ML20237L623

From kanterella
Jump to navigation Jump to search
Partially Deleted Transcript of Unnamed Region IV Official 860624 Investigative Interview Re Region IV Mgt of Plant. Pp 1-57
ML20237L623
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/24/1986
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237F760 List: ... further results
References
NUDOCS 8708200285
Download: ML20237L623 (59)
v • d • e


Text

{{#Wiki_filter:O' 0TG NAL 0 I h UN11ED STATES l NUCLEAR REGULATORY COMMISSION I i IN THE MATTER OF: DOCKET NO: _i INVESTIGATIVE INTERVIEW 4 { q l l .s / i LOCATION: RAMana TMN ~ PAGES: DATE-June 24, 1986 .. ) l ) Q ACE-FEDERAL REPORTERS, INC. OfficialReporters 444 North itol Street 8708200285 870819 N"' PDR ADOCK 05000445 @2W'N G PDR NATIONWIDE COVERACE ~==___:_=-.=_=--r,--:r-m------~~~---- - - ~ ~ - - - - -

1 1 v 1 MR.'MULLEY: The time is 2:46 p.m. and l ~ 2 the date is the 24th of June, 1986. We are in Room 171 3 of the Ramada Inn 4 Present is \\i 5 myself, George Mulley, Special 6 Assistant to the Directo1's Office of the Inspector and 1 l 7 Auditor, NRC, and the Court Reporter, Mrs. Banks. 8 We're here today to discuss with i 8 j information'~he has concerning Region Four's i 10 management of'the Comanche Peak Nuclear Power Plant. 11 12 being first duly sworn, made the following answers to 3 ~13 the fol. lowing questions: 14 EXAMINATION BY MR. MULLEY: a r. 15 Q before we get started, would i 16 you first briefly give us a resume of your experiences 8 17 at Region Four? I 18 A Yes. I came to Region Fout .ae P 20 (' I [' ' w'm-3 L...- \\ { ~.... 21 ^ ~ hith the' t where I i g l 22 am currently employed. 23 When I came to Region Four, Mr. John Collins 24 was the Regional Administ.'ator. Soon after I arrived 26 it became apparent that many of the projects underway

7 v 2 1 in Region Four were not progressing.well in the regulatory 2 These included the Comanche Peak project, Wolf sense. 3 Creek, Watcrford and River Bend. I 4 Within a few months after I began work 5 in Region Four, an NRC task force was formed to handle 1 j 6 the completion of inspections at the Waterford Plant. . ) 7 At about the same time, but shortly afterward, an NRC 8 wide effort began on the Comanche Peak Plant. Neither .i 9 of these' efforts were under the direction and control l 10 of Region Four, although there were personnel performing 11 in this group or in these groups. o 12 J' later on in that first year, r %) t 14 ~ ' located in Kansas, and(((spentmu6hofmytimeduring ~ s ni 15 the period of5 at the t s g 16 4 I believe personally'that the necessity f 17 for NRC task forces at Waterford and Comanche Peak were i I 18 k a direct result of the management resulting over a period e t 19 of time at these plants. That is, the Regional efforts Y l 20 were not sufficiently strong to manage the inspection j 21 program and resolve the issues in a' normal sense of l 22 the regional responsibilities. 23 Part of these problems stemmed from l 24 p, insuring that the licensee complied with the regulations, g 2 One of the strong elements in insuring compliance with 1 .1

1 3 w 1 the regulations is enforcement. I did'not consider that 2 Region Four-had a strong enforcement program,'and I believe 3 that'a lack of a strong enforcementLprogram has its roots k 4 in the' attitudes of the senior managers. 1 5 Can we go off the record a. minute? Because l 6 I.want to be sure I'm headicq where you want to head. 7 (Thereupon, there was a discussion off i 8 the record.) i I t THE WITNESS: In my view, the attitudes ) 10 that existed were in three or four par'ts. First of all 11 was the attitude of the senior management about their i 12 responsibility,es. That is, did the senior managers evidence 'l 13 strong commitment to insure conformance with the regulations %) 1 i 14 and take a tough attitude regarding enforcement? In ~ l is my view, they were not doing this. Thd econd attitude related to the. feeling l 16 8 about the utiliti$s themselves, and I believe that the 17 ? 3 L l 18 attitude about the utilities affected how middle and senior Ej 19 management conducted enforcement activities. If the senior i 2 m and middle managers felt good about the utility, friendly r i 21 towards the utility and otherwise had confidence in the l 22 utility, there was a tendency to not take strong. enforcement

  • s 23 attitudes, even though there may be violations occurring.

I 24 The third attitude was the attitude'towards ) 25 the, individual inspectors, and this fundamentally affected l lw 

- m

====_==1--- n= wen er = = ess n + -~ ~ ~ ~,~ _n - ~ ~

4 I their work. When sertior management and middle management 2 let it be known that they had good feelings about the 3 utility, then the production of notices of violation because 4 of violations of regulations were discouraged. All of 3 these attitudes come to bear on the individual inspectors ) 8 and how they perceive their job as guided by their senior 7 management. s Wher gTom Westerman 8 was the enforcement officer, Mr. Check was the deputy j i 10 regional administrator, and I:ric Johnson was the projects 11 branch chief. Mr. Johnson 12 to the regional administrator, Mr. Collins. 13 It was clear to me that all of the attitudes 14 that I mentioned were in operation in making the decisions 15 on whether to take enforcement action which started with 18 the notices of violation of conditions observed by 17 inspectors. 18 overlaying all of the attitudes in the 19 inspection observations or findings'was what I'll refer m. 1 20 to as the political c1'idhte, and that's the political 21 climatewithintheNRCandasgnfluencedbycongressional 22 perceptions which lead people to; develop strong or lenient 23 attitudes, depending upon how the political climate within 24 the NRC and outside the NRC viewed the licensee. And i 25 this view was not strictly limited to whether or not he l i ____.__n_+ 2r_ : r_?:- ~ t~'- n '~ ^ ' ' "

i 5 I was complying with the regulations. 2 I got personally involved in some of these 3 attitudes in at least one case where an inspector at the 4 Fort St. Vrain Plant, Mr. G.L. Plumlee told me that his 6 job was not to focus on inspections and not to get in a the way of the licensee. He had received this guidance 7 from his section chief, Mr. Ireland,.and branch chief, l j s Eric Johnson. Thinking that he had misunderstood the ] g guidance, I asked Mr. Plumlee to meet with me-in the presence 10 of Mr. Ireland and Mr. Johnson. In that' meeting I j-11 . instructed Mr. Plumlee that his primary job was to inspect 12 the licensee, and if his findings caused difficulty for 13 the licensee, that was a burden that the licensee had j i 14 to bear, and that his job was not to be concerned aboutwhether l g 18 the licensee would' find violations or negative inspection, 1 5 l l 16 reports unpalatable and unwelrome. His job, rather, was { l 17 to do a good inspection job and report the results. 1 l l 18 Because of the serious nature of the attitude r t up expressed by Mr. Plumlee and because I was convinced that i. I he gained that attitude,.from his management, that is, 20 l i 21 Mr. Ireland and Mr. Johnson', I documented that conversation g 4t. 22 as an instruction. Mr. Ireland and Mr. Johnson never 23 denied that they had, over the years, given Mr. Plumlee 24 a reason to have the attitude that he had.about his job 26 and how he should inspect and what priorit'ies he should

  • =p-*+**wno.---++e.

4..w ie. .=9.--w4,..med....en,. ... m st -es w

==%-+ .v.,-

6 4 1 place on his time. ~ 2 EXAMINATION BY MR. MULLEY: t 3 Q And you had earlier discussed the attitude 1 4 of senior and middle level management and with respect 5 to how they felt about a utility, and that this would 4 6 affect their enforcement posture. How did Region'Four q 7' -feel about TUGCO specifically? i 8 A In my view, Region Four ' felt that, and-I g I'm speaking now of Region Four management, felt that ] l 10 ' TUGCO was'either doing or trying to do a good job, and-11 that they were tremendously burdened by the1 attacks on 12 their project by intervenor groups in'that Region Four 's 13 did not wish to add to that burden. 14 0 Do you think this affected.the attitudes i l ~ 15 of the inspectors and of the enforcement people? In other a f 16 words, did you think they went out with the attitude.of f 17 trying to help TUGCO get their license? s 3 18 A I think that the lack of negative inspection i' 19 findings could be seen that-way. That the lack of l 0 2 20 negatives is a help, and I personally believe that the t i r t-I { 21 attitude of the Region Four management was not to do more l 3 work which would cause more problems for the utility. n This is difficult to. establish firmly, n 24 but when I looked at the facts, I found that the amount of inspection activities compared to the.need at.the 3 -me s e ._-_ _ -_-':_::? " !rm_-- R:~_:: ~~ nve = --+"'_'s~* r n w* m

  • m ~

-M~ 'm '# : ~ "~~" -

~ 8 7 7 1 plant was very small, and that for a considerable period i 2 of time, almost all the inspections at the Comanche Peak 3 Plant were done by the resident inspector with very little i 4 regional support. So there simply was a fact that the i 5 inspections weren't being done. Whether this arose in i 6 the minds of senior management because of personnel shortagen 7 because of other priorities or because of their attitude 8 about the utility would be difficult to segregate. g However, the same situation had occurred 10 over a period of time at the Waterford Plant, and it was 11 for these reasons that it was necessary to establish NRC 12 task forces at Waterford and at' Comanche Peak. The root is cause for the task forces were, in my view, the lack of 1 14 over the years detailed, precise inspection and l 15 identification of deficiencies and enforcement so the 2 f 16 corrective actions would be taken. We simply had a pile 8 17 of things accumulate on each.of those plants. 4 a 18 Q Region Four, would there be a higher priority h 19 than Comanche Peak that would justifiably divert, you i 2 20 know, inspectors away from Comanche Peak to some other I i 21 project? It would seem to me that Comanche Peak was t e l i 22 very important at that time. It still is. l 23 A Comanche Peak was important at that time 24 and still is, but as I say, 4, the rS% 25 situation was taken out of the hands of Region Four anf

