ML20215F242
| ML20215F242 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/19/1985 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20214X072 | List: |
| References | |
| NUDOCS 8610160132 | |
| Download: ML20215F242 (28) | |
Text
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4-85-008 1
BW ORE THE
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2 NUCLEAR REGULATORY COMMISSION - -
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3 OFFICE OF INVESTIGATION 4
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8 INVESTIGATIVE INTERVIEW 9
CF 10 BILLY RAY CLEMENTS 11
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INVESTIGATOR:
H. Brooks Griffin 15 Nuclear Regulatory Commission 611 Ryan Plaza Drive Arlington, TX 76011 17 18 19 20 I
21 22 23 REPORTER:
Cynthia Clay l
24 DATE August 19, 1985 25 8610160132 860922 PDR ADOCK 05000445 A
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2 MR. GRIFFIN:
For the record, this is an 3
interview of William Ray Clements--
MR. CLEMENTS:
Billy.
5
- MR. GRIFFIN:. Billy.
--Billy Ray Clements, s.'
spelled C-1-e-a-e-n-t-s, who is employed as a Vice-President 7
for Texas Electric Service Ccalpany.
8 The date is August 19, 1985, and the time 8
is 1:37 p.m.
18 Present at this interview are Billy Ray Clemebtsandhispersonalrepresentative,RobertWooldridge.
11 4
12 On behalf of the NRC, myself, B. Brooks Griffin.
13 This intervi,ew is being transcribed by a gg) kyg court reporter.
~
15 Mr. Clements, I need you to rise, raise your 16 right hand; I want to swear you to the contents of your 17 testimony.
18 Whereupon,
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BILLY RAY CLEMENTS, 20 having first been duly sworn to tell the truth, the whole 21 truth and nothing but the truth, testified on his oath as 22 followss 23 EXAMINATION 24 BY MR. GRIFFIN:
25 0
.Before.I start asking you some questions
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1 about tho MAC R port end th3 history of that, I want to.
2 explore your relationship with Mr. Wooldridge here.
3 I,et me tell you to start with that you are 4
antitled, when you're interviewed by the NRC, you're 5
entitled to begrepresented, to have a. representative present if you choose to.
s' That representative can be anyone of 7
your choosing.
It can be a relative or friend or, if you s
choose, an attorney.
9 For the purposes of this interview, is Mr.
Wooldrid'ge your personal representative?
10 11 f'A Yes.
12 G
Mr. Clements, you're also aware of the othar 13 hte:.!C) lated groups a'nd individuals that Mr. Wooldridge re' presents 14 in relation to this particular investigation?
I'm asking 15 that as a question.
Are you aware that he's represented 16 others?
17 A
Yes, I am.
Is S
Are you also aware that he formulated, or to at least drafted the response to the NRC as to why this 20 report was not produced in 19807 Were you aware of that?
21 A
I was aware that he had some input to it.
22 I didn't know that he did the whole thing.
23 0
The reason I ask the questions is only to 24-make sure that you understand that he's representing other--
i..
25 A.
In that context, yes, sir, I do.
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,1 MR. GRIFFIN:
O 2
Mr. Wooldridge,..if during this int'iirview m.
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3 you' perceive a potential conflict of interest between what "
4 ever guidance or counseling you might give Mr. Clements as 5
to his testimony, if you perceive that there was a conflict i
e 6.
of interest, what would,you do in that instance?
7 MR. WOOLDRIDGE:
I would confer with Mr.
s Clements and we would. work out a nutually satisfactory 9
arrangement.
10 MR. GRIFFIN:
Okay.
11 MR. WOOLDRIDGE:
And Mr. Clements and I 1
12 have discussed that circumstance.
9 13 g'/
MR. GRIFFIN:
Okay, good.
if.p)'
4 14 BY MR. GRIFFIN:
15 O
Mr. Clements, when did you first join the 16 Utility?
Do you remember when it was?
17 A.
Can you be a little more specific? when you la say "the Utility," are you talking about Texas Utilities is Company system?
20 0
Yes.
21 A.
July the 1st, 1974.
22 O
In what capacity?
23 A.
I was executive assistant to Mr. Perry Britton who was at that time the president of TUSI, Texas Utilities.,,
24 25 Service, Incorporated.
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So tha question about--the question I 2
answered I answered as far as titles was concerned, but I 3
3 0
was the manager of Nuclear Operations working in Lignite 4
operations.
