation?
l!j-A No, I'm not.
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would a notice of violation regarding a QA 8
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8 normally cross your desk, or would you normally be involved t
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in something like that?
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We get copies of those, and the response.
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I don'.t recall that one.
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.Are you familiar with the Logan report?
+.
A Yes.
A
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B I want to show you the first page of this---
is this is an NBC letter conveying the results of this y.4..
- i inspection performed by Shannan Phillips, and then it I
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has an appendix connected to it which describes the 16
. notice. of violation and another appendix which describes 17 the inspection report.
s, 18 I just want you to look at it, just for the
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purpose of. seeing if it jogs your memory as to....
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A No, I don't.
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The reason I ask is that I personally have 7
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lj some concern that potentially the MAC Report may have been j
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fi 24 the initial request that later resulted in the*-in this l.
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And my purpose for asking is to V
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see if you all revisited the possibility of whether the
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MAC Report should be produced in response to, one, 2
the 3
inspector's request, and two, in answer to the notice of violation, or offer the document up in response to the 4
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..,j notice of violation to--just as a response.
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A.
It doesu't ring a bell.
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Okay.
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And I think probably the reason for this
, spe,cific one is that because it is part--was part of the to technical review team, as mentioned at the bottom, or.as is 7
identified as potentially part of the....
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Well, i think the Applicant's response was y
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. p to be made during the Comanche Peak Action Plan.
1s But that is after the notice of violation.
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16 MR. GRIFFIN:
Could we.go off the record.
- e 37
[ Discussion off the record.]
j; is MR. GRIFFIN:
Back on the record.
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13 BY MR. GRIFFIN:
1i Hg, 20 0
John, you have knowledge of-the original 7
li
. request for the Intervenor and the response made by the 21
..i Utility and to some degree, I presume you know about the 22 prudence audit and how the MAC Report was rediscovered.
23 24 I want to ask ycu an all-encompassing l'
25 question here.
Is there any information you have in any V
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. -- of the areas that reflect on the Applicant's response, 2
the decision not to produce, or subsequent location in
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3 1985 of the MAC Report and the decision or discussions to 4
produce that we have not discussed here today?
a 5
g I don't know of any other area that we
- 3 8
need to discuss.
I don't know of anything.
'2:'
7 S
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You think we have your complete testimony 7;
8 and knowledge on this subject?
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A That's corr'ect.
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John, have I threatened you in any manner,
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l, offered you any rewards in return for this statement?
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Enve you,given this statement freely and
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voluntarily?
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A Yes.
4 S
Is there anything further that you'd care 37 l.j
.to add to the record?
L',
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A No.
A N. GRIFFIN:
Okay, I appreciate your coming.
8 THE WITNESS:
Thank you.
N 21 sj IWhereupon, at.3:45 p.m., the interview g
22 was concluded.]
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CERTIFICATE OF OFFICIAL REPORTER 1
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3 This is to. certif,y that the attached proceedings before the UNITED STiTES NUCLEAR REGULATORY COMMISSION in the u.e statter of:
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P 't N
-Q"l NAME OF PROCEEDING:
OFFICE OF INVESTIGATION i
t INVESTIGATIVE INTERVIEW
.g MR. JOHN MARSHALL q
DOCKET NO.:
i l-PLACE:
DALLAS, TEXAS a
DATE:
Julh31,1985' j -
were held as.heNein appears, and that this is,the original transcript thereof for the. file of the United States Nuclear Regulatory Conunission.
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(TTPEk Cynthia Clay
_.g.
Official Reporter 3
Reporter's Affiliation q
Allied Stenotype Reporters 906 Texas Bldg.
Ft.. Worth, Texas 76102
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