=

= = ~

l ^ 8 i l P aced on a higher level of management within the NRC. 1 2 I can't tell you what the cause was, but;I can tell you 3 the fact was that sufficient inspection to-identify the 4 conditions, which obviously there had not occurred, and .) 5 that the observation of violations and notices of violations ) 6 which should have occurred didn't occur. I w'ould not 7 have thought that there were projects which had higher I 8 Priority-in Region Four other than the Arkansas Nuclear 9 Units which were operating plants, and therefore, required 10 inspection to insure that the operational conditions were 11 being met. 12 I think this higher priority at Arkansas 13 would have been desired simply because the operating plants 14 represented at the instant in time a greater risk to the i 15 public health and safety than did plants under 3 l 16 construction. This was, however, a different kind of 17 inspection. The inspection of operations at Arkansas i 2 3 18 was different than the inspection of operating, of plants 1 h 19 under construction. i l 20 Now, in addition to the Arkansas units, 5 21 there were the units at Omaha and at,.and the other unit l 22 in Nebraska were operating plants primarily covered by t u operational inspectors. The problem with the plants 24 under construction is that deficiencies.in construction .y would eventually come to light and be more difficult to z I i u. ,__._...m ,....,......,._..._,.m___,_,,_-..s..

9 I correct because of already completed construction. This 2 is different than operating plants where' deficiencies t 3 in operating people and operating procedures could be I 4 remedied without significant rewor) in si constructed plant. I 1 6 Nevertheless, Comanche Peak did not appear tome [. .. q g 8 t fpnRegtenFourtohavehad J 7 an aggressive inspection program f'or' a period of years. l 1. 8' I ha'd conversations with the form rl senior resident I 8 inspector, Mr. Robert Taylor, who told me that he had 1 10 repeatedly appealed for assistance from the Region in 11 conducting construction inspections, and that' these appepls 12 had not been r'esponded to. Th'e upshot of all this was 13 that the regional administrator had already given up 14 regaining control of inspection activities at Comanche l -) .i 15 Paak and at Waterford, and this was simply implemented 5 l 16 soon after I arrived. 17 Q How would, I guess when we're talking i 18 about regional management we're talking about Westerman i l t 18 and Check and Eric Johh' son. How would they pass on their ) e f 30 attitudes concerning specifically TUGC0 to the inspection, 5 21 ,the resident inepector to let.them know,4 you know, this I l Et is, we think TUGC0 does a pretty good job. They're being unfairlycriticizedbyintervening/grYups, therefore, 23 ( 24 let us help them along.- How would>that attitude get passed 25 along to the inspectors? ._.... ~ _ _ _

~ 10 1 v i i 1 A Well, first of all, the attitude was passed 2 on by lack of assistants to provide help to inspect the i 3 l 3 l plants. If you don't inspect, you will not find any i j 4 violations. 5 Secondly, one of the very favorite l 6 approaches to discourage inspectors in writing violations 7 and writing reports on those violations is to worry their 8 work product to death and question it to a great extreme. 9 i In dealing with the inspectors who worked 10 for me while I was in Region Four, I always conveyed to I 11 them the attitude that if it looked like a violation and l 12 smelled like a violation, then write it up as a violation 13 ll and let the utility defend itself against that violation. ] 14 If the utility was able to show that it was not actually '\\: ,j 15 in violation of the regulations, then I was perfectly t 4l 16 willing to retract the violation. o l l 17 The attitude that led to worrying the I f inspectors' report and the inspectors' notice of violation 18 g-19 to death simply meant that the inspector would be f 5 M discouraged from writing notices of violation because i, j 21 he had to jump through so many hoops to get it out. l

  • a a

l i 22 Whether or not that attitude and those actions of worrying 23 i the violations to death sprang from the attitude of wanting 24 to go easy on the utility or simply wanting to have an j 25 airtight court case before any notice of violation was -1 i ? ? i I ..,rn,----. n,.- e---,.~~~~ - ~ - - - ~ ~ - ~ ~ ~ ~ ~ ' ~ '

  • k

l 11 sl r i } "/ 1 issued would be difficult to tell. / ,5 2 In my own view, the attit deiof not j i 3 regulating violations was the strongest force. I had l v v { 4 a sufficient number of discussions with Westerman to 5 conclude that Mr. Westerman rea11y didn't believe in 6 enforcement. He didn't believe in enforenment as a means 1, 7 of achieving compliance with the regulations,' and so he l i,. a participated in worrying the paperwork,to the point that g less than the number of violations that could have been. \\ to written were actually written. 11 I veiwed the attitude of Mr. Check as' i 12 quite strongly anti-enforcement. Mr. Check on more than - 13 one occasion told me that utilities had been licensed 14 l by the NRC, had been found com'petent by the NRC, and that I l 5 15 we should be> extremely cautious in saying otherwise, l 16 l particularly in violations. So I considered Mr. Check I l 8 17 a very weak enforcement advocate. i e i l 1s In addition to that,~I believe that r l f 1, Mr. Check was greatly influenced by the political aspects = l I go' of any of the operations we conducted with the utilities r 1 i 21 or against them in terms of enforcement. In fact, I believe i i 22 that Mr. Collins, who was a radional administrator, was l 23 also very much swayed by the political environment within 24 the NRC and in conjunction with the licensee. 26 Q How did, how would Westerman go about 6 ewe-ween..,.po.g.%.we..<=.-.,, .c= + - eas==,eese-m-w,.v-e.=,,- e + - - > ue..- l m..i,+-

J.,. n q ,'(r=' -/ l.,., s . [7 .n. /.. 12 4 e 1 1 worrying inspection findingr? Would he confront the 2 inspectors head-on?. Just drop violations fr m the report? ( 3 How would he go about that? 4 A ile I was'there I had knowledge that ) 6 Mr. Westerman eve dropped a v'iolation rom a report from 6 one of'my inspecto He would have irect contact with 7 the inspectors for < e intended an correct purpose of' 8 (.beingsurethatthefoticeofvi ation was written clearly I t t. 8 and well-written with proper e ations against the { [\\ , regulations. That wa his p mary job. 10 4) i 11 In add tio to that, of course, he had 12 the job of keeping trac 2 the violations so that we 13 could see that violatio were answered and otherwise 14 responded to. I'm su e t at he had many conversations 15 with inspectors, an some of them got back to me, and ) 16 I can't remember e speci fics, where he would argue that 17 something reall wasn't a ' 'iolatien, and as I say, that is wasn't my att ude. If it looks sufficiently like a 18 violation I ould let the t tility' defend itself, rather than have

r. Westerman itef n'nd the utility on violation..

i J 21 I don't say that Mr. Westerman's l i 22 contri tions were all nega tive. He did call our attention -{ 25 to t need for greater pre ::ision in our language a number 24 of 'mes, and this was bene ficial. But overall, l Mr. Westerman's attitude wa s anti-enforcement. l l L ____CZ_E" I " ' ~ 7_' T__.:IT_* E ' ~~ T"""' ' '* ' "^~ ' ' ' ' ""~ ~ ";~'"'" ' ~ ~ ~ ~ " "~

I i 13 1 In addition to' direct contact with 2 inspectors, he interacted with section chiefs and branch 3 chiefs on the production of inspection reports and any 4 accompanying notices of violation. In this interaction 6 I was told a number of times t$at Westerman didn't think 6 that a violation was an appropriate vehicle to achieve 7 the corrected action. I can't recall any instance where 8 I agreed with tha't decision on his part. 9 Q How would he prefer to handle it? 10 A He would have preferred to handle it by 11 discussing the matter with the licensee and by having 12 any documented record be observations in the inspection l l 13 reports, rather than clear violations. 14 Q How would Mr. Westerman handle a disagreement I -i 15 between himself and an inspector? For example, if'he i g 16 didn't think something should be a violation, if he wanted { 17 to downgrade it to an unresolved item or romething like i 18 that? Do you have any knowledge of inspectors just r i g 19 agreeing with his call or how he handled 5that? e f 20 A I can't recall any,at the moment, and i 21 by and large I relied upon the people that worked for l 22 me to work through that process. But Mr. Westerman normally 23 would have interacted with the section chief or more likely 24 the branch chief, Mr. Johnson, to gain his acceptance 25 of Westerman's conclusions, and so you see, we have people ~1"_"_C__*'_1_______'"

l I 14 1 lined-up in a row and an inspector who wants to write 2 a violation, a section chief who may.have no strong feelings 3 one way or the other, and a branch chief attempting to 4 make a call based on his attitudes, as well as the facts 5 available to.him, and being in~fluenced by Mr. Westerman a who basically had an anti-enforcement' attitude, and in 7 someway that I couldn't testify to influenced by the a regional administrator and deputy regional administrator. 9 I'd'say at that time that, and I'm speaking l 10 now of the time frame when the relationships = J between regional administrator and the deputy regional 11 12 administrator,were poor. They simply.didn't like each other, and they did'n't share office responsibilities. is In fact, you might say there were at least two camps in 14 15 Region Four. That camp who, that didn't like Mr. Collins, and.that camp that was more dedicated to.doing their job-16 17 than deciding whether they liked him or not. That'didn't have anything to do with whether they did their job or 18 go not. so I forget the. exact data, but Mr. Martin 31 replaced Mr. Collins as regional administrator.. Free the enforcement viewpoint I c'nsidered this an improvement, se o as but my view on that was more influenced by what Mr. Martin 1 Se said than by what I observed. Mr. Martin repeatedly said in staff meetings and in briefings with the staff and 35 1 -~ j =_.= = _, - = =,-, _- ----_- ~_