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,og,y, e.i For the purposes of this interview, when did
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you take on the responsibility of overseeing the QA program?-
8 A
August the 1st, 1980.
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8 0
Are you familiar with the history at all 10 of the,M'AC contract in 1978, when they were hired to do a 11 QA pr6 ram review?
l' 12 A
No.
9 13 G
When did you first become aware of either gyg.
14 s.
V.
the MAC Review or the MAC Report?
15 A
Generally in 1978, I heard that they were 16 going to do a review.
17 4
So you heard back before they actually started is their review?
'8 A
I'm not sure whether it was before or after, 20 or just generally I knew that MAC--
Your original question 21 was was I familiar with the MAC contract, and the answer to 22 that was no, but I knew in general that MAC was doing some-23 thing.
24 0
Okay.
r.
25 Were you aware that it was related to the gwy_-
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.S When did you become the vice-president ofi 2
TUGCO?
it 3
A June the 5th, 1978.
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0 When did'you assume responsibility for the 5
Nuclear Act, for the Utilities enterprise?
s.,
L I was made manager of Nuclear Operations on 7
September the 1st, 1975.
~s S.
And then in '78 you assumed your vice-presiden cy I
of TUGCO? if I understand you.
, A' Yes.
11
//' S Okay.
f 12 A
The managar of Nuclear Operations was a,TUGCO r
13 giosition.
03 g
Okay.
A Let me clarify that, if you will.
,a There was not much operations, obviously, 17 going on between the first of September 1975, until a s.ubse-quent reorganization in 1980. and so in about 1976 or '77*
our vice-president for Lignite Operations got cancar, 8
developed cancer, so in those interim years from about 1977, t
21 Mr. Griffin, whenever this particular time was, until August 22 1st of 1980, I spent 98 percent of my time working in--that 23 may be a little bit high number--but I spent.a large majority 24 of my time working in Lignite Operations.
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All right.
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implementati:n ef tho QA program? when
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it.
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A I'm not sure, u -uh, I'm not sure.
4 O
Mr. Clements, I have your statement that 5
was included in part of Mr. Wooldridge's affidavit m.-
s that 6
he, prepared in response to the Intervenor and I' m going 7
to be using that; it's dated August 8, 1985, and has your 8
signature.
I'm going to basically follow your testimony 9
and then ask whatever additional questions I have 10 A
August the 8th?
11 0
,l Yes.
12 A
All right.
13 1-
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. I,f Which I believe is the last one that was 69A '
Q) prepared,' t51at I'm aware of.
15 MR. WOOLDRIDGE:
Yes.
16 A
Makes three of us.
17 BY MR. GRIFFIN:
18 g
Okay.
19 In your testimony you said you were not T
interviewed by the MAC representatives, nor did you attend 21 the pre-audit or post-audit meetings That is true, I 22 casume?
23 A
- Yes, t
24 l 0
Have you ever met any of the MAC repr i
like John Jackson, or' Jack Norris?
esentatives, a1 1
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A Subsequently over the years, yes, I have.
2 G
After MAC completed their review of--
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telling 3. 2 this-they prepared a written report.which they provided to various off-icials, within the Utility.
Did 5
you ever have M id you ever see that report?
6 A
Not to my recollection.
7
.g Did you ever have any discussions with any 8
other Utility representatives regarding the findings or I
the results of that report?
10
-g I heard just general discussions among people, and I'm not even sure if the people making those
?
12 discussions had access to the report, but I heard them 1
13 galkingabouttheMACReportorMACReview,orwhatever.
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'd 0
Do you remember the names of some of the 15 people that you md.y have discussed this with?
16 A
The only one that comes to mind is David 17 Chapman.
18 g
Do you know in what context, or what was to said during that conversation with Chapman?
20 A
Specifically I don't recall; just converca-21 tions.
22 O
As you may know I've already interviewed a 23 number of other employees, including Mr. Chapman, on this l
24 particular issue, and you may already be aware that Mr.
25
..yy Chapman has conveyed to me that he believes that he did 8
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.havo o discuccign wkth, ysu en thio.cubject and that be--if 1
2 I'm characterizing his testimony correctly, conveyed to 3
you that he believed that this particular report was producible under the Intervenor's 1980 request.
Do you remember Mr.
