ML20237L358
| ML20237L358 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/23/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237F760 | List:
|
| References | |
| NUDOCS 8708200189 | |
| Download: ML20237L358 (55) | |
Text
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. UN11ED STATES NUCLEAR REGULATORY COMMISSION
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. . . . . . . . . . . . _ . . _ . . . . . _ . _ . . . . . . _.....____..._......................................,......................__....., 1 l
IN THE MATTER OF: DOCKET NO:
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INVESTIGATIVE INTERVIEW l I
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l l LOCATION: ARLINGTON, TEXAS PAGES: 1 - 30 N
j DATE: WEDNESDAY, JULY 23, 1986
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I Aa-FEDERAL REPOrmmS, INC.
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' Washington, Attachment KK 0708200189 B70819 PDR MN - .- -
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ADOCK 05000445 .
l G PDR NATIONWIDE COVERACE i
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SWOERN STATEMENT l I
_o_r ,
JAMES GAGLIARDO July 23, 1986 t l' 4
NRC Region IV Headquarters Arlington., Texas 9:35 a.m., C.D.T. l <
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f TAKEN BY: George Mulley j j
REPORTED BY: R. Patrick Tate '
TATE REPORTING SERVICE, (713) 222-7177 ,
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1 JAMES GAGLIARDO 2 was called as a wi~tness and, having been duly cautioned and 3 sworn, was examined and testified as followw: .
4 EXAMINATION '!
5 By Mr. Mulley: l I
6 0 The time is 9:35 a.m., on July the 23rd, 1986.
7 We're at the Region IV office of the Nuclear Regulatory 8 Commission, in Arlington, Texas. Present is Mr. James-l i 9 Gagliardo who is a Region IV employee; myself, George 10 Mulley, I'm the Assistant Director for Investigations, ,
11 Office of Inspector and auditor, NRC; Mr. Steve Goldberg, 12 and he's a technical advisor to the Office of Inspector and r k
'- 13 Auditor, and the court reporter, Mr. Pat Tate. '
14 We're here today to discuss with Mr. Gagliardo, 15 information he has concerning the activities of the senior 16 resident inspector for construction at the Comanche Peak 17 Nuclear Power Plant. I 18 Before we begin, Mr. Gagliardo, could you give us 19 a brief rundown of your positions here at Region IV?
20 A Okay. Well, I came to Region IV actually when it 21 was still in Denver, in 1974, and was an inspector in the 22 office for a period of about four years, at which time I 23 was selected for performance appraisal branch and I worke.d
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24 for the performance appraisal branch for about two years. l l
25 I was still stationed here in the Dallas area but I was -I TATE REPORTING SERVICE, (713) 222-7177 k
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1 working for headquarters management on that assignment, and 2 involved quite a bit of travel back there.
3 Then I was selected as a section chief in the 4 operations branch, I forget the time frame, I think it was
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l 5 1980. And during that year, supervised the nuclear support
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i 6 section; at which time I was then selected as the director l 7 of the investigation and enforcement staff, a position that 8 I held for a year, was then selected as the division j i
9 director for reactor projects in January of '82 and held 10 that position for two years, and was then selected as the 1
11 director of the training center in Chatanooga.
12 My assignment was delayed there, though, because i
13 I was assigned as the deputy director for two task forces; )
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14 one that was we performed at the Waterford plant down in 15 New Orleans; and then that was followed by the comanche !
l 16 Peak TRT effort that began, I think, in July of '84.
17 I was a released from that special assignment in I
18 February of '85 and then reported to the training center L9 and was there until December of '85 when I returned to 20 Region IV, the position I now hold as the projset branch 21 chief.
22 0 Okay. During your various, in your various 23 positions at Region IV, have you ever worked closely with j 24 Shannon Phillips?
25 A Well, Shannon Phillips was in my division when I ~"
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- 1. was the division director, not for very long. It was 2 shortly after I became division director, I think he was l
3 selected for the section chief in the vendor branch. !
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l 4 I had some association with him prior to that as 5 the director of the investigation and enforcement staff, 6 because I was supervising the investigators and we were in 7 the process of investigating'the Quadrex issue down at 8 South Texas and'Shannon was the senior resident there and 9 very, very much involved in that. He had been the i 10 individual who had along with our investigators surfaced l 11 this Quadrex issue.
l i 12 I also worked with him on the Waterford task l 13 force. I was the deputy -- the deputy to the project ,
14 manager f'or that task force, and Shannon came to us on that 15 task force originally assigned as the deputy to the group 16 leader for the mechanical group. And so I worked with him I 17 during the course of that task force effort. l ;
l i 18 And then, of course, coming back to Region IV, he 19 really hasn't worked for me; the Comanche Peak Project has 20 been assigned to a special aroup that reports to Tom 21 Westerman.