9 -.. L :.:- I-15 g inte. actions with the staff that horse shit on enforcement. , to quote him, 2 "I am I am a strong enforcer. " 3 so he attempted to convey an attitude th {' And that.if it looked like a violati at I fully supported, 4 a violation'. on then write it up as 3 I don't believe that he was fully !13 g in this anymore than some other ma successful ~.e. ..r "' '-g the end product, not knowing that dnagers who simply saw 9 w

r. &

J and downgrading had occurred during thiiscouragem

. ;,D 3

p*] s process. { The one brightest spot in the low @-Q. 10 of management supervision was a gentle fid:., er levels i -D M'<.A Jaudon, whom I relied upon in a man named John 11 Il?;J,, be sure that the violations were w in unofficial capacity to It f@ t' justifiable severity level. r tten at the highest .ff' ' 3 k.x. ih,' 34 Mr. Jaudon had the training and abili $,jifi;y 33 to upgrade a violation to a high s

,,.. e.

ty dgr...- w. er level and upgrade an

f..

e gg unresolved item to a violation, and in thi -Qg,. 11 from most of the other people in R s sense he differed . gf,?. that I arrived. egion Four at the time gg Nfd he'C..' I don't believe, and I didn't ob i c that Mr. Jaudon's attitude was p jl"y),{;.1 serve 3X.i. ervasive in the c organization and overittps. period of ti s 4/ i gg I believe that the' attitude weak me I was there, Qi 'q.t s.<_ I*, f' WW.Q in' fluence of Eric Johnson and ened because of the o Fedl Check. t n,, g .O T .e o Q okay. Bow involved was Mr. Mart 1Das d e 1 A.'Jj ~4d. g ~7*. 9'

  • 6 a_--

m

16 on the short period of time that you were at the Region, 1 1 i he was regional administrator, how involved was he with t the actual working of inspectors, for example, at 3 a Comanche Peak? Did he have a feel for what was going 3 on at all? es 4 6 A I don't beleive that Mr. Martin had a .. ~. 'g 5. good feel for what was' going on at all. -

n...c.--_.\\

., 7 -' ' : f.-;. b

w. 2 :1..,%. ;7;.L-

\\ % '~~ has Il previously stated, the NRC efforts on k-3 ~~ 1 - A s Wolf Creek through the cosmiission decision for full-power g to licensing. When I returned to Region Four, Mr. Check 11 instructed me to pick up.i:1M5fSM0*/sM!2"~'#4'"'[ ~~- that I had been able to transfer to him while I was on { u i ~ 13 one of the first r things thad"_'_tV.4 n conjunction w'ltH Mr. Martin was to 14 'L start to regain control of the inspection efforts at 33 Comanche Peak, and for that purpose we established a task 3g force at Comanche Peak of numerous inspectors. 17 33 And.I'll back up a little bit and say q %.- a that wher., .. ~ ~~-'. c-I was told that the division was undermanned. and overworked, and...,. - ' that ,g go 1 .h .I there were numerous vacancies that simply'weren't being g 1/3 m filled. I believe that the correct number at that time gg was 16 vacancies in the division. s I 3: \\ af ter Oneofthefirstactionstha( I found out that the vendor program was being transferred 3 84$$ L _-owp e_,-;____L;_ w e w, .- -s m n+~ s--s m.

r 1' 17 to headquarters was to determine whether there were good 1 people in the. vendor progran branch who wanted to stay 3 in Arlington and whether those people were capable of 4 carrying reactor inspection responsibilities. 'one of i s the attributes that I looked for was their attitude about 1 e enforcement, particularly an attitude that I expressed J"-gl 7 as holding the licensee's feet to the fire on the e ra?J1ationsJ g Because of that and because of the ..; c.,.. r, backgroundofthepeopleang, q,.~.'j',-[.';'.with them, to .5 11 F. J ' 'I O Ian Barnes, Mr. Lee Ellershaw out of the m g..,.. . a _ _..:...._ l 13, vendor prograin because of' their very strong.comunitment i 18 to enforcement. In ' addition to that, and I will say 1 14 against a lot of advice

  • from Mr. check and Mr. Johnson f--,$"[9.

Mr. Shannon Phillips to stay with the j 33 g gs - organizat\\on. The advice for not keeping Mr. Phillips g 8 37 was based primarily on his performance at the south Texas Ie 33 project where he had identified a number of deficiencies 3 in the licensee's operation and'had participated with I . a s. 3 a special task group at South Texas which eventually led i a to rather momentous changes in the conduct of the South .o g -- I-g Texas project. All of this occurred , '. - [.. T but m. 3 I was made aware of all*these events and the advice that jfornotselectingMr.Phillipswasthatyou, se g couldn't trust Mr. Phillips to be part of the team. --.....a-p .mae.. ....mw+- + .,e e e.. ~n . ~. >

1 18 i 1 My own conclusion was that you could trust him to do his work, and,( ghimandsent him down to Comanche Peak to carry one of the main loads s 4 on the construction inspection activities. While he worked 7,.,n iv.'. ', t,J _.'1 concluded that he was doing a good job. 3-8 e I don't kno'w that I answered your question, s l 7 because I had to start way back with the people. i s Q Yes, I think you did. But you brought 's up another interesting point concerning Shannon Phillips l and the activities he was involved in in south Texas and to 11 how that carried over. some attitudes that were expressed u by Mr. Johnson. Do.you know 'of any repercussions that n Phillips suffered at Region Four as a result of the findings 14 that he, you know, participated in at South Texas other than, is you know, the advice not to keep him on, but during the 14 Periods of time that you were at the Region was there 17 l 23 any sort of campaign against Phillips? Was he, you know, 1 go blacklisted? 1 3 A I can o'nly say what I was able to k rsonally I i a observe. Again, reflecting that much of ay time was spent out.of town, I didn't see anytWing that I**could call a g strong blacklist or campaign, but certainly on the part a i of Westerman and Johnson and a few others, there was a se i continuing stream of comments about watching Mr. Phillips l 5 i e44 ,,,,a 4n v f* ? '"

1 i 19 l 1 and not trusting Mr. Phillips and watching your back with Mr. Phillips. Most o:" that I concluded.was based upo,n l 2 3 his performance at South Texas and his involvement with l 4 l Region Three personnel who did a special inspection on 6 South Texas and revealed many things that were apparent 1 i 6 to Mr. Phillips prior to.that, but hadn't been acted upon 1 7 by Region Four. So I think that the~re was some distrust, 8 some dislike and some apprehension about having a strong i i 8 willed, meticulous and capable person on the staff that j ( I 10 wasn't easily swayed to your point of view. 11 I regarded that as strengths not weakenesses. 12 Q You earlier spoke'about the political l 13 climate and how it affected Region Four management concerning 14 Comanche Peak and TUGCO. What was the political climate R 5 15 at the Region? l l 16 A Well, th'e climate, whether it's political O l 17 or not, was one of good personal relationships between i 4 18 top management and, top management at TUGCO and top i 18 [ management at the itsgion. I say good personal relations I 20 r in the sense that people always acted more than civilly. 5 21 'ihey acted friendly. They had a number of instances where p l 22 I would say that Mr.. Check and.others simply wished to 23 leave the utility alone to do its job, and to insure that 24 the NRC people didn't interfere with that job. 25 We even had, at least one instance that .a e ~ - + - - - we .w+_ .. ~.. - n

20 1 you're familiar with where there was a leaning over backward 2 to not get involved in something that could have been 3 the business of the NCR, particularly considering the 4 total climate on that project and all surrounding 5 circumstances. I think that politically the NRC Region I 6 Four management found it necessary, and I don't say it 7 was really necessary, but they found it necessary to choose 8 sides between TUGCO and the TUGCO adversary so that there 9 was a choosing up sides in at least the philosophical 10 sense and sometimes in the action sense between 4 11 interveners and TUGCO. i ) 12 Whereas I thought that if there were sides, i I 13 there were three sides. The NRC side, the utility side ) 14 and the interveners' side, and we simply didn't have to i 15 choose. This all gets evidenc'e,d in small ways and small 16 changes and attitudes which overall give a bigger picture, i 17 referring to people who alleged problems as alligators, i 18 not being really interested to determine what the problems ) i 19 are seen by the interveners. Referring to them and thinking 20 about them as just a pain, that has to be endured, I think 21 tended to place the regiona,l management on a side that i 22 they didn't need to be on. f 23 I remember at least one instance where 24 a former TUGCO employee wished to discuss the various 25 allegations that she had against TUGCO and Mr. Check was iL.'. ~ '

  • _

.-._? =- ^

1 1 21 1 given that assignment to go interview this person. He asked me to go 'with her, with him, and we spent a number 2 3 of hours at her home underst'anding and having described 4 to us these allegations. From that point onward, 4 s Mr. Check really didn't want anything to do with it, and 4 s the follow-ups were'left to'me, and even after some of th's follow-up was assigned tf__l."-.../..,I'k._~.h.. 's another 7 player in this game,',. ;.}-lj,.j -(.Q... wanted me to continue 8