5 Chapman conveging that to yo'u?
s.,
E I remember a general discussion about that 7
between David and me, yes.
8 9
And is that your recollection, that he felt 8
that it was producible?
10 A'.
Yes.
- 11
..a ' S Are you--
Let me ask you a question.
Are
.f 12 you also aware that Mr. Chapman has indicated, or has 13 h'
,f,destified that he believes that you were generally in O' -
- agreement with his assessment that it was producible at 15 that* time and that that is his recollection?
Is that is accurate?
'7 A
That's not accurate, mainly because I'd Is never seen the report.
I had no notion of whether it was 19 or not.
I hadn't seen the report.
0 Okay.
21 Well, remembaring b=ek to that di :ue:icn, 22 when you became aware,- did.you havn'an opinion.at that 23 time as to whether this report was produced at the-Intervenor's request in 19807 25 A
I had no opinion because I'd never seen the
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' report and I*had had no access'to the report.
So I was--
2 any opinions I had would have been based-on somebody el'se's 3
discussions.
M 4
4 Okay.
5 Nant when you assumed the responsibility over 1
8
- QA, I presume that this same Intervenor's request was in
.7 place, so to speak,.for subsequent years, in that the l
8-Utility was obligated to respond to other audits that might l
fall into this same category, which I believe is referred l
8 10 to as Isam 10 of the Intervenor's request.
Are you familiar with/fktfact?"
11
?
12
.A well, you said "I assume" and "I believe,"
. aid! I'm not sure--is there a question in there?
.13
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'O -
Okay.
I'm asking--I'm formulating this 15 question based on the fact that the Utility did respond, 16 or offered other audits over the years in response to Item 17 10 of the Intervenor's 1980 request.
During that time 1
is you were the QA--you supervised ultimately over QA.
l 1e A
Yeah.
20 4
And in that the Utility made subsequent 21 responses to Item log I'll put the question this way:
Were 22 you involved in those subsequent responses? like the Lobbin 1
23 Report--
24
, A.
Lobbin Report, yes, uh-huh.
I made the decision to present that, yeah.
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Non ::y questipn--
2 A.
I think I nnderstand the question.
On a con-3 tinuing basis, were.we still--was I involved in feeding or 4
providing stuff to the Intervenor based on that.
The i
5 answer is yes.
6 Q
Okay.
7
. Well, with that in mind, why did you choose 8
not, as I'believe your response is, why did you choose not to revisit this matter when you assumed this responsibility 10 over OA?
11 A. f '
There were several reasons.
one, the 1
12 decision was not a Quality Assurance decision.
I was 13
,.9 resp 9nsible through my chain of cr= mand for Quality Assurance.
3
'E 7' 14 but this was not a Quality Assurance decision.
This was ait 15 Licensing decision, and I had no responsibility, nor did 16 anyone in my chain, my immediate boss, and so forth, have 17 any responsibility for Licensing.
'8 So, therefore, I felt it was made by a 18 corporate officer senior to me, not in my chain, and there 20 had been a lot of decisions made over the years from the 21 time we started building Comanche Peak until I took over 22 Quality Assurance the first of August 1980, which I didn't 23 revisit.
And I just didn't feel like it was my responsibility 24 to revisit that decision, based on the fact it wasn't in
/25 my chain of command, and it wasn't under my auspices.
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.jokay.
I understand what you're saying about!
2 chain of command, but it's my understanding that the way t' ^
3 the way the Utility--the form that the Utility used to
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respond to the Intervenor's request and to the NRC's s#
various requests over the years', was to have Licensing lr a
p' resent whatever was needed to the various divisions within j
7 the Utility.and require those divisions to make a response, -
8 thereby making the Licensing division or section just merely e
a conduit for that information.
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That's true.
11
.** S So in this instance, it's my understanding, 12 also, that the QA Department--and this is before you
/
13 sumed responsibility over QA, I understand that--that the:.
14 QA Department received thig request and did make some kind 15 of response to a licensing representative.
16 And with that in mind, did you feel that it-17 was--you were not obligated at the time you assume QA to is go back and revisit, or review what had been presented is before under this?
20 MR. WooLDRIDGE:
Before you answer that, 21 he's made an awful lot of assumptions about what he under-22 stands the record to be to this date.
23 MR. GRIFFIN:
Right.