22 Q Based upon your experiences with Shannon 23 Phillips, how would you evaluate his competence as a j 24 inspector?
25 A Well, I've never had any problem with his !
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1 concerns that, you know, we felt.that the audit program:was-2 sort.of like our l'nspection program,-it didn't necessarily 3 have to be a 100 percent coverage, that you're doing an l- 4 . audit and. inspecting or verifying'that the activities th'at i
5 you utilities are doing are generally in conformance with 6 their requirements. And if you feel comfortable with that _
l 7 sample, then there was no.need to expand it.
8 And I think that -- that's my recollection as the crux of the concern that they had.
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9 But( pnd 10 Harrison would be, would probably have more memory on that 11 issue. ,
l2' Q To the best of your recollection, was.shannon J
'. 13 correct in what.he was saying; maybe not -- maybe you
- 14. disagreed with the results, but was he correct in what he 15 was saying?
16 A Yeah, he was correct in that the utility had not 17 audited all of thoso procedures. And I don't think that 18 there was ever any question about the fact that the 19 findings that he had were not. correct. It's the concern 20 was how do we handle those findings, you know;*is it a, you '
21 know, a problem from a reguistory point of view that they i j j 22 had not audited all o'f those procedures.
23 Q How vigorous was his pursuit of this finding; did ]
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you have problems with him trying to go around you or did 'l
. l 25 he accept, you-know, your evaluation?
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i competence as an inspector. I always thought he was very l
2 throrough as an 16spector.
3 We did have some difficulty in the Waterford task i
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4 force with regard to his report writing. And I think you !
l l 5 may want to talk to ,and Jay Harrison who was
! 6 the team leader, about that concern. {
l - 1 7 I was involved in reviewing some of his draft l
inputs, and had some difficulty with them and bounced it t
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9 back to those individuals and they were the ones who l
10 principally worked with him as far as resolving those 11 issues.
12 0 What sort of difficulties are we talking about?
- 1) What are the nature of the problems?'
14 A Well, my recollection of the prob 1'm, e and it's a '
15 little foggy, but if I recall, that he was, he was con:Orn:d that in the audit program that the utility had at 15 17 Waterford, that they had not audited activities under all 18 of the procedures that had been signed for, performing work I 19 activities at the site. ,
20 Their audit program had covered selected i
21 procedures and had addressed the licensee's compliance or !
22 conformance to those procedures. But there were quite a j 23 number of them that they had not looked at, and Shannon had
( 24 a concern with that.
25 AndmyselfandMr,[ Sand Harrison had ~
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1 A I didn't have problems personally. But I know 2 Mr. Harrison had some problems. Jay Harrison was the group i
i 3 leader for the mechanical group. And he had some !
4 difficulty with Mr. Phillips early on in the task force.
5 And as a result, Shannon was moved out from that position .
i 6 and was made an individual contributor and we brought 7 another person in to work as the deputy.
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And I don't know whether that was more based on a l personality conflict between those two individuals, or 9
10 something that, you know, that was really that he wasn't 11 performing. I think it's more the former than the latter.
12
- But there was quite a' bit of friction there and I
i 13 we chose to fix that by sliding him out of thatl position.
14 And he then performed as an individual contributor like the ;
15 other people that were on the team of looking at the issues j 16 and the allegations and inspecting them and writing his 17 report input.
18 Q Then to the best of your knowledge, did the i 19 concern on this one issue, did he accept your final 20 disposition? -
21 A Yeah, as far as I know, he had no problem, 22 certainly didn't voice any to me. I know that ' D 23 }hadmanysessionswithhimindiscussingthat 24 report, and I think Bill Crossman to some extent, too, 25 ]wastheprincipaloneworkingwith although I believe( a l
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1 Shannon on trying to resolve that SSER input that he wrote. l I
2 Q So apparently from what you're saying, there were 3 group discussions where management tried to explain --
4 A Yes.
5 0 -- to him --
6 A And to my knowledge, he came away satisfied with i 7 what we had done and the final write up of that that went 8 to into the SSER. If he had a concern, he didn't voice it 9 to me nor did it reach me from any of the managers that we 10 had working on that.
11 Q Okay. Do you have any knowledge or have you had 12 any contact with Shannon Phillips in regards to the 13 Comanche Peak Project?