._s x<y

{ p to follow that up. I'dsay,[ don'tkno'wwhythatwasexcept 10 11 to say that it seemed to me they had chosen up sides and ts they were in the enemy' camp anytime they were doing that. 13 But these are small indicators with the cumulative effect of,nothavingwhatMr.Markinwanted,averystrong 14 ta enforcement program, what he said he wanted. And all to of these things or many of these things, I should say, 8 11 occurred before he ever arrived on the scene. But there's I 1s a buildup of small actions'and attitudes and words and to actions regarding the inspection reports and notices of j m violations which have the omsalative effect of not i e i a encouraging the findings and write-up of violations. j u O so even though Mr. Martin, when he arrived 3 at the Region and talked about a strong enforcement posture, as you don't believe his actions or his involvement with m the enforcement at the Region evidenced that type of 1 .l 1 =- r

r v======

~

l 22 .i 3 attitude, then? g A I think he made good speeches and I think } he made, and he provided good policy, but he had so many g things to do that I would not have expected him to 4 l personally be sure that the lower levels were pushing g up notices of violations, nor would I have expected him . ~. e ( to do detail checks'on whether or not all the people in g the Region were following his guidance. I simply think he had too much to do in a short time to have expected it to be effective, because tho' situation had exis.ted to I ' 11 for such a long, time. With respect to any enforcement actions that I took Mr. Martin was fully supportive, u i j gg including civil penalties which I generated. That is, j i , I generated the notices of violations which led to the I 34 l civil penalties, and so he was supportive of those. l , a 16 I would say that there was only one instance where my judgment differed from his, on the ( g, timeliness of issuing a report which contained a violation, u And in that case he simply, delayed it for a variety of y g reasona, rather than issuing it in a more, w!iat I a considered to be more timely manner. I would say that Mr. Martin was. supportive of a strong enforcement policy. g Re just had not_been-able to achieve what he said he' wanted g 2.__,. y to achieve i p g Q Getting to a more specific area, if we g 4 .-. - - ~..

e 23 i could talk for a minute about, I don't know if this is 2 an accurate characterization, but the two different l 3 philosophies concerning the importance.of conducting 1 4 inspections of hardware versus the importance of quality I a assurance type inspections. g From talking to some people at the Region 7 it seems to me there are two different camps. Some people a seem to feel that really what's important is looking at p specific items.of hardware and making sure they've been l to constructed properly ~and some other people believe quality J 11 assurance is very important. Part of, you know, safety f 12 of a plant, and that-we should be spending a lot of time 33 with quality assurance. 14 Do you feel that either one of these two 1 15 played a lesser role at the. Region or did the Region l 16 emphasize one of the two more than the other, quality j S 17 assurance over hardware type' inspections? I a 18 A Well, I think that from the regional I g 19 viewpoint the emphasis seemed to be on hardware. I a ,g considered that to be a fundamental mistake. It is true i i 21 that if you've had an unreliable program over a period i [ 22 of years you don't have any choice but to inspect the 23 hardware to see if the correct hardware came about in 24 spite of theLprogram.. I did not see strong emphasis from1 g the leadership in the Region on quality assurance programs, e 3 4 -rm.ar< a rmie + mww wa pest-+ eea+ sr-4,* sge e e a :& =*

  • ~.-+ww.

+n-+

  • ww-

_ mea ._ y v_ _-as _

24 l 1 but some of this has to be looked at in what is truly 2 a mixed perspective. ) 3 From a regulatory viewpoint the regulators' 4 rely upon the utility to do the right job. They rely 5 on the utility to have good engineering, good organizations 1 e and good construction. And they rely on the utility to l 7 have good quality assurance programs which help insure 8 that what should be done is done. 1 9 It's a common phrase that you don't inspect .i l 10 quality in. You must put the quality in there during ) J l 11 all these processes which you are relying upon to work. j i 12, inspection can only tell you that your programs aren't i 13 working because the hardware is not right. I think that l l it's easier to inspect ' hardware than it is to inspect 14 15 a quality assurance program and reach conclusions on that, 16 and I think that in the past there must have been some t 17 emphasis on hardware rather than on the program yielding 18 the hardware. 3 From an NRC perspective, the man power 3D allocated to direct inspections was extremely small compared 21 to the items which could be inspected, so by and large 22 we never could have been expected to inspect more than 23 about one percent of th'e plant. Some inpsection was intended 24 to determine whether the program was working correctly l 25 to yield the right kind of hardware, and that's a good I I i

== ~

A I 25 1 check on the program, but the probability of uncovering ' I ~ 2 small defects in the program by direct hardware inspection ) ? l 3 was extremely small.- 4 At the same time, the probability of I 5 determining a pro (ram that's really gone awry through l a direct inspection of hardware is quite good. We would 7 expect to see that. We would expect to see pervasive l 8 hardware deficiencies because of pervasive breakdowns j g in quality assurance, pervesive breakdowns in engineering ) ) to and design and construction processes.- This is what you 11 would expect to see as a signal.. 12 But there was no way that the NRC could 13 inspect the plant to insure that all the components were 14 of quality. We simply had to rely upon the utility to j 15 do what they seid they were going to do in program and I l 16 hardware and to inspect to see that they were doing that. f 17 I think there is a general attitude that i 18 things can't be demanded to be perfect,.but certainly I, a we demanded at least reasonable assurance of public health e o and safety protection. c.So I think it's.. mixed, a mixed 20 r i 21 situation that we have. i l 22 You',ve got to inspect the program and ~ 23 you've got to look at the procedures and you've.got to 24 look at the record keeping and you've got to look at the 26 hardware, and in order to achieve an across-the-board ' Wp e s-a. - g ew p. ww a*=* N^ 4* **w a v e "='4ea"**-**n8't'*tes ..r**' r*M*-e+ "*st+*w q 6.s*+e.*rr-N" mw 98-wi

  • * " + > ^ ' ~
  • '~ * "

26 I conclusion that the utility is complying with all of its 2 cor-itments and complying with all of the Regulatory 3 requirements, you have to do it all. If you emphasize

1 4

ene versus the other, then you rely solely on the utility 6 to do a good job with no inspection or no good sampling 6 of its performance at all. 7 I don't think that Region Four could have 8 been considered as having a strong orientation to qual'ity ) 9 assurance programs from the programmatic viewpoint. Had i 10 they had such a strong orientation over the years, then Il the results later seen a.t South Texas and at Comanche, 12 , Peak and at Waterford never would have arisen. I3 Q So you, in your opinich, had Regi.on Four, 14 let's take Comanche Peak, had Region Four emphasized the ~ 15 quality assurance aspect of the inspection program that I l maybe some of the problems at Comanche Peak right now 16 17 may have been resolved at an earlier stage by the utility 18 having a better program set up, identified programs? Am 18 I getting that right? ,1 20 A Yes. 'Yes. And I believe that is 31 fundamentally true. I think about this as a principle 22 of leverage. The program is going to yield hardware based 23 on two things. The strength of the program and its 24 correctness and the capabilities of the construction 25 forces from the craft on up through the supervision. If [ m_l2.'.'_TZ.'_l'*T

  • Ti__"I_"_M__I_"*"f"ff-"_Z-_^_-__-'"T1"M_--'_1E-11PG-L1 M W'

-" * ' " ' ~ " * ~ ' '

27 I the program'for quality assurance is not strong, then r 2 any deficiencies which occur in the construction organization 3 l will simply be magnified. 4 At the same time, if you have a strong 6 I quality assurance program, then the tendencies of constructiontodoapoorjobisoverwhelmedbyagood 6 7 strong quality assurance program. 8 l But as I say, if you are, if you focus l 8 on and give priority to inspection of hardware, you must to realize that your' leverage is very, very small. You must 11 focus, you must give considerable focus to the program 12 and utilize inspections of hardward to insure that what 13 you think is being done in the program is actually showing 14 u;. in the field. It's more of a confirmation. 5 13 You want to be advised if you see bad 3 [ 16 l hardware and you want to have it recognized that it was ) o { l 17 a real foul-up in the program which yielded that. You 1 i f don't want to have bad hardware explained by an inadequate f 18 f [ 18 program, and so I think at Comanche Peak, TUGCO did not i i 20 r have a strong quality assurance program and the lack of I .j 21 a strong quality assurance program yielded a lot of hardware 7 l 22 that wasn't what was intended. And the Region didn't 23 remedy that sitution over a period of years. 24 Q So if Region Four had not conducted an 25 inspection of TUGCO's corporate QA program for the past -~_-,-- A__. ~

38 i 1 ten years, then the Region itself could be at fault, you l 2 feel, for some of these problems t' hat showed up in'the-3 field at this late date? l i 4 A Yeah. I think that.that would be a very i 5 severe deficiency on the part of the Region to have not d 1 conducted an inspection of Ehe quality assurance program e 7 and narrowed the effects of the field and taken corrective l l 8 action. I l l 9 I don't believe that the NRC ought to ll \\ 1 l 10 do the utility's job for them. I think if we're 11 culpable, we're 'cuplable against our own regulations and l 12 our own job descriptions and our own responsibilities. 13 The fact that we didn't do something which would have 14 corrected.a problem meant we didn't fulfill our obligations 15 to the public and to the taxpayers and to our own' oath 16 I of office, rather than that we didn't fulfill any obligations 17 to TUGCO. They were sufficiently staffed. They had 18 sufficient ability to hire good people and to pay good i 19 people so that even if the NRC never inspected them, they j 20 should have been expected to have a good program. 3. It's simply that if we didn't do a good l 1 22 job and we didn't fulfill our obligations, and I don't ) I n think that the utility can lay off on the NRC their own 24 sins. Certainly, we would have well represented the public 25 both in terms of health and safety and in terms of expense 1 1 i _______.___E