24 MR. WOOLDRIDGE:
And by your answer, you 25 clarify what you understand those assumptions as being I
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,I correct or not, or whether you know about them or not.
2
,3' THE WITNESS:
Raybe we. need to ' read the r
A-3 qu'e'stion back so I'll know what the assumptions are.
4 MR. GRIFFIN:
If I have misstated something, 5
would you say "youtre wrong on this point"?
's '
s THE WITNESS:
Well, awhile ag'o you said 7
"I assume". and then "I believ.e" and I believe you're con-a fusing the issue a little.
8 MR. GRIFFIN:
Well, I can probably restate 10 my, question arid break it up into segments and--
lr 11 I
'f THE WITNESS:
Okay, that would be easier.
12 MR. yo0LDRIDGE:
You made, just for my' r
13 br)14 purpo p*'s, you made the point that you thought that all
. Licensing.did was act as'a conduit and I don't believe v
15 that's what's reflected.
16 MR.' GRIFFINS, I'm sure their activities are 17 greater than that.
But as it relates to this particular is request by the Intervenor, see, I've interviewed other l
18 people before you and it's been explained to me that the L1 censing Department did not do the research to " respond 20 21 tn thiF request themselves.
22 In fact, what they did, t; hey notified various 23 division heads who I assume, in turn (this is another 24 assumption on my parth had their subordinates collect or i
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1 14 So for.the purposes of QA, it's my under-2 standing at this time that the Licensing people were not
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really the responsible party, as relates to the CA, but the
.s QA Departmen't was responsible for the response.
4 5
- M.
WOOLDRIDGE:
Why don't you answer that o
s question ad to whether you know that to be true or not.
7 THE WITNESS:
At that period of time I'm 8'
not sure if that's true or not.
9 BY MR. GRIFFIN:
10
,O' Okay, would it have been true at the time that.Mouassumed--
11 t
12 A
No.
You're asking me about the time I y
g,5sumed, I thought.
13 At that particular time I do not know ~
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14 if that was a fact or not.
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15 O
There were subsequent responses to Item 10 16 of the Intervenor's 1980 request while you were over QA7 17 A
Yes.
18 0
Did Licensing make these responses?
19 A
No.
We gathered the documents and presented 20 them to Licensing.
21 0
That's what I'm trying to say.
22 A
You asked me about the July period there, 23 when this stuff was all put together.
This decision was 24 made prior to me taking over.
25 4
I understand that.
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A And.1ubmaquent to that, we gathered up the 2
Quality Assurane.e doct:ma.ts, and presented them to Licensing A
3 But I can't tertify what happened prior to 1 August of '80.
4 G
When you took'over on August 1, did you 5
have occasion +to review any past decisions, or any past
' responses to the'Intervenor's request?
6.
7 A
No.
s O
As part of your duties?
9
'A No.
10 g
so you just went forward from there rather than' backward.
11
'f 12 A
That's right.
1 p/.
13 B-In 1978, did you have any input to the b
14
- Utility's internal response to the MAC Report?
15 L
No.
16 G
In 1980, after you assumed supervision over 17 OA, did you ever see the internal response?
Is
'A In 19807 19 0
Um-hmm.
20 A
No.
21 4
In other words, you didn't see the MAC Report in 1980, and you also did not see TUGCO's, or the internal 22 23 TUGCO response--
24 A.
Best of my knowledge I never saw either one
.2[
25 of them.
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In your discuccicn0--
I know I'o jumping
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2 around here.
But in your discussions with--this one 8
3 Tiscussion, anyw.ay, with Mr. Cha'pman that you had some 4
recollection of, did ha convey to you the contents or the 5
findings of the p C Review?
s A.
Idon'trecailwhetherhedidornot.
I 7
remember discussing it, but I don't remember whether he l
s told me the specifics or not.
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Mr. Clements, as I've gene through this to investigation I've talked to cuite a few people now, and ii you may be aware that some of your subordinates that are f
12 high up in th,e chain on the Nuclear side had what I think 1
gastrongopinionaboutthefactthatthisshouldhave 13 14 been a producible item.
15 And this is a characterization that I'm to putting in at this' points it appears, based on their testi-17 mony, that there was more than a few opportunities for 1
ts upper management, you, Mr. Fikar, others,,to have possibly is he.en exposed to these people's opinions that this was 20 producible.
21 Did any of these individuals, like Chapman or Tolson, ever convey to you t$at they tho'ght that you u
22 23 should reconsider this decision made earliar before you 24 assumed control?