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l 14 A The only contact that I had was in the January 15 time frame, where I went down there to look at the project 1
16 and bring myself up to speed on it. And that was two 17 followed. One that I had been told that I probably would i
18 be taking over that project, at least from the point of 19 view of supervising the routine inspection effort that's 20 being performed by the resident inspectors.
l 21 And the other thing is that early on when I came j i
22 into the job, Eric had indicated, Eric Johnson, that he {
23 wanted me and my trips to the sites to have a lot of 24 interface with the region, regional resident inspector and 25 to make sure that they were up to speed on that plant and ~
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i 1 knew the plant and knew the issues at the plant.
2 And he did indicate that he had some concern that 3 he wasn't sure that Shannon was getting out into the field I 4 enough. And so I went down there and spent a day there the 5 first half of that day I had Dennis Kelley who was the 6 senior resident for operations show me around Unit 1. And l
7 then that afternoon, I had Shannon show me around Unit 2.
8 Q How did the tour gp?
9 A I was disappointed. We were, we went out to the -
10 plant. I wanted to see the auxiliary building where t
l 11 they -- they have the major ECCS type pieces of equipment, 12 let's not call it the auxiliary building there, I think 13 it's called the safeguards building at Comanche Peak, and i
14 quite frankly he got me lost in there.
l 15 And I was really concerned about that, that a i 16 senior resident inspector didn't know his way around that 17 area where there was ongoing work of a very safety related 1
18 nature; in fact he didn't know what some of the components 19 were.
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I pointed out to him that, you know,' corrected j
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21 him on some of the components that he wasn't sure of. And j l 22 I was concerned about that, felt that a senior resident l 23 inspector, be it. construction or operations, needs to be
.. 24 into the plants enough such that he knows his way around.
25 And I'have done this with all of the trips that -
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1 I've made to the sites, it puts a little heat on the 1 2 residents and they' get a little concerned about it, but l 3 with one other exception, I've found that the residents are l f
4 pretty knowledgeable of their facilities and the current '
5 issues and the current problems there..
6 Q How much notice did Shannon have of this visit?
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7 A I don't think that he had any more than just a l l 8 day or two notice of knowing that I was coming arou'nd and 9 was going to be wanting to tour the plant with him.
10 Q The type of things that you just mentioned, the 1
11 fact that he didn't know his way around the aux building l 12 and he didn't know some of the components, would the lack i
i l 13 of notice have any impact on that at all, as far as you're i I
14 concerned? l 15 A I don't know. I don't think so. You know, if 16 he'd have known a couple of weeks in advance that I was 17 going to do that, whether he'd have gotten out into the f l 18 plant and become more familiar with the layout of the plant 19 and where the rooms were and all that, it may have helped a :
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20 little bit but I doubt it, you know. It really concerned 21 me when we were trying to find our way out and he had to 22 ask a utility employee how do we get up to the next level.
23 And that really bothered me.
24 Q So I guess the point you're making is that he 25 should have known this from performing his job as a -- ~'
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1 11-1- A I would like to see my. inspectors be to the point ,
. I 2~ where they know where they're.at and to know how to get
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3 from one place to another, because in my tours I'll do-4 this, you know,.I'll ask them that I want to see the high. ;
5 pressure injection pumps and then the next thing I want, 6 might want to see, is the diesel' generator or something 7 like that, and I expect them to be able to take me from one i 8 to the other, and/or to take me to areas where the utility 9 has had recent problems. And it just' appeared to me that.
10 he hadn't been down.there as much as a senior resident 11 should be down there.
12 Q Was this the first plant tour that you conducted?
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.13 A I don't remember. I had been -- this was in 14 January time frame. I had a trip to River Bend sometime in
,i 15 the January. time frame but I don't remember if that was 16 before or after.
17- There had been another trip that I had to, I ,
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l l 18 can't even remember the plant, oh, Wolf Creek Plant, but i
19 that was for an emergency drill and we didn't get a chance 20 to go on a tour then. I had a tour later on, I went back 21 up there and had the two residents there gave me a. tour.
22 It may have been the first one, the first or the second.
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23 one. i
, 24 Q Have you conducted similar tours of other plants 25 in Region IV? ~I l
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1 A Yes, there's only one plant that I haven't been
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2 to. I was schedul'ed to go to Fort St. Vrain in June and 3 because of our travel crunch, had to cancel that. But I'm !
J 4 going up there in August; we've got a SALP Board meeting 1
5 and we've also got another emergency drill and I'm just J 6 going to stay a day after that and get a tour of the 7 plants.
l 8 But all the other plants I've been to. Now I've )
9 had the residents tour me around. And where there's two 1
10 ~ residents, I have both of them, Wolf Creek I had the two 11 residents take me around, one at a time.