S 29 j I to the public and in terms of public welfare had Region l i 2 Four demanded and obtained better quality assu'rance from' ) 3 TUGCO. 4 Q Let me give you a hypothetical scenario. 1 8 If an inspector'during. inspection of a piece of h'ardware I I finds no problem with that specific piece of hardware ) 6 7 but does find a problem with the record keeping and QA e aspects, do you feel.that you would still have a valid 8 violation, even though that, you know, even though the 10 end result or specific piece of hardware is, the one looked at is fine, do you think that the violation involving, j 11 12 or the deficiency involving quality assurance' would be 18 a valid violation? 1 f l 34 A I certainly do. And a very important 1 j j 15 violation, because now you have good hardware, that ) I [ 16 happened in spite of an inadequate program. And by the I C i 17 way, you think, or you are convinced that you have good 1I 18 hardware in spite of the program, but I must say that i. 18 if the records which document'tbe hardware and all its [ 20 attributes and all its needs are deficient, you have 11 some inherent doubt about'whether what you see is what l 22 is actually there. i 28 Q On that one. specific you looked at? 24 A Even on that one specific thing, because 26 record keeping is important because it yields the pedigree a dse .a -an. wm, .n.,,n ,^..,., .qre. * <,+ee m e,e y s w.m

i 30 1 and in thoroughbred horses a pedigree is an important 2' thing, and care is taken in those, in nuclear plants, l l 3 if you don't have a certified material test report, for 4 example, and if you don't have a documented material content of a component as a pump or a, valve and you don't have 5 6 the quality assurance records that demonstrate that what 7 was done was what should have been done, then you're simply a relying upon surface observation on your part or even I g perhaps better, relying upon the operational experience j l 10 of the component, but all of these things go hand in hand j 4 11 and the quality assurance program is intended to help 12 insure that what is needed is built, and it is no f substitute for that program to simply do an inspection 13 i. 14 !! of the surface attributes of the component or of the whole it 15 I plant. } 16 By the same token, you cannot tell. l r 17 l whether a concrete wall six feet thick is well constructed 18 by looking at the surface of it. You must rely upon the ig proper placement of re-enforcing bar, the inspection of { 2f that re-encorcing bar,.the documentation that says it ~ 21 was put in accordance with design, the inspection of the 22 concrete that's poured. The samples that are taken to n insure that the picture is correct, and of the' proper 24 strength and all of these things go in so that when you're 26 through if you don't have those records and you don't 9 e _y7_ %...-y-._e-e &- t

  • N-.

1-*$- -"t E -N 4 ' -.****M

  • 9

~ ~ ~ ~ ~ ~ ~

j I 31 I have that program that yields those records, then you t a simply are relying upon the surface observations. 3 And at Comanche Peak there was a large 4 program to determine whether help determine whether what e 3 was below the surface was. what 4re thought was below the 1 4 ' surface on concrete. These were referred to as Schmidt i

k 7

Bammer tests, to simply determine or help determine if a we had gt,a strong concre'te, because you can only see i e the surface. l q, ,,[,[.y.[.atRegionFour,did to Q During 11 you ever have any occasion to discuss with'Shannon Phillips \\ is any concerns he may have with the way Regional Four management s j g3 was handling Comanche Peak? s I i l g4 A I can't recollect the details of any at gs the moment, but I visited Comanche Peak rather routinely, to and if Shannon Phillips were on site I generally had a 8 27 conversation with him. He did, from time to time, express l I a 33 to me concerns that he had about.what he was finding in I I his-inspection, and in those I just simply always encouraged y I g him to bring them forward, put them in' reports and write l a violations and so forth when they were due. p g a shannon Phillips to some degres was in g an awkward position, unfortunately. He was the senior a resident inspector for construction and he had certain m responsibilities at the same time because of the enormous e e ..,ye..

  • y.*

- -.m;o w M M** 'e "'Y.-*. ~ ' ' - - ' - ~ - ~ ^ -

32 1 1 I amount of work that had to be done, we put down there 2 a task force with other people on it doing i,n a catch-up 3 mode what needed to be done over a period of years. So 4 in order for Shannon Phillips to be fully effective in I 5 .O the best interest of the NRC, and of course, the Region 6 as they're charged, he would have had.to have close working 7 relationships and good interactions with all the other a people who were part of the team. I think that from time 8 to time he didn't feel a part of that full team. 10 The process which was set in motion in 11 the summer of 1985, simply hadn't progressed to the point l 12 that I would'have said something significant has to be l 13 changed. We always encounter, in dealing with people, 14 l personal preferences, personal emphasis and personal likes l l 15 and dislikes, but during the time,that I was there when l 16 l we had this group going I didn't observe that there was I 17 a condition which needed any significant correction. 18 I do think that Mr. Phillips would have 19 had and probably express'd to me, I don't recollect the e l 2/A 20 specific circumstances n'ow, concern about whether we were 21 giving Comanche Peak a real good shakeout based upon things 22 that he would have perceived in people's attitude. I 23 don't think we had enough factual evidence to say one 24 way or the other that we were going to reach the end of 25 the road and do a solid job in the late summer of 1985; e e m.__ .II ~._..U_^ )..Y ' I "I" ~ ~ - -

l I 33 g and into the early fall I simply didn't have enough evidence.l upon the operat,ional inspectors I g 3 to do their job, the resident inspector in charge of 4 construction to do his job and to work closely with all 3 the other people involved in th$' task force to be sure 4 that the composite, we did 'tihe correct NRC job. [1 i 7 I would not have been surprised if ] 1 subsequent events yielded some disagreements between-people e and perhaps caused some significant differences of opinion. Parbicularlybecauseofthecastofcharactersthatwere go i 11 involved. I say, if my memory were sufficiently prompted, recollect particular things that Shannon Phillips said ga \\ \\ 33 to me sometime. They just don't occur to me at this 14 moment, but if you have any that would help me, I'd be gg pleased to go ahead and deal with them. g Q I have one instanc's here that I'll discuss 8 39 in a little bit. Did you ever have any occasion to witness I t l g any confrontations, for lack of a better word, between e 1, l Mr. Westerman and Mr..Phillips concerning disagreements-g ~ .s., over inspection reports or.maybe even involving go [ g Mr. Johnson, involving what 1should be in an inspection g ..w g g report? Whetherafindingwas},,validfinding,anything g like that? 3 A I simply don't recall at the moment, but's I'm trying to go back a couple of years, almost a couple y G ,%=sw, w oo g wey ,y_

===yv-'

  • w

~_w a*- - - + * '

  • ___________---l----___

i 34 of years now'in my memory, and I may have. I just don't 1 t recall. 3 0 okay. Let me ask you a more detailed 4 question and that concerns the NRC Forn 766 which, if 5 you'll recall is, I guess computer input data form that's a prepared after inspections to show certain inspection =; ,V 7 procedures and modules and whether the work was done on a that procedure during the inspection report.. 1 s Do you recall, did you aave involvement g at all with this program? tj A Well, yes, because..;/'. inspectors were .g l 12 required to provide inputi to that.- The intended result \\ u\\ from the people who prescribe that program was to be able i to capture the data on inspection hours and to keep track 24 i 1 g of modules that were executed. i

,7- '[~

1s . 0%,, n. shortly (,.,_, .. _..s _ _ :. /_ _ n .2 gt found that program to be highly unreliable. I didP t believe the information that was in there, and my a l ~. y disbelief was vindicated b at Wolf Creek. l At Wol' preek I thougSt the data on 3 f j r 5 his'toricalinspectionsthatwasint$atsystem,wasin m 1 _ _ c, - - r that system that uses 766's was so poor tha a s s t L-an inspector from Region Two named Kenneth Jennison and g h he did a hand sort and data accumulation on the total file on Wolf Creek to determine from inspection reports a +e b i ._[_#__ _I__ ___[.. ____I' -Y_*- Y'* _'I" EI ' -' ' ' ' ' ~

g 35 I t what was inspected, what module was executed, how much 2 inspection time was spent and so forth. And hs 3 accumulated that' jonWolfCreeksolelybecauseI 4 found the system in place was a shambles, strictly i s unreliable. ~ 4 Q What would hause the unreliability of J' 7 something that would seem to be so straightforward where, l e I know, from the way I understand the system to be set l up you have an inspector who doas an inspection. He then s i prepares a 766 form which outlines 'what he just did in to ! 11 the inspection, and then that~ form is put into the system. Do you have any indication as to why this system was 13 \\ s 33 unreliable? l I i4 A In my view we had some major contributors e g gg to that. The first starts at the point that you started e it with, and that's the input of the inspector. The system gg '8 37 results that I looked at for Wolf Creek indicated l I a inspections done in the 766 system which the inspection is I, go report didn't support. Simply there was a discrepancy between what was on th's form and whht was just filed in g a i 33 the inspection report. I think that there's a variety I i g a of reasons for that. Carelessness is one, and that's a an unimportant aspect. 2 don't th hk it was a big 34 contributor. 3 The second is that there was an overall i d ____

i 1 n 36 l I attitude that if you can think of something that would 2 have justified your saying that you've done something, 3 then mark it off, even though you didn't put anything l 4 to justify that conclusion in the inspection report. It's, 1 5 I looked at the reactor vessel as I was walking by. That f 6 must fulfill the obligations under this module, but I 7 don't put in my inspection report that I looked at the 0 reactor vessel as I was walking by, because that really 8 isn't an inspection. And this is an example I just dreamed to up to illustrate what I mean by the desire to fulfill 11 the module obligations separately from fulfilling the 1 12 inspection obligations. l 13 ) And when I say that, I mean the module l l I i 14 obligations as relate to the record keeping. 15 Second problem, of course, was correct i l input into the system by the people that took the data 16 i 17 from the 766 forms and put them into the system, and then 18 the fact that the whole system was maintained by the 19 administrative organization to keep it up to date and there were always enormous difficulties in getting data 21 out, and I shouldn't say enormous. There were more than 22 we thought were appropriate difficulties in getting data 23 out and doing sorts and so forth. But I would say that 24 by and large the largest contributor to discrepancies 25 between act'ual inspections and what's in the 766 was O + +-

\\, 37 I I 1 a tendency to, call something an inspection in fulfilling 8 the requirements of the module which really weren't. 8 Q Now, the way the system was set up, did 4 you get credit for doing a pogtion,of an inspection module 2 8 .a. or. procedure, there should ha;ee been some documentation i s 1 8 on the inspection report. Is that true? t,[. T J A Yes, that's true, and that's my view. ] 8' If you did sufficient.;enough, a sufficient antou' t of work n i 8 to fulfill the requirements of the module you,should have U l' written at least a few sentences in the inspection report 1 I i 11 that says you did it. \\ Q Or at least to acknowledge the fact that I i 18 you looked at it? I 14 ' A Yes. I don't work on that calibration, 18 you know. You either did it or you didn't do it. l .e weeevy.M., 38 Q So I guess the situation, 5 ,,at Wolf {

c..