Ferre you ever warned?
25 A.
Warned?
No.
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.S Did th y eycr express this o^ pinion to you 2
after you took control?
3 A
As I've testified, I've heard--I do r.ecall Chapman, and just in general conver,sation, saying, "You 4
know, I think we made a mistake" blah, blah, blah, but 5
e.-
s ',. warning,.bt'salittlestrong.
No, he did not warn me.
7 S
But whatever Mr.. Chapman conveyed to you, it didn't cause you to go back and look at the poport or a
think that you should, or consider that this maybe was, e
10 in faet/ producible?
11
,, ' A No.
It did not.
Based on the reasons I'd j'
12 already given you a'while ago.
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O In your affidavit of August the 8th, you 13 qC.S.
14 say that it was your understanding that a decision had
~
already been made by TUGCC management for the MAC Report 15 is was not within.the scope of the Intervenor's request for 17 information.
18 How did this information come to you?
Is A
Would you read that again, please?
20 0
I'll read the sentence exactly as it appears 21 in your statement.
22 A
Okay.
23 0
"It was my understanding that the decision had already been made by TUGCO management that the' MAC 24 Report was not within the scope of CASE's request for 25 i
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information."
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A Um-hmm.
N 3
g How did you come by that information?-
How did you come by this understanding that a decision had been 8
made?
s.
L Best of my recollection it was a discussion I
with Chasman.
s Did you ever have any discussions with Fikar 8
or Marshall in Licensing?
'O No, I didn't have any with Fikar, and I
' don %' ecall any with Marshall.
1 12 3
Did you know at the time who had made this hecisionthatthiswasnot,producib'le?
18
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14 A
Mo.
I can make an assumption at that time, but I didn't know specifically who had made the decision.
16 0
If I understand correctly, you're saying you relied on this understanding, or this information, but is you don't know who made the decision?
A I.ike I say, I assumed who had made the 20 decision, but I didn't know for sure who had--
21 Who had you assumed had made it?
22 A
I assumed it was Lou Fikar.
23 0
And you--
24 A
Licensing reported to Lou, and I've been 25 told it had been made by management of Licensing, or in
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[ general terms like that,. and I presumed tha.t Iou had Jaade
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He'd been the one in position to do that. -
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3 But I didn't Xhow for sure.
I [idn't hear Lou make the 4
decision, or Lou noyer discussed it with me.
8
's.I'm your statement yo.u also recall being B
s told that the MAC Report was an informal review' and was 7
used.as a management tool and, therefore, was not subject s
to discovery.
Who conveyed this information to you?
8 A
David Chapman.
18
,d Did Chapnan ever tell you about some of the s t' cr,itik:a1 parts' of the MAC Report as it related to, like, 11 f
12 implementation of QA or adherence to Appendix B7 13
,],/
A I don't recall; I'm trying to think, but s.,...
$2,n 14 I don'tirecall any specific time of what he. told me was 18 in the contents.
I have just a general vague idea that
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18 -
it was a review of the project for senior management.
17 Rut any specific items in it, best of my te recollection, I don't remember those.
Is B
I think I already asked you earlier in this 20 interview about whether or not you knew Jackson or Norris 21 with MAC.
Could you tell me'how you got to know these 22 people, what you were doing?
23 A.
Jackson--John Jackson, isn't it?
24 0
Um-hmm.
gj 25 A,
..had come by a couple of times within recent t
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years to 'see if he could sell MAC services to the ecumpany.
2 And Jack Norris, the name 4t.ri.kes--he wouldn't be the one s
3 that works now for the paint company, would he?
4 4
No, he's still--
s
,.MR. WOOLDRIDGE:
That's not the same.
s.
TEE WITNESS:
Not the same Jack Norris?
7 MR. GRIFFI.N No he still works for MAC.
8 A
Best of my knowledge, then, I may have met s
him, but I don't know him.
10 BY MR. GhIFFIN:
11
- f*O When these MAC tapresentatives, Jackson at
.c 12 least, since.you seem to recall him, when they recontacted 13 u, it was for more business, they were trying to get
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14' other contracts?
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l 1s A;
Yes.
More cosasulting business with us.
I Is a
Did you ever hire them for any--or were 1
l, 17 they ever hired?
Is A
No.
Is 0
Do you know why?