I 12 when I went to South Texas, I had all three of 13 the residents take me around individually, each different ,
i l 14 area, because I'm -- I'm very interested that they get out 15 there and I want to keep the heat on them to get out in the j ]
16 plant and know what. And if that's a concern that I feel 17 that they're not getting out there, then I'll do something I
18 about it.
19 We did have that with one ott.er resident and I l
20 spoke to his section chief about it, that he needs to gem 21 out there more frequently, because he wasn't as familiar 22 with that plant as I would like to see my senior residents. j 23 0 That was the next question I was going ask, then, i
24 you, except for this one other resident, the other !
25 ' residents knew their way around the plants to your -
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13 1 satisfaction?
2 A Yes, they did.
3 0 Okay. While conducting the plant tour with 4 Shannon Phillips, did you ask him questions concerning 5 percent of completion of the plant?
6 A Well, I didn't do that at the time of the tour.
7 We did that afterwards. I was trying to pick his mind of 8 how the project is going and asking him about the percent 9 completion; I .was interested in what kind of weld reject 10 rate that they were having; I think I asked him about the 11 status of cable pulling, too, because they were, they were 12 really not very well along on cable pulling in Unit 2 and I 13 was interested in that. I thought that they probably 14 should have been a little further along than that. )
15 Q How was his response to your questions?
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l 16 A He didn't really know what the percentage 17 completion of the project was, and he got back to me later l
18 on that. Also on the weld reject rate, he did give me an 19 answer based en what he thought it was, which turned out to !
20 be pretty close to what was found.
21 Q Is this information that you feel the resident f
22 should have, you know, readily available to answer j l 23 questions like that?
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24 A I've asked other inspectors that. When I was 25 'down at Soutt Texas, I was interested in finding out from ~"
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i 14 1 them the things, or where the percentage completion was, I l
2 was concerned down there, too, that their cable pulling 3 down there is not where I think it should be. And we l 4 talked to the residents about that.
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l 5 And the weld reject rate is something that is of 6 interest to me in a construction plant. And I've asked f
7 residents that before, too, because in this phase and l
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- 8 critical phase when they're doing safety related welding, i 9 it's something that I'd like to keep the heat on ,the 10 utility to assure that we're geting a good product in 11 welding because it's one that bites them in the tail l
12 consistently.
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13 Comanche. Peak has that problem now, in that a lot l 14 of the rework that they've had to do on their hangers is
! 15 because of shoddy welding that went into that thing on the l l 16 front end. I'm not saying that that was our problem, that 17 we could have done anything about it, but maybe we could i
18 have if we were on top of it. And maybe we were. I don't 19 know.
20 But certainly if there's anything that we as an 21 agency can do to prove the quality of that weld, then I l
22 think we ought to because historically that's a problem in i
23 all construction sites.
( 24 Q Did Shannon have to refer to his drawings te --
25 A Yeah, that was a concern, too, that he had the c TATE REPORTING SERVICE, (713) 222-7177
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1 drawing that he took. And I guess that's not a problem if
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2 an inspector wanted to take the drawings along to show him j 3 how, but he needed to use the drawings to look up to find 1
4 the compartment or the room where given components were, 5 and also to try and find his way around. I 6 And even with the drawings, we wound up having to 7 ask a site employee how you get out of there and get up, I 8 wanted to go up-and then into the containment from there, 9 because we came into that safeguards building from the pipe 10 tunnel that they have going from the refueling water 11 storage tank.
12 I was a little disappointed, too, that there 13 was -- in that pipe tunnel, you have stainless steel piping i 14 which you would expect to have on the lines there, but 15 there was carbon steel piping in there. And I asked him j 16 what's the carbon steel piping for and he didn't know.
17 That concerned me a little bit.
18 0 So the plant tour that was conducted in January, i
19 is that the extent of your association with Shannon --
1 20 A That's the extent of my association with Shannon, l 21 yeah. He gave me some feedback later on in answer to those 22 questions. But I have haven't had any feedback since then, }
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23 because the decision to give the Comanche Peak project to j l
24 me has been deferred, and we're talking about it again, or 25 'ric's E talking about it again. ~
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1 I don't know if that's going' to take place or 2 not. But he had indicated that that's what they're looking j 3 at right now, the prospect of having the residents come 4 over to my side of the house and then the project, the 1
5 special project group will still be working for either Eric 6 or Tom.
7 0 So you have no basis, then, to evaluate Shannon's l 8 performance at Comanche Peak currently?