17 Creek has been duplicated at Comanche Peak where we've 18 g had examples of the 766, shows certain inspection ] y procedures going from 10 percent to 100 percent complete and given credit to an ' Inspection 41 sport, we go back to a the inspection report tha[ claissi p have done 90 percent i 1 8 l 9. 88 of inspection procedures, not oneL W rd in that inspection 88 report that shows anything was done'at all. That, to 88 me, is inappropriate. Would you agree to that? A That, to me, is inappropria+.e, and that's e 9 i 5 en, n...~,.n, ...~.-m -- ~ - ~>>~~y~.;*-* -t -*~v~~'**'"' ""~v

l; l l. 38 why I found 'the 766 to be an unreliable indicato,r of the 1 l I 2 inspections that had been done at Wolf Creek and why I l~ __ _f,,, p. 3 told the person that Jim O'Riley loaned ,see what 4 the inspection report says, we'll rely on them to tell s us.what was done. 1 4 02 So far as your study of Wolf Creek, then, l ~ q-7 what was written down is what counted? If it wasn't written a down, it didn't count? t e A That's correct'. Q to j You feel that attitude is pretty much 11 the. prevailing or the way it should be? 12 A\\ I don't think that attitude prevails, but';,I do think that's the way it should be. la 14 Q Right. And if a person goes back to the 1 3 NRC and IE Manuala,, you think that all procedures would le support that sort of attitude? 17 A Yes. is Q Getting back to Region Four's attitude a concerning Comanche Peak, during one of my interviews t. 3 of a Region Four inspector the individual outlined for

r..

..\\ as an incident that he recalled involving you and['__ 31 ___"i.' ^~ '.~ i' i ~' g at the time,. attending a meeting involving 5. cable tray hangers.and also at the meeting was a se Mr. Westerman, and apparently Mr. Westerman had said that th4re was nothing wrong at Comanche Peak and what was 3 4 f e 4 I E__ _ I. E _~_2. _.I__'_

I I l 39 I I reported to me, you told Mr. Westerman that as long as n' 8

  1. yere the Wou didn'.t want to hear j

8 \\ anybody at Region Four ever say again that there was notning 4 wrong with the comanche Peak and that this person who l y e I interviewed said that you h4d heard this continually 8 from Region Four personnel inspectors and supervisors 3 T or whoever, you'just sat in a meeting and heard Mr. Counsel, \\'8 w]* w[.- who was the head of TUGCo at that clase [,. 1 - ey were 8 goingtodoathreemilliondollarreworkinUnkt2and I he didn't know how much' it wa's going to do in Unit 1, I i u l that for stone and Webster to ge back and do a complete I 18 C/aluation of all piping design and hanger work in both i \\ s i 18 ugits, and that for somebody in Region Four to say there's 14 nothing wrong with Comanche Peak, all this was lud'icrous. 3 ~ A I recall an instance, I can't give you a M the date or time when Mr. Westerman said that, but U Mr. Westerman was not alone. Mr. Collins expressed the f f 18 s'ame attitude when(-- . ;', l I sat --.u. _._ t... 8 I in.onmeetingswhereaRegionFourteamsaid7"Tiiisplant looks fine. Why is it still not licensed?" And that wasbasedontheirinspecthonobservations. 81 s l 3 Itwouldbedidficulttome,forasto say why inspectors or regional c.anagement had that attitude, 84 but they did have a lot of input from people that, their f i observations were valid and reliable.. I personally heard j ^6 ~ 5 .,.. =...-.- -,.-,-. = _ - - -

40 j i g Region Three team say that based upon everything they'd 2 done, that! the plant looked good., It looked better than 3 many that they had seen and so forth. And I believe thos.e ] 4 kinds of. signals tended to affect the nilddle management 5 and top management attitudes. 6 As I've already said, the inepection results 7 aren't always extremely reliable indic'ators of the true j g situation, because the amount of things, the number of g things inspected is small compared to the total. We think 10 we've done a good job, but if we inspect one percent of l the plant, and that's across the board, one percent of ) 11 12 the concrete, one percent of the structural steel, one l 13 percent of the primal-system, piping and so on and so l 14 forth, so the utility has hundreds of times as much l 4 l inspection going into the plant as the NRC dees, and this 15 16 is all controlled by the quality assurance program, 17 including training of personnel, the qualifications of 18 personnel, the documentation and al; aspects of doing l l gg their job. i 1 20 That's why the program in quality assurance, 21 just from an. inspection viewpoint, is an extremely g important program, because they magnify our efforts or g their efforts are way beyond our capabilities, and if 24 they do it right, then we can have a much higher level l 25 of confidence than we could have based on our own ~ 4 o D4 ,4 .w. w,..,...%. y.._m. >+~.w-* c a'*__.- = --_._m_- _.2 1 ~

41 1 observations. 2 So yes, Mr. Counsel said, "We've gone 3 out and we've hired hundreds of people to come out and 4 inspect, and we're finding thing that need correction g and we're finding things th'at d 'r's unsur's about, and e we have a large program to'try to correct this." And-7 I didn't see why Region Four should be saying that the 8 Plant is all right and there's no problem if even the e utility couldn't say that. I don't believe we ought to ) get out ahead of the utility, telling him he didn't have go I 11 a problem when he was saying he did. But his is an g3 attitude. -\\ It's;not an unusual attitude 3o think 33 ,1 1 14 that the difficulties that a plant is encountering are 7 n ~. s~. gg all political. I've seen it ' '/;. ' ',, 4[.], It's la a blatant untruth. If the problems weren't there, there i 8 17 won't be any problem. 14 they weren't hardware problems, l 33 record keeping problems, quality assurance problems, then 1 theutilitycouldstandupandsay,}BereitwhatI've y ,r a done and this proves that I've done it right and here 32 are my people and their qualifications and here are my i g a records, and you can look at ther,.* And then you don't have to raise the question of whether something is right. a 3e Ycu'11 see a record that's a reliable record that a something was done. If you can't see that, then you 9 f r -.-mis. r.. = + + m.- e,.,or.- i p.< ., = <., e.

42 I don't have any right to beleive that the plant is built 2 in the way that it was intended to be built.. 3 And so, I didn't think that attitude that 4 the plant was okay and that, things were all-political y; *t t 6 and tied up in inter'venors copcerns andyso forth was a 8 valid attitude at all. 7 This 14 not! to say' tilat some of these 8 processes aren't painful. Not to say that some of the 8 decisions and some of the statements made aren't ones to that we disagreed with. Simply to say, though, that we 11 weren't doing anythin<) that wasn't involved in the 12 regulations and we had to take the pain along.with the 13

joy, H

Q Is there a difference between a violation 15 and an' unresolved item? 16 A Yes. 17 Q What would the difference be? 18 A Well, a violation is something that you 18 contend to a regulatiog that says something has to be 'O done und that it wasn't'done. That's a violation, and 21 you can cite chapter and ver'sm. j 22 An unresolved. iM in its. proper context 88 is an ! tem upon which more information is needed in order N to determine whether it's a violation or not. An' 25 unresolved item is not an item'that we don't know whether I -)

1 43 1 it's a violation or not. It's not simply that. It's 8 an item that we need more information on it and someone's a got the action. Either NRC has got the action to get 4 the'informationortheutilityinastheactiontosupply the information, and upon receipt, of the information a ] 5 re r ~- \\ +. 4 determination will be sede..

l. _.