20 A
well, one reason--
You mean why I didn't 21 hire them, or why anybcdy else didn't hire them?
i t
22 g
Why anybody else didn't.
23 A
No, I de not know why anyone else--
24 g
Okay, do you know why you didn't hire them?
25 A
At one ti2ne John Jackson had m4de an offhand 1
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. comment to our president about our record management system, t
2 and it took me three months of working to prove that it was
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3 a good record management system, and come to find out that 4
this was just an offhand remark by Mr. Jackson in front of 5
Mr. Britton. d e really meant that he didn't like automated S.
record management systems, but he left the impression that 7
we had,--that we had a bad one.
8
.So I wasn't interested -in doing business with s
a guy that would cause me that kind of problems just by an 10 offhand.' comment.
~
11 f' S Did you have any other input from any other 7
12 Tawas Utilities employees regarding the validity of, say, p
13 pefindingsorthefindingsofthat1978reportthat f, t }
!s 14 influenced you not to give MAc more business?
15 A ',
No.
That had nothing to do with it at all.
16 0
The reason I asked is because I had taped 17 a conversation where other members of the Utility had dis-18 agreed with some of MAC's findings and I thought this might 18 have been factored in--
20 4..
A No, since I didn't know what the findings 21 were I couldn't come to that conclusion.
22 O
At the time that you assumed a:Jpervision 23 over QA, were you responsible for seeing that the Intervenor'n 24' requests were filled as information was developed, in
,[
25 response to their original request?
I s.
a
m.
22 1
MR. WOOLDRIDGE:.Perbonally responsible?
2 MR. GRIFFIN; Yes.
?
e 3
f.
1To, that was a Licen ng function.
BY MR. GRIFFIN:
8 0
.so if they needed information from QA or 8 '.
from any other department under your--
7 A
They'd spread'it out and ahk.for'it.
8 g
So you weren't personally involved?
8 A
No.
10
. E' You indicated--we mentioned the Lobbin 11 Repor awhile ago.
Did you have to make a decision as to r
12 whether that would be, produced?
r.
13 f,/
A No.
Oh.
I misunderstood.
Did'I have to g'.?).
18
'A make a decision.
It was obvious to me that that would be 16 produced.
r te S
Were you in on the decision making that that was producible?
18 A
Sure.
Is g
2.m not that familiar with the system--
20 A
No, and I don't mean to be facetious.
What 21 I'm saying is that that Lobbin Report was chartered by me 22 for a purpose--
23 g
okay.
24 A..
--and I knew all about the Lobbin Report.
25 I was the guy who hired Fred Lobbin, based on recommendation.-
s 4
.... ~. _. _. _ _.,.,...,.......,
23 3
So'there was no doubt.in my mind that it 4
2 fit that category because I knew all about it and had been
[
3 involved in the wrap-up of it, and so forth, so it never entered my mind that that was not,prodiscible.
- knthelate1970s,particularly'77 9.
'78, 6
and '78, were you aware that the MAC, the Management Analysis Company, had performed reviews of the Brown & Root 8
QA progre.m?
9 A
No.
~
10
.,0 For Comanche Peak.
11 4
A No.
12 s
9 Did any of the Brown & Root representatives kvardiscussinanyway.withyouhavinginternalorthird-
'3
,:5
- t. a 14-party--not. internal, but third-party or independent reviews 15 of their implementation of the QA program?
'8 A
No.
Remember, Mr. Griffin, this is a time
'7 when I was working 11 to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> a day in Lignite operations, l'
so I really didn't spend that much time involved in Comsnche Peak until I sent full time in '80, so back in those years' 20 I.probably wasn't down there that often.
21 But, no, they did not.
22 G
When you assumed responsibility for QA in 23 1980, did you ever have occasion to submit an independent 24 or third-party audit of implementation of the OA program
' j 25 for Brown & Root or any of the subcontractors? as part of 1
m_
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thJ ICCponse to the Intaryenor's request?
- e. 24.
2 e
2 A
I don't remember--I don't know.
We did 3
audits.
The answer is 7 don' t know.
.s 4
I'm thying to make a distinction here between 0
5 third-party audits of the 'IUGCO prog' ram versus third-party 6,
audits of Brown & Root or Westinghouse or any....
l 7
A Anything like that would have been put 8
together by David Chapman and his folks, and I would not 1
l i
9 personally have overseen a collection of that, and so forth.
to It would have just gone on to Licensing as a routine matter Er 11
.,,a I'm asking, then, do you know if any were 12 refer' red to Licensing?