9 A No, the only thing I have that has happened since 10 then regarding this issue was Eric had asked Bill Seidle l
l 11 and myself and Tom to look at some of the reports that had i
l 12 been submitted by Shannon for which there had been some i l
13 changes made. And just to see if, you know, if we agreed 1
14 with the position that had been taken by himself and Tom,
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15 of changing those.
16 0 (By Mr. Goldberg) Do you have any specifics you 17 can think of?
i l 18 A Well, I know of the one report that we looked at ;
19 in leching at the draft and that was the one on 20 documentation. I don't remember what the number was. But l
21 I was disappointed in the fact that in his draft, he had 22 written up things as violations against things like ;
23 Criteria 17 of Appendix B which I would seriously question 24 as them fitting that criteria.
25 You might be able to say that they were a ~4 TATE REPORTING SERVICE, (713) 222-7177
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-1 1 deviation from there commitment to the ANSI 45.2.9, but'I 2 .thinklit would be really a slender' thread to try and tie.it.
3 to Criteria 17. And I don't'think you can.. And that 4 concerned me, because you know, quite honestly,.I would 5, have expected more of a senior resident with his kind of j 6- background.
7 Q (By Mr. Mulley) 'When you were asked to perform 8 this review of the reports, was there'any' guidance as to 9 which side of the issue you should take up or was this
.q 10 truly an. objective. review? I 1
11 A No, not really, I felt we were truly' objective, J
.l 12 the look,that we took at it, and I felt the way that'Eric 13 ap'proached it, talking about these things and wanting to 14 find cut, " Hey, where we right in changing this."
a 15' Q okay.
16 A And I felt in most of the changes that, yeah, I I 17 would have done the same thing. I don't know how it was i
18 handled as far as communicating to Shannen, the changes; 1
19 but as far as making the chango:, I wculd have made the ;
20 changes, too. (
1 21 Q Now, based on this review -- you had no l
22 communication with Shannon yourself; is-that correct?-
l 23 A No, I did not.
( 24- 0 Based on what you know of the Comanche Peak 2E project, do you believe that the region is doing.an -
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1 13 1 objective job in regulating Comanche Peak?
2 A Oh, thats a hard question to say because I'm not 3 really actively involved in it now. You know, I've 4 personally concerned about Comanche Peak because, you know, 5 a lot of the problems that occurred at Comanche Peak 6 occurred at the time that was, so to speak, under my watch, 7 when Iwas a division director. And I feel, you know, I J 1
8 feel really-disappointed that we didn't catch some of those 3 i
l 9 things at that time. And I don't know why we didn't. But 10 they're there, b
. i 11 But I think that since those kind of things have 12 surfaced, and we surfaced a lot of them in the TRT effort, l
13 and that was a source of, or sort of e' embarrassment to me, 14 because, you know, I was now made -- personally made aware l
15 of problems that I probably should have been aware of as a i 16 division director and hadn't been made aware of. And -- ]
17 but I think as a result of that TRT effort, the working 18 closely then with the efforts that were going on by the 19 region, and I felt it was a pretty objective effort.
I 20 And some of the things that I have just been j 21 informed of as a result of the communications that I've had 22 with them which hasn't been that good, I_think they're 23 doing a pretty good job.
24 I know when I was down there in January, I guess, 25 I went and visited with the task force for a few minutes -c TATE REPOSTING SERVICE, (713) 222-7177
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i 19 1 1 and they were talking to me about seme of the problems that )
2 they were having with cable splices and generally in the ;
3 electrical cable area, the hangers, I can't think'of the 3
4 name of those supports now. But I felt that that'was some a
A 5 excellent findings that they were doing some good work 6 there. -
7 0 Comanche: Peak is getting close or, you know, 8 they're approaching the date when a decisior$~is going to be 9 made on licensing, they're getting hit hard by the ;
1 10 intervenor groups; do you feel from what you know that the i
11 region is leaning towards protecting the licensee on the !
l 12 site against the criticisms; has anything happened to make i
13 you think that way or -- '
14 A I felt at the time that I was on -- that I was on i
15 the TRT, that that we had in the,9egion IV maybe nad
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16 minimi::ed some of the concernsth7 at the allegers were 17 bringing forward. And we did (that in the Waterford ;
i 18 project, too. I think we had'a tendency of mininiae what 19 the allegers ucre bringing ft.rward. l And it turned out that ,-
20 most of the allegers, the cancerns that were being brought 21 fo?:th, had factual basis to them.
l l 22 And that's one of the things that was a real I L !