4 7 There was, and I'll say was, prior to 1 i l 8 Bob Martin some tend'ency to call a violation an unresolved ll 8 item. And upon the production of further information 10 to call the unresolved item resolved because now more I 11 information is provided. That's incorrect. The correct \\ + 12 thing is that you get the aMitional information and \\ i i 18 additionalinformationwilljtellyouwhetherornotia I ) 14 violation has occurred. e 18 But it's a trick, it's a trick to not le call a violation a violation. Mr. Martin was very clear i l 17 and very explicit on what is an unresolved item and what 3 18 1 is a violation, and they're not the same. And you can't j 18 i i write a violation' as an unresolved ihasi and disposition O 88 ~ g it as not a violation when it actually'is. 4 f We tried to practice, I believe in the ~.~ ,. n ) l 8 -,9 the principle that if it's & I ~ ~' time that; c.....,.. j 8 violation it's a violation, and if it is an unresolved 88 item, there's more information due and then we'll make i 8 the call when we've got more information. I don't 6 =

44 w we were entirely successful in that. Mr. Martin 3 s .s 3 reenforced that concept strongly. At the time he 3 hadn't reached the goal yet. I 4 Q Eow capable were unresolved items tracked'/ 5 think dnresolfed items were tracked s A I 4 s quite well. Probably not' in what I,would refer to as J~- the most timely way because of work' load,. personnel shortages 7 4 s and so forth. So when I say they were tracked, it was i e our practice to give a number to an unresolved item just i like we give a number to the open item and just as we to l 11 give a number to the violation so that we could track But, and this is the o\\ 13 them. ne of tho' consequences of \\ the sin of calling a violatiod,an unresolved item. 13 I 14 A violation re'uires a tim ly response q is and timely closure by the NRC. An unresolved item doesn't. is Calling the violation .: unresolved item can permit it 37 to remain in limbo for an extended period of time until somebody gets around to it or opens up the book and says, ta " Hey, this unresolved item bas been around a long tiPe. 33 i

  • . f; e

+ l 3 Let's go do it." l m So one of the sins of misnaming a violation a l s an unresolved itou is like the kimely c6rrective action. 3 The potential is now, and now you depend on the individual to put an echasis on clos.ure of an unresolved item, es whereas it's more automatic if you call it by it's proper m ~< 1 l i l ____.Z_1__.__.z _ E ._..-...+,%,.. ..-r r. 3 r

l 45 1 'name, a violaticn. 2 Q So is it possible for unresolved items 3 to go away? 4 A It's possible for unresolved items to l l 3 he resolved by the obtaining of addition information and 6 never be called a violatich, ye's.' It's possible, I can't 7 think of an instance.where it occurred,,that an unresolved l 8 item hung around so long until' people got tired of it g and just called it resolved without really resolving it. i go Q This is another scenario, hypothetical. j 11 If, for example, Westerman and an inspector had a 12 disagreement over the interpretation of a code, let's J 13 say the code involved record keeping and records off the 14 site and you had an inspector and supervisor disagree i l 15 over what the code intended, would it be appropriate, 4 g 16 who would be the appropriate referee in a disagreement 3 17 like this? Who do you go to? Could you go to the people 0 i gg that wrote the code and try to get a resolution that way? e I 19 You know, call up the people in ANSI and say, " Listen, 20 this is what you say. This is what you require. What t i 21 do you mean?" Is this appropriate? A Well, I think it would be appropriate. l 22 I dontt think it's the appropriate first step, but in 23 24 your first step if Westerman was supervisor of the 25 inspector, then if the inspector disagrees his proper 5 -e. g g een gw 6 +1 t

  • 7 < 3 *ge se- ** * -

wee

    • W++

rw, re 4g 9, +;g-- tage.. w

1 1 46 role is to escalate it to a level above Mr. Westerman. 1 If he doesn't get it resolved there, then he should 2 escalate it up another level and he should get to the 3 regional administrator for a decision, and of course, 4 in MRC there are, there's a process for differing j a professionalopinionsWhichh"becaustait'ssotimeconsuming s C-u 7 and arduous it ought not to be' exercised at will, but s ought to be exercised when'really nieded. \\ { \\ \\ s I would have expected an appeal process ) to on at least two levels to get a resolution of the ) ( i 11 disagreement. And ha .'.'.'. f.\\of the appeal officials,

  • :.Cr* \\

a.. I certainly would have said 4f we don't, if the code really 1 \\ isn't clear, why don't we $sk the people that wrote it. j is s Yes, I think that's an appropriate step', but not the first l g4 ts one. Not the first step. I think the appeal official ought to do that unless there was an agreement to do it is I 17 at the lower level. If the supervisor and inspector l disagreed on the proper interpretation but they did agree 13 ) they would seek another interpretation and abide by it, is that would not give me any problem at Eli as long as the so 3 matter got resolved. m Q So in a case like this, do you 'hink it's a appropraite for some sort of an agreement to be reached between the inspector and supervisor in contrast to just a as saying forget it, it's not a violation, I'm taking it '6 %,,.m., .e wmfre-@'t' N "P - - - _ = _ _ _ - -

47 1 out, where the inspector going out and did the work feels strongly it is'a violation, do you think there should 2 3 be'some sort of accord reached? 4 A Yes. I think there should be an accord 6' reached or it should be escalated. I don't agree with 6 the philosophy or the implementation that the' supervisor. j y 7 ought to make the final' decision unless it's in an instance q 1 l l 8 where the relation says he will. You know, the easy things j g that come to mind are if a selecting official who was 1 1 l to selecting personnel to fill a job is the selecting official, l l 11 then he selects. It's his decision. If the inspector I l 12 who is at least as smart as the. supervisor sa.ys that he 13 thinks that code is being violated, and I would be very h 14 uncomfortable with the supervisor who says, "I don't care 1 l 16 what you say, because I know better than you do and I've i l 16 decided this now. Forget it." -{ { 17 I think that's at least poor style, and j 1; is certainly not something I consider in concert with the I l 13 NRC's general posture on these things. I mean if we can v l have appeal boards for licensing decisions, certainly so a j g2 we can appeal for first line of inspection of hardware, i 2 and I must say that I've been involved in a number of j 25 those open discussions and appeals and written papers 24 on it and things like that where we have inspectors say, j 26 "I don't think that this is right." And we have even 1 9 + ~ee pe,. g wp. e-g s,a, e, ave-s--

  • .9, j a.answ egee

,w p ..w -4 m p p-+pi m 9 g p e..u tem y -.- 5 s- -m.7 q

48 1 had instances where I wouldn't think the inspector did 2 a good enough job and we'd have a discussion,on that and 3 reenforce it. ~ 4 I always think it's my right to require 5 them to do more inspection. I don't feel it's my right [ 6 to tell them to de 1ess than they think they ought to. 7 do, absent some good fundamental reason. 8 Q' You feel the supervisors at the Region, e now we're talking about ai. the level that, you know, 10 Westerman and Eric Johnson and people like that, do you 11 feel they know what's going on in the field at 12 Comanche Peak? 13 A If there's any weakness I can personally i 14 \\ identify for NRC supervisors, is that they don't know l 15 what's going on in the field because they don't get there 16 i often enougn. And the message is passed on to them or, 17 either intentionally or unintentionally filtered, and 18 there ara a lot of things that are difficult to describe l' i in words. The old cliche is a picture is worth a thousand i 3/B 20 i words is magnified by an on-site visit where you can see 21 what's being done and you can.see the conditions in the 22 l field which are very, very difficult to describe to a 23 person from time to time unless things are r9 ally bad i 24 and out of control, and I think that, I think that is 25 a generality. It's really a generality that most I l I l m.....-s e,

  • - +

'S'*

1 49 1 People who confine their workdays to swivel chairs don' t really know what's going on in the fiel.d. I think it's s a weakness that I recognized when i 1 = j q 4 and I took every opportunity I cculd to visit the plants i 8 and c312.around on the hardwa're with inspectors and shine l 4 e flashlights and measure things and insert gauges and, i 7 to see what we were really seeing and unscrew bolts and i t t s things like that where you simply'can't understand that e from a description, particularly a description that's' to constrained by time because you're so busy. I 11 So I would say by and large the regional \\ 33 management doesn't know what's happening in the field \\ i s unless they tpke the time to observe it firsthand. And ) 34 I think that that kind of attitude is certainly an attituds g that I see in commissioners. That's why you see g commissioners visiting power plants; Asselstine and others i I i 17 on inspections, so they could try to see. Now, they don't Ia s see the nitty-gritty. They see a lot more than they can i 33 in swivel chairs in Washington. I l f, ~....

f, ? ,

., ',, r, 7 ),did you have m O . :..u. a. 31 any' knowledge of any of the Region Four management asking to 5 l 3: go up to the site, especially one like Comanche Peak or some as of other sites that were being licensed and ask them to get se out all the closed and opek items and various,. you know,- 3 IP Manual, Capter 25 inspection, ;'ust get out there l i.-we,a==+i

        • re++=~-=mq e

.w4 4--.o e w se i n +.. W - -- r, .,., im a& .m _-or..+--w- -e. v e-6

50 and get them all ciosed, in other words, to facilitate t 2 getting everything dene? 3 A Sure. Yoh. Always. 4 Q What type of attitude was this instruction a given in? Was it just get it done or was it actually. 'to go out there.and do the ins yctions and come back with, s 7 you know, their findings? Com; back with the findings. 3 In other words, just, you know, go out and look at these i things, just get it done or actually go out and do the e so inspection, validly do this inspection? I gg A I never teard that much specificity put onit,butIhaveheardmany, times,\\ 23 said go out there \\ 18 and c1ose those open items. Close thoce unresolved items. I Close those inspection findings and y h !e done. I guess 14 what was intended depends upon the sys h s and this hearer is both, but I think you're dealing with a mixed situation is 17 there. I know t Wolf Creek we had hundreds

u. m _ a u

of items, maybe thousands of items that I think about it to follow up on and close, and we sply recognised, e j our wh' ole team, that we,couldn't do that with a pencil. m We had to do that with inspection,, so we demanded resources m from all over the country that said in order to close a this item we have to do certain things. We don't simply a f sit down and write our name on a piece of paper. as a so our job was to get out there and close, i I S O___.___ II I $_'5_ ___ I ' I _. t