?
13 A
ll I do not know.
jT-14 Sorry I missed the question.
15 g
I'm afraid I'm a little wordy today.
16 Mr. Clements, did you choose not to revisit 17 the matter of the production of the MAC Report in 1980 i
\\'
n 18 '
response to the Intervenor's request because you knew that 4
_it was--that the findings were adverse to the best interests is 20 of the Utility?
21 A
I did not.
22 0
Do you know who, besides Mr. Fikar, was 23 responsible for formulating, or making the decision not 24 to produce the MAC Report as part of the--in response 25 to the Intervenor's request?
t
--w 25 1
As I do not,
,g 2
G Are you familiar with,Mr. Wooldridge's 1etter of June 12, 1985, which is to the Administrative d
Judges of the ASLB for Comanche Peak?
I'll let you take 5
a look at a ampy of it.
Have you seen this document
)
4
'before?
,,..?
In this, Mr. Wooldridge--
3 A
Yes, I've seen this.
~
S
.--writes the explanation of why the document 10 was not$ produced
- A I have seen it.
.,c 12 B
And you're familiar with the contents or My.
heexplanationofwhyitwasnotproduced?
13
'd A
Yes.
15 O.
Seyond what is contained in this document, is in this response, do you know of any other information as U
to,why the MAC Report was not produced in 1980 that would 18 shed light on this subject?
18 A
I do'not.
20 0
okay.
21 I want to read a short paragraph in here 22
'n which Mr. Wooldridge characterizes your testimony.
I 23 kant you to tell me if it's accurate.
24 "The in'terviews also indicated that '
a TUGCO
</
25 officer, Mr. Clements, was aware of the report in 1980, even g.
I i
og em.-A
..,e n. e m
.m
~~-
-. - _ _ _. _ _ ~
1 26 I
though he had not read, the report." Is this cbrrect?
2 A
That's correct.
3 h
g Mr. Clements assumed responsibility.for 4
QA shortly after Mr. Fikar made the decision that the 5
report should %'t be produced, was aware of the decision o
- r 6
not to produce the report, but did not revisit that decision.
7 Is that a true statement?
8 A
That's true.
For the reasons I've so 8
indicated earlier.
10
,d Mr. Clements, can you think of any other
- /
inf'cMnation that you possess or that you recall, or any 11 1
12 information that has coms into your possession, that aheds 1
gnyfurtherlightonwhythisdocumentwasnotproduced N.
13 in 19807 14
~
15 A
No, I can't.
Well, you said--
No, I don't.
to G
I'm asking you for--
17 A
No.
I understand.
Not to my knowledge.
is g
og,y, 18 So you think as far as your testimony is 20 concerned that the NRC and all parties have your testimony 21 on this subject and it's the truth as you know it to be?
22 A
That's correct.
23 O
Mr. Clements, have I threatened you in any 24 manner or offered you any rewards in returh for this T
25 s ta tement?
8 t-0 3
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27 1
g yo, t 2
O Have you given this statement freely and 3
voluntarily?
4 A
Yes.
5 g
,y, there anything further that you would 6
care to add to the record?
7 A
No.
8 S
Okay.
I appreciate your time.
8 MR. GRIFFIN:
.Off the record.
10 IWhereupon, at 2:15 p.m., the interview or 11
was concluded.]
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1 CERTIFICA"E CF CF?!CIX:, REPCP.TER
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,d' This is to ce=*E y that the attached ;==caef4 es bef= e the p
FEDERAL ENERGT REGULATORY COMMISSION in the matter of:
Name of Proceeding:
+-
s.
. INVESTIGATIVE INTERVIEW (CLOSED MTIPC)
NME OF WITIESS:
BILLY REY CLEMENTS Decket No.:
NQE
~
Place:
"""*m TEXAS-Fort WortIn Dah:
Augus't 19, 1985 r
wara. held.as-ein appea=s, and that this is the origicaIL.
_ gc.:
t=ance=ipt thereof'for the file of the Federal East =gy Regula'ary, a
- Asaien, and is a full cer=act t=ansc=iption:of.the e'
g=occedings.
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A.nW/u & '. J,' ~
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official Repe=ta=
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