23 concern to me, was that, you know, here, I had been l ( 24 involved in this project before, and I don't think we had 25 given those allegers enough credit. t l TATE REPORTING SERVICE, (713) 222-7177 ,
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20 1 Admittedly some of them had an axe to grind with 2 the way that, mayb'e that the utility management had treated 1
3 them and there might have been a little sour grapes there, 4 but by and large, the concerns that they were voicing were )
l 5 valid concerns. J
? l 6 MR. MULLEY: Could we go off record for a minute, )
7 please.
8 (Discussion off the record.) ]
9 0 (By Mr. Goldberg) Concerning the inspection
. 10 procedures and modules that are involved in the reviewing l
l I i 11 activity at Comanche Peak, particularly the construction j l )
12 activity, Jim, what I'd be interested in knowing is your l )
13 knowledge of what was covered and particularly in the QA l 14 area, the depth of the coverage, and the frequency of j 15 coverage of these modules.
16 A Okay. Well, in the, as a division director, I 17 was not aware that there were any concerns there with the l l
18 program, that we were not on track in the program.
19 Certainly I was led to believe that we were okay, i
20 When we got on the TRT effort and we had people !
21 looking at the program; there was a group of people from ;
22 headquarters came down to look at the status of the ; ,
23 program, we found that basically the 212 program -- the i 24 2512 program was was in pretty good shape. Most.of the i 25 ' modules had been completed; there was a pretty good -<
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1 tracking system on that. ' #
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2 lithe concern that that group had was with regard
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3 to the tgacking t of the pre;.am was over'ine.the 1513 and '
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t 4 2514 side of the house, where we found to our dismay that 1
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5 there was not a good tracking system on thEt; in' fact what '
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t 6 had\to:be 6cne was to go through individua,b inspection l s
7 reports and idrret out f rom the J,66 form the mo'dules' tha t j l !
8 had been ' completed. t .
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9 Now, later on iri that effort, the QA people bdgan' ]
10 to look pt the QA program. And I was made aware that the l
11 QA modules had not been completed, that they had -- the 12 individual modules had only -- therm had only been 50, 60 s s' ,
I l 13 percent of th6t effort completeo'on[Nsome of those modules x
l
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14 and they had hein closed out on that'basih. I I.think that 15 was true df, if my recollection serves me,jin the Waterford .
16 tash force, a finding that;we had down there,3 also.
17 Q ,
Just a follow dp question would be, if nore work i
18 were done earlier by tue inspectors, would that have e 19 pcLaibly made a difference as A[e know the quality assurance' 20 being a problem at Comanche Peak, would that have been made 21 a difference in terms of institet.ing earlier and more 22 correctivo action at Comarch6/ Peak? \
i 23 A That's a;hard one to say, as to, you know, that's i 24 presuming that our i spection, inspection quality in the 25 plant. And so it's hard to say that thatinould happen. ~I l
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Although certainly the possibility exists that had we been 2 able to do more effort there, we may have surfaced some of
[ 3 these problems and have had a handle on them earlier in the
! 4 game than what we did -- you know, essentially that the TRT t
5 was the one that ferreted out many of those problems.
- 6 0 (By Mr. Mulley) Let me ask you one question 7 concerning your knowledge of the 766 system --
8 A Yes.
l 3 9 0 -- here at the region. How accurate do you l 10 believe that system is? .
11 A Well, I know back many years ago, we had some 12 real concerns about the accuracy of the 766, because at 13 that time we felt the breakdown was because the 766 forms 14 were going into headquarters and the people were inputting 15 into the system there. '
16 We took that over, oh, about the time I guess 17 that I was a section chief and we were inputting the data l
18
. ourselves, our ladies upstairs were doing that. To my 19 knowledge, I have not been cut in that there had been any 20 problems with the fact that what we were submit' ting on the 21 766 was not getting into the system. I honestly can't l 22 think of any examples of where we found holes in it like we I 23 had before that time period.
24 Now, I 1
know in reviewing inspection reports, one 25 of the things that I spot checked periodically was that the ~#
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1 766 that was sent with the report and did it accurately i
2 reflect what was going on, and had some problems there that 3 I had to bounce back to the inspectors or the section 4 chief.
I 5 But in my mind, it doesn't stick out as something 6 that was a chronic type problem that would indicate that j i
i 7 there's a real flaw in the accuracy of that data.
8 0 one of the problems that we've come across in 1
9 this review we're doing now is that, when you go to some of 10 the 766 forms, the form will document an inspection 11 procedure, document ti'.e spent on the procedure, a percent 12- complete, but when you go back to the report, itself, I
I 13 there's not a word mentioned about any activity done on 14 that procedure. Is this correct?
1 15 A That really should not be correct. If the !