  1. ^"*'_.,I

'~

4 51 1 disposition and otherwise take care of those matters that J 3 needed taking care of before we could say the plant was I 3 ready to license, and I thought we did it in the way that 4 it should be done and everyone on the team understood i i 4 s what we meant by go out there and close those items. ] e ( s Inspect. Do what's necessary, justify, do it right. t There's no doubt in my mind there were a some players on the stage that meant get it done if'you o can get it done right. If you can't get it done right, M do it anyway. Yeah, I think there are some of those on at that stage. co you think that\\att[itude 'is proper as Q i i .considering Comanche Peak, just go loutj sud get it done I 13 14 whether it's done right or wrong? -\\' i a 'M i is A I don't know at this time. When

.2.:,..: \\\\ -

,(~. '...,_._._ )with it, it was. a little too early to tell what ...w.. / 14 8 17 the real attitude was. I will say that I observed the t* 1s NRC investing an enormous number of resources in'that I a effort, and that would tell as that wg, expected to do L *

  • t.-

s se the right job and not to pencil whip the; situation. But 1 i at that's kind of almost empirical today. You can't get l se inside the people's mind on it. <./ s. ..,5 . I',5,Q". .g re as you ever aware, did you ever y ek up any indications that 3 Region Four consultants out at Comanche Peak had been ~ e S ep. m e g eaew e ne r , i g e' 2." -l" P

i l 52 1 told to, had been steered away from finding quality 2 assurance issues and had been steered toward quality j 3 control hardware type problems that were very easy to 4 fix? Did you ever pick up anything like that? l l 5 A I can' t recollect any at the moment, but as J 6 they say, I'm trying to get back into the memory bank of 7 all those instances. There's no doubt that people coming in ! t j l 8 and consultants coming in were given emphasis to look at i l 9 hardware. I think there was a perception at that time 10 that the quality assurance program, no matter how*much it l 11 was inspected, might not 5'ield sufficient results to make 12 the plants licensable, so there was certainly an attitude t t l 13 that was in Mr. Collins' mind and some of the things he said 14 that said we really, it's the hardware on it there that 15 counts and we have to go out there, therefore, and* look l 16 at the harduare. But as I've said earlier, there's ( 17 weaknesses in that, because your ability to look at the { i 16 hardware is on the surface. l l la We did have some consultants that focused I i i 20 on hardware, whether it was concrete testing or hangers f 21 or electrical installations and so forth. I don't recollect 22 an instance where the consultant thought he ought to look 23 at the program which led to the hardware as opposed to 24 hardware and was told don' t do that. I j ust don' t l recol' ei:t one. 25 l r i I y 1 r a I J -n.w.m. ..e-r < :w w.e..ee e.we n r ~.-+ - - m<v,- ~ * ~ - ~ ~ ~ " * + = * * ~ ~ ' * ' ~~ ' ' - - - - - - ^ -

53 1 o Do you feel that the Region provides adequate train'ing to their inspectors to go and look at 2 quality assurance and procedures, and manual, Chapter 25, i a 4 twelve type inspections, you know, the quality assurance ~ s type thing, do you feel like the Region inspectors are e trained sufficiently to go out and do these type of -f .g. 7 inspections? 8 A I think that training was'.an historical 3 area of weakness in Region Four. Mr. Martin started on to a rather disciplined program to improve training that i 11 Pe:sonally involved himself in it, because he saw that I N 13 same weakness. And so he did something about'it at the \\ ts top where it could be done. \\ s e s I 14 I would say that there was not emphasis on looking at the programmatic quality assurance in training.. as, le 80*e People that, because of their experience and because-3 17 of their prior training, and that's why I mentioned Ia is previously Mr. Barnes and Mr. Ellershaw and others that I he knew had that ability and that understanding of 33 f '~prograntic matters to assist. ""'M ~~ -, 5 se 'y ~;\\ L i_, - i n . to bring that strength to the division, aid'the~y"azu g l 3 that. g It was a weakness across the board. The training, good cross training is okay as long so you can, se g afford it. I never thought that many of the inspectors 4 1 9 .p,..%.. -yr** ,wew A*- T N* v /Y '" ~ ~ _ _ _ _ _ - _ _ _ - - - - +

q 54 who were hardware crianted had much training in quality r casurance aspects. -{ This is kind of a, during Q h 4t ,- !iidid you think that the inspectors w o w= l,.. ', f,,,,9. '

c.. ;..,. 2. pilcut and found just the, you know, small hardware problems
... * / +,.. )

' ? i, l that could be easily fixed, 4:e you think these are the o ...x "'*lt guys _that got rewarded and got ahead in the Region?* 1 don't know if I can answer that very l A We didn't make very many organizational changes {, well. [- ,'( We brought in':. Y "'}kwho came l '. 1; '-'.*'t~.,.,:- Mr. Jaudon had been promoted. p- .g. from outside the Region. Mr. Lawrence Martin was \\. .i 1 by the time that - q, g made a section chief before, shortly befora he left thpre, It's -l And I better not bay shortly. ~ left the Region. s really not shortly, after I recollect the time scale. l a None of those individuals were people that I thought found is i the easy-to-fix problems necessarily. 17 If we're talking about promotions from is grade to grade but not from position of inspector to o

  • I

,..,l position of supervi.sor, ._e ..a.a. 2_ l G would say that if there were instances of that they'weren't a obvious they occurred because of that. 1' D Well, why don't we go off MR. MULLEY: O the record a minute. l 36 i (Thereupon, there was a discussion off 1 D 6 e ( e enw -e,* 69.e, e, p.nw - messace=er r e %, ep eos==.3 e* 7. g=r .ma* g2s7.e e M -reeat.'r a %e=s'_e***-("*'>**- tiP' .N1r'**e

55 1 the record.) l 2 EXAMINATION BY MR. MULLEY: f 3 Q Do you have anything you would like to 4 add'to this interview or any statement by way of conclusion j 4 6 'that you would like to make?, 6 A Well, I think I've said a lot of things 7 and it might be worthwhile to say something in summary a about what we've been talking about. g We have in' Region Four organization a 10 number of personalities and their relationships with.'each '1 11 other and their way of thinking, and'many times these -j 12 are, these ways of thinking are similar.and they support l .j 13 each other, which tends.to frustrate the checks and j i 14 balances so that the. merits of the checks and balances .] I l 18 are simply overcome by the attitudes and the personal I g 16 relationships. f 17 I would consider that Mr. Westerman and I; is Mr. Johnson and Mr. Check are of like mind so that an I g, appeal is not likely to be heard strictly on its merits. I They'll back each other up. I think that close relationship g l 3 21 between Mr. Check and Mr. Johnson tends to frustrate any i g g appeals, make them rejected out of hand rather than on g the merits. Maybe an a'ctitude of, " Hey, I wan;. to' listen 24 to this, if you can't work 'it out with thena I. don't want m to listen to it.' I can see that occurring and you have i l i i -w.. ..3 .,~.~ fe~ e 4 =-~,,w-- .r m.p -y.,.,,, w pg w,,,.-... .r,,,, .y.

j 56 1 level after level lined up with the same mind, set in 2 the mind. It isn't based on the merits It's just based ] \\ 3 on supporting the organization up and down. The appeal ) I 4 process and checks and balances simply aren't offered, ) l 5 and I think in the current situation in Region F,our I j e would expect that to be in place and to be operating. 7 Q And the mind, I'm getting back to 8 Comanche Peak and TUGCO, these three people would' share j 9 would be one of leaning towards-the utility. Do you feel 10 l that's true? i 11 A I think -- 12 Q (Interposing) Taking the utility's side? I I 13 A Yes. I think that's true, but each one 14 ' of those personalities.has its own mix that lead to that 15 end result. Whether Westerman has his raix because of l 1 16 his prior involvement and his basic attitude about 17 enforcement, and Mr. Johnson, his attitude about the q 18 utility is probably doing good work and there's more smoke 1g than there's fire, and Mr. Check about trusting the utility 20 and let's not get too deeply involved in the business 21 out there, all of these coming from different directions a come to the same re-enforcemen't attitude and the same 23 result that issues aren't considered and ventilated and 24 fully discussed and resolved on their merits. They're 26 done on another basis, and the attitudes and relationships 9 e =p s-4, s e- +er- +4

==t. ..see wee, r, q q 9 .-w-s

  • .-m

,~.-r-m+-,- +w-

l 57 1 I l t and clique. relationships that exist in all those people. 2 MR. MULLEY: Okay. Tha,nk you very much. i I 3 (Thereupon, the interview was concluded 4 at.5:10 p.m.) i 1 0 l 7 8 9 I 10 l I 11 12 1 .13 l 14 e .5 15 I [ 16 0* 17 e I I l l 18 .I 3 19 i h 21 t 3 I n t t i N 94 .....,...._,,._,._......7.., y_ ,7... .,.q.;..yy,,....___.

ND PAGE NUMBER CERTIFICATE OF 0FFICIAi, REPORTER I e 1 'I .This is,t o co.tify that the attached ' proceedings before the UN; TIC STATES NUCI,IAR REGULATORY COMMISS:0N in the matter of: 1 NAME OF PROCEEDING: Comanche Peak f AN INVESTIGATIVE INTERVIEW OF: 4. { '.

'.' l - -

l \\ h.. 2 :.:.:..;, ~; -., .p ~ DOCKET No.: I ~

  • FIACE: Ramada Inn

\\ 1 I ( DATE: June 2,4, 1986 - ' 9 J. i were held as herein appears, and that this is the original - transcript 'thereof for the file of the United States disclear l Regulatory Commission. (siirt) As/I4 { (TYPED) Doroh D. Sanke 09 l Official Reporter i 'j Reporter's Affiliatica ( Smith Reportig Agency t j i 4 e .,,.._.._1., a _}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20237L623&oldid=3920714"