16 individual is doing some inspection effort to close out a 17 procedure, then that should be documented. And that's an i
18 error if you're finding that. That should not be the case.
19 Q One mere quection I'd like to ask. You were 20 reviewing these 766 forms. Was that a requirement or were 21 you doing that on your own?
g 22 A No, I was just doing that on my own. Back when I ;
23 first took over as the division director the policy in 1 24 those days was that the report was aigned out by the branch 25 chief, but the division director concurred in it before it - d TATE REPORTING SERVICE, (713) 222-7177 l _ _ _ _ _ _
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1 went out and one of the things that I would check in the i I l '2 course of my review, and I didn't do that a hundred percent I
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3 of them, maybe 50 percent of them, so I would also check ,
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4 the 766 form.
5 0 when you talk about those days, what, again, what 6 period are we talking about? i 7 A Let's see, I was selected as the division 1 8 director in January of '82. So '82 to shortly thereafter, 9 about a year later, we went into a program where the 10 reports were issued out under the -- still under the branch 11 chief's signature. But it did not have to have my 12 cor.currence before it went out. And I got a copy of them l
l 13 after the fact and could review them then.
14 And the extent of my review then was much less l
l 15 then, because -- well, the reason we had to do that was I i 16 was just tied up with so many other things that I was 17 becoming a bottle neck in getting the reports out. And so i
18 we just had to eliminate that. And so I was much less 19 involved in them. That wculd have been scmewhere around 20 the early '83 time frame.
- 21 Q (By Mr. Goldberg) Do you think it's a good
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22 practice for supervisors to do that kind of a spot check, j 23 where if you have the time, to make that kind of 1
24 correlation? ^
25 A It certainly is. It certainly is. And I, and
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I 25- l 1 that's something that our section chiefs are supposed to be
'2 doing now. And I'quite frankly have not done much of that 3 .now. I sign out the reports'but I have not done probably.
i 4 10 percent at most check of.the 766 to see that it's .
5 accurate. And maybe if you're finding a problem, . don't-6 know what time period you're finding the problem in, if 7 that's a. problem maybe I need to.be looking at that more 8 closely.
1 Would this'be misleading then, 9 0 (By Mr. Mulley) 10 if, for example, some of these procedures you go pull the 11 information off the computer and it does show that'certain 12 procedures are a hundred pere'ent complete?
13 A Yes.
14 0 And so as a manager,. would this make a difference 15 to you in your reviewing the status, I mean would you make l 16 decisions based on this computer output?
17 A Yeah, I would hope that that computer output 18 accurately reflects what we are doing from an inspection 19 point of view. So that the inspection effort is done, .then 20 the report should document clearly.what is done in 21 inspection and the 766, which is tracking system should 22 accurately reflect what is done in the inspection and }
23 what's in the report.
( 24 Q (By Mr. Goldberg) What the issue, Jim,.is --
25 part of the issue is this. And let's see if I can try to t TATE REPORTING SERVICE, (713) 222-7177
26 1 articulate it as best I can.
2 When an inspector goes out and reviews something, 3 he would write up as a finding things that he found that he 4 didn't feel was completely correct or there may be a 5 violation or an unresolved item; in other words, he was 6 looking for the negative aspects of something; he didn't 7 necessarily go down his procedure and write down what he 8 looked for, looked at; so if you pull the inspection 9 report, one of two things could happen. One, you don't get 10 a feeling reading the inspection report of what he really 11 accomplished, except you did see a finding. Two, you might 12 not see any write up there because he didn't see anything 13 of a problem so you're not clear whether he even 14 accomplished that area, itself. 1
! 15 And that's phrt of the thing that we're dealing 16 with, because it's not clear when I look at an inspection 17 report, or whether the fact that area was covered at all, l l
18 although it shows up as being covered in the 766 for that 19 period of time.
23 0 (By Mr. Mulley) There would not even be a 21 comment in the scope of the' report for that area.
22 A Yeah, and that's a concern and it quite frankly 23 is one of the concerns that I have now, you know, when I 24 first joined the Commission, our reports were very brief 25 'and very sketchy. ~'
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27 1 We then had'an era shortly thereafter where we 2 did go'into more d'etail in the reports, you know, the 3 inspector reviewed such and such an area, to verify in.they 4 essentially quoted the objective section of the module, and l
- 5. then you said "The inspector reviewed" -- and you'd. site 6 the data.that you. looked at, that'he looked at, you know, 7 maybe maintenance work requests for a period of such and 8 such through such and such, to verify that -- and you'd 9 paraphrase what the procedure required, and then you came -
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10 up with the' findings.
11 And certainly that made the reports wordy and 12 much longer in length, but it at least communicated to the i
5 13 utility and to everybody else who might be interected what l 14 you did.
15 There then was a shift in emphasis of getting the 16 reports much shorter and much briefer now. We're 17 essentially just saying, the inspector went'in to look at i
18 maintenance and here's what here's what he found.
19 And I really have a little concern with that and 20 I would hope that we could.get to -- into a mode where we i-l :
21 could, where we could get into a little more description of 22 the reports; I notice that some of my inspectors do do'that 23 and I 1.ike to see it. It takes me longer to read the i 24 reports, because I read all the reports before I sign them.
25 But it gives-me a little more comforting feeling when he 1 TATE REPORTING SERVICE, (713) 222-7,177
1 28 l l
l 1 spells out what specifically he looked at and what he was 2 looking for.
3 And I think it's important that we do that, to 4 communicate to the utility that what we were looking at,-
5 certainly they have our inspection modules and they can get 6 them from the PDR. But I think we owe it to them to i
l 7 explain what we're doing.
l 8 And to the extent that we're -- that w'e have a 9 lot of public looking over our. shoulder at what we're 10 doing, it helps there, too, although I don't think we 11 should necessarily write our reports for the general 12 public; we should at least write them such that the general
. 13 public can understand them.
.14 Q (By Mr. Goldberg) Let me get to, I think another 15 factor to consider here, Jim. Eventually, hopefully, this
- 16 plant will come up and you'll be writing the letter ready 17 for licenseability; I think they're called 93400 or 93700 1
18 letters.
19 A Yeah, 93700. ,
1 20 Q 93700. And you have to make some statements 21 about the readiness of the plant to get an OL and you go l 22 back and you look and see how much of the program has been i 23 completed and so you pull your computer printout.
24 And I asked this question to Eric on yesterday; 25 'n i other words, what kind of a documentation trail, what TATE REPORTING. SERVICE, (713).222-7177
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-1 kind of a basis are you going to have to support those 2 statements? And I think if you were able to have a nice 3 layout of your inspection coverage, and being abic to 4 support that with inspection reports, it makes the job a 5 lot easier.
6 A Yes. That certainly should be a basis that you, !
1 7 you know, one of the things that you factor in in making I
8 that judgment call that'you do on your, on the letter that 9 you have to submit.
10 It's just one of the things. There's a whole i
11 bevy of things on that and it's one of the things that I, i j
12 looking at our people on South Texas to get started at now.
I l 13 In fact, I've told them, " Hey, we're a. year away, but 14 that's not too soon to be starting getting all of these ,
- f 15 lined up such that you can keep them on track;" I don't !
16 want to get to the point of 30 days before decision is 17 made, and find out that we haven't done something or.we i
18 haven't adequately addressed it or we don't know the status 19 of such and such.
20 To whatever extent we can minimize gdtting into l
21 that bind, I want to do it. And that's what I'll do on j 22 comanche Peak, if we get, if I get assigned that, of i 23 getting a good road map planned out and we had done that on
( 24 Waterford.
25 When I was on -- assigned the Waterford task
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1 force, I had sort of a dual position, I was the deputy 2 project manager to'Denny Crutchfield who was running that 3 task force, plus I was also the Region IV representative, 4 responsible for coordinating all of the Region IV 5 activities, so I wore two hats. When I went to the 6
Comanche Peak, I just vore the task force hat.(
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7 was there wearing the Region IV coordination hat.
8 MR. MULLEY: Okay, that's all we have. !
9 (Statement recessed at 10:25 a.m., C.D.T.) l 10 11 12 13 14 j l 1 15 )
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I 31 1 THE STATE OF TEXAS:
1 2 COUNTY OF HARRIS. j 3
i 4 I, R. Patrick Tate, CSR and Notary Public in and {
5 for the State of Texas, certify that the facts as stated in l 1
6 the caption hereto are true; that the proceedings indicated l l 7 were had before me, and the same were thereafter reduced to 8 typewriting by me or under my direction.
9 I further certify that the above and foregoing f 10 transcript as set forth in typewriting is a full, true and
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11 correct transcript of the proceedings had at the time 12 indicated.
13 In testimony whereof, witness my hand, this 2'3rd 14 day of July, 1986.
15 l'
L 16 My ausiness address is:
1712 Esperson Buildings
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d/ d l&" i
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R. Patrick Tate, CSR #1730 l 17 Houston, Texas 77002 Notary Public in and for My current certification the State of Texas j 18 expires: 12-31-86 My Commission Expires: 10-27-89 19 1
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